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December 23, 2009 – 4:26 pm
IN THE UNITED STATES DISTRICT COURT
EDWIN A.
Plaintiff,
v.
EXPERIAN INFORMATION SOLUTIONS, INC., LEXISNEXIS RISK & INFORMATION ANALYTICS GROUP, INC., and REED ELSEVIER, INC.
Defendants.
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Civil Action No.
PLAINTIFF’S MEMORANDUM OF LAW IN OPPOSITION TO
DEFENDANTS LEXISNEXIS RISK & INFORMATION ANALYTICS
GROUP, INC. AND REED ELSEVIER, INC.’S MOTION
TO DISMISS PLAINTIFF’S AMENDED COMPLAINT
I. PRELIMINARY STATEMENT
Plaintiff Edwin A. filed this lawsuit against LexisNexis Risk & Information Analytics Group, Inc. (“LNRIAG”) and Reed Elsevier, Inc. (“Reed”) (collectively “Moving Defendants” or “LexisNexis”) alleging claims for violation under the Fair Credit Reporting Act (“FCRA”), 15 U.S.C. §§ 1681 et seq., negligence, defamation and invasion of privacy because Moving Defendants falsely reported to other consumer reporting agencies (“CRAs”) that a civil judgment had been taken out against Plaintiff, and then failed to correct the error after Plaintiff disputed the inaccuracy. As detailed below, and contrary to Moving Defendants’ contentions, Plaintiff has pled sufficient facts and allegations to support each of his claims ...
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December 23, 2009 – 4:22 pm
IN THE UNITED STATES DISTRICT COURT
JOHN J., )
and )
AMANDA N., )
and )
CHARLES E., )
and )
CLARICE J., )
and )
NANCY M., )
and )
TONYA R., )
and )
LAURA ANNE, )
and )
LORI L., )
and )
CATHERINE, )
and )
BERNARD E., )
)
on behalf of themselves and all others )
similarly situated, )
)
Plaintiffs, ) Civil Action No.
vs. )
) JURY TRIAL DEMANDED
EXPERIAN INFORMATION )
SOLUTIONS, INC. )
)
Defendant. )
)
CLASS ACTION COMPLAINT
I. PRELIMINARY STATEMENT
1. Defendant, a national consumer reporting agency (“CRA”), has been selling credit reports inaccurately marking Plaintiffs – and what is believed to be hundreds if not thousands of other American consumers – as “deceased,” when they are very much alive. By reporting Plaintiffs as “deceased” Defendant is making it practically impossible for them to ...
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September 2, 2009 – 8:35 pm
IN THE UNITED STATES DISTRICT COURT
____________________________________
)
on behalf of themselves and all )
others similarly situated, The Sweep movie download Rocky IV hd )
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The Event psp Plaintiffs, ) C. A. No.
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v. )
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) JURY TRIAL DEMANDED
CONSUMER ADVOCATE )
FOUNDATION SERVICE, )
and )
CREDIT COLLECTIONS DEFENSE )
NETWORK, )
and )
CREDIT COLLECTIONS )
RECONCILIATION NETWORK, )
and )
BEACON CONSULTING )
SERVICES, LLC )
and )
R.K. LOCK & ASSOCIATES, )
and Grumpy Old Men download )
ROBERT K. LOCK, JR., ESQ. )
and )
PHILLIP MANGER )
and )
TRACY WEBSTER )
) CLASS ACTION
Defendants. )
____________________________________)
AMENDED COMPLAINT - CLASS ACTION
I. INTRODUCTION
1. This is a consumer class action brought for Defendants’ violations of the Credit Repair Organizations Act, 15 U.S.C. § 1679, et seq. (“CROA”) and Illinois Credit Services Organizations Act, 81 ILCS § 605/1, et seq. (“CSOA”). This law is ...
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September 2, 2009 – 8:18 pm
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
)
John Q full )
Grumpy Old Men movie Plaintiff, The Water Babies dvd A Crude Awakening: The Oil Crash video ) Battle in Seattle release
vs. )
Terms of Endearment movie download ) Civil Action No.
EQUIFAX INFORMATION SERVICES LLC, Saturday Morning In the Mouth of Madness film )
et al. The Puffy Chair trailer )
Defendants. )
)
PLAINTIFF S MEMORANDUM OF LAW IN SUPPORT OF HIS RESPONSE IN OPPOSITION TO DEFENDANT EQUIFAX INFORMATION SERVICES LLC’S MOTION FOR PARTIAL SUMMARY JUDGMENT
Plaintiff, through counsel, respectfully submits this Memorandum of Law in opposition to Equifax Information Services LLC’s (“Equifax”) Motion for Partial Summary Judgment (“Motion”). For the numerous reasons stated below, Equifax’s ...
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September 2, 2009 – 8:16 pm
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
MALIK HODGE, on behalf of himself and all others similarly situated
Plaintiff,
v.
PREMIER CREDIT OF NORTH AMERICA, LLC
Defendant.
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Civil Action No. 09-1644
Class Action
______________________________________________________________________________
MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S PARTIAL MOTION TO DISMISS OR STRIKE THE CLASS ACTION ALLEGATIONS OF THE AMENDED COMPLAINT
______________________________________________________________________________
FRANCIS & MAILMAN, P.C.
JAMES A. FRANCIS
GREGORY GORSKI
Land Title Building, 19th Floor
100 South Broad Street
Philadelphia, PA 19110
(215) 735-8600
TABLE OF CONTENTS
PAGE
I. PRELIMINARY STATEMENT ..............................................................................1
II. BACKGROUND ........................................................................................................3
A. Defendant Has No Permissible Basis To Call A Non-Debtor
And Misrepresent The Reason For Its Call To Coerce Private
Information About A Purported Debtor ..................................................................3
B. Defendant Uses A Standardized Telephone Call Script To
Deceive Third Parties ..............................................................................................4
C. Plaintiff’s Amended Complaint Includes All The Necessary
Elements To Adequately Allege A Class Action ....................................................5
III. LEGAL STANDARD .................................................................................................6
A. A Well Pled Complaint Need Only Allege Claims That Are
Not “Speculative” To Defeat A Motion To Dismiss Pursuant
To ...
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August 20, 2009 – 9:34 pm
FRANCIS & MAILMAN, P.C.
BY: MARK D. MAILMAN, ESQUIRE ATTORNEYS FOR PLAINTIFF
I.D. No. 77760
BY: JOHN SOUMILAS, ESQUIRE
I.D. No. 84527
Land Title Building, 19th Floor
100 South Broad Street
Philadelphia, PA 19110
(215) 735-8600
________________________________________________________________________
:
SEENA ROSENBERRY : COURT OF COMMON PLEAS
1732 S. Dover Street Columbus Day divx The Good Night : OF PHILADELPHIA COUNTY
Philadelphia, PA 19145 :
:
:
vs. : NO.
:
CONSUMER RECOVERY :
ASSOCIATES, INC. :
2697 International Parkway :
Virginia Beach, VA 23452 :
______________________________________________________________________________
COMPLAINT IN CIVIL ACTION
1. Plaintiff Seena Rosenberry is an adult individual residing at 1732 S. Doyer Street, Philadelphia, PA 19145.
2. Defendant Consumer Recovery Associates, LLC is a business entity regularly engaged in the business of collecting debts in this Commonwealth with its principal place of business located at 2697 International Parkway, Virginia Beach, VA 23452. The principal purpose of Defendant is the collection of debts using the mails and telephone, and Defendant regularly attempts to collect ...
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August 20, 2009 – 6:07 pm
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August 20, 2009 – 6:05 pm
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
JOHN L. DOHERTY, JR. )
)
Plaintiff, )
vs. )
) Civil Action No. 07-3049
TRANS UNION, LLC, ET AL. )
)
Defendants. )
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PLAINTIFF JOHN L. DOHERTY, JR.’S MEMORANDUM OF LAW IN SUPPORT OF HIS RESPONSE IN OPPOSITION TO DEFENDANT DELL FINANCIAL SERVICES’ MOTION FOR PARTIAL SUMMARY JUDGMENT
Plaintiff John L. Doherty, Jr., through counsel, hereby respectfully submits this Memorandum of Law in opposition to Defendant Dell Financial Services’ (“Dell”) Motion for Partial Summary Judgment (“Motion”) (Docket No. 23). For the reasons below, the Motion should be denied.
Plaintiff is a victim of identity theft at the hands of his estranged brother, William Doherty. Defendant Dell is the company that permitted William Doherty to obtain at least two computers (one on a business credit account and a second on a consumer credit account) in Plaintiff’s name using his good credit. It then proceeded to hold Plaintiff (not William Doherty) ...
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August 20, 2009 – 6:04 pm
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
CHRISTOPHER JUNG )
)
Plaintiff, )
vs. )
) Civil Action No. 07-2514
TRANS UNION, LLC, et al. )
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Defendants. )
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PLAINTIFF CHRISTOPHER JUNG’S MEMORANDUM OF LAW
IN SUPPORT OF HIS RESPONSE IN OPPOSITION TO DEFENDANT
TRANS UNION, LLC’S MOTION FOR SUMMARY JUDGMENT
Plaintiff Christopher Jung, through counsel, hereby respectfully submits this Memorandum of Law in opposition to Defendant Trans Union, LLC’s (TU) Motion for Summary Judgment (Motion) (Docket Nos. 53, 54, 55). For the reasons below, the Motion should be denied.
I. INTRODUCTION
Jung brought this consumer action seeking relief under the Fair Credit Reporting Act, 15 U.S.C. §§ 1681 et seq. (FCRA) and related common law claims against TU, one of the major consumer reporting agencies (CRA) in the world. The parties stipulated to dismiss the common law claims so that they can streamline this matter for trial. (See Docket No. 56) (submitted April 24, 2009). The FCRA claims, therefore, are ...
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August 20, 2009 – 6:02 pm
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
LARKAY D. WESLEY )
on behalf of herself and all others )
similarly situated )
) C.A. No. 05-3523
Plaintiff, )
vs. )
)
)
CAVALRY INVESTMENTS, LLC )
and )
CAVALRY PORTFOLIO SVCS )
) CLASS ACTION
Defendants. )
) JURY TRIAL DEMANDED
PLAINTIFF LARKAY D. WESLEY’S MEMORANDUM OF LAW IN SUPPORT OF HER RESPONSE IN OPPOSITION TO DEFENDANTS CAVALRY INVESTMENTS, LLC AND CAVALRY PORTFOLIO SVCS’S
MOTION FOR JUDGMENT ON THE PLEADINGS
Plaintiff Larkay D. Wesley, through counsel, hereby respectfully submits this Memorandum of Law in opposition to Defendants Cavalry Investments, LLC and Cavalry Portfolio Svcs’s (“Cavalry”) Motion for Judgment on the Pleadings (“Motion”). For the reasons set forth below, the first part of Defendants’ Motion should be denied.
I. INTRODUCTION
This is a consumer class action brought under the Fair Debt Collection Practices Act, 15 U.S.C. §§ 1692, et seq. (“FDCPA”), a federal statute that prohibits debt collectors from engaging in abusive, deceptive and unfair collection practices. Plaintiff claims that Defendants systematically violate the ...
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