Product: Vehicle loan or lease

XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX Ca XXXX XXXX # XXXX Plaintiff, vs. 
Veros XXXX XXXX, XXXX XXXX XXXX, XXXX XXXX, XXXX XXXX, California XXXX Defendant. 
Case No. : XXXX  COMPLAINT FOR FRAUD, VIOLATIONS OF THE FAIR CREDIT REPORTING ACT ( FCRA ), FAIR DEBT COLLECTION PRACTICES ACT ( FDCPA ), AND TRUTH IN LENDING ACT ( TILA ) JURY TRIAL DEMANDED INTRODUCTION Plaintiff XXXX XXXX XXXX brings this action against Defendant Veros XXXX XXXX for violations of federal and state laws, including, but not limited to, forgery, fraudulent misrepresentation, violations of the Fair Credit Reporting Act ( FCRA ), Fair Debt Collection Practices Act ( FDCPA ), Truth in Lending Act ( TILA ), and other applicable state laws. Plaintiff seeks monetary damages, declaratory relief, injunctive relief, and any other appropriate relief for damages suffered as a result of Defendant 's unlawful conduct. 

PARTIES Plaintiff : XXXX XXXX XXXX, a resident of XXXX, California. 
Defendant : Veros XXXX XXXX is a [ legal entity type, e.g., corporation, XXXX ], with its principal place of business located at XXXX XXXX XXXX, XXXX XXXX, XXXX XXXX, California XXXX. 

JURISDICTION AND VENUE This Court has jurisdiction over this action pursuant to the Fair Credit Reporting Act, 15 U.S.C. 1681p, the Fair Debt Collection Practices Act, 15 U.S.C. 1692k ( d ), the Truth in Lending Act, 15 U.S.C. 1640, and state law claims under supplemental jurisdiction. Venue is proper in this district pursuant to [ State Venue Law/Federal Venue Statute ] because Defendant conducts business in this district, and the events giving rise to the claims occurred in this district. 

FACTUAL ALLEGATIONS On or about XX/XX/year>, Plaintiff entered into a loan agreement with Defendant Veros XXXX XXXX for vehicle financing. 
Plaintiff alleges that

Defendant engaged in fraudulent misrepresentation by altering Plaintiffs signature on the loan agreement, rendering the contract void and unenforceable. Defendant reported this fraudulent loan to credit reporting agencies, despite Plaintiff 's repeated disputes, violating the Fair Credit Reporting Act ( FCRA )
.

Although the loan was charged off, Defendant illegally continued collection efforts, repossessing Plaintiffs vehicle twice without notice, violating state repossession laws and Uniform Commercial Code ( UCC ) Article 9.

Defendant sold Plaintiffs vehicle without providing the required notification, violating Plaintiffs rights under the UCC.

Despite the repossession and sale, Defendant continues to demand payment on the fraudulent and void contract.

Defendants collection attempts on a charged-off debt violate the Fair Debt Collection Practices Act ( FDCPA ).

The loan agreement failed to disclose essential terms as required by the Truth in Lending Act ( TILA ).

The statute of limitations for enforcing any collection on this fraudulent debt has expired, rendering further collection efforts legally unenforceable.

CAUSES OF ACTION COUNT I : Fraudulent Misrepresentation Plaintiff incorporates by reference all preceding paragraphs. Defendant committed fraud by altering Plaintiffs signature and misrepresenting loan terms. As a result, Plaintiff has suffered financial harm and emotional distress. Plaintiff seeks compensatory damages, punitive damages, and any other relief deemed just by the Court.

COUNT II : Violation of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 Plaintiff incorporates by reference all preceding paragraphs. Defendant violated the FCRA by reporting inaccurate information to credit reporting agencies based on a fraudulent contract. Defendant failed to correct the inaccuracies despite Plaintiffs disputes, damaging Plaintiffs creditworthiness. Plaintiff seeks statutory damages, actual damages, and attorneys fees.

COUNT III : Violation of the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692 Plaintiff incorporates by reference all preceding paragraphs. Defendant violated the FDCPA by continuing to collect on a charged-off and fraudulent debt, causing emotional distress and financial harm. Plaintiff seeks statutory damages, actual damages, and attorneys fees.

COUNT IV : Violation of the Truth in Lending Act ( TILA ), 15 U.S.C. 1601 Plaintiff incorporates by reference all preceding paragraphs. Defendant violated TILA by failing to disclose key terms of the loan agreement in accordance with the law. Plaintiff seeks statutory damages, actual damages, and attorneys fees.

COUNT V : Illegal Repossession and Sale of Vehicle ( Violation of State Law and UCC Article 9 ) Plaintiff incorporates by reference all preceding paragraphs. Defendant violated state repossession laws and UCC Article 9 by repossessing and selling Plaintiffs vehicle without proper notice. Plaintiff seeks compensatory damages for the loss of the vehicle, punitive damages, and any other relief deemed just by the Court.

PRAYER FOR RELIEF WHEREFORE, Plaintiff requests that this Court enter judgment in favor of Plaintiff and against Defendant Veros Auto Loan, and award Plaintiff the following relief : A. A declaration that Defendant 's actions violated federal and state consumer protection laws.

B. Actual damages in the amount of {$45000.00} for fraudulent misrepresentation, emotional distress, financial harm, and illegal collection efforts.

C. Statutory damages as provided by the FCRA, FDCPA, and TILA.

D. Punitive damages for Defendant 's willful and malicious conduct.

E. Attorneys fees and costs as provided by law.

F. Any other relief the Court deems just and proper.

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