Complaint — Douglas M. Marshburn v. LexisNexis Risk Solutions (Case 6:24-cv-00027 Document 1)

Full text

      Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 1 of 20 PageID 1




                IN THE UNITED STATES DISTRICT COURT
                FOR THE MIDDLE DISTRICT OF FLORIDA
                         ORLANDO DIVISION

DOUGLAS M. MARSHBURN,                      Case No.: 6:24-cv-00027

             Plaintiff,
v.                                         JURY TRIAL DEMANDED

LEXISNEXIS RISK SOLUTIONS,
LLC,

             Defendant.



                                   COMPLAINT

      Douglas M. Marshburn (“Plaintiff” Or “Mr. Marshburn”) a living, breathing

consumer, brings this action on an individual basis, against LexisNexis Risk

Solutions, Inc. (“LexisNexis” or “Defendant”) and states as follows:

                                 INTRODUCTION

      1.     The computerization of our society has resulted in a revolutionary

increase in the accumulation and processing of data concerning individual American

consumers. Data technology, whether it is used by businesses, banks, the Internal

Revenue Service or other institutions, allows information concerning individual

consumers to flow instantaneously to requesting parties. Such timely information is

intended to lead to faster and better decision-making by its recipients and, in theory,




                                         1/20
      Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 2 of 20 PageID 2




all of society should ultimately benefit from the resulting convenience and

efficiency.

      2.      However, unfortunately this information has also become readily

available for, and subject to, mishandling and misuse. Individual consumers can and

do sustain substantial damage, both economically and emotionally, whenever

inaccurate or fraudulent information is disseminated and/or obtained about them. In

fact, Defendant acknowledges this potential for misuse and resulting damage every

time it sells its respective services to a consumer.

      3.      The ongoing technological advances in the area of data processing have

resulted in a boon for the companies that accumulate and sell data concerning

individuals' credit histories and other personal information. Such companies are

commonly known as consumer reporting agencies ("CRAs").

      4.      These CRAs sell information to readily paying subscribers (i.e.,

retailers, landlords, lenders, potential employers, and other similar interested

parties), commonly called "consumer reports," concerning individuals who may be

applying for retail credit, housing, employment, or a car or mortgage loan.

      5.      Since 1970, when Congress enacted the Fair Credit Reporting Act, 15

U.S.C. § 1681, et seq. ("FCRA"), federal law has required CRAs to implement and

utilize reasonable procedures "to assure maximum possible accuracy" of the




                                         2/20
      Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 3 of 20 PageID 3




personal, private, and financial information that they compile and sell about

individual consumers.

      6.     One of the primary purposes in requiring CRAs to assure "maximum

possible accuracy" of consumer information is to ensure the stability of our banking

system:

      The banking system is dependent upon fair and accurate credit
      reporting. Inaccurate credit reports directly impair the efficiency of the
      banking system, and unfair credit reporting methods undermine the
      public confidence which is essential to the continued functioning of the
      banking system.
See 15 U.S.C. § 1681(a)(1).

      7.     The preservation of one's good name and reputation is also at the heart

of the FCRA's purposes:

     [W]ith the trend toward computerization of billings and the
     establishment of all sorts of computerized data banks, the individual is
     in great danger of having his life and character reduced to impersonal
     "blips" and key-punch holes in a stolid and unthinking machine which
     can literally ruin his reputation without cause, and make him
     unemployable or uninsurable, as well as deny him the opportunity to
     obtain a mortgage or buy a home. We are not nearly as much concerned
     over the possible mistaken turn-down of a consumer for a luxury item
     as we are over the possible destruction of his good name without his
     knowledge and without reason. Shakespeare said, the loss of one's good
     name is beyond price and makes one poor indeed.
Bryant v. TRW, Inc., 689 F.2d 72, 79 (6th Cir. 1982) [quoting 116 cong. Rec.

36570 (1970)] (emphasis added).

      8.     The FCRA also requires CRAs to conduct a reasonable reinvestigation

to determine whether information disputed by consumers is inaccurate and record



                                         3/20
      Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 4 of 20 PageID 4




the current status of the disputed information, or delete the disputed information,

before the end of the 30-day period beginning on the date on which the CRA receives

the notice of dispute from the consumer. This mandate exists to ensure that consumer

disputes are handled in a timely manner and that inaccurate information contained

within a consumer's credit report is corrected and/or deleted so as to not prevent said

consumer from benefiting from his or her credit and obtaining new credit.

      9.      In light of these important findings and purposes, Congress specifically

noted "a need to insure that [CRAs] exercise their grave responsibilities with

fairness, impartiality, and respect for the consumer's right to privacy." See 15 U. S.C.

§ 1681(a)(4).

      10.     The FCRA also requires furnishers of information, a creditor or other

third party that provides information about consumer to a CRA, upon notice, to

conduct a reasonable reinvestigation of all disputes with regard to the completeness

or accuracy of any information it provides to the CRAs regarding a consumer and

modify, delete, or permanently block any items of information found to be

inaccurate, incomplete, or unverifiable after said reinvestigation is completed.

      11.     Plaintiff’s claims arise out of Defendant's blatantly inaccurate

reporting, wherein Defendant reported to Plaintiff’s potential creditors that he is

"deceased."




                                         4/20
      Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 5 of 20 PageID 5




      12.    Accordingly, Plaintiff brings claims against Defendant for failing to

follow reasonable procedures to assure the maximum possible accuracy of Plaintiff’s

credit reports, in violation of the FCRA, 15 U.S.C. § 1681e(b).

      13.    As part of this action, Plaintiff seeks actual, statutory, and punitive

damages, costs and attorneys' fees from Defendant for its willful and/or negligent

violations of the Fair Credit Reporting Act, 15 U.S.C. § 1681, et seq., as described

herein.

                                      PARTIES

      14.    Douglas M. Marshburn (“Plaintiff” Or “Mr. Marshburn”) is a natural

person residing in Deltona, Florida and is a “consumer” as that term is defined in 15

U.S.C. § 1681a(c).

      15.    Defendant LexisNexis        Risk    Solutions, Inc. ("Defendant"        or

"LexisNexis") is a Delaware corporation doing business throughout the United

States, including the State of Minnesota and in this District, and has a principal place

of business located at 1000 Alderman Drive, Alpharetta, Georgia 30005. LexisNexis

can be served at its registered agent, The Corporation Company, located at 40600

Ann Arbor Rd E, Suite 201, Plymouth, Michigan 48170.

      16.    LexisNexis is a "consumer reporting agency" as defined in 15 U.S.C. §

1681a(f). LexisNexis is regularly engaged in the business of assembling, evaluating,




                                         5/20
      Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 6 of 20 PageID 6




and disseminating information concerning consumers for the purpose of furnishing

consumer reports, as defined in 15 U.S.C. § 1681a(d) to third parties.

                             JURISDICTION AND VENUE

      17.      This Court has jurisdiction over Plaintiff’s claims pursuant to 28 U.S.C.

§ 1331 and 15 U.S.C. § 1681p, which allows claims under the FCRA to be brought

in any appropriate court of competent jurisdiction.

      18.      Venue is proper in this District pursuant to 28 U.S.C. § 1391(b)(2)

because a substantial part of the events or omissions giving rise to Plaintiff's claims

occurred in this District.

                                        FACTS

                     Summary of the Fair Credit Reporting Act

      19.      The FCRA governs the conduct of consumer reporting agencies in an

effort to preserve the integrity of the consumer banking system and to protect the

rights of consumers to fairness and accuracy in the reporting of their credit

information.

      20.      The FCRA was designed to protect consumers from the harmful effects

of inaccurate information reported in consumer reports (commonly referred to as

“credit reports”). Thus, Congress enshrined the principles of “fair and accurate credit

reporting” and the “need to ensure that consumer reporting agencies exercise their




                                          6/20
      Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 7 of 20 PageID 7




grave responsibilities with fairness” in the very first provision of the FCRA. See 15

U.S.C. § 1681(a).

      21.    Specifically, the statute was intended to ensure that “consumer

reporting agencies adopt reasonable procedures for meeting the needs of commerce

for consumer credit, personnel, insurance, and other information in a manner which

is fair and equitable to the consumer, with regard to the confidentiality, accuracy,

relevancy, and proper utilization of such information. See 15 U.S.C. § 1681(b).

      22.    To that end, the FCRA imposes the following twin duties on consumer

reporting agencies: (i) consumer reporting agencies must devise and implement

reasonable procedures to ensure the “maximum possible accuracy” of information

contained in consumer reports (15 U.S.C. § 1681e(b)); and (ii) consumer reporting

agencies must reinvestigate the facts and circumstances surrounding a consumer’s

dispute and timely correct any inaccuracies (15 U.S.C. § 1681i).

      23.    The FCRA provides consumers with a private right of action against

consumer reporting agencies that willfully or negligently fail to comply with their

statutory obligations under the FCRA.

   Defendant’s Practices Concerning the Sale of Reports on the “Deceased”
      24.    Defendant sells millions of consumer reports (often called "credit

reports" or "reports") per day.




                                        7/20
      Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 8 of 20 PageID 8




      25.    Pursuant to 15 U.S.C. § 1681e(b), consumer reporting agencies, like

Defendant, are required "to follow reasonable procedures to assure maximum

possible accuracy of the information concerning the individual about whom the

report relates."

      26.    Pursuant to 15 U.S.C. §§ 1681b and 1681e(a), consumer reporting

agencies, like Defendant, must maintain reasonable procedures to assure that

consumer reports are sold only for legitimate "permissible purposes."

      27.    Defendant routinely places a "deceased" notation or marking on reports

when it is advised by any of its many data sources that a given consumer is deceased.

      28.     Defendant does not request or require a death certificate from any of

its data sources which advise that a consumer is "deceased" before placing a

"deceased" mark in that consumer's credit file.

      29.    Defendant does not request or require any proof from any data source

which advises that a consumer is "deceased," showing that the consumer is in fact

deceased before placing a "deceased" mark on that consumer's report.

      30.    Defendant does not independently verify with any source that a

consumer is in fact deceased before placing a "deceased" mark on that consumer's

report.

      31.    In some cases, in order to assure accuracy, Defendant may send letters

and/or other communications to consumers when certain information that may be



                                        8/20
      Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 9 of 20 PageID 9




considered suspicious or unreliable is furnished about said consumers to be placed

in their credit files, such as in cases where consumers have a freeze or fraud alert on

their credit report, or in accordance with certain state laws, such as the consumer

laws of Colorado. Defendant does not have any procedure to notify consumers (such

as a next of kin or executor or administrator of the consumer's estate) when

Defendant has received information suggesting the consumer is deceased before

adding that information to the consumer’s credit file or report.

      32.    The Social Security Administration (SSA) maintains the Death Master

File (“DMF”). The DMF is also known commercially as the Social Security Death

Index (SSDI). The SSA’s DMF as of 2018 contained information on 111 million

deaths that have been reported to the SSA. The DMF is created from internal SSA

records of deceased persons possessing social security numbers and whose deaths

were reported to the SSA. The DMF includes the following information on each

decedent, if the data are available to the SSA: social security number, name, date of

birth, and date of death.

      33.    Legislation (i.e., the Social Security Act) precludes the sharing of the

full DMF with non-benefits paying agencies.

      34.    Because of the wide use and demand for death records for a variety of

industries, SSA has partnered with the U.S. Department of Commerce’s National




                                         9/20
      Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 10 of 20 PageID 10




Technical Information Service (NTIS) to release the Limited Access Death Master

File (LADMF) electronically on a weekly and monthly basis.

        35.      The SSA receives death reports from many sources, including family

members, funeral homes, financial institutions, postal authorities, state information,

and other federal agencies. The SSA does not have a death record for all persons;

therefore, the SSA does not guarantee the veracity of the DMF. The SSA does not

guarantee 100% of the data.

        36.      The SSA estimates that roughly 12,000 living people are added to the

DMF annually, potentially due to clerical error. An erroneous listing can lead to not

only a cessation of government benefits, but also the freezing of bank accounts, the

inability to buy or rent property, and mistaken accusations of identity theft.1 2

        37.      The Office of the Inspector General called the error rate “very low,” but

noted that “SSA’s erroneous death entries can lead to mistaken benefit terminations

and cause severe financial hardship and distress to affected people…when errors like

this occur, it can be a long and difficult process to resurrect your financial health.3

        38.      Defendant does not have access to the full DMF from the SSA, but

rather is a subscriber to the NTIS LADMF.



1
  Aviva Dekornfeld (2018-06-20). "The Plight of the Living Dead". The Indicator from Planet Money (Podcast).
2
  Bichell, Rae Ellen (2016-08-10). "Social Security Data Errors Can Turn People into the Living Dead". National
Public Radio.
3
  "Cases of Mistaken Death Reports Low but Costly | Office of the Inspector General, SSA". oig.ssa.gov. 2016-
03-24. Archived from the original on 2020-07-16.


                                                    10/20
     Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 11 of 20 PageID 11




      39.    Despite being a subscriber to the NTIS LADMF, Defendant does not

cross-reference the information it has received suggesting a consumer is deceased

with the LADMF in order to determine whether any given consumer reported as

deceased via its source is also on the LADMF before selling a credit report about

said consumer, or at any time.

      40.    Defendant fails to employ reasonable procedures that assure that a

consumer is actually deceased before placing the "deceased" mark on that

consumer's report and selling that report for profit.

      41.    Even in instances where other data on the face of the consumer's report

indicates that he/she is not deceased, Defendant does not employ any procedures to

assure that a consumer is in fact actually deceased before placing the "deceased"

mark in that consumer's file.

      42.    Even in instances where the purportedly deceased consumer

communicates directly with the Defendant, Defendant does not employ any

procedures to assure that a consumer is in fact actually deceased before placing the

"deceased" mark on that consumer's report.

      43.    Defendant knows that living consumers are routinely turned down for

credit specifically because they are reporting them as "deceased."




                                         11/20
     Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 12 of 20 PageID 12




      44.    Defendant has been put on notice for years through consumer disputes

and lawsuits that living, breathing consumers are turned down for credit specifically

because Defendant is inaccurately reporting them as "deceased."

      45.    Defendant has received and documented many disputes from

consumers complaining that Defendant had erroneously marked them as "deceased”

on their credit reports.

      46.    Defendant knows that thousands of consumers are erroneously marked

as "deceased" on their credit reports.

      47.    Nevertheless, Defendant does not employ any procedures to assure that

a consumer is actually deceased before adding a “deceased” notation to that

consumer’s credit reports.

      48.    Defendant does not employ any procedures to limit or stop the

furnishing of reports to third parties for consumers that they have marked as

"deceased" under any circumstances.

      49.    For years after a consumer's actual death, Defendant will continue to

sell credit reports about that consumer.

      50.    Defendant will only remove a deceased consumer's file from its

respective credit reporting databases when it is no longer valuable to them—

meaning that no one is continuing to purchase reports about that consumer.




                                           12/20
     Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 13 of 20 PageID 13




      51.    Defendant charges third parties a fee for reports with a mark that a

consumer is deceased ("reports on the deceased") as they would for any other report.

      52.    Defendant profits from the sale of reports on deceased consumers.

      53.    Defendant knows that truly deceased consumers do not apply for credit.

      54.    Defendant knows that the credit information and reports of truly

deceased persons are used by criminals to commit identity theft or credit fraud.

Indeed, identity theft using the personal identifying information of deceased

consumers is known to Defendant to be a common and major source of identity theft.

      55.    Defendant knows that identity theft and credit fraud are serious and

widespread problems in our society.

      56.    Defendant sells reports on supposedly deceased consumers to third

parties in an automated fashion and without any specific or general certification that

could reasonably explain a "permissible purpose" for purchasing or using a

(supposedly) deceased consumer's credit history and/or report.

      57.    For consumers who are deceased, there rarely, if ever, exists a

permissible purpose under the FCRA for the Defendant to sell their credit reports,

absent a court order.

      58.    Defendant knows that such reports contain a vast amount of personal

identifying and credit account information on the supposedly deceased consumer,




                                        13/20
    Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 14 of 20 PageID 14




information that can be used to commit identity theft or for other fraudulent

purposes.

      Plaintiff Applied for a Synchrony Bank Credit Card October 2023

      59.   On or about October 13, 2023, Plaintiff set out to secure a $2000 credit

card to address immediate and pressing expenses for repairs to his vehicle.

      60.   Accordingly, on or about October 13, 2023, the 81-year-old Plaintiff

applied for instant credit for car care with Synchrony Bank Car Care.

      61.   Plaintiff needed a $2,000 credit card to finance part of his bill for

$2,600. He had other Synchrony Bank cards and his credit had been excellent and

anticipated an approval without issue.

  Synchrony Bank Denies Plaintiff’s Credit Card Application October 2023

      62.   Synchrony Bank ordered a consumer report about Plaintiff from

Defendant on or about October 13, 2023.

      63.   Defendant published information about Plaintiff to Synchrony Bank in

response to that credit application on or about October 13, 2023.

      64.   Upon receipt and review of Defendant’s report about Plaintiff,

Synchrony Bank denied Plaintiff’s credit card application. Specifically, Synchrony

Bank denied Plaintiff’s credit card application because Defendant reported that

Plaintiff was deceased.



                                         14/20
     Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 15 of 20 PageID 15




       65.   Upon information and belief, Synchrony Bank denied Plaintiff’s credit

card application based upon the contents of a consumer report Defendant sold about

Plaintiff.

       66.   Plaintiff was surprised, shocked and embarrassed to be denied credit in

a small office with approximately three other customers waiting. The assistant

manager announced that his credit was not approved in front of the other customers.

       67.   Plaintiff was disappointed at the Synchrony Bank credit card denial.

Certainly, Plaintiff was not deceased. Plaintiff found that information to be very

distressing and confusing, even shocking.

       68.   In light of the plaintiff's existing Synchrony Bank Credit Cards, he

contacted Synchrony Bank and successfully demonstrated that he was indeed alive,

ultimately leading to the approval of the applied-for credit card.

     Plaintiff Obtains His Credit Denial Letter from Synchrony Bank and
          Confirms that Defendant Was Reporting Him as Deceased

       69.   After a few days, Plaintiff received the Synchrony Bank denial letter.

       70.   Upon review of the denial letter, Plaintiff saw that Defendant was

reporting Plaintiff as deceased.

       71.   Defendant had every reason to know that Plaintiff was not deceased,

including the many credit applications submitted by Plaintiff, the many credit




                                        15/20
     Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 16 of 20 PageID 16




accounts opened, the many payments made since then, and even the Social Security

Administration records confirming that Plaintiff was very much alive.

      72.    On or around October 23, 2023, Plaintiff contacted Defendant and

disputed the deceased notation Defendant included on Plaintiff’s consumer report to

Synchrony Bank.

      73.    While disputing the false deceased notation, Plaintiff was informed that

it would take up to 30 days for Defendant to correct same.

      74.    On or about October 23, 2023, Defendant was no longer reporting a

deceased notation on Plaintiff’s consumer report, further evidencing the erroneous

nature of such.

      75.    Defendant violated 15 U.S.C. § 1681e(b) by failing to establish or to

follow reasonable procedures to assure maximum possible accuracy of the consumer

information it published and maintained concerning Plaintiff.

      76.    As a result of the deceased notation, Defendant made it practically

impossible for Plaintiff to continue to obtain credit.

      77.    At all times pertinent hereto, Defendant was acting by and through its

agents, servants, and/or employees who were acting within the course and scope of

their agency or employment, and under the direct supervision and control of the

Defendant herein.




                                         16/20
     Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 17 of 20 PageID 17




      78.    At all times pertinent hereto, the conduct of Defendant, as well as that

of its respective agents, servants, and/or employees, was intentional, willful,

reckless, grossly negligent and in utter disregard for federal law and the rights of

Plaintiff herein.

      79.    Defendant is aware of the shortcomings of its procedures and

intentionally chooses not to comply with the FCRA to lower its costs. Accordingly,

the Defendant’s violations of the FCRA are willful.

      80.    As a result of Defendant’s conduct, action, and inaction, Plaintiff

suffered damage by loss of credit; loss of ability to purchase and benefit from his

good credit rating; detriment to his credit rating; and emotional distress including

the mental and emotional pain, anguish, humiliation, and embarrassment of credit

denials.

                              CLAIMS FOR RELIEF
                                 COUNT I
                            15 U.S.C. § 1681e(b)
    Failure to Follow Reasonable Procedures to Assure Maximum Possible
                                  Accuracy

      81.    Plaintiff re-alleges and incorporates by reference the allegations set

forth in preceding paragraphs as if fully stated herein.

      82.    The FCRA imposes a duty on consumer reporting agencies to devise

and implement procedures to ensure the “maximum possible accuracy” of consumer

reports, as follows:


                                        17/20
     Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 18 of 20 PageID 18




      Whenever a consumer reporting agency prepares a consumer report, it
      shall follow reasonable procedures to assure maximum possible
      accuracy of the information concerning the individual about whom the
      report relates.
15 U.S.C. §1681e(b) (emphasis added).

       83.   Defendant prepared patently false consumer reports concerning

Plaintiff.

       84.   Despite actual and implied knowledge that Plaintiff is not dead,

Defendant readily sold such false reports to one or more third parties, thereby

misrepresenting Plaintiff, and ultimately Plaintiff’s creditworthiness.

       85.   Defendant violated 15 U.S.C. § 1681e(b) by failing to establish or to

follow reasonable procedures to assure maximum possible accuracy in the

preparation of the consumer reports it published and maintained concerning

Plaintiff.

       86.   As a result of Defendant’s conduct, action, and inaction, Plaintiff

suffered damage by loss of credit; loss of ability to purchase and benefit from his

good credit rating; detriment to his credit rating; and emotional distress including

the mental and emotional pain, anguish, humiliation, and embarrassment of credit

denials.

       87.   Defendant’s conduct, actions, and inactions was willful, rendering it

liable for actual or statutory damages, and punitive damages in an amount to be




                                        18/20
       Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 19 of 20 PageID 19




determined by the Court pursuant to 15 U.S.C. § 1681n. Alternatively, they were

negligent, entitling Plaintiff to recover under 15 U.S.C. § 1681o.

        88.   Plaintiff is entitled to recover attorneys’ fees and costs from Defendant

in an amount to be determined by the Court pursuant to 15 U.S.C. § 1681n and/or §

1681o.

                               PRAYER FOR RELIEF

        WHEREFORE, Plaintiff prays for the following relief:

  i.    Determining that Defendant negligently and/or willfully violated the FCRA;

 ii.    Awarding Plaintiff actual, statutory, and punitive damages as provided by the

        FCRA;

iii.    Awarding Plaintiff reasonable attorneys’ fees and costs as provided by the

        FCRA; and,

iv.     Granting further relief, in law or equity, as this Court may deem appropriate

        and just.

                           DEMAND FOR JURY TRIAL

        Plaintiff is entitled to and hereby demands a trial by jury on all issues so

triable.

        RESPECTFULLY SUBMITTED this 4th day of January 2024




                                         19/20
Case 6:24-cv-00027 Document 1 Filed 01/04/24 Page 20 of 20 PageID 20




                               CONSUMER ATTORNEYS

                               /s/Catherine Tillman
                               Catherine Tillman, Esq., FL #0057663
                               CONSUMER ATTORNEYS
                               8245 N. 85th Way
                               Scottsdale, AZ 85258
                               T: (941) 263-7310
                               F: (718) 715-1750
                               E: ctillman@consumerattorneys.com


                               Attorney for Plaintiff
                               Douglas M. Marshburn




                               20/20


File and source

File

gov.uscourts.flmd.422624.1.0.pdf

Size

397,532 bytes

SHA-256

144c98fe1add986c7b410d72347523fce4dd7b0979e60bc1b45c3a41c96ba792

Our copy

gov.uscourts.flmd.422624.1.0.pdf

Original

www.courtlistener.com