State of Connecticut Superior Court XX/XX/XXXX FTC ID # XXXX COMPLAINT PLAINTIFF DEMANDS TRIAL BY JURY Plaintiff XXXX XXXX XXXX XXXX XXXX Plaintiff, appearing PRO SE, hereby complains of the defendant ( s ) and alleges upon information and belief as follows : Jurisdiction 1 : These claims arise under Civil Rules of Procedure of Connecticut, including but not limited to USC Title XV-Consumer Protection Act, Sections 1681 seq-The Fair Credit Reporting Act ( FCRA or Act ), USC Title XV Sections, Connecticut Banking Law, CGS 36a-695, and Connecticut General Statute. 
Parties 2. Plaintiff Resides at XXXX XXXX XXXX XXXX Ct XXXX XXXX. Defendant ( s ) is a domestic corporation having its principal place of business at XXXX XXXX XXXX XXXX, XXXX, GA XXXX address XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, CA XXXX ALLEGATIONS 4. Plaintiff is a consumer within the meaning and purview of the act. 
5. Defendant ( s ) is ( are ) a utility company, data furnisher, and consumer reporting agency within the meaning and purview of the Act.

6. Prior to date XX/XX/XXXX of defendants actions from which these allegations arise, plaintiff had a fair credit score had a good payment history was starting a new business 7. Defendants, alone or in concert, joint venture, partnership and/or some other contractual arrangement, violated the Act as pled herein as to be discovered, thus causing plaintiff special general damages, injury and harm. 
8. Defendants, alone or in concert, joint venture, partnership and/or some other contractual arrangement, then illegally produced and disseminated incorrect information to XXXX on or about XX/XX/XXXX, thus causing special, general and punitive damages. 
9. Defendants, alone or in concert, joint venture, partnership and or/some other contractual or non-contractual arrangement rendered, obtained, and or published credit information by -re-reporting XXXX XXXX /XXXX loans on EQUIFAX databases systems. Performed its reporting obligations in a willfully and criminally reckless, negligent and or/illegal fashion in violation of the Act and the laws of this state and of these United States, in inter alia, failing to use and/ or maintain reasonable procedures to avoid violations of section 605, 1681 I and 1692j of the Fair Credit Reporting Act and/or other laws : providing material inaccurate and misleading account status to credit agencies, failing to evaluate and re-evaluate any and all information ; failing to authenticate account information, disseminating false information ; re-selling credit information to third parties, providing false statements, violating consumers privacy, communicating account information to unauthorized persons, address inaccuracies, intentionally deceiving plaintiff who justifiably relied upon defendants promises to plaintiff detriment and damage, acting with malice, acting with presumed malice ; acting with intent ; acting with implied intent ; asserting, maintaining, publishing and otherwise communicating certain false information about plaintiff ; willfully failing to verify and authenticate account information before publishing it, warranting, guarantying, representing, publishing and otherwise communicating certain false information about plaintiff was true ; breaching their contract and trust with plaintiff, making untrue written and/or oral statements defaming, maligning and/or in other ways misrepresenting account status, and account closing dates, failing to honor billing discrepancies, comingling accounts, defendants continued to furnish and report additional account and credit related inaccuracies, formulated additional billing errors after account was paid and closed, and further communicated to Equifax such incorrect and defamatory statements to third parties, including but not limited to as discovery will show ; failing to check the veracity and accuracy of the information before publishing it, wantonly, willfully, reckless and intentionally failing to follow reasonable care over the course of its business, violating inter-alia the Fair Credit Reporting Act, Title 6 Section 607 ( b ) ; in so operating its business as to cause damage by will-full non-compliance doing so in order to maintain a delinquency report on plaintiff s utility account. 
10. Defendants knew, or should have known, that the information rendered and/or obtained was false, inaccurate and/or in some way inappropriate and potentially damaging to plaintiff doing so even after XXXX  was notified of possible unauthorized access or result of data breach, identity theft or fraud, on plaintiffs utility account. 
11. Notwithstanding this known falsity, defendants nonetheless continued to render, disseminated, provided, made available or in some other way published such false information to XXXX, and EQUIFAX to plaintiffs detriment. 
13. Defendants knew or should have known that their acts and/or omissions could have been damaging to the plaintiff. Notwithstanding this knowledge, defendants continued to act or failed to act in accordance with the dispute resolution and reinvestigation procedures of the Act in violation of the Act to plaintiff detriment and damage. 
14. As a result of the acts of defendants, plaintiff caused to incur general and special damages and or statutory damages. 
15. Defendants acts were so reckless, wanton quasi-criminal and performed with such disregard for the rights of plaintiff that plaintiff demands PUNITIVE DAMAGES. 
AS AND FOR A FIRST CLAIM FOR RELIEF UNDER THE ACT 16. Plaintiff repeats and realleges all previous paragraphs with the same force and effect as if the same were set forth more fully at length herein 17. Defendants violated the Act as complained herein and in other ways as discovery will show.

18. Such violation ( s ) caused plaintiff damages.

AS AND FOR A SECOND CLAIM FOR RELIEF IN LIBEL UNDER THE ACT 19. Plaintiff repeats and realleges all previous paragraphs with the same force and effect as if the same were set forth more fully at length herein.

20. As a result of defendants actions, plaintiff has been libeled and sustained damages thereby.

AS AND FOR THE THIRD CLAIM FOR RELIEF IN LIBEL PER SE 21. Plaintiff repeats and realleges all previous paragraphs with the same force and effect as if the same were set forth more fully at length herein.

AS AND FOR THE FOURTH CLAIM OF RELIEF IN SLANDER 22. Plaintiff repeats and realleges all previous paragraphs with the same force and effect as if the same were set forth more fully at length herein.

23. As a result of defendants acts, plaintiff has been slandered and sustained damages thereby.

AS AND FOR A FIFTH CLAIM FOR RELIF IN SLANDER PER SE 24. Plaintiff repeats and realleges all previous paragraphs with the same force and effect as if the same were set forth more fully at length herein.

25. As a result of defendants acts plaintiff has been slandered and sustained per se and punitive damages thereby.

As AND FOR A SIXTH CLAIM FOR RELIEF IN DEFAMATION 26. Plaintiff repeats and realleges all previous paragraphs with the same force and effect as if the same were set forth more fully at length herein.

27. As a result of defendants action, plaintiff has been defamed and sustained damages thereby.

AS AND FOR A SEVENTH CLAIM FOR RELIEF IN FRAUD.

28. Defendants represented to plaintiff that they would accurately compile, maintain and or/disseminate information.

29. Such representations were false.

32. Defendants made such representations recklessly and without regard to their truth ; knew them to be false ; and/or had no knowledge of the truth.

33. Plaintiff relied upon there representations.

34. Plaintiff acted with ordinary prudence in relying upon such representations.

35. Such false representations injured plaintiff.

AS AND FOR AN EIGHTH CLAIM FOR RELIF IN INJUROUS FALSEHOOD 36. Plaintiff repeats and realleges all previous paragraphs with the same force and effect as if the same were set forth more fully at length herein.

37. As a result of defendants acts, plaintiff has been harmed as a result of defendants communicating injurious falsehoods.

AS AND FOR A NINTH CLAIM FOR RELIF IN INTENTIIONAL INFLICTION OF EMOTIONAL DISTRESS 38. Plaintiff repeats and realleges all previous paragraphs with the same force and effect as if the same were set forth more full at length herein.

39. As a result of defendants intentional acts, plaintiff has suffered and continues to suffer emotional distress and diminishment of quality of life, professional life, and business prospects.

AS AND FOR A TENTH CLAIM FOR RELIF IN NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS 40. Plaintiff repeats and realleges all previous paragraphs with the same force and effect as if the same were set forth at length herein.

41. As a result of defendants negligent acts, Plaintiff has suffered and continued to suffer frustration, stress, time lost making calls and writing letters, loss of concentration, delay of personal and business plans, and overall happiness.

AS AND FOR THE ELEVENTH CLAIM FOR RELIF FOR BREACH OF CONTRACT 42. Plaintiff repeats and realleges all previous paragraphs with the same force and effect as if the same were set forth ore fully at length herein.

43. As a result of defendants acts amounting to breach of contract and trust including service agreement, unresolved billing disputes, credit score damages, and failing to correct and block information including adding a consumer statement of dispute per CGA 36a-699c, and 36a-699f and the Fair Credit Billing Act.

AS AND FOR THE TWELVE CLAIM OF RELIEF FOR BREACH OF PRIVACY 44. Plaintiff repeats and realleges all previous paragraphs with the same force and effect as if the same were set forth ore fully at length herein. 
WHEREOFORE, Plaintiff demands judgement against the defendants in a sum in excess of {$50000.00} ( FIFTY THOUSAND DOLLARS ) in the first claim for relief, a sum in excess of {$50000.00} ( FIFTY THOUSAND DOLLARS ) in the second claim for relief, in a sum in excess of {$50000.00} ( FIFTY THOUSAND DOLLARS ) in the third claim for relief in excess of {$50000.00} ( FIFTY THOUSAND DOLLARS ). In the fourth claim of relief in excess of {$50000.00} ( FIFTY THOUSAND DOLLARS ). In the fifth claim of relief in excess of {$50000.00} ( FIFTY THOUSAND DOLLARS ). In the sixth claim of relief in excess of {$50000.00} ( FIFTY THOUSAND DOLLARS ). In the seventh claim of relief in excess of {$50000.00} ( FIFTY THOUSAND DOLLARS ). In the eighth claim of relief in excess of {$50000.00} ( FIFTY THOUSAND DOLLARS ). In the ninth claim of relief in excess of {$50000.00} ( FIFTY THOUSADN DOLLARS ). In the tenth claim of relief in excess of {$50000.00} ( FFITY THOUSAND DOLLARS ). In the eleventh claim of relief ; PUNITIVE DAMAGES FOR ALL CLAIMS AS SET BY THE JURY OR THE COURT, together with attorney fees, the cost and disbursements of this action and such other relief this court may deem just and proper. 

_________________________ Signed _____________________________ Notary