 65.  Plaintiff incorporates the foregoing paragraphs as though the same were set forth at  length herein.   66.  Defendant is a “person” and “consumer reporting agency” as defined by sections  1681a(b) and (f) of the FCRA.   67.  Plaintiff is a “consumer” as defined by section 1681a(c) of the FCRA.   68.  The above-mentioned reports are “consumer reports” as defined by section  1681a(d).   69.  Pursuant to sections 1681n and 1681o, Defendant is liable for willfully and  negligently violating the FCRA by failing to follow reasonable procedures to assure maximum  possible accuracy of the information concerning the individual about whom a consumer report  relates, in violation of section 1681e(b).   )  SERVICES CORP.,   )  )  Defendant.  )  Jury Trial Demanded  ) 