Summary 1. Defendant, Nordstom XXXX XXXX causes XXXX XXXX, Plaintiff, damages of at least {$10000.00} by issuing a knowingly false XXXX for cancellation of {$34000.00} in debt thereby increasing Defendant state and federal income tax obligation ( Exhibit A ). 
Facts 2. In XX/XX/XXXX Defendant weds XXXX XXXX, date of birth XX/XX/XXXX, XXXX XXXX of XXXX, KS. 
3. In XX/XX/XXXX Nordstrom XXXX extends Credit to XXXX XXXX Account # XXXX XXXX XXXX XXXX. 
4. In XX/XX/XXXX, Plaintiff divorce judgment of XXXX XXXX is entered in XXXX County Kansas Case XXXX. 
5. Between XX/XX/XXXX and XX/XX/XXXX Nordstrom XXXX moves the subject account balance of {$34000.00} to the name of the Plaintiff without Plaintiff knowledge or authorization ( Exhibit B ). 
6. In XX/XX/XXXX Nordstrom XXXX furnishes the Defendant and the IRS a XXXX for of {$34000.00} under account # XXXX. 
7. In XX/XX/XXXX Defendant informs Nordstrom XXXX the XXXX is a violation of Internal Revenue Service Treasury Regulation Section 1.6050P-1 ( 7 ) which requires the XXXX Cancellation of Debt be provided to the individual benefiting from the debt which in this case is the account holder, XXXX XXXX ( Exhibit C ). 
8. In XX/XX/XXXX Nordstrom XXXX asserts the XX/XX/XXXX XXXX is issued correctly ( Exhibit D ). 
9. Nordstrom XXXX changed its name to XXXX XXXX XXXXXXXX XXXX in XX/XX/XXXX. The company was founded in XX/XX/XXXX and is based in XXXX, Arizona. As of XX/XX/XXXX,  XXXX XXXX XXXXXXXX XXXX  operates as a subsidiary of XXXX, XXXX. 

Statute of Limitations 10. Plaintiff is informed of the fraud by XXXX XXXX, Nordstrom XXXX Recovery Specialist, on XX/XX/XXXX. The statute of limitations shall not commence until the fact of injury becomes reasonably ascertainable to the injured party, but in no event shall an action be commenced more than 10 years beyond the time of the act giving rise to the cause of action for Civil action ( XXXX XXXX ( XXXX ) ) and before XX/XX/XXXX for Criminal action ( XXXX. XXXX ( XXXX ) 3. 

Jurisdiction and Venue 11. Plaintiff XXXX XXXX is a resident of XXXX XXXX Kansas. 

Count I 12. Nordstrom XXXX created an account and transferred funds in the name of the Plaintiff without the knowledge or authorization of the Plaintiff between XX/XX/XXXX and XX/XX/XXXX. Section 1036 ( a ) ( 1 ) ( B ) of the CFPA prohibits unfair acts or practices. 12 U.S.C. 5536 ( a ) ( 1 ) ( B ). An act or practice is unfair if it causes or is likely to cause consumers substantial injury that is not reasonably avoidable and is not outweighed by countervailing benefits to consumers or to competition. 12 U.S.C. 5531 ( c ) ( 1 ).

Count II 13. Nordstrom XXXX issued a XXXX in the name of the Plaintiff for the false account created in Count I XX/XX/XXXX. Section 1036 ( a ) ( 1 ) ( B ) of the CFPA prohibits unfair acts or practices. 12 U.S.C. 5536 ( a ) ( 1 ) ( B ). An act or practice is unfair if it causes or is likely to cause consumers substantial injury that is not reasonably avoidable and is not outweighed by countervailing benefits to consumers or to competition. 12 U.S.C. 5531 ( c ) ( 1 ).

Count III 14. Nordstrom XXXX refused to correct the false XXXX after being appraised of the Internal Revenue Service Treasury Regulation Section 1.6050P-1 ( 7 ) XX/XX/XXXX, a felony, 26 USC 7206 ( 1 ).

Count IV 15. Nordstrom XXXX issued a XXXX in the name of the Plaintiff for the false account created in Count I XX/XX/XXXX in violation of Kansas Statue ( K.S.A. ) 79-3228 ( e ) a misdemeanor, and ( f ) a felony.