Product: Credit reporting or other personal consumer reports

UNITED STATES XXXX COURT [ INSERT DISTRICT ] XXXX XXXX, XXXX v. 
EDFinancial Services, Defendant COMPLAINT Plaintiff, XXXX XXXX ( Plaintiff ), alleges the following against EDFinancial Services ( Defendant ) : I. INTRODUCTION XXXX is an action for damages brought by an individual consumer for violations of the Fair Debt Collection Practices Act ( " FDCPA '' ), 15 U.S.C. 1692 et seq., and the Fair Credit Reporting Act ( " FCRA '' ), 15 U.S.C. 1681 et seq.

2.Plaintiff seeks actual damages, statutory damages, punitive damages, costs, and attorneys fees for Defendants violations.

II. JURISDICTION AND VENUE 3.Jurisdiction is proper under 28 U.S.C. 1331 because this action arises under federal statutes.

4.Venue is proper under 28 U.S.C. 1391 ( b ) because Defendant conducts business in this District, and a substantial part of the events or omissions giving rise to the claims occurred in this District. 

XXXX. XXXX XXXX XXXX XXXX XXXX XXXX natural person residing at XXXX XXXX XXXX, XXXX, CA XXXX. 
6.Plaintiff is a " consumer '' as defined by 15 U.S.C. 1692a ( 3 ) and 15 U.S.C. 1681a ( c ).

7.Defendant EDFinancial Services is a [ describe Defendants business and registered location ] and is a " debt collector '' as defined by 15 U.S.C. 1692a ( 6 ).

IV. FACTUAL ALLEGATIONS 8.On or about [ DATE ], Plaintiff discovered that Defendant was attempting to collect an alleged debt from Plaintiff related to a [ loan/credit account ] with an account number ending in [ XXXX ]. 
9.Plaintiff previously sent a written notice to Defendant on [ DATE ] requesting that all communication regarding the alleged debt cease pursuant to 15 U.S.C. 1692c ( c ).

10.Despite this notice, Defendant continued to contact Plaintiff, including but not limited to : a. Phone calls to Plaintiffs home and mobile numbers ; b. Letters mailed to Plaintiffs address ; c. Reporting the debt inaccurately to credit reporting agencies.

11.Defendants actions caused Plaintiff significant emotional distress, anxiety, and financial harm. 
Inaccurate Credit Reporting 12.On [ DATE ], Plaintiff reviewed her credit reports from XXXX, XXXX, and XXXX and discovered inaccuracies in the reporting of her payment history regarding the alleged debt. 
13.Specifically, the credit reports contained the following inaccuracies : a. Reporting missed payments that did not occur ; b. Reporting the debt as " open '' despite it being closed or disputed.

14.Plaintiff promptly disputed these inaccuracies with the credit reporting agencies in writing on [ DATE ] and notified Defendant of the inaccuracies.

15.Despite Plaintiffs disputes, the inaccurate information remained on her credit reports, damaging her creditworthiness.

V. CLAIMS FOR RELIEF COUNT I : Violation of the FDCPA ( 15 U.S.C. 1692 et seq. ) 16.Plaintiff repeats and re-alleges all prior paragraphs as though fully set forth herein.

17.Defendant violated the FDCPA by : a. Communicating with Plaintiff after being notified to cease communications, in violation of 15 U.S.C. 1692c ( c ) ; b. Using false, deceptive, or misleading representations in connection with the collection of the debt, in violation of 15 U.S.C. 1692e ; c. Engaging in conduct the natural consequence of which was to harass, oppress, or abuse Plaintiff, in violation of 15 U.S.C. 1692d.

COUNT II : Violation of the FCRA ( 15 U.S.C. 1681 et seq. ) 18.Plaintiff repeats and re-alleges all prior paragraphs as though fully set forth herein. 
19.Defendant violated the FCRA by : a. Failing to conduct a reasonable investigation of Plaintiffs disputes regarding the inaccurate reporting of her payment history ; b. Reporting inaccurate information to credit reporting agencies in violation of 15 U.S.C. 1681s-2 ( a ) ; c. Continuing to report inaccurate information after receiving notice of Plaintiffs disputes, in violation of 15 U.S.C. 1681s-2 ( b ).

VI. PRAYER FOR RELIEF WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in her favor and against Defendant as follows : 1.Awarding actual damages under 15 U.S.C. 1692k ( a ) ( 1 ) and 15 U.S.C. 1681o ; 2.Awarding statutory damages under 15 U.S.C. 1692k ( a ) ( 2 ) ( A ) and 15 U.S.C. 1681n ; 3.Awarding punitive damages under 15 U.S.C. 1681n ( a ) ( 2 ) ; 4.Awarding costs and reasonable attorneys fees under 15 U.S.C. 1692k ( a ) ( 3 ) and 15 U.S.C. 1681o ( a ) ( 2 ) ; 5.Granting such other and further relief as the Court deems just and proper.