Fulk v. LVNV Funding LLC, 2014 U.S. Dist. LEXIS 150220 (E.D. Ky. Oct. 21, 2014):
Fulk holds that statutory prejudgment interest can only be awarded by a trial court. The debt collector violated the FDCPA by adding extra-judicially accrued interest to the amount of a debt it reported to consumer reporting agencies.