ANSWER

Defendant Trans Union, L.L.C., by and through undersigned counsel, hereby responds to Plaintiff's Complaint and denies the allegations asserted by Plaintiff and any liability to Plaintiff because it has not violated the federal Fair Credit Reporting Act, 15 U.S.C. 1681 et seq. Defendant denies each and every allegation of Plaintiff's complaint not expressly admitted to herein.

AFFIRMATIVE DEFENSES

As and for its affirmative defenses, Defendant affirmatively asserts, as follows:

A. The Complaint fails to set forth facts sufficient to state a claim upon which relief may be granted against Defendant, and further fails to state facts sufficient to entitle Plaintiff to the relief sought, or to any other reliefwhatsoever, from Defendant;

B. Upon information and belief, some or all of the purported damages allegedly suffered by Plaintiff are the results of the acts or omissions of third parties/persons over whom the Defendant had neither control nor responsibility;

C. Plaintiff has failed to mitigate her damages;

D. Upon information and belief, some or all purported damages allegedly sustained by Plaintiff were, at least in part, caused by the actions or inactions of Plaintiff herself and resulted from Plaintiff's own neglegence which equaled or exceeded any alleged negligence or wrongdoing by Defendant;

E. All Plaintiff's claims against Defendant are barred because Defendant complied with all statutory requirements;

F. The Complaint and each claim for relief therein is barred by laches, waiver, estoppel and/or unclean hands;

G. Upon information and belief, Plaintiff's claims against Defendant in the Complaint are barred by the provisions of 15 U.S.C. 1681p, the applicable statute of limitations.

H. At all relevant times, Defendant maintained and followed reasonable procedures to assure compliance with statutory requirements and maximum possible accuracy of the information concerning Plaintiff in preparing consumer reports; and

I. Defendant reserves the right to assert such other and additional affirmative defenses available to it, pursuant to Ariz. R. Civ. P. Rules 8 and 12 and Fed. R. Civ. P. Rules 8(c) and 12(b), at such time and to such extend as is warranted and as may be revealed through disclosure, discovery and the factual development in this matter.

WHEREFORE, Defendant respectfully requests that this Court dismiss Plaintiff's Complaint in its entirety as against it, and grant judgment in its favor, together with an award of attorneys' fees and costs incurred in defense of this action pursuant to the Fair Credit Reporting Act, 15 U.S.C. 1681n and 1681o, and for any such further relief as the Court deems proper under the circumstance.

RESPECTFULLY SUBMITTED this 17th day of October, 2001.

Renaud, Cook & Drury, P.A.

(signature)
LeslieAnn Haacke

Paul L. Myers, Esq.
Amanda Stamps, Esq.
Strasburger & Price, L.L.P.
Attorneys for Defendant Trans Union, L.L.C.