How to word complaint for small claims suit?

I am filing a small claims suit against a collection agency because they are continuing to report (monthly) a debt as unpaid/past due/with $9999 balance 6 months after they were notified of the CH. 7 bankruptcy discharge for this debt. I disputed the debt with Experian and the collection agency responded stating that the debt is valid and being reported accurately. Therefore, this tradeline remained unchanged.
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I need some advice on how to word my small claims complaint since they only give you about 2 inches of space to write it.

Here is what I was thinking of writing for the complaint:
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Defendant violated bankruptcy discharge order by continuing to report a debt as past due with a balance of $9999 after the debt was discharged on 05/02. Experian contacted defendant on 10/02 for validation purposes and they refused to provide the correct information to update my credit report properly. Therefore, defendant furnished inaccurate information to Experian. Per the FCRA, defendant is prohibited from reporting information to a CRA with actual knowledge of errors. Defendant willfully failed to comply with the FCRA. Defendant has negatively affected my credit worthiness by reporting an inaccurate delinquent outstanding balance.
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Does this look like a good complaint for small claims? Also, I am seeking $1,000 + Court Cost's. Is this too much or too little?

Do I have a good case here? Or, is this not enough of a violation/damages to win in court?

FYI: The collection agency is called "The Bureaus" in IL. They responded to a possible legal action letter I sent them asking for deletion of the trade line or $1,000 for FCRA violations. I received their letter yesterday and all they offered to do is immediately update my credit report with the correct info. However, I still want to sue them for FCRA violations from the past 6 months that they were reporting inaccurately. Is it still possible to sue under these circumstances since they are now agreeing to fix the problem?

Thanks in advance for any advice on this!!!!!!!!!!!!!
Christine....Great Site!!!

Sue for the FDCPA violations instead - you get the statutory damages and $1,000 sounds good.

Generic FDCPA $1,000 demand letter (http://www.bayhouse.com/credit-forum/showthread.php?s=&threadid=1066)

Based on BBB files, this company has an unsatisfactory record with the Bureau due to a pattern of unanswered complaints.

SEnd them a 48 hour intent to sue letter. In in let them know the courts will be made aware of theur crappy BBB file. Also let them know that they must send you and the 3 CRAs a letter stating the account was placed in error on your credit report and must be deleted. You could nail them for fcra and fdcpa violations but I am too dang tired to list them all. It sounds much more impressive when you list the exact statutes they have violated. I have sent out about a dozen of those. AFter 48 hours I usually follow up with a call which I do not recommend unless you can handle yourself. I usually ask for someone in their legal department or a floor manager. In 11 of the 12 cases they caved either from that call or my letter. The 12th decided the laws did not apply to them. I sued. Their lawyer called with a settlement. I win. If you make it seem like you want the money they may fight. If you give them a free out like a deletion they may take that much easier. You may also let them know they are violating federal bankruptcy law and you will also let the attorney general of their state and your state know, the BBB, and the FTC. Also let them know you will be sueing them for slander and defamation of character along with punitive damages plus attorney fees.

Originally posted by Christine
Sue for the FDCPA violations instead - you get the statutory damages and $1,000 sounds good.

Hey, newbie here..good to be here..

Ok Chistine...is not it good to sue under FCRA...I'm presently doing my suit and i'm suing under both FCRA and FDCPA. Is that a good combo. The CA has more FDCPA and about 1 or 2 FCRA vio's. What' da ya think.

I'M a TeChi3 t2o :D

The problem is that debtors are prohibited by section §623(c) from suing for violations of the FCRA § 623(a). You could try §623(b), for failing to verify a dispute, but I would stick with the FDCPA, as I have had more success with that. That being said, I usually include the FCRA §623(b) in the suit, but I rely primarily on the FDCPA and on state collection laws, as they are easier to prove.

See section 623(c), below:

(c) Limitation on liability. Sections 616 and 617 [§§ 1681n and 1681o] do not apply to any failure to comply with subsection (a), except as provided in section 621(c)(1)(B) [§ 1681s].

Thanks for the reply. I'm suing in Circuit Court in a couple days after I get the results from the CRA about the dispute. So is it 1000 per violation right... this CA has about 5 violations. I hope the judge orders a good some of $$ for punitive damages, because I'm trying to get a job and they are checking my CR in a couple of days and i'm affraid that they will deny me employment.