Complaint 

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UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF NEW JERSEY 

________________________________ 

 ) 

JANICE BECKFORD, ) 

 ) 

 Plaintiff, ) Civil Action No.

 ) 

 vs. ) COMPLAINT 

 ) 

PRESSLER & PRESSLER, LLP ) Jury Trial Demanded

 ) 

Defendant. ) 

_________________________________) 

NATURE OF ACTION 

1. This is an action brought under the Fair Debt Collection Practices 

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

JURISDICTION AND VENUE 

2. This Court has jurisdiction under 15 U.S.C. § 1692k(d) and 28 

U.S.C. § 1331. 

3. Venue is proper before this Court pursuant to 28 U.S.C. §1391(b), 

where the acts and transactions giving rise to Plaintiff’s action occurred in this 

district, (where Plaintiff resides in this district), and/or where Defendant transacts 

business in this district. 

PARTIES 

4. Plaintiff, Janice Beckford (“Plaintiff”), is a natural person who at all 

relevant times resided in the State of New Jersey, County of Bergen, and City of 

Elmwood Park. 

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

6. Defendant, Pressler & Pressler, LLP (“P&P”) is an entity who at all 

relevant times was engaged, by use of the mails and telephone, in the business of 

attempting to collect a “debt” from Plaintiff, as defined by 15 U.S.C. §1692a(5). 

FACTUAL ALLEGATIONS 

7. Plaintiff is a natural person obligated, or allegedly obligated, to pay a 

debt owed or due, or asserted to be owed or due a creditor other than Defendant. 

8. Plaintiff's obligation, or alleged obligation, owed or due, or asserted 

to be owed or due a creditor other than Defendant, arises from a transaction in 

which the money, property, insurance, or services that are the subject of the 

transaction were incurred primarily for personal, family, or household purposes. 

Plaintiff incurred the obligation, or alleged obligation, owed or due, or asserted to 

be owed or due a creditor other than Defendant. 

9. Defendant uses instrumentalities of interstate commerce or the mails 

in a business the principal purpose of which is the collection of any debts, and/or 

regularly collects or attempts to collect, directly or indirectly, debts owed or due, 

or asserted to be owed or due another. 

10. In connection with an alleged debt, Defendant placed a call to 

Plaintiff’s cellular telephone on February 19, 2011 at 12:16 P.M., and at such time, 

left a voicemail message for Plaintiff in which Defendant failed to disclose the 

individual identity of the caller, failed to disclose the true corporate and/or 

business name of the debt collection company, and failed to notify Plaintiff that 

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the communication was from a debt collector. (15 U.S.C. §§ 1692d(6), 

1692e(11)). 

COUNT I 

DEFENDANT P&P 

11. Plaintiff repeats and re-alleges each and every allegation contained 

above. 

12. Defendant violated the FDCPA as detailed above. 

WHEREFORE, Plaintiff prays for relief and judgment, as follows: 

a) Adjudging that Defendant violated the FDCPA; 

b) Awarding Plaintiff statutory damages, pursuant to 15 U.S.C. §1692k, 

in the amount of $1,000.00; 

c) Awarding Plaintiff actual damages, pursuant to 15 U.S.C. §1692k; 

d) Awarding Plaintiff reasonable attorneys’ fees ands costs incurred in 

this action; 

e) Awarding Plaintiff any pre-judgment and post-judgment interest as 

may be allowed under the law; 

f) Awarding such other and further relief as the Court may deem just 

and proper. 

TRIAL BY JURY 

13. Plaintiff is entitled to and hereby demands a trial by jury. 

Dated: May 18, 2011 Respectfully submitted, 

 /s/ Dennis R. Kurz

 Dennis R. Kurz 

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 NJ Bar No. 4570453 

 Weisberg & Meyers, LLC 

 Attorneys for Plaintiff 

 5025 N. Central Ave., #602 

 Phoenix, AZ 85012 

 (888) 595-9111 ext. 412 

 (866) 842-3303 (fax) 

 dkurz@attorneysforconsumers.com

 

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