[NY] What points should be reviewed for accuracy before filing a motion for summary judgment in a consumer protection case?

I'm a Plaintiff Pro Se in Civil Court litigation under FCRA violations. I'm going to file a Motion for Summary Judgment pursuant to NY CPLR 3212. My goal is to have my motion reviewed to see if there are any flaws within my motion and what should I add or omit from it.

Sure, this is a case that involves FCRA violations under sections 616 and 617. The Defendant's culpability is clear as they placed inaccurate loans on my credit reports and refused to comply with the Fair Credit Reporting Act after receiving documentation from myself and two separate companies that the loans were inaccurate. The Defendant has not denied their culpability. Hence, why I am filing a Motion for Summary Judgment pursuant to NY CPLR 3212.

I have drafted the motion and can submit it here.

Yes, my action is to file a motion for summary judgment. The court has already received my endorsed complaint. This case has gone on for almost a full year in the courts. The Court requested in December of last year for me to structure my endorsed complaint over which I have done. I am filing the motion because it has been established that the Defendant violated my rights under FCRA sections 616 and 617. I am looking for my motion to be reviewed to see if there are any glaring defects within it that the court would not be able to overlook.

Sure. I am handling this case in New York in Queens County. My argument is that the Defendant, a student loan company, violated my rights under FCRA 616 and 617 after they were sent repeated documentation from myself, my university, and the National Student Loan Data Systems that the loans they placed on my credit reports were inaccurate and fraudulent and needed to be removed from my credit reports. The Defendant refused to comply with the FCRA. I am not suing the Defendant for fraudulent loans. I am suing solely for FCRA violations. The Defendant and their Defense counsel are not contesting the FCRA violations. The Defendant is trying to argue each time a CPLR inaccuracy within my papers. My Exhibits and the Defendant's Exhibits both establish that the Defendant placed inaccurate loans on my credit reports.

Sure, if you can review the first pages of my motion, I need to know if there are any glaring issues. Something that I should add. Something I should omit. I am aware that under NY CPLR 2001 the court may overlook mistakes I may have made in my motion if they are not prejudicial to the Defendant.

1. Plaintiff, the Plaintiff, is filing a Motion for Summary Judgment per New York CPLR 3212 as the Plaintiff has established through his endorsed complaint the following.
2. Plaintiff, in compliance with the Court ruling on 12/15/2025, stated his endorsed complaint pursuant to CPLR 3025 (b) stated that litigation commenced against the Defendant for Fair Credit Reporting Act Violations and is seeking Compensatory damages for lost wages, Statutory damages for violations of Plaintiff's rights under FCRA § 617, Civil liability for negligent noncompliance [15 U.S.C. § 1681].
3. Under FCRA § 616 Civil liability for willful noncompliance and Punitive damages under FCRA § 616 Civil liability for willful noncompliance [15 U.S.C. §1681n] after the Defendant received multiple times documentation that the two loans with the origin amount of $3,000 the Defendant placed on the Plaintiff's credit reports were inaccurate and needed to be removed.
4. That the Defendant has not deny culpability or nor financial responsibility for violating the Plaintiff's rights under the Fair Credit Reporting Act U.S.C. § 1681.
5. Plaintiff will state this act as simply the Fair Credit Reporting Act for all future references as allow under § 601.
6. As the Queens Civil Court is the body that has the jurisdiction to rule on this matter as stated under § 618 Jurisdiction of courts [15 U.S.C. § 1681p] the Plaintiff will present the facts that highlight the Defendant violated the Plaintiff's rights under the Fair Credit Reporting Act.
7. Under NY CPLR § 3017 the Plaintiff is requesting the court to grant with the Motion for Summary Judgment the relief of $17,990 plus interest due to lost wages and statutory damages by Defendant's actions for violating the Plaintiff's rights under FCRA § Civil liability for Willful Noncompliance and FCRA § 617 for Negligent Noncompliance that started on 03/01/2024.
8. Through Defendant's own Exhibits previously received by the court, the Defendant has acknowledged that they violated my rights under the Fair Credit Reporting Act by placing inaccurate loans on my credit reports, such as the major credit reporting agencies.

Thank you Seth. I believe I have what I need to move forward with my motion.