The opinion
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8 UNITED STATES DISTRICT COURT
9 FOR THE EASTERN DISTRICT OF CALIFORNIA
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11 VERONICA S. CHAPMAN, Case No. 2:26-cv-01184-DC-CSK (PS)
12 Plaintiff, ORDER
13 v. (ECF Nos. 1, 2)
14 TRANSUNION LLC; GOLDMAN
SACHS BANK USA,
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Defendants.
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18 Plaintiff Veronica S. Lee-Chapman is representing herself in this action and seeks
19 leave to proceed in forma pauperis (“IFP”) pursuant to 28 U.S.C. § 1915.1 (ECF No. 2.)
20 Plaintiff’s application in support of the IFP request makes the required financial showing.
21 Accordingly, the Court grants Plaintiff’s IFP request.
22 I. SCREENING REQUIREMENT
23 Pursuant to 28 U.S.C. § 1915(e), the Court must screen every in forma pauperis
24 proceeding, and must order dismissal of the case if it is “frivolous or malicious,” “fails to
25 state a claim on which relief may be granted,” or “seeks monetary relief against a
26 defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); Lopez v. Smith,
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1 This matter proceeds before the undersigned pursuant to 28 U.S.C. § 636, Fed. R.
28 Civ. P. 72, and Local Rule 302(c).
1 203 F.3d 1122, 1126-27 (2000) (en banc). A claim is legally frivolous when it lacks an
2 arguable basis either in law or in fact. Neitzke v. Williams, 490 U.S. 319, 325 (1989). In
3 reviewing a complaint under this standard, the court accepts as true the factual
4 allegations contained in the complaint, unless they are clearly baseless or fanciful, and
5 construes those allegations in the light most favorable to the plaintiff. See Neitzke, 490
6 U.S. at 327; Von Saher v. Norton Simon Museum of Art at Pasadena, 592 F.3d 954, 960
7 (9th Cir. 2010), cert. denied, 564 U.S. 1037 (2011).
8 Pleadings by self-represented litigants are liberally construed. Hebbe v. Pliler, 627
9 F.3d 338, 342 & n.7 (9th Cir. 2010) (liberal construction appropriate even post–Iqbal).
10 However, the court need not accept as true conclusory allegations, unreasonable
11 inferences, or unwarranted deductions of fact. Western Mining Council v. Watt, 643 F.2d
12 618, 624 (9th Cir. 1981). A formulaic recitation of the elements of a cause of action does
13 not suffice to state a claim. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-57 (2007);
14 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).
15 To state a claim on which relief may be granted, the plaintiff must allege enough
16 facts “to state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “A
17 claim has facial plausibility when the plaintiff pleads factual content that allows the court
18 to draw the reasonable inference that the defendant is liable for the misconduct alleged.”
19 Iqbal, 556 U.S. at 678. A pro se litigant is entitled to notice of the deficiencies in the
20 complaint and an opportunity to amend unless the complaint’s deficiencies could not be
21 cured by amendment. See Lopez, 203 F.3d at 1130-31; Cahill v. Liberty Mut. Ins. Co., 80
22 F.3d 336, 339 (9th Cir. 1996).
23 II. THE COMPLAINT
24 Plaintiff brings this action against Defendants TransUnion LLC and Goldman
25 Sachs Bank USA alleging the following violations of the Fair Credit Reporting Act: (1) 15
26 U.S.C. § 1681c-2 against Defendant TransUnion, based on a failure to block the
27 reporting of information resulting from an alleged identity theft; (2) 15 U.S.C. § 1681i
28 against Defendant TransUnion, based on a failure to reasonably reinvestigate disputed
1 information; and (3) 15 U.S.C. § 1681s-2(b) against Defendant Goldman Sachs, based
2 on a failure to reasonably investigate disputed reporting inaccuracies. See Compl. at 4-5
3 (ECF No. 1).
4 Plaintiff alleges that, in January 2025, she discovered a fraudulent credit account
5 had been opened with Defendant Goldman Sachs under her name as a result of identity
6 theft. Id. at 2. Plaintiff alleges she submitted an identity-theft dispute to Defendant
7 TransUnion containing a request to block the reporting of the information pursuant to
8 15 U.S.C. § 1681c-2. Id. at 2-3. Plaintiff alleges she included the following items in her
9 dispute and request to block: “FTC Identity Theft Report,” “Police Report,” “Notarized
10 Affidavit,” “Government-issued ID,” and “Proof of address.” Id. Plaintiff alleges that
11 Defendant TransUnion received and reviewed this documentation but “failed and refused
12 to block the fraudulent account.” Id. at 3.
13 Plaintiff attached various documents to her Complaint. One is a document titled,
14 “Affidavit of Truth Regarding Identity Theft,” which is addressed to Defendant
15 TransUnion as well as Equifax and Experian. (ECF No. 1 at 22-24.) The Affidavit lists
16 several financial accounts, including that identified in the Complaint’s allegations as
17 “Apple Card / Goldman Sachs Bank USA [. . .]” and states that Plaintiff “did not open,
18 authorize, or benefit from the following credit accounts that are now reported under my
19 name.” Compl. at 2, (ECF No. 1 at 22). The Affidavit indicates that Plaintiff appended to
20 it her “Government-issued ID,” “Proof of current address,” “Credit report(s) reflecting the
21 disputed accounts,” and two “FTC Identity Theft Reports.” (ECF No. 1 at 24.) The
22 Affidavit is dated April 25, 2025. Id. Plaintiff alleges that Defendant TransUnion failed to
23 block the information she identified as resulting from identity theft within four business
24 days. Compl. at 4.
25 Plaintiff further alleges she submitted a CFPB complaint each against Defendant
26 TransUnion and Defendant Goldman Sachs, which “placed Defendants on actual notice
27 of the identity theft and dispute.” Id. at 3. Plaintiff further alleges that Defendant
28 TransUnion “contacted Goldman Sachs Bank USA to verify the account.” In the attached
1 copy of Plaintiff’s CFPB complaint against Defendant TransUnion, TransUnion appears
2 to indicate that it had notified Defendant Goldman Sachs of the dispute, identifying the
3 account with Goldman Sachs (“APPLE CARD GS BANK USA”) under dispute. (ECF No.
4 1 at 10 (stating under “Company’s Response” heading that “we investigated the
5 information by contacting the creditors to verify the accuracy of the information”)).
6 However, Plaintiff alleges that Defendant Goldman Sachs “verified the account as
7 accurate despite clear evidence of identity theft” and “failed to conduct a reasonable
8 investigation.” Compl. at 3. Plaintiff alleges “[t]he fraudulent account continues to be
9 reported.” Id. Plaintiff alleges harm in the forms of damage to her credit, emotional
10 stress, and denial of credit opportunities. Id. at 3-4, 5.
11 III. DISCUSSION
12 The Fair Credit Reporting Act (“FCRA”), 15 U.S.C. §§ 1681-1681x, regulates
13 credit reporting agencies to guarantee that consumer information is assembled,
14 evaluated, and disseminated with “fairness, impartiality, and a respect for the
15 consumer's right to privacy.” Gorman v. Wolpoff & Abramson, LLP, 584 F.3d 1147, 1153
16 (9th Cir. 2009) (quoting 15 U.S.C. § 1681(a)(4)). The purpose of the FCRA is “to ensure
17 fair and accurate credit reporting, promote efficiency in the banking system, and protect
18 consumer privacy.” Safeco Ins. Co. of Am. v. Burr, 551 U.S. 47, 52 (2007). In addition to
19 regulating credit reporting agencies, the “FCRA imposes duties on the credit furnishers,
20 which are the sources that provide information to credit reporting agencies, to ensure
21 accurate credit reporting.” Arnold v. Bay Finance Co., 2023 WL 2088460, at *5 (E.D. Cal.
22 Feb. 17, 2023).
23 The FCRA imposes different penalties depending on the state of knowledge in
24 which the violation occurred. A consumer reporting agency or credit furnisher that
25 negligently violates its obligations to a consumer under the FCRA is liable to the
26 consumer for the consumer’s actual damages, plus costs and attorney’s fees. 15 U.S.C.
27 § 1681o. “’Negligence’ is ‘the failure to exercise the standard of care that a reasonably
28 prudent person would have exercised in a similar situation . . .’” Moran v. Screening
1 Pros, LLC, 2020 WL 4724307, at *5 (C.D. Cal. July 30, 2020) (quoting Black's Law
2 Dictionary (11th ed. 2019)). A consumer reporting agency or credit furnisher that willfully
3 violates its obligations to a consumer under the FCRA is liable to the consumer for the
4 consumer’s actual damages, costs and attorney’s fees, and, potentially, punitive
5 damages. 15 U.S.C. § 1681n. “A FCRA violation is willful if it is made either knowingly or
6 with reckless disregard for the requirements imposed under the Act.” Moran, 2020 WL
7 4724307, at *4 (citing Safeco, 551 U.S. at 56-60). An entity under the FCRA acts in
8 “reckless disregard” where its actions involve “an unjustifiably high risk of harm that is
9 either known or so obvious that it should be known.” Id. (quoting Safeco, 551 U.S. at 68).
10 However, “[a] plaintiff who alleges a ‘bare procedural violation’ of the FCRA, ‘divorced
11 from any concrete harm,’ fails to satisfy Article III's injury-in-fact requirement.” Syed v. M-
12 I, LLC, 853 F.3d 492, 499 (9th Cir. 2017) (quoting Spokeo, Inc. v. Robins, 578 U.S. 330,
13 341 (2016)).
14 A. Claims Under 15 U.S.C. § 1681c-2
15 15 U.S.C. § 1681c-2 requires a credit reporting agency to block reported
16 information in a consumer's file that the consumer has identified as resulting from
17 identify theft. 15 U.S.C. § 1681c-2. A credit reporting agency has a duty to block
18 information after receiving: “(1) appropriate proof of the identity of the consumer; (2) a
19 copy of an identity theft report; (3) the identification of such information by the consumer;
20 and (4) a statement by the consumer that the information is not information related to
21 any transaction by the consumer.” 15 U.S.C. § 1681c-2(a); see Nicoletta v. Experian
22 Info. Sols., 2024 WL 5046469, at *2 (E.D. Cal. Nov. 19, 2024) (holding that plaintiff
23 stated claim under 15 U.S.C. § 1681c-2 where plaintiff attached copy of letter allegedly
24 sent to defendant TransUnion, in which the letter identified the disputed account,
25 indicated that copies of driver’s license and identity theft reports were enclosed, and
26 stated plaintiff was victim of identity theft).
27 Here, Plaintiff adequately states a claim against Defendant TransUnion under
28 section 1681c-2. Plaintiff alleges that she alerted Defendant TransUnion to the existence
1 of a fraudulent bank account that she stated was the result of identity theft. Compl. at 2.
2 In support of this allegation, Plaintiff attached an “Affidavit of Truth Regarding Identity
3 Theft,” which is addressed to Defendant TransUnion, identifies an account that was
4 allegedly fraudulently opened under the label “Apple Card / Goldman Sachs Bank USA [.
5 . .],” and states that Plaintiff “did not open, authorize, or benefit from the following credit
6 accounts that are now reported under my name.” (ECF No. 1 at 22.) The Affidavit further
7 indicates that Plaintiff appended to it her “Government-issued ID,” “Proof of current
8 address,” “Credit report(s) reflecting the disputed accounts,” and two “FTC Identity Theft
9 Report[s].” Id. at 24. Plaintiff alleges that Defendant TransUnion failed to block the
10 information she identified as resulting from identity theft within four business days.
11 Compl. at 4. Thus, the Court finds that for screening purposes Plaintiff has stated a claim
12 for violation of 15 U.S.C. § 1681c-2. See Nicoletta, 2024 WL 5046469, at *2.
13 B. Claims Under 15 U.S.C. § 1681i
14 “[15 U.S.C. § 1681i] provides that consumer reporting agencies such as
15 [TransUnion] must ‘conduct a reasonable reinvestigation’ when an item in the
16 consumer's credit file ‘is disputed by the consumer and the consumer notifies the agency
17 directly . . . of such dispute.’” Warner v. Experian Information Solutions, Inc., 931 F.3d
18 917, 920 (9th Cir. 2019) (emphasis in original) (citing 15 U.S.C. § 1681i(a)(1)(A)).
19 Here, Plaintiff fails to state a claim against Defendant TransUnion under § 1681i.
20 Plaintiff makes what amounts to conclusory allegations that Defendant TransUnion failed
21 to conduct a reasonable reinvestigation. Compl. at 4. For example, Plaintiff alleges that
22 Defendant TransUnion was “on actual notice of the identity theft and dispute,” yet “failed
23 and refused to block the fraudulent account” and “instead relied on automated
24 verification procedures.” Id. at 3. Plaintiff’s brief allegation that Defendant TransUnion
25 “contacted Goldman Sachs Bank USA to verify the account” fails to clarify the nature of
26 Defendant TransUnion’s reinvestigation or the reasonableness thereof. Id. Under the
27 heading “Count II,” Plaintiff alleges that “TransUnion failed to conduct a reasonable
28 reinvestigation. . . . relied solely on creditor verification. . . . ignored Plaintiff’s
1 documentation. . . . [and] continued reporting inaccurate information,” and that “[t]hese
2 actions were willful and/or negligent.” Id. at 4. These allegations are likewise
3 conclusory.2 See Iqbal, 556 U.S. at 678; Wilson v. Experian Info. Sols., Inc., 2025 WL
4 1663287, at *3 (E.D. Cal. June 12, 2025) (holding that plaintiff failed to state section
5 1681i claim because “plaintiff's conclusory allegations that Experian failed to conduct a
6 reasonable investigation and acted willfully are not enough to state a claim”); Gonzalez
7 v. Equifax Info. Servs., LLC, 2026 WL 145700, at *2 (E.D. Cal. Jan. 20, 2026) (holding
8 that plaintiff failed to state FCRA claim because “Plaintiff's interactions with Defendants
9 are not clearly alleged” and “Plaintiff alleges in entirely conclusory manner that
10 Defendants ‘failed to reinvestigate disputes’”).
11 For these reasons, Plaintiff’s 15 U.S.C. § 1681i against TransUnion is subject to
12 dismissal. Because Plaintiff may be able to state a claim under section 1681i, the Court
13 grants Plaintiff leave to amend her Complaint to the extent Plaintiff is able to allege a
14 viable claim against Defendant TransUnion for violating section 1681i. Accordingly,
15 Plaintiff's claim against Defendant TransUnion under 15 U.S.C. § 1681i is dismissed with
16 leave to amend. See Lopez, 203 F.3d at 1130-31.
17 C. Claims Under 15 U.S.C. § 1681s-2
18 15 U.S.C. § 1681s-2 establishes the “[r]responsibilities of furnishers of information
19 to consumer reporting agencies.” 15 U.S.C. § 1681s-2. As the Ninth Circuit has
20 summarized,
Section 1681s–2(b) imposes . . . obligations [upon furnishers of
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information that] are triggered “upon notice of dispute”—that is, when a
22 person who furnished information to a CRA receives notice from the
CRA that the consumer disputes the information. See § 1681i(a)(2)
23 (requiring CRAs promptly to provide such notification containing all
relevant information about the consumer's dispute). Subsection 1681s–
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2 Presumably in support of these allegations, Plaintiff appends to her Complaint, among
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other things, copies of her CFPB complaints to Defendants TransUnion and Goldman
26 Sachs. (ECF No. 1 at 7-21.) It is not immediately apparent to the Court whether these
attachments establish a reasonable inference of unlawful conduct under section 1681i.
27 See Flores v. Missouri Higher Educ. Loan Auth., 2025 WL 2432449, at *4 n.3 (E.D. Cal.
Aug. 22, 2025) (“The Court need not sift through many pages of documents to find
28 claims for a party.”) (internal citations omitted).
1 2(b) provides that, after receiving a notice of dispute, the furnisher
shall:
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(A) conduct an investigation with respect to the disputed
3 information;
(B) review all relevant information provided by the [CRA]
4 pursuant to section 1681i(a)(2) ...;
5 (C) report the results of the investigation to the [CRA];
6 (D) if the investigation finds that the information is
incomplete or inaccurate, report those results to all other
7 [CRAs] to which the person furnished the information ...; and
8 (E) if an item of information disputed by a consumer is found
to be inaccurate or incomplete or cannot be verified after any
9 reinvestigation under paragraph (1) ... (i) modify ... (ii)
delete[or] (iii) permanently block the reporting of that item of
10 information [to the CRAs].
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§ 1681s–2(b)(1). These duties arise only after the furnisher receives
12 notice of dispute from a CRA; notice of a dispute received directly from
the consumer does not trigger furnishers' duties under subsection (b).
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14 Gorman v. Wolpoff & Abramson, LLP, 584 F.3d 1147, 1154 (9th Cir. 2009). To state a
15 claim under section 1681s-2(b), “plaintiffs must allege that they had a dispute with a
16 credit reporting agency regarding the accuracy of an account, that the credit reporting
17 agency notified the furnisher of the information, and that the furnisher failed to take the
18 remedial measures outlined in the statute.” Marsh v. Freedom Mortg. Corp., 2024 WL
19 279131, at *3 (E.D. Cal. Jan. 25, 2024) (quoting Matracia v. JP Morgan Chase Bank,
20 N.A., 2011 WL 5374776, at *3 (E.D. Cal. Nov. 4, 2011)).
21 Here, the Court finds that Plaintiff states a claim under section 1681s-2(b) against
22 Defendant Goldman Sachs. Plaintiff alleges that she contacted Defendant TransUnion to
23 dispute an account opened with Goldman Sachs in Plaintiff’s name as fraudulently
24 opened as the result of identity theft. Compl. at 2. Plaintiff alleges that Defendant
25 TransUnion notified Defendant Goldman Sachs of the foregoing dispute. Id. at 3. In the
26 attached copy of Plaintiff’s CFPB complaint against Defendant TransUnion, TransUnion
27 appears to confirm that it had notified Defendant Goldman Sachs of the dispute,
28 identifying the account with Goldman Sachs (“APPLE CARD GS BANK USA”) under
1 dispute. (ECF No. 1 at 10) (stating under “Company’s Response” that “we investigated
2 the information by contacting the creditors to verify the accuracy of the information”).
3 Based on this information, the Court concludes that Plaintiff has sufficiently alleged that
4 a consumer reporting agency, namely, Defendant TransUnion, notified Defendant
5 Goldman Sachs of the disputed information. Lastly, Plaintiff alleges that, despite being
6 notified of disputes regarding credit information, Defendant Goldman Sachs failed to
7 take the remedial measures outlined in the statute when it “verified the account as
8 accurate despite clear evidence of identity theft,” and “[t]he fraudulent account continues
9 to be reported.” Compl. at 3. Taking these allegations together, Plaintiff states a claim
10 because Plaintiff alleges that she “had a dispute with a credit reporting agency regarding
11 the accuracy of an account, that the credit reporting agency notified the furnisher of the
12 information, and that the furnisher failed to take the remedial measures outlined in the
13 statute.” Marsh, 2024 WL 279131, at *3 (holding that plaintiffs stated claim under section
14 1681s-2(b) because plaintiffs alleged (1) defendant inaccurately reported information to
15 credit reporting agency and plaintiff sent letter to reporting agency disputing the
16 information, (2) credit reporting agency responded by letter that it notified the reporting
17 company, referencing account information with defendant, and (3) defendant furnisher
18 failed to take remedial measures to rectify inaccuracies). Thus, the Court concludes that
19 for screening purposes Plaintiff states a claim against Defendant Goldman Sachs under
20 15 U.S.C. § 1681s-2(b).
21 D. Leave to Amend
22 Although the Federal Rules adopt a flexible pleading policy, even a pro se
23 litigant's complaint must give fair notice and state the elements of a claim plainly and
24 succinctly. Jones v. Community Redev. Agency, 733 F.2d 646, 649 (9th Cir. 1984). In
25 light of Plaintiff's pro se status, and because it is at least conceivable that Plaintiff could
26 allege additional facts to state claims under 15 U.S.C. § 1681i, the Court finds it
27 appropriate to grant Plaintiff an opportunity to amend her Complaint. See Lopez, 203
28 F.3d at 1130-31 (indicating that prior to dismissal, the court is to tell the plaintiff of
1 deficiencies in the complaint and provide an opportunity to cure – if it appears at all
2 possible the defects can be corrected).
3 Plaintiff may proceed forthwith to serve Defendants TransUnion and Goldman
4 Sachs and pursue Count I of her Complaint under 15 U.S.C. 1681c-2 and Count III of
5 her Complaint under 15 U.S.C. 1681s-2(b) only, or she may delay serving any
6 Defendant and attempt again to state cognizable claims against TransUnion under
7 15 U.S.C. § 1681i. If Plaintiff elects to proceed forthwith against Defendants TransUnion
8 and Goldman Sachs as to Counts I and III, then within thirty days Plaintiff must so elect
9 on the appended form. In this event, the Court will construe Plaintiff’s election as consent
10 to dismissal of her claim under Count II for violation of 15 U.S.C. § 1681i against
11 Defendant TransUnion without prejudice. Under this option, Plaintiff does not need to file
12 a First Amended Complaint.
13 Or, Plaintiff may delay serving any Defendant and attempt again to cure the
14 deficiencies identified above. If Plaintiff elects to attempt to amend her complaint to cure
15 the deficiencies identified above, she has thirty days to do so.
16 If Plaintiff elects to file an amended complaint, this new pleading shall allege facts
17 establishing the existence of federal jurisdiction and must contain a short and plain
18 statement of Plaintiff's claim. The allegations of the complaint must be set forth in
19 sequentially numbered paragraphs, with each paragraph number being one greater than
20 the one before, each paragraph having its own number, and no paragraph number being
21 repeated anywhere in the complaint. Each paragraph should be limited “to a single set of
22 circumstances” where possible. See Fed. R. Civ. P. 10(b). Forms are available to help
23 plaintiffs organize their complaint in the proper way. They are available at the Clerk's
24 Office, 501 I Street, 4th Floor (Rm. 4-200), Sacramento, CA 95814, or online at
25 www.uscourts.gov/forms/pro-se-forms.
26 The amended complaint must not require the Court and the defendants to guess
27 at what is being alleged against whom. See McHenry v. Renne, 84 F.3d 1172, 1177 (9th
28 Cir. 1996) (affirming dismissal of a complaint where the district court was “literally
1 guessing as to what facts support the legal claims being asserted against certain
2 defendants”). The amended complaint must not require the Court to spend its time
3 “preparing the ‘short and plain statement’ which Rule 8 obligated plaintiffs to submit.” Id.
4 at 1180. The amended complaint must not require the Court and defendants to prepare
5 lengthy outlines “to determine who is being sued for what.” Id. at 1179.
6 Plaintiff is informed that the court cannot refer to a prior complaint or other filings
7 in order to make the amended complaint complete. The amended complaint should be
8 titled “First Amended Complaint.” Local Rule 220 requires that an amended complaint be
9 complete in itself without reference to any prior pleading. As a general rule, an amended
10 complaint supersedes prior complaint(s), and once the amended complaint is filed and
11 served, any previous complaint no longer serves any function in the case. Lacey v.
12 Maricopa Cnty., 693 F.3d 896, 927 (9th Cir. 2012).
13 IV. CONCLUSION
14 Accordingly, IT IS HEREBY ORDERED that:
15 1. Plaintiff’s motion to proceed in forma pauperis (ECF No. 2) is GRANTED;
16 2. Plaintiff’s 15 U.S.C. § 1681i claim against Defendant TransUnion LLC is
17 dismissed with leave to amend. Within thirty days of service of this order, Plaintiff may
18 amend her complaint to attempt to state additional cognizable claims against Defendant
19 TransUnion. Plaintiff is not obligated to amend her complaint.
20 3. The allegations in the Complaint are sufficient at least to state claims under
21 15 U.S.C. § 1681c-2 and 15 U.S.C. § 1681s-2(b) against Defendants TransUnion LLC
22 and Goldman Sachs Bank USA. See 28 U.S.C. § 1915A. If Plaintiff chooses to proceed
23 solely as to these claims, Plaintiff shall so indicate on the attached form and return it to
24 the Court within thirty days from the date of this order. In this event, the Court will
25 construe Plaintiff’s election to proceed forthwith as consent to an order dismissing the
26 defective claims without prejudice.
27 / / /
28 / / /
1 3. Failure to comply with this order will result in a recommendation that this action
2 | be dismissed.
3
4 | Dated: May 11, 2026 C iy S \U
5 CHI SOO KIM
6 UNITED STATES MAGISTRATE JUDGE
7 || 8, chap.1184.26
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8 UNITED STATES DISTRICT COURT
9 FOR THE EASTERN DISTRICT OF CALIFORNIA
10
11 VERONICA S. CHAPMAN, No. 2:26-cv-01184-DC-CSK
12 Plaintiff,
13 v. NOTICE OF ELECTION
14 TRANSUNION LLC; GOLDMAN
SACHS BANK USA,
15
Defendants.
16
17
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Plaintiff elects to proceed as follows:
19
20 ______ Plaintiff opts to proceed with her 15 U.S.C. § 1681c-2 claim against
Defendant TransUnion LLC and 15 U.S.C. § 1681s-2(b) claim
21 against Defendant Goldman Sachs Bank USA. Under this option,
Plaintiff consents to dismiss her 15 U.S.C. § 1681i claim against
22 Defendant TransUnion LLC without prejudice.
OR
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_____ Plaintiff opts to file an amended complaint and delay service of
24 process.
25
26 DATED:
27 _______________________________
Plaintiff Veronica S. Lee-Chapman
28