Product: Credit reporting or other personal consumer reports

COMPLAINT Plaintiff XXXX XXXX ( " Plaintiff '' ), by and through her attorney, brings this Complaint against Defendant Department of Education XXXX Aidvantage ( " Defendant '' ) and alleges as follows : INTRODUCTION This action arises from Defendant 's 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., specifically 1681s-2 ( a ) and 1692c ( c ). Defendant willfully and negligently failed to comply with its legal obligations to report accurate information to credit reporting agencies and to cease communication after receiving written notification to do so.

JURISDICTION AND VENUE Jurisdiction is proper under 28 U.S.C. 1331 because this action arises under the laws of the United States, namely the FCRA and FDCPA.

Venue is proper in this District under 28 U.S.C. 1391 ( b ) because the events giving rise to the claim occurred within this District, and Defendant conducts substantial business in this District. 
PARTIES Plaintiff XXXX XXXX, an individual, resides at XXXX XXXX  XXXX XXXX, XXXX, NY XXXX. Plaintiff 's date of birth is XX/XX/year>. 
XXXX Department of Education XXXX Aidvantage is a federal entity responsible for servicing student loans and regularly reports to credit reporting agencies. Aidvantage operates as a contracted servicer and conducts substantial business throughout the United States, including within this District.

FACTUAL ALLEGATIONS On or about [ specific date ], Plaintiff reviewed her consumer credit reports from XXXX, XXXX, and XXXX and discovered that Defendant had inaccurately reported the payment history associated with a student loan under Plaintiffs name. 
Specifically, the reported payment history reflected delinquencies that were incorrect, inaccurately affecting Plaintiffs creditworthiness. These inaccuracies have negatively impacted Plaintiffs credit score and hindered her financial opportunities. 
Plaintiff notified Defendant and the credit reporting agencies of the inaccuracies in writing and requested an investigation into the errors, pursuant to 15 U.S.C. 1681s-2 ( a ). 
Despite receiving these notifications, Defendant willfully and negligently failed to conduct a reasonable investigation and to correct the inaccurate information, as required by the FCRA. 
In addition, Plaintiff sent a cease-and-desist letter to Defendant, requesting that all communications regarding the disputed account cease. Defendant received the letter but continued to communicate with Plaintiff in violation of 15 U.S.C. 1692c ( c ), causing undue distress. 
CLAIMS FOR RELIEF COUNT I - VIOLATION OF THE FAIR CREDIT REPORTING ACT ( 15 U.S.C. 1681s-2 ( a ) ) Plaintiff incorporates by reference all preceding paragraphs as though fully stated herein.

Defendant had a duty under 15 U.S.C. 1681s-2 ( a ) to report accurate information regarding Plaintiffs student loan account to consumer reporting agencies. 
Defendant knowingly and willfully reported inaccurate information regarding Plaintiffs payment history and failed to correct these inaccuracies upon being notified by Plaintiff.

Defendants failure to conduct a reasonable investigation into Plaintiffs dispute, as required by 15 U.S.C. 1681s-2 ( a ), constitutes a violation of Plaintiff 's rights under the FCRA.

As a direct and proximate result of Defendant 's conduct, Plaintiff suffered actual damages, including but not limited to a lower credit score, emotional distress, and the loss of financial opportunities. 
Plaintiff is entitled to statutory damages, actual damages, costs, and attorney 's fees as provided by 15 U.S.C. 1681n and 1681o.

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

Defendant received written notification from Plaintiff, requesting that all communications regarding the disputed account cease.

Despite Plaintiff 's written request, Defendant continued to communicate with Plaintiff regarding the disputed account, violating 15 U.S.C. 1692c ( c ).

Defendants actions were intentional and willful, causing Plaintiff emotional distress and further harm. 
Plaintiff is entitled to statutory damages, actual damages, costs, and attorney 's fees as provided by 15 U.S.C. 1692k.

PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment against Defendant as follows : For actual damages suffered by Plaintiff, including but not limited to emotional distress, financial losses, and damage to creditworthiness, in an amount to be determined at trial ; For statutory damages as provided under 15 U.S.C. 1681n, 1681o, and 1692k ; For punitive damages as allowed under applicable statutes ; For costs of litigation and attorney 's fees pursuant to 15 U.S.C. 1681n, 1681o, and 1692k ; For such other and further relief as the Court deems just and proper. 
DEMAND FOR JURY TRIAL Plaintiff hereby demands a trial by jury on all issues so triable.