IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN … -6- and Ninth Circuits, and the United...

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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF WISCONSIN

GREEN BAY DIVISION

JESSICA SMITH,

on behalf of plaintiff and a class,

Plaintiff,

vs.

SIMM ASSOCIATES, INC.,

Defendant.

) ) ) ) ) ) ) ) ) ) ) )

Case No.: 1:17-cv-00769-WCG

DECLARATION OF ANDREW T. THOMASSON IN SUPPORT OF PLAINTIFF’S

RENEWED MOTION FOR CLASS CERTIFICATION

I, Andrew T. Thomasson, of full age, hereby certify as follows:

1. I am an attorney at law of the State of New Jersey and I am admitted to practice

before the bar of this Court. My law firm, Stern•Thomasson LLP, is co-counsel for Plaintiff,

Jessica Smith, in this action. I submit this Declaration in support of Plaintiff’s Renewed Motion

for Class Certification. I am familiar with all the facts set forth herein and state them to be true

based upon my own personal knowledge.

2. Stern•Thomasson LLP was formed on July 1, 2015, when Philip D. Stern, Esq.

and I merged our respective solo consumer law practices. The newly formed law firm’s principal

practice area remains focused on representing plaintiffs in class action litigation involving

various state and federal consumer protection statutes. In that regard, Stern•Thomasson LLP

consists of two principals, Philip D. Stern and me, and one associate, Heather B. Jones; our

professional experience is set forth below.

Case 1:17-cv-00769-WCG Filed 10/31/17 of 10 Document 35

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PROFESSIONAL EXPERIENCE AND QUALIFICATIONS

3. Andrew T. Thomasson. I received my bachelor’s degree from Arkansas State

University and my law degree from Thomas Jefferson School of Law, an ABA-accredited

institution in San Diego, California. I was admitted to practice law in the State of New Jersey in

2013. I am also admitted to practice law before the United States Courts of Appeal for the

Second, Third, Fourth, and Seventh Circuits, as well as the following United States District

Courts: District of New Jersey; Northern District of Florida; Eastern and Western Districts of

Michigan; District of Colorado; Northern, Southern, and Western Districts of Texas; Northern

and Central Districts of Illinois; and the Eastern and Western Districts of Wisconsin.

I have remained a member in good standing and my license to practice law has never

been suspended or revoked by the State of New Jersey or any court. There are no disciplinary

proceedings pending against me in any jurisdiction and no discipline has previously been

imposed on me in any jurisdiction.

From 2009 and continuing until 2013 when I was admitted to practice, I was employed as

a law clerk at the Law Office of William F. Horn in Fresh Meadows, New York and, upon my

admission to practice law I became counsel to the firm. In that regard, I worked on a variety of

complex consumer class action cases including, but not limited to, all aspects of the following

successful class actions in which William F. Horn was certified as class counsel: Anderson v.

Nationwide Credit, Inc., E.D.N.Y. Case No. 2:08-cv-01016; Harrigan v. Receivables

Performance Management, LLC, N.D.N.Y. Case No. 8:09-cv-01351; Gravina v. United

Collection Bureau, Inc., E.D.N.Y. Case No. 2:09-cv-04816; Gravina v. National Enterprise

Systems, Inc., E.D.N.Y. Case No. 2:09-cv-02942; Anderson v. Nationwide Credit, Inc., E.D.N.Y.

Case No. 2:10-cv-03825; Pawelczak v. Bureau of Collection Recovery, LLC, N.D. Ill. Case No.

1:11-cv-01415; Zirogiannis v. Professional Recovery Consultants, Inc., E.D.N.Y. Case No. 2:11-


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cv-00887; Lagana v. Stephen Einstein & Associates, P.C., S.D.N.Y. Case No. 1:10-cv-04456;

Corpac v. Rubin & Rothman, LLC, E.D.N.Y. Case No. 2:10-cv-04165; Castellano v. Global

Credit & Collection Corporation, E.D.N.Y. Case No. 2:10-cv-05898; Cedeno v. Bureau of

Collection Recovery, Inc., C.D. Cal. Case No. 8:10-cv-01960; Pawelczak v. Financial Recovery

Services, Inc., N.D. Ill. Case No. 1:11-cv-02214; Gravina v. Weltman, Weinberg & Reis, Co.,

LPA., E.D.N.Y. Case No. 2:11-cv-01161; Krug v. Davis Davis Attorneys, P.C., D. NJ. Case No.

1:10-cv-04975; Zirogiannis v. Mel S. Harris & Associates, LLC, E.D.N.Y. Case No. 2:12-cv-

00680; Sebrow v. Fulton, Friedman & Gullace, LLP, E.D.N.Y. Case No. 1:10-cv-05897; Burton

v. Nations Recovery Center, Inc., E.D.N.Y. Case No. 1:13-cv-01426; and Steinmetz v. Shapiro,

Dicaro & Barak, LLC, E.D.N.Y. Case No. 2:12-cv-01646.

Since becoming licensed to practice law, I have been personally certified as class counsel

in the following consumer class action lawsuits: Pascal, et al. v. Steine & Associates, P.C., et al.,

U.S. District Court, E.D.N.Y. Case No. 2:12-cv-04436-JFB-WDW; Fischer v. NCB Management

Services, Inc., U.S. District Court, S.D.N.Y. Case No. 7:12-cv-09451-CS; Freeman v. General

Revenue Corporation, U.S. District Court, E.D.N.Y. Case No. 1:12-cv-01406-RER; Goldman v.

Horizon Financial Management, LLC, U.S. District Court, S.D.N.Y. Case No. 7:12-cv-07592-

LMS; Dabbas v. Alpha Recovery Corp., U.S. District Court, E.D.N.Y. Case No. 1:13-cv-05169-

SMG; Sabri v. E. Hope Greenberg d/b/a Law Office of E. Hope Greenberg, U.S. District Court,

E.D.N.Y. Case No. 1:13-cv-00699-FB-VMS; Bryan v. National Enterprise Systems, Inc., et al.,

U.S. District Court, E.D.N.Y. Case No. 2:13-cv-03740-LDW-WDW; Gillman Harris v. Midland

Credit Management, Inc., U.S. District Court, S.D.N.Y. Case No. 1:13-cv-03125-TPG; Graff v.

United Collection Bureau, Inc., U.S. District Court, E.D.N.Y. Case No. 2:12-cv-02402-GRB;

Rice v. National Enterprise Systems, Inc., et al., U.S. District Court, E.D.N.Y. Case No. 2:13-cv-

05118-LDW-ARL; Mazzucco, et al. v. Certified Credit & Collection Bureau, U.S. District Court,


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D.N.J. Case No. 3:13-cv-07422-TJB; Kavalin v. AmeriFinancial Solutions, LLC, U.S. District

Court, S.D. Fla. Case No. 0:13-cv-62789-DPG; Cohen v. M.L. Zager, P.C., U.S. District Court,

D.N.J. Case No. 2:14-cv-03143-JBC; Manuel, et al. v. Caliber Home Loans, Inc., U.S. District

Court, D.N.J. Case No. 2:14-cv-05233-SRC-CLW; Babcock, et al. v. C.Tech Collections, Inc., et

al., U.S. District Court, E.D.N.Y. Case No. 1:14-cv-03124-MDG; Mansour v. Seas & Associates,

LLC, U.S. District Court, D.N.J. Case No. 2:14-cv-02935-SCM; Avila v. Law Office of Gary M.

Feldman, Esq., U.S. District Court, E.D.N.Y. Case No. 2:13-cv-07407-GRB; Dispennett v.

Frederick J. Hanna & Associates, P.C., U.S. District Court, W.D. Pa. Case No. 2:15-cv-00636-

MPK; Jones v. Delta Management Associates, Inc., U.S. District Court, E.D. Wis. Case No.

1:15-cv-00267-WCG; Zavian v. Client Services, Inc., U.S. District Court, D.N.J. Case No. 2:15-

cv-0682-SCM; Kopchak v. United Resourse Systems, et al., U.S. District Court, E.D. Pa. Case

No. 5:13-cv-05884-MSG; Kavalin v. AFNI, Inc., U.S. District Court, S.D. Fla. Case No. 0:15-cv-

60143-BB; Maldonado, et al. v. Raymond Meisenbacher & Sons, Esqs., P.C., et al., U.S. District

Court, N.J.D. Case No. 3:15-cv-01845-DEA; Gamil v. Rubin & Rothman, LLC, U.S. District

Court, E.D.N.Y. Case No. 2:15-cv-00981-ARL; Wood v. New Century Financial Services, Inc.,

N.J. Superior Court, Docket No. MRS-L-002679-15; Prendergast v. Certified Credit &

Collection Bureau, U.S. District Court, D.N.J. Case No. 3:15-cv-07411-TJB; Kielbasinski v. A.R.

Resources, Inc., U.S. District Court, W.D. Pa. Case No. 3:15-cv-00066-KRG; Rittle v. Premium

Receivables, LLC, U.S. District Court, M.D. Pa. Case No. 1:15-cv-00166-SHR; Specht v.

Eastern Account System of Connecticut, Inc., U.S. District Court, S.D.N.Y. Case No. 7:15-cv-

02159-PED; Gadime v. NRA Group, LLC, U.S. District Court, E.D.N.Y. Case No. 2:15-cv-

04841-SJF-AKT; Hayes v. Convergent Healthcare Recoveries, Inc., U.S. District Court, C.D. Ill.

Case No. 1:14-cv-01467-JES-JEH; Maldonado, et al. v. Nelson, Watson & Associates, et al.,

U.S. District Court, D.N.J. Case No. 2:15-cv-05940-MAH; Sandoval v. LVNV Funding LLC, et


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al., U.S. District Court, D.N.J. Case No. 2:15-cv-06728-KM-MAH; Chung v. CCB Credit

Services, Inc., U.S. District Court, D.N.J. Case No. 2:15-cv-05198-KM-MAH; Wood v. Credit

Control, LLC, U.S. District Court, D. Kan. Case No. 6:16-cv-01098-KGG; Feliciano, et al. v.

Forster, Garbus & Garbus, U.S. District Court, D.N.J. Case No. 2:15-cv-02496-CLW;

Maldonado, et al. v. Law Offices of Faloni & Associates, LLC, U.S. District Court, D.N.J. Case

No. 2:15-cv-02859-CLW; Dickon v. Rubin & Rothman, LLC, U.S. District Court, D.N.J. Case

No. 2:15-cv-7961-SCM; Williams v. Pressler and Pressler, LLP, U.S. District Court, D.N.J.

Case No. 2:11-cv-07296-KSH-CLW; Bell v. Adler Wallach & Associates, Inc., et al., U.S.

District Court, W.D. Tex. Case No. 5:16-cv-00366-OLG; and Thomas v. ARS National Services,

Inc., U.S. District Court, D.N.J. Case No. 2:15-cv-03635-JAD.

Since 2009, I have also been a member in good standing of the National Association of

Consumer Advocates (“NACA”), a non-profit association of attorneys and consumer advocates

committed to representing consumers’ interests. I have attended, and regularly attend

conferences and symposiums conducted by NACA and the National Consumer Law Center

covering a variety of Continuing Legal Education topics, including, but not limited to, the Fair

Debt Collection Practices Act (FDCPA), the Truth In Lending Act, the Real Estate Settlement

Procedures Act , other federal and state consumer protection statutes, professional responsibility,

and, in particular, class action litigation involving consumer protection statutes. In that regard, I

have also been a presenter for Continuing Legal Education programs on issues related to

consumer debt collection.

4. Philip D. Stern received his bachelor’s degree from the University of

Pennsylvania and graduated the Benjamin N. Cardozo School of Law. He was admitted to

practice before the State and Federal Courts in New Jersey on December 20, 1984. He is also

admitted in the District of Columbia, the United States Courts of Appeals for the Second, Third


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and Ninth Circuits, and the United States District Courts for the Western District of New York

and the Eastern District of Wisconsin.

From September 1984 through January 1995, he worked for two law firms focusing on

business-oriented litigation, including employment, environmental, land use, non-consumer

collections and matters involving the enforcement of contracts. At the latter of those two firms,

Stern, Dubrow & Marcus, P.C., he worked closely with Morris Stern, the late Bankruptcy Judge

in the District of New jersey. Despite their common last names, Judge Stern and Mr. Stern have

no familial relationship. Much of Mr. Stern’s work involved pleadings, motions, trials and

appeals.

In February 1995, Mr. Stern went into solo practice and in January 2007, he became

counsel to Wacks & Hartmann, LLC, Morristown, New Jersey. In January 2009, he returned to

his solo practice until July 1, 2015, when Stern•Thomasson LLP was formed.

In 1994, Mr. Stern taught Appellate Advocacy as an adjunct professor at Seton Hall Law

School and, since October 2011, he has taught two CLE classes each year offered through Legal

Services of New Jersey relating to debt collection and the Fair Debt Collection Practices Act. He

also presented at the 2012 Advanced Fair Debt Collection Practices Conference sponsored by the

National Consumer Law Center.

During his career, Mr. Stern has tried numerous bench and jury trials and has handled

several appeals before the New Jersey Appellate Division as well as before the Second, Third,

and Ninth U.S. Circuit Courts of Appeals. Many of the non-consumer cases he handled involved

complex litigation in both state and federal court involving sophisticated commercial real estate

financing, large-scale construction disputes, title insurance claims, bankruptcy, and zoning.

Mr. Stern is experienced in cases involving complex litigation including claims arising

under the FDCPA and the pursuit of those claims in class action cases. He has been certified as


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class counsel in the following matters: Anderson v. Rubin & Rothman, LLC, Case 2:07-cv-03375

(E.D.N.Y., Hon. Sandra J. Feuerstein); Anderson v. Nationwide Credit, Inc., Case 2:08-cv-01016

(E.D.N.Y., Hon. Leonard D. Wexler); Gravina v. Client Services, Inc., Case 2:08-cv-03634,

(E.D.N.Y., Hon. Leonard D. Wexler); Seraji v. Capital Management Services, LP, Case 1:09-cv-

00767 (D.N.J., Hon. Douglas Arpert); Krug v. Forster, Garbus & Garbus, Case 2:08-cv-03504

(D.N.J., Hon Michael A. Shipp); Williams v. Palisades Collection, LLC, Docket BER-L-001604-

11 (N.J.Super., Hon. Robert C. Wilson); Krug v. Brachfeld, Docket GLO-000419-11 (N.J.Super.,

Hon.Eugene J. McCaffrey, Jr.); Nicholas v. CMRE Financial Services, Inc., Docket BER-L-

4336-11 (N.J.Super., John J. Langan, Jr.); Krug v. Focus Receivables Management, LLC, Docket

BER-L-4337-11 (N.J.Super., John J. Langan, Jr.); Thomas Williams v. The CBE Group, Inc.,

Case 2:11-cv-03680-PS (D.N.J., Hon Patty Shwartz); Natalie A. Williams v. Pressler and

Pressler, LLP, Case 2:11-cv-07296-KSH-CLW (D.N.J., Hon. Katharine S. Hayden); Weissman

v. Gutworth, Case 2:14-cv-00666-WHW-CLW (D.N.J., Hon. William H. Walls); Irizarry v.

Member Solutions, Inc., et al., Case 2:14-cv-00628-MCA-MAH (D.N.J., Hon. Madeline C.

Arleo); Mansor v. Seas & Associates, LLC, Case 2:14-cv-02935-SCM (D.N.J., Hon. Steven C.

Mannion); Jones v. Delta Management Associates, Inc., Case 1:15-cv-00267-WCG (E.D. Wis.,

Hon. William C. Griesbach); Zavian v. Client Services, Inc., Case 2:15-cv-0682-SCM (D.N.J.,

Hon. Steven M. Mannion); Maldonado, et al. v. Raymond Meisenbacher & Sons, Esqs., P.C., et

al., Case 3:15-cv-01845-DEA (D.N.J., Hon. Douglas E. Arpert); Wood v. New Century Financial

Services, Inc., Docket MRS-L-002679-15 (N.J.Super., David H. Ironson); Prendergast v.

Certified Credit & Collection Bureau, Case 3:15-cv-07411-TJB (D.N.J., Hon. Tonianne J.

Bongiovanni); Kielbasinski v. A.R. Resources, Inc., Case 3:15-cv-00066-KRG (W.D. Pa., Hon.

Kim R. Gibson); Rittle v. Premium Receivables, LLC, Case 1:15-cv-00166-SHR (M.D. Pa., Hon.

Sylvia H. Rambo); and Specht v. Eastern Account System of Connecticut, Inc., Case 7:15-cv-


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02159-PED (S.D.N.Y., Hon. Paul E. Davison); Gadime v. NRA Group, LLC, Case No. 2:15-cv-

04841-SJF-AKT (E.D.N.Y., Hon. Sandra J. Feuerstein); Maldonado, et al. v. Nelson, Watson &

Associates, et al., Case 2:15-cv-05940-MAH (D.N.J., Hon. Michael A. Hammer); Sandoval v.

LVNV Funding LLC, et al., Case 2:15-cv-06728-KM-MAH (D.N.J., Hon. Kevin McNulty);

Chung v. CCB Credit Services, Inc., Case 2:15-cv-05198-KM-MAH (D.N.J., Hon. Kevin

McNulty); Wood v. Credit Control, LLC, Case 6:16-cv-01098-KGG (D.N.J., Hon. Kenneth G.

Gale); Feliciano, et al. v. Forster, Garbus & Garbus, Case 2:15-cv-02496-CLW (D.N.J., Hon.

Cathy L. Waldor).

Mr. Stern has never been the subject of an ethics complaint or sued on a malpractice

claim. He has never been charged with violating Fed. R. Civ. P. 11 and, for as long as

Martindale-Hubbell has rated him, he has had a rating of AV or, after its introduction, AV

Preeminent—it’s highest—with a peer rating of 5.0 out of 5.0.

Mr. Stern is a member of the New Jersey State Bar Association and the Essex County Bar

Association, a member of the New Jersey State Bar’s Consumer Protection Law Committee, and

a member of the National Association of Consumer Advocates.

5. Heather B. Jones received her bachelor’s degree from University of Wisconsin-

Oshkosh and her law degree from Thomas Jefferson School of Law in San Diego, California.

Ms. Jones was admitted to practice law in the State of Wisconsin in 2015. She is also admitted to

practice law before the United States District Courts for the Eastern and Western Districts of

Wisconsin. There are no disciplinary proceedings pending against Ms. Jones in any jurisdiction

and no discipline has ever been imposed on her in any jurisdiction.

From 2010 to 2014, Ms. Jones was employed as a law clerk at the Law Office of William

F. Horn in Fresh Meadows, New York. In that regard, she worked on a variety of complex and

consumer class action cases including, but not limited to, all aspects of the following successful


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class actions in which William F. Horn was certified as class counsel: Anderson v. Nationwide

Credit, Inc., E.D.N.Y. Case No. 2:10-cv-03825; Pawelczak v. Bureau of Collection Recovery,

LLC, N.D. Ill. Case No. 1:11-cv-01415; Zirogiannis v. Professional Recovery Consultants, Inc.,

E.D.N.Y. Case No. 2:11-cv-00887; Lagana v. Stephen Einstein & Associates, P.C., S.D.N.Y.

Case No. 1:10-cv-04456; Corpac v. Rubin & Rothman, LLC, E.D.N.Y. Case No. 2:10-cv-04165;

Castellano v. Global Credit & Collection Corporation, E.D.N.Y. Case No. 2:10-cv-05898;

Cedeno v. Bureau of Collection Recovery, Inc., C.D. Cal. Case No. 8:10-cv-01960; Pawelczak v.

Financial Recovery Services, Inc., N.D. Ill. Case No. 1:11-cv-02214; Gravina v. Weltman,

Weinberg & Reis, Co., LPA., E.D.N.Y. Case No. 2:11-cv-01161; Krug v. Davis Davis Attorneys,

P.C., D. NJ. Case No. 1:10-cv-04975; Zirogiannis v. Mel S. Harris & Associates, LLC, E.D.N.Y.

Case No. 2:12-cv-00680; Sebrow v. Fulton, Friedman & Gullace, LLP, E.D.N.Y. Case No. 1:10-

cv-05897; Burton v. Nations Recovery Center, Inc., E.D.N.Y. Case No. 1:13-cv-01426; and

Steinmetz v. Shapiro, Dicaro & Barak, LLC, E.D.N.Y. Case No. 2:12-cv-01646.

Ms. Jones is a member in good standing of the National Association of Consumer

Advocates, a non-profit association of attorneys and consumer advocates committed to

representing consumers’ interests. She is also a member in good standing of the Outagamie

County Bar Association and the Winnebago County Bar Association, and serves as co-vice chair

for the Fox Valley Young Lawyers Association.

After being admitted to practice law, Ms. Jones joined Stern•Thomasson LLP as an

associate; her work is focused on representing plaintiffs in class action litigation involving

various state and federal consumer protection statutes.

6. Stern•Thomasson LLP litigates class action lawsuits throughout the United States

where it has been retained to represent plaintiffs. Many of those cases have either been resolved

on a class basis and are awaiting preliminary approval, or have fully briefed contested motions


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for class certification and await a court’s ruling. In that regard our law firm has several favorable

decisions from various United States District Courts and Appeals Courts.

7. Stern•Thomasson LLP has the financial and other resources to see this case

through to its conclusion and we remain committed to doing so.

RELEVANT FACTS OBTAINED IN DISCOVERY

8. Attached hereto as Exhibit 1 is a true and correct copy of Defendant, SIMM

Associates, Inc.’s, Amended Responses to Plaintiff’s First Set of Interrogatories dated October

30, 2017.

9. Attached hereto as Exhibit 2 is a true and correct copy of Defendant, SIMM

Associates, Inc.’s, Amended Responses to Plaintiff’s First Set of Requests for Production of

Documents dated October 30, 2017; attached as Exhibit 3 is a document identified as

“Smith/Simm000034” which is referenced in, and produced with, with the foregoing responses.

In accordance with 28 U.S.C. §1746, I certify under penalty of perjury under the laws of

the United States of America that the foregoing is true and correct. Executed on this 31st day of

October 2017.

s/ Andrew T. Thomasson

Andrew T. Thomasson

STERN•THOMASSON LLP

150 Morris Avenue, 2nd Floor

Springfield, NJ 07081-1315

Telephone: (973) 379-7500

Facsimile: (973) 532-5868

E-Mail: [email protected]

One of the Attorneys for Plaintiff, Jessica

Smith, and all others similarly situated


EXHIBIT “1” Case 1:17-cv-00769-WCG Filed 10/31/17 Page 1 of 8 Document 35-1

1



GREEN BAY DIVISION

JESSICA SMITH,


Plaintiff


v.


Defendant

DEFENDANT SIMM ASSOCIATES, INC.’S

AMENDED RESPONSES TO PLAINTIFF’S FIRST SET OF INTERROGATORIES

Interrogatory No. 1. Please Identify all Persons who provided any information used to answer

these Interrogatories.

RESPONSE: Jeffrey Simendinger, Chief Operating Officer, Simm Associates, Inc. Mr.

Simendinger is a current employee of Defendant and may only be contacted through counsel.

Interrogatory No. 2. Please Identify all Persons who investigated the factual allegations set forth

in Plaintiff’s Complaint [Doc. 1] or who provided any information used to formulate Your Answer

to Plaintiff’s Complaint [Doc. 16].

RESPONSE: Jeffrey Simendinger, Chief Operating Officer, Simm Associates, Inc. Mr.

Simendinger is a current employee of Defendant and may only be contacted through counsel.

Interrogatory No. 3. How are records created and stored of each written and oral Communication

between You and a Consumer? If any records are stored in an electronic database, include a list of

each field in the database.

RESPONSE: Objection.

Defendant objects to this request because it uses the term of art “consumer,” which has a

specific and significant meaning under the FDCPA. A “debt” under the FDCPA must be

“consumer” by nature. See Hennings v. Alltran Fin., LP, No. 16-CV-1561, 2017 U.S. Dist.

LEXIS 81289 at *4-5 (E.D. Wis. May 26, 2017). The FDCPA defines a “debt” as “any

obligation or alleged obligation of a consumer to pay money arising out of a transaction in

Case 1:17-cv-00769-WCG Filed 10/31/17 Page 2 of 8 Document 35-1

2

which the money, property, insurance, or services which are the subject of the transaction

are primarily for personal, family, or household purposes.” 15 U.S.C. § 1692f(5).

It is specifically denied that Defendant has any information as to whether any obligation it

attempts to collect constitutes a debt under the FDCPA.

Without waiving the foregoing objections, see the attached Account Notes (Smith/Simm

000001-000003) regarding Plaintiff’s Account with Defendant. All correspondence received

from a consumer is converted to a PDF and attached to the account in Latitude. Outgoing

dunning letters are kept by the vendor for approximately 90 days on their secure system.

After 90 days, the vendor purges them from their website and loads the images onto a DVD

that is then mailed to SIMM. SIMM keeps these files indefinitely.

Interrogatory No. 4. What is the meaning of each abbreviation, code, letter, numeral, or symbol

regularly used in Your records of collection activities?

RESPONSE: Defendant does not possess a separate legend or key for its Account Notes. If

Plaintiff has any questions about specific entries on the Account Notes, Defendant will

provide an explanation regarding those entries.

Interrogatory No. 5. Please state the number of Persons whom your records reflect meets the

following criteria:

All persons with addresses in the State of Wisconsin to whom You mailed an initial

written communication during the Term, which was not returned as undeliverable,

and which identified “Paypal Credit” as the “Client” but not the current creditor or

owner of the debt.

RESPONSE: 2,495.

Interrogatory No. 6. Identify each Person whom Your records reflect meets the following

criteria:




owner of the debt.

RESPONSE: Objection. This request is premature as a class has not been certified.

Defendant states that 2,495 individuals were sent a letter.

Interrogatory No. 7. Identify the number or code You use to Identify Your template collection

letter attached as Exhibit A to Plaintiff’s Complaint [Doc. 1].

RESPONSE: 40VSL


Andrew T. Thomasson

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Andrew T. Thomasson

Highlight

Andrew T. Thomasson

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Interrogatory No. 8. Please state the number of Persons to whom You mailed the template

collection letter, which You Identified in response to Interrogatory No. 7, to a Person with a

Wisconsin address during the Term.

RESPONSE: 2,495.

Interrogatory No. 9. Identify each Agent who, during the Term, drafted, authorized, or approved

the form of Your written Communications to Consumers in the form attached as Exhibit A to

Plaintiff’s Complaint [Doc. 1].

RESPONSE: Objection. Defendant objects to this request because it uses the term of art

“consumer,” which has a specific and significant meaning under the FDCPA. A “debt”

under the FDCPA must be “consumer” by nature. See Hennings v. Alltran Fin., LP, No. 16-

CV-1561, 2017 U.S. Dist. LEXIS 81289 at *4-5 (E.D. Wis. May 26, 2017). The FDCPA defines

a “debt” as “any obligation or alleged obligation of a consumer to pay money arising out of

a transaction in which the money, property, insurance, or services which are the subject of

the transaction are primarily for personal, family, or household purposes.” 15 U.S.C. §

1692f(5).



Without waiving the foregoing objections, Defendant identifies Jeffrey Simendinger, Chief

Operating Officer, Simm Associates, Inc. Mr. Simendinger is a current employee of

Defendant and may only be contacted through counsel.

Interrogatory No. 10. Identify each Agent who, during the Term, who was responsible for

mailing Your written Communications to Consumers in the form attached as Exhibit A to

Plaintiff’s Complaint [Doc. 1].

RESPONSE: Objection. Defendant objects to this request because it uses the term of art

“consumer,” which has a specific and significant meaning under the FDCPA. A “debt”

under the FDCPA must be “consumer” by nature. See Hennings v. Alltran Fin., LP, No. 16-

CV-1561, 2017 U.S. Dist. LEXIS 81289 at *4-5 (E.D. Wis. May 26, 2017). The FDCPA defines

a “debt” as “any obligation or alleged obligation of a consumer to pay money arising out of

a transaction in which the money, property, insurance, or services which are the subject of

the transaction are primarily for personal, family, or household purposes.” 15 U.S.C. §

1692f(5).



Without waiving the foregoing objections, Defendant’s independent letter vendor,

RevSpring, Inc., mails Defendant’s collection letters. SIMM uploads a letter request file to


Andrew T. Thomasson

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4

the vendor, but SIMM does not have knowledge of which RevSpring processing/printing

center prints and mails each letter.

Interrogatory No. 11. Describe, step by step, the process which resulted in Your written

Communication, which is attached as Exhibit A to Plaintiff’s Complaint [Doc.1], being transmitted

to Plaintiff, beginning with the date and method of transmission of debtor information to You, e.g.,

computer tapes, or other media delivered (when, by whom, where, and to whom); content of the

computer tapes or media; data input of the (where and by whom); computer entry or other means

of directing transmission letters tape or media (where and by whom entry made); letter with Debtor

information printed (from where and by whom); letter with Debtor information mailed (from

where and by whom); computer tapes or media returned (on what occasion, when, by whom, and

to whom).

RESPONSE: Objection. This request seeks information that is not relevant to the claims or

defenses in this case, nor is the request proportional to the needs of the case. Defendant also

objects to this request as it is compound and overbroad. This request seeks information that

contains confidential and proprietary business information. Without waiving the foregoing

objections, Defendant’s independent letter vendor, RevSpring, Inc., mailed the letter dated

February 23, 2017 that is attached as Exhibit A to Plaintiff’s Complaint. During the initial

letter setup, Simm preselects variables of data necessary to obtain which will be included in

the body of the letter. The data is saved in files which are saved to a local server folder at

Simm. The letter files are generated by the custodian process into CSV format. Each business

day morning, the files are then manually uploaded to RevSpring’s SFTP site using an SFTP

file transfer capable program such as FileZilla. Simm will receive a confirmation file

whenever on of the letters is processed by the vendor. Simm will also receive files for mail

rejections.

Interrogatory No. 12. State the date upon which You began using the templated written

Communication attached as Exhibit A to Plaintiff’s Complaint [Doc. 1] and, if applicable, the date

You ceased using it.

RESPONSE: Defendant began using the most recent template for the 40VSL letter that is

attached as Exhibit A to Plaintiff’s Complaint on or about August 12, 2016. Defendant

continued using the template through until July 2017.

Interrogatory No. 13. Please state all facts which support Your contention that Plaintiff

has failed to state a claim upon which relief can be granted in the Action.

RESPONSE: Objection. Defendant objects to the foregoing interrogatory on the basis that

it improperly seeks a narrative response. As discovery is ongoing, Defendant has not yet

identified all facts it may rely upon to support its affirmative defenses. Furthermore,

Interrogatory No. 13 is a contention interrogatory. “[C]ontention interrogatories require the

answering party to commit to a position and give factual specifics supporting its claims. The

general policy is to defer contention interrogatories until discovery is near an end.” Ziemack

v. Centel Co., 1995 U.S. Dist. LEXIS 18192 (N.D. Ill. Dec. 6, 1995). Because discovery and

claim investigation can change contentions and supporting information, contention


5

interrogatories, if allowed at all, should be used only at the end of the discovery period. In

re: Convergent Technologies Securities Litigation, 108 F.R.D. 328, 335 (N.D. Cal. 1985).

Subject to and without waiving said objections, investigation continues; Defendant reserves

the right to timely supplement this response.

Interrogatory No. 14. Identify all Persons who provided any accounting and tax

preparation services for You during the past four years.



objects to this request as it overbroad. Notwithstanding said objection, Lori LaPenta, CPA

from McKenzie Services, LLC prepares the financials.

Interrogatory No. 15. What is Your net worth and how did You compute it?

RESPONSE: Objection. Defendant objects to this request on the grounds that it seeks

proprietary information. Defendant further objects to this interrogatory as premature, in

that the net worth of Defendant is only relevant upon a finding of liability. Subject to and

without waiving said objections, Defendant is producing its balance sheet dated December

31, 2016 in accordance with a Stipulated Protective Order.

Messer Strickler, Ltd.

Attorneys for Defendant Simm Associates, Inc.

/s/ Stephanie A. Strickler

Stephanie A. Strickler, IL6314089


225 West Washington, Suite 575

Chicago, IL 60606

P 312-334-3469

F 312-334-3473

[email protected]


mailto:[email protected]

6

CERTIFICATE OF SERVICE BY MAIL

I, Stephanie A. Strickler, an attorney, after being first duly sworn, on oath state that I caused

a true and correct copy of this Defendant’s Amended Responses to Plaintiff’s First Set of

Interrogatories to be delivered via email on October 30, 2017 to:

Francis R. Greene

Edelman, Combs, Latturner & Goodwin, LLC

20 South Clark St.

Suite 1500

Chicago, IL 60603


Andrew T. Thomasson



[email protected]

s/ Stephanie A. Strickler

Stephanie A. Strickler IL6314089


Chicago, IL 60606

P 312-334-3465

F 312-334-3473

[email protected]


1



GREEN BAY DIVISION

JESSICA SMITH,


Plaintiff


v.


Defendant

RESPONSE TO REQUESTS FOR DOCUMENTS

Document Request No. 1. All Documents You understand as creating the Obligation and the

amount due.

RESPONSE: See the following documents:

1) Account Notes (Smith/Simm 000001-000003);

2) February 23, 2017 Letter (Smith/Simm 000004-000005); and

3) Billing/Shipping Data (Smith/Simm 000034-000035).

Document Request No. 2. All Documents You understand as creating Your ownership of, or

right to collect, the Obligation. Included in this Request are any agreements between You and the

Person who sold or assigned the Obligation to You for collection.

RESPONSE: Objection. This request as it overbroad. Further, this request seeks

information that contains confidential and proprietary business information. Without

waiving the foregoing objections, see the Account Notes (Smith/Simm 000001-000003).

Document Request No. 3. All Documents which reflect the date of last payment activity

concerning the Obligation.

RESPONSE: Defendant does not possess any documents that are responsive to this request.

Defendant received information electronically at placement indicating that

the last payment date was January 12, 2014.


Andrew T. Thomasson

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Andrew T. Thomasson

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Document Request No. 4. All Documents You understand to memorialize the terms and

conditions under which You attempted to collect the Obligation for or on behalf of the owner of

the Obligation.

RESPONSE: Objection. Defendant objects to this request as it overbroad. Further, this

request seeks information that contains confidential and proprietary business information.

Without waiving the foregoing objections, see the Account Notes (Smith/Simm 000001-

000003).

Document Request No. 5. All Documents You received from a Creditor concerning the

Obligation.

RESPONSE: Electronic information was provided to Defendant at the time of placement.

That information was loaded into Defendant’s Latitude system. See the Account Notes

(Smith/Simm 000001-000003). Subsequent to the time of placement, Defendant received an

updated telephone number. See Telephone Information Spreadsheet (Smith/Simm 000006-

000021); see also Smith/Simm 000034-000035.

Document Request No. 6. All Documents You sent to any Creditor concerning the Obligation.

RESPONSE: None.

Document Request No. 7. All Documents which comprise an agreement or contract for

services between You and any Agent responsible for printing Your written Communication

attached as Exhibit A to Plaintiff’s Complaint [Doc. 1].



objects to this request as it overbroad. Further, this request seeks information that contains

confidential and proprietary business information.

Document Request No. 8. All Documents which comprise an agreement or contract for

services between You and any Agent responsible for mailing Your written Communication

attached as Exhibit A to Plaintiff’s Complaint [Doc. 1].





Document Request No. 9. All Documents You received from any Agent, which reflects the

mailing activity concerning Your template written Communications in the form attached as Exhibit

A to Plaintiff’s Complaint [Doc. 1].

RESPONSE: Objection. Defendant objects to this request as it vague and overbroad.

Notwithstanding said objections, none.


Andrew T. Thomasson

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Document Request No. 10. All Documents memorializing each effort or activity by You to

collect the Obligation. Without limiting this Request, included are: (A) all records and notations

of written or oral Communications and of attempts to communicate with the Plaintiff; (B) copies

of all written correspondence and envelopes; (C) recorded telephone calls; (D) Live Messages; and

(E) Prerecorded Messages.


1) Account Notes (Smith/Simm 000001-000003); and

2) February 23, 2017 Letter (Smith/Simm 000004-000005).

Defendant sent emails to the Plaintiff on the following dates: March 23, 2017, March 28,

2017, April 5, 2017, April 12, 2017, April 19, 2017, April 25, 2017, May 4, 2017, May 11, 2017,

and May 18, 2017. See the Account Notes (Smith/Simm 000001-000003). Defendant does

not maintain copies of the emails. Defendant sent the emails in accordance with its

“SOP Consumer Email Campaigns – PayPal” which contains templates of the emails that

were sent to Plaintiff (Email SOP Consumer Email Campaigns – PayPal (Smith/Simm

000022-28).

Defendant did not have any telephonic contact with Plaintiff. As a result, Defendant does

not possess any telephone call recordings.

Document Request No. 11. All Documents describing Your typical, intended, or expected

procedures for collection of a Debt.



Defendant also objects to this request because it uses the term of art “debt,” which has a









Notwithstanding said objections, see Smith/Simm000022-000028; 000036-000048.

Document Request No. 12. All Documents which You used during the Term as training

materials, operations manuals, standard operating procedures, policies, or practices concerning any

Collector’s Communications with Consumers. Without limiting this Request, included are


4

instructions given to Collectors concerning the content of template written Communications You

send to Consumers.













Document Request No. 13. All Documents reflecting Your policies and procedures concerning

the approval of written Communications You send to Consumers. Without limiting this Request,

included are the policies and procedures concerning the approval of the written template

Communication attached as Exhibit A to Plaintiff’s Complaint [Doc. 1].

RESPONSE: Objection. This request seeks information that contains confidential and

proprietary business information.

Defendant also objects to this request because it uses the term of art “consumer,” which has

a specific and significant meaning under the FDCPA. A “debt” under the FDCPA must be









Document Request No. 14. All Documents that reflect the number of Persons whom Your

records reflect meets the following criteria:

All persons with addresses in the State of Wisconsin to whom You mailed an initial written

communication during the Term, which was not returned as undeliverable, and which identified

“Paypal Credit” as the “Client” but not the current creditor or owner of the debt.


5

RESPONSE: Objection. If a class is certified, Defendant will provide the names and

addresses of the putative class subject to a mutually agreeable confidentiality order.

Document Request No. 15. All Documents that reflect the Identity of each Person whom Your

records reflect meets the following criteria:




owner of the debt.

RESPONSE: Objection. If a class is certified, Defendant will provide the names and

addresses of the putative class subject to a mutually agreeable confidentiality order.

Document Request No. 16. All Documents that describe, step by step, the process which

resulted in Your template written Communication, which is attached as Exhibit A to Plaintiff’s

Complaint [Doc. 1], being transmitted to Plaintiff, beginning with the date and method of

transmission of debtor information to You, e.g., computer tapes, or other media delivered (when,

by whom, where, and to whom); content of the computer tapes or media; data input of the (where

and by whom); computer entry or other means of directing transmission letters tape or media

(where and by whom entry made); letter with debtor information printed (from where and by

whom); letter with debtor information mailed (from where and by whom); computer tapes or media

returned (on what occasion, when, by whom, and to whom).



objects to this request as it overbroad. Without waiving the foregoing objections, see

Smith/Simm000022-000028; 000036-000038; 000042-000048. Answering further,

Defendant’s independent letter vendor, RevSpring, Inc., mailed the letter dated February

23, 2017 that is attached as Exhibit A to Plaintiff’s Complaint.

Document Request No. 17. All reports that concern Your use of the type of template written

Communication, which is attached as Exhibit A to Plaintiff’s Complaint [Doc. 1].



objects to this request as it overbroad. Notwithstanding said objection, none.

Document Request No. 18. All internal and external reports or memoranda that concern Your

use of the template written Communication, which is attached as Exhibit A to Plaintiff’s Complaint

[Doc. 1].



Notwithstanding said objection, none.


6

Document Request No. 19. All Documents that concern Your surveying the number of template

written Communications, which is attached as Exhibit A to Plaintiff’s Complaint [Doc. 1], that

You mailed to Persons in the State of Wisconsin during the Term.



Notwithstanding said objection, none.

Document Request No. 20. All written complaints You have received concerning Your use of

the template written Communications, which is attached as Exhibit A to Plaintiff’s Complaint

[Doc. 1], and/or similar factual or legal claims.

RESPONSE: Sergio Maximiliano v. Simm Associates, Inc., Case No. 9:17-cv-80341 filed in

the Southern District of Florida; Nieto v. Simm Associates, Inc., Case No. 17-cv-06859 filed

in the Northern District of Illinois.

Document Request No. 21. All lawsuits where You are named as a defendant and which

involved Your collection of Debts that the Creditor of the Obligation hired You to collect.

RESPONSE: Sergio Maximiliano v. Simm Associates, Inc., Case No. 9:17-cv-80341 filed in

the Southern District of Florida; Nieto v. Simm Associates, Inc., Case No. 17-cv-06859 filed

in the Northern District of Illinois; Tuck v. Paypal Credit et al., Case No. 17-cv-01577 filed

in the Southern District of California.

Document Request No. 22. Your organizational chart.

RESPONSE: See the attached Organizational Chart (Smith/Simm 000029).

Document Request No. 23. All Documents describing Your Document and/or record retention

and disposal policies.


1) Data Retention and Disposal Policy (Smith/Simm 000030-000032).

Document Request No. 24. All Documents used to describe, record, or establish Your methods,

techniques, and compliance policies to be used in the collection of Debts.

RESPONSE: Objection. Defendant objects to this request as it overbroad. This request

seeks information that contains confidential and proprietary business information.






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Document Request No. 25. All Documents used to describe, record, or establish Your methods,

techniques, and compliance policies You are required to follow when collecting Debts on behalf

of the Creditor of the Obligation.













Document Request No. 26. All Documents that comprise Your maintenance of procedures

adapted to avoid any violation of the Fair Debt Collection Practices Act.




Document Request No. 27. All Documents relating to Your association with a consumer

reporting agency, if any.

RESPONSE: Objection. Defendant objects to this request as it overbroad and vague as

“association” is not defined. This request seeks information that is not relevant to the claims

or defenses in this case, nor is the request proportional to the needs of the case. Defendant

also objects to this request as it overbroad. Defendant does not credit report on accounts

placed by PayPal. If and when Defendant reports on other accounts, it uses the standard

industry Metro 2 formatted file provided to it by the credit reporting agencies.


8

Document Request No. 28. All Documents that demonstrate the calculation of Your net worth.

RESPONSE: Smith/Simm000049-000050.

Document Request No. 29. Your financial statements covering the past four years, including the

most recently completed fiscal year. Financial statements include, but are not limited to, balance

sheets, net worth statements, income statements, and profit and loss statements.

RESPONSE: Defendant’s financials were recently audited. Smith/Simm000049-000050.

Document Request No. 30. Your federal, state, and local tax returns covering the past four years,

including the most recently completed fiscal year.

RESPONSE: Defendant objects irrelevant as it is not reasonably calculated to lead to the

discovery of admissible evidence. Notwithstanding said objection, Defendant has agreed to

produce its most recent balance sheet. See, Smith/Simm000049-000050.

Document Request No. 31. All financial statements of firms to which You outsource any of

Your collection activities if that firm is affiliated with You. “Affiliated” means either (a) that You

and the firm to which You outsourced such activities have one or more common owners, (b) You

own an interest in that firm, or (c) that firm owns an interest in You. Financial statements include,

but are not limited to, balance sheets, net worth statements, income statements, and profit and loss

statements.

RESPONSE: See, Smith/Simm000049-000050.

Document Request No. 32. Copies of all loan applications You submitted to a bank or any other

lending institution during the past four (4) years.

RESPONSE: Defendant objects to this request as irrelevant as it is not reasonably calculated

to lead to the discovery of admissible evidence.

Document Request No. 33. Copies of all Documents You submitted in support of, or in

conjunction with, any loan application You submitted to a bank or any other lending institution

during the past four (4) years.

RESPONSE: Defendant objects to this request as irrelevant as it is not reasonably calculated

to lead to the discovery of admissible evidence.

Document Request No. 34. A list Identifying Your Agents who engaged in the collection of

debts such as the Obligation, as well as their positions and responsibilities.




9











attempts to collect constitutes a debt under the FDCPA. Notwithstanding said objection,

none.

Document Request No. 35. All Documents You submitted to any governmental authority in

connection with Your registration with or licensing by such authority and submitted within the

past four (4) years.





Document Request No. 36. All Documents You submitted to, or received from, any regulatory

authorities concerning complaints about Your debt collection practices during the past four (4)

years.















10

Document Request No. 37. All manuals, memoranda, instructions, reports, and other

Documents which discuss, describe or set forth standards, criteria, guidelines, policies, practices,

or usage relating to Your mailing of template written Communications to Consumers.



In addition, this request is duplicative of other requests.











Document Request No. 38. All manuals, memoranda, instructions and other Documents which

discuss, describe or set forth Your standards, criteria, guidelines, policies or practices relating to

ensuring compliance with the FDCPA.



In addition, this request is duplicative of other requests.


Document Request No. 39. All Documents You reviewed, used, and/or relied upon when

investigating the factual allegations set forth in Plaintiff’s Complaint on file in the Action [Doc.

1].




3) Smith/Simm 00006-000021; 000034-000048.

Document Request No. 40. All skip tracing or other reports that You obtained to Identify or

locate Plaintiff in connection with Your attempt to collect the Obligation.

RESPONSE: Defendant does not have a separate report that is responsive to this request.


11

Plaintiff’s account was reviewed at the time of placement to check for any bankruptcies, cell

phone information, whether the Plaintiff was deceased, had filed lawsuits, and to check

demographic information. The results were then loaded into Defendant’s Latitude system.

See the Account Notes (Smith/Simm 000001-000003).

Document Request No. 41. All insurance agreements under which an insurance business may

be liable to satisfy all or part of a possible judgment in the action or to indemnify or reimburse for

payments made to satisfy a judgment in this Action.

RESPONSE: See the following document:

1) Certificate of Liability Insurance with Nautilus Insurance Company (Smith/Simm

000033). A claim was submitted to the insurance carrier.

Document Request No. 42. All Documents referenced, but not previously produced, in Your

Fed. R. Civ. P. 26(a) initial disclosures

RESPONSE:

1) Certificate of Liability Insurance with Nautilis Insurance Company (Smith/Simm 000033).

Document Request No. 43. All Documents relating to Plaintiff, or which are indexed, filed or

retrievable under Plaintiff’s name or any numbers, symbols, designations or codes (such as account

number or Social Security number) assigned to Plaintiff.




3) Telephone Information Spreadsheet (Smith/Simm 000006-000021).

Document Request No. 44. All Account notes relating to Plaintiff.

RESPONSE: See the Account Notes (Smith/Simm 000001-000003).

Document Request No. 45. All Documents that provide factual support for the “First Defense”

alleged in Your Answer to Plaintiff’s Complaint in the Action. [Doc. 16].


1) Account Notes (Smith/Simm 000001-000003); and

2) February 23, 2017 Letter (Smith/Simm 000004-000005).

Document Request No. 46. All Documents that provide factual support for the “Second

Defense” alleged in Your Answer to Plaintiff’s Complaint in the Action. [Doc. 16].


12

RESPONSE: None. Defendant reserves the right to supplement this response.

Document Request No. 47. All Documents that provide factual support for the “Third Defense”



Document Request No. 48. All Documents that provide factual support for the “Fourth


RESPONSE: None. Defendant removed this affirmative defense in its Amended Answer.

Document Request No. 49. All Documents that provide factual support for the “Fifth Defense”



Document Request No. 50. All Documents that provide factual support for the “Sixth Defense”



Document Request No. 51. All Documents that provide factual support for the “Seventh



Document Request No. 52. All Documents that provide factual support for the “Eighth



Document Request No. 53. All Documents that provide factual support for the “Ninth Defense”



Document Request No. 54. All Documents that provide factual support for the “Tenth Defense”



Document Request No. 55. All Documents that provide factual support for the “Eleventh



13


Document Request No. 56. All Documents that provide factual support for the “Twelfth



Document Request No. 57. All Documents that provide factual support for the “Thirteenth



Document Request No. 58. All Documents that provide factual support for the “Fourteenth




Attorneys for Defendant Simm Associates, Inc.

/s/ Stephanie A. Strickler

Stephanie A. Strickler, IL6314089



Chicago, IL 60606

P 312-334-3469

F 312-334-3473

[email protected]


mailto:[email protected]

14

CERTIFICATE OF SERVICE BY MAIL

I, Stephanie A. Strickler, an attorney, after being first duly sworn, on oath state that I caused

a true and correct copy of this Defendant’s Amended Responses to Plaintiff’s Requests to Produce

to be delivered via email on October 30, 2017 to:

Francis R. Greene

Edelman, Combs, Latturner & Goodwin, LLC

20 South Clark St.

Suite 1500

Chicago, IL 60603


Andrew T. Thomasson



[email protected]

s/ Stephanie A. Strickler

Stephanie A. Strickler IL6314089


Chicago, IL 60606

P 312-334-3465

F 312-334-3473

[email protected]


JESSICA SMITH

Neenah, Wisconsin 54956-6913 Re: PayPal Credit Account Original Creditor: Comenity Capital Bank Current Creditor: Comenity Capital Bank Servicer: Bill Me Later, Inc. Account Number: 6461 Date Account Opened via Internet: 12/10/2013 Last Payment Date: 01/11/2014 Date Account Charged off: 04/16/2016 Current Balance: $484.28

Billing/Shipping Data

BILLING DATA

First

Name Middle

Name Last

Name Address Line 1 Address Line 2 City State Zip Country

JESSICA SMITH 1780 DUBLIN

TRAIL #16 NEENAH WI 54956 USA

JESSICA SMITH 636 RACINE

STREET MENASHA WI 54952 USA

SHIPPING DATA

First

Name Middle

Name Last

Name Address Line 1 Address Line 2 City State Zip Country

GEORGE ARWOOD 345 STANLEY

CT NEENAH WI 549564760 US

JESSICA SMITH

JESSICA SMITH 1780 DUBLIN

TRAIL #16 NEENAH WI 54956 US

JESSICA SMITH 636 RACINE

STREET MENASHA WI 54952 US

SS SMITH

JESSICA 3701 E

CALUMET ST APPLETON WI 54915 US

SS SMITH

JESSICA 955 MUTUAL

WAY APPLETON WI 54913 US

PHONE DATA

Type Number Invalid Active

HOME () (000) 000-0000

0000000000

Y

EMAIL DATA

Type Address Invalid

Primary [email protected]


Andrew T. Thomasson

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN … -6- and Ninth Circuits, and the United...

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Transcript of IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN … -6- and Ninth Circuits, and the United...