Despite my previous written requests for Experian to provide me with the name of the person in thier company who verified that these disputed accounts are accurate and belong on my file along with copies of the documentation that they used to verify the accuracy of the items I disputed Experian ignored my right to request this information from them. Rather than complying with their duty to provide me with this information Experian repeated refusal to comply clearly demonstrates their willful violation of the FCRA and I believe the Courts will agree when I present them with copies of my letters and their boiler-plate responses to them. 

XXXX Law XXXX, XXXX XXXX, XXXX, defines " Verify '' as, 1 ) " To prove to be true ; to confirm or establish the truth or truthfulness of ; to authenticate. '' 2 ) " to confirm or substantiate by oath or affidavit ; to swear to the truth of. '' and " XXXX '' as, " Confirmation of correctness, truth or authenticity, by affidavit, oath, or deposition. Affidavit of truth of a matter stated and object of verification is to assure good faith in averments or statements of a party. '' I am sure that you are aware of XXXX v. Experian Info. Solutions, XXXX, XXXX XXXX XXXX. XXXX XXXX, XXXX ( XXXX XXXX XXXX ). The reality under the law requires that a credit reporting agency MUST perform an actual independent investigation of a consumer dispute rather than deferring to the reporting information provider and " parroting '' the response of the information provider. The law is clear that a credit reporting agency does not comply with the investigation requirement of 15 USC 1681i if it simply parrots the information provider 's response. 

Experian do n't have any proof on file to verify that these accounts are accurate and belong on my file. When we go to litigation Experian will be required to produce the documents you used to verify these items through the discovery process and since they do n't have any documents in their files verifying that these items are valid then that will be proof that you did not properly verify the accounts and they will have to be deleted and I 'll be entitled to damages including punitive damages. 

Experian repeated refusal to modify their reinvestigation procedures and their insistence on mimicking the original sources ' responses supports the conclusion that punitive damages are also necessary to deter Experian from repeated future violations. See : XXXX of XXXX. XXXX, XXXX XXXX XXXX , XXXX XXXX XXXX, XXXX, XXXX XXXX XXXX XXXX, XXXX XXXX XXXX . XXXX XXXX ( XXXX ). 

Please be advised that under Section 611 ( 5 ) ( A ) of the FCRA - you are required to " ... promptly DELETE all information which can not be verfied. '' The law is very clear as to the Civil liability and the remedy available to me ( Section 616 & 617 ) if you fail to comply with Federal Law. I am a litigious consumer and fully intend on pursuing litigation in this matter to enforce my rights under the FCRA. 




I am offering you one last chance to settle this matter without suffering any monetary damages. I am willing to forgo litigation if you promptly delete the unverified accounts listed below and then send me copies of the updated credit report showing that these unverified accounts have been removed.