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Name

Address

City, State, Zip

555 555-1212

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IN THE UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

MY NAME, pro se,

Plaintiff,

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vs,

No.

DEBT COLLECTOR, L.L.C.,

Defendant.

COMPLAINT

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PRELIMINARY STATEMENT

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1. This is an action for damages brought from violations of the Fair Credit Reporting Act
(FCRA) 15 U.S.C. 1681 et seq.

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JURISDICTION
2. The jurisdiction of this Court is conferred by 15 U.S.C. 1681p.

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FACTUAL ALLEGATIONS

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2. On October 13, 2009, Defendant initiated a soft pull of Plaintiffs

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credit report from

Experian without permissible purpose.

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COMPLAINT page ____

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COUNT I
VIOLATION OF FAIR CREDIT REPORTING ACT (FCRA), 15 U.S.C. 1681

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WILLFUL NON-COMPLIANCE BY DEFENDANT DEBT COLLECTOR, L.L.C.

3. Plaintiff is a consumer within the meaning of the FCRA, 15 U.S.C.
1681a(c).

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4. DEBT COLLECTOR, L.L.C. is a furnisher of information within the meaning of the

FCRA, 15 U.S.C. 1681s-2.

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5. DEBT COLLECTOR, L.L.C. willfully violated the FCRA. Defendants violations

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include, but are not limited to, the following:

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(a) DEBT COLLECTOR, L.L.C. willfully violated 15 U.S.C. 1681b(f) by obtaining

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Plaintiffs consumer report without a permissible purpose as defined by15 U.S.C. 1681b.
WHEREFORE, Plaintiff demands judgment for damages in the amount of $1,000 against
DEBT COLLECTOR, L.L.C. for actual or statutory damages, and punitive damages,
attorneys fees and costs, pursuant to 15 U.S.C. 1681n.

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COUNT II

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VIOLATION OF FAIR CREDIT REPORTING ACT (FCRA), 15 U.S.C. 1681

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NEGLIGENT NON-COMPLIANCE BY DEFENDANT DEBT COLLECTOR, L.L.C.

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6. Plaintiff is a consumer within the meaning of the FCRA, 15 U.S.C.

1681a(c).

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7. DEBT COLLECTOR, L.L.C. is a furnisher of information within the meaning of the

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FCRA, 15 U.S.C. 1681s-2.

COMPLAINT page ____

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8. DEBT COLLECTOR, L.L.C. negligently violated the FCRA. Defendants violations

include, but are not limited to, the following:

(a) DEBT COLLECTOR, L.L.C. negligently violated 15 U.S.C. 1681b(f)

by obtaining Plaintiffs consumer report without a permissible purpose as defined

by15 U.S.C. 1681b.

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WHEREFORE, Plaintiff demands judgment for damages in the amount of $1,000 against
DEBT COLLECTOR, L.L.C. for actual damages, and attorneys fees and costs,
pursuant to 15 U.S.C. 1681o.

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WHEREFORE, Plaintiff demands judgment for damages against DEBT COLLECTOR,

L.L.C. and $2,000 for actual or statutory damages, and punitive damages, attorney's fees
and costs, pursuant to 15 U.S.C. 1681n (a) (3) and 15 U.S.C. 1681o (a)

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DEMAND FOR JURY TRIAL

Plaintiff hereby demands a trial by jury of all issues so triable as a matter of law.

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Respectfully submitted this 30th day of June, 2011

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_________________________________

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Name
Address
City, State, Zip
COMPLAINT page ____

555 555-1212

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COMPLAINT page ____