How to word a pay to remove?

Seems to me that you are wanting to do that which is nearly impossible in this type of situation which is trying to kill 2 birds with one stone.

The problem with trying to do that is you can't easily force either entity to remove the listing put on your credit reports by the other. It can be accomplished in the course of settling a federal lawsuit against the debt collector by demanding a strict no disclosure statement which applies to both parties, i.e. both the creditor and the debt collector. Even then the process of roping both of them into the lawsuit is not all that easy because the creditor is liable under FCRA but not under FDCPA so it may take two separate suits to get the job done even then.

Your state laws may allow you to do that easier than federal law does. It may be best to sue the debt collector in federal and get rid of them and their listing in the process using the strict disclosure statement when you get to the Rule 26(f) meetings then once that is settled do a dispute with the credit bureaus and if they respond sue them again for violating the strict disclosure agreement.

Once the federal lawsuit is concluded you could attempt to use the Westcap endorsement to force the original creditor to remove their listing as a pay for delete method. As far as I know that may be the only way to get rid of all the listings from both parties.

Actually, I tend to think that if I were ever faced with having to try to do that I'd rather try the Westcap method with the original creditor first and let them get rid of their debt collector themselves. Then if I couldn't get them to go along with it I'd go after the debt collector in federal court as I have outlined above.

I'm sure others will enter into this discussion and they may have better methods or have ideas that you might like better. We will just have to see what others might have to offer in the way of suggestions as well.