In Ramirez v. Palisades Collection LLC, No. 07 C 3840, (N.D. Ill. June 23, 2008), on cross-motions for summary judgment, the court considered whether plaintiff's claim that the defendant debt collector's debt collection suit violated the Fair Debt Collection Practices Act as a deceptive practice because it was filed after the 5-year limitations period of section 13-205, or if the underlying suit was subject to the 10-year period of section 13-206. Ramirez, slip op. at 6. There was no dispute over the existence of a contract and only an affidavit of indebtedness was attached to the complaint. Ramirez, slip op. at 7-8. The court noted that the defendant's assertion that the 10-year period applied was undermined by the fact that parol evidence would be required to determine its right to sue, whether the assignments of the contract were lawful, and whether the original terms were altered. Ramirez, slip op. at 9. Furthermore, the court held that the Harris Trust & Savings Bank v. McCray reasoning did not apply to the case because the issue addressed did not apply to all credit card agreements and did not consider whether section 13-205 applied. Ramirez, slip op. at 10-11. The Court added that it was uncertain whether parol evidence would be required to prove elements not defined in the account statement. Specifically, the court noted that statements typically do not provide terms defining default or other remedies or whether any terms may be changed or altered. Furthermore, the statements do not contain an affirmative promise to pay by the consumer. Ramirez, slip op. at 4.