Product: Credit reporting or other personal consumer reports

UNITED STATES DISTRICT COURT FOR THE [ APPROPRIATE DISTRICT COURT ] XXXX XXXX, Plaintiff, v. 
CAINE & WEINER ( XXXX XXXX ), 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 out of Defendants violations of the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692, the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681, and related claims, whereby the Defendants unlawfully attempted to collect a disputed debt, failed to properly investigate disputes regarding inaccurate credit reporting, and reported false and misleading information about the Plaintiff, causing damages.

2.Plaintiff seeks actual, statutory, and punitive damages, along with attorneys fees and costs, to remedy Defendants unlawful conduct. 

PARTIES XXXX XXXX  a natural person, residing XXXX XXXX XXXX, XXXX, Maryland XXXX XXXX born XXXX XXXX, 1990, and is a consumer as defined by 15 U.S.C. 1692a ( 3 ) and 15 U.S.C. 1681a ( c ). 
XXXX & XXXX a debt collection agency headquartered at [ Insert Address ], engaged in the business of collecting debts owed or asserted to be owed to others, making it a debt collector under 15 U.S.C. 1692a ( 6 ). 
XXXX XXXX XXXX XXXX  ( XXXX ) is a credit reporting agency headquartered at [ Insert Address ] and regularly engages in the business of assembling and evaluating consumer credit information. 
XXXX, XXXX ( XXXX ) is a credit reporting agency headquartered at [ Insert Address ], engaged in the business of assembling and evaluating consumer credit information. 
XXXX, XXXX ( XXXX ) is a credit reporting agency headquartered at [ Insert Address ], engaged in the business of assembling and evaluating consumer credit information. 

JURISDICTION AND VENUE 8.This Court has jurisdiction under 15 U.S.C. XXXX ( d ) and 15 U.S.C. 1681p, and 28 U.S.C. 1331, as this action arises under federal law.

9.Venue is proper in this judicial district pursuant to 28 U.S.C. 1391 ( b ), as a substantial part of the events giving rise to the claims occurred in this district.

FACTUAL ALLEGATIONS 10.On or around [ Insert Date ], Caine & Weiner , on behalf of XXXX XXXX XXXX began attempting to collect an alleged debt of {$17000.00} from Plaintiff. 
11.On [ Insert Date ], Plaintiff sent a cease-and-desist letter to Caine & Weiner, disputing the debt and demanding no further communications. Despite this, Caine & Weiner left multiple voicemail messages on Plaintiff 's phone, causing distress and invading Plaintiff 's privacy.

12.In violation of 15 U.S.C. 1692c ( c ), Defendant Caine & Weiner continued to communicate with Plaintiff after being explicitly instructed not to.

13.Defendant also failed to meaningfully identify itself in communications, in violation of 15 U.S.C. 1692d ( 6 ).

14.Defendants XXXX, XXXX, and XXXX included inaccurate information about Plaintiffs alleged debt on Plaintiffs credit reports, including false payment history and failure to indicate the disputed nature of the debt, in violation of 15 U.S.C. 1681e ( b ).

15.Plaintiff repeatedly disputed these inaccuracies with the reporting agencies under 15 U.S.C. 1681i, yet Defendants failed to conduct a reasonable investigation or correct the errors, continuing to report false and damaging information.

CAUSES OF ACTION Count I Violations of the FDCPA Against Caine & Weiner 16.Plaintiff repeats and realleges all preceding paragraphs as if fully set forth herein.

17.Caine & Weiner violated 15 U.S.C. 1692c ( c ), 1692d ( 6 ), and 1692e ( 14 ) by : a. Continuing to communicate with Plaintiff after a cease-and-desist request ; b. Failing to meaningfully identify itself in voicemail messages ; c. Using a name other than its true name in communications.

18.As a direct and proximate result of these violations, Plaintiff suffered actual damages, including emotional distress and harm to Plaintiffs credit reputation.

Count II Violations of the FCRA Against All Defendants 19.Plaintiff repeats and realleges all preceding paragraphs as if fully set forth herein.

20.Defendants XXXX, XXXX, and XXXX violated 15 U.S.C. 1681e ( b ) and 1681i by : a. Failing to maintain reasonable procedures to ensure the accuracy of Plaintiffs credit information ; b. Failing to reasonably investigate Plaintiffs disputes regarding the false information.

21.Defendant Caine & Weiner violated 15 U.S.C. 1681s-2 ( b ) by : a. Failing to properly investigate Plaintiffs disputes regarding the alleged debt ; b. Continuing to report false information about Plaintiff 's payment history.

22.As a direct and proximate result, Plaintiff suffered actual damages, including loss of credit opportunities, emotional distress, and harm to Plaintiffs credit reputation.

PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment against Defendants as follows : 1.Actual damages in an amount to be determined at trial ; 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.Attorneys fees and costs pursuant to 15 U.S.C. 1692k ( a ) ( 3 ) and 15 U.S.C. 1681n ( a ) ( 3 ) ; 5.Any other relief the Court deems just and proper. 

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