Exhibit A 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 1 of 61
11 /1' OCYVY 8121:146 UNTA JUSTICE COURT 

FILED 

2015 DEC I PH 3: 46 

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McCarthy Law. PLC Manr 

4250 N. Drinkwater Blvd 

MCC AR.INI LAW PLC 

tmnineoifvutsx... mu coma. 

Kevin Fallon McCarthy, 011017 

Joon N. Kee, 028152 _ 

4250 North Drinkwater Blvd, Suite 320 

Scottsdale, AZ 85251 

602-456-8900 

ioon.kee (4mccarthylawver.com Attorneys for Plaintiff(s) 

MCDOWELL MOUNTAIN JUSTICE COURT 

MAIUCOPA COUNTY, STATE OF ARIZONA 

18380 NORTH 40TH STREET, PHOENIX, ARIZONA 85032 

MICHELLE MANNING Case No:--C2 0 I 5 2 2 3 5 9 iRg-, 

COMPLAINT FOR VIOLATION OF 

Plaintiff, FAIR CREDIT REPORTING ACT (15 

U.S.C. § 1681 et seq.) 

CITIFINANCIAL INC., EQUIFAX 

INFORMATION SERVICES LLC, 

EXPERIAN INFORMATION SOLUTIONS, 

INC., AND TRANSUNION, LLC, 

Defendants. 

COMES NOW Plaintiff, Michelle Manning ("Plaintiff"), by and through counsel 

undersigned, and for its cause of action against the Defendants above-named alleges as follows: 

1. That Plaintiff is and was at all times hereinafter mentioned a resident of Maricopa 

County, Arizona. 

2. That, on information and belief, Defendant, CITIFINANCIAL, INC., ("CITI") is, 

and at all times relevant hereto was, a corporation registered with the Arizona Corporation 

Commission as a Foreign Corporation doing business in Arizona and has designated the 

following registered statutory agent: CT CORPORATION SYSTEM, 3800 NORTH CENTRAL 

AVENUE SUITE 460, PHOENIX, ARIZONA 85012. 

3. That, on information and belief, Defendant CITI, is, and at all times relevant 

hereto was, regularly doing business in the State of Arizona. 

4. That, on information and belief, Defendant, EQUIFAX INFORMATION 

SERVICES LLC, ("EQUIFAX"), is a credit reporting agency, as defined by 15 U.S.C. § 

v. Citifinancial. INC. etal. 1 COMPLAINT 

V. 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 2 of 61
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McCarthy Law. PLC Manr 

4250 N. Ddnkwater Blvd 

1681a(f), licensed to do business in Arizona and has designated the following registered statutory 

agent: CORPORATION SERVICE COMPANY, 2338 WEST ROYAL PALM ROAD, STE. J, 

PHOENIX, ARIZONA 85021. 

5. That, on information and belief, Defendant, EQUIFAX, is, and at all times 

relevant hereto was, regularly doing business in the State of Arizona. 

6. That, on information and belief, Defendant, EXPERIAN INFORMATION 

SOLUTIONS, INC. (Herein after "Experian") is a credit reporting agency, as defined by 15 

U.S.C. § 1681a(f), licensed to do business in Arizona and has designated the following registered 

statutory agent: CT CORPORATION SYSTEM, 3800 NORTH CENTRAL AVENUE, SUITE 

460, PHOENIX, ARIZONA 85012. 

.7. That, on information and belief, Defendant, Experian, is, and at all times relevant 

hereto was, regularly doing business in the State of Arizona. 

8. That, on information and belief, Defendant, TRANSUNION LLC. 

("Transunion"), is a credit reporting agency, as defined by FCRA § 1681 a(f), licensed to do 

business in Arizona and has designated the following registered statutory agent: PRENTICEHALL CORP SYSTEM, 2338 WEST ROYAL PALM ROAD, STE-J, PHOENIX, AZ 85021. 

9. That, on information and belief, Defendant, TransUnion, is, and at all times 

relevant hereto was, regularly doing business in the State of Arizona. 

10. That the Court has jurisdiction over this action pursuant to 15 U.S.C. § 1681p, the 

Fair Credit Reporting Act ("FCRA") and that personal jurisdiction exists over Defendants as it 

had the necessary minimum contacts with the State of Arizona. 

11. That the Plaintiff is a consumer and victim of inaccurate reporting by Defendants. 

12. That Defendant CITI account ending in 5404 ("Account") was being serviced by a 

debt collection agency, Capital Management Services, LP. Exhibit A. 

13. That on May 19, 2014, Capital Management Services, LP, and Plaintiffs counsel, 

McCarthy Law, PLC, reached an agreement on behalf of their clients to settle Plaintiff's 

Account. Exhibit B. 

14. That Plaintiff completed the payments pursuant to the settlement offer and Capital 

ing v. Citifinancial. INC. etal. 2 COMPLAINT 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 3 of 61
McCarthy Law. PLC 

4250 N. Drinkwater Blvd 

1 Management Services, LP accepted these payments for Account. Exhibit B. 

2 15. That Plaintiff completed the payments pursuant to the settlement offer and Capital 

3 Management Services, LP accepted these payments for Account. Exhibit C. 

4 16. On October 28, 2015, Plaintiff sent written disputes regarding the accuracy of the 

5 derogatory information reported by the Defendant CRAs. Exhibits D - F. 

6 17. That CITI is willfully reporting derogatory and inaccurate information about 

7 Plaintiff to one or more consumer reporting agencies by continuing to report a balance on 

8 Account, as defined by 15 U.S.C. § 1681a. 

9 18. The Defendants, Experian, Equifax, and TransUnion (referred to herein as 

10 "Defendant CRAs") are willfully reporting derogatory and inaccurate information about Plaintiff 

11 to third-parties. 

12 19. The Defendant CRAs have failed to correct the inaccurate reporting of the 

13 Account in violation of 15 U.S.C. § 1681i and to the detriment of the consumer Plaintiff. 

14 Exhibits G - I. 

15 20. That Defendant CRAs, willfiffly failed to maintain reasonable procedures to assure 

16 maximum accuracy of the information contained in Plaintiff's credit report in violation of 15 

17 U.S.C. § 1681e. 

18 21. The foregoing acts and omissions of the Defendants constitute unacceptable 

19 violations of the FCRA. 

20 22. As a result of the foregoing, Plaintiff has suffered damages in an amount to be 

21 shown at trial but not exceeding $10,000.00. 

22 WHEREFORE, Plaintiff seeks a reasonable and fair judgment against defendant for 

23 willful noncompliance of the Fair Credit Reporting Act and seeks his statutory remedies as 

24 defined by 15 U.S.C. § 1681n and demands: 

25 1. Actual damages, pursuant to 15 U.S.C. § 1681n(a)(1)(A), of not less than $100 

26 and not more than $1,000 per violation; 

27 2. Punitive damages, pursuant 15 U.S.C. § 1681n(a)(2), for Defendant's willful 

28 violation; 

Manr ing v. Citifinancial. INC. etal. 3 COMPLAINT 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 4 of 61
3. The costs of instituting this action together with reasonable attorney's fees 

incurred by Plaintiff pursuant to 15 U.S.C. § 1681n(a)(3); and 

4. Any further legal and equitable relief as the court may deem just and proper in the 

circumstances. 

Respectfully submitted thiselay of NVIOYIbtr2015. 

MCCARTHY LAW, PLC 

. Kee, Esq. 

Kevin Fallon McCarthy, Esq. 

Attorneys for Plaintiffs 

Mg v. Citifinancial. INC. etal. 4 COMPLAINT 

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McCarthy Law. PLC Manr 

4250 N. Drinkwater Blvd 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 5 of 61
EXHIBIT A 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 6 of 61
6981/2 SOUTH OGDEN STREET 

BUFFALO, NY 14208-2317 

Relbrence# 089779298 

I 

'111111+611111111111 11111111+111"1101"111"11 1 11'11 

T15 P2****AUTO**ALL FOR AADC 852 

Michelle Manning 

5393 WI-IARRISON CT 

CHANDLER, AZ 85226-1934 

CAPITAL MANAGEMENT SERVICES, LP 

698 1/2 South Ogden Street Buffalo, NY 14206-2317 

Office Hours: M-F 8 a.m. - 10 p.m. ET 

Sat 8 a.m. -4 p.m. ET 

Toll Free: 1-877-218-8319, Fag: (716) 512-6020 

Description: NETWORK PERSONAL LOAN 

Current Creditor: CITIFINANCIAL, INC 

Account #: )00000000003404 

AMOUNT ENCLOSED: 

Balance: $2086.36 

PLEASE DETACH AND RETURN TOP PORTION WITH PAYMENT TO ADDRESS LISTED BELOW 

Dear Michelle Manning: 

. March 08, 2013 

This company has been engaged by CMRNANCIAL, INC to resolve your delinquent debt of $2086.36. Please submit your 

payment and make your check or money order payable to Onemain Financial to the address listed below. 

Unless you notify this office within 30 days after receiving this notice that you dispute the validity of this debt or any portion 

thereof, this office will assume this debt Is valid. If you notify this office In writing within 30 days from receiving this notice that 

you dispute the validity of this debt or any portion thereof, this office will obtain verification of the debt or obtain a copy of a 

judgment and mail you a copy of such judgment or verification. If you request this office in writing within 30 days after 

receiving this notice this office will provide you with the name and address of the original creditor, if different than the current 

creditor. 

Our representatives are trained to offer assistance regarding this obligation. For account inquiries, you may contact Capital . 

Management Services, LP. at 698-1/2-SoaliOlideri Street, lfriffito, NY 14206-2317 or caU 1-877-218-8319 Mon. through Fri. 8 

am to 10 pm ET, Sat 8 am to 4 pm E. Payments and correspondence should be mailed to: Capital Management Services, LP, 

P.O. Box 120, Buffalo, NY 14220-0120. Overnight deliveries should be addressed to: Capital Management Services, LP., 698 1/2 

South Ogden Street, Buffalo, NY 14206-2317. 

This is an attempt to collect a debt; any Information obtained will be used for that purpose. This communication is from a debt 

collector. 

Cepnita-122733.1et 123232 • 01-CMFINANCIA4INC4018132-AZ 6840 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 7 of 61
EXHIBIT B 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 8 of 61
, MAY. 19.2014 11:21AM CAPITAL MANAGEMENT NO. 526 P. 1/3 

Capital Management Service; LP? 

Tel- (14004574220) 

Paz— (116) 512-6020 

Facsimile # 

To: loan Fax: 602-218-4447 

.11M=11, 

From: CMS Date: May 19, 2014 

Ref#: 89779298 Pages: 3 

CI Urgent IZIFor Review D Plume Comment ID Please Reply OPlease Recycle 

Disclaimer "This communication system, (including all hardware, software, and 

peripheral equipment, induding faxes or printouts) is the property of CM81. Use of this . 

communication-systernivestricted to-official CMSI blis-ine—iFs.-CIVISI reserves the tight to 

monitor use of this communication system at any time. Use of this communication system 

constitutes consent to such monitoring. My unauthorized access, use, or modification of 

the communisation system may result in civil liability and/or criminal penalties." 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 9 of 61
, MAY.19.2014 11:21AM CAPITAL MANAGEMENT NO. 526 P. 2/3 

698 A South Ogden St 

Buffalo, NY14206 

Tel: (716) 871-9050 

Fax: (716)512-6046 

Capital Management Services, IP 

May 19, 2014 

Michelle Manning 

5393 W Harrison Court 

Chandler, AZ 85226 

Reference #: 89779292 

Account #0000000000005404 

Description: Network Personal Loan 

Current Creditor: Citifinancial 

Balance: $2086.36 

Dear Michelle Manning: 

Capital Management Services, L.P. has been engaged byCitifmancial, and is authorized to accept less 

than the full balance on the above mentioned account. The settlement offer shall be in the total amount of 

$1043.18, the final payment due on 08/28/14.We are not obligated to renew this offer. 

Installments Amount Due Date 

1 5243.18 5/28/14 

2 $260.00 6/28/14 

3 $260.00 7/28/1 4 

4 $260.00 8/28/14 

Upon clearance of sufficient funds, our records will be updated to reflect that the above account has been 

satisfied. 

Please submit your payment and make your check or money order payable to Citifinanciaho the address 

below or you may call 877-211-5288 for other convenient payment options. Payments should be mailed to: 

Capital Management Services, L.P. P.O. Box 120, Buffalo, NY 14220-0120. Overnight deliveries should be 

addressed to: Capital Management Services, L.P., 698% South Ogden Street, Buffalo, NY 14206-2317. 

Whenever $600.00 or more in principal of a debt is discharged as a result of settling a debt for less than the 

balance owing, the creditor may be required to report the amount of the debt discharged to the Internal 

Revenue Servke on a 1099C form, a copy of which would be mailed to you by the creditor. If you are 

uncertain of the legal or tax consequences, we encourage you to consult your legal or tart advisor. 

This is an attempt to collect a debt; any information obtained • will be used for that purpose. This 

communication is from a debt collector. 

Please see the additional page with this letter that may contain important information. We are required under 

state law to notify consumers of the following rights. This list does not contain a complete list of the rights 

consumers have under state and federal law. 

CMS • VIP OUE 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 10 of 61
s MAY. 19. 2014 11:21AM CAPITAL MANAGEMENT'. NO. 526 P. 3/3 

ADJIMONAL INFORMATION FOR CALIFORNIA RESIDENTS 

The state Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt Collection 

Practices Act require that, except under unusual circumstances, collectors may not contact you 

before 8 a.m. or after 9 p.m. They may not harass you by using threats of violence or arrest or by 

using obscene language. Collectors may not use false or misleading statements or call you at 

.--- • work if they bow or have reason to know that you may not receive personal calls at work. For 

the most part, collectors may not tell another person, other than your attorney or spouse, about 

your debt. Collectors may contact another person to confirm your location or enforce a judgment. 

For more information about debt collection activities, you may contact the Federal Trade 

Commission at 1-877-FTC-HELP or www.ftc_gov. 

• ADDITIONAL INFORMATION FOR COLORADO RES1DENIS 

FOR INFORMATION. ABour THE COLORADO FAIR DEBT COLLECTION PRACTICES 

ACT, SEE WWW.COLORADOATTORNEYGFNERAL.O0V/CA 

A consumer has the right to request in writing that a debt collector or collection agency cease 

further communication with the consumer. A written request to cease communication will not 

prohibit the debt collector or collection agency from taking any other action authorized by law to 

collect the debt. 

. Our in-state office is located at 1776 S Jackson Street, Suite 900, Denver, CO 80210 telephone 

number (303) 753-0945. We suggest that you send all correspondence and payments to our home 

office listed on top of letter. We also suggest that you contact our home office via telephone for 

any verbal inquiries that you may have. 

ADDITIONAL INFORMATION FOR MAS SACHUSETFS RESIDENTS 

NOTICE OF IMPORTANT RIGHTS 

• • YOUHAVE-THE-RIGHT TO-MAKE-A WRITTEN OR ORAL REQUESTTHAT- — 

TELEPHONE CALLS REGARDING YOUR DEBT NOT BE MADE TO YOU AT YOUR 

PLACE OF EMPLOYMENT. ANY SUCH ORAL REQUEST WILL BE VALID FOR ONLY 

TEN DAYS UNLESS YOU PROVIDE WRITTEN CONFIRMATION OF THE REQUEST 

POSTMARKED OR DELIVERED WITHIN SEVEN DAYS OF SUCH REQUEST. YOU 

MAY TERMINATE THIS REQUEST BY WRITING TO THE DEBT COLLECTOR. 

ADDITIONAL INFORMATI2N_FOR MINNESOTA RE IDENT4 

This collection agency is licensed by the Minnesota Department of Commerce. 

ADDiTIONAL INFORMATIONFOR NEW YORK CITY RESIDENTS 

This collection agency is licensed by the New York City Department of Consumer Affairs, 

License No. 1242722. 

ADDITIONAL INFORMATION FOR NORTH CAROLINA RESIDENTS 

This collection agency conducts business in the state of North Carolina under North Carolina 

Department of Insurance Permit No. 4416. • 

ADDITIONAL INFORMATION FOR TENNESSEE RESIDENTS 

This collection agency is licensed by the Collection Service Board of the Deparunent of 

Commerce and Insurance. 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 11 of 61
EXHIBIT C 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 12 of 61
11,1, PO,' Ic/P C0,74C,L A .0/V VAjI 

MMUS MAtiffiNG 

1717 MAIN ST 

DAUM, TX, 75201 

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Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 13 of 61
MI5 COMM 11. Awl WITODUT A ORDEN • MU& MORO= a/80 •ACK011011110.1.V111111111111, • mannuirr imarawit iNe MCA • 1101D •T MOW IV vis 

Global Client Solutions, LLC Custodian 

F80 Michelle M. Manning 

4600 South 126th East Ave, Sidle 116 

Tulsa, O74134 

ay: TWO HUNDRED FOR111-/MREE Nifl 101100 001.LARS 

Combo flank eze.&A /PA 20123414$ 

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Oalles, TX 76201 

32-76/1110 P12970717 

I/1 4,x941* Date: 0511972014 

Amount r• 243.18 

For 09775200 

Reference 69776291 

Manning Moho% 

o The Capital Management Services LP CIS MOS 

ST en 1M South Ogden $treet 

Buffalo, NV US 1420$ 

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Account # Check # Amount Paid Date Sequence # 

201234146 $243.18 05/28/2014 

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Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 14 of 61
Check Image Inquiry Results 

Check # Amount Paid Date Sequence # 

201245750 $260.00 06/24/2014 

Account # 

To The 

'Order 

431 

6 

For: 59778292 

Refeience 89719282 

Manning Michelle 

Capital Management Services LP CM 6404 

698 112 South Ogden Street 

Buffalo. NY US 14208 

Global Client Solutions, U.0 Custodian COM** Bank 

IMO Michelle M. Manning 1717 Main Si 

4290 Gavrn 12901 East Am Sulte 175 W)13/Dallas. TX WU 75201os 

. OM 14134 

32.751110 

Pay IWO HUNDRED OM MD1011100 DOLLARS 

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Date: 06118/2014 

Amount r• 260.00 

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Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 15 of 61
Check Image Inquiry Results 

Paid Date 

07/24/2014 

Check # 

201257433 

Amount 

$260.00 

Account # Sequence # 

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F130 Michelle M. Manning 'N;\ ivir Main 81 

45011 South 129th East Arc Suite 175 '4 Dallas. TX 75201 

Tuba, Ok 74134 

1 Slobs) Client Solutions, LLC Custodian 

Capital Management Services LP 

6981/2 South Ogden Street 

Buffalo, NY US 14208 

32-7011110 

For: 89779293 

Reference 89779292 

Manning Michelle 

CM 5404 

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Pay: TWO HUNDRED mart apao %MOO DOLLARS 

f.To The 

;Order 

P12979719 

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Amount r,260.00 

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Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 16 of 61
TAT • • • • • • • WA/TAO/MN a.tek • ,wIQiIT& rMOUaiN TaananaaaOil ems smug • NOM AT AM O TO VIM 

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F130 illehelio at Manning 

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corned;. Bart 

1717 Main St 

112112% TX 75201 

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0811 112 South Ogden Street 

Buffalo, NY US 14200 

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Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 17 of 61
. SEP. 10. 2015 10:32AM CAPITAL MANAGEMENT NO. 254 P. 1/3 

• Capital Management Services, LP. 

Tel- (1-800-4574220) 

Fax —(716) 512-6020 

Facsimile transmittal 

To: JOAN Fax: 602 218 4447 

From: CMS Date; September 10,2015 

Ref #: 089779298 Pages: 3 

0 Urgent OFor Review 0 Please Comment CI Please Reply °Please Recycle 

Disclaimer: 'This communication system, (including all hardware, software, and 

ppripheral_equipment, including faxes or printouts) is the property of CMS:-Use of this • - 

communication system is restricted to official CMS business. CMS reserves the right to 

monitor use of this communication system at any time. Use of this communication system 

constitutes consent to such monitoring. My unauthorized access, use, or modification of 

the communication system may remit in dvil liability and/or criminal penalties?' 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 18 of 61
• SEP. 10. 2015 10:32AM CAPITAL MANAGEMENT NO. 254 P. 2/3 

698 South Ogden St 

Buffalo, NY 14206 

Tel: (716) 871-9050 

Fax: (716) 512-6046 

Capital Management Services, LP 

hircirELLE MANNING.- 

C/0 ASHLEY TUSBNIAN 

4250 N DRINKWATER BLVD S'TE 320 

SCOTTSDALE, AZ 85251 

September 102 2015 

Reference #: 089779298 

Account #: 3000000000C.X5404 

Description: NETWORK PERSONAL LOAN 

Current Creditor: CITIFINANCIAL, INC 

Balance: 5.00 

Dear MICHELLE MANNING: 

We are in receipt of your payment(s) in the total amount of $280.00 which was received in our office on 

08/22/15 for your account. 

This letter serves as confirmation that as duly authorized representatives of Lai eINANCIAL, INC, 

Capital Management Services, L.P., has accepted this payment as Settled for less than the full balance on 

the above mentioned account, upon clearance of sufficient funds. 

_ 

Whenbirill$600.00 or nioreiiPrin—ciparota*cieht is discharged as a result of settling a debt for less than the 

balance owing, the creditor may be required to report the amount of the debt discharged to the Internal 

Revenue Service on a 1099C form, a copy of which would be mailed to you by the creditor. If you are 

uncertain of the legal or tax consequences, we encourage you to consult your legal or tax advisor. 

This is an attempt to collect a debt; any information obtained will be used for that purpose. This 

communication is from a debt collector. 

Please see the additional page with this letter that may contain important information. We are required under 

state law to notify consumers of the following rights. This list does not contain a complete list of the rights 

consumers have under state and federal law. 

CMS • 051F PD • Cui 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 19 of 61
. SEP. 10. 2015 10:32AM CAPITAL MANAGEMENT NO. 254 P. 3/3 

aDITIONAL Tt&ORMATIONEOR CALIFORNIA RESIDENTS 

The state Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt Collection Practices Act require that, 

except under unusual circumstances, collectors may not contact you before 8 a.m. or after 9 p.m. They may not harass you 

by using threats of violence or arrest or by using obscene language. Collectors may nor use false or misleading statements 

or fall you at work if they know or have reason to know that you may not receive personal calls at work. For the most 

part, collectors may not tell another person, other than your attorney or spouse, about your debt. Collectors may contact 

another person to confirm your location or enforce a judgment. For more information about debt collection activities, you 

may contact the Federal Trade Commission at 1-8774LC-HELP.or iscater.ftc.goz... . . 

ADDITIONALINFORMATION_FOLCOLORADO RESIDENTS 

FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE 

WWW.COLORADOATTORNEYGENERALGOV/CA, 

A consumer has the right to request in writing that a debt collector or collection agency cease further communication with 

the consumer. A written request to cease communication will not prohibit the debt collector or collection agency from 

taking any other action authorized by law to collect the debt. 

Our in-state office is located at 1776 S Jackson Street, Suite 900, Denver, CO 80210 telephone number (303) 753-0945. 

We suggest that you send all correspondence and payments to our home office listed on top of letter. We also suggest that 

you contact our home office via telephone for any verbal inquiries that you may have. 

ADDITIONAL lNFORIV=ION FOR MASSACHUSETTS RESIDENTS 

NOTICE OF IMPORTANT RIGHTS 

YOU HAVE THE RIGHT TO MAKE A WRITTEN OR ORAL REQUEST THAT TELEPHONE CALLS REGARDING 

YOUR DEBT NOT BE MADE TO YOU AT YOUR PLACE OF EMPLOYMENT. ANY SUCH ORAL REQUEST 

WILL BE VALID FOR ONLY TEN DAYS UNLESS YOU PROVIDE WRITTEN CONFIRMATION OF THE 

REQUEST POSTMARKED OR DELIVERED WITHIN SEVEN DAYS OF sPal REQUEST. YOU MAY....... 

TERMINATE THIS REQUEST BY WRITING TO THE -DEBT COLLECTOR. 

A:MITIONAL I INFOMATION_FOR MINNESOTA RESIDENTS 

This collection agency is licensed by the Minnesota Department of Commerce. 

IMPORTANT NOTICES FOR NEW YORK STATE RESIDENTS 

If a creditor or debt collector receives a money judgment against you in court, state and federal laws prevent 

the following types of income from being taken to pay the debt: 

I. Supplemental security income, (SSI); 

2. Social security; 

3. Public assistance (welfare); 

4. Spousal support, maintenance (alimony) or child support; 

5. Unemployment benefits; 

6. Disability benefits; 

7. Workers' compensation benefits; 

8. Public or private pensions; 

9. Veterans' benefits; 

10. Federal student loans, federal student grants, and federal work study funds; and 

11. Ninety percent of your wages or salary earned in the last sixty days. 

ADDITIONAL INFORMATION FOR NEW ORK CITY RESIDENTS 

This collection agency is licensed by the New York City Department of Consumer Affairs, License No. 1242722. 

ADDITIONAL INFOIllvIATION FOR NORTH CAROLINA RESIDENT 

This collection agency conducts business in the stateof North Carolina under North Carolina Department of Insurance 

Permit No. 4416. 

ADDITIONAL INFORMATION TOR TENNESSEP RESIDENTS 

This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance. 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 20 of 61
EXHIBIT D 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 21 of 61
MiChelle M., Manning 

5393 W. Harrison Cmut 

Chandler, AZ 85226 . 

October 28,.2015 

gquifax Information Services, LLC 

PO Box 74N50,'' 

Atlanta, GA 30374 

Name:. hdlleM.Manning 

SocintSecurityl#: 9436 

AOC 0.0.irtb; 

Report date: 10115/11' 

To Whom It May concern, 

I :alb Writing to dispute the:following.information in my fi1e 1 have attached the items I dispute 

on the enclOseci Copy ON* trelliattifitt tettived. 

Tins item Citifinancial account#MIIM.404 is incorrectly reporting a balance owed 

of $1;043.00. This: ii.inacourateasiliis ascount was settled with Capital Management, a , 

collection ag:enCy acting o htfoitibank This account was paid as agreed in August 2014: 

I am requesting that the :Item he tOitettecl t 2fleta iern balance OVed. 

Please. investigate this matter and/correct the disputed item as soon as.possible. 

Sincerely, 

Michelle M. Manning 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 22 of 61
— 1.4Expetian-- 

.MICHEILLE'MMANNING 

1060 . ,..„ 

5393Yittl#R1140N. gr. ckyANDLERAz"85220,1034 

MED MARK 

10.rIzPOP. highways 

Personal-Statement 

This space is reserved for staternerat Of disptdo. For rriptitCansumers, no information appears In this Section. 

Equifax 

JoctiEug MANNING 

;MICHELLE:090E10 

1960 

.5393W HARRISORCT 

,CHANDLEFAZ 96.49 

MFDiAMFFiCAcORP 

tAAOPE.DfliA0 

TrinisUeleit • - - 

_ • • _ - 

k1P9.4,4k:KMANNII!,0: MANNING mIgligugMARIE 

fkiyitittiMiCHEIUM 

1960 

5393 HARRISON CT, VIANN,ER, 

#0000 

SW,PP,F,AftgON1.% 

• 

Profile 

WOO; 

iNtio 10pown AO AKA 

Year of.fiksi! 

Ade/0004 

,Curratt(Einfilbier 

Pt001040,Employer . 

MICHELLE M MANNING 

RePort AS Cifi'lpti mos 

'One 

el 1: EXPetiare 

• • 9 

Personal Information 

Here you will Ind,yoar personal information, IncludlngyOur legaL name(s), year ofhirth, currenty end previous addresses, and cyrrentand.preViousvemPloyers. 

Piisonal information Page 1 of 

•.• • 

Report Summary • Bankruptcies Credit Inquiries • Credit Cards & Loans • Credit Score 

Page 3 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 23 of 61
CITIFINANCIAL 

IVO. • 

. . . Experiarr Equifax • 

'CITIFINANCIAL 

c/- TronnUni0IP 

Account Name CITIFINANCIA 

Potentially Negative Closed AecoliMO 607209182718)090C 607209182718XXXX 

Account Type Personal Loans Cos. Finance, personal 

Balance $1.043.00 $1,043.00 

8009226235 

605 MUNN ROAD 

C/S CARE DEPT 

Past Due 

Date Opened 

Account Status 

No. Payment 

41,043.00 

4/28/2007 

Closed 1; 

$150.00 

$1,043.00 

V28/160 

Closed 

$150.00 

FORT MILL, SC 29715 Payment Status Bad debt & placed for collection & Charged off as bad debt 

skip High Balance $0.00 $7,490.00 

Limit $0.00 $0.00 

Terms M 76M !I 76 Months 

Comments 0 CHARGED OFF ACCO UNT. 

PRINCIPAL DEFERRED / INTEREST 

PAYMENT ONLY 

24/Mo Payment History 

2013 2014 2015 

Month AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUN JUL AUG '" SEP OCT NOV DEC JAN FEB ': MAR APR MAY JUN JUL 

Equifax.CO CO CO CO CO r CO CO CO CO CO CO CO CO CO CO CO CO : CO CO r CO CO CO CO CO 

MICHELLE M MANNING 

Report As Of: 10/15/2015 T I:Experiarr • .. 

Credit Cards, Loans & Other Debt 

Here you will find Specific Information on each acaoiint you opened, Including current status and any past due information. Positive credit Information remains on your 

report Indefinitely. Creditor contact information has been provided in Order to make It -easier Or you to resolve any Issues. 

1, Personal Information Report Summary Bankruptcies Credit Inquiries Credit Cards & Loans Page 12 of 19 Credit Score 

Page 19 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 24 of 61
EXHIBIT E 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 25 of 61
Michelle mans 

5391 W. Harrison Coini 

Chandler, Az 85226. 

,0010b#r 254 2„ 

Zit.fiat' 

l'..47.44M9701 

Allen;TX '7501,3 

Re: . Name: .Michelle M. aiming 

'Social Security 436 

Rate OW* 

Report date: 

To Whom If May 'Concerti, 

I aft .Writing to dispute the following infatmation itymy file.,I have attached the items I dispute 

on thereneloted dopy Of the credit repottlireceiVed. 

'This item Citifinancial. aecount:i011111.11111.1$44 TiSincorrectly'repottinglibalanceOwed • 

ofS1;043:00. This is inaccurate as this account was settled with Capital Management, a 

collection ageney acting on behalf of Citibank. This aecourit was paid as agreed in August 2014. 

1 am requestiug that the item be'Corrected tOltfledt a ern balance owed. 

Please investigate this matter and correct the disputed item as soon as possible. 

Sincerely, 

Michelle M. Manning 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 26 of 61
MICHELLE M MANNING 

Raped AS Cif; 1.0/10/20I 

•4/1.11 

OS %V 

.1" EXPeriang? 

9 

PerS.Onal Information 

'Hera you wit! AarLyour personal Information, including your legal flame(s); year Of bap, tikrrenty•anttptairtousadstresses, and current and preitous employers. 

. eriarr 

MICHELLE M MANNING' 

Equifax 

mickigug:mArokNo, 

40104 POWERS' 

.190 

51:93AHARRISOKVT; 

.CHANDIPiX852162 

M#01,4 AMERICA CORP 

Tronsunion. • - • -1 

Name 

:(AisoKnown.AN ,MA: 

YOarotem0 

Addies**) 

cm0001;0410),* - Previous Employer . 

AZ, asni. 

.MANKINGittcHELMMAXtE 

STAWCIF•ARIp3NA 

OP HARRISON dr. CRANDLEft. 1 

MCX.4.0,4,,MANNING, 

POIBIERS,MicREICE,M 

1960' 

1 

f9„0.0.. „ 

..03.9P:0;r8.ARRISPM.C511 , 

:CHANDLER, 80164934 

MEG MARK 

1440110=0.ifitiW00. 

PersOnallitaferneilt 

Thibra-p4Otft)POlvt0191.--stelen.fen.4 Of dispute. For mOstoonsumers, noiritomuition appears in this tectien, 

I Persona! Information Page 1 of 1 

_ . 

• 

Report Summary Bankruptcies Credit Inquiries Credit Cards & Loans. Credit Score 

Page 3 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 27 of 61
CITIFINANCIAL 

• 

Account Name 

Potentially Negative Closed Account 0 

Account Type 

Balance 

Pelt Due 

Date Opened 

Account Status 

Mo. Payment 

Payment Status 

High Balance 

: .Limit 

Terms 

Comments 

Y ..1;Experian 1 - 

, . 

CITIFINANCIAL 

607209182718 

Personal Loan Comóanies 

$1,043.00 

$1,043.00 

4/1/2007 

Closed 

$0.00 

Charge-off 

$0.00 

$0.00 

76 Months 

8009226235 

300 SAINT PAUL PL 

BALTIMORE, MD 21202 

Equifax Tram:Unto:1S 

24/Mo Payment History 

2013 2014 2015 

Month SEP OCT NOV DEC JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUN JUL AUG 

Experlan CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO 

MICHELLE M MANNING 

Report As Of: 10/15/2015 

• •• • 

•••• 

•• ma r" 

•.... • ••txperiane 

• • • • 

Credit Cards, Loans & Other Debt --- 

_ 

Here you will find specific information on each account you opened, Including current status and any past due information. Positive credit Information remains on your 

report Indefinitely. Creditor contact information bee been provided in order to make it easier for you to resolve any Issues. 

1

.Personal Information Report Summary Bankruptcies Credit Inquiries Credit Cards & Loans Page 4 of 19 Credit Score 

Page 11 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 28 of 61
EXHIBIT F 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 29 of 61
MichelloM, Manning 

5393 W. Hanison Court 

Chandler, AZ 85226 

OcteheiIt, 1015 

Transunion Consumer Relations 

P.O tkiik ;2000 

'Chest0A1;9.6kt2O0.6 

14: MichdWiLanflig 

SOW SgmitYlt ..436 

Datiof Birth: 

ittepocitatet 10115/151 

To WhOtiilt May.COncern, 

.1 an. writing to dispUtellteldllowinginfOrination in my file, I have attached the items I dispute 

on .the.enelOsed eopyof the eroditirepan reetiVed. 

This item Citifinandial account # 404 is incorrectlyrepottiog a'halanCe owed 

of $1iO4.3.60., this is initeetnitte as this was tettled witkcapital.Management, 4 

collection lagency acting on behalf of Citibank This account was paid as agreed in August 2Q14 

I amIrequetting that theltem be correctedle reflect a zerO.balatice owed. 

Please investigate this matter and ,correct the disputed item 4.5,pq-pn as possible, 

Sincerely, 

Michelle M. Manning 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 30 of 61
'a • • 

- • T3Everian-. [quits); 

elPRE44E eANNOO: 

0101W:PC49.440 ‘,.. 

1980 

5395 HARRISON'CTi 

•CHANDLENA2'04116. 

ME.414,AMERICA.CORP 

MAC-PHX;MAG 

TranstkiPft • 

eggEkLEIMIONNING 

!emiNifiggiqNELCENNkit 

pcsykRAMickaicm 

1#00 

.849344aRISON 0, CHANDLER. 

g804-6 

STATE OF *gel* 

•Nam,„ o 

Known As) 

Year.pitiitia 

4;1005104' 

Pffitet.10060t 

erc4.40.14.0.110100 

MICHELLE:1;i MANNING 

1.960 . 

p.393,W.:HotRpoNci, . 

CHANDLER. AZ 85225-1934 

;MED mAfik 

Profile - 

Pe/Venal Statement 

This.spaceir reserved for stoeyrie0t0 61dief40..fOrr MOM con.Sofeern, On infonnation.epoears In . sectiark 

MICHELLE M noisONG 

Ropott As Of:ISMS/41S 

•o 

1 

r 1

° EXperiaile 

• • • • 

Personal information 

Mere you vIIi find fofr personal information, including your legal flame(s), year Of birth,COrrenty end previOns addresses, argl,c_urrent antipre4ious emplOyers. 

Personal information Plgel Of 

• • 

Report Summary Bankruptcies Credit Inquiries .) Credit Cards & Loans Credit Score 

Page 3 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 31 of 61
• 

•gsq• • 

▪ ,,s•Expenan ' • -- • Equifax • • 

OTONANCIAL 

ii 607209182718)000C 

5113;tosbriBeloloans Cos. 

4$.1;p41.pp 

4/28/2007 

ClOted 

$150.00 

Bad debt 8 placed for collection & I 

skip 

6PA .

HA 

$07.00 

$CO.ORO 

MG

. E 

D OFF ACCOUNT. 

PRINCIPAL DEFERRED / INTEREST 

PAYMENT ONLY 

.C111FINANCIAj_. 

8609228235 

605 MUNN ROAD 

C/S CARE DEPT 

FORT MILL, SC 29715 

Potentielly Negati 

Account Name 

ye Closed ACount - AccoUnt TO* 

_Balance 

tt::=VtatplAu—li 

Date Opened 

Account Status 

Mo. Payment 

Payment Status 

High Balance 

Limit 

Teims 

Comments 

24/(io Payment History 

2013 2014 2015 

Month ; AUG1 $EP 1 OCT NOV! DEF JAf4 I FEB IrAR; APR hliky JUL !%t.s.p Set); 06:f NOV! DEC JAN 1 FEB MAR ! ApR I MAY' JUN; JUL • 

I Equffax, CO CO CO 1 CO CO 4 CO ; COI CO ; CO ! CO cc, ; co ; co I co I co co I co co I co; co co co co co 

1 

CITIRNANCIA 

607209182718)000C 

Fine*, Personal 

$1.043.90 

..$1,04310 

4/28/2007 

Closed 

$150.00 

Charged off as bad debt 

57.490.00 

$0.00 

76 Months 

MICHELLE M MANNING 

Report As.01: 10/16/2015 

Credit Cards, Loans Is Other Debt 

Here you willitrid specific information On each Beppu!!! you opened, including current status,and any past .due Infpietatieri, positive credit information remains on your 

report indefiniek:.Creditor ,c9.04t. ihfOrttitillion has been provided in order to It easier for you to resolve any issues. 

1 

Personal Information . Report Summary ; Bankruptcies : Credit Inquiries )Credit aardi,& Loans Page 12 of 19 Credit Score I 

Page 19 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 32 of 61
EXHIBIT G 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 33 of 61
EqUIFA7C 

CREDIT FILE: November 13, 2015 

Confirmation # 5309031466 

Dear Michelle Manning: 

Below are the results of your. reinvestigation request and. as applicable, any revisions to your credit file. If you have 

additional questions regarding the reinvestigated items. please contact the source of that information directly. You 

may also contact Equifax regarding the specific information contained within this letter or report within the next 60 days 

by visiting us at www.investioate.eauifax.comor by calling a Customer Representative at (888) 425-7961 from 9:00am 

to 5:00pm Monday-Friday in your time zone. 

For an added convenience, use one of the below options to start an investigation or check the status of your dispute. 

Please note. when you provide documents. including a letter. to Equifax as part Ice your dispute. the documents may be 

submitted to one or more companies whose information are the subject of your dispute. 

Visit us at www.eouifax.com/CreditReoortAssistanceor Call us at 866-349-6186. 

Thank you for giving Equifax the opportunity to serve you. 

The Results Of Our Reinvestigation 

'Credit Account Information 

(For your security, the last 4 digits of account number(s) have been replaced by *) 

(This section Includes open and closed accounts repotted by credit grantors) 

, 

Account History 1: 30-59 Days Past Due 

2 : 60-89 Days Past Due 

5 :150-179 Days Past Due 

6 : 180 or More Days Past Due 

J : Voluntary Surrender 

K: Repossession Status Code 3: 90-119 Days Past Due G: Collection Account . L : Charge Off 

Descriptions 4 : 120-149 Days Past Due H: Foreclosure 

>>> We have researched the credit account. Account # - 607209182718* The results are: This creditor has 

verified to OUR company that the balance is being reported correctly. This creditor has verified to OUR company that 

the current status is being reported correctly. This creditor has verified to OUR company that the prior paying history is 

being reported correctly. Additional information has been provided from the original source regarding this item. If you 

have additional questions about this item please contact: Citifinancial, 605 Munn Rd E, C/S Care Dept, Fort Mill 

SC 29715-8421 Phone: (800) 922-6235 

( Continued On Next Page) Page 1 of 2 5309031466APPLADM-002077651- 13764- 17056 - 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 34 of 61
- 

E Attn CIS Care Dept Fort Mill SD 29715-8421 : (800) 922-6235 

Account Number Date Opened High Credit Cr $Credit Limit 7Te6nns mDuration Terms Frequency Months Revd Activity Designator 

607209182718* 04/01/2007 $0 Monthly 99 

Creditor Classification 

Items As of Balance Amount Date of Actual Scheduled , Date of 1st Date of Date Maj. Charge Off Deferred Pay Balloon Pay 

Date Reported Amount Past Due Last Paymnt Paymnt Amount Paymnt Amount ; Delinquency Last Activity Del. 1st Rptd Amount Start Date Amount 

11/13/2015 $1.043 $1.043 08/2014 $0 $150 I 08/2012 02/2013 $2.086 $0 

Balloon Date 

Pay Date Closed 

Status - Charge Off; Type of Account - Installment; Type of Loan - Unsecured; Whose Account - Individual Account; ADDITIONAL INFORMATION - ; Charged Off Account; Principal 

Deferred/Interest Payment Only; • 

Account History 

with Status Codes 

08/2015 

L 

07/2015 

L 

06/2015 

L 

05/2015 

L 

04/2015 

L 

03/2015 

L 

02/2015 

L 

01/2015 

L 

12/2014 

L 

01/2014 

: L 

10/2014 

L 

09/2014 

L 

08/2014 

L 

07/2014 

L 

06/2014 

L 

05/2014 

L 

04/2014 

L 

03/2014 

L 

02/2014 

L 

01/2014 

L 

12/2013 

L 

11/2013 10/2013 09/2013 08/2013 07/2013 06/2013 05/2013 04/2013 03/2013 02/2013 01/2013 12/2012 11/2012 10/2012 09/2012 08/2012 

L L L L L L L L L 1 L 6 5 4 3 2 1 

Notice to Consumers 

You may request a description of the procedure used to determine the accuracy, and completeness of the information, including the business name and address of the 

furnisher of information contacted. and if reasonably available the telephone number. 

If the reinvestigation does not resolve your dispute. you have the right to add a statement to your credit file disputing the accuracy or completeness of the information; 

the statement should be brief and may be limited to not more than one hundred words (two hundred words for Maine residents) explaining the nature of your dispute. 

If the reinvestigation results in the deletion of disputed information, or you submit a statement in accordance with the preceding paragraph. you have the right to 

request that we send your revised credit file to any company specifically designated by you that received your credit report in the past six months (twelve months for 

California. Colorado. Maryland. New Jersey and New York residents) for any purpose or in the past two years for employment purposes. 

( End Of Report) Page 2 of 2 5309031466APPLADM-002077651- 13764- 17056 - 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 35 of 61
EXHIBIT H 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 36 of 61
7-iWy i,j

11,tr 

▪ g 

C 5- Los— :r.T.ocm 

• cm 

co 

te, 

; g 

▪ cc cc u, uj 

mg= cd 

22OM'S) §g 

How to read your results 

Deleted - This Item was removed from your credit 

report _ 

Remains - This item was not changed as a result 

of our processing of your dispute 

Updated - A change was made to this item; 

review this report to view the change. If 

ownership of the item was disputed, then it was 

verified as belonging to you 

Processed - This item was either updated or 

deleted; review this report to learn its outcome 

Results 

We have completed the processing of your 

dispute(s). Here are the results: 

Credit items Outcome 

CHASE CARD Updated 

428688003453.... 

Visit experian.comIstatus to check the status of 

your pending disputes at any time 

f d 

• :"! _Lxpertan 

rawri at imIntrt 

Prepared for MICHELLE M MANNING 

Date: November 12, 2018 

Report number 2822-5508-19 

Page 1 of 4 

Dispute Results 

This summary shows the revision(s) made to your 

credit file as a result of our processing of your dispute. 

If you still question an item, then you may want to 

contact the furnisher of the information directly or 

review the original Information in the public record. 

You may also submit additional documents to us 

supporting your claim at experian.com/uploador by 

mall. 

The federal Fair Credit Reporting Act states that you 

may: 

- request a description of how we processed your 

dispute, Including the business name and address of 

any furnisher of information contacted in connection 

with such information and the telephone number if 

reasonably available: 

- add a statement disputing the accuracy or . 

completeness of the information; and 

- request that we send these results to organizations 

that you specifically designate who have requested 

your credit report, which contained the deleted or 

disputed information, within the past two years for 

employment purposes or within six months for any 

other purpose (the past 12 months for residents of 

Colorado, Maryland or New York.) As a word of 

general precaution, the results can contain sensitive 

Information; as such, you will want to give careful 

thought when sharing this information.. 

If you send a request to have your results sent to past 

recipients of your credit report, please designate the 

organization's name and address. In the event an 

organization is not specifically designated, we will 

generally default to sending only to companies that 

have requested your credit information as a result of 

an action you took, such as applying for credit, 

insurance, employment or apartment rental. 

If no Information follows, oursesponse appeared on 

the previous page. 

By law, we cannot disCiosscertain medical Information 

(relating to physical, rental, or behavioral health or 

condition). Although we do not generally collect such 

information, it could appear in the name of a data 

furnisher (I.e. "Cancer Center) that moods your 

payment history to us. If so, those names display on 

your report, but on reports to others, they display only 

as MEDICAL PAYMENT DATA. Consumer statements 

Included on your report at your request that contain 

medical information are disclosed to others. 

0139718540 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 37 of 61
Payment history legend 

Currentftemta of agreement met Es Account 30 days past due 

fi Account 80 days past due sal Account 90 days past due 

-Account 120 days past due 

LI Account 150 days pest due 

D Account 180 days past due 

ism Creditor received deed 

Foreclosure proceedings started 

Ell Foreclosed 

':Volunterity surrendered 

,Repossession 

Paid by creditor 

:El Insurance claim 

fi Claim filed with govenenent 

:11131 Defaulted on conbuct 

.2 

 Collection 

Charge off 

as Closed 

Iowa isgo No data for thle time pored 

111111111111111111111111111111111111111111111111111 

= Prepared fort MICHELLE M MANNING 

Date: Novemlier 12,2015 

Report numbel:V2822-5508-19 

NR. Page 2 of 4 

Experian. e• 

r.4 L. 

Your accounts Mat may e consider negativa 

The most common items in this section are late payments, accounts that have been charged 

off or sent to collection, bankruptcies, liens, and judgments. It also may,contain items that are 

not necessarily negative, but that a potential creditor might want to review more closely, such 

as an account that has been settled or transferred. This information is generally removed 

seven years from the initial missed payment that led to the delinquency. Missed payments 

and most public record items may remain on the credit report for up to seven years, except 

Chapters 7, 11 and 12 bankruptcies, which may remain for up to 10 years. Unpaid tax liens 

may remain for up to 10 years from the filing date, and paid tax liens may remain for up to 

seven years from the filing date. Transferred accounts that have not been past due remain up 

to 10 years after the date the account was transferred. 

Credit items 

Recent balance 

$3,973 as of Nov 

2015 

CHASE CARD Date opened Type Credit limit or 

PO BOX15298 May 2003 Credit card original amount 

WILMINGTON DE 19850 First reported Terms $11,000 

Pliorienumber Feb 2009 Not reported High balance 

(800) 432 3117 Date of statue Monthly $11,578 ' 

Partial account number Sep 2012 payment 

.426688003453:... Not reported 

'Address identifleation numbeiy• 

0164272037 

Responsibility 

Individual 

Status 

Account charged off. $3,973 written off. $3,973 past due as of 

Nov 2015. 

This account is scheduled to continue on record until Jul 2016. 

Comment: 

Account closed at credit grantor's request 

This item was updated from our processing of your dispute in 

Nov2015. 

Payment history 

2015 2014 2013 2012 

NOV OCT SEP AUG JUL JUN MAY APR MAR FEB JAN DEC NOV OCT SEP AUG JUL JUN MAY APR MAR FEB JAN DEC NOV OCT SEP AUG JUL JUN MAY APR MAR FEB JAN DEC NOV OCT SEP AUG JUL JUN. 

1301E111111113111116111111111111111011111111111111111111111111111111111111111111111111111111115111111611161111111165111811111i112116111111810211IIIIMMIla 

2011 2010 2009 

MAY APR MAR FEB JAN DEC Nov OCT SEP AUG JUL JUN MAY APR MAR FES JAN DEC -Nov octimP,S410 JUL JUN MAY MAR FES JAN DEC NOV OCT SEP AUG JUL. JUN MAY APR MAR FEB 

Int::77:3[313=771011121131ER 4,1) „ 

0139718540 . 

.1 01 rtiqt/v pelifWi‘10H• 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 38 of 61
U." 

`r. 

„ 

, 

Prepared fart MICHELLE M MANNING,' 

Date: NoVember111015 

Report nuriter: 21424E08-19 c?- 

,„- 

- End of Report — 

If you disagree with information in your report you may dispute most Information at 

www.experian.com/disputes •-) 

You may also visit www.experian.comto view your report again. 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 39 of 61
_If Imo ill IIum II 11, 

- 

Prepared to6 MICHELLE M MNING 

Date: NOietilier 122i115 

Report nulnlie-E-2822:6508-1 

4.14 

• 

: 

THIS PAGE INTENTIONALLY LEFT BLANK 

' 

•T' ' - • ' 

r's 

A 

!4 

nia718•14.,.) ••;, 

iJL 

,s 

1,-;\ 

1\/ 

.01 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 40 of 61
EXHIBIT I 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 41 of 61
‘;0:1 are Invited to partidpate In a brief survey designed to measureyourisatisfactron with-,431 TransUnlon. f‘' 

of your personal Information or your credit Information will be colledeclihroughthIs online survey. 

We value your feedbackl gj 

http://transunlonmail.perlscopeia.com 

*11332311032-On *** 

P.O. Box 2000 

Chester, PA 19022-2000 

111111111111111111 111111311111 11/13/2015 TransUnion 

PSIZW100200212-1001267-014803394 

1.111111141411111111111119011191$101111111111101111 

MICHELLE M. MANNING 

5393 W HARRISON CT 

CHANDLER, AZ 85226-1934 

. Our investigation-or the dispute you recently-submitted is -now-ciiiiipitte:Trie Teliilffar'e Oita-below. If in item you 

disputed is not In the list of results below, it was either not appearing in your credit file or it already reflected the 

corrected status at the time of investigation. 

If our investigation has not resolved your dispute, you may add a 100-word statement to your report. If you provide a 

consumer statement that contains medical information related to service providers or medical procedures, then you 

expressly consent to TransUnion including this information In every credit report we issue about you. If you wish to obtain 

documentation or written verification concerning your accounts, please contact your creditors directly. 

If there has been a change to your credit history resulting from our investigation, or if you add a consumer statement, you 

may request that TranstInlon send an updated report to those who received your report within the last two years for 

employment purposes, or within the last six months for any other purpose. 

If interested, you may also request a description of how the investigation was conducted along with the business name, 

address and telephone number of the source of information. 

Thank you for helping ensure the accuracy of your credit information. 

For frequently asked questions about your credit report, please visit http://transunion.com/consumerfaqs 

Investigation Results 

ITEM DESCRIPTION RESULTS 

• . . 

CITIFINANCIAL # 607209182718111* NEW INFORMATION BELOW 

605 MUNN RD 

C/5 CARE DEPT 

FORT MILL, SC 29715 

(800) 922-6235 

P 51ZW1-002 00212-100126701M 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 42 of 61
Fite Number: 

Date Issued: 

332311032 

11/13/2015 

rapt 1013 

TransUraioe 

-Begin Credit ReportlAccountlotormatf99 

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yttu toattvhind some of the at (040st Inliomratinfs 11111 could be er DOANE 

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nviVb orilm4141bY wow cnitlimil-:&,yItls$4gie 6tIo001400041 teeth !oPktOpira *avow. tient Ont.!. Some Net nnt all Al These 'Ono tnap be prrse(0 ii 

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• Isla *amide(' 

• 

- - 

a iyiyeytt Accomfes 

#607209182718**** (605 MUNN RD. C/S CARE DEPT. FORT MILL SC 29715, (BOO) 922.6235) 

Responsibility: Individual Account Date Updated: 11/12/2015 

DMeOpeneth -04/28/2007 Baboon $1.043 

Tema" $150 perlibrith. paid Monthly for 

payStatum rgetOff 

AmmuntiVpaz Installment Account Payment Received: $O 76 months 

Loanlype: UNSECURED last Payment Madm 08/28/2014 Date Closed: 02/28/2013 

Nth Balance: $7.490 :Maximum Delinquency 01 120 days In 11/2012 

Past Due: 41,0431 for $778 and In 01/20134 

Remade: DISP INVG COMP-RPT BY GRN1R1 PRNCPL DEIRD/INVIST PYMT ONLY: :UNPAID BALANCE CHARGED OFR 

Estimated moath and veer that this Item wiUbe removed: 07/2019 

1 1012015 0912015 011/2015 0512025 04 21)25 03/2015 02/2025 61/2015 ' 11/2014 

Rating j. [TCI nn 

07/20151 0612015 Ns 12/2ay 

, 10/2014 09/2014 08/2014 , 0712014 06/2014 SAWS 04/2014 412024 040014 ii/201i: - , 12/2016-I 12/2013 

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10/2013 0912023 1 07/2015 ] 06/2013 1 05/2013 I 04/2013 - 0312013 02i2013 01/2013 , 1712012 22022.: 

Ming 

i 100/2013 

I 111111 NMI. -..11.11..._JINI ...__IIII __WM _AIL 1111111 ... ION 

-6072012 05-/t612- .04/201 631201 20/2011 09/201 08120126-7/71711 

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02420 01)2010 12/2000 11)2009 10e000 094000, 03/200007/2009 064000 05/2000 04j200‘ 03/2009 

1: 1441 O D I EP-1 flik:1 fj0 .V. ai l-DX I Lki-J Ciiir 1 aJTLt.. DTI jffil EPT1 

02/2000 011201 

Llif.1 

- End of investigation results - 

To view a free copy of your full, updated credit file, go to our website www.tyansunion.cgm/fullreport 

-End of Credit ReportP 51AV:402 00212400126903108 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 43 of 61
MCCARTHY LAW PLC 

CANDID tONELASAT ION. WISE COUNSEL. 

Kevin Fallon McCarthy, 011017 

Joon Kee, 028152 

4250 North Drinkwater Blvd, Suite 320 

Scottsdale, AZ 85251 - 

602-456-8900 

ioon.keeQmccarthvlawver.com 

Attorneys for Plaintiff(s) 

HcOONVELL tIOUNTAIN 

JUSTICE COURT 

FILED 

1015 DEC - I PM 3: I.5 

McDOWELL MOUNTAIN JUSTICE COURT 

MARICOPA COUNTY, STATE OF ARIZONA - 

18380 NORTH 40TH STREET, PHOENIX, ARIZONA 85032 

MICHELLE MANNING 

Plaintiff, 

V. 

CITIFINANCIAL INC., EQUIFAX 

INFORMATION SERVICES LLC, 

EXPERIAN INFORMATION 

SOLUTIONS, INC., AND TRANSUNION, 

LLC, 

Defendants. 

Case No.: CC 2 0 1 5 2 2 3 5 9 3 

INITIAL DISCOVERY SET TO 

CITIFINANCIAL, INC. 

Plaintiff, MICHELLE MANNING, gives notice of service upon and requests that 

Defendant individually respond to the following interrogatories, requests for production, and 

• / 

requests for admission within sixty (60) days of service 

PREFATORY INSTRUCTIONS TO ERROGATORIES 

The Justice Court Rules of Civil Procedure allow a party to send up to forty (40) 

interrogatories to another party. An interrogatory is a written question that is .sent by a party to 

another party that must be answered in writing and under oath by the party to whom the 

interrogatory is sent. If you do not answer an interrogatory because you object to the 

interrogatory, you must state a reason for your objection. 

Provide your answers in the space directly below each question. If there is not enough 

space for your answer to a particular question, you may continue on a blank page by including 

the question above your answer. After you have completed your response to the interrogatories, 

you must sign on the last page to affirm that you have truthfully answered the questions and that 

you have a good faith basis for any objections that you may have made. You must provide your 

original answers to interrogatories to the party who sent them to you, and you must provide a 

copy to every other party in the lawsuit. 

Your response to these interrogatories is due forty (40) days after they have been served 

on you, unless the interrogatories were served with the summons and complaint, in which case 

Manning v. Citifmancial, INC. etal. 1 DISCOVERY 

CCARTHY LAW, PLC 

250 N. DRINKWATER BLVD 

JITE 320 

:."0TrSDALE. ARIZONA 85251 

D245649960 

• 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 44 of 61
your response is due within sixty (60) days after the date of service, or unless otherwise ordered 

by the court. If you do not answer these interrogatories by the date provided in this notice, the 

party who served them may file a motion asking that the court order you to answer them. If the 

court enters that order, the court may also require you to pay expenses, including attorneys' fees 

incurred 

by the other party in obtaining the order. If you fail to comply with the order, the other party may 

ask the court to impose additional penalties against you, including: that you may not introduce 

evidence of some or all or your claims or defenses in this lawsuit; if you are a plaintiff, that your 

lawsuit be dismissed; or if you are a defendant, that judgment be entered against you by default. 

All information is to be divulged which is in the possession of the individual or corporate 

party, his attorneys, investigators, agents, employees, or other representatives of the named party. 

When an individual interrogatory calls for an answer that involves more than one party, 

each part of the answer should clearly set out so that it is understandable. 

DEFINITIONS 

When the terms "you," "Plaintiff' or "Defendant" are used, they are meant to include 

every individual party and include your agents, employees, your attorneys, your accountants, 

your investigators, anyone else acting on your behalf. Separate answers should be given for each 

person named as the party, if requested. 

When the term "document" is used, it is meant to include every "writing", "recording" and 

"photograph' -as those terms-are defined in Rule 1001;" For each -"dbaitridnt" 

responsive to any request withheld from production by you on the ground of any privilege, please 

state: 

(a) the nature of the document (e.g., letter, memorandum, contract, etc.); 

(b) the author or sender of the document; 

(c) the recipient of the document; 

(d) the date the document was authored, sent, and/or received; and 

(e) the reason such document is allegedly privileged. 

Where the term "contract" is used, it is meant to mean or to include the contract between 

the parties to this action that is the subject of the pleadings. 

Where the terms "claim" or "claims" are used, they are meant to mean or to include a 

demand, cause of action or assertion for something due or believed to be due. 

Where the terms "defense" or "defenses" are used, they are meant to mean or to include 

any justification, excuse, denial or affirmative defense in response to the opposing party's claim. 

Manning v. Citifinancial, INC. etal. 2 DISCOVERY 

CCARTHY LAW. PLC 

250 N. DRINKWATER BLVD 

JITE 320 

7.071SOALE, ARIZONA 85251 

D2-455-8900 

. . • 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 45 of 61
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 

Where the term "negotiation(s)" is used, it is meant to mean or to include conversations, 

discussions, meetings, conferences and other written or verbal exchanges that relate to the 

contract. 

Where the term "Audit Trail" is used, it is meant to mean or include a complete, detailed 

listing of each and every alteration, deletion, inquiry into, modification or other change to the 

credit report or profile as maintained in recorded form, in the broadest sense, by "you". The 

listing should include the identity, address, employer and title of the person(s) taking the action, 

the identity, address, employer and title of the person(s) authorizing the action, a detailed 

explanation of the action taken, the date of the action, the means used to effect such action, the 

location of origin of the action and the reason the action was taken. 

Where the term "data" is used, it is meant to mean or include the physical symbols in the 

broadest sense that represent information, regardless of whether the information is oral, written or 

otherwise recorded. 

"Identify" means that you should state: 

(a) any and all names, legal, trade or assumed; 

(b) all addresses used; and 

(c) all telephone and tele-fax numbers used. 

"Person(s)" means any human being, sole proprietorship, limitetpartnership, partnership, 

association, group of human beings, other legal or de facto entity, or corporation, of whatever 

kind. 

"Personal Identifiers" means a person's name or social security number or other unique 

data which identifies or is associated with a particular "person." 

The term "consumer reporting agency" means any person which, for monetary fees, dues, 

or on a cooperative nonprofit basis, regularly engages in whole or in part in the practice of 

assembling or evaluating consumer credit information or other information on consumers for the 

purpose of furnishing consumer reports to third parties, and which uses any means or facility of 

interstate commerce for the purpose of preparing or furnishing consumer reports. 

NON UNIFORM INTERROGATORIES 

INTERROGATORY NO. 1: Please identify the names, addresses, and telephone numbers of 

all persons who supplied information responsive to these interrogatories. 

ANSWER: 

CCARTHY LAW. PLC 

250 N. DRINKWATER BLVO 

JITE 320 

COTYSDALE. ARIZONA 85251 

D2-4568900 

- 

Manning v. Citifinancial, INC. etal. 3 DISCOVERY 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 46 of 61
INTERROGATORY NO. 2: Please identify the names, addresses, and telephone numbers of 

all persons who have personal knowledge of any of the facts, events, or matters that are alleged in 

Plaintiffs complaint, your answer, anticipated answer and/or defenses thereto and describe and 

explain your understanding of the matters on which the persons named have knowledge. 

ANSWER: 

INTERROGATORY NO. 3: Please identify all correspondence or documents that refer or 

relate to any correspondence or communication between you and any other person relating or 

referring to the facts, acts, events, or matters alleged in Plaintiff's complaint, or your answer, 

anticipated answer and/or defenses thereto. 

ANSWER: 

INTERROGATORY NO. 4: Please identify each person whom you may call as a witness at 

trial including name, address, and telephone number, and the substance of the facts and opinions 

to which the witness may testify. 

ANSWER: 

INTERROGATORY NO. 5: Please list, explain and describe documents known to you or 

believed by you to exist concerning the events described in Plaintiffs complaint or concerning 

any event which is the subject of any defense you have raised to this lawsuit. 

ANSWER: 

Manning v. Citifmancial, INC. etal. 4 DISCOVERY 

CCARTNY LAW, PLC 

250 N. DRINKWATER BLVD 

JITE 320 

ZOTTSDALE, ARIZONA 85251 

D2-4568900 

- 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 47 of 61
INTERROGATORY NO. 6: Please identify each employee or non-employee witness or expert 

witness you believe may have formed any opinion or consulted with you about the facts or basis 

of this lawsuit or any defense or allegation you have raised in this lawsuit. For each such person 

identified, please list each and every lawsuit in which that person has testified by affidavit, 

deposition, trial testimony, or by report furnished to the court or opposing counsel. Please explain 

and describe the nature of each such statement by the person so identified. Please identify the 

lawsuit by complete caption, court name, cause number, and date the affidavit, deposition, trial 

testimony, or report was made, taken or occurred. 

ANSWER: 

INTERROGATORY NO. 7: Please identify all individuals known to you or your attorney who 

are not witnesses, but who you have reason to believe have knowledge pertinent to the events at 

issue as alleged in the pleadings, and provide a brief summary of the facts to which each such 

person could testify. For each person, please state the following: 

a. Please state whether each such person is affiliated with, or related 

to, or employed by any party (or its agents, servants, officers, or 

employees) to this lawsuit; 

b. If any of the persons so listed in response to this interrogatory do 

not fit the characterization in subpart (a) above, please describe the nature 

of their involvement in this lawsuit; 

c) Please explain and describe your understanding of their knowledge 

of such facts. 

ANSWER: 

INTERROGATORY NO. 8: Please state whether any of the individuals listed in the answers to 

the preceding interrogatories have given any statement[s] to you and, if so, please identify the 

Manning v. Citifinancial, INC. etal. 5 DISCOVERY 

°GAMUT LAW, PLC 

250 N. DRINI1WATER BLVD 

JITE 320 

7.0TTSDALE, ARIZONA 85251 

D24568900 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 48 of 61
2 

3 

4 

1 individual giving the statement, identify the individual to whom the statement was given, the date 

of the statement, and whether or not the statement was written or recorded and, if it was written 

or recorded, identify the individual presently in possession of such writing or recording. 

ANSWER: 

5 

6 

7 INTERROGATORY NO. 9: Please list each exhibit which you may attempt to introduce as 

8 evidence at the trial of this case, or which has been used or referred to by any witness, expert or 

9 lay, on your behalf. 

10 ANSWER: 

11 

12 

INTERROGATORY NO. 10: For each paragraph of Plaintiffs complaint which you deny the 

14 allegations, please explain and describe any facts which you believe support each denial. 

ANSWER: 

13. 

15 

16 

17 

21 

18 INTERROGATORY NO. 11: Please explain and describe when, how and under what 

circumstances you archive, retain or capture account data in any file bearing any of Plaintiffs' 

personal identifiers. List the archived data files and reports wherein any personal information 

about Plaintiff or attributed to any of Plaintiffs personal identifiers, including the date such data 

was captured, retained and/or archived, who has possession of those reports, the manner in which 

the reports are maintained, and the retention policy[ies] regarding those reports. This request 

includes your normal data file retention processes. 

ANSWER: 

19 

20 

22 

23 

24 

25 

26 

27 

28 

CCARTHY LAW. PLC 

250 N. DRINKWATER BLVD 

arE 320 

:OrrsoALE, ARIZONA 85251 

324568900 

Manning v. Citifinancial, INC. etal. 6 DISCOVERY 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 49 of 61
INTERROGATORY NO. 12: Please explain and describe when and how you transmit account 

data stored in any file bearing any of Plaintiff's personal identifiers to any Consumer Reporting 

Agency ("CRA"). 

ANSWER: 

INTERROGATORY NO. 13: Please explain and describe any disputes you received from 

Plaintiff or concerning Plaintiff and explain and describe your actions and disposition of your 

actions in connection with each contact or communication. 

ANSWER: 

INTERROGATORY NO. 14: Please explain and describe each Consumer Dispute Verification 

or Automated Consumer Dispute Verification ("CDV" or "ACDV" respectively) communication 

. . . _ . . . . 

or other dispute communication you issued to any furnisher of credit information which pertained 

to Plaintiff or any of his/her personal identifiers. For each such CDV, ACDV or other dispute 

communication, please identify the person reporting such dispute, state the date the dispute was 

received and the date you issued any response, explain and describe the dispute conveyed, and 

fully explain and describe your response[s] on each such occasion. 

ANSWER: 

INTERROGATORY NO. 15: Please list, explain and describe each and every code contained 

in each reinvestigation record and file and retained computer record and screen/file you generated 

and accessed regarding Plaintiff. For each such code, please also explain and describe, in detail, 

the purpose of such code, the content of such action, the duration of such action, and the reason 

you permitted such action or entry. 

ANSWER: 

Manning v. Citifinancial, INC. etal. 7 DISCOVERY 

CCARTHY LAW. PLC 

250 N. DRINKWATER BLVD 

ATE 320 

ZOTTSDALE, ARIZONA 85251 

32.456-8900 

- 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 50 of 61
1 

2 

3 

4 

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.24 

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PREFATORY INSTRUCTIONS TO REQUEST FOR PRODUCTION 

The Justice Court Rules of Civil Procedure allow a party to request from another party up 

to ten (10) documents or items, or up to ten (10) categories of documents or items. If you do not 

produce a document or a category of documents or items because you object to a specific request, 

you must state a reason for your objection. A party may also request to enter on to designated 

land or other property to inspect it, or to take measurements, photographs, or samples. 

A party who produces documents must provide them as they are kept in the usual course 

of business, or they must organize and label them in response to the requests. Electronic 

documents or electronic records must be produced in the format that has been requested or in the 

format that the electronic documents or records are usually kept. 

You must provide your original response to requests under this rule to the party who sent 

them to you, and you must provide a copy to every other party in the lawsuit. Your response to 

requests made under this rule is due forty (40) days after the requests have been served on you, 

unless the requests were served with the summons and complaint, in which case your response is 

due within sixty (60) days after the date of service, or unless otherwise ordered by the court. If 

you do not comply with the requests that have been made in this notice, the party who served 

them may file a motion asking that the court order you to comply. If the court enters that order, 

the court may also require you to pay expenses, including reasonable attorneys' fees, incurred by 

the other party in obtaining the order. Thyou fail to comply with the orde-r,-the thet gaTty ftlay 

ask the court to impose additional penalties against you, including: that you may not introduce 

evidence of some or all or your claims or defenses in this lawsuit; if you are a Plaintiff, that your 

lawsuit be dismissed; or if you are a defendant, that judgment be entered against you by default. 

Each of the above-named parties is to produce for inspection and copying all documents 

in their possession or control or otherwise available to it/them that is/are responsive to the 

requests contained in the numbered paragraphs below. Each of the above-named parties shall 

specify which documents are produced in response to each of the numbered paragraphs. 

If any document herein requested was formerly in the possession, custody, or control of 

each of the above-named parties and has been lost or destroyed, each of the above-named parties 

is requested to submit in lieu of each document a written statement which: 

1. Describes in detail the nature of the document and its contents; AND 

2. Identifies the person who prepared or authored the document . and, if applicable, the 

person(s) to whom the document was sent; AND 

3. Specifies the date on which the document was prepared or transmitted or both; AND 

4. Specifies, if possible the date on which the document was lost or destroyed, and, if 

destroyed, the conditions or the reasons for such destruction and the persons requesting and 

performing the destruction. 

CCARTHY LAW, PLC 

250 N. DRINKWATER BLVD 

JITE 320 

=0/TSOALE, ARIZONA 85251 

D2•45613900 

• 

Manning v. Citifinancial, INC. etal. 8 DISCOVERY 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 51 of 61
If any document otherwise required to be produced by this request is withheld on the 

grounds of privilege or otherwise, you shall identify the document by document control number 

if available, or other sufficient information to identify the document and the reasons for the nondisclosure. 

This request for production of documents is continuing and any document obtained or 

located subsequent to production, which would have been produced, had it been available or its 

existence known at the time is to be supplied forthwith. 

DEFINITIONS 

When the terms "you," "Plaintiff" or "Defendant" are used, they are meant to include 

every individual party and include your agents, employees, your attorneys, your accountants, 

your investigators, anyone else acting on your behalf. Separate answers should be given for each 

person named as the party, if requested. 

When the term "document" is used, it is meant to include every "writing", "recording" and 

"photograph' as those terms are defined in Rule 1001, Ariz.R.Evid. For each "document" 

responsive to any request withheld from production by you on the ground of any privilege, please 

state: 

(a) the nature of the document (e.g., letter, memorandum, contract, etc.); 

(b) the author or sender of the document; 

• (e) the recipient-of the document; - 

(d) the date the document was authored, sent, and/or received; and 

(e) the reason such document is allegedly privileged. 

Where the term "contract" is used, it is meant to mean or to include the contract between 

the parties to this action that is the subject of the pleadings. 

Where the terms "claim" or "claims" are used, they are meant to mean or to include a 

demand, cause of action or assertion for something due or believed to be due. 

Where the terms "defense" or "defenses" are used, they are meant to mean or to include 

any justification, excuse, denial or affirmative defense in response to the opposing party's claim. 

Where the term "negotiation(s)" is used, it is meant to mean or to include conversations, 

discussions, meetings, conferences and other written or verbal exchanges that relate to the 

contract. 

Where the term "Audit Trail" is used, it is meant to mean or include a complete, detailed 

listing of each and every alteration, deletion, inquiry into, modification or other change to the 

credit report or profile as maintained in recorded form, in the broadest sense, by "you". The 

listing should include the identity, address, employer and title of the person(s) taking the action, 

the identity, address, employer and title of the person(s) authorizing the action, a detailed 

Manning v. Citifinancial, INC. etal. 9 DISCOVERY 

CCARTMY LAW. PLC 

250 N. DRINKWATER BLVD 

JITE 320 

orrsoALE. ARIZONA 85251 

32-4568900 

• 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 52 of 61
explanation of the action taken, the date of the action, the means used to effect such action, the 

location of origin of the action and the reason the action was taken. 

Where the term "data" is used, it is meant to mean or include the physical symbols in the 

broadest sense that represent information, regardless of whether the information is oral, written or 

otherwise recorded. 

"Identify" means that you should state: 

(a) any and all names, legal, trade or assumed; AND 

(b) all addresses used; AND 

(c) all telephone and tele-fax numbers used. 

"Person(s)" means any human being, sole proprietorship, limited partnership, partnership, 

association, group of human beings, other legal or de facto entity, or corporation, of whatever 

kind. 

"Personal Identifiers" means a person's name or social security number or other unique 

data which identifies or is associated with a particular "person." 

The term "consumer reporting agency" means any person which, for monetary fees, dues, 

or on a cooperative nonprofit basis, regularly engages in whole or in .part in the practice of 

assembling or evaluating consumer credit information or other information on consumers for the 

purpose of furnishing consumer reports to third parties, and which uses any means or facility of 

interstate commerce for the purpose of preparing or furnishing consumer reports. 

REQUESTS FOR PRODUCTION 

REQUEST NO. 1: Please produce a copy of all documents or computerized records, kept in any 

form or manner, known to you or believed by you to exist concerning any of the events described 

in Plaintiffs Complaint or concerning any of the events which are the subject[s] of any 

allegations, defense[s] or contentions you have raised to this lawsuit or in connection with this 

lawsuit. 

ANSWER: 

REQUEST NO. 2: Please produce a complete and legible copy, transcription and summary of 

any statement[s], in any recorded format, provided to you or your attorneys in connection with 

Manning v. Citifmancial, INC. etal. 10 DISCOVERY 

CCARTHY LAW. PLC 

250 N. DRINKWATER BLVD 

AYE 320 

ZOTTSDALE. ARIZONA 85251 

32456E1900 

• 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 53 of 61
any of the facts, asserted by any person, in this lawsuit and, if the witness produce any tangible 

item, please produce that item for inspection and copying at the time of your responses or 

produce a copy of that item with your responses. 

ANSWER: 

REQUEST NO. 3: 

Please produce a complete and legible copy of each exhibit which you may attempt to introduce 

as evidence at the trial of this case. 

ANSWER: 

REQUEST NO. 4: For each paragraph of Plaintiffs petition for which you deny the allegations, 

please provide a copy of any evidence or proof which you believe may support each denial. 

ANSWER: 

REQUEST NO. 5: Please produce a complete and legible copy of any communications you 

received from Plaintiff and which you sent to Plaintiff. 

ANSWER: 

Manning v. Citifinancial, INC. etal. 11 DISCOVERY 

OCARTI4Y LAW. PLC 

250 N. ORINKWATER BLVD 

JUTE 320 

=OTTECIALE. ARIZONA 85251 

324568900 

• 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 54 of 61
1 

2 

3 

PREFATORY INSTRUCTIONS TO REOUEST FOR ADMISSION 

The Justice Court Rules of Civil Procedure allow a party to send up to twenty-five (25) 

requests for admissions to another party. Each request must contain only one fact or one 

contention to admit or deny. A request may inquire about whether a document is genuine or 

accurate. You must admit or deny each of these requests, unless you object to a request, in which 

case you must state a reason for your objection. You may not object on the basis that you do not 

have knowledge or information concerning the request unless you have first made a reasonable 

inquiry to obtain knowledge or information. 

You must provide your original response to requests under this rule to the party who sent 

them to you, and you must provide a copy to every other party in the lawsuit. Responses to 

requests for admissions are due forty (40) days from the date they are served, unless the requests 

were served with the summons and ,complaint, in which case your response is due within sixty 

(60) days after the date of service, or as ordered by the court. 

If you do not respond to these requests for admissions by the date provided in this notice, 

your failure to respond may be considered as an admission of the requests. 

DEFINITIONS 

When the Terms "576ii," "Plaiiitiff".of ."IY6felidiñ1" àe uied, they are mein to iiiclude 

every individual party and include your agents, employees, your attorneys, your accountants, 

your investigators, anyone else acting on your behalf. Separate answers should be given for each 

person named as the party, if requested. 

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When the term "document" is used, it is meant to include every "writing", "recording" and 

"photograph' as those terms are defined in Rule 1001, Ariz.R.Evid. For each "document" 

responsive to any request withheld from production by you on the ground of any privilege, please 

state: 

(a) the nature of the document (e.g., letter, memorandum, contract, etc.); 

(b) the author or sender of the document; 

(c) the recipient of the document; 

(d) the date the document was authored, sent, and/or received; and 

(e) the reason such document is allegedly privileged. 

Where the term "contract" is used, it is meant to mean or to include the contract between 

the parties to this action that is the subject of the pleadings. 

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CCARTHY LAW. PLC 

250 N. ORINKWATER BLVD 

JITE 320 

ZOTTSDALE. ARIZONA 85251 

D2.4568900 

Manning v. Citifmancial, INC. etal. 12 DISCOVERY 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 55 of 61
Where the terms "claim" or "claims" are used, they are meant to mean or to include a 

demand, cause of action or assertion for something due or believed to be due. 

Where the terms "defense" or "defenses" are used, they are meant to mean or to include 

any justification, excuse, denial or affirmative defense in response to the opposing party's claim. 

Where the term "negotiation(s)" is used, it is meant to mean or to include conversations, 

discussions, meetings, conferences and other written or verbal exchanges that relate to the 

contract. 

Where the term "Audit Trail" is used, it is meant to mean or include a complete, detailed 

listing of each and every alteration, deletion, inquiry into, modification or other change to the 

credit report or profile as maintained in recorded form, in the broadest sense, by "you". The 

listing should include the identity, address, employer and title of the person(s) taking the action, 

the identity, address, employer and title of the person(s) authorizing the action, a detailed 

explanation of the action taken, the date of the action, the means used to effect such action, the 

location of origin of the action arid.the reason the action was taken. 

Where the term "data" is used, it is meant to mean or include the physical symbols in the 

broadest sense that represent information, regardless of whether the information is oral, written or 

otherwise recorded. 

"Identify" means that you should state: 

(a) any and all names, legal, trade or assumed; AND 

(b) all addresses used; AND 

(c) all telephone and tele-fax numbers used. 

"Person(s)" means any human being, sole proprietorship, limited partnership, partnership, 

association, group of human beings, other legal or de facto entity, or corporation, of whatever 

kind. 

"Personal Identifiers" means a person's name or social security number or other unique 

data which identifies or is associated with a particular "person." 

The term "Consumer Reporting Agency" means any person which, for monetary fees, 

dues, or on a cooperative nonprofit basis, regularly engages in whole or in part in the practice of 

assembling or evaluating consumer credit information or other information on consumers for the 

purpose of furnishing consumer reports to third parties, and which uses any means or facility of 

interstate commerce for the purpose of preparing or furnishing consumer reports. 

.REQUESTS FOR ADMISSION 

REQUEST FOR ADMISSION NO. 1: Admit that .you, Defendant, reported to one or more 

Consumer Reporting Agency ("CRA") account information bearing the personal identifier[s] of 

Plaintiff. 

Manning v. Citifmancial, INC. etal. 13 DISCOVERY. 

CCARTHY LAW. PLC 

250 N. DRINKWATER BLVD 

JUTE 320 

ZOTTSOALE. ARIZONA 85251 

D2.4568900 

- . 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 56 of 61
allon McCarthy, Esq. 

Joon N. Kee, Esq. 

Attorney for Plaintiff(s) 

DADMIT ODENY 

REQUEST FOR ADMISSION NO. 2: Admit that you, Defendant, hired Capital Management 

Services, LP to service the Account ending 5404. 

['ADMIT ODENY 

REQUEST FOR ADMISSION NO. 3: Admit that you, Defendant, sold Plaintiff's account 

ending in 5404 to a third party. 

['ADMIT ['DENY 

REQUEST FOR ADMISSION NO. 4: Admit that you, Defendant, no longer own Plaintiff's 

account ending in 5404 to a third party. 

DADMIT [DENY 

REQUEST FOR ADMISSION NO. 5: Admit that you, Defendant, failed to report to one or 

more CRA(s) that Plaintiff's account ending in 5404 was sold to a third party. 

DADMIT []DENY 

REQUEST FOR ADMISSION NO. 6: Admit that you, Defendant, failed to report to one or 

more CRA(s) that Plaintiff's account ending in 5404 was charged off. 

DADMIT []DENY 

REQUEST FOR ADMISSION NO. 7: Admit that you, Defendant, failed to report to one or 

more CRA(s) that Plaintiff's account ending in 5404 has a zero balance. 

['ADMIT ODENY 

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,,4-h 

Respectfully submitted this ,I)V day of 1\\ Dvaytba- 2015. 

MCCARTHY LAW, PLC 

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Manning v. Citifinancial, INC. etal. 14 DISCOVERY 

CCARTHY LAW. PLC 

250 N. DRINKWATER BLVD 

JITE 320 

7..OTTSCIALE. ARIZONA 85251 

32.456.8900 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 57 of 61
MCCARI 11'1 LAW PLC 

.6rnoo CorimetsAnoe. Wm Comm. 

Kevin Fallon McCarthy, 011017 

Joon Kee, 028152 

4250 North Drinkwater Blvd, Suite 320 

Scottsdale, AZ 85251 

602-456-8900 

ioon.keeAmccarthvlawyer.com Attorneys for Plaintiff(s) 

Mr.DOWELL MOUNTAIN* 

JUSTICE COURT 

FILED 

:2015 DEC - I PH 3: till 1 

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5 MCDOWELIAMOUNTAIN JUSTICE COURT 

MARICOPA'COUNTY, STATE OF ARIZONA 

18380 NORTH 40TH STREET, PHOENIX, ARIZONA 85032 

MICHELLE MANNING Case No.; C.S4015223593 

Plaintiff, 

V. SUMMONS 

CITIFINANCIAL INC., EQUIFAX 

INFORMATION SERVICES LLC, EXPERIAN 

INFORMATION SOLUTIONS, INC., AND 

TRANSUNION, LLC, 

Defendants. 

STATE OF ofARIZONA TO: 

CITIFINANCIAL, INC. 

S/A: CT CORPORATION SYSTEM, 

3800 NORTH CENTRAL AVENUE, 

SUITE 460, 

PHOENIX, ARIZONA 85012. 

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EQUIFAX INFORMATION SERVICES LLC, 

S/A: CORPORATION SERVICE COMPANY 

2338 WEST ROYAL PALM ROAD 

STE J 

PHOENIX, ARIZONA 85021 

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EXPERI FORMATION SOLUTIONS, INC. 

S/A: CT CORPORATION SYSTEM 

3800 NORTH CENTRAL AVENUE 

SUITE 460 

PHOENIX, ARZIONA 85012 

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McCarthy Law. PLC 

4250 N. Drinkwater Blvd 

Suite 320 

Scottsdale. Arizona 85251 

602-456-8900 

www.McCarihyLawyer.com 

Manning v. Citifinancial. INC. etal. 1 Summons 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 58 of 61
TRANSUNION, LLC 

S/A: PRENTICE-HALL CORP SYSTEM 

2338 WEST ROYAL PALM ROAD 

STE J 

PHOENIX, ARIZONA 85021 

THE STATE OF ARIZONA TO THE ABOVE-NAMED DEFENDANT(S): 

1. YOU ARE SUMMONED to respond to this complaint by filing a written ANSWER with 

this Court and by paying the required fee. If you cannot afford to pay the required fee, you may 

request that the Court either waive or defer the fee. 

2. If you were served with this summons in the State of Arizona, the Court must receive 

your answer within twenty (20) calendar days from the date you were served. If you were served 

outside the State of Arizona, the Court must receive your answer within thirty (30) calendar days 

from the date you were served. If the last day is a Saturday, Sunday, or legal holiday, you will 

have until the next working day to file your answer. When calculating time, do not count the day 

you were served with the summons. 

3 Your answer Mitit be in writing. 

(a) You may obtain an answer form from this Court. 

(b) You may also obtain an answer form from the Form section of the Maricopa County 

Justice Courts website at http://justicecourts.maricopa.gov. • 

4. Provide a copy of your answer to the Plaintiff(s) or to the Plaintiffs attorney in 

accordance with JCRCP Rule 120. 

5. IF YOU FAIL TO FILE A WRITTEN ANSWER WITH THIS COURT WITHIN 

THE TIME INDICATED ABOVE, A DEFAULT JUDGMENT MAY BE ENTERED 

AGAINST YOU. 

The name and address of Plaintiff's attorney is: 

Kevin Fallon McCarthy, Esq. 

Joon Kee, Esq. 

McCARTHY LAW PLC 

4250 North Drinlcwater Boulevard, #320 

Scottsdale, Arizona 85251 

Manning v. Citifinancial. INC. etal. 2 Summons 

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McCarthy Law. PLC 

4250 N. Drinkwater Blvd 

Suite 320 

Scottsdale. Arizona 85251 

602-456-8900 

www.McCarthylawyer.com 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 59 of 61
SIGNED AND SEALED this date: / CO0 -70 

, • ov 1HE p&N,s 

By: /NA Z iZ 

DiplutYrtreick 

G`CO` 

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DEC 0 1 2015 

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McCarthy Law. PLC 

4250 N. Drinkwater Blvd 

Suite 320 

Scottsdale. Arizona 85251 

802-456-8900 

www.McCarthyLawyer.com 

Manning v. Citifinancial. INC. et al. 3 Summons 

Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 60 of 61
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NOTICE TO THE DEFENDANT: A LAWSUIT HAS BEEN FILED AGAINST YOU IN 

I JUSTICE COURTS 

You have rights and responsibilities in this lawsuit. Read this notice carefully. 

3 1. In a justice court lawsuit, individuals have a right to represent themselves, or they may hire an attorney 

to represent them. A family member or a friend may not represent someone in justice court unless the 

family member or friend is an attorney. A corporation has a right to be represented by an officer of the 

corporation, and a limited liability company ("LLC") may be represented by a managing member. A 

corporation or an LLC may also be represented by an attorney. If you represent yourself, you have the 

responsibility to properly complete your court papers and to file them when they are due. The clerks and 

staff at the court are not allowed to give you legal advice. If you would like legal advice, you may ask the 

court for the name and phone number of a local lawyer referral service, the local bar association, or a legal 

aid organization. 

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2. You have a responsibility to follow the Justice Court Rules of Civil Procedure ("JCRCP") that apply in 

9 your lawsuit. The rules are available in many public libraries, at the courthouse, and online at the Court 

Rules page of the Arizona Judicial Branch website, at http://www.azcourts.govi, under the "AZ Supreme 

Court" tab. 

11 3. A "plaintiff' is someone who files a lawsuit against a "defendant." You must file an answer or other 

12 

response to the plaintiff's complaint in writing and within twenty (20) days from the date you were served 

with the summons and complaint (or thirty (30) days if you were served out-of-state.) If you do not file an 

answer within this time, the plaintiff may ask the court to enter a "default" and a "default judgment" 

13 against you. Your answer must state your defenses to the lawsuit. Answer forms are available at the 

courthouse, on the Maricopa County Justice Court website at http://justicecourts.maricopa.govi, and on 

14 the Self-Service Center of the Arizona Judicial. Branch website at http://www.azcourts.gov/ under the 

"Public Services" tab. You may also prepare your answer on a plain sheet of paper, but your answer must 15 include the court location, the case number and the names of the parties. You must provide to the plaintiff 

a copy of any document that you file with the court, including your answer. 

17 4. You may bring a claim against the plaintiff if you have one. When you file your answer or written 

response with the court, you may also file your "counterclaim" against the plaintiff. 

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McCarthy Law. PLC 

4250 N. Drinkwater Blvd 

Suite 320 

Scottsdale. Arizona 85251 

602-4564900 

www.McCarthyLawyer.com 

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5. You must pay a filing fee to the court when you file your answer. If you cannot afford to pay a filing 

19 fee, you may apply to the court for a fee waiver or deferral, but you must still file your answer on time. 

20 6. You may contact the plaintiff or the plaintiff's attorney and try to reach an agreement to settle the 

lawsuit. However, until an agreement is reached you must still file your answer and participate in the 

lawsuit. During the lawsuit, the court may require the parties to discuss settlement. 

22 7. Within forty (40) days after your answer has been filed, you and the plaintiff are required to provide a 

disclosure statement to each other. The disclosure statement provides information about witnesses and 

exhibits that will be used in the lawsuit. A party may also learn more about the other side's case through 

discovery. Read the Justice Court Rules of Civil Procedure for more information about disclosure 

statements and discovery. 

25 8. The court will notify you of all hearing dates and trial dates. You must appear at the time and place 

specified in each notice. If you fail to appear at a trial or a hearing, the court may enter a judgment against 

you. To assure that you receive these notices, you must keep the court informed, in writing, of your 

current address and telephone number until the lawsuit is over. 

Manning v. Citifinancial. INC. etal. 4 Summons 

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Case 2:16-cv-00049-DKD Document 1-1 Filed 01/08/16 Page 61 of 61