Product: Credit reporting or other personal consumer reports

COMPLAINT FOR VIOLATIONS OF THE FAIR CREDIT REPORTING ACT ( FCRA ) I. INTRODUCTION This is an action for damages brought by the Plaintiff, XXXX XXXX XXXX, against Defendant Sloan/Nelnet Services for violations of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq. 
The FCRA mandates that entities that furnish information to consumer reporting agencies must report accurate information and conduct a reasonable investigation when a dispute is raised. Defendant has failed to comply with these statutory obligations, causing significant harm to Plaintiff 's creditworthiness, reputation, and causing emotional distress. 
II. JURISDICTION AND VENUE Jurisdiction of this Court arises under 15 U.S.C. 1681p and 28 U.S.C. 1331. The Plaintiff seeks damages under the FCRA. 
Venue is proper in this district pursuant to 28 U.S.C. 1391 ( b ) because the Defendant conducts business in this district and the wrongful acts giving rise to this complaint occurred within this district. 
III. PARTIES Plaintiff, XXXX XXXX XXXX, is a natural person and a resident of [ State ], residing at XXXX XXXX XXXX XXXX XXXX XXXX, XXXX, AZ. 
Defendant, Sloan/Nelnet Services , is a business entity with its principal address at XXXX XXXX XXXX, XXXX, XXXX XXXX, that provides information to consumer reporting agencies. 
IV. FACTUAL ALLEGATIONS On or about XX/XX/year>, Plaintiff discovered that Defendant Sloan/Nelnet Services had furnished inaccurate and misleading information regarding Plaintiffs account to multiple consumer reporting agencies, including but not limited to XXXX and XXXX. 
The inaccurate information includes, but is not limited to, incorrect payment history, dates of first delinquency, and dates of the last payment. 
Specifically, the payment history furnished by Sloan/Nelnet Services misrepresented Plaintiff 's payment activity, showing delinquencies and charge-offs that did not accurately reflect the Plaintiffs actual account status, in violation of 15 U.S.C. 1681s-2 ( a ). 
Additionally, XXXX and XXXX reported conflicting dates of first delinquency and last payment, causing further inaccuracies in Plaintiff 's credit report. 
Defendants actions, in failing to ensure the accuracy of the reported information, caused significant damage to Plaintiffs creditworthiness, emotional distress, and loss of reputation. 
V. COUNT I - VIOLATION OF 15 U.S.C. 1681s-2 ( a ) - NEGLIGENT VIOLATION Plaintiff incorporates by reference all preceding paragraphs as though fully set forth herein. 
Under 15 U.S.C. 1681s-2 ( a ), Defendant is required to provide accurate information to consumer reporting agencies and to ensure that such information is up-to-date and correct. 
Defendant negligently failed to comply with this duty by reporting inaccurate payment histories and conflicting delinquency dates. 
As a result of Defendants negligence, Plaintiff suffered harm, including damage to creditworthiness, emotional distress, and financial loss. 
Defendants actions were in reckless disregard of its obligations under the FCRA, constituting willful noncompliance. 
VI. COUNT II - VIOLATION OF 15 U.S.C. 1681s-2 ( b ) - FAILURE TO REINVESTIGATE Plaintiff incorporates by reference all preceding paragraphs as though fully set forth herein. 
Upon Plaintiffs formal dispute of the inaccurate information on or about XX/XX/year>, Defendant was obligated under 15 U.S.C. 1681s-2 ( b ) to conduct a reasonable reinvestigation of the disputed information. 
Defendant failed to conduct a reasonable investigation or correct the inaccuracies in Plaintiffs report within the 30-day period required by law. 
Defendants failure to adequately reinvestigate or amend the incorrect information is a direct violation of the FCRA. 
VII. WILLFUL NONCOMPLIANCE Defendants repeated and knowing failures to ensure accuracy and correct disputed information demonstrate willful noncompliance with the FCRA. 
Defendant 's actions were taken with reckless disregard for its statutory obligations, causing substantial and foreseeable harm to Plaintiff. 
VIII. PRAYER FOR RELIEF WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in favor of the Plaintiff and against the Defendant for : Statutory damages as provided under 15 U.S.C. 1681n ; Actual damages suffered by the Plaintiff, including damage to creditworthiness, emotional distress, and financial loss, as provided under 15 U.S.C. 1681o ; Punitive damages for willful noncompliance under 15 U.S.C. 1681n ; Costs of the action, including reasonable attorneys fees, as provided under 15 U.S.C. 1681n ( c ) ; Any other relief the Court deems just and proper.

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