Product: Credit reporting or other personal consumer reports

COMPLAINT FOR DAMAGES I. INTRODUCTION This is an action for damages brought by XXXX XXXX XXXX ( hereinafter " Plaintiff '' ) against Credit Collection Services ( hereinafter " Defendant '' ) for violations of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq., and the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692 et seq., for inaccurate credit reporting, failure to conduct a reasonable investigation of disputed information, and continuing to report false and misleading data despite notification of disputes. 
Plaintiff seeks actual, statutory, and punitive damages, attorneys fees, and costs for Defendants violations. 
II. JURISDICTION AND VENUE Jurisdiction of this Court arises un

der 15 U.S.C. 1681p and 28 U.S.C. 1331. Venue is proper in this district pursuant to 28 U.S.C. 1391 ( b ) because Defendant conducts business in this district, and a substantial part of the events giving rise to this action occurred within this district. 
XXXX. PARTIES Plaintiff XXXX XXXX XXXX is a natural person residing at XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, and is a " consumer '' as defined by 15 U.S.C. 1681a ( c ). 
Defendant Credit Collection Services ( CCS ) is a business entity engaged in the collection of consumer debts, with its principal place of business at XXXX XXXX XXXX XXXX XXXX XXXXXXXX. Defendant regularly transacts business within this district, including the collection of consumer debts, and is a furnisher of information under 15 U.S.C. 1681s-2. 
IV. FACTUAL ALLEGATIONS On or about [ date ], Defendant began reporting negative information about Plaintiffs alleged account to the three major credit reporting agencies ( XXXX, XXXXXXXX XXXX XXXXXXXX ), including incorrect payment history and incorrect dates of delinquency, thereby misleadingly portraying Plaintiff 's creditworthiness. 
The inaccuracies identified by Plaintiff include : Incomplete and incorrect reporting of the payment history, including failure to report the correct dates of the first and last delinquent payments. 
The report failed to provide verifiable proof of when the alleged delinquency occurred. 
On or about [ date ], Plaintiff disputed the inaccuracies with the credit reporting agencies pursuant to 15 U.S.C. 1681i ( a ).

The credit reporting agencies notified Defendant of Plaintiff 's dispute, as required by 15 U.S.C. 1681i ( a ) ( 2 ). 
Despite receiving notice of the dispute, Defendant failed to conduct a reasonable investigation and continued to report inaccurate and incomplete information, in violation of 15 U.S.C. 1681s-2 ( b ).

Defendant 's failure to correct or remove the inaccurate information has caused significant harm to Plaintiff 's creditworthiness, including emotional distress, frustration, and the inability to secure credit on favorable terms. 
In addition, Defendant 's continued reporting of inaccurate information and its failure to cease communication after Plaintiffs written notice also constitutes a violation of 15 U.S.C. 1692c ( c ) of the FDCPA.

V. CLAIMS FOR RELIEF COUNT ONE : VIOLATION OF THE FAIR CREDIT REPORTING ACT ( FCRA ), 15 U.S.C. 1681s-2 ( b ) Plaintiff incorporates by reference all preceding paragraphs as though fully stated herein.

Defendant violated 15 U.S.C. 1681s-2 ( b ) by : a. Failing to conduct a reasonable investigation of the disputed information after receiving notice from the credit reporting agencies. b. Continuing to report inaccurate and unverifiable information to the credit reporting agencies. c. Failing to promptly correct or delete the inaccurate information after being notified of the dispute. 
Defendant 's actions were willful and/or negligent, entitling Plaintiff to damages under 15 U.S.C. 1681n and 1681o.

COUNT TWO : VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT ( FDCPA ), 15 U.S.C. 1692c ( c ) Plaintiff incorporates by reference all preceding paragraphs as though fully stated herein.

On [ date ], Plaintiff sent Defendant a written request to cease all communications regarding the alleged debt, as provided for in 15 U.S.C. 1692c ( c ). 
Despite receiving the cease communication notice, Defendant continued to contact Plaintiff and report the alleged debt to credit reporting agencies, in violation of 15 U.S.C. 1692c ( c ).

Defendants continued communications and reporting caused emotional distress and undue harassment to Plaintiff. 
Plaintiff is entitled to statutory damages of up to {$1000.00}, actual damages, and reasonable attorneys fees under 15 U.S.C. 1692k.

VI. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays that judgment be entered against Defendant and that Plaintiff be awarded damages as follows : a. Actual damages in an amount to be determined at trial. b. Statutory damages as provided under 15 U.S.C. 1681n and 1692k. c. Punitive damages as the Court may allow. d. Attorneys fees, costs, and disbursements. e. Any other relief the Court deems appropriate. 
VII. JURY DEMAND Plaintiff demands trial by jury on all issues so triable.