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UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

CHARNJIT SINGH,

Plaintiff,

vs. Case No.: 

NCO FINANCIAL SYSTEMS, INC.,

Defendant.

_______________________________/

COMPLAINT

1. Plaintiff alleges violations of the Fair Debt Collection Practices Act, 15 U.S.C. 

1692 et seq. (“FDCPA”).

JURISDICTION

2. Jurisdiction of this Court arises under 28 U.S.C. § 1331, 1337, and pursuant to 15

U.S.C. § 1692 et seq. (“FDCPA”).

3. This action arises out of Defendant’s violation of the FDCPA, and out of the 

invasions of Plaintiff’s personal and financial privacy by this Defendant and its agents in its

illegal effort to collect a consumer debt from Plaintiff.

4. Venue is proper in this District because the act and transaction occurred here, 

Plaintiff resides here, and Defendant transacts business here.

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PARTIES

5. Plaintiff, CHARNJIT SINGH, is a natural person who resides in the City of 

Union, County of Union, State of New Jersey, and is a “consumer” as that term is defined by 15 

U.S.C. § 1692a(3).

6. Defendant NCO Financial Systems, Inc.., (hereinafter “Defendant NCO”) is a 

collection agency operating from an address of 507 Prudential Road, Horsham, Pennsylvania 

19044, and is a “debt collector” as that term is defined by 15 U.S.C. § 1692a(6).

7. Defendant NCO regularly uses the mail and telephone in a business the principal 

purpose of which is the collection of debts.

8. Defendant NCO regularly collects or attempts to collect debts for other parties.

9. Defendant NCO is a “debt collector” as defined in the FDCPA.

10. Defendant NCO was acting as a debt collector with respect to the collection of 

Plaintiff’s alleged debt. 

FACTUAL ALLEGATIONS

11. Plaintiff incurred a financial obligation that was primarily for personal, family or 

household purposes and is therefore a “debt” as that term is defined by 15 U.S.C. § 1692a(5).

12. Sometime thereafter, the debt was consigned, placed or otherwise transferred to 

Defendant for collection from this Plaintiff.

13. Defendant sought to collect from Plaintiff an alleged debt arising from 

transactions incurred for personal, family or household purposes.

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COLLECTION CALL

14. In or about March, 2011, Defendant NCO’s collector contacted Plaintiff by 

telephone in an effort to collect this debt, which was a “communication” in an attempt to collect 

a debt as that term is defined by 15 U.S.C. § 1692a(2). 

15. During this March, 2011 call, Defendant left a voice mail on Plaintiff’s answering 

machine, and failed to identify himself as a debt collector. 

SUMMARY

16. The above-described collection communication made to Plaintiff by Defendant 

NCO, and collection employees employed by Defendant NCO, was made in violation of 

numerous and multiple provisions of the FDCPA, including but not limited to 15 U.S.C. § 

1692(d)6, and 1692e(11).

17. During its collection communication, Defendant and the individual debt collector

employed by Defendant NCO failed to provide Plaintiff with the notice required by 15 U.S.C. § 

1692(d) 6, and 1692e(11), amongst others.

18. The above-detailed conduct by this Defendant of harassing Plaintiff in an effort to 

collect this debt was a violation of numerous and multiple provisions of the FDCPA, including 

but not limited to all of the above mentioned provisions of the FDCPA.

TRIAL BY JURY

19. Plaintiff is entitled to and hereby respectfully demands a trial by jury on all issues 

so triable. US Const. amend. 7. Fed.R.Civ.P. 38.

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CAUSES OF ACTION

COUNT 1

VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT

15 U.S.C. § 1692 et seq.

20. Plaintiff incorporates by reference all of the above paragraphs of this Complaint 

as though fully stated herein.

21. The foregoing act and omission of the Defendant and its agent constitutes

numerous and multiple violations of the FDCPA including, but not limited to, each and every 

one of the above-cited provisions of the FDCPA, 15 U.S.C. § 1692 et seq.

22. As a result of the Defendant’s violations of the FDCPA, Plaintiff is entitled to 

statutory damages in an amount up to $1,000.00 pursuant to 15 U.S.C. § 1692k(a)(2)(A); and, 

reasonable attorneys’ fees and costs pursuant to 15 U.S.C. § 1692k(a)(3), from the Defendant 

herein.

COUNT 2

FAILURE TO DISCLOSE STATUS AS A DEBT COLLECTOR

23. Defendant failed to disclose in the telephone messages that it is a debt collector in 

violation of 15 U.S.C. 1692e(11).

WHEREFORE, Plaintiff requests that this Honorable Court enter judgment in favor of 

Plaintiffs and against Defendant for:

a) Damages and

b) Attorneys’ fees and costs.

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COUNT 3

FAILURE TO MAKE MEANINGFUL DISCLOSURE OF IDENTITY

24. Defendant placed a telephone call to Plaintiff without making meaningful 

disclosure of its identity when it failed to disclose that he was a debt collector, and the purpose of 

Defendant’s communication in the telephone message in violation of 15 U.S.C. 1692d(6).

WHEREFORE, Plaintiff requests that this Honorable Court enter judgment in favor of 

Plaintiff and against Defendant for:

A) Damages and

B) Attorneys’ fees and costs.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays that judgment be entered against the Defendant.

Dated: March 18, 2010 Respectfully submitted,

/s Andrew I. Glenn________________________ 

Andrew I. Glenn

E-mail: AGlenn@cardandglenn.com

Florida Bar No.: 026491992

Card & Glenn, P.A.

35 Journal Square, Suite 403

Jersey City, New Jersey 07306

Telephone: (201) 254-5009

Facsimile: (201) 643-5959

Attorneys for Plaintiff

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