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David Ali Chami

SBN: 027585

Price Law Group, APC

1204 E. Baseline Road, Suite 102

Tempe, AZ 85283

Tel: (866) 881-2133

Fax: (866) 401-1457

David@pricelawgroup.com

Attorney for Plaintiff,

Jill Shover

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

TUCSON DIVISION

Jill Shover,

Plaintiff,

v.

National Credit Adjusters, LLC,

Defendant.

No. 

Plaintiff’s Complaint

Plaintiff, Jill Shover (“Plaintiff”), through her attorneys, Price Law Group, APC, alleges the 

following against Defendant, National Credit Adjusters, LLC (“Defendant”):

INTRODUCTION

1. Count I of Plaintiff’s Complaint is based on the Fair Debt Collection Practices Act, 15 

U.S.C. 1692 et seq. (“FDCPA”). 

JURISDICTION AND VENUE

1. This Court has jurisdiction under 28 U.S.C. §§1331, 1337, and 15 U.S.C. §1692k (FDCPA).

2. Venue and personal jurisdiction in this District are proper because Defendants do or transact 

business within this District, and a material portion of the events at issue occurred in this 

District.

Case 4:15-cv-00502-RM Document 1 Filed 10/21/15 Page 1 of 4
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PARTIES

1. Plaintiff is a natural person residing in Tucson, Pima County, Arizona.

2. Plaintiff is a consumer as that term is defined by 15 U.S.C. 1692a(3).

3. Plaintiff allegedly owes a debt as that term is defined by 15 U.S.C. 1692a(5).

4. Defendant is a debt collector as that term is defined by 15 U.S.C. 1692a(6).

5. Within the last year, Defendant attempted to collect a consumer debt from Plaintiff.

6. Defendant is a collection agency located in Hutchinson, Reno County, Kansas. 

7. Defendant is a business entity engaged in the collection of debt within the State of Kansas.

8. The principal purpose of Defendant’s business is the collection of debts allegedly owed to 

third parties. 

9. Defendant regularly collects, or attempts to collect, debts allegedly owed to third parties. 

10. During the course of its attempts to collect debts allegedly owed to third parties, Defendant 

sends to alleged debtors bills, statements, and/or other correspondence, via the mail and/or 

electronic mail, and initiates contact with alleged debtors via various means of 

telecommunication, such as by telephone and facsimile. 

11. Defendant acted through its agents, employees, officers, members, directors, heirs, 

successors, assigns, principals, trustees, sureties, subrogees, representatives, and insurers.

FACTUAL ALLEGATIONS

3. Defendant is attempting to collect an alleged consumer debt from Plaintiff.

4. The alleged debt owed arises from transactions for personal, family, and household 

purposes.

5. Within the last year, Defendant began calling Plaintiff on Plaintiff’s home telephone at 

520-579-89xx. 

6. Defendant calls Plaintiff from 704-264-1119, which is one of Defendant’s telephone 

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numbers. 

7. In or around January 14, 2015, Plaintiff answered one of Defendant’s calls and spoke with 

one of Defendant’s collectors. 

8. During the aforementioned conversation, Plaintiff requested written validation of the 

alleged debt.

9. During the aforementioned conversation, Plaintiff requested Defendant stop calling her. 

10. Despite Plaintiff’s request, Defendant continued to place collection calls to Plaintiff. 

11. To date, Plaintiff has not received anything in writing from Defendant validating the 

alleged debt.

COUNT I

DEFENDANT VIOLATED THE FAIR DEBT COLLECTION PRACTICES ACT

12. Defendant violated the FDCPA based on the following:

a. Defendant violated §1692d of the FDCPA by engaging in conduct that the natural 

consequences of which was to harass, oppress, and abuse Plaintiff in connection 

with the collection of an alleged debt, when Defendant continued to place collection 

calls to Plaintiff’s home telephone after Plaintiff requested Defendant stop calling 

her; 

b. Defendant violated §1692d(5) of the FDCPA by causing a telephone to ring 

repeatedly and continuously with the intent to annoy, abuse, and harass Plaintiff, 

when Defendant continued to place collection calls to Plaintiff’s home telephone 

after Plaintiff requested Defendant stop calling her; and

c. Defendant violated §1692g of the FDCPA by failing to send Plaintiff a written 

notice within five days after the initial communication with a consumer in 

collection with the collection of any debt, a written notice containing the amount of 

the debt, the name of the creditor to whom the debt is owed, a statement that the 

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debt will be assumed valid unless the consumer disputes the validity of the debt 

within thirty days, a statement that if the consumer notifies the debt collector in 

writing within thirty-days , the collector will obtain verification of the debt, and a 

statement that, upon a written request within the thirty day period, the collector will 

provide the consumer with the name and address of the original creditor. 

WHEREFORE, Plaintiff, JILL SHOVER, respectfully requests judgment be entered against 

Defendant, NATIONAL CREDIT ADJUSTERS, LLC, for the following:

13. Statutory damages of $1,000.00 pursuant to the Fair Debt Collection Practices Act, 15 

U.S.C. 1692k,

14. Costs and reasonable attorneys’ fees pursuant to the Fair Debt Collection Practices Act, 15 

U.S.C. 1692k 

15. Any other relief that this Honorable Court deems appropriate.

RESPECTFULLY SUBMITTED,

DATED: October 20, 2015

 

By: /s/David Ali Chami________________

 David Ali Chami 

 Price Law Group, APC

 Attorney for Plaintiff

 Jill Shover

Case 4:15-cv-00502-RM Document 1 Filed 10/21/15 Page 4 of 4