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And now for something completely different:  Lemke v. Escallate, LLC, No. 17-cv-5234 (N.D. Ill. Mar. 19, 2019).  Although some case law out of Illinois may make one question whether to collect debts there, this case illustrates that just because a consumer may state a plausible claim doesn’t mean they can always prove it. In October 2016, the Plaintiff, Laura Lemke, got a collection letter from Escallate, LLC, for a $1225.00 debt.  The letter listed the…
The plaintiff in Mollberg v. Advanced Call Center Technologies, Inc., No. 18-1210, 2019 WL 288128 (E.D.Wis. Jan. 22, 2019) received a letter from Advanced Call Center Technologies (which I’ll refer to as ACCT) that attempted to collect a debt owed to Synchrony Bank.  The letter said that the “Total Account Balance” was $1,113.00 and that the “Amount Now Due” was $234.00.  Even though the letter didn’t itemize it, the “Amount Now Due” was the sum of the…
The least sophisticated consumer doesn’t need everything spelled out for him.  Or at least that’s what the Eleventh Circuit held recently in Conde v. Webcollex, LLC, No. 18-12551 — another case where a court finds that something means exactly what it says. The plaintiff in Conde filed suit after he got a validation letter from Webcollex telling him that: Unless you notify this office within 30 days after receiving this notice that you dispute the validity…