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Case 3:03-cv-00316-JCH

Document 98

Filed 04/08/2004

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT JOHN J. CHAPMAN v. CASE NO. 3:03CV 316 (JCH)

EXPERIAN INFORMATION SOLUTIONS, INC. CHASE MANHATTAN BANK USA, N.A.

April 7, 2004

PLAINTIFF'MOTION FOR PARTIAL SUMMARY JUDGMENT S AGAINST CHASE MANHATTAN BANK The plaintiff moves for partial summary judgment as to liability alone against defendant Chase Manhattan Bank USA, N.A. on the basis that it violated the Equal Credit Opportunity Act, 15 U.S.C. §1691(d) and the Fair Credit Reporting Act, 15 U.S.C. §1681m(a) by providing plaintiff with a false or misleading adverse action notice in connection with reducing his line of credit, and by not providing him any adverse action notice when it closed his account. Other claims against Chase involve disputed issues of fact for the jury, but there are no disputed facts as to the December 25, 2002, letter reducing plaintiff'line of credit or the circumstances surrounding the s incidents of closing his account or reducing his credit line.

THE PLAINTIFF

BY_____/s/ Joanne S. Faulkner______ JOANNE S. FAULKNER ct04137 123 Avon Street New Haven, CT 065l1-2422 (203) 772-0395 [email protected]

Case 3:03-cv-00316-JCH

Document 98

Filed 04/08/2004

Page 2 of 2

This is to certify that the foregoing was mailed on April 7, 2004, postage prepaid, to:

Thomas Stagg Simmons, Jannace & Stagg 90 Merrick Ave # 102 East Meadow NY 11554 Michelle Blum Jones Day 3 Park Plaza #1100 Irvine CA 92614-5976
___/s/ Joanne S. Faulkner___ Joanne S. Faulkner