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TRINETTE G. KENT (State Bar No. 025180)

KENT LAW OFFICES

3219 E. Camelback Rd #588

Phoenix, AZ 85018

Telephone: (480) 247-9644

Facsimile: (480) 717-4781

E-mail: tkent@kentlawpc.com

Of Counsel to:

Credit Repair Lawyers of America

22142 West Nine Mile Road

Southfield, MI 48033

Telephone: (248) 353-2882

Facsimile: (248) 353-4840

Attorneys for Plaintiff,

Mikel Anderson

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

Mikel Anderson,

Plaintiff,

vs.

Trans Union, LLC,

a Delaware limited liability company,

Equifax Information Services, LLC,

a foreign limited liability company,

Healthcare Collections-I, L.L.C.,

an Arizona limited liability company, and

Toyota Motor Credit Corporation,

a California corporation,

 Defendants.

Case No.: 

COMPLAINT

JURY TRIAL DEMAND

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NOW COMES THE PLAINTIFF, MIKEL ANDERSON, BY AND THROUGH 

COUNSEL, TRINETTE G. KENT, and for his Complaint against the Defendants, 

pleads as follows:

JURISDICTION

1. Jurisdiction of this court arises under 15 U.S.C. §1681p.

2. This is an action brought by a consumer for violation of the Fair Credit Reporting 

Act (15 U.S.C. §1681, et seq. [hereinafter “FCRA”]).

VENUE

3. The transactions and occurrences which give rise to this action occurred in the 

City of Chandler, Maricopa County, Arizona. 

4. Venue is proper in the District of Arizona, Phoenix Division. 

PARTIES

5. Plaintiff is a natural person residing in Chandler, Maricopa County, Arizona.

6. The Defendants to this lawsuit are:

a. Trans Union, LLC (“Trans Union”) is a Delaware limited liability 

company that maintains a registered agent in Maricopa County, Arizona;

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b. Equifax Information Services, LLC (“Equifax”) is a foreign limited 

liability company that maintains a registered agent in Maricopa County, 

Arizona;

c. Healthcare Collections-I, L.L.C. (“Healthcare Collections”) is an Arizona 

limited liability company that maintains a registered agent in Maricopa 

County, Arizona; and

d. Toyota Motor Credit Corporation (“Toyota Motor”) is a California 

corporation that maintains a registered agent in Maricopa County, Arizona.

GENERAL ALLEGATIONS

7. Toyota Motor is reporting its trade line with account number 30682C**** on Mr. 

Anderson’s Equifax and Trans Union credit files with inaccurate disputed 

language. Further, Healthcare Collections is reporting its trade line with account 

number AC5722 with inaccurate disputed language on Mr. Anderson’s Equifax 

credit file. All of the above trade lines are hereinafter referred to as “Errant Trade 

Lines.” Mr. Anderson no longer disputes the Errant Trade Lines.

8. On June 20, 2017, Mr. Anderson obtained his credit file and noticed the Errant 

Trade Lines reporting with disputed language.

9. On or about September 8, 2017, Mr. Anderson submitted a letter to Trans Union, 

Equifax and Experian disputing the Errant Trade Lines. In these dispute letters, 

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Mr. Anderson asked the credit bureaus to remove the disputed language from the 

Errant Trade Lines.

10.Upon information and belief, Trans Union, Equifax and Experian forwarded Mr. 

Anderson’s consumer dispute to Toyota Motor and Healthcare Collections.

11.Mr. Anderson did not receive Trans Union’s investigation results so on or about 

November 28, 2017, he obtained his credit file which showed that Toyota

continued to report the Errant Trade Line with disputed language.

12.Mr. Anderson did not receive Equifax’s investigation results so on or about 

November 28, 2017, he obtained his credit file which showed that Toyota and 

Healthcare Collections continued to report the Errant Trade Lines with disputed 

language.

13.To date, Mr. Anderson hasn’t received Experian’s investigation results.

14.As a direct and proximate cause of the Defendants’ negligent and/or willful 

failure to comply with the Fair Credit Reporting Act, 15 U.S.C. § 1681, et seq., 

Plaintiff has suffered credit and emotional damages. Due to the Defendants’ 

failure to correct the errors in his credit file, Plaintiff has been forced to refrain 

from applying for new credit or more favorable terms on existing credit lines. 

Plaintiff has also experienced undue stress and anxiety due to Defendants’ failure 

to correct the errors in his credit file or improve his financial situation by 

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obtaining new or more favorable credit terms as a result of the Defendants’ 

violations of the FCRA.

COUNT I

NEGLIGENT VIOLATION OF THE FAIR CREDIT REPORTING ACT BY 

TOYOTA MOTOR

15. Plaintiff realleges the above paragraphs as if recited verbatim.

16.After being informed by Trans Union and Equifax of Mr. Anderson’s consumer 

dispute of the disputed language on the Errant Trade Line, Toyota Motor

negligently failed to conduct a proper investigation of Mr. Anderson’s dispute as 

required by 15 USC 1681s-2(b).

17.Toyota Motor negligently failed to review all relevant information available to it 

and provided by Trans Union and Equifax in conducting its reinvestigation as 

required by 15 USC 1681s-2(b), and failed to direct Trans Union and Equifax to 

remove the disputed language from the Errant Trade Line.

18.The Errant Trade Line is inaccurate and creating a misleading impression on Mr. 

Anderson’s consumer credit files with Trans Union and Equifax to which it is 

reporting such trade line.

19.As a direct and proximate cause of Toyota Motor’s negligent failure to perform 

its duties under the FCRA, Mr. Anderson has suffered damages, mental anguish, 

suffering, humiliation, and embarrassment. 

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20.Toyota Motor is liable to Mr. Anderson by reason of its violations of the FCRA 

in an amount to be determined by the trier fact together with reasonable attorneys’ 

fees pursuant to 15 USC 1681o.

21.Mr. Anderson has a private right of action to assert claims against Toyota Motor

arising under 15 USC 1681s-2(b).

WHEREFORE, PLAINTIFF PRAYS that this court grants him a judgment 

against the Defendant Toyota Motor for damages, costs, interest, and attorneys’ fees.

COUNT II

WILLFUL VIOLATION OF THE FAIR CREDIT REPORTING ACT BY 

TOYOTA MOTOR

22. Plaintiff realleges the above paragraphs as if recited verbatim.

23.After being informed by Trans Union and Equifax that Mr. Anderson disputed 

the accuracy of the information it was providing, Toyota Motor willfully failed 

to conduct a proper reinvestigation of Mr. Anderson’s dispute, and willfully 

failed to direct Trans Union and Equifax to remove the disputed language from 

the Errant Trade Line.

24.Toyota Motor willfully failed to review all relevant information available to it 

and provided by Trans Union and Equifax as required by 15 USC 1681s-2(b). 

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25.As a direct and proximate cause of Toyota Motor’s willful failure to perform its

duties under the FCRA, Mr. Anderson has suffered damages, mental anguish, 

suffering, humiliation, and embarrassment. 

26.Toyota Motor is liable to Mr. Anderson for either statutory damages or actual 

damages he has sustained by reason of its violations of the FCRA in an amount 

to be determined by the trier fact, together with an award of punitive damages in 

the amount to be determined by the trier of fact, as well as for reasonable 

attorneys’ fees and he may recover therefore pursuant to 15 USC 1681n.

WHEREFORE, PLAINTIFF PRAYS that this court grants him a judgment 

against the Defendant Toyota Motor for the greater of statutory or actual damages, plus 

punitive damages, along with costs, interest, and attorneys’ fees.

COUNT III

NEGLIGENT VIOLATION OF THE FAIR CREDIT REPORTING ACT BY 

HEALTHCARE COLLECTIONS

27. Plaintiff realleges the above paragraphs as if recited verbatim.

28.After being informed by Equifax of Mr. Anderson’s consumer dispute of the

disputed language on the Errant Trade Line, Healthcare Collections negligently 

failed to conduct a proper investigation of Mr. Anderson’s dispute as required by 

15 USC 1681s-2(b).

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29.Healthcare Collections negligently failed to review all relevant information 

available to it and provided by Equifax in conducting its reinvestigation as 

required by 15 USC 1681s-2(b), and failed to direct Equifax to remove the 

disputed language from the Errant Trade Line.

30.The Errant Trade Line is inaccurate and creating a misleading impression on Mr. 

Anderson’s consumer credit files with Equifax to which it is reporting such trade 

line.

31.As a direct and proximate cause of Healthcare Collections’ negligent failure to 

perform its duties under the FCRA, Mr. Anderson has suffered damages, mental 

anguish, suffering, humiliation, and embarrassment. 

32.Healthcare Collections is liable to Mr. Anderson by reason of its violations of the 

FCRA in an amount to be determined by the trier fact together with reasonable 

attorneys’ fees pursuant to 15 USC 1681o.

33.Mr. Anderson has a private right of action to assert claims against Healthcare 

Collections arising under 15 USC 1681s-2(b).

WHEREFORE, PLAINTIFF PRAYS that this court grants him a judgment 

against the Defendant Healthcare Collections for damages, costs, interest, and 

attorneys’ fees.

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COUNT IV

WILLFUL VIOLATION OF THE FAIR CREDIT REPORTING ACT BY 

HEALTHCARE COLLECTIONS

34. Plaintiff realleges the above paragraphs as if recited verbatim.

35.After being informed by Equifax that Mr. Anderson disputed the accuracy of the 

information it was providing, Healthcare Collections willfully failed to conduct 

a proper reinvestigation of Mr. Anderson’s dispute, and willfully failed to direct 

Equifax to remove the disputed language from the Errant Trade Line.

36.Healthcare Collections willfully failed to review all relevant information 

available to it and provided by Equifax as required by 15 USC 1681s-2(b). 

37.As a direct and proximate cause of Healthcare Collections’ willful failure to 

perform its duties under the FCRA, Mr. Anderson has suffered damages, mental 

anguish, suffering, humiliation, and embarrassment. 

38.Healthcare Collections is liable to Mr. Anderson for either statutory damages or 

actual damages he has sustained by reason of its violations of the FCRA in an 

amount to be determined by the trier fact, together with an award of punitive 

damages in the amount to be determined by the trier of fact, as well as for 

reasonable attorneys’ fees and he may recover therefore pursuant to 15 USC 

1681n.

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WHEREFORE, PLAINTIFF PRAYS that this court grants him a judgment 

against the Defendant Healthcare Collections for the greater of statutory or actual 

damages, plus punitive damages, along with costs, interest, and attorneys’ fees.

COUNT V

NEGLIGENT VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY TRANS UNION

39.Plaintiff realleges the above paragraphs as if recited verbatim.

40.Defendant Trans Union prepared, compiled, issued, assembled, transferred, 

published, and otherwise reproduced consumer reports regarding Mr. Anderson

as that term is defined in 15 USC 1681a.

41.Such reports contained information about Mr. Anderson that was false, 

misleading, and inaccurate.

42.Trans Union negligently failed to maintain and/or follow reasonable procedures 

to assure maximum possible accuracy of the information it reported to one or 

more third parties pertaining to Mr. Anderson, in violation of 15 USC 1681e(b).

43. After receiving Mr. Anderson’s consumer dispute to the Errant Trade Line, 

Trans Union negligently failed to conduct a reasonable reinvestigation as 

required by 15 U.S.C. 1681i.

44.As a direct and proximate cause of Trans Union’s negligent failure to perform its 

duties under the FCRA, Mr. Anderson has suffered actual damages, mental 

anguish and suffering, humiliation, and embarrassment.

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45.Trans Union is liable to Mr. Anderson by reason of its violation of the FCRA in 

an amount to be determined by the trier fact together with his reasonable 

attorneys’ fees pursuant to 15 USC 1681o. 

WHEREFORE, PLAINTIFF PRAYS that this court grants him a judgment 

against Trans Union for actual damages, costs, interest, and attorneys’ fees.

COUNT VI

WILLFUL VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY TRANS UNION

46.Plaintiff realleges the above paragraphs as if recited verbatim.

47.Defendant Trans Union prepared, compiled, issued, assembled, transferred, 

published, and otherwise reproduced consumer reports regarding Mr. Anderson

as that term is defined in 15 USC 1681a.

48.Such reports contained information about Mr. Anderson that was false, 

misleading, and inaccurate.

49.Trans Union willfully failed to maintain and/or follow reasonable procedures to 

assure maximum possible accuracy of the information that it reported to one or 

more third parties pertaining to Mr. Anderson, in violation of 15 USC 1681e(b).

50. After receiving Mr. Anderson’s consumer dispute to the Errant Trade Line, 

Trans Union willfully failed to conduct a reasonable reinvestigation as required 

by 15 U.S.C. 1681i.

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51.As a direct and proximate cause of Trans Union’s willful failure to perform its 

duties under the FCRA, Mr. Anderson has suffered actual damages, mental 

anguish and suffering, humiliation, and embarrassment.

52.Trans Union is liable to Mr. Anderson by reason of its violations of the FCRA in 

an amount to be determined by the trier of fact together with his reasonable 

attorneys’ fees pursuant to 15 USC 1681n. 

WHEREFORE, PLAINTIFF PRAYS that this court grants him a judgment 

against Defendant Trans Union for the greater of statutory or actual damages, plus 

punitive damages along with costs, interest, and reasonable attorneys’ fees.

COUNT VII

NEGLIGENT VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY EQUIFAX

53.Plaintiff realleges the above paragraphs as if recited verbatim.

54.Defendant Equifax prepared, compiled, issued, assembled, transferred, 

published, and otherwise reproduced consumer reports regarding Mr. Anderson 

as that term is defined in 15 USC 1681a.

55.Such reports contained information about Mr. Anderson that was false, 

misleading, and inaccurate.

56.Equifax negligently failed to maintain and/or follow reasonable procedures to 

assure maximum possible accuracy of the information it reported to one or more 

third parties pertaining to Mr. Anderson, in violation of 15 USC 1681e(b).

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57. After receiving Mr. Anderson’s consumer dispute to the Errant Trade Lines,

Equifax negligently failed to conduct a reasonable reinvestigation as required by 

15 U.S.C. 1681i.

58.As a direct and proximate cause of Equifax’s negligent failure to perform its 

duties under the FCRA, Mr. Anderson has suffered actual damages, mental 

anguish and suffering, humiliation, and embarrassment.

59.Equifax is liable to Mr. Anderson by reason of its violation of the FCRA in an 

amount to be determined by the trier fact together with his reasonable attorneys’ 

fees pursuant to 15 USC 1681o. 

WHEREFORE, PLAINTIFF PRAYS that this court grants him a judgment 

against Equifax for actual damages, costs, interest, and attorneys’ fees.

COUNT VIII

WILLFUL VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY EQUIFAX

60.Plaintiff realleges the above paragraphs as if recited verbatim.

61.Defendant Equifax prepared, compiled, issued, assembled, transferred, 

published, and otherwise reproduced consumer reports regarding Mr. Anderson 

as that term is defined in 15 USC 1681a.

62.Such reports contained information about Mr. Anderson that was false, 

misleading, and inaccurate.

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63.Equifax willfully failed to maintain and/or follow reasonable procedures to assure 

maximum possible accuracy of the information that it reported to one or more 

third parties pertaining to Mr. Anderson, in violation of 15 USC 1681e(b).

64. After receiving Mr. Anderson’s consumer dispute to the Errant Trade Lines, 

Equifax willfully failed to conduct a reasonable reinvestigation as required by 15 

U.S.C. 1681i.

65.As a direct and proximate cause of Equifax’s willful failure to perform its duties 

under the FCRA, Mr. Anderson has suffered actual damages, mental anguish and 

suffering, humiliation, and embarrassment.

66.Equifax is liable to Mr. Anderson by reason of its violations of the FCRA in an 

amount to be determined by the trier of fact together with his reasonable 

attorneys’ fees pursuant to 15 USC 1681n. 

WHEREFORE, PLAINTIFF PRAYS that this court grants him a judgment 

against Defendant Equifax for the greater of statutory or actual damages, plus punitive 

damages along with costs, interest, and reasonable attorneys’ fees.

JURY DEMAND

Plaintiff hereby demands a trial by Jury. 

DATED: November 29, 2017

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KENT LAW OFFICES

By: /s/ Trinette G. Kent 

Trinette G. Kent 

Attorneys for Plaintiff,

Mikel Anderson

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