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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

RAY F. BUENO,

an individual, 

 Case No.: 

Plaintiff,

v.

UNIVERSITY OF MIAMI,

A Florida Non-Profit Corporation,

EQUIFAX INFORMATION 

SERVICES, LLC, 

a foreign limited liability company, and

TRANS UNION, LLC,

a foreign limited liability company,

Defendants.

_________________________________________/

COMPLAINT

COMES NOW, Plaintiff, RAY BUENO (hereinafter, “Bueno” or 

“Plaintiff”), by and through the undersigned counsel, and hereby sues Defendants, 

UNIVERSITY OF MIAMI (hereinafter, “University of Miami”), EQUIFAX 

INFORMATION SERVICES, LLC (hereinafter, “Equifax”), and TRANS UNION, 

LLC (hereinafter, “Trans Union”) (hereinafter collectively, “Defendants”). In 

support thereof, Plaintiff states:

PRELIMINARY STATEMENT

1. This is an action brought by an individual consumer for damages for 

University of Miami’s violation of the Fair Credit Reporting Act (“FCRA”) wherein

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University of Miami unlawfully reported an alleged a student account balance in

Plaintiff’s consumer credit files as maintained by Equifax and Trans Union. 

2. More specifically, despite Plaintiff advising University of Miami that 

he did not owe a balance on the alleged account, and after Plaintiff disputed 

University of Miami’s reporting of such erroneous information directly to Equifax 

and Trans Union, University of Miami continued to report the account balance.

3. Furthermore, this is an action for damages for Equifax’s and Trans 

Union’s violations of the Reporting Act, 15 United States Code, Section 1681 et seq. 

(hereinafter, the “FCRA”) FCRA wherein Equifax and Trans Union each continued 

to incorrectly report Plaintiff as responsible for the alleged University of Miami

account balance after Plaintiff repeatedly advised that such balance was not owed, 

and after Plaintiff provided information to Equifax and Trans Union proving the

same.

JURISDICTION, VENUE & PARTIES

4. Jurisdiction of this Court arises under 28 United States Code, Section 

1331 as well as pursuant to the FCRA, 15 United States Code Section 1681, et seq.

5. Defendants are subject to the jurisdiction of this Court as Defendants

each regularly transact business in this District.

6. Venue is proper in this District as the acts and transactions described 

herein occur in this District.

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7. At all material times herein, Plaintiff is a natural person residing in 

Miami-Dade County, Florida.

8. At all material times herein, University of Miami does business in 

Florida.

9. At all material times herein, Equifax is a foreign limited liability 

company existing under the laws of the state of Georgia, with its principal place of 

business located at 1550 W Peachtree Street, Atlanta, Georgia 30309.

10. At all material times herein, Trans Union is a foreign limited liability 

company existing under the laws of the state of Delaware with its principal place of 

business located at 555 West Adams Street, Chicago, Illinois 60661.

FCRA STATUTORY STRUCTURE

11. Congress enacted the FCRA requiring consumer reporting agencies to 

adopt reasonable procedures for meeting the needs of commerce for consumer credit, 

personnel, insurance, and other information in a manner fair and equitable to the 

consumer, with regard to the confidentiality, accuracy, relevancy, and proper 

utilization of such information. See 15 United States Code, Section 1681b.

12. Under the FCRA, whenever a consumer reporting agency prepares a 

consumer report, it shall follow reasonable procedures to assure maximum possible 

accuracy of the information concerning the individual about whom the report relates. 

Id. at § e(b) (emphasis added).

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13. Under the FCRA, if a consumer disputes the completeness or accuracy 

of any item of information contained in a consumer’s file, and the consumer 

notifies the agency directly of such dispute, the agency shall reinvestigate—free 

of charge—and report the current status of the disputed information, or delete the 

item from before the end of the 30-day period beginning on the date on which the 

agency receives notice of the consumer’s dispute. Id. at § i(a).

14. Under the FCRA, when a consumer reporting agency conducts any 

reinvestigation with respect to disputed information in the file of any consumer, the 

consumer reporting agency shall review and consider all relevant information 

submitted by the consumer. Id. at § i(a)(4).

15. Under the FCRA, if, after any reinvestigation of any information 

disputed by a consumer, an item of information is found to be inaccurate, 

incomplete, or cannot be verified, the consumer reporting agency shall promptly 

delete that item of information from the consumer’s file or modify that item of 

information, as appropriate, based on the results of the reinvestigation. Id. at § 

i(a)(5).

16. Under the FCRA, after a furnisher of information receives notification 

pursuant to Section 1681i(a)(2) of a dispute with regard to the completeness or 

accuracy of any information provided by a person to a consumer reporting agency, 

the furnisher shall: (A) conduct an investigation with respect to the disputed 

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information; (B) review all relevant information provided by the consumer 

reporting agency pursuant to Section 1681i(a)(2) of this title; (C) report the results 

of the investigation to the consumer reporting agency; and (D) if the investigation 

finds that the information is incomplete or inaccurate, report those results to all 

other consumer reporting agencies to which the person furnished the information 

and that compile and maintain files on consumers on a nationwide basis. Id. at § 

s-2(b).

17. Under the FCRA, any person who willfully fails to comply with any 

requirement imposed under this subchapter with respect to any consumer is liable to 

that consumer: in an amount equal to the sum of any actual damages sustained by 

the consumer as a result of the failure; for statutory damages of not less than $100 

and not more than $1,000; for such amount of punitive damages as the court may 

allow; and for the costs of the action together with reasonable attorneys’ fees. Id. at 

§ n.

18. Under the FCRA, any person who is negligent in failing to comply with 

any requirement imposed with respect to any consumer is liable to that consumer 

in an amount equal to the sum of any actual damages sustained by the consumer 

as a result of the failure and the costs of the action together with reasonable 

attorneys’ fees. Id. at § o.

GENERAL ALLEGATIONS

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19. At all material times herein, Plaintiff is an alleged “consumer” or 

“debtor” as defined by the FCRA, Section 1681a(c).

20. At all material times herein, University of Miami, itself and through its 

subsidiaries, regularly maintains student accounts of consumers residing in MiamiDade County, Florida.

21. At all material times herein, University of Miami is a “person” who 

furnishes information to credit reporting agencies as provided in the FCRA and as 

defined by 15 United States Code, Section 1681s-2. 

22. At all material times herein, University of Miami attempts to collect

and report information concerning an alleged student account referenced by account 

number 6D4699XXXXXXXXXXXX and DA6D46XXXXXXXXXXXX

(hereinafter, the “Alleged Debt” or the “Account”). 

23. At all material times herein, University of Miami furnishes, reports, and 

publishes specific details of consumers alleged outstanding or delinquent debt 

accounts to compel or coerce the consumer to either satisfy an alleged balance owed, 

or suffer the consequences of delinquent accounts, such as higher interest rates on 

consumer loans or complete denial of credit. 

24. At all material times herein, Equifax and Trans Union are each a 

“consumer reporting agency” as defined in 15 United States Code, Section 1681a(f) 

of the FCRA and each regularly engages in the business of assembling, evaluating, 

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and disseminating information concerning consumers for the purpose of furnishing 

consumer reports. Equifax and Trans Union each disburse such consumer reports to 

third parties under contract for monetary compensation. 

25. At all material times herein, Defendants act themselves or through their 

agents, employees, officers, members, directors, successors, assigns, principals, 

trustees, sureties, subrogees, representatives, third-party vendors, and insurers.

26. All necessary conditions precedent to the filing of this action occurred, 

or Defendants waived or excused the same.

FACTUAL ALLEGATIONS

UNIVERSITY OF MIAMI ACCOUNT BALANCE

27. Prior to March 2022, Plaintiff had a student loan account with the 

University of Miami.

28. On March 31, 2022, University of Miami sent Plaintiff an e-mail 

notifying him that University of Miami absolved Plaintiff of the remaining balance 

on the Account. See Exhibit A.

29. The e-mail also states that “no further action relating to payments will 

be pursued” from Plaintiff’s account. Id.

30. Moreover, University of Miami refunded Plaintiff a $640 payment he 

had made in March 2022.

PLAINTIFF’S DISPUTES REGARDING 

THE UNIVERSITY OF MIAMI ACCOUNT

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31. In March 2022, University of Miami was still reporting a balance on 

the Account in an amount greater than $2000.

32. In or around March 2022, Plaintiff submitted a dispute (hereinafter, 

“Plaintiff’s First Dispute”) to Trans Union, Equifax, and Experian Information 

Solutions, Inc. (hereinafter, “Experian”) and stated that the balance of $2,026 was 

incorrect and should instead be $0.

33. University of Miami, Trans Union, Equifax, and Experian each 

received Plaintiff’s First Dispute.

34. In response to Plaintiff’s First Dispute, Experian fixed the incorrect 

balance, but Trans Union and Equifax failed to change the balance from $2,026 to 

$0. 

35. As such, on or about July 19, 2022, Plaintiff submitted yet another 

dispute (hereinafter, “Plaintiff’s Second Dispute”) to Trans Union and Equifax and 

stated that the balance of $2,026 was incorrect and should instead be $0. See Exhibit 

B.

36. Plaintiff’s Second Dispute included University of Miami’s e-mail

absolving the Alleged Debt (Exhibit A).

37. University of Miami, Trans Union, and Equifax each received 

Plaintiff’s Second Dispute.

38. On or about July 29, 2022, Equifax responded to Plaintiff’s Second 

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Dispute and reported the Account as having a balance of $2,065. A true and correct 

copy of Equifax’s Second Dispute response is attached as Exhibit C. 

39. On or about July 30, 2022, Trans Union responded to Plaintiff’s Second 

Dispute and reported the Account as having a balance of $2,065. A true and correct 

copy of Trans Union’s Second Dispute response is attached as Exhibit D. 

40. Importantly, Trans Union and Equifax each verified the incorrect 

balance on the Account, while Experian managed to correct the incorrect reporting.

41. To date, University of Miami is still reporting the Account as having a 

balance on Plaintiff’s Equifax and Trans Union reports. 

DAMAGES

42. As a result of Defendants’ reporting of the Debt, Plaintiff further dealt 

with the stress and anxiety of feeling hopeless, believing that he will be denied credit 

as a result of the erroneous and incorrect reporting of the Account reflecting the 

Alleged Debt asserted as owed by University of Miami if he needs to obtain credit 

in the near future, and that Plaintiff would either be denied credit or pay higher 

interest rates in the event he could obtain financing. 

43. Overall, Plaintiff suffered damage to his otherwise pristine credit 

reputation as a result of Defendants’ conduct.

44. Plaintiff retained Swift, Isringhaus & Dubbeld, P.A. for the purpose of 

pursuing this matter against Defendants.

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45. The FCRA, Sections 1681n or 1681o, or both, provide for the award of 

up to $1,000.00 statutory damages, actual damages, punitive damages, as well as an 

award of attorneys’ fees and costs to Plaintiff, should Plaintiff prevail in this matter 

against University of Miami, Equifax, and Trans Union.

46. As a result of Defendants’ conduct, actions, and inactions, Plaintiff was

deterred from making credit applications as he believed he would not be able to 

obtain favorable credit terms as a result of Defendants’ derogatory and continued

reporting of the Account, he did not wish to further damage his credit score with 

futile credit inquires, and he was continually evaluated for credit using consumer 

reports that reported the Account with incorrect information resulting in the Account 

being reported as a derogatory, negative, or adverse account.

47. Plaintiff was denied credit as a result of Defendants’ derogatory and 

continued reporting of the Account. 

48. Additionally, as a result of Defendants’ actions, Plaintiff suffered 

emotional distress, anxiety, inconvenience, frustration, annoyance, fear, and 

confusion, believing that despite Plaintiff’s exhaustive efforts to convey to 

University of Miami that he did not owe a balance on the Account, Plaintiff must 

simply endure Defendants’ reporting of the Account.

COUNT ONE

FAIR CREDIT REPORTING ACT –

VIOLATION OF 15 UNITED STATES CODE, SECTION 1681s-2(b)

(As to University of Miami Only)

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Plaintiff re-alleges paragraphs one (1) through forty-eight (48) as if fully 

restated herein and further states as follows:

49. University of Miami is subject to, and violated the provisions of, 15 

United States Code, Section 1681s-2(b), by willfully and/or negligently publishing 

or furnishing inaccurate trade-line information within Plaintiff’s credit reports, 

failing to fully and properly re-investigate Plaintiff’s disputes, failing to review all 

relevant information regarding the same, and failing to request that Equifax and 

Trans Union remove the Account balance from Plaintiff’s credit reports and credit 

file after re-investigating Plaintiff’s repeated disputes.

50. As described above, University of Miami absolved Plaintiff of any 

balance on the Account.

51. As such, it is materially misleading for University of Miami to continue 

to report Plaintiff as having a balance after the same was described in multiple 

disputes. 

52. Despite University of Miami receiving notice of Plaintiff’s disputes

from Plaintiff, Equifax, and Trans Union—including the information and documents 

referenced in the above paragraph—University of Miami willfully and/or 

negligently failed to request that Equifax and Trans Union remove the balance on 

the Account and continued to report derogatory, incorrect information to Equifax 

and Trans Union including a significant balance due.

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53. University of Miami’s credit reporting is materially misleading.

54. University of Miami’s re-investigations were not conducted in good 

faith.

55. University of Miami’s re-investigations were not conducted 

reasonably. 

56. University of Miami’s re-investigations were not conducted using all 

information and documents reasonably available to University of Miami.

57. As a result of University of Miami’s conduct, actions, and inactions, 

Plaintiff suffered damage to his credit reputation and credit worthiness, was deterred 

from making credit applications as he believed he would not be able to obtain 

favorable credit terms as a result of Defendants’ derogatory and continued reporting 

of the Account, did not wish to further damage his credit score with futile credit 

inquires, and he was continually evaluated for credit using consumer reports that 

reported the Account with incorrect information resulting in the Account being 

reported as a derogatory, negative, or adverse tradeline account.

58. University of Miami’s conduct was a direct and proximate cause of, as 

well as a substantial factor in, causing the serious injuries, damages, and harm to 

Plaintiff as stated herein.

59. Plaintiff was denied credit as a result of University of Miami’s 

inaccurate reporting. 

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60. University of Miami’s actions in violation of 15 United States Code, 

Section 1681s-2(b), constitute negligent or willful noncompliance, or both, with the 

FCRA, and entitles Plaintiff to actual damages, statutory damages, and punitive 

damages, as well as attorneys’ fees and costs as enumerated in 15 United States 

Code, Sections 1681n or 1681o, or both.

COUNT TWO:

FAIR CREDIT REPORTING ACT –

VIOLATION OF 15 UNITED STATES CODE, SECTION 1681e(b)

Plaintiff re-alleges paragraphs one (1) through forty-eight (48) as if fully 

restated herein and further states as follows:

61. Equifax and Trans Union are each subject to, and each violated the 

provisions of, 15 United States Code, Section 1681e(b), by failing to establish or 

follow reasonable procedures to assure maximum possible accuracy in the 

preparation of the credit reports and credit files published and maintained concerning 

Plaintiff.

62. Equifax and Trans Union willfully and/or negligently failed to establish 

or follow reasonable procedures to assure maximum possible accuracy in the 

preparation of Plaintiff’s credit reports regarding the Account. 

63. Specifically, despite Plaintiff advising Equifax and Trans Union that 

Plaintiff did not owe a balance the Account—Equifax and Trans Union each 

continued to report the Account with a balance due, resulting in the Account being 

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reported as a derogatory, negative, or adverse account in Plaintiff’s credit reports 

and credit files.

64. Further, Equifax and Trans Union willfully and/or negligently failed to 

establish or follow reasonable procedures to assure maximum possible accuracy of 

Plaintiff’s credit reports and credit files when re-investigating Plaintiff’s disputes of 

the above-referenced inaccuracies contained in his Equifax and Trans Union credit 

reports and credit file. 

65. Such reporting of the Account is false and evidences Equifax’s and 

Trans Union’s failure to establish or follow reasonable procedures to assure the 

maximum possible accuracy of Plaintiff’s credit reports and credit file. 

66. As a result of Equifax’s and Trans Union’s conduct, actions, and 

inactions, Plaintiff suffered damage to his credit reputation and credit worthiness, 

was deterred from making credit applications as he believed he would not be able to 

obtain favorable credit terms as a result of Defendants’ derogatory and continued 

reporting of the Account, did not wish to further damage his credit score with futile 

credit inquires, and he was continually evaluated for credit using consumer reports 

that reported the Account with incorrect information resulting in the Account being 

reported as a derogatory, negative, or adverse tradeline account.

67. Plaintiff was denied credit as a result of Equifax’s and Trans Union’s 

actions.

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68. Equifax’s and Trans Union’s actions were a direct and proximate cause 

of, as well as a substantial factor in, the serious injuries, damages, and harm to 

Plaintiff as stated herein. 

69. Equifax’s and Trans Union’s violations of 15 United States Code

Section 1681e(b), constitute negligent or willful noncompliance—or both—with the 

FCRA, and entitle Plaintiff to actual damages, statutory damages, punitive damages, 

as well as attorneys’ fees and costs as enumerated in 15 United States Code, Sections 

1681n, or 1681o, or both.

COUNT THREE:

FAIR CREDIT REPORTING ACT –

VIOLATION OF 15 UNITED STATES CODE, SECTION 1681i(a)(1)

Plaintiff re-alleges paragraphs one (1) through forty-eight (48) as if fully 

restated herein and further states as follows:

70. Equifax and Trans Union are each subject to, and each violated the 

provisions of, 15 United States Code, Section 1681i(a)(1), by failing to conduct 

reasonable re-investigations of Plaintiff’s disputes to determine whether the disputed 

information was inaccurate and by failing to subsequently update the inaccurate 

information in Plaintiff’s credit reports and credit files.

71. Specifically, Equifax and Trans Union each willfully and/or negligently 

refused to properly re-investigate Plaintiff’s consumer reports upon receiving 

Plaintiff’s disputes, as described herein.

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72. Equifax and Trans Union did not request any documents from 

University of Miami corroborating information furnished and verified by University 

of Miami to Equifax and Trans Union regarding Plaintiff and the Account in 

response to any of Plaintiff’s Disputes.

73. As such, Equifax’s and Trans Union’s re-investigations were not 

conducted in such a way as to assure whether information regarding Plaintiff and the 

Account was inaccurate and each failed to subsequently update and remove the 

inaccurate information in Plaintiff’s credit reports and credit files.

74. Such reporting is false and evidences Equifax’s and Trans Union’s

failure to conduct reasonable re-investigations of Plaintiff’s repeated disputes. 

75. Equifax’s and Trans Union’s reinvestigations of Plaintiff’s disputes 

were not conducted reasonably. 

76. Equifax’s and Trans Union’s reinvestigations merely copied and relied 

upon the inaccurate Account information conveyed by University of Miami.

77. Equifax’s and Trans Union’s reinvestigations of Plaintiff’s disputes 

were not conducted in good faith.

78. Equifax’s and Trans Union’s reinvestigation procedures are 

unreasonable. 

79. Equifax’s and Trans Union’s re-investigations of Plaintiff’s disputes 

were not conducted using all information reasonably available to Equifax and Trans 

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Union.

80. Equifax’s and Trans Union’s reinvestigations were per se deficient by 

reason of these failures in Equifax’s and Trans Union’sreinvestigations of Plaintiff’s

disputes and the Account.

81. As a result of Equifax’s and Trans Union’s conduct, actions, and 

inactions, Plaintiff suffered damage to his credit reputation and credit worthiness, 

was deterred from making credit applications as he believed he would not be able to 

obtain favorable credit terms as a result of Defendants’ derogatory and continued 

reporting of the Account, did not wish to further damage his credit score with futile 

credit inquires, and he was continually evaluated for credit using consumer reports 

that reported the Account with incorrect information resulting in the Account being 

reported as a derogatory, negative, or adverse tradeline account.

82. Plaintiff was denied credit as a result of Equifax’s and Trans Union’s 

actions.

83. Equifax’s and Trans Union’s actions were a direct and proximate cause 

of, as well as a substantial factor in, the serious injuries, damages, and harm to 

Plaintiff as stated herein. 

84. Equifax’s and Trans Union’s actions in violation of 15 United States 

Code, Section 1681i(a)(1), constitute negligent or willful noncompliance—or 

both—with the FCRA, and entitle Plaintiff to actual damages, statutory damages, 

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punitive, damages, as well as attorneys’ fees and costs enumerated in 15 United 

States Code, Sections 1681n or 1681o, or both.

COUNT FOUR: 

FAIR CREDIT REPORTING ACT –

VIOLATION OF 15 UNITED STATES CODE, SECTION 1681i(a)(4) 

Plaintiff re-alleges paragraph one (1) through forty-eight (48) as if fully 

restated herein and further states as follows:

85. Equifax and Trans Union are each subject to, and each violated the 

provisions of, 15 United States Code, Section 1681i(a)(4), by failing to review and 

consider all relevant information received in Plaintiff’s disputes, including all 

relevant attachments.

86. Specifically, despite Equifax and Trans Union receiving Plaintiff’s

Disputes—Equifax and Trans Union each continued to report the Account with 

derogatory, incorrect information, causing the Account to be reported as a 

derogatory, negative, or adverse tradeline account. 

87. Equifax’s and Trans Union’s failure to review and consider all 

information received in Plaintiff’s disputes was done in bad faith.

88. As a result of Equifax’s and Trans Union’s conduct, actions, and 

inactions, Plaintiff suffered damage to his credit reputation and credit worthiness, 

was deterred from making credit applications as he believed he would not be able to 

obtain favorable credit terms as a result of Defendants’ derogatory and continued 

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reporting of the Account, did not wish to further damage his credit score with futile 

credit inquires, and he was continually evaluated for credit using consumer reports 

that reported the Account with incorrect information resulting in the Account being 

reported as a derogatory, negative, or adverse tradeline account.

89. Plaintiff was denied credit as a result of Equifax’s and Trans Union’s 

actions.

90. Equifax’s and Trans Union’s actions were a direct and proximate cause 

of, as well as a substantial factor in, the serious injuries, damages, and harm to 

Plaintiff as stated herein. 

91. Equifax’s and Trans Union’s actions in violation of 15 United States 

Code, Section 1681i(a)(4), constitute negligent or willful noncompliance—or 

both—with the FCRA, and entitle Plaintiff to actual damages, statutory damages, 

punitive, damages, as well as attorneys’ fees and costs enumerated in 15 United 

States Code, Sections 1681n or 1681o, or both.

COUNT FIVE: 

FAIR CREDIT REPORTING ACT –

VIOLATION OF 15 UNITED STATES CODE, SECTION 1681i(a)(5)

Plaintiff re-alleges paragraphs one (1) through forty-eight (48) as if fully 

restated herein and further states as follows:

92. Equifax and Trans Union are each subject to, and each violated the 

provisions of, 15 United States Code, Section 1681i(a)(5), by failing to update or 

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delete any information that was the subject of Plaintiff’s disputes found to be

inaccurate or that could not be verified. 

93. Specifically, despite Equifax and Trans Union receiving Plaintiff’s

Disputes—neither Equifax nor Trans Union removed the balance of the Account 

from Plaintiff’s credit reports and credit files.

94. Instead, Equifax and Trans Union continued to report derogatory

information regarding the Account. 

95. As a result of Equifax’s and Trans Union’s conduct, actions, and 

inactions, Plaintiff suffered damage to his credit reputation and credit worthiness, 

was deterred from making credit applications as he believed he would not be able to 

obtain favorable credit terms as a result of Defendants’ derogatory and continued 

reporting of the Account, did not wish to further damage his credit score with futile 

credit inquires, and he was continually evaluated for credit using consumer reports 

that reported the Account with incorrect information resulting in the Account being 

reported as a derogatory, negative, or adverse tradeline account.

96. Plaintiff was denied credit as a result of Equifax’s and Trans Union’s 

actions.

97. Equifax’s and Trans Union’s actions were a direct and proximate cause 

of, as well as a substantial factor in, the serious injuries, damages, and harm to 

Plaintiff as stated herein. 

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98. Equifax’s and Trans Union’s actions in violation of 15 United States 

Code, Section 1681i(a)(5), constitute negligent or willful noncompliance—or 

both—with the FCRA, and entitles Plaintiff to actual damages, statutory damages, 

punitive, damages, as well as attorneys’ fees and costs enumerated in 15 United 

States Code, Sections 1681n or 1681o, or both.

PRAYER FOR RELIEF 

WHEREFORE, as a direct and proximate result of Defendants’ conduct, 

Plaintiff respectfully request an entry of: 

a. Judgment against University of Miami, Equifax, and Trans 

Union for maximum statutory damages for violations of the FCRA;

b. Actual damages in an amount to be determined at trial; 

c. Compensatory damages in an amount to be determined at trial; 

d. Punitive damages in an amount to be determined at trial;

e. An award of attorney’s fees and costs; and 

f. Any other such relief the Court may deem proper. 

DEMAND FOR JURY TRIAL 

Plaintiff hereby demand a trial by jury on all issues triable by right. 

SPOLIATION NOTICE AND DEMAND TO RETAIN EVIDENCE 

Plaintiff hereby gives notice to Defendants and demands that Defendants and 

their affiliates safeguard all relevant evidence—paper, electronic documents, or 

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data—pertaining to this litigation as required by law. 

Respectfully submitted,

 SWIFT, ISRINGHAUS & DUBBELD P.A.

/s/ Jon P. Dubbeld __________

Aaron M. Swift, Esq., FBN 0093088

Jordan T. Isringhaus, Esq., FBN 0091487

Jon P. Dubbeld, Esq., FBN 105869

Sean E. McEleney, Esq., FBN 125561

8380 Bay Pines Blvd.

St. Petersburg, FL 33709

Phone: (727) 755-3676

Fax: (727) 255-5332

aswift@swift-law.com

jisringhaus@swift-law.com

jdubbeld@swift-law.com

smceleney@swift-law.com

Counsel for Plaintiff

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