COMPLAINT 1

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David J. McGlothlin, Esq. (SBN 026059)

david@southwestlitigation.com

Hyde & Swigart

2633 E. Indian School Road, Ste. 460

Phoenix, AZ 85016

Telephone: (602) 265-3332

Facsimile: (602) 230-4482 Ryan L. McBride, Esq. (SBN 032001)

ryan@kazlg.com

Kazerouni Law Group, APC

2633 E. Indian School Road, Ste. 460

Phoenix, AZ 85016

Telephone: (800) 400-6808

Facsimile: (800) 520-5523

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

INTRODUCTION

1. The United States Congress has found the banking system is dependent upon 

fair and accurate credit reporting. Inaccurate credit reports directly impair 

the efficiency of the banking system, and unfair credit reporting methods 

Carol A. Fadale, 

 Plaintiff, 

 v. 

Experian Information Solutions, 

Inc., Arizona Federal Credit 

Union, Citibank, N.A., and 

Synchrony Bank,

 Defendants.

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Case No.:

COMPLAINT FOR DAMAGES 

PURSUANT TO THE FAIR CREDIT 

REPORTING ACT, 15 U.S.C. § 1681, ET SEQ.

JURY TRIAL DEMANDED

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 1 of 17
COMPLAINT 2

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undermine the public confidence, which is essential to the continued 

functioning of the banking system. Congress enacted the Fair Credit 

Reporting Act, 15 U.S.C. § 1681 et seq. (“FCRA”), to insure fair and 

accurate reporting, promote efficiency in the banking system, and protect 

consumer privacy. The FCRA seeks to ensure consumer reporting agencies 

exercise their grave responsibilities with fairness, impartiality, and a respect 

for the consumer’s right to privacy because consumer reporting agencies 

have assumed such a vital role in assembling and evaluating consumer credit 

and other information on consumers. The FCRA also imposes duties on the 

sources that provide credit information to credit reporting agencies, called 

“furnishers.”

2. CAROL A. FADALE (“Plaintiff”), by Plaintiff’s attorneys, brings this 

action to challenge the actions of EXPERIAN INFORMATION 

SERVICES, LLC (“Experian”), ARIZONA FEDERAL CREDIT UNION

(“AFCU”), CITIBANK, N.A. (“Citibank”), and SYNCHRONY BANK

(“Synchrony”) (or jointly as “Defendants”) with regard to erroneous reports 

of derogatory and negative credit information made by Defendants to 

national reporting agencies, and for failure of Defendants to properly 

investigate, and this conduct caused Plaintiff damages. 

3. Plaintiff makes these allegations on information and belief, with the 

exception of those allegations that pertain to Plaintiff, or to Plaintiff’s 

counsel, which Plaintiff alleges on personal knowledge.

4. While many violations are described below with specificity, this Complaint 

alleges violations of the statute cited in its entirety. 

5. Unless otherwise stated, all the conduct engaged in by Defendants took 

place in Arizona.

6. Any violations by Defendants were knowing, willful, and intentional, and 

Defendant did not maintain procedures reasonably adapted to avoid any such 

violation.

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 2 of 17
COMPLAINT 3

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7. Unless otherwise indicated, the use of Defendants’ name in this Complaint 

includes all agents, employees, officers, members, directors, heirs, 

successors, assigns, principals, trustees, sureties, subrogees, representatives, 

and insurers of Defendants’ named.

JURISDICTION AND VENUE

8. This Court has federal question jurisdiction because this case arises out of 

violation of federal law. 15 U.S.C. §1681 et seq.; 28 U.S.C. §1331; 

Jurisdiction arises for Plaintiff’s supplemental state claims under 28 U.S.C. 

§ 1367.

9. This action arises out of Defendants’ violations of the Fair Credit Reporting 

Act, 15 U.S.C. §§ 1681-1681(x) (“FCRA”).

10. Venue is proper in the United States District Court for the District of 

Arizona pursuant to 28 U.S.C. § 1391(b) because Plaintiff is a resident of 

Maricopa County, the State of Arizona and Defendants are subject to 

personal jurisdiction in the County of Maricopa, State of Arizona as they 

conduct business there, and the conduct giving rise to this action occurred in 

Arizona. 28 U.S.C. § 1391(b)(2). 

PARTIES

11. Plaintiff is a natural person residing in the County of Maricopa, State of 

Arizona. In addition, Plaintiff is a “consumer” as that term is defined by 15 

U.S.C. § 1681a(c). 

12. Defendant Experian is a corporation doing business in the State of Arizona.

13. Defendant AFCU is a credit union doing business in the State of Arizona. 

14. Defendant Citibank is a bank doing business in the State of Arizona.

15. Defendant Synchrony is a bank doing business in the State of Arizona. 

16. Defendants AFCU, Citibank, and Synchrony are furnishers of information as 

contemplated by 15 U.S.C. § 1681s-2(b) that regularly and in the ordinary 

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 3 of 17
COMPLAINT 4

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course of business furnish information to a consumer credit reporting 

agency. 

17. Defendant Experian is a national credit reporting agency, doing business in 

Arizona, with a principal place of business in Ohio.

GENERAL ALLEGATIONS

18. At all times relevant, Plaintiff was an individual residing within the State of 

Arizona.

19. At all times relevant, Defendants conducted business in the State of Arizona.

20. On or about August 17, 2012, Plaintiff filed for Bankruptcy in the United 

States Bankruptcy Court for the District of Arizona. Plaintiff’s case was 

assigned Case Number 2:12-bk-18542-SSC (the “Bankruptcy”).

21. The obligations (“Debt”) to each defendant were scheduled in the 

Bankruptcy and Defendants, the Creditors, received notice of the 

Bankruptcy.

22. On or about January 10, 2013, Plaintiff received a Bankruptcy discharge.

23. None of the Defendants filed any proceedings to declare their Debt “non 

dischargeable” pursuant to 11 U.S.C. § 523 et seq. 

24. Defendants also did not request relief from the “automatic stay” codified at 

11 U.S.C. §362 et seq. while the Plaintiff’s Bankruptcy was pending to 

pursue the Plaintiff on any personal liability for any of the underlying Debts.

25. Accordingly, the Debt to each defendant was discharged through the 

Bankruptcy.

26. Further, while the automatic stay was in effect during the Bankruptcy, it was 

illegal for any of the Defendants to report any post-Bankruptcy derogatory 

collection information.

27. Defendants’ attempt to collect upon their respective Debt by reporting postBankruptcy derogatory information was therefore false or inaccurate and 

prohibited by the automatic stay or Discharge. 

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 4 of 17
COMPLAINT 5

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28. Plaintiff subsequently learned that each of the named Defendants reported 

post-Bankruptcy derogatory credit information regarding the obligations on 

Plaintiff’s credit reports, thereby causing erroneous and negative credit 

information in Plaintiff’s credit files.

Arizona Federal Credit Union Misreported Credit Information

29. In an Experian credit report dated July 15, 2015, AFCU reported the 

following inaccurate, derogatory information:

• Account No. 3033XXXX: Post-bankruptcy information for the 

following dates: November 2012 (Charge Off).

30. AFCU should not have reported derogatory information on Plaintiff’s 

account after August 17, 2012, because Plaintiff filed for Bankruptcy on 

August 17, 2012.

31. On or about July 29, 2015, Plaintiff disputed AFCU’s reported information 

regarding the Debt pursuant to 15 U.S.C. § 1681I(a)(2) by notifying 

Experian, in writing, of the incorrect and inaccurate credit information 

furnished by AFCU.

32. Specifically, Plaintiff sent a letter, certified, return receipt, to Experian (the 

“Experian Dispute Letter”), requesting the above inaccurate and incorrect 

derogatory information be removed as follows:

• Account #3033XXXX: This account was discharged in my 

Bankruptcy which was filed on 08/17/2012 and discharged 

01/10/2013, bearing Case No. 2:12-bk-18542-SSC in the 

District for Arizona. There should be no derogatory reporting 

after the filing date. Specifically, please remove the derogatory 

information for the following post-bankruptcy dates: November 

2012 (Charge Off).

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 5 of 17
COMPLAINT 6

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33. The Experian Dispute Letter further requested that Experian:

• Immediately delete this account and the disputed derogatory 

information from my credit report.

• The discharged debt should be reported with an account balance 

of $0 with a status of “current”.

• Further, there should be no post-bankruptcy activity reported on 

this account. The date of last activity on this account should predate my bankruptcy filing date, 08/17/2012, since a default on this 

account occurred no later than the Bankruptcy filing date.

• Any post-bankruptcy derogatory information should be 

immediately deleted from [Plaintiff’s] report.

• If [Experian] do[es] not immediately delete this from 

[Plaintiff’s] credit report, please include a 100-word statement in 

my credit report of all of the disputed information contained in this 

letter regarding this account. 

34. Upon information and belief, Experian timely notified AFCU of Plaintiff’s 

dispute, but AFCU continued reporting derogatory information.

35. AFCU and Experian were required to conduct a reinvestigation into this

specific account on Plaintiff’s consumer report pursuant to 15 U.S.C. 

§1681i.

36. On or about August 11, 2015, Plaintiff received notification from Experian

that AFCU and Experian received notice of Plaintiff’s dispute pursuant to 15 

U.SC. § 1681i(a)(6), and Defendants verified the account had been updated. 

37. Surprisingly, rather than remove all the derogatory information from 

Plaintiff’s report, AFCU and Experian simply left derogatory information on 

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 6 of 17
COMPLAINT 7

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Plaintiff’s report. Specifically, AFCU and Experian reported the following

inaccurate, derogatory information:

• Account No. 3033XXXX: Post-bankruptcy information for the 

following dates: November 2012 (Charge Off).

38. AFCU and Experian, upon receipt of Plaintiff’s dispute, failed to conduct an 

investigation with respect to the disputed information as required by 15 

U.SC. § 1681s-2(b)(1)(A).

39. AFCU and Experian failed to review all relevant information provided by 

Plaintiff in the dispute to Experian, as required by and in violation of 15 

U.SC. § 1681s-2(b)(1)(B).

40. Due to AFCU and Experian’s failure to investigate, they each further failed 

to correct and update Plaintiff’s information as required by 15 U.S.C. § 

1681s-2(b)(1)(E), thereby causing continued reporting of inaccurate 

information in violation of 15 U.S.C. § 1681-s(2)(b)(1)(C).

41. Plaintiff’s continued efforts to correct AFCU and Experian’s erroneous and 

negative reporting of the Debt by communicating Plaintiff’s dispute with 

AFCU and Experian were fruitless.

42. AFCU and Experian’s continued inaccurate and negative reporting of the 

Debt in light of its knowledge of the actual error was willful.

43. AFCU and Experian’s inaccurate and negative reporting damaged Plaintiff’s 

creditworthiness.

44. By inaccurately reporting account information relating to the Debt after 

notice and confirmation of its errors, AFCU and Experian failed to take the 

appropriate measures as determined in 15 U.S.C. §§ 1681-s(2)(b)(1)(D) and 

(E).

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Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 7 of 17
COMPLAINT 8

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Citibank, N.A. Misreported Credit Information

45. In an Experian credit report dated July 15, 2015, CBNA reported the 

following inaccurate, derogatory information:

• Account #504994852605....: Post-bankruptcy information for 

the following dates: September 2012-December 2012 (Account 

90 days past due).

46. CBNA should not have reported derogatory information on Plaintiff’s 

account after August 17, 2012, because Plaintiff filed for Bankruptcy on 

August 17, 2012.

47. On or about July 29, 2015, Plaintiff disputed CBNA’s reported information 

regarding the Debt pursuant to 15 U.S.C. § 1681I(a)(2) by notifying 

Experian, in writing, of the incorrect and inaccurate credit information 

furnished by CBNA. 

48. Specifically, Plaintiff sent a letter, certified, return receipt, to Experian (the 

“Experian Dispute Letter”), requesting the above inaccurate and incorrect 

derogatory information be removed as follows:

• This account was discharged in my Bankruptcy which was filed 

on 08/17/2012 and discharged 01/10/2013, bearing Case No. 

2:12-bk-18542-SSC in the District for Arizona. There should 

be no derogatory reporting after the filing date. Specifically, 

please remove the derogatory information for the following 

post-bankruptcy dates: September 2012-December 2012 

(Account 90 days past due).

49. The Experian Dispute Letter further requested that Experian:

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 8 of 17
COMPLAINT 9

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• Immediately delete this account and the disputed derogatory 

information from [Plaintiff’s] credit report.

• The discharged debt should be reported with an account balance 

of $0 with a status of “current”.

• Further, there should be no post-bankruptcy activity reported on 

this account. The date of last activity on this account should predate my bankruptcy filing date, 08/17/2012, since a default on this 

account occurred no later than the Bankruptcy filing date.

• Any post-bankruptcy derogatory information should be 

immediately deleted from [Plaintiff’s] report.

• If [Experian] do[es] not immediately delete this from 

[Plaintiff’s] credit report, please include a 100-word statement in 

my credit report of all of the disputed information contained in this 

letter regarding this account. 

50. Upon information and belief, Experian timely notified CBNA of Plaintiff’s 

dispute, but CBNA continued reporting derogatory information.

51. CBNA and Experian were required to conduct a reinvestigation into this 

specific account on Plaintiff’s consumer report pursuant to 15 U.S.C. 

§1681i.

52. On or about August 11, 2015, Plaintiff received notification from Experian

that CBNA and Experian received notice of Plaintiff’s dispute pursuant to 15 

U.SC. § 1681i(a)(6), and Defendants verified the account had been updated. 

53. Surprisingly, rather than remove all the derogatory information from 

Plaintiff’s report, CBNA and Experian simply left derogatory information on 

Plaintiff’s report. Specifically, CBNA and Experian reported the following

inaccurate, derogatory information:

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 9 of 17
COMPLAINT 10

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• Account #708019682XXXX: Post-bankruptcy information for 

the following dates: September 2012-December 2012 (Account 

90 days past due).

54. CBNA and Experian, upon receipt of Plaintiff’s dispute, failed to conduct an 

investigation with respect to the disputed information as required by 15 

U.S.C. § 1681s-2(b)(1)(A).

55. CBNA and Experian failed to review all relevant information provided by 

Plaintiff in the dispute to Experian, as required by and in violation of 15 

U.S.C. § 1681s-2(b)(1)(B).

56. Due to CBNA and Experian’s failure to investigate, they each further failed 

to correct and update Plaintiff’s information as required by 15 U.S.C. § 

1681s-2(b)(1)(E), thereby causing continued reporting of inaccurate 

information in violation of 15 U.S.C. § 1681-s(2)(b)(1)(C).

57. Plaintiff’s continued efforts to correct CBNA and Experian’s erroneous and 

negative reporting of the Debt by communicating Plaintiff’s dispute with 

CBNA and Experian were fruitless.

58. CBNA and Experian’s continued inaccurate and negative reporting of the 

Debt in light of its knowledge of the actual error was willful.

59. CBNA and Experian’s inaccurate and negative reporting damaged Plaintiff’s 

creditworthiness.

60. By inaccurately reporting account information relating to the Debt after 

notice and confirmation of its errors, CBNA and Experian failed to take the 

appropriate measures as determined in 15 U.S.C. §§ 1681-s(2)(b)(1)(D) and 

(E).

Synchrony Bank Misreported Credit Information

61. In an Experian credit report dated July 15, 2015, Synchrony reported the 

following inaccurate, derogatory information:

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 10 of 17
COMPLAINT 11

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• Account #601919360029....: Post-bankruptcy information for 

the following dates: October 2012 (Account 180 days past 

due); November 2012-December 2012 (Charge Off); In the 

“Account History” section, the account is listed as: 180 days 

past due as of Oct 2012; 150 days past due as of Oct 2012; 120 

days past due as of Sep 2012.

• Account #600889227046....: October 2012-December 2012 

(Charge Off); In the “Account History” section account is 

listed as:120 days past due as of Oct 2012; 90 days past due as 

of Sep 2012.

• Account #771411041297....: October 2012 (Account 150 days 

past due); November 2012-December 2012 (Charge Off); In 

the “Account History” section account is listed as: 150 days 

past due as of Oct 2012; 120 days past due as of Oct 2012; 90 

days past due as of Sep 2012.

62. Synchrony should not have reported derogatory information on Plaintiff’s 

account after August 17, 2012, because Plaintiff filed for Bankruptcy on 

August 17, 2012.

63. On or about July 29, 2015, Plaintiff disputed Synchrony’s reported 

information regarding the Debt pursuant to 15 U.S.C. § 1681I(a)(2) by 

notifying Experian, in writing, of the incorrect and inaccurate credit 

information furnished by Synchrony. 

64. Specifically, Plaintiff sent a letter, certified, return receipt, to Experian (the 

“Experian Dispute Letter”), requesting the above inaccurate and incorrect 

derogatory information be removed as follows:

• Account #601919360029....: This This account was discharged 

in my Bankruptcy which was filed on 08/17/2012 and 

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 11 of 17
COMPLAINT 12

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discharged 01/10/2013, bearing Case No. 2:12-bk-18542-SSC 

in the District for Arizona. There should be no derogatory 

reporting after the filing date. Specifically, please remove the 

derogatory information for the following post-bankruptcy dates: 

October 2012 (Account 180 days past due); November 2012-

December 2012 (Charge Off); In the “Account History” 

section, the account is listed as:

o 180 days past due as of Oct 2012

o 150 days past due as of Oct 2012

o 120 days past due as of Sep 2012

o These are all inaccurate statements as to this account.

• Account #600889227046....: This account was discharged in 

my Bankruptcy which was filed on 08/17/2012 and discharged 

01/10/2013, bearing Case No. 2:12-bk-18542-SSC in the 

District for Arizona. There should be no derogatory reporting 

after the filing date. Specifically, please remove the derogatory 

information for the following post- bankruptcy dates: October 

2012-December 2012 (Charge Off); In the “Account History” 

section account is listed as:

o 120 days past due as of Oct 2012

o 90 days past due as of Sep 2012

o These are inaccurate statements as to this account.

• Account #771411041297....: This account was discharged in 

my Bankruptcy which was filed on 08/17/2012 and discharged 

01/10/2013, bearing Case No. 2:12-bk-18542-SSC in the 

District for Arizona. There should be no derogatory reporting 

after the filing date. Specifically, please remove the derogatory 

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 12 of 17
COMPLAINT 13

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information for the following post-bankruptcy dates: October 

2012 (Account 150 days past due); November 2012-December 

2012 (Charge Off); In the “Account History” section account is 

listed as:

o 150 days past due as of Oct 2012

o 120 days past due as of Oct 2012

o 90 days past due as of Sep 2012

o These are all inaccurate statements as to this account.

65. The Experian Dispute Letter further requested that Experian:

• Immediately delete this account and the disputed derogatory 

information from [Plaintiff’s] credit report.

• The discharged debt should be reported with an account balance 

of $0 with a status of “current”.

• Further, there should be no post-bankruptcy activity reported on 

this account. The date of last activity on this account should predate my bankruptcy filing date, 08/17/2012, since a default on this 

account occurred no later than the Bankruptcy filing date.

• Any post-bankruptcy derogatory information should be 

immediately deleted from [Plaintiff’s] report.

• If [Experian] do[es] not immediately delete this from 

[Plaintiff’s] credit report, please include a 100-word statement in 

my credit report of all of the disputed information contained in this 

letter regarding this account. 

66. Upon information and belief, Experian timely notified Synchrony of 

Plaintiff’s dispute, but Synchrony continued reporting derogatory 

information.

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 13 of 17
COMPLAINT 14

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67. Synchrony and Experian were required to conduct a reinvestigation into this 

specific account on Plaintiff’s consumer report pursuant to 15 U.S.C. 

§1681i.

68. On or about August 11, 2015, Plaintiff received notification from Experian 

that Synchrony and Experian received notice of Plaintiff’s dispute pursuant 

to 15 U.SC. § 1681i(a)(6), and Defendants verified the three accounts had 

been updated. 

69. Surprisingly, rather than remove all the derogatory information from 

Plaintiff’s report, Synchrony and Experian simply left derogatory 

information on Plaintiff’s report. Specifically, Synchrony and Experian

reported the following inaccurate, derogatory information:

• Account #601919360029....: Post-bankruptcy information for 

the following dates: October 2012 (Account 180 days past due); 

November 2012-December 2012 (Charge Off).

• Account #600889227046....: Post-bankruptcy information for 

the following dates: October 2012-December 2012 (Charge 

Off).

• Account #771411041297....: Post-bankruptcy information for 

the following dates: October 2012 (Account 150 days past due); 

November 2012-December 2012 (Charge Off). 

70. Synchrony and Experian, upon receipt of Plaintiff’s dispute, failed to 

conduct an investigation with respect to the disputed information as required 

by 15 U.S.C. § 1681s-2(b)(1)(A).

71. Synchrony and Experian failed to review all relevant information provided 

by Plaintiff in the dispute to Experian, as required by and in violation of 15 

U.S.C. § 1681s-2(b)(1)(B).

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 14 of 17
COMPLAINT 15

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72. Due to Synchrony and Experian’s failure to investigate, they each further 

failed to correct and update Plaintiff’s information as required by 15 U.S.C. 

§ 1681s-2(b)(1)(E), thereby causing continued reporting of inaccurate 

information in violation of 15 U.S.C. § 1681-s(2)(b)(1)(C).

73. Plaintiff’s continued efforts to correct Synchrony and Experian’s erroneous 

and negative reporting of the Debt by communicating Plaintiff’s dispute 

with Synchrony and Experian were fruitless.

74. Synchrony and Experian’s continued inaccurate and negative reporting of 

the Debt in light of its knowledge of the actual error was willful.

75. Synchrony and Experian’s inaccurate and negative reporting damaged 

Plaintiff’s creditworthiness.

76. By inaccurately reporting account information relating to the Debt after 

notice and confirmation of its errors, Synchrony and Experian failed to take 

the appropriate measures as determined in 15 U.S.C. §§ 1681-s(2)(b)(1)(D) 

and (E).

FIRST CAUSE OF ACTION

VIOLATION OF THE FAIR CREDIT REPORTING ACT

15 U.S.C. § 1681 ET SEQ. (FCRA)

77. Plaintiff incorporates by reference all of the above paragraphs of this 

Complaint as though fully stated herein.

78. The foregoing acts and omissions constitute numerous and multiple willful, 

reckless or negligent violations of the FCRA, including but not limited to 

each and every one of the above-cited provisions of the FCRA, 15 U.S.C § 

1681.

79. As a result of each and every willful violation of the FCRA, Plaintiff is 

entitled to actual damages as the Court may allow pursuant to 15 U.S.C. § 

1681n(a)(1); statutory damages pursuant to 15 U.S.C. § 1681n(a)(1); 

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 15 of 17
COMPLAINT 16

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punitive damages as the Court may allow pursuant to 15 U.S.C. § 

1681n(a)(2); and reasonable attorney’s fees and costs pursuant to 15 U.S.C. 

§ 1681n(a)(3) from Defendants.

80. As a result of each and every negligent noncompliance of the FCRA, 

Plaintiff is entitled to actual damages as the Court may allow pursuant to 15 

U.S.C. § 1681o(a)(1); and reasonable attorney’s fees and costs pursuant to 

15 U.S.C. § 1681o(a)(2) from Defendants.

PRAYER FOR RELIEF

Plaintiff respectfully requests the Court grant Plaintiff the following relief 

against Defendants:

FIRST CAUSE OF ACTION

VIOLATION OF THE FAIR CREDIT REPORTING ACT

15 U.S.C. § 1681 ET SEQ. (FCRA)

• an award of actual damages pursuant to 15 U.S.C. § 1681n(a)(1);

• award of statutory damages pursuant to 15 U.S.C. § 1681n(a)(1);

• an award of punitive damages as the Court may allow pursuant to 15 

U.S.C. § 1681n(a)(2); 

• award of costs of litigation and reasonable attorney’s fees, pursuant to 15 

U.S.C. § 1681n(a)(3), and 15 U.S.C. § 1681(o)(a)(1) against Defendants 

for each incident of negligent noncompliance of the FCRA; and

• any other relief the Court may deem just and proper.

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Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 16 of 17
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TRIAL BY JURY

81. Pursuant to the seventh amendment to the Constitution of the United States 

of America, Plaintiff is entitled to, and demands, a trial by jury.

Dated: September 16, 2015 Respectfully submitted,

BY: /S/ RYAN L. MCBRIDE______

RYAN L. MCBRIDE, ESQ.

ATTORNEY FOR PLAINTIFF

Case 2:15-cv-01843-GMS Document 1 Filed 09/16/15 Page 17 of 17