Sorrentino v. Fay Servicing, LLC

CourtDistrict Court, D. Connecticut
DecidedSeptember 18, 2025
Docket3:25-cv-00098
StatusUnknown

This text of Sorrentino v. Fay Servicing, LLC (Sorrentino v. Fay Servicing, LLC) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sorrentino v. Fay Servicing, LLC, (D. Conn. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT KATHRYN SORRENTINO, ) 3:25-CV-00098 (SVN) Plaintiff, ) ) v. ) ) FAY SERVICING, LLC, and ED FAY, ) Defendants. ) September 18, 2025 RULING AND ORDER ON DEFENDANTS’ MOTION TO DISMISS Sarala V. Nagala, United States District Judge. In this action, pro se Plaintiff Kathryn Sorrentino alleges violations of her federal rights under the Fair Debt Collection Practices Act (“FDCPA”), 15 U.S.C § 1692 et seq., and the Truth in Lending Act (“TILA”), 15 U.S.C. § 1601 et seq., by Defendants Fay Servicing, LLC (“Fay Servicing”) and its CEO Ed Fay. The complaint alleges that periodic mortgage statements sent by Fay Servicing were inducements to collect payment and included false, misleading and unfair representations. Defendants have moved to dismiss the complaint for lack of standing and failure to state a claim. For the reasons detailed below, the Court GRANTS Defendants’ motion to dismiss. I. FACTUAL BACKGROUND The facts set forth in Plaintiff’s complaint, ECF No. 1, although sparse, are taken as true for purposes of a motion to dismiss. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). According to the complaint, Defendant Fay Servicing was attempting to collect a mortgage loan from Plaintiff. ECF No. 1 ¶ 9. Fay Servicing was required to send periodic statements to Plaintiff regarding the status of her mortgage loan, including the amount due and the due date, under the TILA. Id. ¶ 10. In addition to this required information, Defendant included a “remittance form”—a “detachable coupon for submitting payment”—with the periodic statements. Id. ¶ 11. Plaintiff attaches several such mortgage statements with accompanying “payment coupons” to her complaint. Id. at 6–13. Each of these statements is addressed to “Saverio A. Sorrentino,” not to Plaintiff. Id. Most of these mortgage statements also contained a section entitled “Delinquency Notice.” Id. That section stated: “You are late on your monthly payments. Failure to bring the account

current may result in additional fees or expenses, and in certain instances, you may risk foreclosure - the loss of your home.” Id. This section also listed the amount of the delinquency and directed the statement’s recipient to “call your account manage to explore your options.” Id. at 6–10, 12– 13. Plaintiff alleges that Fay Servicing’s use of the remittance form was “not intended solely to inform Plaintiff of the debt owed, but to induce payment,” thus constituting an attempt to collect a debt, in violation of the FDCPA. Id. ¶ 16. Plaintiff claims these statements went “beyond mere informational disclosures required by TILA and instead were intended to collect the debt using false, misleading, and unfair representations.” Id. ¶ 17.

Defendants have moved to dismiss the complaint, arguing that Plaintiff does not have standing, Defendants’ form mailings do not violate either the FDCPA or the TILA, and Defendants are not liable under TILA. ECF No. 17. As to Defendant Ed Fay, Defendants argue that the complaint fails to allege that he personally engaged in any of the actions alleged in the complaint. Defs.’ Br., ECF No. 18 at 1, n.1. Plaintiff opposes the motion. ECF No. 25.1 II. LEGAL STANDARD Pursuant to Federal Rule of Civil Procedure 12(b)(6), a defendant may move to dismiss a case or cause of action for failure to state a claim upon which relief can be granted. When

determining whether a complaint states a claim upon which relief can be granted, highly detailed allegations are not required, but the complaint must “contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Iqbal, 556 U.S. at 678 (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. at 678. This plausibility standard is not a “probability requirement,” but imposes a standard higher than “a sheer possibility that a defendant has acted unlawfully.” Id. In undertaking this analysis, the Court must “draw all reasonable inferences in [the plaintiff’s] favor, assume all well-pleaded factual allegations to be true, and

1 Plaintiff filed a sur-reply and motion for leave to file a sur-reply. ECF Nos. 27, 28. Sur-reply briefs cannot be filed without permission of the Court, which the Court grants only “upon a showing of good cause.” D. Conn. L.R. 7(d). “Sur-replies are appropriate only in the exceptional though rare case” where “a party demonstrates to the court that papers to which it seeks to file a reply raise new issues which are material to the disposition of the question before the court.” Sec. & Exch. Comm'n v. Xia, No. 21-CV-5350 (PKC) (RER), 2022 WL 2784871, at *1 (E.D.N.Y. July 15, 2022) (internal quotation marks and citation omitted). District courts may strike an unauthorized sur-reply. See Laguerre v. Nat'l Grid USA, No. 20-3901-cv, 2022 WL 728819, at *5 n. 7 (2d Cir. Mar. 11, 2022) (summary order). While Plaintiff claims the sur-reply is necessary to “address new arguments raised by Defendants in their reply and to ensure that the Court has a complete record for consideration of the motion,” Plaintiff’s sur-reply arguments are repetitive of her assertions in her original opposition and the sur-reply does not identify any new issues material to the Court’s disposition of Defendants’ motion to dismiss. As such, Plaintiff’s motion for leave to submit a sur-reply brief is denied. determine whether they plausibly give rise to an entitlement to relief.” Faber v. Metro. Life Ins. Co., 648 F.3d 98, 104 (2d Cir. 2011) (internal quotation marks and citation omitted). The Court is not “bound to accept conclusory allegations or legal conclusions masquerading as factual conclusions,” Rolon v. Henneman, 517 F.3d 140, 149 (2d Cir. 2008), and “a formulaic recitation of the elements of a cause of action will not do,” Iqbal, 556 U.S. at 678

(quoting Twombly, 550 U.S. at 555). Consequently, “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. (citing Twombly, 550 U.S. at 555). Ultimately, “[d]etermining whether a complaint states a plausible claim for relief will . . . be a context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Id. at 679. These pleading standards apply to self-represented parties. It is true that courts are under an obligation to extend “special solicitude” to pro se litigants and ought to read their pleadings “to raise the strongest arguments that they suggest.” Fowlkes v. Ironworkers Local 40, 790 F.3d 378, 387 (2d Cir. 2015) (quoting Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 477 (2d Cir. 2006))

(internal quotation marks omitted). But at the same time, a pro se complaint must meet the basic pleading standards outlined above to survive a motion to dismiss. Fowlkes, 790 F.3d at 387 (citing Twombly, 550 U.S. at 570). III. DISCUSSION A. FDCPA Claim The Court first dismisses Plaintiff’s FDCPA claim.

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Bluebook (online)
Sorrentino v. Fay Servicing, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sorrentino-v-fay-servicing-llc-ctd-2025.