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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ADRIEANNE AMOS,

Plaintiff,

-v.-

TORRES CREDIT SERVICES, INC.,

Defendant.

__________________________

COMPLAINT AND JURY DEMAND

NOW COMES THE PLAINTIFF, ADRIEANNE AMOS, THROUGH COUNSEL, 

BRIAN J. OLSZEWKI, and for her Complaint against the Defendant, pleads as follows:

JURISDICTION

1. This is an action for damages, brought against a debt collector for violating the Fair Debt 

Collection Practices Act at 15 U.S.C. § 1692 et seq. ("FDCPA").

VENUE

2. The transactions and occurrences which give rise to this action occurred in Cook County, 

Illinois. 

3. Venue is proper in the Northern District of Illinois.

PARTIES

4. Plaintiff is a natural person residing in Rolling Meadows, Cook County, Illinois.

5. The Defendant to this lawsuit is Torres Credit Services, Inc., which is a Pennsylvania

corporation that conducts business in the State of Illinois.

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GENERAL ALLEGATIONS

6. Defendant is attempting to collect a consumer type debt in the amount of $556.00 allegedly 

owed by Plaintiff to Commonwealth Edison Company (“the Alleged Debt”).

7. On October 24, 2019, Plaintiff obtained her Trans Union credit disclosure and noticed 

Defendant reporting the Alleged Debt.

8. On or about December 23, 2019, Plaintiff submitted a letter to Defendant disputing the 

Alleged Debt.

9. On February 16, 2020, Plaintiff obtained her Trans Union credit disclosure which showed 

Defendant failed or refused to flag the Alleged Debt as disputed, in violation of the 

FDCPA.

10. In the credit reporting industry, data furnishers, such as the Defendant, communicate 

electronically with the credit bureaus.

11. Defendant had more than ample time to instruct Trans Union to flag its trade line as 

Disputed.

12. Defendant’s inaction to have its trade line on Plaintiff’s credit report flagged as disputed 

was either negligent or willful.

13. Plaintiff suffered pecuniary and emotional damages as a result of Defendant’s actions. Her 

credit report continues to be damaged due to the Defendant’s failure to properly report the 

associated trade line.

COUNT I – VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT

14. Plaintiff reincorporates the preceding allegations by reference.

15. 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.

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16. Plaintiff is a "consumer" for purposes of the FDCPA and the account at issue in this case 

is a consumer debt.

17. Defendant is a "debt collector" under the Fair Debt Collection Practices Act ("FDCPA"), 

15 U.S.C. §1692a(6).

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

provisions of the FDCPA:

a. 15 U.S.C. §1692e by reporting credit information which is known to be false, 

including failure to communicate that a disputed debt is disputed. 

19. To date, and as a direct and proximate cause of the Defendant’s failure to honor its statutory 

obligations under the FDCPA, the Plaintiff has continued to suffer from a degraded credit 

report and credit score. 

20. Plaintiff has suffered economic, emotional, general and statutory damages as a result of 

these violations of the FDCPA.

WHEREFORE, PLAINTIFF PRAYS THAT THIS HONORABLE COURT grant her a 

judgment against Defendant Torres Credit Services, Inc. for actual damages, statutory damages,

costs, interest, and attorneys' fees.

JURY DEMAND

Plaintiff hereby demands a trial by Jury.

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 Respectfully submitted.

/s/ Brian J. Olszewski

Brian J. Olszewski

Law Offices of Michael Lee Tinaglia, Ltd.

444 N. Northwest Hwy., Ste. 350

Park Ridge, IL 60068

Telephone: (847) 692-0421

Fax: (847) 685-8440

E-mail: bolszewski@tinaglialaw.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,

Adrieanne Amos

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