Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Save to My Library
Look up keyword
Like this
0Activity
0 of .
Results for:
No results containing your search query
P. 1
Vanderpool v Sentinel Real Estate Fair Collections Outsourcing OCSPA FDCPA Highland Park Apartments Reynoldsburg

Vanderpool v Sentinel Real Estate Fair Collections Outsourcing OCSPA FDCPA Highland Park Apartments Reynoldsburg

Ratings: (0)|Views: 13 |Likes:
Published by ghostgrip

More info:

Published by: ghostgrip on Aug 24, 2013
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

12/17/2013

pdf

text

original

 
 1
IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION
Deborah Vanderpool f/k/a Deborah Whitehead, 6548 Creon Drive Reynoldsburg OH 43068 Plaintiff, v. Sentinel Real Estate Corporation, c/o CSC-Lawyers Incorporating Service 50 W. Broad St., Suite 1800 Columbus, OH 43215 Fair Collections & Outsourcing, Inc., 12304 Baltimore Ave., Suite E Beltsville, MD 20705 Defendants. Civil Case Number: 2:13-cv-474 Judge: Magistrate Judge:
COMPLAINT FOR MONEY DAMAGES AND OTHER RELIEF JURY DEMAND ENDORSED HEREIN I. PRELIMINARY STATEMENT
1.
 
Plaintiff Deborah Vanderpool f/k/a Deborah Whitehead institutes this action for actual damages, statutory damages, attorney fees, and the costs of this action against Defendants Sentinel Real Estate Corporation and Fair Collections & Outsourcing, Inc. for violations of the Fair Debt Collections Practices Act, 15 U.S.C. 1692,
et seq.
, (hereinafter “FDCPA”
) and for violations of
Ohio’s Consumer Sales Practices Act, R.C. 1345.01,
et seq.,
(hereinafter
“CSPA”)
.
 
Case: 2:13-cv-00474-GLF-TPK Doc #: 1 Filed: 05/17/13 Page: 1 of 8 PAGEID #: 1
 
 2
II. JURISDICTION
2.
 
This Court has jurisdiction for the First Count pursuant to the Fair Debt Collections Practices Act, 15 U.S.C. 1692k(d), and 28 U.S.C. 1331 and 1337. 3.
 
This Court has supplemental jurisdiction over the state law claims pursuant to 28 U.S.C. 1367.
III. PARTIES
4.
 
Plaintiff
Deborah Vanderpool f/k/a Deborah Whitehead (“Ms. Vanderpool”)
, is a natural  person currently
residing within this Court’s jurisdiction at
 6548 Creon Drive, Reynoldsburg, OH 43068. 5.
 
Ms. Vanderpool was a natural person allegedly obligated to pay a debt at all times relevant to this transaction. 6.
 
At all times relevant to this transaction, Ms. Vanderpool was and is a
Consumer
 within the meaning of 15 U.S.C. 1692a(3). 7.
 
Ms. Vanderpool is and was engaged in a consumer transaction with a supplier at all times relevant to this transaction. 8.
 
At all times relevant to this transaction, Ms. Vanderpool was and is a
Consumer
 within the meaning of R.C. 1345.01(D). 9.
 
Defendant Fair Collections & Outsourcing, Inc.
(“FCO”)
 is a company with its principal  place of business in the State of Maryland. 10.
 
FCO regularly engaged in collecting on the account of another, at all times relevant to this transaction. 11.
 
At all times relevant to this transaction, FCO was and is a
Debt Collector
within the meaning of 15 U.S.C. 1692a(6).
Case: 2:13-cv-00474-GLF-TPK Doc #: 1 Filed: 05/17/13 Page: 2 of 8 PAGEID #: 2
 
 3
12.
 
FCO is and was engaged in the business of soliciting and/or effecting consumer transactions at all times relevant to this transaction. 13.
 
At all times relevant to this transaction, FCO was and is a
Supplier
within the meaning of R.C. 1345.01(C). 14.
 
Defendant Sentinel Real Estate Corporation
(“Sentinel”)
is a company incorporated under the laws of New York. 15.
 
Sentinel is the successor and/or parent c
ompany of Highland Park Apartments (“Highland”), Ms. Vanderpool’s former landlord.
 16.
 
FCO acted as Sentinel’s agent in its attempts to collect Ms. Vanderpool’s alleged debt.
17.
 
Sentinel is and was vicariously liable for the actions of FCO, at all times relevant to this transaction.
IV. FACTUAL ALLEGATIONS
18.
 
Ms. Vanderpool incorporates all preceding paragraphs as though fully rewritten here. 19.
 
Each action or inaction alleged herein against any Defendant is also an allegation of action or inaction by
that Defendant’s
 agents, predecessors, successors, employees, contractors, assignees, and servicers, as appropriate. 20.
 
The actions that gave rise to this lawsuit took place within this Court’s jurisdiction.
 21.
 
On or around October 31, 2011, Ms. Vanderpool moved out of an apartment that she rented from Highland, located at 2556 Prendergast Place, Apt. 2556, Reynoldsburg, Ohio 43068
(the “Apartment”)
. 22.
 
On or around November 3, 2011, Highland sent Ms. Vanderpool a letter (attached as Exhibit A) indicating that there was damage to the carpet in the Apartment from pet urine and that
Case: 2:13-cv-00474-GLF-TPK Doc #: 1 Filed: 05/17/13 Page: 3 of 8 PAGEID #: 3

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->