United States District Court, D. New Jersey
K. WARREN, WARREN LAW GROUP, LLC On behalf of Plaintiff.
E. SCHOENFELD, WILMER CUTLER PICKERING HALE AND DORR LLP On
behalf of Defendant Chase Bank
J.T. MCKENNA, BALLARD SPAHR, LLP, ANDREW MICHELE CAROBUS,
BALLARD SPAHR LLP On behalf of Defendant Discover Products,
L. HILLMAN, U.S.D.J.
January 16, 2019, Plaintiff, Paula Visconti, filed a
complaint asserting violations of the Fair Credit Reporting
Act (“FCRA”), 15 U.S.C. § 1681, et seq., and
several state law violations, such as invasion of privacy and
negligence, against twelve defendants. Plaintiff avers
the following verbatim:
16. Plaintiff is a seventy-five-year-old retired Chief
17. Plaintiff retired from a major East Coast Hospital System
(Virtua Health) and wanted to take her interest of
participating in a small business, previously medical physics
consulting, to a new level by joining several very
experienced friends in forming a small dog training company.
18. Plaintiff eventually became the Chief Financial Officer
in Absolute Control Dog Training (ACDT) LLC in 2017,
investing over one-half a million dollars in the project
between 2017 and the first half of 2018.
19. Joseph R. Merry, Jr. (“Merry”) was the CEO of
the company after convincing Plaintiff and other officers
that he had the knowledge and contacts to grow the business.
20. Merry told the group that he was able to procure a
contract with Duke Energy for ACDT LLC and its OBA Parks K9
Scent Detection to provide guard dogs and handlers 24/7 to 13
energy plants spanning 7 states[.]
21. The contract was worth approximately 400 hundred million
dollars per annum to ACDT and Parks K9.
22. Merry produced a very detailed and lengthy signed
contract from Duke Energy that was later found to be
23. As time went on the actions of Merry, especially from
March onward in 2018, became more and more suspicious and it
was learned that all of his boasting about business was
24. After admitting this to an ACDT principal, Perry Parks,
and to subsidiary partners, Global K9 Protection Group based
in Opelika, Alabama, who had joined with ACDT and Parks K9 in
the 1st quarter of 2018 where the majority of the
preparations to implement this massive contract were being
undertaken, Merry fled the area and is now wanted by the
Federal Bureau of Investigation. There are also 4 outstanding
warrants for his arrest in the State of Massachusetts for
25. Plaintiff discovered in late June of 2018 that not only
had Merry depleted all the assets of ACDT, he had also opened
up multiple credit and loan accounts in her name, using her
personal information which he acquired during his multiple
deceptions from November, 2017 through the first quarter of
26. Plaintiff throughout the end of June and much of July and
into August as well notified all the creditors listed as
defendants to this complaint, all of them multiple times, but
none, not a single creditor took her allegations to be the
truth and instead began a ...