1. The Plaintiff, for its Complaint against the Defendant, states and alleges as follows : 2. The Plaintiff, XXXX ( hereinafter XXXX ) is a resident of, North Dakota. 3. The Defendant, Wells Fargo Bank, ( hereinafter W.F.B. ), is a California Corporation, with its principle address at XXXX. XXXX XXXX, XXXX XXXX, CA XXXX. 4. W.F.B. is the creditor with account ending in # XXXX. W.F.B. alleged XXXX owed {$1300.00}. 5. By W.F.B. reporting inaccurate information regarding XXXX has caused Defamation and Financial Injury as outlined in the US Court of Appeals, XXXX Circuit, No. XXXX, XXXX vs. XXXX XXXX. 6. On XX/XX/2018, XXXX sent a letter to W.F.B. advising to validate the account pursuant to the Fair Debt Collection Practices Act and the Fair Credit Reporting Act. 7. There is evidence the Defendant received the letter on XX/XX/2018 at XXXX XXXX  in XXXX XXXX, CA   XXXX. 8. W.F.B. responded by sending copies of the account statements ; which they failed to comply with the request and has violated the Fair Debt Collection Practices Act Section 807-8 and Violated the Fair Credit Reporting Act Section 623-b. 9. OnXX/XX/2018, XXXX attempted to send a 2nd letter requesting W.F.B. to once again validate the account. 10. The Defendant received the letter on XX/XX/2018 at XXXX XXXX. to XXXX XXXX, CA XXXX. 11. W.F.B. once again responded with copies of the account statements, which they failed to comply again with the request and has violated the Fair Debt Collection Practices Act Section 807-8 and Violated the Fair Credit Reporting Act Section 623-b. 11 ( a ). W.F.B. violated FAILED to report the item as disputed to the credit reporting agencies after receiving notice each time. 12. On XX/XX/2018, XXXX mailed a 3rd letter to W.F.B. advising them to Cease and Desist any further contact with him regarding this account. 13. The Defendant received the letter on XX/XX/2018 at XXXX XXXX. to XXXX XXXX, CA  XXXX. 14. There is evidence the Defendant called XXXX on the following dates and times : Wednesday, XX/XX/2018 at XXXX XXXX., Wednesday, XX/XX/XXXX, at XXXX XX/XX/XXXX., Thursday XX/XX/2018, at XXXX XXXX, Thursday, XX/XX/2018 at XXXX XXXX 15. W.F.B. Violated FDCPA Section 805 ( c ) for EACH and EVERY time they continued to contact the Plaintiff AFTER receiving the Cease and Desist letter. 16. W.F.B. still continues to damage XXXX credit score by reporting this INACCURATE information to the credit bureaus. 17. W.F.B. has violated North Dakota Century Code 12.1-17-07 ( d ) Harassment which stated : A person is guilty of an offense if, with intent to frighten or harass another, the person : it goes on to say under section d : d. Communicated a falsehood in writing or by electronic communication and causes mental anguish. 18. By W.F.B.  continuing to harass XXXX via phone has caused XXXX extreme mental anguish. 19. Violations of said sections are a MINIMUM of {$1000.00} PER violation. 
I have attached PROOF that Wells Fargo FAILED to report to the Credit Agencies that the item was being DISPUTED which is a VIOLATION of FEDERAL LAW FCRA Section 623. I have attached the credit report for the following dates : XX/XX/2018, XX/XX/2018, XX/XX/2018 and XX/XX/2018. ALL SHOWING they failed to ADDRESS anything in the comments.