Product: Credit reporting or other personal consumer reports

UNITED STATES DISTRICT COURT FOR THE [ District ] XXXX XXXX, Plaintiff, v. 
CBNA ( Citibank ), Defendant. 
COMPLAINT PARTIES AND JURISDICTION Plaintiff : XXXX XXXX, an individual residing at XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX, FL XXXX ; Date of Birth : XXXX. 
Defendant : CBNA ( Citibank ), a banking and credit services institution with its principal offices in XXXX XXXX  NY, engaged in consumer credit reporting and collections within the United States. 
Jurisdiction : This Court has jurisdiction under 28 U.S.C. 1331, as this action arises under federal statutes : the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692c ( c ), and the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681.

FACTUAL BACKGROUND Cease Communication Request : On [ Date of Written Notification ], Plaintiff sent a written request to Citibank, instructing Defendant to cease all communication related to a disputed debt, as outlined in 15 U.S.C. 1692c ( c ).

Continued Communication : After receiving Plaintiffs written request, Citibank continued to contact Plaintiff in connection with the debt, which violated the cease-communication directive under the FDCPA.

Inaccurate Credit Reporting : Defendant inaccurately reported Plaintiffs account to consumer reporting agencies, including [ e.g., Experian, Equifax, TransUnion ], by falsely listing delinquent payments and an erroneous charge-off date that did not reflect the accounts actual status or history. Despite disputes raised with both Citibank and the credit reporting agencies, Defendant failed to amend these inaccuracies.

CLAIM I : VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1692c ( c ) Elements Satisfied : Debt Collection Attempt : Defendant was engaged in debt collection activity in connection with a personal debt alleged to be owed by Plaintiff.

Written Cease-Communication Request : Plaintiff provided Defendant with a clear written notice to cease communications, as permitted by 1692c ( c ).

Continued Collection Efforts : Defendant violated the FDCPA by continuing to contact Plaintiff after the cease-communication request, outside of the statutes limited exceptions.

Damages : Defendants actions caused Plaintiff significant emotional distress, frustration, and inconvenience. Plaintiff requests statutory damages under 15 U.S.C. 1692k, as well as compensation for actual damages, and attorneys fees and costs.

CLAIM II : VIOLATION OF THE FAIR CREDIT REPORTING ACT, 15 U.S.C. 1681e ( b ) AND 1681s-2 ( b ) Elements Satisfied : Inaccurate Reporting : Defendant reported incorrect payment history, including inaccurate delinquency dates and charge-off entries, to credit reporting agencies.

Failure to Correct : Despite Plaintiffs dispute and notification of these inaccuracies to Defendant and the credit bureaus, Defendant did not conduct a reasonable investigation or correct the reported information, violating its duties under 15 U.S.C. 1681s-2 ( b ).

Damages : The inaccurate reporting harmed Plaintiffs credit standing, leading to potential denials of credit, financial losses, and emotional distress. Plaintiff seeks statutory damages, actual damages, punitive damages, and reasonable attorneys fees and costs.

RELIEF REQUESTED WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in favor of Plaintiff and against Defendant as follows : a. Statutory damages under 15 U.S.C. 1692k ( a ) ( 2 ) ( A ) for Defendants FDCPA violations.

b. Actual damages for emotional distress, financial harm, and the impact on Plaintiffs credit.

c. Punitive damages for willful violations under the FCRA.

d. Reasonable attorneys fees and costs for pursuing this action.

e. Any further relief the Court deems just and proper.