… should not be held in contempt and sanctioned for its willful violations of the automatic stay provisions of Section 362(a) of the Bankruptcy Code
and 362(k) of the Bankruptcy Code and for actual damages and punitive damages in the amount of $20,000.00.
The punitive damages of $20,000.00 sought in this case are reasonable and necessary to prevent Creditor and Collection Agency from taking these actions in future cases. Creditor and Collection Agency are experienced in the bankruptcy court
and with its rules, and therefore, has no excuse for the actions they took in this matter. In addition, the $20,000.00 amount requested is necessary and sufficient enough to sting the pocketbook of a large company such as Creditor and Collection Agency.
Based upon Creditor and Collection Agency’s willful actions and the consequences they have had upon the Debtor, he requests $20,000.00 in punitive damages from Creditor and Collection Agency in this case and a refund of the $3,093.71 taken by Creditor and the $14,985.00 being held by Creditor.
WHEREFORE, … and for punitive damages in the amount of $20,000.00 and actual damages in the amount of $18,078.71, consisting of a refund of the $3,093.71 taken by Creditor and the $14,985.00 being held by Creditor, and for such other and further relief as is just, including any additional damages which the Debtor may incur from the date of the filing of this Motion through the date of the hearing.