1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1

TRINETTE G. KENT (State Bar No. 025180)

KENT LAW OFFICES

10645 North Tatum Blvd., Suite 200-192

Phoenix, AZ 85028 

Telephone: (480) 247-9644

Facsimile: (480) 717-4781

E-mail: tkent@kentlawpc.com

Attorneys for Plaintiff,

Erin Brown

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

Erin Brown,

Plaintiff,

vs.

Experian Information Solutions, Inc., 

an Ohio corporation.

Defendant.

Case No.: 

COMPLAINT

JURY TRIAL DEMAND

Case 2:15-cv-01997-DJH Document 1 Filed 10/06/15 Page 1 of 7
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

2

NOW COMES THE PLAINTIFF, ERIN BROWN , BY AND THROUGH 

COUNSEL, TRINETTE G. KENT, and for her Complaint against the Defendant, 

pleads as follows:

JURISDICTION

1. Jurisdiction of this court arises under 15 U.S.C. §1681p, 15 U.S.C. §1692k(d) 

and 28 U.S.C. §§1331,1337.

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 Buckeye, Maricopa County, Arizona. 

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

PARTIES

5. The Defendant to this lawsuit is Experian Information Solutions, Inc. 

(“Experian”), which is an Ohio company that maintains a registered agent in 

Maricopa County, Arizona.

Case 2:15-cv-01997-DJH Document 1 Filed 10/06/15 Page 2 of 7
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

3

GENERAL ALLEGATIONS

6. On or about February 2 2015, Plaintiff obtained her Experian credit file and 

noticed inaccuracies several trade lines (“Errant Trade Lines”):

7. On or about April 20, 2015, Ms. Brown submitted a letter to Experian,

disputing the Errant Trade Lines.

8. On or about May 8, 2015, Ms. Brown received a letter from Experian, stating 

that it received a suspicious request and determined that it was not sent by Ms. 

Brown. Experian stated that it would not be initiating any disputes based on the 

suspicious correspondence and that it would apply this same policy to any 

future suspicious requests that it received.

9. Experian refused to investigate Ms. Brown’s dispute, in violation of the Fair 

Credit Reporting Act. 

COUNT I

NEGLIGENT VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY EXPERIAN

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

11.Defendant Experian prepared, compiled, issued, assembled, transferred, 

published, and otherwise reproduced consumer reports regarding Ms. Brown as 

that term is defined in 15 USC 1681a.

Case 2:15-cv-01997-DJH Document 1 Filed 10/06/15 Page 3 of 7
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

4

12.Such reports contained information about Ms. Brown that was false, 

misleading, and inaccurate.

13.Experian 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 Ms. Brown, in violation of 15 USC 1681e(b).

14. After receiving Ms. Brown’s consumer dispute to the Errant Trade Lines, 

Experian negligently failed to conduct a reasonable reinvestigation as required 

by 15 U.S.C. 1681i.

15.As a direct and proximate cause of Experian’s negligent failure to perform its 

duties under the FCRA, Ms. Brown has suffered actual damages, mental 

anguish and suffering, humiliation, and embarrassment.

16.Experian is liable to Ms. Brown by reason of its violation of the FCRA in an 

amount to be determined by the trier fact together with her reasonable 

attorneys’ fees pursuant to 15 USC 1681o. 

WHEREFORE, PLAINTIFF PRAYS that this court grant her a judgment 

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

COUNT II

WILLFUL VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY EXPERIAN

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

Case 2:15-cv-01997-DJH Document 1 Filed 10/06/15 Page 4 of 7
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

5

18.Defendant Experian prepared, compiled, issued, assembled, transferred, 

published, and otherwise reproduced consumer reports regarding Ms. Brown as 

that term is defined in 15 USC 1681a.

19.Such reports contained information about Ms. Brown that was false, 

misleading, and inaccurate.

20.Experian 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 Ms. Brown, in violation of 15 USC 1681e(b).

21. After receiving Ms. Brown’s consumer dispute to the Errant Trade Lines, 

Experian willfully failed to conduct a reasonable reinvestigation as required by 

15 U.S.C. 1681i.

22.As a direct and proximate cause of Experian’s willful failure to perform its 

duties under the FCRA, Ms. Brown has suffered actual damages, mental 

anguish and suffering, humiliation, and embarrassment.

23.Experian is liable to Ms. Brown by reason of its violations of the FCRA in an 

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

attorneys’ fees pursuant to 15 USC 1681n. 

Case 2:15-cv-01997-DJH Document 1 Filed 10/06/15 Page 5 of 7
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

6

WHEREFORE, PLAINTIFF PRAYS that this court grant her a judgment 

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

along with costs, interest, and attorneys’ fees. 

JURY DEMAND

Plaintiff hereby demands a trial by Jury. 

DATED: August 5, 2015 KENT LAW OFFICES

By: /s/ Trinette G. Kent 

Trinette G. Kent 

Attorneys for Plaintiff,

Erin Brown

Case 2:15-cv-01997-DJH Document 1 Filed 10/06/15 Page 6 of 7
Case 2:15-cv-01997-DJH Document 1 Filed 10/06/15 Page 7 of 7