Product: Debt collection

1. On or about XX/XX/XXXX, I discovered that XXXX XXXX XXXX in XXXX, California, engaged collection action for emergency services rendered. 

2. On or about XX/XX/XXXX, I re-submitted my proof of XXXX XXXX for the time in question in XXXX. I personally hand-delivered copies of my ( i ) insurance card, ( ii ) Medi-Cal BIC Card, and ( iii ) valid State of California Drivers License, at the administrative office XXXX XXXX XXXX located at XXXX XXXX XXXX, XXXX, CA XXXX. I spoke to the admirative assistant of XXXX XXXX, and was informed that ( i ) they would contact XXXX to verify coverage period, ( ii ) and that I would be contacted to follow-up. 

3. On or about XX/XX/XXXX, I contacted the admirative office of XXXX XXXX XXXX by telephone. I was informed that they were in fact able to confirm with XXXX that I had insurance coverage for the emergency services rendered, and that the billing error would be corrected by the finance department. I reasonably relied upon their representations. 

4. It was not until XX/XX/XXXX when I obtained a credit report for the first time since XX/XX/XXXX, I obtained a copy of my credit report to prepare and file for Chapter XXXX Bankruptcy. I discovered that your agency was attempting to collect this invalid debt. 

5. On or about XX/XX/XXXX, I notified one of your companys debt collection agents at your XXXX XXXX office regarding the above-stated facts, and was informed that the inaccurate derogatory credit reported to the credit bureaus would be corrected. 

6. Attached is a true and correct copy of my Chapter XXXX Bankruptcy Discharge on XX/XX/XXXX. I was informed by U.S. Trustee, XXXX XXXX XXXX, after testifying as to the facts concerning this invalid debt at the meeting of creditors hearing in my case. 

7. On or about XX/XX/XXXX, I filed a complaint with the Consumer Financial Protection Bureau ( Case No. XXXX ) Your company was provided a photocopy of my XXXX XXXX Card. My complaint specifically urged your company to exercise reasonable due diligence and contact your client, XXXX, and verify with State of California XXXX officials the fact I had coverage by XXXX well-before, during and after the alleged debt was incurred, and take immediate action to remove the derogatory credit reported. 

8. After receiving your companys negligent response, I called and spoke to XXXX who informed me that the card I submitted to CFPB was a current ID card and did not cover the time of the invalid debt. This level of ignorance, contempt and material failure to exercise reasonable due diligence in tortious and actionable. XXXX stated It was discharged in my bankruptcy, we are allowed to report the debt to the credit bureaus. Not only did she not respond correctly to the CFPB complaint, and the fact that it does not matter if it was included in the bankruptcy, the debt is fraudulent and invalid, and must be removed entirely. Her incompetent and insolent response should be grounds for her immediate termination. 

9. On or about XX/XX/XXXX, I contacted XXXX of the above-stated facts and circumstances, and requested Verification and proof of coverage for the period of time of the alleged debt. On XX/XX/XXXX, I received such verification. 

10. Attached hereto is a true and correct from XXXX confirming that I did in fact have continuous insurance coverage well-before the alleged debt was incurred.