In a pro se suit under the Fair Credit Reporting Act (FCRA), Johnson alleged that Experian failed to accurately update his credit report to reflect an accommodation provided by his creditor during the COVID-19 pandemic.
Walker moved pursuant to Federal Rule of Civil Procedure 12(f) to strike the affirmative defenses raised by LVNV, arguing that the Iqbal/Twombley pleading standards apply to affirmative defenses. Finding no controlling case law, the court rejected this relying on Liles v. Wyman (E.D.N.C. 2019) as motions to strike " are generally viewed with disfavor because striking a portion of a pleading is a drastic remedy".
