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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
NEAL PRESTON, individually, and on
behalf of all others similarly situated,
Plaintiff,
v.
MRS BPO, L.L.C,
Defendant.
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JURY DEMANDED
CASE NUMBER
CLASS ACTION COMPLAINT
NOW COMES Plaintiff NEAL PRESTON (“Plaintiff”), individually, and on behalf of all
others similarly situated, by and through his lead counsel, James C. Vlahakis, asserts the following
Class Action Complaint for violations of the Fair Debt Collection Practices Act, 15 U.S.C. § 1692,
et seq., (“FDCPA”) against Defendant MRS BPO, L.L.C. (“Defendant”):
INTRODUCTION
1. This action seeks to recover for violations of the FDCPA resulting from two debt
collection letters sent by Defendant to Plaintiff on October 31, 2016, for two separate debts
allegedly owed to the identified creditor, “Chase Bank USA N.A.”
2. Plaintiff alleges that the following language violated the FDCPA:
“If we settle this debt with you for less than the full outstanding balance, Chase
may offer you less favorable terms in the future for some Chase products or
services, or may deny your application.”
3. The letters, attached as Exhibits A and B to the Complaint are each a
“communication” as defined by 15 U.S.C. § 1692a(2) because the letters attempted to collect debts
allegedly owed to Chase Bank USA N.A.
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4. The letters are redacted to remove personal financial information relative to the
amounts of the debts, proposed payment amounts, creditor account number and Defendant’s
internal account number.
5. The last three digits of Defendant’s account number have been left to demonstrate
that two separate letters were mailed by Defendant.
PARTIES, JURISDICTION AND VENUE
6. Plaintiff is a citizen of Illinois who resides in LaGrange, Illinois.
7. Plaintiff is a “consumer” as defined by 15 U.S.C. § 1692a(3).
8. Defendant MRS BPO, L.L.C. (“Defendant”), is a New Jersey Limited Liability
Company with a principal place of business in Camden County, New Jersey.
9. Defendant is regularly engaged in the collection of consumer debts.
10. Defendant is a “debt collector” as defined by 15 U.S.C. § 1692a(6).
11. Defendant was conducting substantial and continued debt collection related
activities within the State of Illinois during 2016 and continues to do so.
12. This Court has federal subject matter jurisdiction pursuant to 28 U.S.C. § 1331 and
15 U.S.C. § 1692k(d).
13. Venue is proper under 28 U.S.C. §1391(b) because a substantial part of the events
or omissions giving rise to the claim occurred in this Judicial District.
GENERAL ALLEGATIONS
14. As set forth below, Plaintiff is complaining that Defendant sent identical standard
form letters to more than forty persons.
15. Plaintiff alleges that the following language violated the FDCPA:
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“If we settle this debt with you for less than the full outstanding balance, Chase
may offer you less favorable terms in the future for some Chase products or
services, or may deny your application.”
See Exhibit A (MRS Account No. ending in 490) and Exhibit B (MRS Account No. ending in
596).
16. The above quoted language informed Plaintiff that it would not be beneficial for
him to settle the debt by paying less than the amount owed because the letter warned Plaintiff that
if he paid “less than the full outstanding balance, Chase may offer you less favorable terms in the
future for some Chase products or services.”
17. The letter also told Plaintiff that if he paid “less than the full outstanding balance”
Chase “may deny your application.”
18. This language was intended to give debtors like Plaintiff a confusing, Hobson’s
Choice of sorts – save money and settle the debt for less than the amount owed, but suffer some
unspecified action at the hands of Chase.
19. The letter also indicated that in order to make sure that Chase would not offer “less
favorable terms in the future for some Chase products or services” Plaintiff and the proposed class
members would have to pay every cent owed.
20. Finally, the letter indicated that in order to make sure that Chase would not “deny”
an “application”, Plaintiff and the proposed class members would have to pay every cent owed.
21. On information and belief, Chase would not offer less favorable terms in the future
for some Chase products or services” or otherwise “deny [an] application” if a debtor paid less
than the total amount owed. This is especially true if a debtor paid close to the full value of the
debt.
22. Under the language utilized by Defendant, the language was intended (or at least
had the result) to urge debtors to settle for the full amount owed.
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23. This is especially true if the debt was for a low balance.
24. The quoted language violates Section 1692e of the FDCPA because it is confusing,
false, deceptive and/or misleading to the Plaintiff and is likely to be viewed the same way by the
“least sophisticated consumer.”
25. The quoted language violates Section 1692e of the FDCPA because the confusing
language is an “unfair or unconscionable means to collect or attempt to collect” a debt.
26. Additionally, the language is confusing, false, deceptive and/or misleading because
it is contained at the very bottom of the letter.
27. The location of the language (at the bottom of the letter) is also problematic because
the letter was sent folded with perforated edges, and one of the perforated folds, is located just
above the subject language. See Exhibit C (front of letter), Exhibit D (back of letter), Exhibit E
(front and back), Exhibit F (lower half of letter folded over) and Exhibit G (close up of perforated
nature of the fold).
28. Ultimately, the quoted language would benefit Defendant to the extent that it would
earn higher commissions if debtors paid the full amount owed.
29. Plaintiff has suffered monetary damages, as he was required to retain counsel to
review this letter and protect his rights under the FDCPA.
30. On information and belief, it is plausible that class members were confused by the
letter and did not pay any amount.
31. It is also plausible that certain class members may have had to consult with legal
counsel in order to ascertain their rights under the FDCPA.
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32. It is also plausible that certain class members were confused by the letter and chose
to pay the full amount of their debt to avoid having Chase offer them “less favorable terms in the
future for some Chase products or services, or deny [their] application.”
33. Additionally, it is clear that a statutory violation of the FDCPA, on its own, is
sufficient to confer Article III standing.
COUNT I - 15 U.S.C. § 1692e
34. Plaintiff incorporates the above paragraphs into this Count.
35. As alleged above, Plaintiff asserts that the quoted language violated 15 U.S.C. §
1692e because the language constitutes a false, deceptive or misleading representation or means
to collect a debt.
36. Because the above quoted language violated the FDCPA, Plaintiff and the proposed
class are entitled to the relief set forth below.
COUNT II - 15 U.S.C. § 1692e(2)(A)
37. Plaintiff incorporates the above paragraphs into this Count.
38. As alleged above, Plaintiff asserts that the quoted language violated 15 U.S.C. §
1692e(2)(A) because the language constitutes a false representation regarding character or legal
status of the alleged debts.
39. Contrary to Defendant’s representation, it was not required by the FDCPA to
include the quoted language in order to comply with the FDCPA.
40. Accordingly, the language, by being included below two other required disclosures
(“This is an attempt to collect a debt and any information obtained will be used for that purpose”
and “This communication is from a debt collector”) – strongly implied to Plaintiff and others that
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the language was a legal disclosure required by the FDCPA - which must be made to consumers
when this is not the case.
41. Because the above quoted language was not required to comply with the FDCPA,
it constitutes false representation regarding character or legal status of the alleged debts and the
impact that partial or full payment may have on a debt.
42. By making a false representation regarding character or legal status of the alleged
debts and the impact that partial or full payment may have on a debt, Defendant violated the
FDCPA.
43. Because the above quoted language violated the FDCPA, Plaintiff and the proposed
class are entitled to the relief set forth below.
COUNT III - 15 U.S.C. § 1692e(10)
44. Plaintiff incorporates the above paragraphs into this Count.
45. For the reasons set forth above, Plaintiff asserts that the quoted language violated
15 U.S.C. § 1692e(10) of the FDCPA because the language constitutes a false representation or
deceptive means to collect or attempt to collect a debt.
46. Because the above quoted language violated the FDCPA, Plaintiff and the proposed
class are entitled to the relief set forth below.
COUNT IV - 15 U.S.C. § 1692f
47. Plaintiff incorporates the above paragraphs into this Count.
48. For the reasons set forth above, Plaintiff asserts that the quoted language violated
15 U.S.C. § 1692f because the language constitutes the use of an unfair or unconscionable means
to collect a debt.
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49. Because the above quoted language violated the FDCPA, Plaintiff and the proposed
class are entitled to the relief set forth below.
CLASS ALLEGATIONS
50. This action is brought as a class action. Plaintiff brings this action on behalf of
himself and on behalf of all other persons similarly situated pursuant to Rule 23 of the Federal
Rules of Civil Procedure.
51. Plaintiff received two identical collection letters for two separate debts.
52. The proposed class involves: (a) all persons who were sent a collection letter in
substantially the same form letter as the letters attached to the Complaint as Exhibits A and B; (b)
to addresses within the States of Illinois, Indiana and Wisconsin; (c) on or about October 31, 2016
until the present; and (d) where the collection letters were not returned by the postal service as
undelivered.
53. The identities of all class members are readily ascertainable from the records of
MRS BPO, L.L.C. and those business and governmental entities on whose behalf it attempts to
collect debts.
54. Excluded from the Plaintiff’s Class is the Defendant and all officers, members,
partners, managers, directors, and employees of MRS BPO, L.L.C., and all of their respective
immediate families, legal counsel for all parties to this action and all members of their immediate
families and this Court and persons working with or for this Court.
55. There are common questions of law and fact between Plaintiff’s claims and those
of the class.
56. Common issues predominate over any issues involving only individual class
members.
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57. The principal issues are whether Defendant’s communications with Plaintiff and
the proposed class, such as the above stated claims, violate provisions of the Fair Debt Collection
Practices Act.
58. Plaintiff’s claims are typical of the class members, as his claims are based upon the
same facts and legal theories as the proposed class members.
59. Plaintiff will fairly and adequately protect the interests of the proposed Class.
60. Plaintiff has retained counsel with experience in litigating, defending and settling
consumer lawsuits, complex legal issues, and class actions.
61. Neither the Plaintiff nor his attorneys have any interests which might prevent them
from vigorously pursuing this action.
62. This action has been brought, and may properly be maintained, as a class action
pursuant to the provisions of Rule 23 of the Federal Rules of Civil Procedure because the use of a
class action is superior to the other available means for the fair and efficient adjudication of this
controversy because individual joinder of all members would be impracticable.
63. Class action treatment will permit a large number of similarly situated persons to
prosecute their common claims in a single forum efficiently and without unnecessary duplication
of effort and expense that individual actions would engender.
64. Certification of a class under Rule 23(b)(l)(A) of the Federal Rules of Civil
Procedure is appropriate because adjudications with respect to individual members create a risk of
inconsistent or varying adjudications which could establish incompatible standards of conduct for
Defendant who, on information and belief, collects debts throughout the United States of America.
65. Certification of a class under Rule 23(b)(2) of the Federal Rules of Civil Procedure
is also appropriate in that a determination that the above stated claims, violate provisions of the
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Fair Debt Collection Practices Act, and is tantamount to declaratory relief and any monetary relief
under the FDCPA would be merely incidental to that determination.
66. Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure
is also appropriate in that the questions of law and fact common to members of the proposed Class
predominate over any questions affecting an individual member, such that class action is superior
to other available methods for the fair and efficient adjudication of the controversy.
67. Defendant has acted, or failed to act, on grounds generally applicable to the Rule
23(b)(l)(A) and 23(b)(2) Classes, thereby making appropriate final injunctive relief with respect
to the Class as a whole.
68. Depending on the outcome of further investigation and discovery, Plaintiff may, at
the time of class certification motion, seek to certify one or more classes only as to particular issues
pursuant to Fed. R. Civ. P. 23(c)(4).
JURY DEMAND
69. Plaintiff hereby demands a trial of this action by jury.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests judgment as follows: certify this action as a
class action; appoint Plaintiff as Class Representatives of the Class; appoint her attorneys as Class
Counsel; find that Defendant’s actions violate the FDCPA; award damages against Defendant
pursuant to 15 U.S.C. § 1692k; award Plaintiff’s attorneys’ fees pursuant to 15 U.S.C. § 1692k;
issue declaratory and injunctive relief; and grant all other relief that the Court determines is just
and proper.
Respectfully submitted,
Plaintiff NEAL PRESTON, individually, and on
behalf of all others similarly situated,
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By: s/James Vlahakis
James Vlahakis (lead counsel)
Ahmad T. Sulaiman
Omar T. Sulaiman
Mohammed O. Badwan
Nathan C. Volheim
SULAIMAN LAW GROUP, LTD.
2500 South Highland Avenue, Suite 200
Lombard, Illinois 60148
(630) 581-5456 telephone
(630) 575-8188 facsimile
Case: 1:17-cv-07868 Document #: 1 Filed: 10/31/17 Page 10 of 10 PageID #:10
MRS
Dear NEAL PRESTON,
Send PaymenVCorrespondence to: MRS Associates of New Jersey 1930 OLNEY AVE. CHERRY HILL, NJ 08003 877-851-1451
Office Hours : Monday - Thursday 9am - 11 pm ET Fnday 9am- 8pm ET
CREDITOR: CHASE BANK USA N.A.
MRS ACCT#: LU4 ... 490 CREDITOR /\CCTII: )()()()()()000(1 ..
ACCOUNT BALANCE
October 31, 2016
We recognize that a possible hardship or pitfall may have prevented you from satisfying your obligation. We are presenting three options to resolve your balance We are not obligated to renew this offer.
Option 1: You pay $1_., ONE PAYMENT to be received in this office on or before 11/14/2016.
Opt1on 4; You make TWO PAYME. NTS of ~each. The first payment to be received in this office on or before 11/14/2016 and the second payment on or before 12114/2016 . WI" Option ;3. A monthly payment plan to pay the full balance of the account.
Payment may be made by calling 877-851-1451, mailing to the above address or by using our online payment website at https://mrspay.webview.com (internet connection required).
When you call please let our representative know that you have received the CHASE BANK USA N.A. Option Letter.
Smcereiy,
MRS Associates of New Jersey 877-851-1451 MRS Associates of New Jersey Is a trade na.-ne of MRS BPO, L.L.C. LU4 2890490.7242766
Th1s is an attempt to collect a debt and My lnfonnallon obtained will be used for that purpose. This cornnullcatlonls from a debt collector.
If we setUe th1s debt wtth you for l~s than the full outsla'ldlng balalce, Chase may offer you less favorable terms In the future for some Chase products or SE!fVIces or may deny your apphcat1011.
Case: 1:17-cv-07868 Document #: 1-1 Filed: 10/31/17 Page 2 of 2 PageID #:12
MRS ~;oiiii'HS A 11/~UIIS
Dear NEAL PRESTON,
'rvr.o.,nrv"'f1ence to: MRS Associates of New Jersey 1930 OLNEY AVE. CHERRY HILL, NJ 08003 877-851 -1451
Office Hours : Monday - Thursday 9am - 11pm ET Friday 9am - 8pm ET
CREDITOR: CHASE BANK
MRS ACCT#: LU4- 596
C REDITOR ACCT#: >00000000000<9-ACCOUNT BALANCE : 1
October 31,2016
We recognize that a possible hardship or pitfall may have prevented you from satisfying your obligation. We are presenting three options to resolve your balance. We are not obligated to renew this offer.
Option 1: You pay ONE PAYMENT to be received In this office on or before 11/14/2016.
Option 2: You make TWO PAYMENTS of$ .. each. The first payment to be received in this office on or before 11/14/2016 and the second payment on or before 12/14/2016.
Option 3: A monthly payment plan to pay the full balance of the account.
Payment may be made by calling 877-851-1451, mailing to the above address or by using our online payment website at h!.!Ps ://m~ebvi~.._corn (Internet connection requ1red)
When you call please let our representative know that you have received the CHASE BANK USA NA Option Letter.
Sincerely,
MRS Associates of New Jersey 877-851-1451 MI1C Associates of New Jersey Is a trade name of MRS BPO, L.L.C. LU4 2897598.7245739
This Is an altempt to collect a debt and any Information obtained will be used for that purpose. This communication Is from a debt collector.
If we settle this debt wtth )10U for leas than the full outstmlding balance, Chase may offer you less fiMnble terms In the future for some Chase products or services. a may deny your appltcallon.
Case: 1:17-cv-07868 Document #: 1-2 Filed: 10/31/17 Page 2 of 2 PageID #:14
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PRESORT FIRST CLASS
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HOV SERVICES
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Case: 1:17-cv-07868 Document #: 1-3 Filed: 10/31/17 Page 2 of 2 PageID #:16
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5-SFMRSA11 P6910E00406995 501853040 106996 Return Address MRS BPO. L L C 1930 OLNEY AVE CHERRY HILL, NJ 08003
LAGRANGE IL
PRESORT FRST-CLASS
U.S. POSTAGE & FEESPAO
HOV SERVICES
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"'''· 1•. n11 IIIIIJIIIpllo t.UIIt·t.l n IIIJIJI :u1rl :u1y h•lmrnntio11 cA>Iflhl(}(l will brJ lJ!'.(J(l for that purpose. I hi , l.C>~ nfllllflir ,ntloll 1· , lr<Jfl1 :1 clr;hl v.>llf:()or
II W'•'·lllll' ' rltl•. tlt·l rl wHit Y"" lex,,..,., lllrut llliJ 11111 Cilll •. lruttlhtfl h:ll:•nr:u, C llr•' ·'' rn:•y otf r,r you Jcy,r, fnvort.Jblo tr,rrnn In the future for some Chase products or .,,., vlt ,..,, or 11111y t ii•IIY yuw .1/tflllt 111lo11
STI 002wWP
Case: 1:17-cv-07868 Document #: 1-6 Filed: 10/31/17 Page 2 of 2 PageID #:22
.. .. 16. n
10 pay the fUll oalance of the account
7 ..ssl-1451. mmling to the above address or by using our online payrnu
1' that }'00 have received the CHASE BANK USA N .A. Option
name of MRS BPO, L.L.C.
tempt to collect a debt and . the run outst:~:nco~munic~~k:f~f~o~~ J:fi~~:;n be usEI(i
. g alance, Chase may ff or. o er you less f
Case: 1:17-cv-07868 Document #: 1-7 Filed: 10/31/17 Page 2 of 2 PageID #:24