IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION 

IN RE: Kristen Felcan ) Case No. 

 ) 

 ) 

 Plaintiff ) COMPLAINT 

 ) 

 ) Judge: 

v. ) 

 ) Magistrate Judge: 

 ) 

 ) 

) July Demand Requested

 ) 

 National Service Bureau ) 

18912 North Creek Parkway, Suite 205 ) 

Bothwell, WA 98011 ) 

Defendant ) 

______________________________________________________________________ 

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

follows: 

INTRODUCTION 

1. Plaintiff, Kristen Felcan, brings this action to secure redress from 

unlawful collection practices engaged in by Defendant, National 

Service Bureau (hereinafter “NSB”).; Plaintiff allege violation of the Fair 

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

(“FDCPA”).

2. The FDCPA broadly prohibits unfair or unconscionable collection 

methods, conduct which harasses or abuses any debtor, and any 

false, deceptive or misleading statements in connection with the 

collection of a debt. 15 U.S.C. Section 1692d, 1692e and 1692f. 

3. Under 15 U.S.C. Section 1692d(6), a Debt collector must give a 

meaningful disclosure of its identity. “Meaningful disclosure” means, 

according to all caselaw, identifying that the caller is a debt collector, 

revealing who the debt collector is, and stating that “this is an attempt 

to collect a debt and any information will be used for this purpose.” 

Case: 1:20-cv-03092 Document #: 1 Filed: 05/26/20 Page 1 of 4 PageID #:1
Hutton v. C.B. Accounts, Inc., No. 10-3052 2010 U.S. Dist. LEXIS 

77881, * 8 (N.D. Ill. Aug. 3, 2010) Pawelczak v. Nations Recovery 

Ctr., Inc. 11-cv-3700 (N.D. Ill., 2012). 

4. Under 15 U.S.C. Section 1692g(a), a Debt Collector, within five days of 

the initial communication in connection with the attempt to collect a 

debt, must advise the Consumer of his rights under 15 U.S.C. Section 

1692g(a). Janetos v. Fulton Friedman & Gullace, LLP, 825 F.3d 317, 

321 (7th Cir. 2016)

 JURISDICTION AND VENUE

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

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

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

this claim occurred in this District. 

PARTIES 

7. Plaintiff, Kristen Felcan (hereinafter “Plaintiff”) incurred an obligation to 

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

household uses (the “Debt”).

8. Plaintiff is a resident of the State of Illinois 

9. Defendant, NSB (“Defendant”), is an Washington business entity with 

an address of 18912 North Creek Parkway, Suite 205, Bothwell, WA 

98011 operating as a collection agency, and is a “debt collector” as 

the term is defined by 15 U.S.C. Section 1692a(6). 

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

NSB. 

11. At some point, the original creditor, transferred this debt to Defendant 

for debt collection. 

12. The type of debt being collected upon was for a student loan. 

Case: 1:20-cv-03092 Document #: 1 Filed: 05/26/20 Page 2 of 4 PageID #:2
ALLEGATIONS 

 

13. The Plaintiff allegedly incurred a financial obligation (the “Debt”) to an 

original creditor (the “Creditor”) for a consumer debt 

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

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

Debt. 

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

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

16. Between April 1, 2020 and May 22, 2020, Defendant left numerous 

voicemails for Plaintiff. 

17. Not one of these Voice Mails stated that “this is an attempt to collect a 

debt and any information will be used for that purpose.” 

18. By failing to give the information above clearly, and not stating it was 

an attempt to collect a debt, Defendant did not give meaningful 

disclosure of its identity and violated 15 U.S.C. Section 1692d(7). 

19. Moreover, Plaintiff never received any communication from Defendant 

advising her of her rights under 15 U.S.C. Section 1692g(a). 

Violations of the FDCPA

20. Defendant violated the FDCPA by not providing adequate disclosure 

as required under 15 U.S.C. Section 1692d(7). 

21. Defendant violated the FDCPA by not sending Plaintiff the initial 

disclosures, as required by 15 U.S.C. Section 1692g(a), within five 

days of the first communication in connection with the attempt to 

collect a debt. 

STANDING AND INJURY 

22. Plaintiff has suffered an injury in fact that is traceable to Defendant's 

conduct and that is likely to be redressed by a favorable decision in 

this matter. 

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23. Specifically, Plaintiff suffered a concrete informational injury as a result 

of Defendant's failure to provide truthful information in connection with 

its attempt to collect an alleged debt from Plaintiff.

24. The Plaintiff has suffered and continues to suffer actual damages as a 

result of the Defendant’s unlawful conduct.

25. As a direct consequence of the Defendant’s acts, practices and 

conduct, the Plaintiff suffered and continues to suffer from humiliation, 

anger, anxiety, and frustration. 

JURY DEMAND 

26. Plaintiff demands a trial by jury. 

PRAYER FOR RELIEF 

27. 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 

 

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