IN THE UNITED STATES DISTRICT COURT FOR THE 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

GABRIEL BROWN and IVAN BROWN, ) Docket Number: 20 cv 4579 

Plaintiffs, ) 

 ) District Judge: Robert Dow, Jr. 

v. ) 

 ) Magistrate Judge: Jeffrey Cumming 

CACH, L.L.C., UNIFIN, INC., and ) 

SUBSCRIBER TO ) 

TELEPHONE NUMBER (515) 705-2053, ) 

 Defendants. ) 

PARTIES’ INITIAL JOINT STATUS REPORT

 Pursuant to this Honorable Court’s order (ECF 12), the parties respectfully submit their 

Initial Joint Status Report as follows: 

A. The Plaintiffs are represented by: 

 Paúl Camarena 

 500 So. Clinton, No. 132 

 Chicago, IL 60607 

 paulcamarena@paulcamarena.com 

 (312) 493-7494 

 Defendant CACH, LLC is represented by: 

 Nabil Foster Lindsey Conley 

 Barron & Newburger PC Hinshaw & Culbertson LLP 

 701 Main, No. 6369 151 North Franklin, No. 2500 

 Evanston, IL 60204 Chicago, IL 60606 

 nfoster@bn-lawyers.com lconley@hinshawlaw.com 

 (312) 767-5750 (312) 704-3000 

B. The basis for federal jurisdiction is 28 U.S.C. § 1331, because Counts 1, 4, and 5 arise 

under the laws of the United States. Another basis for federal jurisdiction is 28 U.S.C. § 

1367(a) because Counts 2 and 3 form part of the same controversy as the Counts that 

arise under the laws of the United States. Subject to Defendant CACH’s affirmative 

defenses, Defendant CACH is not challenging jurisdiction or venue. 

C. Plaintiff Brown, a debtor, asserts that the debtor’s counsel asked Defendant CACH’s debt 

collector to cease communicating with the debtor, and that Defendant CACH then 

switched debt collectors to evade a statutory prohibition on communicating with the 

debtor. Plaintiffs further allege that Defendant CACH’s new debt collector contacted 

Plaintiff, but refused to identify itself, in violation of the Fair Debt Collection Practices 

Case: 1:20-cv-04579 Document #: 18 Filed: 09/24/20 Page 1 of 3 PageID #:54
Act. 

D. Plaintiffs have not served Defendant Subscriber to Telephone number (515) 705-2053. 

Plaintiffs do not know this Defendant’s identify, but Plaintiffs asserts that this Defendant 

was an agent of Defendant CACH. 

E. & F 

 The principal factual and legal issues with respect to Defendant CACH are whether 

Defendant CACH switched debt collectors to evade a statutory prohibition on 

communicating with a debtor and whether such conduct would violate the Illinois 

Consumer Fraud and Deceptive Business Practices Act. 

 The principal factual and legal issues with respect to Defendant Subscriber to Telephone 

number (515) 705-2053 is whether this Defendant failed to identify itself and whether 

such conduct would violate the federal Fair Debt Collection Practices Act. 

 Another factual issue is whether the Plaintiff sustained any damage or injury. 

G. The Plaintiff demands a jury trial. 

H. The parties have not yet engaged in any discovery. Plaintiff proposes the following 

discovery deadline dates and Defendant’s counsel acknowledges these dates are 

acceptable: 

 Written discovery first issue date: 10/01/20; 

 Fact discovery completion date: 02/01/21; 

 Expert discovery completion: 03/01/21; 

 Dispositive motions due date: 04/01/21. 

I. Plaintiffs submit that the earliest date the parties would be ready for trial is 06/01/21 and 

that a trial would run for 1 to 2 days. Defendant’s counsel acknowledges this trial date 

and length of trial is acceptable. 

J. Plaintiffs consent to proceeding before a Magistrate Judge. Defendant CACH also 

consents to proceed before the Magistrate Judge. 

K. The Plaintiff has reached a settlement with one of the defendants, Unifin Inc. A notice of 

settlement with Unifin was filed with the Court and the parties are working on finalizing 

the settlement papers. A settlement discussion with CACH has started. No other 

settlement discussion has occurred. 

L. The parties do not request a settlement conference at this time. 

Case: 1:20-cv-04579 Document #: 18 Filed: 09/24/20 Page 2 of 3 PageID #:55
 Respectfully submitted, 

 Plaintiff’s, Gabriel Brown and Ivan Brown’s, Counsel 

 North & Sedgwick, L.L.C. 

by: /s/ Paúl Camarena .

 Paúl Camarena, Esq. 

 500 So. Clinton, No. 132 

 Chicago, IL 60607 

 (312) 493-7494 

 paulcamarena@paulcamarena.com 

Case: 1:20-cv-04579 Document #: 18 Filed: 09/24/20 Page 3 of 3 PageID #:56