Lashonda Whitehurst v RealPage - Amended Complaint

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IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
LASHONDA WHITEHURST, )
)
Plaintiff, ) 8:18-cv-00326-VMC-JSS
)
v. ) Judge Covington
) Magistrate Judge Sneed
RP ON-SITE LLC, )
)
Defendant. )
AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL
NOW COMES the Plaintiff, LASHONDA WHITEHURST, by and through her
attorneys, SMITHMARCO, P.C., and for her amended complaint against RP ON-SITE LLC,
Plaintiff states as follows:
I. PRELIMINARY STATEMENT
1. This is an action for actual and statutory damages for violations of the Fair Credit
Reporting Act, 15 U.S.C. §1681, et. seq.
II. JURISDICTION & VENUE
2. Jurisdiction arises under the Fair Credit Reporting Act (hereinafter “FCRA”), 15
U.S.C. §1681, et. seq., and pursuant to 28 U.S.C. §1331 and 28 U.S.C. §1337.
3. Venue is proper in this district pursuant to 28 U.S.C. §1391(b).
III. PARTIES
4. LASHONDA WHITEHURST, (hereinafter, “Plaintiff”) is an individual who was
at all relevant times residing in the City of St. Petersburg, County of Pinellas, State of Florida.
Case 8:18-cv-00326-VMC-JSS Document 14 Filed 04/02/18 Page 1 of 6 PageID 55
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