Acorin

I. BACKGROUND

26 In January 2020, while on deployment in Korea as an Army servicemember, Plaintiff 27 discovered fraudulent transactions on her Wells Fargo Credit Card, exceeding her limit. 28 (Complaint, Doc. No. 1, ¶¶ 27, 29, 30.) Plaintiff immediately contacted Wells Fargo to dispute the transactions and request the closure of her Wells Fargo account, but this request was denied. (Id. ¶¶ 31–32.) Plaintiff was informed she was required to go to a Wells Fargo branch in person to make said request, despite her deployment. (Id. ¶ 32.) Thereafter, in April 2020, an unknown and unauthorized individual, using Plaintiff’s personal information, took out a loan through Wells Fargo in the amount of $10,800.00. (Id. ¶ 34.) Wells Fargo refused to close Plaintiff’s account until the fraudulent balance was paid off. (Id. ¶ 37.) As a result, Wells Fargo began reporting the fraudulent balance of both the credit card and the loan to Consumer Reporting Agencies, damaging Plaintiff’s credit. (Id. ¶ 40.) On November 25, 2020, Plaintiff sent a dispute letter to EIS reporting the fraudulent information. (Id. ¶ 41.) EIS never responded to Plaintiff’s…