Product: Credit reporting or other personal consumer reports

UNITED STATES DISTRICT COURT FOR THE [ APPROPRIATE DISTRICT COURT ] XXXX XXXX, Plaintiff, v. 
NAVY FEDERAL CREDIT UNION, XXXX XXXX XXXX XXXX XXXX, XXXX, XXXXXXXX XXXX XXXX  XXXX XXXX, Defendants. 
CIVIL ACTION NO. : [ TO BE ASSIGNED ] COMPLAINT FOR VIOLATIONS OF THE FAIR CREDIT REPORTING ACT ( 15 U.S.C. 1681 ), FAIR DEBT COLLECTION PRACTICES ACT ( 15 U.S.C. 1692 ), AND OTHER RELIEF INTRODUCTION 1.This action arises from Defendants violations of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681, and the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692, involving unlawful debt collection practices, failure to investigate disputes, and the reporting of false information on Plaintiffs credit reports.

2.Plaintiff seeks actual, statutory, and punitive damages, along with attorneys fees and costs, to remedy Defendants unlawful conduct. 

PARTIES 3.PlaintiffXXXXXXXX XXXXis a natural person residing XXXX XXXX XXXX, XXXX, Maryland XXXX XXXX born XXXXXXXX XXXX XXXX  and is a consumer as defined by XXXX XXXX.S.C. 1692a ( 3 ) and 15 U.S.C. 1681a ( c ).

4.DefendantNAVY FEDERAL CREDIT UNION ( NFCU ) is a financial institution headquartered at [ Insert Address ], engaged in providing loans, credit services, and debt collection. NFCU qualifies as a debt collector under 15 U.S.C. 1692a ( 6 ) for its attempts to collect on disputed debts.

5.DefendantXXXXXXXX XXXX XXXX XXXXXXXX ( XXXX ) is a credit reporting agency headquartered at [ Insert Address ] that regularly assembles and evaluates consumer credit information for profit. 
6.DefendantXXXXXXXX XXXX  ( XXXX ) is a credit reporting agency headquartered at [ Insert Address ] that regularly assembles and evaluates consumer credit information for profit. 
7.DefendantXXXX XXXX XXXX XXXXXXXX XXXX is a credit reporting agency headquartered at [ Insert Address ] that regularly assembles and evaluates consumer credit information for profit. 

XXXX XXXX XXXX  XXXXThis Court has jurisdiction under 28 U.S.C. 1331 and 15 U.S.C. 1692k ( d ) and 1681p, as this action arises under federal law.

9.Venue is proper in this district pursuant to 28 U.S.C. 1391 ( b ), as a substantial part of the events giving rise to the claims occurred within this district. 

FXXXX XXXX XXXX0.Plaintiff entered into a credit card agreement with NFCU. Subsequently, XXXXlaintiff faced financial hardships and fell behind on payments.

11.On or about [ Insert Date ], NFCU charged off the account but continued to report inaccurate payment history to XXXX, XXXX, and XXXX, including that the account was severely delinquent despite Plaintiffs efforts to dispute the debt.

12.On or around [ Insert Date ], NFCU began sending Plaintiff collection notices and making phone calls, including after Plaintiff disputed the debt and requested no further communication.

13.Plaintiff formally requested that NFCU validate the alleged debt and cease communication, but NFCU failed XXXX provide proper validation and continued its collection efforts, violating 15 U.S.C. 1692c ( c ).

14.NFCU also failed to meaningfully identify itself in certain communications, in violation of 15 U.S.C. 1692d ( 6 ). 
XXXX reporting agenciesXXXX XXXXXXXX, and XXXXerroneously reported the following inaccurate information regarding Plaintiffs NFCU account : The account was listed as charged off but simultaneously showed ongoing late payments. 
The disputed nature of the debt was not flagged on Plaintiffs credit reports, violating the FCRA. 
False payment history entries indicated delinquency during periods when disputes were pending or Plaintiff was attempting to resolve the matter.

16.Plaintiff disputed the inaccuracies with the credit reporting agencies under 15 U.S.C. 1681i. However, the agencies failed to conduct reasonable investigations or correct the inaccuracies.

17.As a direct result of Defendants actions, Plaintiff suffered harm, including denial of credit opportunities, emotional distress, reputational damage, and financial loss. 

CAUSES OF ACTION Count I Violations of the FDCPA Against NFCU 18.Plaintiff repeats and realleges all preceding paragraphs as if fully set forth herein.

19.NFCU violated the FDCPA by : a. Continuing to communicate with Plaintiff after a written cease-and-desist request, in violation of 15 U.S.C. 1692c ( c ) ; b. Failing to provide meaningful identification in certain communications, in violation of 15 U.S.C. 1692d ( 6 ) ; c. Misrepresenting the status of the debt and failing to validate it upon request, in violation of 15 U.S.C. 1692e ( 2 ) and 1692g.

20.As a result, Plaintiff suffered actual damages, including emotional distress, costs, and reputational harm.

Count II Violations of the FCRA Against All Defendants 21.Plaintiff repeats and realleges all preceding paragraphs as if fully set forth herein. 
XXXX, XXXX, and XXXX violated the FCRA by : a. Failing to maintain reasonable procedures to ensure maximum possible accuracy of the information reported about Plaintiff, in violation of 15 U.S.C. 1681e ( b ) ; b. Failing to conduct a reasonable reinvestigation of Plaintiffs disputes regarding the NFCU account, in violation of 15 U.S.C. 1681i.

23.NFCU violated 15 U.S.C. 1681s-2 ( b ) by : a. Failing to conduct a reasonable investigation of disputes forwarded by the credit reporting agencies ; b. Continuing to furnish inaccurate and incomplete information to the reporting agencies. 
24.As a result, Plaintiff suffered economic harm, emotional distress, and damage to creditworthiness.

PRAYER FOR RELIEF WHEREFORE, Plaintiff requests judgment in Plaintiffs favor and against Defendants as follows : 1.Actual damages pursuant to 15 U.S.C. 1681o ( a ) and 15 U.S.C. 1692k ( a ) ( 1 ) ; 2.Statutory damages pursuant to 15 U.S.C. 1692k ( a ) ( 2 ) ( A ) and 15 U.S.C. 1681n ( a ) ( 1 ) ( A ) ; 3.Punitive damages pursuant to 15 U.S.C. 1681n ( a ) ( 2 ) ; 4.Attorneys fees and costs pursuant to 15 U.S.C. 1692k ( a ) ( 3 ) and 15 U.S.C. 1681n ( a ) ( 3 ) ; 5.Any other relief the Court deems just and proper. 

DEMAND FOR JURY TRIAL Plaintiff demands a trial by jury on all issues so triable.