UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

Edward Goeckel 

807 Cedar St 

Owosso, MI 48867 

 Plaintiff, 

 

v. 

GC Services Limited Partnership 

c/o The Corporation Company, Registered 

Agent 

30600 Telegraph Road 

Bingham Farms, MI 48025 

 Defendant. 

Case No.: 

 

Judge: 

COMPLAINT FOR DAMAGES 

UNDER THE FAIR DEBT COLLECTION 

PRACTICES ACT AND OTHER 

EQUITABLE RELIEF

JURY DEMAND ENDORSED HEREIN 

 

JURISDICTION AND VENUE

1. Jurisdiction is founded on 28 U.S.C. §1331 pursuant to the Fair Debt Collection Practices 

Act (FDCPA), 15 U.S.C. §1692. Venue is proper because a substantial part of the events 

giving rise to this claim occurred in this judicial district. 

FACTS COMMON TO ALL COUNTS

2. Plaintiff is a “consumer” as defined by 15 U.S.C. §1692a(3). 

3. Plaintiff incurred a “debt” as defined by 15 U.S.C. §1692a(5). 

4. At the time of the communications referenced herein, Defendant either owned the debt or 

was retained by the owner to collect the debt. 

5. Defendant is a “debt collector” as defined by the FDCPA, 15 U.S.C. §1692a(6). 

6. Plaintiff filed this claim within the timeframe permitted under the FDCPA. 

7. On or around August 25, 2008, Defendant sent Plaintiff written notice of Plaintiff’s 

opportunity to dispute the validity of the debt pursuant to 15 U.S.C. 1692g. 

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8. On or around September 9, 2008, Plaintiff sent Defendant a letter via certified mail in which 

Plaintiff disputed the debt and requested verification of the debt. 

9. Defendant received Plaintiff’s letter on or around September 22, 2008. 

10. Despite receipt of Plaintiff’s letter, and without first verifying the debt, Defendant telephoned 

Plaintiff on or around September 25, 2008. 

11. Despite receipt of Plaintiff’s letter, and without first verifying the debt, Defendant telephoned 

Plaintiff on or around October 2, 2008. 

12. Despite receipt of Plaintiff’s letter, and without first verifying the debt, Defendant telephoned 

Plaintiff multiple times on or around October 3, 2008. 

13. Defendant damaged Plaintiff emotionally and mentally and caused Plaintiff substantial 

anxiety and stress. 

14. Defendant violated the FDCPA. 

COUNT ONE

Violation of the Fair Debt Collection Practices Act 

15. Plaintiff incorporates each of the preceding allegations as if specifically stated herein. 

16. Defendant violated 15 U.S.C. §1692c in that it communicated with Plaintiff notwithstanding 

its receipt of written cease and desist instructions. 

COUNT TWO

Violation of the Fair Debt Collection Practices Act 

17. Plaintiff incorporates each of the preceding allegations as if specifically stated herein. 

18. Defendant violated 15 U.S.C. §1692g by continuing its efforts to collect the debt without first 

validating the debt pursuant to Plaintiff’s written request. 

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JURY DEMAND

19. Plaintiff demands a trial by jury. 

PRAYER FOR RELIEF

20. Plaintiff prays for the following relief: 

a. Judgment against Defendant for actual damages, statutory damages, and costs and 

reasonable attorney’s fees pursuant to 15 U.S.C. §1692k. 

b. For such other legal and/or equitable relief as the Court deems appropriate. 

RESPECTFULLY SUBMITTED, 

 Legal Helpers, P.C. 

 Attorneys for Plaintiff 

 

 By: s/Timothy J. Sostrin

Timothy J. Sostrin 

233 S. Wacker, Suite 5150 

Chicago, IL 60606 

Telephone: 312-753-7576 

Fax: 312-822-1064 

Email: tjs@legalhelpers.com

 s/ with consent of Lori A. Leigh 

Lori A. Leigh 

17117 W. Nine Mile, Suite 1020 

Southfield, MI 48075 

Telephone: 866-339-1156 

Fax: 248-569-3874 

Email: lal@legalhelpers.com

Bar # P65423 (Local Counsel) 

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