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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

Tracy Williams,

Plaintiff,

vs.

Medical Business Bureau, LLC, 

Defendant.

Case No.: 

COMPLAINT

JURY TRIAL DEMANDED

NOW COMES THE PLAINTIFF, TRACY WILLIAMS, BY AND THROUGH 

COUNSEL, BRIAN J. OLSZEWSKI, and for her Complaint against the Defendant, pleads as 

follows:

JURISDICTION

1. This court has jurisdiction under the Fair Debt Collection Practices Act (“FDCPA”), 15 

U.S.C. §1692k(d) and 28 U.S.C. §§1331,1337.

VENUE

2. The transactions and occurrences which give rise to this action occurred in DuPage

County, Illinois.

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

PARTIES

4. Plaintiff is a natural person residing in the village of Downers Grove, DuPage County, 

Illinois.

5. The Defendant to this lawsuit is Medical Business Bureau, LLC, which is a limited 

liability company that conducts business in the State of Illinois.

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GENERAL ALLEGATIONS

6. Defendant is attempting to collect two consumer type debts allegedly owed by Plaintiff to 

DuPage Emergency Physicians. The first debt is in the amount of $263.00 and the second 

debt is in the amount of $62.00 (“the alleged Debts”).

7. Plaintiff disputes the alleged Debts.

8. On November 5, 2019, Plaintiff obtained her Trans Union and Equifax credit disclosures

and noticed Defendant reporting the alleged Debts.

9. On or about December 23, 2019, Plaintiff sent Defendant a letter disputing the alleged 

Debts.

10. On February 21, 2020, Plaintiff obtained her Trans Union and Equifax credit disclosures, 

which showed that Defendant failed or refused to flag the accounts reflected by the 

alleged Debts as disputed, in violation of the FDCPA.

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

electronically with the credit bureaus.

12. Defendant had more than ample time to instruct Equifax and Trans Union to flag its trade 

lines as Disputed.

13. Defendant’s inaction to have its trade lines on Plaintiff’s credit reports flagged as 

disputed was either negligent or willful.

14. 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 lines.

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VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT

15. Plaintiff reincorporates the preceding allegations by reference.

16. 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.

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

is a consumer debt.

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

15 U.S.C. §1692a(6).

19. Defendant's foregoing acts in attempting to collect these alleged debts violated 15 U.S.C. 

§1692e(8) of FDCPA by communicating to any person credit information that is known 

to be false or should be known to be false, including failure to report a disputed debt as 

disputed.

20. As a direct and proximate cause of the Defendant’s violations of the FDCPA, Plaintiff 

has suffered economic, emotional, general, and statutory damages.

WHEREFORE, PLAINTIFF PRAYS that this Honorable Court grant her a judgment 

against Defendant for statutory damages, actual damages, costs, interest, and attorneys’ fees. 

JURY DEMAND

Plaintiff hereby demands a trial by Jury. 

 /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

 bolszewski@tinaglialaw.com 

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 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,

 Tracy Williams

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