opinions on letters please!

Hey!
I hope to be filing the following lawsuit tomorrow. I wanted some opinions/suggestions on these letters please )

I
Defendant, XXX, sent a collection notice to Plaintiff on or about DATE.
II
As is her lawful right in accordance with the Fair Debt Collection Practices Act (FDCPA), Plaintiff sent via United States Postal Service regular mail, a letter requesting formal debt validation. This letter was sent on or around DATE, well within the 30-day period expressly provided by the FDCPA.
III
Defendant failed to respond within the 30-day guideline promulgated by the Federal Trade Commission.
IV
On or about DATE, Plaintiff sent via United States Postal Service Certified Mail, with return receipt requested, a second letter requesting formal debt validation. Defendant signed for this correspondence on DATE.
V
Defendant again failed to respond within the 30-day guideline.
VI
On or about DATE, in a good faith effort to allow Defendant ample opportunity to validate the alleged debts, sent a third letter via Certified mail with return receipt requested, which was signed for by the defendant on DATE.
VII
Defendant again failed to respond.
VIII
A fourth letter was sent by Plaintiff, signed by Defendant on DATE.
IX
Defendant failed to respond.
X
During this period of time, Defendant failed to note any of the accounts with the National Credit Reporting Agencies as being disputed by consumer as is required by the FCRA.
XI
On or around DATE, two of the Defendants collection account tradelines were reported to Equifax in violation of the FDCPA, the FCRA, and an FTC staff opinion letter which clearly states that a collection agency may not report an account to the credit reporting agencies during the pendency of its verification of the account to the debtor, if the debtor has so requested.
XII
On DATE at 11:45 A.M., Defendant called Plaintiffâ??s residence and left a message on Plaintiffâ??s voice mail stating its urgency to return the phone call. Around 1:00 P.M., Plaintiff returned Defendants phone call. During which in the call the Defendant attempted to collect payment on the four alleged collection accounts. Defendant further stated that it is not their responsibility to provide debt validation.
XIII
On DATE at 8:45 P.M., Defendant again called Plaintiffâ??s residence and left a message on Plaintiffâ??s voice mail.
XIV
On or around DATE, two of the Defendants collection account tradelines were re-reported by Defendant to Trans Union in violation of the FDCPA, the FCRA, and an FTC staff opinion letter after being deleted from the credit file on DATE.
XV
On or around DATE, Plaintiff received four collection notices from Defendant demanding payment in violation of the FDCPA, which clearly states if the consumer disputes the debt the debt collector shall cease all communication of the debt until the verification is obtained and mailed to the consumer by the debt collector.
XVI
These actions on the part of Defendant demonstrate a willful disregard for federal law and constitute a blatant attempt to injure or ruin the credit rating of Plaintiff since Defendant has demonstrated an inability to validate the alleged debt and subsequently attempted to coerce payment. Plaintiff requests judgment in the amount of $5,000.00 plus accrued court costs plus permanent removal of all Defendant's collection account tradelines from Plaintiff's files with the four national credit reporting agencies (Equifax, Experian, Trans Union and Innovis).


And the offer to settle:

March 11, 2002


RE: Account:

XXX
P.O. Box XXX
XXX, XX XXXXX

To Whom It May Concern:


I regret to inform you that your company is now the target of a lawsuit do to an endless circle of grief you have caused me. You have violated the Fair Debt Collection Practices Act as well as the Fair Credit Reporting Act on multiple occasions as described in the following lawsuit. I have an extensive paper trail along with substantial proof of these violations.

I am willing to settle this matter and save us both the aggravation of fighting this out in court. I am willing to withdraw the lawsuit upon:

1. A check in the amount of $2,500.00

2. Deletion of the accounts in question from my credit file with the four national credit-reporting agencies.

3. Receipt of a letter stating the accounts will be blocked from reappearing on my credit files and will not be sold or transferred to another company.


If you wish to settle this matter, you may contact me at the address listed at the top of this letter. If you decline this offer of settlement, I will seek the full amount available in county court and a court order from the judge ordering the information to be removed. I look forward to your response.

Sincerely,

 

Anything else?

 

*bump*

 

Thanks George & Andrew!

I went down and filed the lawsuit this morning

)

 

Thanks!

I have to laugh at how nervous I was though......

I'll keep everyone posted