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TRINETTE G. KENT (State Bar No. 025180)

KENT LAW OFFICES

3219 E. Camelback Rd #588

Phoenix, AZ 85018

Telephone: (480) 247-9644

Facsimile: (480) 717-4781

E-mail: tkent@kentlawpc.com

Of Counsel to:

Credit Repair Lawyers of America

22142 West Nine Mile Road

Southfield, MI 48033

Telephone: (248) 353-2882

Facsimile: (248) 353-4840

Attorneys for Plaintiff,

Jennifer Collins

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

Jennifer Collins,

Plaintiff,

vs.

Phoenix Financial Services, LLC dba

Indiana Resolution Group, LLC,

a foreign L.L.C.,

Defendant.

Case No.: 

COMPLAINT

JURY TRIAL DEMAND

Case 2:17-cv-04439-SPL Document 1 Filed 11/30/17 Page 1 of 5
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NOW COMES THE PLAINTIFF, JENNIFER COLLINS, BY AND 

THROUGH COUNSEL, TRINETTE G. KENT, and for her Complaint against the 

Defendant, pleads as follows:

JURISDICTION

1. This court has jurisdiction under the Fair Debt Collection Practices Act 

(“FDCPA”), 15 U.S.C. §1692k(d) and 28 U.S.C. §§ 1331, 1337.

VENUE

2. The transactions and occurrences which give rise to this action occurred in the 

City of Phoenix, Maricopa County, Arizona.

3. Venue is proper in the District of Arizona, Phoenix Division. 

PARTIES

4. Plaintiff is a natural person residing in Phoenix, Maricopa County, Arizona.

5. Defendant is Phoenix Financial Services, LLC dba Indiana Resolution Group, 

LLC, which conducts business in the State of Arizona.

GENERAL ALLEGATIONS

6. Defendant is attempting to collect a consumer debt allegedly owed by Plaintiff

to Harrison Medical Center in the amount of $3,547.75 (“alleged Debt”).

7. Mrs. Collins does not owe the alleged Debt as neither she nor anyone in her 

immediate family has received services at Harrison Medical Center.

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8. On or about July 11, 2017, Mrs. Collins received a letter from Defendant 

attempting to collect the alleged Debt.

9. On September 25, 2017, Mrs. Collins obtained her credit files and noticed the 

alleged Debt reporting on her credit report.

10.Mrs. Collins suffered pecuniary and emotional damages as a result of 

Defendant’s actions.

 COUNT I-VIOLATION OF

THE FAIR DEBT COLLECTION PRACTICES ACT

11.Plaintiff reincorporates the preceding allegations by reference.

12.At all relevant times, Defendant, in the ordinary course of its business, regularly 

engaged in the practice of collecting debts on behalf of other individuals or 

entities.

13.Plaintiff is a "consumer" for purposes of the FDCPA, and the account at issue in 

this case is a consumer debt.

14.Defendant is a "debt collector" under the Fair Debt Collection Practices Act 

("FDCPA"), 15 U.S.C. §1692a(6).

15.Defendant's foregoing acts in attempting to collect this alleged debt violated the 

following provisions of the FDCPA:

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a. 15 U.S.C. §1692e(2)(a) by misrepresenting the character, amount, or 

legal status of any debt. Defendant misrepresented the alleged Debt by 

trying to collect a debt that Plaintiff does not owe.

b. 15 U.S.C. §1692e(8) by communicating or threatening to communicate to 

any person credit information which is known or which should be known 

to be false, including the failure to communicate that a disputed debt is 

disputed. Defendant violated this provision by reporting the alleged Debt 

that does not belong to Plaintiff.

c. 15 U.S.C. §1692e(10) by using false representations or deceptive means 

to collect any debt. Defendant violated this provision by misrepresenting 

that Plaintiff owed a debt that she did not owe.

d. 15 U.S.C. §1692f(1) by collecting any amount not permitted by law. 

Defendant violated this provision by collecting a debt that does not 

belong to Plaintiff.

16.Plaintiff has suffered economic, emotional, general, and statutory damages as a 

result of these violations of the FDCPA.

WHEREFORE, PLAINTIFF PRAYS that this court grant her a judgment 

against Defendant for actual damages, costs, interest, and attorneys’ fees. 

DEMAND FOR JUDGMENT RELIEF

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Accordingly, Plaintiff requests that the Court grant her the following relief against 

the Defendant:

a. Actual damages;

b. Statutory damages; and

c. Statutory costs and attorneys’ fees.

JURY DEMAND

Plaintiff hereby demand a trial by Jury. 

DATED: November 27, 2017 

KENT LAW OFFICES

By: /s/ Trinette G. Kent 

Trinette G. Kent 

Attorneys for Plaintiff,

Jennifer Collins

Case 2:17-cv-04439-SPL Document 1 Filed 11/30/17 Page 5 of 5