martin v cellco partnership tcpa fdcpa complaint illinois

8/12/2019 Martin v Cellco Partnership TCPA FDCPA Complaint Illinois

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Case: 1:12-cv-05147 Document #: 1 Filed: 06/27/12 Page 1 of 30 PageID #:1

IN T IED STATS DISTRICT COTFOR T NORTRN DSTRICT OF ILLINOS

EASTRN DISION

FILED

JUN 2 7 Z01

NICOAS MARTIN ))))))

OM G BRUTONCLE U.S DISCT COUR

Plan

vs

CLLCO PARTNERSHIP d/b/a VRIZON )WLSS; VANTAG SOURCING C; )MAC FINANCIA INC. d CRDIT )BUAU OF NAP A COUNTY INC. d/b/a )CAS RECEIVABLS )

Dendans

)))

cv54

JudgeRonaldA. GuzmanMagistrateSheilaM. Finnegan

COMPLAINT

INTRODUCTION

1. Plan Ncolas Marn proceedng pro se, brngs s acon o secure redress

agans dendans r volaon of e Telepone Consumer Proecon Ac 47 U.SC 227 e

seq ("TCPA) and mplemenng regulaons and orders ad e Far Deb Collecon Pracces

Ac 5 US.C. 692 e se. ("FDCPA). Plan also requess a s cour ssue a

declaraory uden

2. Plan alleges a a reless pone carrer aemped o cge plan es

a ere no conemplaed by ay of agreemen or conrac. Te reless pone carrer en

red deb collecors o volaed las n er aemps o collec a deb a asn' acually due

and ong


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JUISDICTION AND VENUE

3. This Curt hs der questn jurisdictin ver plintifs FDCPA d CPA

clims pursunt t 28 U.S.C. 1331. This curt hs supplementl jurisditin er pintifs

request r decrtry judent pursut t 28 U.S.C. 1367.

Venue is prper in ths District becuse the wrngl cts engged m by

dendnts ccurred n ths District.

PARTIES

5 Plnti s n ndvdul tht resides in the Nrthe District f Illns. Pintifs

cellulr teephne phne number s 630-xxx-3271

6. Dendnt Cec Prnershp d/b/ Verizn Wreless ("Verzn) is generl

prtnership rgnzed under the lws f the stte f Delwre. I is cmprised f tw prtners

Verizn Cmmunictins c. nd Vdne Grup PLC. Verizn prvides wireless

cmmunictin servces t businesses nd cnsmers. Verizns hedqurters re in Bedminster,

ew Jersey.

7. Dendnt Vntge Surcing, LLC ("Vntge Surcing) is debt cllectr s

tht term s dened by 15 U.SC 1692(6). It hs fces n Dthan, Albm.

8. Dendt Mirce Fincl, Inc ("Mrce Fnnc) is debt cectr s tht

term is dened by 15 U.S.C. 1692(6). I hs ces in Plyuth, Msschusetts.

9. Dendnt Credit Bureu f Np Cunty, Inc. D/B/A Chse Receivbles ("Chse

Receivbes) is debt cllectr s tht term is dened by 15 U.S.C. 1692(6). I hs ces n

Snm Clii.

FACTUAL ALLEGATIONS

10. On Febrry 12, 2011, pinti entered int n greement with Verzn t prvide

wireless serice r his wn persnl use.

2


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11 Accoding o he e of he ageemen beween paini d Veizon, paini

wa enied o ccel he enie ageemen wihin 30 day of acivaing evice

Yo c ccel (if youe a new come and no aming anohe come

eice) WTHN 30 DAYS of acceping. Yol i be eponible hough hadae he new eice d any chage aociaed wih i

12 Unaied wih he eice povided by Veizon, plaini canceled hi cellua

eice on Mach 8, 2011, by poing hi phone nmbe o ohe wiele caie

13 On Mch 9 2011, plaini mailed a ee o Veizon coning ha he had

canceled hi evice along wih he nal pamen on he accoun Exhibi A

1 Accoding o he Unied Sae Poa Seice, Veizon eceived plaini lee

on Mach 11, 2011. Exhibi B

15. Paini encoed a deaied iemizaion of he chage he wa eponibe

unde he ageemen

16 Veizon depoied plainif nal pamen check and he nd ceed plainif

checking accon

1 7. ligh of he above c, paini h cceled he enie ageemen wih

Veizon.

18 n he Mach 9, 2011, lee, paini ao expely evoked any conen he migh

have povided o Veizon o ca hi cell phone nmbe

Peae emove my cell phone numbe, 630-xxx-3271, om yo daabae a I dono wih o eceive phone call egading hi accon Pleae diec al ue

coepondence o he po ofce box adde have lied aop hi ee

19 Nowihanding he c ha plaini led he em of he ageemen,

Veizon en invoice o paini daed Mach 16, 2011, which aemped o chage paini an

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"early temination e in the amont of $30 a "retocking e adjtment in the amont of

$35, and vario taxe compted baed on the aement of thee additiona charge

20 Plainti and Veizon never ageed to the aement of ch e.

VERIZON PLACES THE ACCOUNT WITH VANTAGE SOURCING

21 Veizon aied the alleged debt r coection with Vantage Socing in or

abot March or Api 2011.

22 ny ch debt that Vantage Sorcing wold have been attempting to colect

wold have been incred r peronal fiy, or hoehod ppoe

23 Vantage Sorcing e one or more "predictive diaer a that term i dened by

the Federal Commnication Commiion

2 Vantage Sorcing predictive dialer ha the capacity to dia phone nmber

withot hman intervenion

25 Vantage Sorcing predictive dialer ha the ability to play a meage that ha

been recorded ahead of time ding a connected phone call.

26 Vantage Socing' predictive dialer i an "atomatic telephone iaing ytem

a that te i dened by the TCPA d the Federal Commnication Comiion

27 n April 2011, Vantage Sorcing beg pacing call to painti ce phone

28 Vantage Sorcing placed telephone ca to plaintif ce phone nmber 630

xxx-3271 on at leat the llowing occaion (all time are in CST):

a 0/21/2011 17:6

b 0/23/2011 20:8

c 0/27/2011 12:50

d 0/29/2011 11:19

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e. 05/03/2011 155

f 05/05/2011 1615

g 05/07/2011 153

h. 05/10/2011 112

1 05/12/2011 115

J 05/1/2011 1717

k 05/17/2011 1829

06032011 11

m. 06/06/2011 1156

n. 06062011 18 1

0. 06/08/2011 1551

p 06/10/2011 1206

q. 06/13/2011 1605

06/15/2011 136

s. 06/17/2011 113

t 06/17/2011 1619

06212011 11 02

v. 06/23/2011 101

w 06282011 1101

29 The above i of call Vtage Socing placed o plainti i not inclive Thee

may be othe ca tha will be acetained thogh dicovey.

30 On inmaion and beief, Vantage Socing ed one of hei pedicive diae

to make each of he phone ca to plaini lited above

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31 A hman being did not manally dia the call that Vtage Sorcing placed to

plaintif ce phone

32 Vantage Socing payed a meage dring it phone ca to painti that had

been recorded ahead of time

33 Vantage Sorcing tilize technoogy which aow r the inetion of "articia

oice in the meage it payed dring it phone call to painti

3 A of the ca that Vtage Socing placed to painti cell phone were made

withot plainti conent

35 All of the meage played by Vtage Socing ding their phone cal to

plainti did no properly identiy the caer' identity Thi wa the cae on the Jne 28 2011

phone ca

36 A of the meage payed by Vtage Sorcing ding their phone call to

plainti iled to dicloe that the commnication wa om a debt colector Thi wa the cae

on the Jne 28, 2011 phone call

37 Vtage Sorcing mailed a etter dated May 16, 2011, to plainti which

attempted to collect aleged debt owed to Veizon in the amont of $57 73 Painti receied

thi etter on May 19 2011.

38 Painti dipted the aeged debt ia a letter ent to Vtage Sorcing on Jne

10, 2011. Exhibit C

39 According to the United State Potal Seice Vtage Sorcing receied thi

etter on Jne 13, 2011 Exhibit D

40. the letter plainti tated:

am in receipt of yo coection notice dated May 16 2011. dipte the alidityof the alleged debt Pleae tate with pecicity how yo aied at the amont

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you claim owe. f you contend that owe money an ealy termination e,pleae povide a copy of the ageement that enteed into that provide uch ae

Pleae direct all ture corepondence to the addre lited atop thi letter

1 Notwithtding the ct that Vatage Sourcing wa in receipt of plaintif debt

dipute and had not yet povided validation of the alleged debt, Vantage Soucing continued to

place collection call to plainti cell phone a pecied in call q-w pecied in paagaph 28

of thi complaint

2 Vantage Soucing ent a lette to plainti dated June 28, 2011 The letter'

potmk indicated a date of June 29 2011

3 Plainti received thi letter on July 2 20

The June 28, 2011 lette tated, among other thing

Our ofce ae in receipt of you letter of dipute d equet vericationpuruat to 15 USC 1692g of the Fai Debt Collection Pactice Act Pleae beadvied we have contacted our client, Verizon Wirele, who ha invetigatedyour claim and credit have been applied to your account The coected balance ilited below addition, pleae nd rthe proof of the debt attached

5 Vtage Sourcing tated that the new debt amount wa $5993 The lette doe not

tate how the alleged debt wa reduced om $5773 to $5993

6 Encloed with the letter wee two account tatement om Veizon dated March

16 2011 d Februy 16 2011 Vantage Soucing highlighted in yellow cerain gure om the

tatement but thoe gure do not add up to $5993

7 Plainti wa coned a to Vtage Soucing' explanation of the new alleged

debt amount.

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VEIZON PLACES THE ACCOUNT WTH MIRACLE FNANCAL

48 Verzon assigned the aleged debt r colecton with Miracle Financial in or

about July 2011

49 Any suc debt tat Mirace Fnacia would have been attemptng to colect

would have been incurred r personal miy or household purposes

50 Miracle Fnanca sent a etter dated July 28 2011 to plaint to colect an

alleged debt owed to Verzon n the ount of $7311

51 Plant received this ltter on August , 2011

52. the letter Mracle Fnancal clams tat there s a prncipal balance due of

$5993 and "VZW collection es due n te ount of $1318

53 Such a e equals approxmately 22 percent of the alleged prncipal balance due.

54 Mracle Financial was not entitled or authorized to charge or attempt to collect

such a e.

55 Plant sent a etter of dspute to Miracle Fnanca on August 18 2011.

56 Paint did not receive a etter om Mirace Financa wic valdated the debt.

57 Upon nrmaton d beief Mracle Finca did not send a valdation letter to

plainti

VERIZON PLACES THE ACCOUNT WITH CHASE RECEIVABLES

58 Verzon assed te aleged debt r colecton wth Case Receivabes in or

about Juary or Febrary 2012

59 Any suc debt that Chase Recevables woud have been attempting to colect

would have been incued r persona mly or household puoses.

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60 Chase Receivabes uses one or more "predictive dialers as that te is dened by

the Federal Communications Commission

61. Chase Receivabe's predictive diaer has the capacity to dia phone numbers

without human intervention.

62 Chase Receivabes predictive diaer has the ability to play a message that has

been recorded ead of time during a connected phone call

63 Vantage Sourcings predictive dialer is an "automatic teephone dialing system

as that term is dened by the TCPA d the Federa Counications Commission

64hase Receivables placed teephone cas to plaintis cl phone number 630

xxx-3271 on at east the llowing occasions (a times are in C.ST.):

a. 02/02/2012 11:40

b 02/03/2012 0822

c 02/04/2012 10:19

d. 02/06/2012 08:32

e 02/07/2012 19:22

f 02/09/2012 10:27

g. 02/10/2012 1738

h 02/11/2012 11:19

1. 02/14/2012 1013

J. 02/15/2012 08:11

k 02/16/2012 10:59

65. The above list of cals that Chase Receivables paced to painti is not inclusive

There may be other calls that wi be ascertained through discovery

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66 On naton and belef, Chae Recevable ed one of the pedctve dale

to make each of the phone ca to plant lted above

67 A hman beng dd not manally da the ca that wee paced to plantf cell

phone ted above.

68 Chae Recevable payed a meage dng t phone ca to pant that had

been ecoded ahead of tme

69. Chae Recevabe tzed technology whch allow the neton of "atcal

voce n the meage t payed dng t phone call to plant

70.Al of the call that Chae Recevabe paced to pantf cel phone wee made

wthot plantf conent

71 Al of the meage played by Chae Recevable dng the phone call to

plant dd not dentfy the calle' dentty

72 Plant dd not eceve a notce om Chae Recevable whch explaned the

amont of the debt d the cedto to whch the alleged debt wa owed

73. Upon nmaton d belef, Chae Recevabe neve ent a notce to pant

whch explaned the amont of the debt d the cedto to whch the aeged debt wa owed

COUNT I FAIR DEBT COLLECTION PRACTICES ACT (AGAINST VANTAGESOURCING)

74. Pant ncopoate paagaph 1 - 73 above.

7 5The FDCPA, 15 USC 1692e povde, n petnent pat:

A deb coecor may no engage in any conduc he naura consequence ofwhich is o harass, oppress, or abuse any person in connecion wih he

coecion of a deb Wihou imiing he genera appicaion of he regoing,

he owing conduc is a vioaion of his secion:

***

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(6) Except as provded n secton 1692 of ths ttle, the placement of

telephone calls wthout meanngful dsclosure of the caller's dentty

76. Dendt Vantage Sourcing violated 15 SC 1692e(6) when it placed

telephone calls to plainti and did not disclose the actual identity of the caller

WHEFOE, the Court should enter judent in vor of plainti and against

dendant Vantage Sourcing r:

a. Statutory damages

b. Attoeys es, litigation expenses and costs of suit

c. Suchother d rther relief as the Court dees proper.

COUNT II FAIR DEBT COLLETION PRACTICES ACT AGAINST VANTAGESOURCING)

77 Plainti incoorates paragraphs 1 73 above

78. The FDCPA, 15 USC 1692e, provides, in pertinent pt:

A debt collector may not use any flse, deceptve, or msleadng

representaton or means n connecton wth the collecton of any debtWthout lmtng the general applcaton of the regong, the fllowngconduct s a volaton of ths secton:

***

() The flure to dsclose n the ntal wrtten communcaton wth theconsumer and, n addton, f the ntal communcaton wth the consumer s

oral, n that ntal oral communcaton, that the debt collector s attemptngto collect a det and that any nrmaton otaned wll e used r thatpurpose, and the flure to dsclose n subsequent communcatons that the

communcaton s om a debt collector, except that ths paragraph shall notapply to a frmal pleadng made n connecton wth a legal acton

79 Dendant Vtage Sourcing violated 15 USC 1692e() when it placed

elephone calls to plainti and played prerecorded messages which did not contain the waing

required by 15 USC 1692e(l 1).


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HRFO, the Cor shod enter dgment m vor of plant d against

dendant Vtage Sorcing r

a Stattory dages

b Attoeys es, ltgation expenses d costs of st

c. Sch other and rther relef as the Cort deems proper

COUNT III FAIR DEBT COLLECTION PRACTICES ACT AGNSTVANTAGESOURCING)

80. Plant incorporates paragraphs 1 - 73 above.

81. The FDCPA, 15 USC 1692g(b ), provides, in pernent part:

(b) Dispued debs

If he consumer noies he deb coecor in wriing wihin he hiryday

period described in subsecion (a) of his secion ha he deb, or any porionhereof, is dispued, or ha he consumer requess he name and address of

he origina credior, he deb coecor sha cease collecion of he deb, orany dispued porion hereof, uni he deb collecor obains vericaion ofhe deb or a copy of a judgmen, or he name and address of he originacredior, and a copy of such vericaion or judgmen, or name and address of

he original credior, is maied o he consumer by he deb coecorCoecion aciviies and communicaions ha do no oherwise vioae his

subchaper may coninue during he 30day period referred o in subsecion.

82 Dendant Vtage Sorcng voated 15 USC 1692g(b) when t did not cease

collection of the debt aer t was n recept of paints dspte of debt d reuest r

verication letter

HRFOR, the Cort shold enter jdgment m vor of plant d against

dendt Vantage Sorcng r:

a Stattory dages

b Attoeys es, ltigaton expenses d costs of sit

c. Such other and rther relef as the Cor deems proper

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COUNT I FAIR DEBT COLLECTION PRACTICES ACT AGAINST MIRACLEFINANCIAL)

83 Paini incopoaes paagaphs 1 73 above

84 The FDCPA, 15 SC 1692f, povides, in peinen pa:

A deb coecor may no use unir or unconscionabe means o coec or

aemp o coec any deb. Wihou imiing he genera appicaion of he

regoing, he owing conduc is a vioaion of his secion:

() The coecion of any amoun (incuding any ineres, e, charge, orexpense incidena o he principa obigaion) uness such amoun is expressyauhored by he agreemen creaing he deb or permied by aw.

***

85 Dendan Miacle Financial violaed 15 SC 1692f() when i aemped o

collec VZW coecion es in he oun of $13.18

WHEFOE, he Cou shoud ene udgmen m vo of paini and agains

dend Miacle Financia :

a. Sauoy dages;

b. Aoeys es, liigaion expenses d coss of sui;

c Such ohe d he elief as he ou deems pope

COUNT V FAIR DEBT COLLECTIN PRACTICES ACT AGAINST CHASECEIVABLES)

86. Paini incooaes paagaphs 1 73 above

87 The FDCPA, 15 SC 1692e, povides, in peinen p

A deb coecor may no engage in any conduc he naura consequence of

which is o harass, oppress, or abuse any person in connecion wih hecoecion of a deb. Wihou imiing he genera appicaion of he regoing,he owing conduc is a vioaion of his secion:

***

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(6) Excep as provided in secion 1692b of his ile, he pacemen ofelephone cas wihou meaningfu discosure of he caller's ideniy

88. Dendant Chase Receiables iolated 15 USC 692e6) when it placed

telephone calls to plainti d did not disclose the actual identity of the calle

WHEREFORE, the Cout should ente udgment in o of plainti and against

dendt hase Receiables

a. Statutoy damages

b. Attoeys es, litigation expenses and costs of suit

c Such othe and the elief as the Cout deems pope

COUNT VI - TELEPHONE CONSUMER PROTECTION ACT AGAINSTVERIZOND VANTAGE SOURCING)

89. Plainti incooates paagaphs 3 aboe.

90. The TCPA, 4 US.C. 22 poides in petinent pat

(b) Resricions on use of auomaed eephone equipmen

(1) Prohibiions I shall be unlawfu r any person wihin he Unied

Saes, or any person ouside he Unied Saes if he recipien is wihinhe Unied Saes-

(A) o make any ca (oher han a cal made r emergency purposesor made wih he prior express consen of he called pary) using anyauomaic elephone diaing sysem or an aricial or prerecorded

voice***

(iii) o any eephone number assigned o a paging service, celuar

eephone service, specialized mobie radio service, or oher radiocommon carrier service, or any service r which he called paryis charged r he ca;

9. Vantage Soucings phone calls to plaintis cell phone iolated the TCPA

because they wee made using an automatic telephone dialing system d used both an aticial

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and prerecorded voce Te pone calls to pants cell pone were not made r emergency

purposes and tey were not made wt te pror express consent of plant

92 Verzon s aso abe r te cas tat Vantage Sourcng placed on ts beaf

wc volate te TCPA "Calls placed by a trd py colector on beaf of tat credtor are

treated as f te credtor tself paced te cal In re Rules and Regulations Implementing the

Telephone Consumer Protection Act of1991, GC Doc. 02 278 23 FCC Rd. 559 (Jauary 4

2008)

93 Upon nrmaton and beef Verzon was aware tat Vantage Sourcng would

utze predctve daers and atcal d prerecorded voce wen pacng pone cas to colect

debts alegedy owed to Verzon

94 Te dendants' cals were neglgent or ateatvey tey were wll 47

U.SC 32((1)

95 Pant was damaged as a resut of dendants' pone calls He was needlessy

botered and was rced to utze mnutes om s cel pone plan's alotted mnutes wc

could ave been used r oter puoses.

WHEREFORE pant requests tat te Court enter judgment n vor of msef and

aganst dendts Vantage Sourcng d Verzon tat provdes te lowng reef

a Statutory dages of $500 per voaton and up to $500 per volaton f

proven to be wll;

b A permanent njuncton probtng dendts om volatng te TCPA

n te ture troug cang cellular pones usng automatc telepone dalng

system and/or a prerecorded voce message; d

c Any oter reef te Court nds just ad proper

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COUNT VII - TELEPHONE CONSUMER PROTECTION ACT AGAINST VERIZONAND CHASE RECEIVABLES)

96 Plant ncorporates paragraphs 1- 3 above.

9 The TCPA, U.S.C 22 provdes n pertnent pt:

(b) Restrictions on use of automated telephone equpment

(1) Prohibitons.It sha be unawful r any person withn the UnitedStates, or any person outsde the Unted States f the recpent is wthinthe Unted States

(A) to make any cal (other than a call made fr emergency purposesor made with the pror express consent of the called party) using any

automatic telephone daing system or an artcial or prerecordedvoice-***

() to any teephone number assigned to a pagng service, celluartelephone service, specialzed mobie radio servce, or other rado

common carrer servce, or any servce fr whch the caed party

is charged r the call; ...

98 Chase Recevables phone calls to plants cell phone volated the TCPA

because they were made usng automatc telephone dalng system and used both an artcal

d prerecorded voce. The phone calls to plants cell phone were not made r emergency

puoses and they were not made wth the pror express consent of plant

99 Verzon s also lable r the calls that Chase Recevables placed on ts behalf

whch volate the TCPA. "Calls placed by a thrd party collector on behalf of that credtor are

treated as f the credtor tself placed the call. In re Rules and Regulations Implementing the

elephone Consumer Protection Act of1991, GC Doc. 02 28 23 FCC Rd. 559 (Juary

2008)

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100 Upon nrmton d beef, Verzon ws we tht Chse Recevbes wuld

utlze predctve ders d cl d prerecorded voce when pcng phone cs to coect

debts egedy owed to Verzon

101 The dendts' cls were neglgent or ltetvey the were wl 47

u.sc 312((1)

102 Plnt ws dmged s resut of dendts' phone cls He ws needessly

bothered nd ws rced to utlze mnutes om hs cell phone ps otted mnutes whch

coud hve been used r other puoses

WHEREFORE pnt requests tht the Court enter judgment n vor of hmself d

gnst dendnts Chse Recevbes d Verzon tht provdes the llowng reef:

Sttutory dmges of $500 per voton d up to $1,500 per voton f

proven to be wl;

b A perment nuncton prohbtng dendnts om voltng the TCP A

n the ture trough cllng cellulr phones usng n utomtc telephone dng

system nd/or prerecorded voce messge; nd

c y other relef the Court nds just d proper

COUNT VIII DECLARATORY ACTION AGAINS VERIZON)103 Pnt ncoortes prgrphs 1 73 bove

104 There exsts n ctu controversy beween Plnt nd Verzon

105 Plnt beleves he hs led the terms of the eement wth Verzon d no

rther pyments to Verzon should be mde

106 Verzon contnues o ssert tht debt exsts I hs hred debt colectors nd hs

reported the lleged debt to consumer reporng gency

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EEFOE plainti rqusts tat t Curt ntr udnt in vr f imslf and

against dndt Vrizn tat prvids t lwing rlif

a A dclaratin tat plainti as llld t trms f t agrmnt d

ds nt w mny t Vrizn

b. Any tr rlif t Curt nds just and prpr.

spctlly Submittd,

Niclas MartinPro Se

PO Bx 4030Cicag L 60654-4030(32) 25-903

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JURY DEMAND

Plainti demands ial by jy r all cs so iableNicholas Main


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Exhibit A


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NICHOLAS MARTI

PO BOX 4030

CICAGO IL 60654-400 I f 1006 260 0002 9228 0823

VERIZON WIRELESS OPERATIONS SUPPOR

777 BIG TIMBER RD

ELGIN IL 60123-1488


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Mrch 9, 2011

Nicos MartiPO Box 4030

CicgoIL 60654-4030

SENT VIA USPS CERTIFIED MAIL- 7006 2760 0002 9228 0823

Verizo Wireess Operatios Suppor777 Big Timer RdElgi I 60123-1488

Accout#28664459000001

adies ad Getleme:

te to dvise you tt I ve cnceed my ccount wit your compny. I avecceled my ccout due to poor customer service adprolems I ve exprieced wit

my Backey device

Icluded with tis leter is my l paymet r tis ccout Attched please d clcultio t prortes my moty serice chrges

My Blckerry telepoe (Bold 9650 I MED HEX #: A000005945492) d SIM crd(Seril# 064i0108931440337615529734) re eig reted vi FedEx to

VZWC/O

New BreedCorportio4801 Merctile DrFt Worh, TX 76000

The trackig umer is: 874973588852

I ave take pictures of the Blackberry device s evidece o its excellet physicalcoditio

Plese remove m cell poeumer, 6304793271 om yor dtase s I do ot wishto receive phoe clls regrdig tis ccout Pese direct ll tue correspodece tote post ofce ox address I ave listed top this letter

Sicerey,


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Verizon Wireless Account#: 286644590-00001

Service activated on February 6, 20Service canceled on March 8 201

Days of Servce28 Days in Blling Cycle

2/28 = 75% Prorated Amount

450 Minutes and Unimited Texts

8% DiscountE-Mai and Internet20% DiscontVisal Voice MalMonth Access CaeFederal Univesal Servce haeRulato haeAdministratve haeVrizn Wrl Sura

hicago 9 FeeIllinos State Telecom Excse Taxhica_o MTTTaxes and Govrnmenta SurchasTotal Monthy Charge

Monthl Char es Prorated Amont

$59.99 $4499

$080 -$8.10

$2999 $22.49

-$6.00 -$450

$2.99 $2.24

$76.17 $57.13

$6 $0.87

$0.13 $0.$0.83 $062

$2.12 $59

$250 $1.8

$639 $479

$6.39 $4.79

$1528 $11.46

$93.57 $7018


24/30


Exhibit B


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UNITE SJPOst1i 'ERVwDate: 03/11/2011

Nicholas Marin

The followig is in response o your 03/10/2011 request for delivery information on youCerified Mai(M) item number 7006 2760 0002 9228 0823. he deivery record shows thattis item was deivered on 03/11/2011 a 0924 AM in ELGIN, IL 60123 to C BOYD. hescanned image of the recipient infrmaion is provided below.

_,

Sigature of Recipien

, .

Address of Recipient:

. :.,r

hak you fr selecing the Postal Service for your mailing needs. If you require additionalassistance, please conac your local Post Oice or postal representative.

Sinceey

United States Postal Service


26/30


Exhibit C


27/30


28/30


June 10, 2011

Nicholas MartinPO Box 4030Chicago, IL 60654-4030

SENT VIA USPS CERTIFIED MAIL #7006 2760 0002 9227 6543

RETURN RECEIPT REQUESTEVatage Sourcing LLC328 Ross Clrk CircleDotn AL 363035834

Vntage Sourcing Account#: 1028886

Ladies a Getleme:

am i eceipt of yor collectio otice ated May 16 201. I ispute the valiity of theallege debt Please state with specicity how you arrive at the amount you claim owe.f you conten that owe money r an ery termination fee pease provie a copy of theagreement that entere into that provies r sch a e

lease irect all ture correspondence to the adress liste atop this letter.


29/30


Exhibit D


30/30

martin v cellco partnership tcpa fdcpa complaint illinois

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