Product: Credit reporting or other personal consumer reports

On the XXXXXXXX XXXX XXXX XXXXXX/XX/XXXX XXXX XXXX XXXX reported a collection of {$7700.00} with an account number as XXXX on my Experian credit report without my knowledge, consent, or authorization. 

Since then XXXX XXXX XXXX has been increasing a balance on an account that has already been charged off, closed and they have already received the tax benefit. 

15 U.S. Code 1692c ( c ) : ( c ) Ceasing communication If a consumer notifies a debt collector in writing that the consumer refuses to pay a debt or that the consumer wishes the debt collector to cease further communication with the consumer, the debt collector shall not communicate further with the consumer with respect to such debt, except ( 1 ) to advise the consumer that the debt collectors further efforts are being terminated ; ( 2 ) to notify the consumer that the debt collector or creditor may invoke specified remedies which are ordinarily invoked by such debt collector or creditor; or ( 3 ) where applicable, to notify the consumer that the debt collector or creditor intends to invoke a specified remedy. 

XXXX has allowed XXXX XXXX XXXX to report the same inaccurate information on my credit report under an entirely different name COMPUTER CHECK VERIFICAT XXXX is also reporting a collection that is listed as XXXX XXXX XXXX which is inaccurate and has already been deleted from my Experian credit report. 

Experian has a history of allowing inaccurate items to be reported on my credit report that are not verified with a proper investigation. 

In XXXX XXXX XXXX XXXX XXXX XXXX XXXX, 748 F. Supp. 2d 1030, 1036 ( XXXX XXXX XXXX ), the court held that failure to properly investigate and correct disputed information can result in liability for both the furnisher and the credit reporting agency. This principle applies here, as the continued reporting of inaccurate information has caused undue harm to my creditworthiness.

12 C.F.R. 1016.7 states that, A consumer may exercise the right to opt out at any time.

I am hereby exercising my right to opt out of any adverse items, collection accounts, credit usage amounts, phone numbers and any other derogatory items or remarks made by any party on to my reports under any circumstances. This serves as lawful notice.

15 U.S. Code 1681c ( a ) ( 5 ) states Except as authorized under subsection ( b ), no consumer reporting agency may make any consumer report containing any of the following items of information Any other adverse item of information, other than records of convictions of crimes which antedates the report by more than seven years. '' Under 5 of the FTC Act, the Commission expects that each financial institution will have in place at least the administrative or other safeguards necessary to honor any opt-out requests made by consumers under the Privacy Rule.

12 C.F.R. 1022.42 Reasonable policies and procedures concerning the accuracy and integrity of furnished information. ( a ) Policies and procedures. Each furnisher must establish and implement reasonable written policies and procedures regarding the accuracy and integrity of the information relating to consumers that it furnishes to a consumer reporting agency. The policies and procedures must be appropriate to the nature, size, complexity, and scope of each furnisher 's activities.

( b ) Guidelines. Each furnisher must consider the guidelines in appendix E of this part in developing its policies and procedures required by this section, and incorporate those guidelines that are appropriate.

( c ) Reviewing and updating policies and procedures. Each furnisher must review its policies and procedures required by this section periodically and update them as necessary to ensure their continued effectiveness.

12 C.F.R. 1026.10 Payments. ( a ) General rule. A creditor shall credit a payment to the consumer 's account as of the date of receipt, except when a delay in crediting does not result in a finance or other charge or except as provided in paragraph ( b ) of this section.

( b ) Specific requirements for payments ( 1 ) General rule. A creditor may specify reasonable requirements for payments that enable most consumers to make conforming payments.

( 2 ) Examples of reasonable requirements for payments. Reasonable requirements for making payment may include : ( i ) Requiring that payments be accompanied by the account number or payment stub ; ( ii ) Setting reasonable cut-off times for payments to be received by mail, by electronic means, by telephone, and in person ( except as provided in paragraph ( b ) ( 3 ) of this section ), provided that such cut-off times shall be no earlier than 5 p.m. on the payment due date at the location specified by the creditor for the receipt of such payments ; ( iii ) Specifying that only checks or money orders should be sent by mail ; ( iv ) Specifying that payment is to be made in XXXXXXXX XXXX or ( v ) Specifying one particular address for receiving payments, such as a post office box.

( 3 ) In-person payments on credit card accounts ( i ) General. Notwithstanding 1026.10 ( b ), payments on a credit card account under an open-end ( not home-secured ) consumer credit plan made in person at a branch or office of a card issuer that is a financial institution prior to the close of business of that branch or office shall be considered received on the date on which the consumer makes the payment. A card issuer that is a financial institution shall not impose a cut-off time earlier than the close of business for any such payments made in person at any branch or office of the card issuer at which such payments are accepted. Notwithstanding 1026.10 ( b ) ( 2 ) ( ii ), a card issuer may impose a cut-off time earlier than 5 p.m. for such payments, if the close of business of the branch or office is earlier than 5 p.m. ( ii ) Financial institution. For purposes of paragraph ( b ) ( 3 ) of this section, financial institution shall mean a bank, savings association, or credit union.

( 4 ) Nonconforming payments ( i ) In general. Except as provided in paragraph ( b ) ( 4 ) ( ii ) of this section, if a creditor specifies, on or with the periodic statement, requirements for the consumer to follow in making payments as permitted under this 1026.10, but accepts a payment that does not conform to the requirements, the creditor shall credit the payment within five days of receipt.

( ii ) Payment methods promoted by creditor. If a creditor promotes a method for making payments, such payments shall be considered conforming payments in accordance with this paragraph ( b ) and shall be credited to the consumer 's account as of the date of receipt, except when a delay in crediting does not result in a finance or other charge.

( c ) Adjustment of account. If a creditor fails to credit a payment, as required by paragraphs ( a ) or ( b ) of this section, in time to avoid the imposition of finance or other charges, the creditor shall adjust the consumer 's account so that the charges imposed are credited to the consumer 's account during the next billing cycle.

( d ) Crediting of payments when creditor does not receive or accept payments on due date ( 1 ) General. Except as provided in paragraph ( d ) ( 2 ) of this section, if a creditor does not receive or accept payments by mail on the due date for payments, the creditor may generally not treat a payment received the next business day as late for any purpose. For purposes of this paragraph ( d ), the next business day means the next day on which the creditor accepts or receives payments by mail.

( 2 ) Payments accepted or received other than by mail. If a creditor accepts or receives payments made on the due date by a method other than mail, such as electronic or telephone payments, the creditor is not required to treat a payment made by that method on the next business day as timely, even if it does not accept mailed payments on the due date.

( e ) Limitations on fees related to method of payment. For credit card accounts under an open-end ( not home-secured ) consumer credit plan, a creditor may not impose a separate fee to allow consumers to make a payment by any method, such as mail, electronic, or telephone payments, unless such payment method involves an expedited service by a customer service representative of the creditor. For purposes of paragraph ( e ) of this section, the term creditor includes a third party that collects, receives, or processes payments on behalf of a creditor.

( f ) Changes by card issuer. If a card issuer makes a material change in the address for receiving payments or procedures for handling payments, and such change causes a material delay in the crediting of a payment to the consumer 's account during the 60-day period following the date on which such change took effect, the card issuer may not impose any late fee or finance charge for a late payment on the credit card account during the 60-day period following the date on which the change took effect.

The Privacy Act of 1974, also known as 5 U.S. Code 552a, is a United States federal law that establishes a Code of Fair Information Practice. This code governs the collection, maintenance, use, and dissemination of personally identifiable information about individuals. Federal agencies maintain this information in systems of records. A system of records refers to a group of records controlled by an agency, from which information can be retrieved either by the individuals name or by an assigned identifier. Here are some key points about the Privacy Act : ( 1 ) Purpose : The Privacy Act aims to protect individuals privacy rights by regulating how federal agencies handle their personal information.

( 2 ) Notice : Agencies must provide public notice of their systems of records through publication in the Federal Register.

( 3 ) Consent : Disclosure of an individuals record from a system of records is generally prohibited without the written consent of the individual. However, there are statutory exceptions that allow for disclosure.

( 4 ) Access and Amendment : Individuals have the right to seek access to and amendment of their records.

( 5 ) Record-Keeping Requirements : The Act sets forth various requirements for agencies regarding record-keeping.

15 U.S. Code 1681 : ( a ) Accuracy and fairness of credit reporting The Congress makes the following findings : ( 1 ) The banking system is dependent upon fair and accurate credit reporting. Inaccurate credit reports directly impair the efficiency of the banking system, and unfair credit reporting methods undermine the public confidence which is essential to the continued functioning of the banking system.

( 2 ) An elaborate mechanism has been developed for investigating and evaluating the credit worthiness, credit standing, credit capacity, character, and general reputation of consumers.

( 3 ) Consumer reporting agencies have assumed a vital role in assembling and evaluating consumer credit and other information on consumers.

( 4 ) There is a need to insure that consumer reporting agencies exercise their grave responsibilities with fairness, impartiality, and a respect for the consumers right to privacy.

( b ) Reasonable procedures It is the purpose of this sub-chapter to require that consumer reporting agencies adopt reasonable procedures for meeting the needs of commerce for consumer credit, personnel, insurance, and other information in a manner which is fair and equitable to the consumer, with regard to the confidentiality, accuracy, relevancy, and proper utilization of such information in accordance with the requirements of this sub-chapter.

( Pub. L. 90321, title VI, 602, as added Pub. L. 91508, title VI, 601, Oct. 26, 1970, 84 Stat. 1128. ) 15 U.S. Code 1681a Definitions ; rules of construction ( a ) Definitions and rules of construction set forth in this section are applicable for the purposes of this sub-chapter.

( c ) The term consumer means an individual.

( d ) Consumer Report.

( 1 ) In general.The term consumer report means any written, oral, or other communication of any information by a consumer reporting agency bearing on a consumers credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living which is used or expected to be used or collected in whole or in part for the purpose of serving as a factor in establishing the consumers eligibility for ( A ) credit or insurance to be used primarily for personal, family, or household purposes ; ( B ) employment purposes ; or ( C ) any other purpose authorized under section 1681b of this title.

( 2 ) Exclusions.Except as provided in paragraph ( 3 ), the term consumer report does not include ( A ) subject to section 1681s-3 of this title, any ( I ) report containing information solely as to transactions or experiences between the consumer and the person making the report ; ( ii ) communication of that information among person related by common ownership or affiliated by corporate control ; or ( iii ) communication of other information among person related by common ownership or affiliated by corporate control, if it is clearly and conspicuously disclosed to the consumer that the information may be communicated among such person and the consumer is given the opportunity, before the time that the information is initially communicated, to direct that such information not be communicated among such person ; ( B ) any authorization or approval of a specific extension of credit directly or indirectly by the issuer of a credit card or similar device ; ( C ) any report in which a person who has been requested by a third party to make a specific extension of credit directly or indirectly to a consumer conveys his or her decision with respect to such request, if the third party advises the consumer of the name and address of the person to whom the request was made, and such person makes the disclosures to the consumer required under section 1681m of this title, or ( D ) a communication described in subsection ( o ) or ( x ). [ 1 ] 15 U.S. Code 1825 ( 2 ) ( b ) : ( B ) Any person who knowingly makes, or causes to be made, a false entry or statement in any report required under this chapter ; who knowingly makes, or causes to be made, any false entry in any account, record, or memorandum required to be established and maintained by any person or in any notification or other information required to be submitted to the Secretary under section 1823 of this title ; who knowingly neglects or fails to make or cause to be made, full, true, and correct entries in such accounts, records, memorandum, notification, or other materials ; who knowingly removes any such documentary evidence out of the jurisdiction of the United States ; who knowingly mutilates, alters, or by any other means falsifies any such documentary evidence ; or who knowingly refuses to submit any such documentary evidence to the Secretary for inspection and copying shall be guilty of an offense against the United States, and upon conviction thereof shall be fined not more than {$5000.00}, or imprisoned for not more than three years, or both.

Under 807 of the Fair Debt Collection Practices Act False or misleading representations A debt collector may not use any false, deceptive, or misleading representation or means in connection with the collection of any debt. Without limiting the general application of the foregoing, the following conduct is a violation of this section : ( 1 ) The false representation or implication that the debt collector is vouched for, bonded by, or affiliated with the United States or any State, including the use of any badge, uniform, or facsimile thereof.

( 2 ) The false representation of -- ( A ) the character, amount, or legal status of any debt; or ( B ) any services rendered or compensation which may be lawfully received by any debt collector for the collection of a debt.

( 3 ) The false representation or implication that any individual is an attorney or that any communication is from an attorney.

( 4 ) The representation or implication that nonpayment of any debt will result in the arrest or imprisonment of any person or the seizure, garnishment, attachment, or sale of any property or wages of any person unless such action is lawful and the debt collector or creditor intends to take such action.

( 5 ) The threat to take any action that can not legally be taken or that is not intended to be taken.

( 6 ) The false representation or implication that a sale, referral, or other transfer of any interest in a debt shall cause the consumer to -- ( A ) lose any claim or defense to payment of the debt; or ( B ) become subject to any practice prohibited by this subchapter.

( 7 ) The false representation or implication that the consumer committed any crime or other conduct in order to disgrace the consumer.

( 8 ) Communicating or threatening to communicate to any person credit information which is known or which should be known to be false, including the failure to communicate that a disputed debt is disputed.

( 9 ) The use or distribution of any written communication which simulates or is falsely represented to be a document authorized, issued, or approved by any court, official, or agency of the United States or any State, or which creates a false impression as to its source, authorization, or approval.

( 10 ) The use of any false representation or deceptive means to collect or attempt to collect any debt or to obtain information concerning a consumer.

( 11 ) The failure to disclose in the initial written communication with the consumer and, in addition, if the initial communication with the consumer is oral, in that initial oral communication, that the debt collector is attempting to collect a debt and that any information obtained will be used for that purpose, and the failure to disclose in subsequent communications that the communication is from a debt collector, except that this paragraph shall not apply to a formal pleading made in connection with a legal action.

( 12 ) The false representation or implication that accounts have been turned over to innocent purchasers for value.

( 13 ) The false representation or implication that documents are legal process.

( 14 ) The use of any business, company, or organization name other than the true name of the debt collector 's business, company, or organization.

( 15 ) The false representation or implication that documents are not legal process forms or do not require action by the consumer.

( 16 ) The false representation or implication that a debt collector operates or is employed by a consumer reporting agency as defined by section 1681a ( f ) of this title.

Under 812 of the Fair Debt Collection Practices Act Furnishing certain deceptive forms ( a ) It is unlawful to design, compile, and furnish any form knowing that such form would be used to create the false belief in a consumer that a person other than the creditor of such consumer is participating in the collection of or in an attempt to collect a debt such consumer allegedly owes such creditor, when in fact such person is not so participating.

( b ) Any person who violates this section shall be liable to the same extent and in the same manner as a debt collector is liable under section 1692k of this title for failure to comply with a provision of this sub-chapter.

15 U.S. Code 6801 : ( a ) Privacy obligation policy It is the policy of the Congress that each financial institution has an affirmative and continuing obligation to respect the privacy of its customers and to protect the security and confidentiality of those customers nonpublic personal information.

( b ) Financial institutions safeguards In furtherance of the policy in subsection ( a ), each agency or authority described in section 6805 ( a ) of this title, other than the Bureau of Consumer Financial Protection, shall establish appropriate standards for the financial institutions subject to their jurisdiction relating to administrative, technical, and physical safeguards ( 1 ) to insure the security and confidentiality of customer records and information ; ( 2 ) to protect against any anticipated threats or hazards to the security or integrity of such records ; and ( 3 ) to protect against unauthorized access to or use of such records or information which could result in substantial harm or inconvenience to any customer.

( Pub. L. 106102, title V, 501, Nov. 12, 1999, 113 Stat. 1436 ; Pub. L. 111203, title X, 1093 ( 1 ), July 21, 2010, 124 Stat. 2095. ) 15 U.S. Code 6802 : ( a ) Notice requirements Except as otherwise provided in this sub-chapter, a financial institution may not, directly or through any affiliate, disclose to a non-affiliated third party any nonpublic personal information, unless such financial institution provides or has provided to the consumer a notice that complies with section 6803 of this title.

( b ) Opt out ( 1 ) In general A financial institution may not disclose nonpublic personal information to a non-affiliated third party unless ( A ) such financial institution clearly and conspicuously discloses to the consumer, in writing or in electronic form or other form permitted by the regulations prescribed under section 6804 of this title, that such information may be disclosed to such third party ; ( B ) the consumer is given the opportunity, before the time that such information is initially disclosed, to direct that such information not be disclosed to such third party ; and ( C ) the consumer is given an explanation of how the consumer can exercise that nondisclosure option.

( 2 ) Exception This subsection shall not prevent a financial institution from providing nonpublic personal information to a non-affiliated third party to perform services for or functions on behalf of the financial institution, including marketing of the financial institutions own products or services, or financial products or services offered pursuant to joint agreements between two or more financial institutions that comply with the requirements imposed by the regulations prescribed under section 6804 of this title, if the financial institution fully discloses the providing of such information and enters into a contractual agreement with the third party that requires the third party to maintain the confidentiality of such information.

( c ) Limits on reuse of information Except as otherwise provided in this sub-chapter, a non-affiliated third party that receives from a financial institution nonpublic personal information under this section shall not, directly or through an affiliate of such receiving third party, disclose such information to any other person that is a non-affiliated third party of both the financial institution and such receiving third party, unless such disclosure would be lawful if made directly to such other person by the financial institution.

( d ) Limitations on the sharing of account number information for marketing purposes A financial institution shall not disclose, other than to a consumer reporting agency, an account number or similar form of access number or access code for a credit card account, deposit account, or transaction account of a consumer to any non-affiliated third party for use in telemarketing, direct mail marketing, or other marketing through electronic mail to the consumer.

( e ) General exceptions Subsections ( a ) and ( b ) shall not prohibit the disclosure of nonpublic personal information ( 1 ) as necessary to effect, administer, or enforce a transaction requested or authorized by the consumer, or in connection with ( A ) servicing or processing a financial product or service requested or authorized by the consumer ; ( B ) maintaining or servicing the consumers account with the financial institution, or with another entity as part of a private label credit card program or other extension of credit on behalf of such entity ; or ( C ) a proposed or actual securitization, secondary market sale ( including sales of servicing rights ), or similar transaction related to a transaction of the consumer ; ( 2 ) with the consent or at the direction of the consumer ; ( 3 ) ( A ) to protect the confidentiality or security of the financial institutions records pertaining to the consumer, the service or product, or the transaction therein ; ( B ) to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability ; ( C ) for required institutional risk control, or for resolving customer disputes or inquiries ; ( D ) to persons holding a legal or beneficial interest relating to the consumer ; or ( E ) to persons acting in a fiduciary or representative capacity on behalf of the consumer ; ( 4 ) to provide information to insurance rate advisory organizations, guaranty funds or agencies, applicable rating agencies of the financial institution, persons assessing the institutions compliance with industry standards, and the institutions attorneys, accountants, and auditors ; ( 5 ) to the extent specifically permitted or required under other provisions of law and in accordance with the Right to Financial Privacy Act of 1978 [ 12 U.S. Code 3401 et seq. ], to law enforcement agencies ( including the Bureau of Consumer Financial Protection [ 1 ] a Federal functional regulator, the Secretary of the Treasury with respect to sub-chapter II of chapter 53 of title 31, and chapter 2 of title I of Public Law 91508 ( 12 U.S. Code 19511959 ), a State insurance authority, or the Federal Trade Commission ), self-regulatory organizations, or for an investigation on a matter related to public safety ; ( 6 ) ( A ) to a consumer reporting agency in accordance with the Fair Credit Reporting Act [ 15 U.S. Code 1681 et seq. ], or ( B ) from a consumer report reported by a consumer reporting agency ; ( 7 ) in connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of a business or operating unit if the disclosure of nonpublic personal information concerns solely consumers of such business or unit; or ( 8 ) to comply with Federal, State, or local laws, rules, and other applicable legal requirements ; to comply with a properly authorized civil, criminal, or regulatory investigation or subpoena or summons by Federal, State, or local authorities ; or to respond to judicial process or government regulatory authorities having jurisdiction over the financial institution for examination, compliance, or other purposes as authorized by law.

( Pub. L. 106102, title V, 502, Nov. 12, 1999, 113 Stat. 1437 ; Pub. L. 111203, title X, 1093 ( 2 ), July 21, 2010, 124 Stat. 2095. ) 15 U.S. Code 6803 : ( a ) Disclosure required At the time of establishing a customer relationship with a consumer and not less than annually during the continuation of such relationship, a financial institution shall provide a clear and conspicuous disclosure to such consumer, in writing or in electronic form or other form permitted by the regulations prescribed under section 6804 of this title, of such financial institutions policies and practices with respect to ( 1 ) disclosing nonpublic personal information to affiliates and non-affiliated third parties, consistent with section 6802 of this title, including the categories of information that may be disclosed ; ( 2 ) disclosing nonpublic personal information of persons who have ceased to be customers of the financial institution; and ( 3 ) protecting the nonpublic personal information of consumers.

( b ) Regulations Disclosures required by subsection ( a ) shall be made in accordance with the regulations prescribed under section 6804 of this title.

( c ) Information to be included The disclosure required by subsection ( a ) shall include ( 1 ) the policies and practices of the institution with respect to disclosing nonpublic personal information to non-affiliated third parties, other than agents of the institution, consistent with section 6802 of this title, and including ( A ) the categories of persons to whom the information is or may be disclosed, other than the persons to whom the information may be provided pursuant to section 6802 ( e ) of this title ; and ( B ) the policies and practices of the institution with respect to disclosing of nonpublic personal information of persons who have ceased to be customers of the financial institution ; ( 2 ) the categories of nonpublic personal information that are collected by the financial institution ; ( 3 ) the policies that the institution maintains to protect the confidentiality and security of nonpublic personal information in accordance with section 6801 of this title ; and ( 4 ) the disclosures required, if any, under section 1681a ( d ) ( 2 ) ( A ) ( iii ) of this title.

( d ) Exemption for certified public accountants ( 1 ) In general The disclosure requirements of subsection ( a ) do not apply to any person, to the extent that the person is ( A ) a certified public accountant ; ( B ) certified or licensed for such purpose by a State ; and ( C ) subject to any provision of law, rule, or regulation issued by a legislative or regulatory body of the State, including rules of professional conduct or ethics, that prohibits disclosure of nonpublic personal information without the knowing and expressed consent of the consumer.

( 2 ) Limitation Nothing in this subsection shall be construed to exempt or otherwise exclude any financial institution that is affiliated or becomes affiliated with a certified public accountant described in paragraph ( 1 ) from any provision of this section.

( 3 ) Definitions For purposes of this subsection, the term State means any State or territory of the United States, the District of Columbia, XXXX XXXX, XXXX, XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX, the XXXX XXXX, or the XXXX XXXX XXXX. 
( XXXX ) Model forms ( 1 ) In general The agencies referred to in section 6804 ( a ) ( 1 ) of this title shall jointly develop a model form which may be used, at the option of the financial institution, for the provision of disclosures under this section. 
( XXXX ) Format A model form developed under paragraph ( XXXX ) shall ( A ) be comprehensible to consumers, with a clear format and design ; ( B ) provide for clear and conspicuous disclosures ; ( C ) enable consumers easily to identify the sharing practices of a financial institution and to compare privacy practices among financial institutions ; and ( D ) be succinct, and use an easily readable type font. 
( XXXX ) Timing A model form required to be developed by this subsection shall be issued in proposed form for public comment not later than 180 days after XX/XX/XXXX. 
( XXXX ) Safe harbor Any financial institution that elects to provide the model form developed by the agencies under this subsection shall be deemed to be in compliance with the disclosures required under this section.

( f ) Exception to annual notice requirement A financial institution that ( 1 ) provides nonpublic personal information only in accordance with the provisions of subsection ( b ) ( 2 ) or ( e ) of section 6802 of this title or regulations prescribed under section 6804 ( b ) of this title, and ( 2 ) has not changed its policies and practices with regard to disclosing nonpublic personal information from the policies and practices that were disclosed in the most recent disclosure sent to consumers in accordance with this section, shall not be required to provide an annual disclosure under this section until such time as the financial institution fails to comply with any criteria described in paragraph ( 1 ) or ( 2 ).

( Pub. L. 106102, title V, 503, Nov. 12, 1999, 113 Stat. 1439 ; Pub. L. 109351, title VI, 609, title VII, 728, Oct. 13, 2006, 120 Stat. 1983, 2003 ; Pub. L. 11494, div. G, title LXXV, 75001, Dec. 4, 2015, 129 Stat. 1787. ) See attachments for full complaint, and relating documentation.