IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION 

IN RE: Teresa Velez ) Case No. 

 ) 

 ) 

 Plaintiff ) COMPLAINT 

 ) 

 ) Judge: 

 ) 

 ) Magistrate: 

v. ) July Demand Requested

 ) 

 State Collection Service, Inc. ) 

 2509 S. Stoughton Road ) 

Madison, WI 53716 ) 

Defendant ) 

 ) 

______________________________________________________________________ 

Now comes Plaintiff, by and through his attorneys, and, for his Complaint alleges as 

follows: 

INTRODUCTION 

1. Plaintiff, Teresa Velez, brings this action to secure redress from 

unlawful collection practices engaged in by Defendant, State Collection 

Service, Inc (hereinafter “State”)., Plaintiff alleges violation of the Fair 

Debt Collection Practices Act, 15 U.S.C. Section 1692 et seq. 

(“FDCPA”). 

2. The FDCPA broadly prohibits any false, misleading or deceptive 

threats in connection with the collection of a debt 15 U.S.C. Section 

1692e 

 JURISDICTION AND VENUE

3. This court has jurisdiction pursuant to 28 U.S.C. Section 1331, 1337, 

1367; and 15 U.S.C. section 1692(d). 

4. Venue is proper because a substantial part of the events giving rise to 

this claim occurred in this District. 

Case: 1:20-cv-03309 Document #: 1 Filed: 06/04/20 Page 1 of 3 PageID #:1
PARTIES 

5. Plaintiff, Teresa Velez (hereinafter “Plaintiff”) incurred an obligation to 

pay money, the primary purpose of which was for personal, family, or 

household uses (the “Debt”). 

6. Plaintiff is a resident of the State of Illinois. 

7. Defendant, State (“Defendant”), is a Wisconsin business entity with an 

address of 2509 S. Stoughton Road, Madison, WI 53718 operating as 

a collection agency, and is a “debt collector” as the term is defined by 

15 U.S.C. Section 1692a(6). 

8. Unless otherwise stated herein, the term “Defendant” shall refer to 

State Collection Service, Inc.. 

9. At some point, the current creditor, assigned this debt to Defendant for 

debt collection. 

ALLEGATIONS 

10. The Plaintiff allegedly incurred a financial obligation in the approximate 

amount of $170 (the “Debt”) to at least two different creditors (the 

“Creditors”) 

11. The Debt was purchased, assigned or transferred to Defendant for 

collection, or Defendant was employed by the Creditor to collect to 

Debt. 

12. The Defendant attempted to collect the Debt and, as such, engaged in 

“communications” as defined in 15 U.S.C. Section 1692a(2). 

13. There is one account number for the debt described in paragraph 10. 

14. Plaintiff received a letter on January 22, 2020 stating that she owed 

$170. 

15. Then on March 10, 2020, Plaintiff received a collection letter from the 

same company saying that he owed $190 on the same account-a $20 

increase from the same debt; there is no explanation how the debt 

increased from one creditor. 

16. Defendant is adding fees and/or failing to state how this fee increased 

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for a static debt. 

VIOLATIONS OF THE FDCPA-15 U.S.C. SECTION 1692, et seq.

17. The Plaintiff incorporates by reference all of the above paragraphs of 

this Complaint as though fully stated herein. 

18. The Defendants’ conduct violated 15 U.S.C. Section 1692e in that the 

Defendant materially misled Plaintiff through this communication. 

19. Plaintiff is entitled to damages as a result of Defendants’ violations. 

JURY DEMAND 

20. Plaintiff demands a trial by jury. 

PRAYER FOR RELIEF 

21. Plaintiff demands the following relief: 

WHEREFORE, the Court should enter Judgment in favor of Plaintiff and 

against Defendant for: 

(1) Statutory damages; 

(2) Attorney fees, litigation expenses and costs of suit; and 

(3) Such other and further relief as the Court deems proper. 

Respectfully submitted, 

 /s/ John Carlin__________________ 

 John P. Carlin #6277222 

 Suburban Legal Group, P.C. 

 1305 Remington Rd., Ste. C 

 Schaumburg, IL 60173 

 jcarlin@suburbanlegalgroup.com

 Attorney for Plaintiff 

 

Case: 1:20-cv-03309 Document #: 1 Filed: 06/04/20 Page 3 of 3 PageID #:3