invasion of privacy under the doctrine enunciated in
Fernandez v.United Acceptance Corporation
, 610 P.2d 461 (Ariz. App. 1980).Defendant also took affirmative actions and converted to its ownuse property which belonged to Plaintiffs. Plaintiffs seek to re-cover actual damages, statutory damages, and punitive damages,as well as reasonable attorney’s fees and costs.
2.Jurisdiction of this Court, over this action and the parties herein,arises under 15 U.S.C. § 1692k(d) (FDCPA), and 28 U.S.C. § 1331.Venue lies in the Phoenix Division of the District of Arizona asPlaintiffs’ claims arose from acts of the Defendant perpetratedtherein.
3.Plaintiffs, Michael Collier and Kim Collier-Dingman, reside inMaricopa County, Arizona.4.Michael and Kim are natural persons obligated to pay a consumerdebt.5.Michael and Kim are “consumers” as that term is defined byFDCPA § 1692a(3).6.Defendant Gurstel Chargo, P.A. (“Gurstel”) is a Minnesota profes-sional corporation doing business within the state of Arizona as athird party debt-collection law firm.7.Gurstel uses Arizona licensed attorneys and Minnesota legalassistants to collect or attempt to collect debts owed or assertedto be owed or due another.
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Case 2:12-cv-02161-BSB Document 1 Filed 10/10/12 Page 2 of 8