WILLIAM KOVACIC
General Counsel .
GREGORY A. ASHE
SEENA D. GRESSIN
KAREN S. HOBBS
Federal Trade Commission
600 Pennsylvania Avenue
Washington, DC 20580
202-326-3719
GA 8431
CHRISTOPHER J. CHRISTIE
United States Attorney
MICHAEL A. CHAGARES
Chief, Civil Division
970 Broad Street, 7th Floor
Newark, NJ 07102
(973) 6452700
MC 5483
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW JERSEY
FEDERAL TRADE COMMISSION, 600 Pennsylvania )
Avenue, NW, Washington, DC 20580 1
1
Plaintiff,
V. i Civil No.
>
CHECK INVESTORS, INC., 55 Hartz Way, Suite 202, )
Secaucus, New Jersey 07094; CHECK ENFORCEMENT, )
INC., 55 Hartz Way, Secaucus, New Jersey 07094, )
JAREDCO, INC., Harmon Cove Tower One, Suite AL-13, )
Secaucus, New Jersey 07094, BARRY S. SUSSMAN, )
340 Slocum Way, Fort Lee, New Jersey 07024-463 1, )
ELISABETH M. SUSSMAN, 340 Slocum Way, Fort Lee, )
New Jersey 07024, and CHARLES T. HUTCHINS, 1
5011 Marshall Road, Farmingdale, New Jersey 07727, )
1
Defendants. )
COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission ("FTC"), for its Complaint alleges:
SNIPPETS:
United States Attorney
5011 Marshall Road, Farmingdale, New Jersey 07727,)
The FTC brings this action under Section 13of the Federal Trade Commission
Act, 15 U.S.C. 8 53, and Section 814 of the Fair Debt Collection Practices Act
relief, rescission of contracts, restitution, disgorgement, appointment of a receiver, and
the FDCPA, 15 U.S.C. $ 1692 et seq..
This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.
Venue in the District of New Jersey is proper under 28 U.S.C. $6 1391and
Defendant CHECK INVESTORS, INC., d/b/a National
Check Control, is a New Jersey corporation with its principal place of business at 55 Hartz
Suite 202, Secaucus, New Jersey 07094.
Cove Tower One, Suite AL-13, Secaucus, New Jersey 07094, and its previous corporate name
was "Check Enforcement is Not a Collection Agency,
transacts or has transacted business in the District of New Jersey.
Defendant JAREDCO, INC., d/b/a Goldman & Co., is a New Jersey
At all times material to this Complaint,
Defendant BARRY S. SUSSMAN is or has been the vice president
and director of defendant Check Investors, and the president of defendants Jaredco, and Check
Hutchins is or has been general counsel to corporate defendants Check Investors,
course of trade in the collection of debts, in or affecting commerce, as "commerce" is
Hutchins, engage in the collection of debts for consumer
NCC operated as Jaredco, d/b/a Goldman & Co., from 1995 through about August
NCC purchases at a substantial discount NSF checks from large commercial
consumers every month to collect payment.
NCC collects payment for NSF checks through dunning letters and telephone calls
NCC attempts to collect debts in an amount that equals the face value of the
On numerous occasions, in dunning telephone calls to consumers or third parties,
remedy, in violation of section 805of the FDCPA, 15 U.S.C. 0 1692c.
(0 Using false representations or deceptive means to collect or attempt to
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