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UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

MARY KAY WEISS, 

Plaintiff, 

v. 

EQUIFAX INFORMATION SERVICES, LLC 

and CREDIT MANAGEMENT, LP, 

 

Defendants. 

CIVIL ACTION 

COMPLAINT 4:22-cv-00331 

JURY TRIAL DEMANDED 

COMPLAINT 

 NOW COMES Mary Kay Weiss (“Plaintiff”), by and through her attorneys, Sulaiman Law 

Group, Ltd., complaining of the Defendants Equifax Information Services, LLC (“Equifax”) and 

Credit Management, LP, (“Credit Management”) (collectively as “Defendants”) as follows: 

NATURE OF THE ACTION

1. Plaintiff brings this action seeking redress for Defendants’ violations of the Fair Credit 

Reporting Act (“FCRA”) pursuant to 15 U.S.C. §1681 et seq., and Credit Management’s violations 

of the Fair Debt Collection Practices Act (“FDCPA”) pursuant to 15 U.S.C. §1692 et seq. 

JURISDICTION AND VENUE

2. Subject matter jurisdiction is conferred upon this Court by the FCRA, FDCPA, 28 U.S.C. 

§§1331 and 1337, as the action arises under the laws of the United States. 

3. Venue is proper in this Court pursuant to 28 U.S.C. §1391 as a substantial part of the events 

or omissions giving rise to Plaintiff’s claims against Defendants occurred in the Northern District 

of Texas. 

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PARTIES

4. Plaintiff is a consumer and a natural person over 18-years-of-age who, at all times relevant, 

is a consumer over the age of 21. 

5. Defendant Credit Management is a Texas corporation with its principal place of business 

located at 6080 Tennyson Parkway, Suite 100 Plano, Texas. Credit Management is a third-party 

debt collector that is in the business of collecting debts owed or asserted to be owed or due to 

others. Credit Management is registered with the Texas Secretary of State and actively collects 

consumer debts in Texas. Credit Management is a furnisher of information to the major credit 

reporting agencies, including Equifax. 

6. Defendant Equifax is a Georgia limited liability corporation with its principal place of 

business located in Texas. Equifax is regularly engaged in the business of assembling, evaluating, 

and disbursing information concerning consumers for the purpose of furnishing consumer reports 

and credit files to third parties bearing on a consumer’s credit worthiness, credit standing, and 

credit capacity on a nationwide basis, including in the State of Texas. 

FACTS SUPPORTING CAUSE OF ACTION

7. Prior to the events giving rise to this action, Plaintiff obtained a membership with Equifax 

to monitor her credit report. 

8. On or around January 2022, Plaintiff noticed Credit Management began reporting a 

collection account owed to AllianceRx Walgreens Prime for $231.00 (“alleged subject debt”). 

9. Unfortunately, Credit Management had inaccurately reported the alleged subject debt to 

Plaintiff’s Equifax credit report despite her not owing the subject debt. 

10. At no point in time did Plaintiff receive services from AllianceRx Walgreens Prime that 

resulted in a balance still owed. 

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11. After receiving notice of the inaccurate reporting, Plaintiff placed an outgoing call to Credit 

Management to dispute the subject debt. 

12. Specifically, Plaintiff was told by Credit Management that the alleged subject debt was 

reported in error and the Plaintiff had no outstanding accounts in its offices. 

13. On January 20, 2022, Plaintiff mailed written disputes to Equifax to correct Credit 

Management’s error on her credit report. 

14. On February 9, 2022, Equifax reviewed and responded to Plaintiff’s disputes, detailing that 

the subject account belonged to Plaintiff and it was reporting correctly. 

15. Plaintiff was flabbergasted by Equifax’s response as she was already told by Credit 

Management that the alleged subject debt did not belong to her and no other accounts were in its 

office for collection. 

16. Upon information and belief, Credit Management received notice of Plaintiff’s disputes 

and all relevant information from Equifax within five days of Equifax receiving Plaintiff’s 

disputes. See 15 U.S. Code §1681i(a)(2). 

17. Furthermore, Defendants’ reporting of the inaccurate subject has prevented Plaintiff from 

receiving financial and credit opportunities for her personal use that she otherwise would have 

qualified for, but for Defendants inaccurate and materially misleading reporting of the subject debt. 

18. Notwithstanding Plaintiff’s disputes, Credit Management failed to conduct timely and 

reasonable investigations of Plaintiff’s disputes after being put on notice of erroneous credit 

reporting of the subject debt in Plaintiff’s credit file from Equifax. 

19. The reporting of the subject debt was inaccurate and materially misleading because Credit 

Management had previously confirmed with Plaintiff that the subject debt was not owed by 

Plaintiff at any point in time. 

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IMPACT OF CONTINUING

INACCURATE REPORTING ON PLAINTIFF’S CREDIT FILE

20. The erroneous reporting of the Credit Management account paints a false and damaging 

image of Plaintiff. After it was provided notice by Plaintiff and Equifax, Credit Management did 

not update its trade line to accurately reflect that Plaintiff did not owe the alleged subject debt. 

21. The entire experience has imposed upon Plaintiff significant distrust, frustration, distress, 

and has rendered Plaintiff helpless as to her ability to regain a firm foothold on her 

creditworthiness, credit standing, and credit capacity. 

22. The inaccurate reporting of subject debt had significant adverse effects on Plaintiff’s credit 

rating because it created a false impression that Plaintiff was still personally liable and obligated 

to pay on the subject debt, rendering Plaintiff a high risk consumer and damaging her 

creditworthiness. 

23. As a result of the conduct, actions, and inaction of Credit Management, Plaintiff has 

suffered various types of damages as set forth herein, including specifically, the loss of credit 

opportunity, the loss of ability to purchase and benefit from a credit line, increased interest rates, 

expenses arising from local telephone calls, tracking the status of her disputes, monitoring her 

credit files, and mental and emotional pain and suffering. 

24. Due to the conduct of Credit Management, Plaintiff was forced to retain counsel to correct 

the inaccuracies in her credit file. 

COUNT I – VIOLATIONS OF THE FAIR CREDIT REPORTING ACT

(Against Equifax) 

25. Plaintiff restates and realleges all paragraphs 1 through 24 as though fully set forth herein. 

26. Equifax is a “consumer reporting agency” as defined by 15 U.S.C. §1681a(f). 

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27. Equifax is a “consumer reporting agency that compiles and maintains files on consumers 

on a nationwide basis” as defined by 15 U.S.C. §1681a(p). 

28. At all times relevant, the above-mentioned credit reports were “consumer reports” as that 

term is defined by §1681a(d). 

29. At all times relevant, Plaintiff was a “consumer” as the term is defined by 15 U.S.C. 

§1681a(c). 

30. The FCRA mandates that “[w]henever 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.” 15 U.S.C. § 1681e(b). 

31. The FCRA requires the credit reporting industry to implement procedures and systems to 

promote accurate credit reporting. 

32. If a consumer notifies a credit reporting agency of a dispute concerning the accuracy of 

any item of credit information, the FCRA requires the credit reporting agency to conduct a 

reasonable investigation to determine whether the disputed information is inaccurate and record 

the current status of the disputed information or delete the disputed information within 30 days of 

receiving the dispute. 15 U.S.C. §1681i(a)(1)(A). 

33. Plaintiff provided Equifax with all relevant information and documentation in her dispute 

to support her contention that the disputed account was reporting inaccurately. 

34. A cursory review of the evidence submitted by Plaintiff would have confirmed that the 

disputed account was reporting inaccurately. 

35. Equifax failed to conduct a meaningful investigation into Plaintiff’s dispute. Instead, it 

continued to blindly report the false information provided to it by Credit Management. 

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36. Equifax violated 15 U.S.C. §1681e(b) by failing to establish or to follow reasonable 

procedures to assure maximum possible accuracy in preparation of the consumer reports it 

furnished and refurnished concerning Plaintiff. 

37. Equifax repeatedly distributed patently false and materially misleading consumer reports 

concerning Plaintiff to third parties. 

38. Equifax failed to follow reasonable procedures to assure maximum possible accuracy by 

repeatedly ignoring the evidence provided by Plaintiff and blindly accepting erroneous information 

furnished to it by Credit Management as accurate. 

39. Had Equifax followed reasonable procedures to assure maximum possible accuracy, it 

would have reviewed the dispute and evidence submitted by Plaintiff and promptly discovered that 

the disputed account was reporting inaccurately. Instead, Equifax repeatedly accepted erroneous 

information as true and continued the reporting of the erroneous information pertaining to the 

disputed account. 

40. Equifax should have implemented procedures and safeguards to prevent the repeated 

reporting inaccurate information regarding the account. 

41. Equifax violated 15 U.S.C. §1681i(a)(1) by failing to (1) conduct a reasonable investigation 

into Plaintiff’s dispute and (2) modify the account to report accurately on Plaintiff’s credit file. 

42. Had Equifax conducted a reasonable investigation into Plaintiff’s valid dispute, it would 

have promptly determined that the disputed account was reporting incorrectly. 

43. Equifax took no meaningful action to determine whether the disputed account was 

reporting incorrectly and blindly reported the same with no regard to its accuracy. 

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44. At very minimum, Equifax should have requested that Credit Management provide proof 

that their reporting was accurate. Instead, Equifax continued to recklessly report false and 

unreliable information regarding the account. 

45. Equifax violated 15 U.S.C. §1681i(a)(2) by failing to provide adequate notification of 

Plaintiff’s dispute to Credit Management. Upon information and belief, Equifax may have failed 

to forward all relevant information provided by Plaintiff to Credit Management. 

46. Equifax violated 15 U.S.C. §1681i(a)(4) by failing to review and consider all relevant 

information that it received from Plaintiff with regard to the disputed account. 

47. Equifax violated 15 U.S.C. §1681i(a)(5) by failing to modify the disputed account that was 

the subject of Plaintiff’s dispute after Plaintiff submitted compelling evidence that the disputed 

account was reporting inaccurately. 

48. Equifax had actual knowledge that the erroneous reporting of the disputed account would 

have a significant adverse effect on Plaintiff’s credit worthiness and ability to obtain credit. 

49. Despite having actual knowledge that Plaintiff’s credit file contained erroneous 

information, Equifax readily distributed Plaintiff’s inaccurate and misleading credit reports to one 

or more third parties, thereby misrepresenting facts about Plaintiff and Plaintiff’s creditworthiness. 

50. By deviating from the standards established by the credit reporting industry and the FCRA, 

Equifax acted with a reckless disregard of its duty to report accurate and complete consumer credit 

information. 

51. It is Equifax’s regular business practice to blindly report disputed information without 

taking the required investigatory steps to meaningfully verify such information as accurate. 

52. Equifax’s non-compliance with the requirements of the FCRA is indicative of the reckless, 

willful, and wanton nature of its mistreatment of Plaintiff. 

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53. Equifax has exhibited a pattern of refusing to correct errors in consumer credit files despite 

being on notice of patently false and materially misleading information contained in such files, 

ultimately valuing its own convenience above its grave responsibility to report accurate consumer 

data. 

54. As stated above, Plaintiff was significantly harmed by Equifax’s conduct. 

WHEREFORE, Plaintiff, MARY KAY WEISS, prays for the following relief: 

a. A finding that Equifax’s conduct as set forth herein violated the FCRA; 

b. An Order enjoining Equifax from reporting the fraudulent account; 

c. An award of compensatory damages to Plaintiff to be determined by the jury; 

d. An award of statutory damages of $1,000.00 for each violation of the FCRA; 

e. An award of punitive damages to be determined by the jury; and 

f. An award of reasonable attorney’s fees and costs pursuant to 15 U.S.C. §1681n and 15 

U.S.C. §1681o; and 

g. Awarding any other relief as this Honorable Court deems just and appropriate. 

COUNT II - VIOLATIONS OF THE FAIR CREDIT REPORTING ACT

(Against Credit Management) 

55. Plaintiff restates and reallages paragraphs 1 through 54 as though fully set forth herein. 

56. Plaintiff is a “consumer” as defined by 15 U.S.C. §§1681a(b) and (c). 

57. Credit Management is a “person” as defined by 15 U.S.C. §1681a(b). 

58. Credit Management is a “furnisher of information” as defined by 15 U.S.C. §1681s-2 and 

a “financial institution” as defined by 15 U.S.C. §1681a(t). 

59. At all times relevant, the above mentioned credit reports were “consumer reports” as the 

term is defined by §1681a(d)(1). 

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60. Credit Management violated 15 U.S.C. §1681s-2(b)(1)(A) by failing to conduct an 

investigation with respect to the disputed information after receiving requests for an investigation 

from Equifax and Plaintiff. 

61. Credit Management violated 15 U.S.C. §1681s-2(b)(1)(B) by failing to review all relevant 

information, provided by Equifax and Plaintiff pursuant to 15 U.S.C. §1681i(a)(2). 

62. Had Credit Management reviewed the information provided by Equifax and Plaintiff, it 

would have corrected the inaccurate designation of the subject debt, transmitting the correct 

information to Equifax. Instead, Credit Management wrongfully and erroneously confirmed its 

inaccurate reporting without conducting a reasonable investigation. 

63. Credit Management violated 15 U.S.C. §1681s-2(b)(1)(C) by failing to report the results 

of the investigation or reinvestigation of Plaintiff’s disputes with Equifax. 

64. Credit Management violated 15 U.S.C. §1681s-2(b)(1)(C)-(D) by failing to report the 

results of its investigation or reinvestigation to Equifax after being put on notice and discovering 

inaccurate and misleading reporting with respect to the subject debt. 

65. Credit Management violated 15 U.S.C. §1681s-2(b)(1)(E) by failing to modify, delete, or 

permanently block the inaccurate information in Plaintiff’s credit files. 

66. Credit Management failed to conduct a reasonable investigation of its reporting of the 

subject debt, record that the information was disputed, or delete the inaccurate information from 

Plaintiff’s credit files within 30 days of receiving notice of the disputes from Equifax under 15 

U.S.C. §1681i(a)(1). 

67. Despite the blatantly obvious errors in Plaintiff’s credit files, and Plaintiff’s efforts to 

correct the errors, Credit Management did not correct the errors or trade line to report accurately. 

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Instead, Credit Management wrongfully furnished and reported the inaccurate and misleading 

information after Plaintiff’s disputes to one or more third parties. 

68. A reasonable investigation by Credit Management would have confirmed the veracity of 

Plaintiff’s disputes, yet the inaccurate information continues to be reported in Plaintiff’s credit 

files. 

69. Had Credit Management taken steps to investigate Plaintiff’s valid disputes or Equifax’s 

requests for investigation, it would have permanently corrected the erroneous and misleading 

credit reporting. 

70. By deviating from the standards established by the debt collection industry and the FCRA, 

Credit Management acted with reckless and willful disregard for its duty as a furnisher to report 

accurate and complete consumer credit information to Equifax. 

WHEREFORE, Plaintiff MARY KAY WEISS respectfully prays this Honorable Court for the 

following relief: 

a. Declare that the practices complained of herein are unlawful and violate the 

aforementioned statute; 

b. An order directing that Credit Management immediately delete all of the inaccurate 

information from Plaintiff’s credit reports and credit files; 

c. Award Plaintiff actual damages, in an amount to be determined at trial, for each of the 

underlying FCRA violations; 

d. Award Plaintiff statutory damages of $1,000.00 for each violation of the FCRA, pursuant 

to 15 U.S.C. §1681n; 

e. Award Plaintiff punitive damages, in an amount to be determined at trial, for the underlying 

FCRA violations, pursuant to 15 U.S.C. §1681n and 15 U.S.C. §1681o; 

f. Award Plaintiff costs and reasonable attorney’s fees as provided under 15 U.S.C. §1681n 

and 15 U.S.C. §1681o; and 

g. Award any other relief as this Honorable Court deems just and appropriate. 

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COUNT III – VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT

(AGAINST CREDIT MANAGEMENT) 

71. Plaintiff restates and realleges paragraphs 1 through 70 as though fully set forth herein. 

72. The Plaintiff is a “consumer” as defined by FDCPA §1692a(3). 

73. The subject debt qualifies as a “debt” as defined by FDCPA §1692a(5) as it arises out of a 

transaction due or asserted to be owed or due to another for personal, family, or household 

purposes. 

74. Credit Management qualifies as a “debt collector” as defined by §1692a(6) because it 

regularly collects debts and uses the mail and/or the telephones to collect delinquent consumer 

accounts. 

75. Credit Management qualifies as a “debt collector” because it acquired rights to the subject 

debt after it was in default or in the alternative, treated the subject debt as if it was in default. 15 

U.S.C. §1692a(6). 

76. Credit Management’s communications to Plaintiff were made in connection with a 

collection of the subject debt. 

77. Credit Management violated 15 U.S.C. §§1692e(2), e(8), e(10), f, and f(1), through its debt 

collection efforts on the subject debt. 

a. Violations of FDCPA § 1692e 

78. Credit Management violated §1692e(2) when it misrepresented the character, amount, or 

legal status of the subject debt. The subject debt was not owed at the time Credit Management 

began reporting the subject debt because it was not Plaintiff’s subject debt. Specifically, Plaintiff 

did not have any legal or personal obligation to pay Credit Management since she never received 

services from AllianceRx Walgreens Prime at any point resulting in a balance owed. 

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79. Credit Management violated §1692e(8) by threatening and communicating patently false 

credit information to Equifax that it knew, or should have known, to be false by inaccurately 

reporting the subject debt as in collections and a high balance. This information was inaccurate 

and misleading because Plaintiff had no obligations to pay Credit Management or the subject debt. 

80. Credit Management had actual knowledge that the subject debt was false because it 

received notices of Plaintiff’s disputes from Plaintiff and Equifax. 

81. Credit Management violated §1692e(10) when it used false representations and/or 

deceptive means to collect and/or attempt to collect the subject debt. The subject debt was not 

owed by Plaintiff at the time Credit Management began reporting the subject debt. 

b. Violations of FDCPA § 1692f 

82. Credit Management violated §1692f when it used unfair and unconscionable means to 

collect the subject debt. The subject debt was not owed at the time Credit Management demanded 

payment and continued to report Plaintiff in collections with a high balance. Plaintiff did not have 

any legal obligation to pay Credit Management as the subject debt did not belong to her. Instead, 

Credit Management tried to dragoon Plaintiff into making a payment by attempting to mislead her 

into believing that she is delinquent on the subject debt and is still obligated to make payment on 

the subject debt. 

83. Credit Management violated §1692f(1) by attempting to collect a debt that was not owed 

by Plaintiff. 

84. Credit Management attempted to coerce and induce the Plaintiff into paying a debt that 

was not legally owed. 

85. As an experienced debt collector, Credit Management knew or should have known the 

ramifications of collecting on a debt not owed. 

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86. Upon information and belief, Credit Management has no system in place to identify and 

cease collection of debts that were paid in full. 

87. As stated above, Plaintiff was severely harmed by Credit Management’s conduct. 

WHEREFORE, Plaintiff MARY KAY WEISS respectfully prays this Honorable Court for the 

following relief: 

a. Declare that the practices complained of herein are unlawful and violate the 

aforementioned statute; 

b. Award Plaintiff statutory and actual damages, in an amount to be determined at trial, for 

the underlying FDCPA violations; 

c. Award Plaintiff costs and reasonable attorney fees as provided under 15 U.S.C. 

§1692k; and 

d. Award any other relief as this Honorable Court deems just and appropriate. 

Plaintiff demands trial by jury. 

Dated: April 19, 2022 Respectfully Submitted, 

 /s/ Marwan R. Daher 

Marwan R. Daher, Esq.

Counsel for Plaintiff 

Sulaiman Law Group, Ltd 

2500 S Highland Ave, Suite 200 

Lombard, IL 60148 

Telephone: (630) 575-8181 

mdaher@sulaimanlaw.com

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