Andrew M. Altschul, OSB No. 980302

andrew@baaslaw.com

BUCHANAN ANGELI ALTSCHUL

& SULLIVAN LLP

321 SW 4th Avenue, Suite 600

Portland, Oregon 97204

Telephone: (503) 974-5015

Facsimile: (503) 230-0337

Frederick T. Smith (pro hac vice application to be filed)

fsmith@seyfarth.com

Megan H. Poonolly (admitted pro hac vice)

mpoonolly@seyfarth.com

SEYFARTH SHAW LLP

1075 Peachtree Street, Suite 2500

Atlanta, Georgia 30309-3958

Telephone: (404) 885-1500

Facsimile: (404) 892-7056

Counsel for Defendant

First Advantage Background Services Corp.

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

PORTLAND DIVISION

SAMANTHA JOHNSON,

Plaintiff,

v.

BACKGROUND INVESTIGATIONS, INC., a

domestic corporation, CORELOGIC

CREDCO, LLC, a foreign corporation, FIRST

ADVANTAGE BACKGROUND SERVICES

CORP., a foreign corporation, ADVANCED

REPORTING, LLC, a domestic corporation,

Defendant.

Case No. 3:16-cv-00051-BR

DEFENDANT FIRST ADVANTAGE BACKGROUND

SERVICES CORP.’S ANSWER TO PLAINTIFF’S AMENDED COMPLAINT

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 1 of 18
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Defendant FIRST ADVANTAGE BACKGROUND SERVICES CORP., by its attorneys

and pursuant to Rules 8 and 12 of the Federal Rules of Civil Procedure, hereby answers Plaintiff

SAMANTHA JOHNSON’s Amended Complaint and asserts its affirmative defenses as follows:

COMPLAINT ¶ 1:

The court has jurisdiction under 15 U.S.C. § 1681p.

ANSWER:

First Advantage admits the allegations in Paragraph No. 1 of Plaintiff’s Amended

Complaint.

COMPLAINT ¶ 2:

Plaintiff Samantha Johnson (“Plaintiff’) is a consumer as defined by the Fair Credit

Reporting Act (FCRA), 15 U.S.C. § 1681a(c).

ANSWER:

First Advantage admits the allegations in Paragraph No. 2 of Plaintiff’s Amended

Complaint.

COMPLAINT ¶ 3:

Defendant Background Investigations, Inc. (“Background Investigations”) is a consumer

reporting agency as defined by the FCRA, 15 U.S.C. § 1681a(f).

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 3 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 4:

Defendant CoreLogic Credco, LLC, which does business under the name CoreLogic

SafeRent, LLC (“CoreLogic”) is a consumer reporting agency as defined by the FCRA, 15

U.S.C. § 1681a(f).

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 2 of 18
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ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 4 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 5:

Defendant First Advantage Background Services Corp. (“First Advantage”) is a

consumer reporting agency as defined by the FCRA, 15 U.S.C. § 1681a(f).

ANSWER:

First Advantage admits the allegations in Paragraph No. 5 of Plaintiff’s Amended

Complaint.

COMPLAINT ¶ 6:

Defendant Advanced Reporting, LLC (“Advanced Reporting”) is a consumer reporting

agency as defined by the FCRA, 15 U.S.C. § 1681a(f).

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 6 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 7:

On or about January 13, 2014, Plaintiff applies for housing at River City & Rentals N.W.

(“River City”). River City requests Plaintiff’s consumer report from Background Investigations.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 7 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 8:

Background Investigations prepares and issues Plaintiff’s consumer report to River City

that includes inaccurate information, in violation of the FCRA, § 1681e(b).

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 3 of 18
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ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 8 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 9:

Background Investigations reported to River City that Plaintiff was a felon and had been

convicted of Third Degree Sale of Narcotics, Fourth Degree Sale of Drugs, Domestic Assault,

Fourth Degree Burglary and Disorderly Conduct. This is false. Plaintiff is not a felon, nor has

she ever been convicted of any crime.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 9 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 10:

On or about January 15, 2014, River City denies Plaintiff for housing. River City told

Plaintiff she was denied because of the criminal conviction information, including a felony that

Background Investigations reported on her consumer report to River City. Plaintiff tells River

City that the convictions are not hers.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 10 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 11:

On or about January 15, 2014, Plaintiff calls Background Investigations and tells them

about their reporting of criminal conviction information to River City that does not pertain to her.

Background Investigations tells Plaintiff that her consumer report contains the crimes and

convictions that were reported to River City. Plaintiff notifies Background Investigations that she

disputes the accuracy of this information. Background Investigations does not comply with the

requirements of the FCRA, § 168li(a), including failing to conduct a reasonable reinvestigation,

in response to Plaintiff’s dispute. Plaintiff requests her consumer report. Background

Investigations does not provide Plaintiff with her consumer report, in violation of the FCRA, §

1681g(a).

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 4 of 18
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ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 11 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 12:

On or about January 24, 2014, Plaintiff calls River City and tells them that the

convictions reported by Background Investigations are not hers. River City calls Background

Investigations, who tells River City that the criminal information matched Plaintiff.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 12 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 13:

In June 2015, Plaintiff again notifies Background Investigations that she disputes the

accuracy of the information it is reporting on her. Plaintiff also requests her consumer report.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 13 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 14:

Background Investigations sends Plaintiff a copy of her consumer report. Background

Investigations does not include a Summary of Rights with Plaintiff’s consumer report in

violation of the FCRA, § 1681g(c)(2).

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 14 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 15:

In or around February 2015, CoreLogic prepares and issues Plaintiff’s consumer report

that includes inaccurate information, in violation of the FCRA, § 1681e(b).

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 5 of 18
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ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 15 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 16:

CoreLogic reports that Plaintiff is a felon and reports scores of criminal convictions that

do not belong to Plaintiff, including Second Degree Sale of Drugs (three grams or morecocaine), Second Degree sale of Schedule 1 or 2 Narcotic, LSD, Third Degree Sale of Narcotics,

Fourth Degree Sale of Drugs, Domestic Assault-Intentionally Inflict, Fifth Degree Assault –

Fear/Inflict/Attempt Harm, Fourth Degree Burglary, Disorderly Conduct, Obstructing Legal

Process, Interference with Emergency Call, Criminal Damage to Property, Petty Theft, Giving

Peace Officer False Name, and Driving after Suspension. This is false. Plaintiff is not a felon and

has never been convicted of any crime.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 16 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 17:

In or around March 2015, First Advantage prepares and issues Plaintiff’s consumer report

that includes inaccurate information, in violation of the FCRA, § 1681e(b).

ANSWER:

First Advantage denies the allegations in Paragraph No. 17 of Plaintiff’s Amended

Complaint.

COMPLAINT ¶ 18:

First Advantage reports multiple criminal convictions and an address that do not belong

to Plaintiff, including Third Degree Sale of Narcotics, Fourth Degree Sale of Drugs, Fourth

Degree Burglary, Domestic Assault, Giving Peace Office False Name and Obstructing Legal

Process. First Advantage also reports that Plaintiff was serving a “Standard Supervised Release,

Conditional Release” for a conviction of a drug offense. This is false. Plaintiff has never been

convicted of a crime and she has never served a supervised or conditional release.

ANSWER:

First Advantage denies the allegations in Paragraph No. 18 of Plaintiff’s Amended

Complaint.

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 6 of 18
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COMPLAINT ¶ 19:

On or about January 27, 2016, Plaintiff applies to enroll her stepson at the Columbia

County Christian School. As part of the application process, the Columbia County Christian

School requests Plaintiff’s consumer report from Advanced Reporting.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 19 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 20:

Advanced Reporting prepares and issues Plaintiff’s consumer report to the Columbia

County Christian School that includes inaccurate information, in violation of the FCRA, §

1681e(b).

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 20 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 21:

Advanced Reporting reported to the Columbia County Christian School that Plaintiff was

a felon and had been convicted of multiple crimes, including Third Degree Sale of Narcotics,

Fourth Degree Sale of Drugs, Domestic Assault, Fourth Degree Burglary, Disorderly Conduct,

Giving a False Name to a Peace Officer, Obstructing Legal Process, Theft, Disorderly Conduct –

Brawling or Fighting, and Traffic Offenses. Advanced Reporting also reported to the Columbia

County Christian School that there was an active warrant issued for Plaintiff’s arrest. This is

false. Plaintiff is not a felon, she has never been convicted of any crime, and there is no active

warrant for her arrest.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 21 of Plaintiff’s Amended Complaint.

FIRST CLAIM FOR RELIEF

(against Background Investigations)

(Negligent Noncompliance with the FCRA)

COMPLAINT ¶ 22:

Plaintiff realleges and incorporates paragraphs 1 through 21.

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 7 of 18
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ANSWER:

First Advantage restates its answers to Paragraph Nos. 1 through 21 of Plaintiff’s

Amended Complaint as its answer to Paragraph No. 22 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 23:

Background Investigations negligently failed to comply with the requirements of the

FCRA.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 23 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 24:

As a result of Background Investigations’ failure to comply with the requirements of the

FCRA, Plaintiff has suffered and continues to suffer, actual damages, including economic loss,

denial of housing, damage to reputation, emotional distress and interference with Plaintiff’s

normal and usual activities for which Plaintiff seeks damages in an amount to be determined by

the jury.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 24 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 25:

Plaintiff requests attorney fees pursuant to 15 U.S.C. § 1681o(a).

ANSWER:

First Advantage admits the allegations in Paragraph No. 25 of Plaintiff’s Amended

Complaint.

SECOND CLAIM FOR RELIEF

(against Background Investigations)

(Willful Noncompliance with the FCRA)

COMPLAINT ¶ 26:

Plaintiff realleges and incorporates paragraphs 1 through 21.

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 8 of 18
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ANSWER:

First Advantage restates its answers to Paragraph Nos. 1 through 21 of Plaintiff’s

Amended Complaint as its answer to Paragraph No. 26 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 27:

Background Investigations willfully failed to comply with the requirements of the FCRA.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 27 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 28:

As a result of Background Investigations’ failure to comply with the requirements of the

FCRA, Plaintiff has suffered and continues to suffer, actual damages, including economic loss,

denial of housing, damage to reputation, emotional distress and interference with Plaintiff’s

normal and usual activities for which Plaintiff seeks damages in an amount to be determined by

the jury. Plaintiff also seeks punitive damages in an amount to be determined by the jury.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 28 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 29:

Plaintiff requests attorney fees pursuant to 15 U.S.C. § 1681n(a).

ANSWER:

First Advantage admits the allegations in Paragraph No. 29 of Plaintiff’s Amended

Complaint.

THIRD CLAIM FOR RELIEF

(against CoreLogic)

(Negligent Noncompliance with the FCRA)

COMPLAINT ¶ 30:

Plaintiff realleges and incorporates paragraphs 1 through 21.

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 9 of 18
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ANSWER:

First Advantage restates its answers to Paragraph Nos. 1 through 21 of Plaintiff’s

Amended Complaint as its answer to Paragraph No. 30 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 31:

CoreLogic negligently failed to comply with the requirements of the FCRA.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 31 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 32:

As a result of CoreLogic’s failure to comply with the requirements of the FCRA, Plaintiff

has suffered and continues to suffer, actual damages, including economic loss, emotional distress

and interference with Plaintiff’s normal and usual activities for which Plaintiff seeks damages in

an amount to be determined by the jury.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 32 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 33:

Plaintiff requests attorney fees pursuant to 15 U.S.C. § 1681o(a).

ANSWER:

First Advantage admits the allegations in Paragraph No. 33 of Plaintiff’s Amended

Complaint.

FOURTH CLAIM FOR RELIEF

(against CoreLogic)

(Willful Noncompliance with the FCRA)

COMPLAINT ¶ 34:

Plaintiff realleges and incorporates paragraphs 1 through 21.

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 10 of 18
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ANSWER:

First Advantage restates its answers to Paragraph Nos. 1 through 21 of Plaintiff’s

Amended Complaint as its answer to Paragraph No. 34 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 35:

CoreLogic willfully failed to comply with the requirements of the FCRA.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 35 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 36:

As a result of CoreLogic’s failure to comply with the requirements of the FCRA, Plaintiff

has suffered and continues to suffer, actual damages, including economic loss, emotional distress

and interference with Plaintiff’s normal and usual activities for which Plaintiff seeks damages in

an amount to be determined by the jury. Plaintiff also seeks punitive damages in an amount to be

determined by the jury.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 36 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 37:

Plaintiff requests attorney fees pursuant to 15 U.S.C. § 168 ln(a).

ANSWER:

First Advantage admits the allegations in Paragraph No. 37 of Plaintiff’s Amended

Complaint.

FIFTH CLAIM FOR RELIEF

(against First Advantage)

(Negligent Noncompliance with the FCRA)

COMPLAINT ¶ 38:

Plaintiff realleges and incorporates paragraphs 1 through 21.

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 11 of 18
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ANSWER:

First Advantage restates its answers to Paragraph Nos. 1 through 21 of Plaintiff’s

Amended Complaint as its answer to Paragraph No. 38 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 39:

First Advantage negligently failed to comply with the requirements of the FCRA.

ANSWER:

First Advantage denies the allegations in Paragraph No. 39 of Plaintiff’s Amended

Complaint.

COMPLAINT ¶ 40:

As a result of First Advantage’s failure to comply with the requirements of the FCRA,

Plaintiff has suffered and continues to suffer, actual damages, including economic loss,

emotional distress and interference with Plaintiff’s normal and usual activities for which Plaintiff

seeks damages in an amount to be determined by the jury.

ANSWER:

First Advantage denies the allegations in Paragraph No. 40 of Plaintiff’s Amended

Complaint.

COMPLAINT ¶ 41:

Plaintiff requests attorney fees pursuant to 15 U.S.C. § 1681o(a).

ANSWER:

First Advantage admits that Plaintiff requests attorneys’ fees, but denies that she is

entitled to any relief whatsoever from First Advantage.

SIXTH CLAIM FOR RELIEF

(against First Advantage)

(Willful Noncompliance with the FCRA)

COMPLAINT ¶ 42:

Plaintiff realleges and incorporates paragraphs 1 through 21.

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 12 of 18
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ANSWER:

First Advantage restates its answers to Paragraph Nos. 1 through 21 of Plaintiff’s

Amended Complaint as its answer to Paragraph No. 42 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 43:

First Advantage willfully failed to comply with the requirements of the FCRA.

ANSWER:

First Advantage denies the allegations in Paragraph No. 43 of Plaintiff’s Amended

Complaint.

COMPLAINT ¶ 44:

As a result of First Advantage’s failure to comply with the requirements of the FCRA,

Plaintiff has suffered and continues to suffer, actual damages, including economic loss,

emotional distress and interference with Plaintiff’s normal and usual activities for which Plaintiff

seeks damages in an amount to be determined by the jury. Plaintiff also seeks punitive damages

in an amount to be determined by the jury.

ANSWER:

First Advantage denies the allegations in Paragraph No. 44 of Plaintiff’s Amended

Complaint.

COMPLAINT ¶ 45:

Plaintiff requests attorney fees pursuant to 15 U.S.C. § 1681n(a).

ANSWER:

First Advantage admits that Plaintiff requests attorneys’ fees, but denies that she is

entitled to any relief whatsoever from First Advantage.

SEVENTH CLAIM FOR RELIEF

(against Advanced Reporting)

(Negligent Noncompliance with the FCRA)

COMPLAINT ¶ 46:

Plaintiff realleges and incorporates paragraphs 1 through 21.

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 13 of 18
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ANSWER:

First Advantage restates its answers to Paragraph Nos. 1 through 21 of Plaintiff’s

Amended Complaint as its answer to Paragraph No. 46 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 47:

Advanced Reporting negligently failed to comply with the requirements of the FCRA.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 47 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 48:

As a result of Advanced Reporting’s failure to comply with the requirements of the

FCRA, Plaintiff has suffered and continues to suffer, actual damages, including economic loss,

damage to reputation, emotional distress and interference with Plaintiff’s normal and usual

activities for which Plaintiff seeks damages in an amount to be determined by the jury.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 48 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 49:

Plaintiff requests attorney fees pursuant to 15 U.S.C. § 1681o(a).

ANSWER:

First Advantage admits the allegations in Paragraph No. 49 of Plaintiff’s Amended

Complaint.

EIGHTH CLAIM FOR RELIEF

(against Advanced Reporting)

(Willful Noncompliance with the FCRA)

COMPLAINT ¶ 50:

Plaintiff realleges and incorporates paragraphs 1 through 21.

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 14 of 18
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ANSWER:

First Advantage restates its answers to Paragraph Nos. 1 through 21 of Plaintiff’s

Amended Complaint as its answer to Paragraph No. 50 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 51:

Advanced Reporting willfully failed to comply with the requirements of the FCRA.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 51 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 52:

As a result of Advanced Reporting’s failure to comply with the requirements of the

FCRA, Plaintiff has suffered and continues to suffer, actual damages, including economic loss,

damage to reputation, emotional distress and interference with Plaintiff’s normal and usual

activities for which Plaintiff seeks damages in an amount to be determined by the jury. Plaintiff

also seeks punitive damages in an amount to be determined by the jury.

ANSWER:

First Advantage lacks knowledge or information sufficient to form a belief as to the truth

of the allegations in Paragraph No. 52 of Plaintiff’s Amended Complaint.

COMPLAINT ¶ 53:

Plaintiff requests attorney fees pursuant to 15 U.S.C. § 1681n(a). Plaintiff requests a jury

trial on all claims.

ANSWER:

First Advantage admits the allegations in Paragraph No. 53 of Plaintiff’s Amended

Complaint.

AFFIRMATIVE DEFENSES

FIRST DEFENSE

To the extent Plaintiff’s claims are based on acts that occurred prior to the expiration of

any applicable statute of limitations period, such claims are time-barred.

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 15 of 18
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SECOND DEFENSE

Plaintiff is not entitled to punitive damages because First Advantage’s reading of its

obligations under the FCRA is objectively reasonable.

THIRD DEFENSE

To the extent Plaintiff failed to mitigate her damages, her recovery, if any, should be

reduced accordingly.

WHEREFORE, First Advantage respectfully requests that the Court dismiss with

prejudice Plaintiff’s Amended Complaint in its entirety and award First Advantage its costs and

any and all other relief this Court deems appropriate.

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 16 of 18
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Date: May 12, 2016

Respectfully submitted,

FIRST ADVANTAGE BACKGROUND

SERVICES CORP.

By: /s/ Megan Poonolly

Andrew M. Altschul, OSB No. 980302

andrew@baaslaw.com

BUCHANAN ANGELI ALTSCHUL

& SULLIVAN LLP

321 SW 4th Avenue, Suite 600

Portland, Oregon 97204

Telephone: (503) 974-5015

Facsimile: (503) 230-0337

Frederick T. Smith (pro hac vice

application to be filed)

Georgia Bar No. 657575

fsmith@seyfarth.com

Megan H. Poonolly (admitted pro hac

vice)

Georgia Bar No. 345633

mpoonolly@seyfarth.com

SEYFARTH SHAW LLP

1075 Peachtree Street, N.E.

Suite 2500

Atlanta, Georgia 30309-3958

Telephone: (404) 885-1500

Facsimile: (404) 892-7056

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 17 of 18
CERTIFICATE OF SERVICE

I certify that on May 12, 2016, I electronically filed DEFENDANT FIRST

ADVANTAGE BACKGROUND SERVICES CORP.’S ANSWER TO PLAINTIFF’S

AMENDED COMPLAINT with the Clerk of Court using the CM/ECF system, which will

automatically send electronic notification of such filing to the following attorneys of record:

Robert S. Sola

Shidon B. Aflatooni

ROBERT S. SOLA, P.C.

1500 SW First Avenue, Suite 800

Portland, Oregon 97201

Counsel for Plaintiff Samantha Johnson

Ronald I. Raether , Jr.

TROUTMAN SANDERS

5 Park Plaza, Suite 1400

Irvine, CA 92614-2545

Counsel for CoreLogic Credco, LLC

Christopher J. Kayser

LARKINS VACURA LLP

121 SW Morrison St., Suite 700

Portland, OR 97204

Counsel for CoreLogic Credco, LLC

Kimberley Hanks McGair

FARLEIGH WADA WITT, PC

121 SW Morrison Street, Suite 600

Portland, OR 97204-3136

Counsel for Advanced Reporting, LLC.

/s/ Megan Poonolly_________________

Counsel for First Advantage Background Services Corp.

Case 3:16-cv-00051-BR Document 28 Filed 05/12/16 Page 18 of 18