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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,

Janine Hanson

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

Janine Hanson,

Plaintiff,

vs.

Northland Group, LLC,

a foreign limited liability company,

Defendant.

Case No.: 

COMPLAINT

JURY TRIAL DEMAND

Case 3:17-cv-08225-SPL Document 1 Filed 10/31/17 Page 1 of 6
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NOW COMES THE PLAINTIFF, JANINE HANSON, 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 Mayer, Yavapai County, Arizona.

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

PARTIES

4. Plaintiff is a natural person residing in Mayer, Yavapai County, Arizona.

5. The Defendant to this lawsuit is Northland Group, LLC, which conducts 

business in the State of Arizona. 

GENERAL ALLEGATIONS

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

Plaintiff to Capital One Auto Finance in the amount of $9,897.35 (“the alleged 

Debt”). 

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7. On or about July 26, 2017, Mrs. Hanson’s attorneys, Credit Repair Lawyers of 

America, sent Defendant a cease and desist letter because Defendant was 

excessively contacting her to collect the alleged Debt.

8. On or about August 23, 2017, Mrs. Hanson received a letter from Defendant, 

attempting to collect the alleged Debt. The letter was addressed to Janine 

Mcbrayer. Mcbrayer is Mrs. Hanson’s maiden name.

9. On or about September 18, 2017, Credit Repair Lawyers of America sent 

another cease and desist letter to Defendant, identifying Plaintiff as Janine 

Hanson f/k/a Janine Mcbrayer to clear up any confusion.

10.On or about September 26, 2017, Defendant sent Credit Repair Lawyers of 

America a letter, stating that it is unable to locate Mrs. Hanson in its system, 

and it will need the original creditor account number and Northland account 

number to locate her account.

11.On the same day, Defendant directly sent Mrs. Hanson a letter, attempting to 

collect the alleged Debt, in violation the FDCPA. 

12.Mrs. Hanson suffered pecuniary and emotional damages as a result of 

Defendant’s actions.

 COUNT I-VIOLATION OF

THE FAIR DEBT COLLECTION PRACTICES ACT

13.Plaintiff reincorporates the preceding allegations by reference.

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14.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.

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

this case is a consumer debt.

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

("FDCPA"), 15 U.S.C. §1692a(6).

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

following provisions of the FDCPA:

a. 15 U.S.C. §1692c(a)(2 )by communicating with a consumer if the debt 

collector knows the consumer is represented by an attorney. Defendant 

violated this provision of the FDCPA by sending a letter directly to 

Plaintiff, attempting to collect the alleged Debt after receiving notice that 

Plaintiff is represented by an attorney. 

b. 15 U.S.C. §1692c(c) by failing to cease communication with Plaintiff 

after Defendant received a cease and desist letter from Plaintiff’s 

attorney.

18.The Plaintiff has suffered economic, emotional, general, and statutory damages 

as a result of these violations of the FDCPA.

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WHEREFORE, PLAINTIFF PRAYS that this court grant her a judgment 

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

DEMAND FOR JUDGMENT RELIEF

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 demands a trial by Jury. 

DATED: October 31, 2017 

KENT LAW OFFICES

By: /s/ Trinette G. Kent 

Trinette G. Kent 

Attorneys for Plaintiff,

Janine Hanson 

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