Fill and Sign the Wrongful Information

IN THE ________________ COURT OF ________________________ (County) , _______________________________ (State) ______________________________________ PLAINTIFF (Name of Plaintiff) V. CAUSE NO. ______,_______ _______________________________________ DEFENDANT (Name of Defendant) COMPLAINT COMES NOW ________________________________________ (Name of Plaintiff) , Plaintiff in the above-styled and numbered cause, by and through his attorneys, and files this his Complaint against Defendant, ___________________________________________ (Name of Defendant) , and in support thereof would show unto the Court the following matters and facts: 1. Plaintiff is an adult resident citizen of _________________________________________ ___________________________________ (city, county, state) . 2 . Defendant is an adult resident citizen of _______________________________________ ___________________________________ (city, county, state) , and resides at ______________ ______________________________________________________________________________ ____________________________________ (street address, city, county, state, zip code) . 4. ______________________________________________________ (Name of Collection Agency) , of ___________________________________________________________________ (city, county, state) , hereinafter called Agency , at all times alleged was regularly engaged in the business of assembling and evaluating consumer credit information on consumers for the purposes of furnishing consumer credit reports to third parties for monetary fees, and, in the course of the business, created and maintained a file containing consumer credit information relating to Plaintiff. 5. On or about ______________________________________________ (date) , Defendant knowingly and willfully obtained access to and data from Plaintiff's file other than as provided by the Fair Credit Reporting Act ( 15 U.S.C. § 1681 et seq.) in that Defendant misrepresented to Agency that he intended to use the credit information from Plaintiff's file in connection with a credit, business, or other transaction involving Plaintiff, when, in reality, Defendant intended to and did use information from Plaintiff's file for the sole purpose of selling that information to other parties for a valuable consideration. 6. As a result of Defendant's wrongful use of Plaintiff's credit information, Plaintiff has been damaged, as follows: (Describe Damage) _______________________________________ ______________________________________________________________________________ ______________________________________________________________________________ _____________________________________________________________________________ . WHEREFORE, Plaintiff requests judgment against Defendant for: 1. Compensatory damages in the amount of $ __________________ (dollar amount) ; 2. Reasonable attorney fees, pursuant to the Fair Credit Reporting Act ( 15 U.S.C. § 1681 et seq.) ; 3. Costs of suit incurred; and 4. Such other and further relief as the court may deem just and proper. Respectfully submitted on this _________________________________________ (date) . __________________________________________ (Name of Plaintiff) By: ______________________________________ (Name of Plaintiff’s Attorney) State Bar No. ________________ His Attorney OF COUNSEL: ________________________________________ (Name of Plaintiff’s Attorney) Post Office Box __________-__________ City, State, Zip Code __________________________________________________________ Telephone: ________-________-____________