Case 2:17-cv-02726-JS-AYS Document 1 Filed 05/05/17 Page 1 of 1.1 1 PaaeLD 1 1=L IN CLERKS OFFICE U.S. DISTRICT COURT E.D.N.Y. MAY 05 2017 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK LONG ISLAND OFFICE CASE NO.: JAMIE GRAMBO; an individual; on behalf of herself and all others similarly situated, Plaintiffs, CV 17 2726 vs.: CLASS ACTION COMPLAINT FOR VIOLATIONS OF THE FAIR DEBT RELIANT CAPITAL SOLUTIONS, LLC,: COLLECTION PRACTICES ACT Defendant. DEMAND FOR JURY TRIAL :x SEYBER1 J. I. PRELIMINARY STATEMENT SHIELDS, M.J. 1. Plaintiff, JAMIE GRAMBO ("Plaintiff' or "GRAMBO"), on behalf of herself and all others similarly situated, and demanding a trial by jury, brings this action for the illegal practices of the Defendant RELIANT CAPITAL SOLUTIONS, LLC who, inter alia, used false, deceptive, misleading, unconscionable, and other illegal practices, in connection with their attempts to collect an alleged debt from the Plaintiff and others. 2. The Plaintiff alleges that the Defendant's collection practices violate the Fair Debt Collection Practices Act, 15 U.S.C. 1692 et seq. ("FDCPA"). 3. The FDCPA regulates the behavior of collection agencies attempting to collect a debt on behalf of another. The United States Congress has found abundant evidence of the use of abusive, deceptive, and unfair debt collection practices by many debt collectors, and has determined that abusive debt collection practices contribute to a number of personal bankruptcies, marital instability, loss of jobs, and invasions of individual privacy. Congress enacted the FDCPA to eliminate abusive debt collection practices by debt collectors, to ensure that those debt collectors who refrain from using abusive debt collection practices are not
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Case 2:17-cv-02726-JS-AYS Document 1 Filed 05/05/17 Page 1 of 1.11 PaaeLD 11=LIN CLERKS OFFICE
U.S. DISTRICT COURT E.D.N.Y.
MAY 05 2017UNITED STATES DISTRICT COURTEASTERN DISTRICT OF NEW YORK LONG ISLAND OFFICE
CASE NO.:JAMIE GRAMBO; an individual; on behalf ofherself and all others similarly situated,
Plaintiffs, CV 17 2726vs.: CLASS ACTION COMPLAINT FOR
VIOLATIONS OF THE FAIR DEBTRELIANT CAPITAL SOLUTIONS, LLC,: COLLECTION PRACTICES ACT
Defendant. DEMAND FOR JURY TRIAL
:x SEYBER1 J.
I. PRELIMINARY STATEMENT SHIELDS, M.J.
1. Plaintiff, JAMIE GRAMBO ("Plaintiff' or "GRAMBO"), on behalf of herself
and all others similarly situated, and demanding a trial by jury, brings this action for the illegal
practices of the Defendant RELIANT CAPITAL SOLUTIONS, LLC who, inter alia, used false,
deceptive, misleading, unconscionable, and other illegal practices, in connection with their
attempts to collect an alleged debt from the Plaintiff and others.
2. The Plaintiff alleges that the Defendant's collection practices violate the Fair Debt
Collection Practices Act, 15 U.S.C. 1692 et seq. ("FDCPA").
3. The FDCPA regulates the behavior of collection agencies attempting to collect a
debt on behalf of another. The United States Congress has found abundant evidence of the use of
abusive, deceptive, and unfair debt collection practices by many debt collectors, and has
determined that abusive debt collection practices contribute to a number of personal
bankruptcies, marital instability, loss of jobs, and invasions of individual privacy. Congress
enacted the FDCPA to eliminate abusive debt collection practices by debt collectors, to ensure
that those debt collectors who refrain from using abusive debt collection practices are not
Case 2:17-cv-02726-JS-AYS Document 1 Filed 05/05/17 Page 2 of 11 PagelD 2
competitively disadvantaged, and to promote uniform State action to protect consumers against
debt collection abuses. 15 U.S.C. 1692(a) (e).
4. The FDCPA is a strict liability statute, which provides for actual or statutory
damages upon the showing of one violation. The Second Circuit has held that whether a debt
collector's conduct violates the FDCPA should be judged from the standpoint of the "least
Attorneys for Plaintiff, Jamie Grambo, and allothers similarly situated
Case 2:17-cv-02726-JS-AYS Document 1-1 Filed 05/05/17 Page 1 of 3 PagelD 12
EXHIBIT A
Case 2:17-cv-02726-JS-AYS Document 1-1 Filed 05/05/17 Page 2 of 3 PagelD 13PO Box 30469Columbus, 01-1 43230 reliant
Phone (866) 738-3179 Fax (614) 452-6099
File Amount Due Amount Enclosed
126148425 $455.40
DO NOT SEND CASH.MAKE CHECKS PAYABLE TO: Reliant Capital Solutions, LLC
PLEASE INCLUDE YOUR FILE NUMBER ON YOUR PAYMENT.
RETURN THIS PORTION WITH YOUR PAYMENT.SEND PAYMENT TO:
1 AT 'A-01-QHG-AM-01496-6
JAMIE GRAMBO Reliant Capital Solutions, LLCPO BOX 30469COLUMBUS OH 43230-0469
05/17/2016
Dear JAMIE GRAMBO, ACCOUNT INFORMATION
This notice is to inform you that this office represents NASSAU COMMUNITY Re: NASSAU COMMUNITY COLLEGE
COLLEGE regarding the past due balance listed below: Name: Jamie Grambo
File igiaC620SPlease include the coupon above with your payment. You may also pay online at Tem/ easame As Ofosii7/2016 $455.40.www.payrefiantnow.com. Please include your file number when paying: 12816835
This communication is from a debt collector. This is an attempt to collect a debt OFFICEmouRsand any information obtained will be used for that purpose. Monday. Thursday
Update your communication preferences by visiting 84-00am Ofielern Thre
Telephone calls with Reliant Capital Solutions, LLC are monitored and recorded forEinarn 5:000MP3Steitt TiMe-
quality and training purposes. PAYMENToPTIONSUnless you notify this office within 30 days after receiving this notice that you dispute Check by Phone
the validity of this debt or any portion thereof, this office will assume this debt is valid. (866)1384m.If you notify this office in writing within 30 days from receiving this notice that you
dispute the validity of this debt or any portion thereof, this office will obtain verification Credit Cards
of the debt or obtain a copy of a judgment and mail you a copy of such judgment or iJverification. If you request of this office in writing within 30 days after receiving this
notice, this office will provide you with the name and address of the original creditor, if different from the current creditor.
Debt collectors, in accordance with the Fair Debt Collection Practices Act. 15 U.S.C. 1692 et seq., are prohibited from
engaging in abusive, deceptive, and unfair debt collection efforts, including but not limited to:
1. the use or threat of violence;2. the use of obscene or profane language; and
3. repeated phone calls made with the intent to annoy, abuse, or harass.
If a creditor or debt collector receives a money judgment against you in court, state and federal laws may prevent the following
types of income from being taken to pay the debt:
1. Supplemental security income, (SSI);2. Social security;3. Public assistance (welfare):4. Spousal support, maintenance (alimony) or child support:5. Unemployment benefits;6. Disability benefits;7. Workers' compensation benefits;8. Public or private pensions;9. Veterans' benefits;10. Federal student loans, federal student grants, and federal work study funds; and
qc.c. euirlitinnal Paces for Important Information. Page 1 of 2
Case 2:17-cv-02726-JS-AYS Document 1-1 Filed 05/05/17 Page 3 of 3 PagelD 1411. Ninety percent of your wages or salary earned in the last sixty days.
ACCOUNT INFORMATION
Account Principal Interest Collection Costs Other Charges Balance
1066193a09 $379.50 $0.00 $75.90 $0.00 $455.40
1 AT *A-01-QHG-AM-01496-6 Page 2 of 2
FO
1Rev. 07/1(4Case 2:17-cv-02726-JS-AYSdwaiiiER2 RAT/105/17 Page 1 of 2 PagelD 15
IS 44F I LE ID
Thc JS 44 civil cover sheet and thc information contained herein neither replace nor supplement the filing and service of pleadings or otherTapai Okrpli(e.ct byitawfocept as
provided by local rules ofcourt. This form. approved by the Judicial Conference of the United States in September 1974, is required foUleuLt;pTtNglerteSo\ttrtJtIr:,thpurpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORAI) Y.
I. (a) PLAINTIFFS DEFENDANTS MM O 5 217JAMIE GRAMBO; an individual; on behalf of herself and all others RELIANT CAPITAL SOLUTIONS, LLCsimilarly situated LONO 1SLAND OFFICE
(b) County of Residence of First Listed Plaintiff NASSAU County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OFTHE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name. Address. and Telephone Number) Attorney s (If Known)
KLEINMAN LLC ri V 1 7 2 7 26626 RXR PLAZA qt4,
UNIONDALE, NEW YORK 11556-0626 (516) 522-2621
II. BASIS OF JURISDICTION (Place an "X" in One Bay Onlv) III. CITIZENSHIP OF PRINCIPAL PARTIES (Pace an "X" in OnnBox for Plaintiff(Foe ))ivrEviry ('a(cc Only) and One BoxJi.or IVendani)
O 1 U-S. Govermnent N 3 Federal Question PIT DEF I'TF DEE
Plaintiff (U.S. Govonmenl Nor a Pwv) Citizen of This State 3 3 n 1 Incorporated or Principal Place 71 4 71 4ofBusiness hi This State
O 2 U.S. Government 0 4 Diversity Citizen of Another State 0 2 0 2 Incorporated and Principal Place 0 5 0 5Defendant SUgriariescisgititiftiPurfies in Item HO ofBusiness In Another State
MMON Z., 1Citizen or Subject of a 0 3 CI 3 Foreign Nation CI 6 71 6
IV. NATURE OF SUIT (Place an "X"' in One Box Only)
I CONTRACT TORTS FORFEITUREIPENAITY BANKRUPTCY OTHER STATUTKS IO 110 Insurance PERSONAL INJURY PERSONAL INJURY 0 625 Drag Related Seizure 0 422 Appeal 28 USC 158 3 375 False Claims Au1 i 20 Marine CI 310 Airplane 0 365 Personal Injury of Property 21 USC 881 0 423 Withdrawal 0 376 Qui Tam (31 USCO 130 Miller Act ri 315 Airplane Product Product Liability 0 590 Other 28 USC 157 3729(a))O 140 Negotiable Instnuncnt Liability 0 367 Health Care, 0 400 State ReapportionmentO 150 Recovery of Overpayment 171 320 Assault, Libel S.: Pharmaceutical PROPERTY RIGHTS 3 410 Antitrust
& Enforcement ofJudgment Slander Personal Injury 171 820 Copyrights o 430 Banks and BankingO 151 Medicare Act 0 330 Federal Employers' Product Liability 0 830 Patent 3 450 CommerceO 152 Recovery of Defaulted Liability 0 368 Asbestos Pcl-sonal 0 840 Trademark 0 460 Deportation
O 153 Recover}, of Overpayment Liability PERSONAL PROPERTY [0 710 Fair Labor Standaids 0 861 HIA (1395f0 X 480 Consumer Creditof Veteran's Benefits 0 350 Motor Vehicle 0 370 Other Fraud Act 0 862 Black Lung (923) CI 490 CableiSat TV
O I 60 StockholdeW Suits 3 355 Motor Vehicle CI 371 Truth in Lending 0 720 Labor/Mattagement 0 863 DINVC/D1WW (405(g)) 0 850 Securitics/Commodifies/O 190 Other Contract Product Liability 0 380 Other Personal Relations 0 864 SS1D Title XVI Exchange3 195 Contract Product Liability 0 360 Other Personal Property Damage 0 740 Railway Labor Act 0 565 RS1 (405(g)) 0 890 Other Statutory Actions3 196 Franchise Injury 0 385 Property Damage 0 751 Family and Medical 0 891 Agricultural Acts
0 362 Personal Injury Product Liability Leave Act 0 893 Environmental MattersMedical Malpractice 0 790 Other Labor Litigation 0 895 Freedom of Information
I REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 0 791 Employee Retirement FEDERAL TAX SUITS ActO 210 Land Condemnation 0 440 Other Civil Rights Habeas Corpus: 111COMIC Security Act 0 870 Taxes (U.S. Plaintiff o 896 ArbitrationO 220 Foreclosure 0 441 Voting 0 463 Alien Detainee or Defendant) Cl 899 Administrative ProcedureO 230 Rent Lease & Ejectment 0 442 Employment o 510 Motions to Vacate 0 571 IRS—Third Party Act/Review or Appeal ofO 240 Torts to Land 0 443 Housing/ Sentence 26 USC 7609 Agency DecisionO 245 Tort Product Liability Accommodations 0 530 General 0 950 Constitutionality ofO 290 All Other Real Property 0 445 Amer. w/Disabilities 0 535 Death Penalty IMMIGRATION State Statutes
Employment Other: 0 462 Naturalization Application0 446 Amer. w/Disabilities, 0 540 Mandamus & Other 0 465 Other linini,aation SEYBER J.
Other 0 550 Civil Rights Actions0 448 Education 0 555 Prison Condition
0 560 Civil DetaineeConditions of SHIELDS) 1111•J.Confinement
V. ORIGIN (Plaa. an 'X'in (Sie Box Only)X I Original 0 2 Removed from 1 3 Remanded from 0 4 Reinstated or 0 5 Transferred from 0 6 Multidistrict 0 8 Mullidistrict
Proceeding State Court Appellate Court Reopened Another District Liligation Litigation("speeics) Transfer Direct File
Cite thc U.S. Civil Statute under which you arc filing (Do Hof cite PiriSdicihIngl sialures artless diversity):15 U.S.C. 1692 et seq.VI. CAUSE OF ACTION....Brief description of cause:
VIOLATION OF FEDERAL COLLECTION LAWVII. REQUESTED IN 2 CHECK IF TJIIS IS A CLASS ACTION DEMAND CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: X Yes CI No
Case 2:17-cv-02726-JS-AYS Document 1-2 Filed 05/05/17 Page 2 of 2 PagelD 16
CERTIFICATION OF ARBITRATION ELIGIBILITYLocal Arbitration Rule 83.10 provides that with certain exceptions, actions seeking money damages only in an amount not in excess of$150,000,exclusive of interest and costs, are eligible for compulsory arbitration. The amount of damages is presumed to be below the threshold amount unless a
certification to the contrary is filed.
12 ABRAHAM KLEINMAN, counsel for JAMIE GRAMM, do hereby certify that the above captioned civil action isineligible for compulsory arbitration for the following reason(s):
0 monetary damages sought are in excess of $150,000, exclusive of interest and costs,
0 the complaint seeks injunctive relief,
El the matter is otherwise ineligible for the following reasonMatter Filed as a Putative Class Action.
DISCLOSURE STATEMENT FEDERAL RULES CIVIL PROCEDURE 7.1
Identify any parent corporation and any publicly held corporation that owns 10% or more or its stocks:
Not applicable.
RELATED CASE STATEMENT (Section VIII on the Front of this Form)
Please list all cases that are arguably related pursuant to Division ofBusiness Rule 50.3.1 in Section VIII on the front of this form. Rule 50.3.1 (a)provides that "A civil case is "related" to another civil case for purposes of this guideline when, because of the similarity of facts and legal issues or
because the cases arise from the same transactions or events, a substantial saving ofjudicial resources is likely to result from assigning both cases to thesame judge and magistrate judge." Rule 50.3.1 (b) provides that A civil case shall not be deemed "related" to another civil case merely because the civilcase: (A) involves identical legal issues, or (B) involves the same parties." Rule 50.3.1 (c) further provides that "Presumptively, and subject to the powerof a judge to determine otherwise pursuant to paragraph (d), civil cases shall not be deemed to be "related" unless both cases are still pending before thecourt."
NY-E DIVISION OF BUSINESS RULE 50.1(d)(21
1.) Is the civil action being filed in the Eastern District removed from a New York State Court located in Nassau or SuffolkCounty: NO.
2.) Ifyou answered "no" above:a) Did the events or omissions giving rise to the claim or claims, or a substantial part thereof, occur in Nassau or SuffolkCounty? YES-
b) Did the events or omissions giving rise to the claim or claims, or a substantial part thereof, occur in the EasternDistrict? YES.
Ifyour answer to question 2 (b) is "No, does the defendant (or a majority of the defendants, if there is more than one) reside in Nassau or
Suffolk County, or, in an interpleader action, does the claimant (or a majority of the claimants, if there is more than one) reside in Nassauor Suffolk County?
(Note: A corporation shall be considered a resident of the County in which it has the most significant contacts).
BAR ADMISSION
I am currently admitted in the Eastern District ofNew York and currently a member in good standing of the bar of this court.M Yes 0 No
Are you currently the subject of any disciplinary action (s) in this or any other state or federal court?
0 Yes (Ifyes, please explain) Kl No
T certify the accuracy of all information provided above.
Signature:
ClassAction.orgThis complaint is part of ClassAction.org's searchable class action lawsuit database and can be found in this post: Reliant Capital Solutions Sued Over Collection Practices