UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

Michael Kupritz,

Plaintiff,

v.

Palisades Collections, LLC; and DOES 1-10, 

inclusive,

Defendants.

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Civil Action No.: ______

COMPLAINT

Plaintiff, Michael Kupritz, says by way of Complaint against Defendant, 

Palisades Collections, LLC, as follows: 

JURISDICTION

1. This action arises out of Defendant’s repeated violations of the Fair Debt 

Collection Practices Act, 15 U.S.C. § 1692, et seq. (“FDCPA”), and the invasions of Plaintiff’s 

personal privacy by Defendant and its agents in their illegal efforts to collect a consumer debt.

2. This Court has supplemental jurisdiction over all other claims in this action, as all 

such claims arise out of the same case or controversy as Defendant’s violations of the FDCPA 

pursuant to 28 U.S.C. § 1367.

3. Venue is proper in the U.S. District Court for the District of New Jersey pursuant 

to 28 U.S.C. § 1391(b), as Defendant transacts business in the State of New Jersey.

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PARTIES

4. The Plaintiff, Michael Kupritz (“Plaintiff”), is an adult individual residing in Palm 

Beach Gardens, Florida, and is a “consumer” as the term is defined by 15 U.S.C. § 1692a(3).

5. Defendant Palisades Collections, LLC (“Palisades”), is a New Jersey business 

entity with an address of 210 Sylvan Avenue, Englewood Cliffs, New Jersey 07632, operating as 

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

6. Does 1-10 (the “Collectors”) are individual collectors employed by Palisades and 

whose identities are currently unknown to the Plaintiff. One or more of the Collectors may be 

joined as parties once their identities are disclosed through discovery.

7. Palisades at all times acted by and through one or more of the Collectors.

ALLEGATIONS APPLICABLE TO ALL COUNTS

A. The Debt

8. The Plaintiff incurred a financial obligation in the approximate amount of

9,637.17 (the “Debt”) to Heritage Chase (the “Creditor”).

9. The Debt arose from services provided by the Creditor which were primarily for 

family, personal or household purposes and which meets the definition of a “debt” under 15 

U.S.C. § 1692a(5). 

10. The Debt was purchased, assigned or transferred to Palisades for collection, or 

Palisades was employed by the Creditor to collect the Debt.

11. The Defendants attempted to collect the Debt and, as such, engaged in 

“communications” as defined in 15 U.S.C. § 1692a(2).

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B. Palisades Engages in Harassment and Abusive Tactics

12. On or about November 15, 2010, Plaintiff returned call to Defendants, during 

which Defendants demanded payment of the Debt.

13. Following November conversation, Defendants mailed a letter to the Plaintiff, 

dated December 29, 2010, which failed to inform the Plaintiff of his right to seeks validation of 

the Debt. 

C. Plaintiff Suffered Actual Damages

14. The Plaintiff has suffered and continues to suffer actual damages as a result of the 

Defendants’ unlawful conduct. 

15. As a direct consequence of the Defendants’ acts, practices and conduct, the 

Plaintiff suffered and continues to suffer from humiliation, anger, anxiety, emotional distress, 

fear, frustration and embarrassment. 

COUNT I

VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT

15 U.S.C. § 1692, et seq.

16. The Plaintiff incorporates by reference all of the above paragraphs of this 

Complaint as though fully stated herein.

17. The Defendants’ conduct violated 15 U.S.C. § 1692g(a)(1) in that Defendants 

failed to send the Plaintiff a validation notice stating the amount of the Debt.

18. The Defendants’ conduct violated 15 U.S.C. § 1692g(a)(2) in that Defendants 

failed to send the Plaintiff a validation notice stating the name of the original creditor to whom 

the Debt was owed.

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19. The Defendants’ conduct violated 15 U.S.C. § 1692g(a)(3) in that Defendants 

failed to send the Plaintiff a validation notice stating the Plaintiff’s right to dispute the Debt 

within thirty days.

20. The Defendants’ conduct violated 15 U.S.C. § 1692g(a)(4) in that Defendants 

failed to send the Plaintiff a validation notice informing the Plaintiff of a right to have 

verification and judgment mailed to the Plaintiff.

21. The foregoing acts and omissions of the Defendants constitute numerous and 

multiple violations of the FDCPA, including every one of the above-cited provisions.

22. The Plaintiff is entitled to damages as a result of Defendants’ violations.

PRAYER FOR RELIEF

WHEREFORE, the Plaintiff prays that judgment be entered against the Defendants:

1. Actual damages including, but not limited to, the emotional distress the 

Plaintiff has suffered (and continues to suffer) as a result of the intentional, 

reckless, and/or negligent FDCPA violations and intentional, reckless, and/or 

negligent invasions of privacy pursuant to 15 U.S.C. § 1692k(a)(1);

2. Statutory damages of $1,000.00 pursuant to 15 U.S.C. §1692k(a)(2)(A);

3. Costs of litigation and reasonable attorney’s fees pursuant to 15 U.S.C. 

§ 1692k(a)(3);

4. Such other and further relief that the Court may deem just and proper.

TRIAL BY JURY DEMANDED ON ALL COUNTS

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Dated: March 24, 2011

Respectfully submitted,

By: /s/ Sofia Balile

Sofia Balile, Esq.

Lemberg & Associates LLC

1100 Summer Street

Stamford, CT 06905

Phone: (917) 981-0849

Fax: (203) 653-3424

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