Product: Debt collection

On XX/XX/XXXX and XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX Plaintiff obtained a copy of her consumer report and discovered incomplete, inaccurate, false information furnished by the defendant CAPITAL ONE AUTO FINANCE. Defendant CAPITAL ONE AUTO FINANCE furnished one trade line, Account No. XXXX, in the amount of {$8400.00}. 

On XX/XX/XXXX, the defendant CAPITAL ONE AUTO FINANCE flagged the above account as closed and a charge off. However, records indicate that account was opened until XXXX of XXXX. The defendant CAPITAL ONE AUTO FINANCE received payments toward the open account during the months the account was marked closed/charged off. 

On XX/XX/XXXX and XX/XX/XXXX, Plaintiff contacted Defendant CAPITAL ONE AUTO FINANCE via certified mail by requesting that debt to be verified by the defendant CAPITAL ONE AUTO FINANCE providing a detailed and itemized statement of ALL activity to this account, including the contract the Plaintiff must have allegedly signed to bind the Plaintiff to this debt, The photo identification the Plaintiff must have provided at the time of starting services with the defendant CAPITAL ONE AUTO FINANCE in order for the defendant CAPITAL ONE AUTO FINANCE to assure that this was not an attempt of someone else to commit a fraud the Plaintiff, an itemized statement breaking down the balance with the defendant CAPITAL ONE AUTO FINANCE claim the Plaintiff owe, and any other documentation the defendant CAPITAL ONE AUTO FINANCE must have in order to truthfully make a notarized statement on the defendant CAPITAL ONE AUTO FINANCE letterhead, attesting to the defendant CAPITAL ONE AUTO FINANCE compliance of the XXXX. 

Defendant CAPITAL ONE AUTO FINANCE failed to verify debt at the Plaintiff request- FDCPA violation, continued to report & communicate this disputed debt to the CRA- FCRA violation & FDCPA violation ( s ) 15 usc 1681b12, 15 usc 1692c , and ignore the change of address.

Plaintiff disputed the tradeline with Defendants XXXX, XXXX, and XXXX by sending written disputes on the following dates, XX/XX/XXXX ; XX/XX/XXXX, XX/XX/XXXX and XX/XX/XXXX. Plaintiff informed all defendants that the following information was inaccurate and needed to be investigated ; account status, high balance, payment history, last activity date, account opened date. The plaintiff requested to be provided proof of this alleged item, specifically the contract, note or other instrument bearing the Plaintiffs signature. 

Upon information and belief, Defendants XXXX, XXXX, and XXXX sent a dispute to the defendant CAPITAL ONE AUTO FINANCE providing all relevant disputed information. 

Upon information and belief, defendant CAPITAL ONE AUTO FINANCE verified to the Defendants XXXX, XXXX, and XXXX that the tradeline was accurate. 

My potential legal claims pursuant to the FCRA include the following : ( 1 ) 15 U.S.C. 1681s-2 ( b ) ( 1 ) ( A ) failure to conduct a reasonable investigation on the alleged tradeline after receiving notice of the consumer dispute ; ( 2 ) 15 U.S.C. 1681s-2 ( b ) ( 1 ) ( B ) failing to review all relevant information forwarded to you by the consumer reporting agencies ; ( 3 ) 15 U.S.C. 1681s-2 ( b ) ( 1 ) ( C ) failure to report the accurate information to consumer reporting agencies and failing to report the results of the reinvestigation; ( 4 ) 15 U.S.C. 1681s-2 ( b ) ( 1 ) ( D ) failing to report accurate information to the consumer reporting agencies and continuing to report information that was false, inaccurate and unverifiable.

( 5 ) 15 U.S.C. 1681s-2 ( b ) ( 1 ) ( E ) failing to have a procedure in your system with the consumer reporting agencies to ( i ) modify the inaccurate information in your system, ( ii ) delete the inaccurate or unverifiable, erroneous information, or ( iii ) block the re-reporting of inaccurate or unverifiable information.

It is my position that your conduct has been negligent and/or willful, which will entitle me to recover actual damages, punitive damages and costs pursuant to 15 U.S.C. 1681n.