Opinion
1:14-cv-06529
12-18-2014
MACKIE CAMPILLO, Plaintiff, v. STEVEN J. FINK & ASSOCIATES, P.C., Defendant.
Daniel J. McGarry, Esq. ARDC#6309647 Counsel for Plaintiff Sulaiman Law Group, LTD 900 Jorie Blvd, Ste 150 Oak Brook, IL 60523 Phone (630)575-8181 Fax: (630)575-8188
MOTION FOR PROVE-UP AND ENTRY OF JUDGMENT
NOW COMES the Plaintiff, MACKIE CAMPILLO ("Plaintiff"), by the undersigned attorneys, bringing this Motion for Prove-Up and Entry of Judgment against the Defendant, STEVEN J. FINK & ASSOCIATES, P.C. ("Defendant") pursuant to Federal Rule of Civil Procedure 58, and in support there of, stating as follows:
Background
1. On August 23, 2014, Plaintiff filed the instant complaint against Defendant. 2. Plaintiff brings this action against Defendant for violation of the Fair Debt Collection Practices Act, 15 U.S.C. § 1692, et seq. ("FDCPA"). Plaintiff alleges that Defendant violated the FDCPA § 1692i(a)(2) by improperly filing a debt collection lawsuit against Plaintiff in the First Municipal District of Cook County, a location in which Plaintiff neither resides nor signed the underlying contract. The lawsuit seeks statutory and actual damages. 3. Plaintiff seeks entry of a judgment amount against Defendant in the amount of $1,000.00 in statutory damages, plus $5,037.50 in costs and reasonable attorney fees as provided under 15 U.S.C. §1692k See Affidavit of Daniel J. McGarry, attached as Exhibit A.
WHEREFORE, Plaintiff MACKIE CAMPILLO, prays for an entry Judgment against Defendant, in the amount of $1,000.00 in statutory damages and $5,037.50 in costs and reasonable attorney fees. Dated: December 18, 2014
Respectfully Submitted,
/s/ Daniel J. McGarry,
Daniel J. McGarry, Esq. ARDC#6309647
Counsel for Plaintiff
Sulaiman Law Group, LTD
900 Jorie Blvd, Ste 150
Oak Brook, IL 60523
Phone (630)575-8181
Fax: (630)575-8188
CERTIFICATE OF SERVICE
I hereby certify that on December 18, 2014 I caused copies of Plaintiff's Motion for Prove-Up and Entry of Judgment to be filed pursuant to the Federal Rules of Civil Procedure and Local Rules with the Clerk of the United States District Court, Northern District of Illinois, using the CM/ECF system. Copies will be served by certified mail by depositing copies of the same, at 900 Jorie Blvd., Oak Brook, Illinois 60523, with proper postage pre-paid, upon the following: Steven J. Fink
Steven J. Fink and Associates P.C.
25 East Washington Street Suite 1125
Chicago, IL 60602
(312) 696-1000
Email: sfink26340@aol.com
/s/ Daniel J. McGarry
Daniel J. McGarry, Esq. ARDC#6309647
Counsel for Plaintiff
Sulaiman Law Group, LTD
900 Jorie Blvd, Ste 150
Oak Brook, IL 60523
Phone (630)575-8181
Fax: (630)575-8188