Product: Vehicle loan or lease

3. Facts a. On or about XX/XX/XXXX, the Defendant unlawfully released the Plaintiffs private loan information, including but not limited to the Plaintiffs drivers license and vehicle details, in the presence of employees and third parties. This act constitutes an invasion of privacy under XXXX  Statutes XXXX. 
b. The disclosed information included an outdated vehicle tag, further compromising the Plaintiffs privacy rights. 
c. The Defendants actions were intended to cover up his loss of assets from an affair, corroborated by witnesses XXXX ( employee ) and XXXX XXXX XXXX 
d. The Defendant attempted to conceal a loss exceeding {$20000.00}. XXXX and XXXX, upon considering purchasing XXXX XXXX XXXX in XXXX, discovered the Defendants pending lawsuits and unpaid taxes, leading them to withdraw from the transaction. 
e. XXXX terminated her professional relationship with XXXX XXXX in XXXX, providing documentation thereof. Following this termination, XXXX experienced harassment and false allegations from the Defendant, culminating in the incident in XXXX. 

4. Legal Claims a. Defamation : The Defendant knowingly published false statements about the Plaintiff, which were unprivileged and caused harm to the Plaintiffs reputation. Under Florida law, to establish defamation, a plaintiff must prove : ( 1 ) a false statement ; ( 2 ) publication to a third party ; ( 3 ) fault amounting to at least negligence ; and ( 4 ) damages. ( See XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX b. The disclosed information included an outdated vehicle tag, further compromising the Plaintiffs privacy rights. 
c. The Defendants actions were intended to cover up his loss of assets from an affair, corroborated by witnesses XXXX ( employee ) and XXXX XXXX XXXX 
d. XXXX XXXX, prior to the events leading to this complaint, advised XXXX XXXX that using illegal actions in the car business was unacceptable, including utilizing financing consumers ' trades to enter false trade-ins and misdirecting funds to the financial company. e
. XXXX intervened to assist XXXX XXXX with compliance issues related to dealer services and the state of XXXX  's compliance requests for car dealership owners. 
f. During the course of her work for XXXX XXXX multiple complaints were made by consumers regarding his business practices, including a lawsuit concerning the sale of an inoperable vehicle. 
g. The Defendant attempted to conceal a loss exceeding {$20000.00}. XXXX and XXXX, upon considering purchasing XXXX XXXX XXXX in XXXX, discovered the Defendants pending lawsuits and unpaid taxes, leading them to withdraw from the transaction. 
h. XXXX terminated her professional relationship with XXXX XXXX in XXXX, providing documentation thereof. Following this termination, XXXX experienced harassment and false allegations from the Defendant, culminating in the incident in XXXX. 
4. Legal Claims a. Defamation : The Defendant knowingly published false statements about the XXXX, which were unprivileged and caused harm to the Plaintiffs reputation. Under Florida law, to establish defamation, a plaintiff must prove : ( 1 ) a false statement ; ( 2 ) publication to a third party ; ( 3 ) fault amounting to at least negligence ; and ( 4 ) damages. ( See XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  ) ). 
b. Invasion of Privacy : The unauthorized disclosure of private facts constitutes an invasion of privacy, actionable under Florida law. The Defendants actions fall under this category as they revealed private information without consent. ( See XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ). 
c. Failure to Cease and Desist : The Defendant did not comply with a cease-and-desist letter issued on [ Insert Date ], further demonstrating willful misconduct.

5. Damages As a direct and proximate result of the Defendants actions, the XXXX has suffered significant damages, including emotional distress, reputational harm, and other consequential damages. The Plaintiff seeks compensatory damages as well as punitive damages to deter similar conduct in the future. 
XXXX ) ). 
c. Failure to Cease and Desist : The Defendant did not comply with a cease-and-desist letter issued on [ Insert Date ], further demonstrating willful misconduct.

5. Damages As a direct and proximate result of the Defendants actions, the Plaintiff has suffered significant damages, including emotional distress, reputational harm, and other consequential damages. The Plaintiff seeks compensatory damages as well as punitive damages to deter similar conduct in the future. 



XXXX XXXX sold a vehicle to XXXX XXXX from XXXX XXXX released private personal loan information to memember of public with out consent. Which was used to falsify police report. Also sold car with Broken XXXX  never complied to fix car was stolen XXXX weeks ago paid off in fed with sensible auto pay off leteer they never released loan. stolen during this issue. I have filed a lawsuit for my information being released illegally. XXXX was conduction alot of illegal activity via dealer service buerue complaints, tag complaint, all files missing documents. Falsifying trade ins on finacing apps adding customer cars not the consumers as trade locking vin with DMV.