In Parkis v. Arrow Financial Services, LLS, No. 07 C 410, 2008 U.S. Dist. (N.D. Ill. January 8, 2008), the plaintiff sought certification of a class and brought suit against the defendant debt collector for proceeding on a collection beyond the statute of limitations period in violation of the federal Fair Debt Collection Practices Act. The plaintiff moved for summary judgment claiming the defendant's actions over six years from the date the action accrued were beyond the limitations period in Illinois. Parkis, slip op. at 2-7. When the defendant acquired the alleged debt, it did not obtain documentation, such as monthly statements or the plaintiff's credit application. Parkis, No., slip op. at 2-3. The defendant alleged that it had sent 16 letters and made 73 calls to the plaintiff in attempts to collect the debt. However, the plaintiff denied receiving any collection communications from the defendant. The only exhibit attached to the defendant's complaint in the circuit court of Cook County was an affidavit of indebtedness executed by an account manager for the defendant. Parkis, No., slip op. at 3-5.