Full text
1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
NORFOLK DIVISION
ANGELINA FRANCESCA WILLIAMS,
Plaintiff,
vs.
LEXISNEXIS RISK SOLUTIONS, INC.,
Defendant.
Case No.: 2:24-cv-00283
DEMAND FOR JURY TRIAL
COMPLAINT
Angelina Francesca Williams (“Plaintiff” or “Ms. Williams”) a living, breathing 53-year-
old consumer, brings this action on an individual basis, against LexisNexis Risk Solutions, Inc.
(“LexisNexis” or “Defendant”) for violating her rights under the Fair Credit Reporting Act, 15
U.S.C. § 1681 et seq.
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, all of society should ultimately benefit from the resulting
convenience and efficiency.
2.
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
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 1 of 16 PageID# 1
2
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 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
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 2 of 16 PageID# 2
3
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 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 she is "deceased."
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 3 of 16 PageID# 3
4
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.
Angelina Francesca Williams (“Plaintiff” or “Ms. Williams”) is a natural person
residing in Virginia Beach, Virginia, 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 Commonwealth
of Virginia, in this District and Division. It has a principal place of business located at 1000
Alderman Drive, Alpharetta, Georgia 30005. LexisNexis can be served at its registered agent, C T
Corporation System, located at 4701 Cox Rd Ste 285, Glen Allen, VA, 23060 - 6808.
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, 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.
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 4 of 16 PageID# 4
5
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
and Division.
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 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).
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 5 of 16 PageID# 5
6
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.
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 considered suspicious or
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 6 of 16 PageID# 6
7
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 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.
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 7 of 16 PageID# 7
8
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
39.
Defendant also obtains death information from third parties other than NTIS.
40.
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.
41.
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.
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.
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 8 of 16 PageID# 8
9
42.
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.
43.
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.
44.
Defendant knows that living consumers are routinely turned down for credit
specifically because they are reporting them as "deceased."
45.
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."
46.
Defendant has received and documented many disputes from consumers
complaining that Defendant had erroneously marked them as "deceased” on their credit reports.
47.
Defendant knows that thousands of consumers are erroneously marked as
"deceased" on their credit reports.
48.
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.
49.
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.
50.
For years after a consumer's actual death, Defendant will continue to sell credit
reports about that consumer.
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 9 of 16 PageID# 9
10
51.
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.
52.
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.
53.
Defendant profits from the sale of reports on deceased consumers.
54.
Defendant knows that truly deceased consumers do not apply for credit.
55.
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.
56.
Defendant knows that identity theft and credit fraud are serious and widespread
problems in our society.
57.
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.
58.
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.
59.
Defendant knows that such reports contain a vast amount of personal identifying
and credit account information on the supposedly deceased consumer, information that can be used
to commit identity theft or for other fraudulent purposes.
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 10 of 16 PageID# 10
11
Plaintiff Applied for a Capital One Credit Card February 2024
60.
In or around October 2023, Plaintiff had completed the process of discharging her
debt through a Chapter 7 Bankruptcy procedure.
61.
Following the discharge of Plaintiff’s debt, she set out to establish a rebuild her
credit by beginning to apply for credit cards.
62.
Despite her efforts, Plaintiff was unable to see her credit score rise and assumed the
cause had to be low credit limits and a poor credit mix.
63.
Plaintiff suffered a stroke in or around January 2024, and therefore took a step back
from building up her credit while trying to recover her health.
64.
As Plaintiff recovered, she reviewed varying credit card promotions and wanted to
find for the right card for her.
65.
It was important to Plaintiff to apply for the right credit opportunities in order to be
able to build her credit back up.
66.
Accordingly, in or about February 6, 2024, Plaintiff completed and submitted an
online pre-approval application with Capital One for a credit card.
Capital One Denies Plaintiff’s Credit Card Application February 2024
67.
Capital One ordered a consumer report about Plaintiff from Defendant in or around
early February 2024.
68.
Defendant published information about Plaintiff to Capital One in response to that
credit application on or about early February 2024.
69.
Upon receipt and review of Defendant’s report about Plaintiff, Capital One denied
Plaintiff’s credit card application. Specifically, Capital One denied Plaintiff’s credit card
application because Defendant reported Plaintiff deceased.
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 11 of 16 PageID# 11
12
70.
Upon information and belief, Capital One denied Plaintiff’s credit card application
based upon the contents of a consumer report Defendant sold about Plaintiff.
71.
Plaintiff was disappointed at the Capital One credit card denial. Certainly, Plaintiff
was not deceased. Plaintiff found that information to be very distressing and confusing, even
shocking. Plaintiff assumed it was just some sort of fluke and endeavored to continue to seek
opportunities for credit.
Plaintiff Applied Again for a Capital One Credit Card March 2024
72.
Plaintiff applied to a variety of other creditors for credit cards after the Capital One
denial in February 2024, citing her Chapter 7 bankruptcy as the reason.
73.
Nonetheless, Plaintiff was determined to build her credit and continued looking for
opportunities.
74.
On or about March 12, 2024, Plaintiff completed and submitted an application with
Capital One for a credit card.
Capital One Denies Plaintiff’s Credit Card Application March 2024
75.
Upon information and belief, Capital One ordered a consumer report about Plaintiff
from Defendant on or about March 12, 2024.
76.
Upon information and belief, Defendant published information about Plaintiff to
Capital One in response to that credit application on or about March 12, 2024.
77.
Upon receipt and review of Defendant’s report about Plaintiff, Capital One denied
Plaintiff’s credit card application.
78.
On or about March 12, 2024 Plaintiff received an adverse action notice from Capital
One denying her credit card application. Specifically, Capital One denied Plaintiff’s credit card
application because Defendant reported that Plaintiff was deceased.
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 12 of 16 PageID# 12
13
79.
Upon information and belief, Capital One denied Plaintiff’s credit card application
based upon the contents of a consumer report Defendant sold about Plaintiff.
80.
After receiving another denial that reported Plaintiff was deceased, Plaintiff, who
received regular disability benefits from the Social Security Administration (“SSA”) decided to
access her online SSA records to ensure she was not being reported as deceased.
81.
A thorough review of Plaintiff’s online profile on the SSA website and her benefits
documents did not reveal any indication that she was being reported as deceased by the SSA.
82.
Furthermore, Plaintiff continued to receive her disability benefits from the SSA
without issue, further indicating that they had not reported her as deceased.
83.
Plaintiff was embarrassed to learn that Defendant had reported that Plaintiff was
deceased. Certainly, Plaintiff was not deceased. Plaintiff was very distressed at the continued
furthering of information suggesting she was deceased. Plaintiff was frustrated at the credit denial
because she very much needed to rebuild her credit. Plaintiff felt that the recipients of that
information no doubt questioned her motives and integrity and worst yet possibly suspected her of
identity theft as they could clearly discern that she was not deceased.
Plaintiff Obtains Her Consumer Report and Confirms that Defendant Was Reporting Her
as Deceased
84.
In or around March 8, 2024, Plaintiff viewed copies of her consumer reports from
the three major consumer reporting agencies (“CRA’s”) Equifax, Experian, and Trans Union.
85.
Plaintiff’s Equifax consumer report had no mention of any deceased notation.
86.
Plaintiff’s Trans Union consumer report had no mention of any deceased notation.
87.
Plaintiff was unable to access her Experian consumer report due to technical
difficulties, but had been denied credit in the past due to Experian reporting her Chapter 7
bankruptcy to creditors.
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 13 of 16 PageID# 13
14
88.
In or about March 9, 2024, Plaintiff viewed her LexisNexis consumer report.
89.
Upon information and belief, Defendant is the only credit reporting agency that
could have been reporting Plaintiff was deceased to her potential creditors.
90.
Plaintiff reasonably believes that Defendant sold Capital One an identity
verification product that is not visible on her consumer disclosure.
91.
Defendant had every reason to know that Plaintiff was not deceased, including the
many credit applications submitted by Plaintiff, the many credit accounts opened, the many
payments made since then, and Plaintiff’s regular disability benefits from the SSA.
92.
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.
93.
As a result of the deceased notation, Defendant made it practically impossible for
Plaintiff to continue to obtain credit.
94.
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.
95.
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.
96.
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.
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 14 of 16 PageID# 14
15
97.
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 her good credit rating; detriment to
her 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
98.
Plaintiff re-alleges and incorporates by reference the allegations set forth in
preceding paragraphs as if fully stated herein.
99.
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:
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).
100.
On numerous occasions, Defendant prepared patently false consumer reports
concerning Plaintiff.
101.
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.
102.
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.
103.
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 her good credit rating; detriment to
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 15 of 16 PageID# 15
16
her credit rating; and emotional distress including the mental and emotional pain, anguish,
humiliation, and embarrassment of credit denials.
104.
Defendant’s conduct, actions, and inactions was willful, rendering it liable for
actual or statutory damages, and punitive damages in an amount to be 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.
105.
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,
Angelina Francesca Williams
/s/ _
Susan Mary Rotkis, VSB 40693
CONSUMER ATTORNEYS
2290 East Speedway Blvd.
Tucson, AZ 85719
Direct: 602-807-1504
Facsimile: 718-715-1750
E-mail: srotkis@consumerattorneys.com
Attorney for Plaintiff
Angelina Francesca Williams
Case 2:24-cv-00283-RBS-RJK Document 1 Filed 05/02/24 Page 16 of 16 PageID# 16