Free Motion for Summary Judgment - District Court of Connecticut - Connecticut

Case 3:03-cv-00636-JBA

Document 35

Filed 03/29/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT EVELINE GOINS v. JBC & ASSOCIATES, P.C. ET AL. CASE NO. 3:03CV 636 (JBA)

March 29, 2004

PLAINTIFF' MOTION FOR PARTIAL SUMMARY JUDGMENT S Plaintiff moves for summary judgment against each defendant as to liability alone on the following violations which are undisputed or indisputable. The defendants violated the Fair Debt Collection Practices Act, 15 U.S.C. § 1692e and §1692f, and parallel state law in at least the following respects: Defendants drafted and sent a collection letter dated February 17, 2003 (1) even though they were not licensed to collect as required by Connecticut law; (2) even though they knew plaintiff was represented by counsel; (3) which demanded considerably more than any possible amount of the alleged debt; (4) which threatened to sue on a timebarred debt. THE PLAINTIFF

BY__/s/ Joanne S. Faulkner___ JOANNE S. FAULKNER ct04137 123 Avon Street New Haven, CT 06511-2422 (203) 772-0395 [email protected]

Case 3:03-cv-00636-JBA

Document 35

Filed 03/29/2004

Page 2 of 2

This is to certify that the foregoing was mailed on March 27, 2004, postage prepaid, to: Jonathan D. Elliot Sabatino Fiano P. O. Box 763 Southport CT 06490

____/s/ Joanne S. Joanne S. Faulkner

Faulkner___