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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

CATHERINE DOUGLAS, individually, 

and on behalf of all others similarly 

situated,

Plaintiff,

v.

THE TRAVELERS INDEMNITY 

COMPANY,

Defendant.

Case No. 1:20-cv-04472

Honorable Charles R. Norgle, Sr.

INITIAL STATUS REPORT

Pursuant to the Court’s March 18, 2021 Order [Dkt. 17], the parties jointly submit the 

following Joint Status Report:

A. Attorneys of Record:

Mohammed O. Badwan

Sulaiman Law Group, Ltd.

2500 South Highland Avenue

Suite 200

Lombard, Illinois 60148

(630) 575-8180

mbadwan@sulaimanlaw.com

Counsel for Plaintiff

Joseph R. Marconi

Brian C. Langs

Johnson & Bell, Ltd.

33 West Monroe Street - Suite 2700

Chicago, IL 60603

(312) 372-0770

marconij@jbltd.com

langsb@jbltd.com

Counsel for Defendant

B. Basis for Jurisdiction:

The Court has federal question jurisdiction pursuant to 28 U.S.C. § 1331 as Plaintiff alleges 

violations of the Fair Credit Reporting Act (“FCRA”), 15 U.S.C. §1681 et seq.

C. Whether a jury has been requested and by which party:

Plaintiff has made a jury demand.

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D. Nature of Claims/Counterclaims/Affirmative Defenses:

Plaintiff First Amended Class Action Complaint brings individual and class claims against 

Defendant Travelers Indemnity Company (“Travelers”) for violations of the FCRA. 

Specifically, Plaintiff alleges that Defendant violated the FCRA by accessing her Equifax 

credit report on January 9, 2020 for “insurance underwriting purposes” when Plaintiff is 

not and has never been a customer of Travelers, Plaintiff has not applied for or otherwise 

sought insurance products from Travelers, Plaintiff did not consent or authorize Travelers 

to access her Equifax credit report, and Travelers did not otherwise have a a permissible 

purpose prescribed by the FCRA. The alleged putative class is defined as follows:

All persons within the United States (1) that had their consumer 

credit report(s) obtained by Travelers; (2) within the five (5) years 

preceding the date of the original complaint through the date of class 

certification; (3) from Equifax, Experian, and/or Trans Union; (4) 

that were not existing Travelers customers; (5) that did not seek 

insurance coverage from Travelers; and (6) that did not receive a 

firm offer of credit from Travelers.

Travelers has answered the Complaint by denying all substantive individual and all 

substantive class allegations. Travelers has also asserted nine Affirmative Defenses, 

including, inter alia, affirmative defenses (1) that Plaintiff lacks Article III standing for her 

FCRA claim; (2) that Travelers never accessed Plaintiff’s (or any alleged putative class 

member’s) Equifax credit report; and (3) even if Travelers did access Plaintiff’s Equifax 

credit report, it did so because Plaintiff applied for insurance coverage from one of 

Travelers’s affiliates or Plaintiff’s Equifax credit report was accessed in order to send 

Plaintiff a firm offer for insurance coverage. 

E. Relief Sought by Plaintiff: 

Plaintiff is seeking (1) an order enjoining Defendant from unlawfully accessing consumers’ 

credit reports; (2) an order certifying the class and the appointment of Plaintiff’s counsel 

as class counsel; (3) statutory damages in the amount of $1,000 to Plaintiff; (4) statutory 

damages in the amount of $1,000 for each of the putative class members; (5) punitive 

damages; and (6) attorney’s fees and costs. 

F. Status of Service:

Defendant has been served.

G. Anticipated Motions:

None at this time.

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H. Proposed Discovery Plan:

1. Type of Discovery Need: Parties will conduct written and oral discovery.

2. Deadline to serve Rule 26(a)(1) initial disclosures: /June 30, 2021

3. Deadline to issue written discovery: July 30, 2021

4. Deadline for the amendment of pleadings: August 16, 2021

5. Fact Discovery Deadline: February 28, 2022 

I. Trial: The parties will be ready for trial in July 2022.

J. Status of Settlement Discussions: The parties have not engaged in settlement discussions. 

Plaintiff will make a settlement demand once Defendant expresses an interest in settlement.

K. Magistrate Judge: the parties do no consent to proceed before a magistrate judge.

DATED: May 18, 2021

/s/ Mohammed O. Badwan

Mohammed O. Badwan

Sulaiman Law Group, Ltd.

2500 South Highland Avenue

Suite 200

Lombard, Illinois 60148

630-575-8180

mbadwan@sulaimanlaw.com

Counsel for Plaintiff

Respectfully submitted,

/s/ Brian C. Langs 

Joseph R. Marconi

Brian C. Langs

Johnson & Bell, Ltd.

33 West Monroe Street - Suite 2700

Chicago, IL 60603

312-372-0770

marconij@jbltd.com

langsb@jbltd.com

Counsel for Defendant

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