Jennifer M. Kurtz 

The Law Offices of Jennifer M. Kurtz, LLC 

540 Old Bridge Turnpike 

South River, NJ 08882 

Tel: 732-390-5262 

Fax: 732-390-2162 

jennifer.kurtz@kurtz-law.com 

Attorneys for Plaintiff, 

Michelle McKay 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF NEW JERSEY 

 : 

Michelle McKay, : 

 Plaintiff, : Civil Case No.:

vs. : 

NCB Management Services, Inc., : 

 Defendant. : 

 : 

 

VERIFIED COMPLAINT

Plaintiff, Michelle McKay (“Plaintiff”), through her attorneys, alleges the following 

against Defendant, NCB Management Services, Inc. (“Defendant”): 

INTRODUCTION 

1. Count I of Plaintiff’s Complaint is based on the Fair Debt Collection Practices Act 

(“FDCPA”), 15 U.S.C. § 1692, et seq. 

PARTIES 

2. Plaintiff is a natural person residing at 390 Hopedale Drive SE, Bayville, Ocean County, 

New Jersey, 08721. 

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3. Defendant is a debt collection company with a business office located at 1 Allied Drive, 

Trevose, Pennsylvania, 19053. 

4. Defendant is a debt collector as that term is defined by 15 U.S.C. § 1692a(6), and sought 

to collect a consumer debt from Plaintiff. 

5. Defendant acted through its agents, employees, officers, members, directors, heirs, 

successors, assigns, principals, trustees, sureties, subrogees, representatives, and 

insurers. 

JURISDICTION AND VENUE 

6. Jurisdiction of this court arises pursuant to 15 U.S.C. § 1692k(d), which states that such 

actions may be brought and heard before “any appropriate United States district court 

without regard to the amount in controversy.” 

7. Defendant conducts business in the state of New Jersey, and therefore, personal 

jurisdiction is established. 

8. Venue is proper pursuant to 28 U.S.C. § 1391(b)(2). 

FACTUAL ALLEGATIONS

9. Defendant is attempting to collect a consumer debt from Plaintiff. 

10. Plaintiff’s alleged debt owed arises from transactions for personal, family, and household 

purposes. 

11. Defendant left a message for Plaintiff, in an attempt to collect a debt, which did not 

disclose the caller’s identity. See Transcribed Voice Message, attached hereto as Exhibit 

A. 

12. Defendant left a message for Plaintiff, in an attempt to collect a debt, which did not state 

the communication was from a debt collector. See Exhibit A. 

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13. Defendant’s voicemail messages for Plaintiff request that Plaintiff call Defendant at 800-

828-1110, a telephone number that belongs to Defendant. 

COUNT I 

DEFENDANT VIOLATED THE FAIR DEBT COLLECTION PRACTICES ACT 

14. Defendant violated the FDCPA based on the following: 

a. Defendant violated § 1692d of the FDCPA by engaging in conduct that the 

natural consequences of which was to harass, oppress, and abuse Plaintiff in 

connection with the collection of an alleged debt. 

b. Defendant violated § 1692d(6) of the FDCPA by placing telephone calls without 

meaningful disclosure of the caller’s identity. 

c. Defendant violated § 1692e of the FDCPA by using false, deceptive, and 

misleading representations in connection with the collection of any debt. 

d. Defendant violated § 1692e(10) of the FDCPA by using deceptive means in an 

attempt to collect a debt. 

e. Defendant violated § 1692e(11) of the FDCPA by failing to disclose in 

subsequent communications that the communication was from a debt collector. 

Wherefore, Plaintiff, Michelle McKay, respectfully requests judgment be entered against 

Defendant, NCB Management Services, Inc., for the following: 

15. Statutory damages of $1,000.00 pursuant to the Fair Debt Collection Practices Act, 15 

U.S.C. § 1692k, 

16. Costs and reasonable attorneys’ fees pursuant to the Fair Debt Collection Practices Act, 

15 U.S.C. § 1692k 

17. Any other relief that this Honorable Court deems appropriate. 

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DEMAND FOR JURY TRIAL

 Please take notice that Plaintiff, Michelle McKay, demands a jury trial in this cause of 

action. 

CERTIFICATION PURSUANT TO LOCAL RULE 11.2 

Pursuant to Local Rule 11.2, I certify that this matter in controversy is not the subject of 

any other action pending in any court, arbitration, or administrative proceeding. 

DATED: July 26, 2011 Respectfully Submitted, 

The Law Offices of Jennifer M. Kurtz, LLC 

By: /s/ Jennifer M. Kurtz .

Jennifer M. Kurtz 

Attorney for Plaintiff, 

Michelle McKay 

 

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