IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OKLAHOMA

1. WILLIAM DUTTON, JR.,
2. STACY WHITE, and
3. SHANNON WHITE, on behalf of themselves
and others similarly situated,
Plaintiffs,

vs.

4. WELLS FARGO BANK, N.A.,
5. EQUIFAX INFORMATION SERVICES, L.L.C.,
successor in interest to EQUIFAX CREDIT
INFORMATION SERVICES, INC.,
6. EXPERIAN INFORMATION SOLUTIONS, INC,
7. EXPERIAN INFORMATION SERVICES, INC.,
8. TRANS UNION L.L.C.,
Defendants.

EXCERPT:

CLASS ACTION ALLEGATIONS

20. Plaintiffs seek relief on behalf of the themselves and to represent the following class:

All homeowners in the State of Oklahoma who have been adversely
affected by predatory mortgage servicing and improper foreclosure
process by Defendant Wells Fargo, N.A., and are at risk of losing
their homes to foreclosure; and have suffered damage to their
creditworthiness due to the concomitant failure of Defendants credit
reporting agencies in their fiduciary duty to investigate independently
the factual accuracy of Defendant Wells Fargo, N.A.’s negative
information concerning their creditworthiness relating to home
mortgage loans between 2006 to the date of class certification in this
action.

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