Product: Credit reporting or other personal consumer reports

UNITED STATES XXXX XXXX FOR THE [ APPROPRIATE DISTRICT COURT ] XXXX XXXX, Plaintiff, v. 
CARRINGTON MORTGAGE SERVICES , LLC, XXXX XXXX XXXX XXXX XXXX, XXXX, XXXX, and XXXX XXXX XXXX, Defendants. 
CIVIL ACTION NO. : [ TO BE ASSIGNED ] COMPLAINT FOR VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT ( 15 U.S.C. 1692 ), THE FAIR CREDIT REPORTING ACT ( 15 U.S.C. 1681 ), AND OTHER RELIEF INTRODUCTION 1.This action arises from Defendants violations of the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692, and the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681, involving unlawful debt collection practices, failure to investigate disputes, and the reporting of false information on Plaintiffs credit reports. 
XXXX seeks statutory, actual, and punitive damages, along with attorneys fees and costs, to remedy Defendants unlawful conduct. 

PARTIES XXXX XXXXis a natural person residing XXXX XXXX XXXX, XXXX, XXXX  XXXX XXXX born XXXX XXXX, XXXX, and is a consumer as defined by 15 U.S.C. 1692a ( 3 ) and 15 U.S.C. 1681a ( c ). 
XXXX MORTGAGE SERVICES, XXXX ( XXXX ) is a mortgage servicing company with its principal office located at [ Insert Address ] and regularly engages in collecting debts and servicing mortgages. XXXX is a debt collector under 15 U.S.C. 1692a ( 6 ). 
XXXX XXXX XXXX XXXX XXXX XXXXXXXX ) is a credit reporting agency headquartered at [ Insert Address ] that regularly assembles and evaluates consumer credit information for profit. 
XXXX, XXXX ( XXXX ) XXXX a credit reporting agency headquartered at [ Insert Address ] that regularly assembles and evaluates consumer credit information for profit. 
XXXX, XXXX ( XXXX ) XXXX a credit reporting agency headquartered at [ Insert Address ] that regularly assembles and evaluates consumer credit information for profit. 

JURISDICTION AND VENUE XXXX Court has jurisdiction under 28 U.S.C. 1331 and 15 U.S.C. 1692k ( d ) and 1681p, as this action arises under federal law. 
XXXX is proper in this district pursuant to XXXX XXXX. XXXX ( b ), as a substantial part of the events giving rise to the claims occurred within this district. 

FACTUAL ALLEGATIONS XXXX entered into a mortgage agreement serviced by XXXX XXXX Mortgage XXXX XXXX 
XXXX or around [ Insert Date ], XXXX began XXXX to collect an alleged past-due amount of {$26000.00}, despite XXXX having disputed the debt multiple times, including disputing the accuracy of its reporting on Plaintiffs credit reports. 
XXXX communicated XXXX XXXX  via phone and mail, including after XXXX explicitly requested XXXX cease XXXX communications and validate the debt. 
XXXX failed XXXX provide adequate validation of the debt yet continued its collection efforts in violation of 15 U.S.C. 1692c ( c ). 
XXXX also XXXX to meaningfully identify itself in voicemail messages, violating 15 U.S.C. 1692d ( 6 ). 
XXXX Plaintiffs XXXX, XXXX, and XXXX credit XXXX, XXXX falsely XXXX the following : A foreclosure proceeding was initiated despite Plaintiff actively disputing the debt. 
The account was listed as 180 days late for multiple months, even during periods when payments were made or disputes were pending. 
The disputed debt was not flagged as disputed, in violation of the FCRA. 
XXXX formally disputed these inaccuracies with XXXX, XXXX, and XXXX under 15 U.S.C. 1681i, but the reporting agencies failed to conduct reasonable investigations or correct the errors. 
XXXX reporting agencies relied on Carringtons erroneous XXXX, which continued to harm Plaintiffs creditworthiness XXXX causing denial of credit opportunities, higher interest rates, and emotional distress. 

CAUSES OF ACTION Count I Violations of the FDCPA XXXX XXXX Mortgage XXXX XXXX repeats and realleges all preceding paragraphs as if fully set forth herein. 
XXXX violated XXXX FDCPA by : a. Continuing to contact Plaintiff after receiving a written cease-and-desist request, in violation of 15 U.S.C. 1692c ( c ) ; b. Failing to meaningfully identify itself in voicemail messages, in violation of 15 U.S.C. 1692d ( 6 ) ; c. Misrepresenting the status of the debt, in violation of 15 U.S.C. 1692e ( 2 ). 
XXXX a direct and proximate result, XXXX suffered emotional distress, reputational harm, and out-of-pocket costs. 

Count XXXX Violations of the FCRA XXXX XXXX XXXX XXXX repeats and realleges all preceding paragraphs as if fully set forth herein. 
XXXX, XXXX, and XXXX violated XXXX FCRA by : a. Failing to ensure the maximum possible accuracy of Plaintiffs credit information, in violation of 15 U.S.C. 1681e ( b ) ; b. Failing to conduct a reasonable investigation after XXXX disputed inaccuracies, in violation of 15 U.S.C. 1681i ( a ).

23.Carrington violated 15 U.S.C. 1681s-2 ( b ) by : a. Failing to properly investigate disputes forwarded by the credit reporting agencies ; b. Continuing to furnish inaccurate and incomplete information about Plaintiffs account. 
XXXX a direct and proximate result of these violations, XXXX suffered economic harm, denial of credit, emotional distress, and damage to Plaintiffs reputation. 

PRAYER FOR RELIEF WHEREFORE, Plaintiff requests judgment in Plaintiffs favor and against Defendants as follows : XXXX damages pursuant to 15 U.S.C. 1681o ( a ) and 15 U.S.C. 1692k ( a ) ( 1 ) ; 2.Statutory damages pursuant to 15 U.S.C. 1692k ( a ) ( 2 ) ( A ) and 15 U.S.C. 1681n ( a ) ( 1 ) ( A ) ; 3.Punitive damages pursuant to 15 U.S.C. 1681n ( a ) ( 2 ) ; 4.Costs and attorneys fees pursuant to 15 U.S.C. 1692k ( a ) ( 3 ) and 15 U.S.C. 1681n ( a ) ( 3 ) ; 5.Such other relief as the Court deems just and proper. 

DEMAND FOR JURY TRIAL Plaintiff demands a trial by jury on all issues so triable.