IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JOI-IN L. SCI-INIEIDER, )
Plaintiff, l C.A. No. €}7»69¢l—-SLR
v. l JURY TRIAL DEMANDED
I~lOl.lSEI-IOLD FINANCE CORP. II and l
HSBC GROUP CORP. )
DEFENI)ANTS’ ANSWER TO COMPLAINT
I. Defendants admit that plaintiff purports to bring an action pursuant to the Fair
Credit Reporting Act. Ihey deny that plaintiff purports to bring any "1·elated state law claims?
All other allegations in this paragraph ofthe complaint, if any, are denied.
2. Defendants admit that this Court has jurisdiction to entertain the claims based
upon alleged violations of the Fair Credit Reporting Act. This paragraph alleges that this Court
has _jurisdiction to entertain "related state clai1ns" but no such claims are alleged.
3. Admitted.
4. Defendants are without sufticient knowledge or information so as to be able to
form a belief as to the truth of the averments contained in this paragraph ofthe complaint.
5. Admitted.
6.. Admitted.
7. Admitted.
8,. Achnitted.
zur l—323{l67¢l-l
Case 1:07-cv-00694-SLR Document 5 Filed O1/10/2008 Page 2 of 4
9. Admitted. By way of further response, at no time did Household Finance Group
II agree to delete any tradelines relating to the debt giving rise to the Court of Common Pleas
litigation.
E0. it is admitted that a Transunion report indicated that an account opened in
November 2000 was closed in March 2003 with a balance of $8,484.00. When the account was
charged off as a bad debt, it was transferred to an account ending in 459.3 for administrative
purposes. Defendants are without sufficient knowledge or information so as to be able to form a
belief as to the truth of the remaining averments contained in this paragraph of the complaint.
ll. Defendants are without sufficient knowledge or information so as to be able to
form a belief as to the truth of the averrnents contained in this paragraph of the complaint.
12. Defendants are without sufticient knowledge or information so as to be able to
form a belief as to the truth of the averments contained in this paragraph ofthe complaint.
I3. Defendants are without sufficient knowledge or information so as to be able to
form a belief as to the truth ofthe averntents contained in the last sentence of this paragraph of
the complaint. The remaining allegations are denied.
14. Defendants are without sufficient knowledge or inforrnation so as to be able to
form a belief as to the truth ofthe averments contained in this paragraph of the complaint.
15. Admitted.
16. Admitted.
17. Admitted.
18. Denied.
19. Adinitted.
20. Denied.
2
iztr 1-szstisrti-i
Case 1:07-cv-00694-SLR Document 5 Filed O1/10/2008 Page 3 of 4
2}. Denied.
22. Denied.
23. Denied.
24. Denied.
25. Denied.
26. Denied.
27. Denied.
i i. ii @2.
g A. Perkins, Jr. (#859) .
‘ -
One Rodney Square
P. O. Box 551
Wilmington, Delaware l9899
302 651-7700
Attorneys for Defendants
Dated: .Ianueu*y 10, 2008.
3
R.; F 1 -3230674-I
Case 1:07-cv-00694-SLR Document 5 Filed O1/10/2008 Page 4 of 4
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
CERTIFICATE OF SERVICE
1 hereby certify that on January EO, 2008, I electronicaily Eied the foregoing document
with the Cierk of Court using CM/EGF which will send notification of such iiling(s) by E—mail
and U.S. Reguiar Mail to the foliowing:
BY E—l\/IAIL AND U.S. REGULAR MAIL
Sandra E. Messick, Esquire
UAW Legal Services i’1an
200 Continental Drive
Suite 212
Newark, DE 19713
n A. Perkins, Jr. (#859)
hards, Layton 62 Ping , . * .
. ne Rodney Square
PO. Box 55i
Wilmington, Delaware 19899
(302) 65l~77OO
Pa1"kins@1’1f,con1
mars-2230674-1
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