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UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

JAMIE L. CASTEN,

Plaintiff,

v.

MIRAMED REVENUE GROUP, LLC,

Defendant.

Case No. 1:20-cv-05089

COMPLAINT 

NOW COMES Plaintiff, JAMIE L. CASTEN, through undersigned counsel, complaining 

of Defendant, MIRAMED REVENUE GROUP, LLC, as follows: 

NATURE OF THE ACTION

1. This action is seeking redress for Defendant’s violation(s) of the Fair Debt 

Collection Practices Act (the “FDCPA”), 15 U.S.C. § 1692 et seq.

JURISDICTION AND VENUE

2. This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331.

3. Venue in this district is proper under 28 U.S.C. § 1391(b)(1).

PARTIES

4. JAMIE L. CASTEN (“Plaintiff”) is a natural person, over 18-years-of-age, who at 

all times relevant resided at 8818 Bunker Lane, Apartment 123, Crystal Lake, Illinois 60014.

5. Plaintiff is a “consumer” as defined by 15 U.S.C. § 1692a(3).

6. MIRAMED REVENUE GROUP, LLC, (“Defendant”) is a limited liability 

company organized and existing under the laws of the state of Illinois. 

7. Defendant maintains a principal place of business at 360 East 22nd Street, Lombard, 

Illinois 60148.

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8. Defendant is a “debt collector” as defined by 15 U.S.C. § 1692a(6).

9. Defendant uses instrumentalities of interstate commerce and the mail in its business 

– the principal purpose of which is the collection of debt owed or due or asserted to be owed or 

due another. 

FACTUAL ALLEGATIONS

10. Alexian Brothers Medical Group performed medical services on Plaintiff. 

11. The cost of the medical services was $162.00.

12. Plaintiff’s $162.00 account balance is a “debt” as defined by 15 U.S.C. § 1692a(5).

13. As result of financial hardship, Plaintiff was not able to make payment(s). 

14. Plaintiff’s $162.00 account balance – once unpaid – was referred for collection. 

15. Defendant mailed Plaintiff a letter, dated December 30, 2019 (the "Letter"), which 

stated:

NOTICE OF AMOUNT DUE

RE: ALEXIAN BROTHERS MEDICAL GROUP

STATEMENT DATE: December 30, 2019 AMOUNT DUE: $162.00

ACCOUNT NUMBER: [REDACTED] REFERENCE #: 29619415

***

This firm represents that creditor named above. Your account has been referred to this office for 

collection because the amount shown above is past due.

We request payment in full. If you cannot pay the amount due, but with to make payments on this 

overdue debt, please call this office with your proposal and we will discuss payment terms.

Unless you notify this office within 30 days after receiving this notice that you dispute the validity 

of this debt, or any portion thereof, this office will assume this debt is valid. If you notify this office 

in writing within 30 days from receiving this notice that you dispute the validity of this debt, or any 

portion thereof, this office will obtain verification of the debt or obtain a copy of a judgment, if one 

exists, and mail you a copy of such judgment or verification. If you request of this office in writing 

within 30 days after receiving this notice, this office will provide you with the name and address of 

the original creditor, if different from the current creditor.

Thank you,

MiraMed Revenue Group, LLC

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THIS COMMUNICATION IS FROM A DEBT COLLECTOR AND THIS IS AN 

ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED 

FOR THAT PURPOSE.

PLEASE INCLUDE YOUR REFERENCE NUMBER ON YOUR CHECK.

Mail All Written Notices, Including Bankruptcy and Dispute Notices, To: MiraMed Revenue 

Group, LLC 360 E 22nd St., Lombard, IL 60148. Please DO NOT Mail Payments to this 

Address

16. The Letter is a “communication” as defined by 15 U.S.C. § 1692a(2).

17. The Letter is the “initial written communication” as required by 15 U.S.C. § 1692g. 

18. The Letter stated: “RE: ALEXIAN BROTHERS MEDICAL GROUP.”

19. The Letter did not say whether Alexian Brothers Medical Group still owned the 

account in question or instead had sold the debt to another entity.

20. The Letter simply stated, “your account has been referred to this office for 

collection because the amount shown above is past due.” 

21. Further down, the Letter did say that Plaintiff could write to Defendant to find out 

if the original creditor was different from the current creditor.

22. This sentence raised the possibility that the debt could have been resold, but the 

Letter did not clarify who actually owned the debt.

23. The Letter did say that Plaintiff should address all future correspondence and 

payments concerning Plaintiff’s account to Defendant, which a recipient could reasonably 

understand as implying that Defendant itself was then the creditor.

24. The only addresses contained in the Letter was the P.O. box of Defendant in Carol 

Stream, Illinois and Defendant’s principal office address in Lombard, Illinois.

25. Finally, a postscript stated: "This communication is an attempt to collect a debt by 

a debt collector or consumer collection agency and any information obtained will be used for that 

purpose."

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DAMAGES

26. Congress enacted the FDCPA to rein in certain "evils" associated with debt 

collection," Bentrud v. Bowman, Heintz, Boscia & Vician, P.C., 794 F.3d 871, 874 (7th Cir. 2015), 

because existing legal remedies were, in its judgment, "inadequate to protect consumers." 15 

U.S.C. § 1692(b).

27. To address those practices, the FDCPA imposes a "rule against trickery." Beler v. 

Blatt, Hasenmiller, Leibsker & Moore, LLC, 480 F.3d 470, 473 (7th Cir. 2007); see also O'Rourke 

v. Palisades Acquisition XVI, LLC, 635 F.3d 938, 941 (7th Cir. 2011) (noting that the FDCPA's 

prohibitions "keep consumers from being intimidated or tricked by debt collectors").

28. The statute thus gives debtors a right to receive accurate information, which they 

can enforce against debt collectors by bringing suit under the FDCPA. See Hahn v. Triumph 

P'ships LLC, 557 F.3d 755, 757 (7th Cir. 2009) ("The [FDCPA] is designed to provide information 

that helps consumers to choose intelligently ... ."). 

29. The value of receiving truthful information about one's financial affairs—and the 

ill effects of receiving misleading information—may be hard to quantify, especially where, as here, 

the plaintiff did not act upon the misinformation.

30. But being misled in violation of an anti-trickery statute like the FDCPA is a 

concrete harm nevertheless. See Havens Realty Corp. v. Coleman, 455 U.S. 363, 373-74, 102 S. 

Ct. 1114, 71 L. Ed. 2d 214 (1982) (holding that a plaintiff "who has been the object of a 

misrepresentation made unlawful" by federal statute suffered an injury in fact and thus had Article 

III standing).

31. Although the Letter refers to Alexian Brothers Medical Group, the Letter fails to 

identify Plaintiff's current creditor. 

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32. Plaintiff was left unsure as to (and could not deduce from reading the Letter) what 

creditor Defendant was attempting to collect for. 

33. Concerned with having had her rights violated, Plaintiff was forced to retain 

counsel; therefore, expending time and incurring attorney’s fees to vindicate her rights. 

CLAIMS FOR RELIEF

COUNT I:

Fair Debt Collection Practices Act (15 U.S.C. § 1692 et seq.)

34. All Paragraphs of this Complaint are expressly adopted and incorporated herein as 

though fully set forth herein.

Violation(s) of 15 U.S.C. § 1692g

35. Section 1692g(a) provides:

(a) Within five days after the initial communication with a consumer in connection 

with the collection of any debt, a debt collector shall, unless the following 

information is contained in the initial communication or the consumer has paid the 

debt, send the consumer a written notice containing –

(1) the amount of the debt;

(2) the name of the creditor to whom the debt is owed;

(3) a statement that unless the consumer, within thirty days after receipt 

of the notice, disputes the validity of the debt, or any portion thereof, 

the debt will be assumed to be valid by the debt collector;

(4) a statement that if the consumer notifies the debt collector in writing 

within the thirty-day period that the debt or any portion thereof, is 

disputed, the debt collector will obtain verification of the debt or a 

copy of a judgment against the consumer and a copy of such 

verification or judgment against the consumer and a copy of such 

verification or judgment will be mailed to the consumer by the debt 

collector; and

(5) a statement that, upon the consumer’s written request within the 

thirty-day period, the debt collector will provide the consumer with

the name and address of the original creditor, if different from the 

current creditor.

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(emphasis added).

36. The FDCPA requires the collector of a consumer debt to send the consumer a 

written notice containing, among other information, "the name of the creditor to whom the debt is 

owed." § 1692g(a)(2).

37. Regardless of who then owned the debt, the question under the statute is whether 

the Letter identified the then-current creditor clearly enough that an unsophisticated consumer 

could identify it without guesswork. See Janetos v. Fulton Friedman & Gullace, LLP, 825 F.3d 

317, 321 (7th Cir. 2016).

38. "[The Seventh Circuit] has long interpreted § 1692g to require that the mandatory 

disclosures be made so that they would be clearly understood by sophisticated debtors." Steffek v. 

Client Servs., 948 F.3d 761, 764 (7th Cir. 2020).

39. This implied requirement of clarity extends to identification of the current creditor 

under § 1692g(a)(2). The mere presence of the correct name in the notice somewhere does not 

suffice. See Smith v. Simm Assocs., Inc., 926 F.3d 377, 381 (7th Cir. 2019) (explaining the § 

1692g(a)(2) "requires a debt collector to present information about the creditor and the debt in the 

manner the unsophisticated consumer can understand"); Janetos, 825 F.3d 321 ("When § 1692g(a) 

requires that a communication requires certain information, compliance demands more than 

simply including that information in some unintelligible form.")

40. The Letter simply did not identify Alexian Brothers Medical Group as the current 

creditor to whom the debt was owed; therefore violating 15 U.S.C. § 1692g(a)(2), which required 

Defendant to identify the current creditor clearly, without leaving the matter to guesswork.

41. Plaintiff may enforce the provisions of 15 U.S.C. § 1692g(a)(2) pursuant to section 

k of the FDCPA (15 U.S.C. § 1692k) which provides "any debt collector who fails to comply with 

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any provision of [the FDCPA] with respect to any person is liable to such person in an amount 

equal to the sum of -

(1) any actual damage sustained by such person as a result of such failure;

(2)

(A) in the case of any action by an individual, such additional damages 

as the court may allow, but not exceeding $1,000.00; or

(3) in the case of any successful action to enforce the foregoing liability, the 

costs of the action, together with reasonable attorney's fees as determined 

by the court. 

WHEREFORE, Plaintiff requests the following relief:

A. a finding that Defendant violated 15 U.S.C. § 1692g(a)(2);

B. an award of any actual damages sustained by Plaintiff as a result of Defendant’ 

violation(s);

C. an award of such additional damages, as the Court may allow, but not exceeding 

$1,000.00;

D. an award of costs of this action, together with reasonable attorney’s fees as 

determined by this Court; and

E. an award of such other relief as this Court deems just and proper.

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DEMAND FOR JURY TRIAL

Pursuant to Fed. R. Civ. P. 38(b), Plaintiff demands a trial by jury of any and all issues in 

this action so triable of right.

DATED: August 28, 2020 Respectfully submitted,

JAMIE L. CASTEN

By: /s/ Joseph S. Davidson

Joseph S. Davidson

LAW OFFICES OF JOSEPH P. DOYLE LLC

105 South Roselle Road

Suite 203

Schaumburg, Illinois 60193

+1 847-985-1100

jdavidson@fightbills.com

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