Complaint/Equivalent Pleading Filed - 24-101542 COMPMCM June 25, 2024 (2024)

Complaint/Equivalent Pleading Filed - 24-101542 COMPMCM June 25, 2024 (1)

Complaint/Equivalent Pleading Filed - 24-101542 COMPMCM June 25, 2024 (2)

  • Complaint/Equivalent Pleading Filed - 24-101542 COMPMCM June 25, 2024 (3)
  • Complaint/Equivalent Pleading Filed - 24-101542 COMPMCM June 25, 2024 (4)
  • Complaint/Equivalent Pleading Filed - 24-101542 COMPMCM June 25, 2024 (5)
  • Complaint/Equivalent Pleading Filed - 24-101542 COMPMCM June 25, 2024 (6)
  • Complaint/Equivalent Pleading Filed - 24-101542 COMPMCM June 25, 2024 (7)
  • Complaint/Equivalent Pleading Filed - 24-101542 COMPMCM June 25, 2024 (8)
  • Complaint/Equivalent Pleading Filed - 24-101542 COMPMCM June 25, 2024 (9)
  • Complaint/Equivalent Pleading Filed - 24-101542 COMPMCM June 25, 2024 (10)
 

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45D04-2406-CC-006373 Filed: 6/25/2024 5:40 AM Clerk STATE OF INDIANA Lake Superior Fourt, CiviLOMiSCRECUIT COURT Lake County, Indiana ) SS: COUNTY OF LAKE ) Case Number: MIDLAND CREDIT MANAGEMENT, INC. Plaintiff v. KAREN HOLM Defendant COMPLAINT. Plaintiff, MIDLAND CREDIT MANAGEMENT, INC., by counsel, sues Defendant KAREN HOLM , under Account Stated and in support thereof states: 1 Plaintiff is authorized to file this Complaint in this Court. Plaintiff owns portfolios of consumer receivables, which it attempts to collect. Plaintiff strives to treat its consumers, such as Defendant, with respect, compassion and integrity, hoping to provide mutually-beneficial opportunities for consumers to repay their debts and attain financial recovery. 2. Defendant is subject to this Court's jurisdiction. COUNT 1 3. Defendant established an account with COMENITY CAPITAL BANK under redacted accountnumber XXXXXXXXXXXXX-7788. 4.Defendant was provided statements delineating Defendants use of the account and stating thecurrent balance due. 5. Defendant defaulted on the account. 6. A statement of account balance was sent to Defendant and not paid. 7. The amount due under this account is $1,007.63. COUNT 2 8. Defendant established an account with COMENITY CAPITAL BANK under redacted accountnumber XXXXXXXXXXXXX-3552. 9. Defendant was provided statements delineating Defendants use of the account and stating thecurrent balance due. 10. Defendant defaulted on the account. 11. A statement of account balance was sent to Defendant and not paid. 12. The amount due under this account is $832.08.GL_0100M File No.:24-101542 SCP13. Plaintiff has acquired all right, title and interest to Defendant's accounts, and has attempted to contact Defendant through several means in an effort to resolve the account with Defendant, but has been unsuccessful. Defendant has not repaid the balance owed on the accounts. Plaintiff remains willing to discuss various options to resolve the outstanding obligation, although the options may be different than they were prior to the initiation of litigation. 14. Defendant owes Plaintiff the combined balance of $1,839.71 15. In support of the allegations, Plaintiff incorporates herein by reference the attached Exhibits. The undersigned certifies that this and any attached document complies with the requirements of Trial Rule 5(G) with regard to information excluded from the public record under Administrative Rule 9(G). WHEREFORE, Plaintiff requests judgment against the Defendant for $1,839.71 and costs of the action and post judgment interest at the stagt\ory rate. By: JOHN /GILLESPIE Bar No. 31983-497 iy ON E. TAYLOR Bar No. 30160-22 Aftorneys for Plaintiff OX 70069 Ou! VILLE, KY 40270-0069 Rho + (866) 300-8750 X (855) 488-1523 E mail: IL_IN@memcg.com PLEASE UNDERSTAND THIS COMMUNICATION IS FROM A DEBT COLLECTOR THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.GL_O100M File No.:24-101542 SCPAFFIDAVIT OF DEBT Comes now affiant, and states: I, Jeanette Ruff, am of adult age and am an employee of Midland Credit Management, Inc. "Plaintiff" or "MCM"), and am fully authorized by Plaintiffto make the following representations. 1 am familiar with the recordkeeping practices of Plaintiff. The following representations are true according to documents kept in the normal course of business and/or my personal knowledge. Thave access to and have reviewed the electronic records pertaining to the account maintained by MCM and am authorized to make this affidavit on MCM's behalf. The electronic records reviewed consist of (i) data and records acquired from the seller or assignor when MCM purchased or was assigned the account, which were incorporated into MCM’s business records upon purchase or assignment, and (ii) data and records generated by MCM in connection with servicing the account since the date the account was purchased by or was assigned to MCM. In addition, I reviewed the documents that are attached to this affidavit. ) The Plaintiff has obtained this debt from COMENITY CAPITAL BANK and the original creditor of this debt was COMENITY CAPITAL BANK. Evidence of the debt, as required in Rule 9.2(A) (2), is attached as one or more Exhibits to this Affidavit. 2) KAREN HOLM, Defendant, had an account balance of $1,007.63 as of 2024-05-01, which is owed to Plaintiffon account XXXXXXXXXXXXXX7788 (hereinafter "the Account"). 3) MCM'‘s records show that the Account was opened on 2020-05-31 and the last payment posted to the Account on 2021-04-14 in the amount of $100.00. MCM's records show that the Defendant defaulted on the Account on or after 2021-07-04 and the Account was charged off on 2021-12-31. 4) The type of account is: Credit card account (e.g. Visa, MasterCard, Department Store). Company issuing credit card: COMENITY CAPITAL BANK (] Other: 5) The account balance includes: MCM's records show that there are no late fees after 2022-01-19. Interest at a rate of 0% beginning on 2021-12-31. 6) The Plaintiffis not seeking attorney's fees. 72) MCM's records do not show that Defendant is a minor or mentally incapacitated person 8) If the Defendant is an individual, Plaintiff states and declares that pursuant to the attachment, Defendant is not in active duty status of the military. (“Active military service” includes fulltime duty in the military (including the National Guard and serves) and, for members of the National Guard, service under a call to active service authorized by the President or Secretary of Defense. For further information, see the definition of “military service” in the Servicemembers Civil Relief Act, as amended, 50 U.S.C.A. Appx. §521.) AFFIDAVIT OF JEANETTE RUFF - 1COUT vb MEN vata mit UOTE OAD ATTAC. '4-1015429) As set forth in the records attached hereto, the complete chain of title including COMENITY CAPITAL BANK, the original creditor, and all post-charge-off purchasers/assignees of the debt are as follows: 1 COMENITY CAPITAL BANK 2022-01-19 2. Midland Credit Management, Inc. 10) Attached hereto are the following records regarding the Account: a) Bill(s) of Sale, Assignment and/or Affidavit(s) of Sale b) Seller data sheet reflecting the individual Account information from the electronic records provided by the seller or assignor pursuant to the Bill(s) of Sale, Assignment(s) and/or A{fidavit(s) of Sale in connection with the sale or assignment of the Account to Plaintiff c) Records regarding the Account and/or payments received: i) Contract, application, or other document evidencing the consumer's agreement to the debt; and/or ii) Statement(s) and/or Account records reflecting: 1) the charge-off balance; and 2) the last purchase transaction, payment, or balance transfer. 1) The documents attached hereto are true and correct copies of the originals, being a reproduction of Plaintiffs records, based upon my review, except to the extent that confidential and privileged information and/or personal identifying information is omitted or redacted as required by local rules, and applicable state and federal law. 1 swear or affirm under the penalties of perjury that the foregoing representations are true. JUN 0 7 9978 Date Jeanette Ruff ont A CA137 AFFIDAVIT OF JEANETTE RUFF - 2FORDE I REO EEN AN IACONO EN AFFRECATTACHEXHIBIT A BILL OF SALE Comenity Capital Bank (“Seller”), for value received and pursuant to the terms and conditions of that certain Credit Card Account Purchase Agreement dated October 25, 2019 between Seller and Midland Credit Management, Inc. (“Purchaser”), its successors and assigns (“Credit Card Account Purchase Agreement”), hereby assigns effective as of the Closing Date of January 19, 2022 all rights, title and interest of Seller in and to those certain Accounts described in the Credit Card Account Purchase Agreement and Schedule | (the “Asset Schedule”) attached hereto and made part hereof for all purposes, to Purchaser. The information contained in the Sale File (collectively, “Seller's Accounts Information”) is true and complete as of the File Creation Date. Further, all of the information contained in Seller's Accounts Information (a) constitutes Seller’s own business records regarding the Accounts and (b) accurately reflects in all material respects the information about the Accounts in Seller’s possession. All of Seller’s Accounts Information has been kept in the regular course of Seller's business, and was made or compiled at or near the time of the event and recorded by (or from information transmitted by) a person (i) with knowledge of the data entered into and maintained in Seller’s business records, or (ii) who caused the data to be entered into and maintained in Seller’s business records. All capitalized terms used, but not defined, in this Bill of Sale shall have the meanings assigned to such term in the Credit Card Account Purchase Agreement.This Bill of Sale is executed without recourse except as stated in the Credit Card Account Purchase Agreement to which this is an Exhibit. No other representation of or warranty oftitle or enforceability is expressed or implied.COMENITY CAPITAL BANK Midland Credit Management, Inc.By: ay: (Dinalle M4 Dat 3/2/2022Title: Chief Credit Officer Title VP of BDSCHEDULE 1 TO BILL OF SALE ASSET SCHEDULEThe individual Accounts transferred pursuant to the Credit Card Account Purchase Agreement andBill of Sale are described in the electronic file namedMCMG_HF_JAN_2022_DPL_CCB.TXT;MCMG_HF_JAN_2022_LCS_CCB.TXT delivered byComenity Capital Bank to Midland Credit Management, Inc, on January 12, 2022 andsummarized in the table immediately below (the “Sale File”). # of Charged-off Accounts Aggregate Unpaid Balance Percent File Creation Date . 11172022EXHIBIT B CLOSING STATEMENTAGREEMENT DATE: October 25, 2019SELLER: COMENITY CAPITAL BANKPURCHASER: Midland Credit Management, Inc. MCMG_HF_JAN_2022_DPL_CCB.TXT;FILE NUMBER: MCMG_HF_JAN_2022_LCS_CCB.TXTNUMBER OF ACCOUNTS:TOTAL UNPAID BALANCE:PURCHASE PRICEPERCENTAGE:PURCHASE PRICE:FILE CREATION DATE: January 11, 2022CLOSING DATE: January 19, 2022WIRING INSTRUCTIONSPORTFOLIO LEVEL AFFIDAVIT OF SALE'BY ORIGINAL CREDITORSTATE OF: UTAHCOUNTY OF: SALT LAKEOn[ bf 22 ;, Bruce Bowman (“A ffiant”) being duly sworn, deposes and says: Tam over 18 and I am the Chief Credit Officer of Comenity Capital Bank (“Seller”). In that capacity and as part of my regular job duties, | have custody of certain business records of Seller, routinely review such business records, and am familiar with Seller’s processes for the sale and assignment of accounts and business records, including those that are maintained in electronic form. Seller owns certain accounts, and maintains and records information in the records as they relate to such accounts. | am authorized to make the statements and representations set forth in this affidavit on behalf of Seller. The statements set forth herein are true and correct to the best of my knowledge, information, and belief, based on either personal knowledge or review of the business records of the Seller. If called upon as a witness, I can testify competently to the facts contained herein. My regular job duties include having knowledge of, and access to, business records relating to the Accounts (as defined below). These records are kept by Seller in the regular course of business, and it was in the regular course of business of Seller, for an employee or representative with personal knowledge of the act, event, condition, or opinion recorded to make memorandum or records or to transmit information thereofto be included in such memorandum or records; and that the records were made at or near the time of the act and/or event recorded or reasonably soon thereafter. On or about 01/19/2022, Seller sold a pool of charged-off accounts (the “Accounts”) bya Credit Card Account Purchase Agreement to Midland Credit Management, Inc. (“Buyer”). The original creditor at the time of charge-off was Comenity Capital Bank. Pursuant to the sale, Seller sold, transferred, assigned, conveyed, granted, bargained, set over and delivered to Buyer and its successors and assigns, good and marketable title to the Accounts and any unpaid balance free and clear of any encumbrance, equity, lien, pledge, charge, claim or security interest. 1 am not aware of any errors in the Accounts.6." In connection with the sale of the Accounts, electronic and other records were transferred to or otherwise made available to the Buyer (the “Transferred Records"). The Transferred Records have been kept in the reguiar course of Seller’s business, and were made or compiled at or near the time of the event and recorded by (or from information transmitted by) a person (i)with knowledge of the data entered into and maintained in Seller’s business records, or ii) who caused the data to be entered into and maintained in Seller's business records. To the extent that the Transferred Records include records that were prepared by a third party, they are records that were incorporated into the records of Seller as a business record and the accuracy of such records are relied upon by Seller in the regular course of business.7. 1 certify under penalty of perjury that the foregoing is true and correct.FURTHER AFFIANT SAYETH NOT.Signed this 13. iday-of” Erin, » 2022.Bruce Bowman TAPFIANT NAME)Comenity Capital BankSubscribed, and sworn =. to before me this day of Telouna, 2022, by ,an employee of Comenity Capital Bank Soe AU Public JENNIFER PARDUE Notary Public « State of Utah G) ‘Comm, No. 718844 ‘dy Commisston Expires on nt 7 202:CERTIFICATE OF CONFORMITYSTATE OF UTAHCOUNTY OF SALT LAKEThe undersigned does hereby certify that he is an attorney at law duly admitted to practice in theState of Utah and is a resident of Utah, County of Salt Lake, Utah; that he is a person dulyqualified to make this certificate of conformity; that the foregoing acknowledgment by BruceBowman named in the foregoing instrument taken before Jennifer Pardue a notary in the State ofUtah duly conforms with the laws of the State of Utah, being the State in which it was taken; andwhen executed by Mr. Bowman in the manner indicated will qualify as a valid and effectivesworn statement in such state. 2+ |1-LOA2 Newey LutonDate Attorney at [aw for the State of UtahField Field DataAccount NumberSeller Account ID 7762First Name KARENLast Name HOLMSSN Hl i -6733Date of BirthAddress 1 158 N COURT STCity CROWN POINTState INZip 46307Home PhoneOpen Date 05/31/2020Last Purchase Date 11/05/2020Last Purchase Amount $202.65Last Payment Date 04/14/2021Last Payment Amount $100.00Sale Amount $1,007.63Charge Off Date 12/31/2021Charge off Balance $1,007.63Post Charge Off interest $0.00Post Charge off Fee $0.00Post Charge off Payments $0.00Post Charge off Payments and Credits $0.00Post Charge off Credits $0.00Affinity GRANDIN ROADAccount information provided by Comenity Capital Bank pursuant to the Bill of Sale/Assignment ofAccounts transferred on or about 01/19/2022 in connection with the sale of accounts from ComenityCapital Bank to Midland Credit Management, Inc.MCMG_HF_JAN_2022_DPL_CCB.TXT; MCMG_HF_JAN_2022_LCS_CCB.TXTPAGE OF « ree See Gem won im‘Account no. New balance ‘$1,007.83 Micienum payment due $322.00Previous balance $947.50 Payment due date ovosrz022Payments 0.00Other credits 0.00 Late payment warnin 0.00 twedo not receive your minimum payment by 01/04/2022 you mayOther debits 0.00 have 10 pay up 1o 8 $98.00 lateFees charged 38.00 Minimum payment warning: If you make only the mi I charged ent or ech ped, you wi ey more fart end wl ake ne 80783 ‘you longer to pay otf your balances. For example:Past due ammount 272.00 you mai no addivonal ‘You will pay off ‘And you willCroc rit $500.00 cchorgesusing this card the balance shown] end up paying an]Avaitable credit $0.00 and ich manth you pay: on the atatement iroated totalStatement closing date s2/09/2021 In about: ofDays in biting cycle 3 ‘Only tne minimum payment ayers ‘i867 For information regarding credit counseling services, call $-800-284-1706, ‘Skip signing in to pay and use Comenity’s EasyPay. It's safe and convenient. Use your smartphone cameraor code reader to scan the GR code printed on your payment stub below to get started.CORInriertarens as = — anTRANS OATE "TRANSACTION DESCRIPTIONA.OCATION wsFeess2nweo21 LATE FEE 38.00 Total fees charged for this period $38.00 be so otinterest charged Interest charge on purchases °? saaas Total interest for this period $2213 2021 tolats year to date Totat fees charged in 2021 $414.00 Total intorast charged in 2021 $192.81‘Your Annual Percentage Rate (APR) is the annual interest rate on your account, See BALANCE COMPUTATION METHOD.‘on page 2 for more delails. Minimum interes! charge may exceed interest charge elon, a! your re card apeemantTyee oFBALANCE ANCE SUBJECT wwrentst an SOiwtencat nae "CHARGEPurchases 26.9000% () 965.45 22.13Effective February 2, 2022, the cutotf times for payments to be credited on the samo day when thapayments are made over the phone and online are changing. Telephone and online Account Centerpayments made by 5:00 pm Eastem Time wil post on the same day. Please see the information provided(on the backof the first page of your statement lor more details about payment cutol! times. (conTiNvED, Pieeee tear at perioration above + nooo TTB me umber grandinroad ‘New balance $1,007.63 ‘wirnar payers $322.00 98 Yes, | have moved or updated my Mailed01 ments must reachus by 6pm ET oO address - gee reverse. Amount on e022 .. Pease make check payable 16 ag tyo odo tN flfefeat COMENITY - Grandin Road Militia WAREN HOUM Please return this portion along with your payment fo: 158. PO BOX 650967 GROWN POINT I 46907-3952 DALLAS TX 75265-0967 I Dealt tity Headset attposgat taal dL44301006 oooossis W778 000032200 00010073Keep tia podion Tor your records {CREDIT REPORTING. We may report information bout you What Too I You Thine You Find MistakeOn Yow Statement ‘ret buneavs, 1 you WieBark tarePO Borisan 182620, ever on fement, rite Io we at: Comenity ‘ay be Larelleeed le payed in your eect poymenia, reer o ODer deals On yout (ailal OH 43216-2620. NOTICE OF CREDIT REPORT DISPUTES tn yur lett, pve wa the flowing inlormalion: yu baie the aceon elomation we reper to census iy eer 2 fecount formation. Yor name al account mater a dueet dapuieYos wen ae apa ‘Dollar aroun a dole amount ol the ursected era Ea Weenies” ‘mal provide sullen "kt Ou 430182120. * Descript of rset you thik Deve iam eer on your bil nd soy why frac whol you Believe wer and why you belie is 8 meta, :bre formation niraccurie You rene re ec abet ‘Yu tatermust contact with 60 dae aller Ube ever appearedon your ‘+ Contact Information: You accreted telephone pubes * Disputed infermation: Kenly Ho secant inlernaion dpated ans ‘You must rail ws of any potent ere in writing. You may ea vt, ba «esau ble i acer Feeyou loUo wepay theotaut veiuued lo iwestigele yo may * fetal pot dueeng a scout revi maton 8 copyfoo weol thesavetng salon of Wiewee we iovestigte whether nol there Ras ben an er, the olowing ioe the Sapte nemation on ep te rey Oe onl ry to collec! the amet in questan, or pot you ws within 30doleof ‘or eliauent on Bal amour lone reported i cure, wil + The cher in cation may frei on your sateen, enotyTo pronase ager wnich we veporied te infemmation,| corer escheorce paring continue te charge you inivest on ha! mou. Bul, ite determithat PAYMENTS MARXED “PAID IM FULL. WI writen communica ‘= rode 2 mista, you wil ot have lo pay te amount in quaslion or sunt a hor ober Bry interestor othe Hees related + Wie you donot ave to pay the amaunl in eueation, you se recone vay Ore, Suitpaymeni120 Comctten,2 sila anguge, vl be xe} ‘+ lorWe thecan renin apply any olunpaid your bale, meant nye yous eed rit 0‘We NOTmay USEaccepTHE payment ENCLOSED A TANCE ENVELC sent fo ary her adres without losing any of foe Hp oA Died Yu dns yen shall operate 83 wn weced and salislction without pee vite sribyatate cot dssatisiedend ondwith youthe Neve gods tedo servegod tests coree fe Bobi, CUSTOMER SEAMICE. visit.dar onthe pur you may have the igh not lo pay the remaining amount 1-844-271-2603 CTDOTTY 1885-815actin reat Tose his igh. all of he following meat be te: TELEDONE WoMTORNE. To vieyy wit hgheay serie, mace i you heme sate or within100 Iornous ronuaion nites ol your eurent malig s0dress ad he purchase‘beenhad more onthan80$50. ate Mester of ese pace must hare ‘en the ont ol ah your WY INT PAYTre ROttlawing ions, when appearingThat sot you the goods or seme me maited io pou, it we ow the company REQUIRED, W INT EO PY meara WAIVE REST. EQUAL PAtPATENT cara WAN INTERES, irs OLFER INTEREST, PAYMENT EST. LOw PAYMENT, Pe Ra 2antoo , Yow mataoncen have von ue Alor minalor check he purchese, Purchases Bal acces pour Ctl made DEFER. re PATHENT; Ri OF INTRED:LOWDEF INT EO PY mens Coed econ! do hat qual JSTEREST. LO ATEN on LOW AP EPA rr LOW AP, CUAL rate 3. You must mol ye hav bly pi lor the purchase. ‘au sy py iol your hero elece at ay he etic mut es peaay wey. {1 ao he cnteris store ace mel ast you ar stil isatsiedwth the Send gigs ew: cusTomen SeANCE, 70 Br 183003, catuminn. OF contact us in wingal: ComertyCapila Bark PO Bor 182620, Cohan, Om 43218-7620, 7 netiesSopotand rasted 0correspondence ‘discussed above Aller we sr ue evi. Fn oes inveligation a0 oh aged wren Espa tons Beret Bos "3008. chamber ‘Secalon At hol emay report you a4 delinquent pots, Toe Boa you com on eur!wt iltd elYou yougo ootat By ‘218-3043 {TICE ABOUT .EcTROME CHECK CONVERSION, an yOu provide& ae us either lo uae formation rom yoroFtheWoW 10 AVOID youclonepayaiereston PAYING ofyeeeachonce bl DtINTEREST. te We wna Yow due date is ol evs 25 days alter Gack iomeve ppocess vertia chock eocbore ‘acecunl che nem ‘oe dale :nementh you interestWe onil porches ‘Tow APR, aval Payment angi {our checkthe fopayment aka ona lactone Uaraacion. tna When lg we mayute salormaion be wan Hem account a 30 0 oF bucget Payer Cet lan bn te dale of purchase youu och cceve your Check backsa Womay Fouwe tril ain LANCE COMPUIAIION METHOD, We cae lees! spl peo arealanacaon Paling pone ee, he, nat iexpe aetermine on Weoun reach dy me bry cycle To pete “Sh tine yo {nee Sewing tne yr aceoat ye Eau balrce ey seta3 ca ty bts oe (routing ary net ) Ths pees ut the cay aancePAYMENTS.be edieinert Pay your Accountectbythe fro eIDtote deo ey stm ed owtb, yourwedDoyen a rece you payne caret eat ind blnoe ‘netted ayoya at reach vtCone Fema Cane oat len pyent Ps ineteet or Orniane See a pera tub areaheck rere check o cai check parable in US, dll, te name ae showha tienen Jour payer t o he c,d eoniaiang c o u t Bomber fur crash ane smaunl erbe coeloge Be suewih proved ror Si tape onO° ‘ar payenentshe, do nos ‘wihnoneIayibentSc ar do ot send a scancece ih ow bayrc,Yoy souk vent 8 rent To 3000 Ketbeay Drive, Suite ‘arrolton. masoresenoot eraa cauhor pt ceicaies, eg opment You fre gage Payerents{235819 Taibo mate pone by Mignone etochiay ttt sin”ay Online By Phen:Faun sabe 8. stat ce at 1-844-271-2603 foment (TOOTPayment{ello Calalt tines Toes Ma Payne eat leneBy aeadlines fo Tsreceive payments we te doe date on tis Statement in the payne stub area a he ind Ovemight 600 pon Eastern oe Ba By Pas 1600 pet (ET; Online By 6:00 aw tatermation Tie (optional) Fest Nome “1 Last Name. Soe. See. No. ‘street Addis. ‘Apt. No. RR PO Box ty, State Ap Code. Forelgn bap ode Homa Prone: ‘Week Phone Eman AgcressPAGE SOF «Cerra Minna ao Eastimportant Reminder: II you make a purchase with this credit card using a promotional plan, thepromotional plan expiration date and payment due date may be di ‘ent. This means that if you have anytemaining promotional pian balance after the promotional plan expiration date, the balance and anyaccrued interest (i! applicable), will move to your regular revolving plan on the next biling statement. How to avoid of minimize inter it charges: Be sure to pay any promotional plan balance in full on or delore the plan expiration date shown in the “Details of your plans” section of your statement, Please also keep an eye out for notifications of when your promotional plan(s) are nearing their expiration date—you'l! se them in the red box on page 1 of your statement. If you have questions, please call us toll-ree at 1-844-271-2603 (TOD/TTY: 1-888-819-1918). To learn more about how promotional plans work, visit comenity.corrvtinancial-education. We're always happy to help. IMMEDIATE ATTENTION REQUIRED! Your Account is extremely past due and will be written off as a bad debt at the end of this month. To avoid this, you can pay the Minimum amount shown on this ‘statement before the end of this month. i! you are not able fo pay he Minimum Payment amount, we will still be able to assist you and prevent your account from being written off. Call us at 1-855-617-8089 (TOOFTTY 1-888-819-1918) and we wil! find @ suitable payment betore the end of this month. If written off, the dad debt willbe reported to the three major credit bureaus and our Recovery team will determine the appropriate steps, as permitted and available under applicable law, to protect our interests. Affected by COVID-197 Comenity Capital Bank Otters Support AAs the bank that manages your credit card, our hearts go out to those affected by the coronavirus {COVID-19) pandemic. ‘The support we're extending to you. If you're experiencing financial hardship because of COVID-19, please call 1-844-271-2603 (TDO/TTY: 1-888-819-1918) to discuss how we maybe able to help. Account Center Is available 24/7 fer you to manage your Grandin Road account online. You ‘can make payments and view your balance, transactions and statements onting. Not yet registered? Visit ‘comenity.neV/grandinroad, enter your Grandin Road credit card account number and ZIP code, then verity in Kdennty. We're looking out for you. We remain focused on the health and weil-being of our customers and soclates, and we'll continue to stay on top of what's happening during the pandemic so we can best ‘support you. IMPORTANT INFORMATION ABOUT LATE FEE CREDITS We may occasionally provide a credit for the amount, part or all, of a late fee charged to your accounl. If we do, we will charge & 186 o! up to $38.00 for any subsequent late payment. in addition, we may reverse 18 Credit and repost the ches to your account if you fail to make the minimum payment due on or before the dus date in the next billing period.Protect yoursetl against mall and phone consumer fraud.ntipy/about. usps.com/publications/pub26 1/welcome.nim44301006 O000S91b 2768 «O0003ee00 0001007L3PAGE SOFAHappy Birthday! Treat yourself to something special with 20% off your purchase. when you use your Grandin Road Credit Card.* See reverse for details Pace Eines Ererne cn ‘Account no. oe 7788, New balance $622.80 ve $31.00 Previous balanco $708.92 Payment due date 6/4/2021 Payments 100,00 Late payment warnin; Other crecits 0.00 Mtwe do not receive your minimum payment by 08/04/2021 you may Purchases 9.00 have to pay up to a $98 00 tate Other debits, 0.00 Fees charged 0,00 Minimum payment warning: H you makeonly the minimum, Interest charged 448 [payment for each period, you will pay more in interes! and it wil oko. Wow bal teaa0 ‘you tonger 10 pay off your belances. For example: Pas! due amount 0,00 Wyou make no additional ‘You will pay off ‘And you wit! Credit et $500.00 charges using this card the beta own, 4 up paying an ‘Available credit ‘$0.00 ‘and each month you pay: | on the etatement ot toment closing dat osvoaiz02§ In about oft Days in biting cycle an ‘Onty the minimum payment ‘Syeers seer For information regarding credit counseling services, ‘cal 1-800-284-1706, The adores for mailed payments has changed. The new address is reflected at the bottom of this billing statement, ‘Account Questions? Need to make a payment? Want to know how to go paperless? Visit comenity.netigrandinreador call 1-844-271-2603 (TDD/TTY 1-888-819-1918). ‘Skip signing in to pay and use Comenity’s EasyPay. It’s safe and convenient. Use your smartphone cameraor code ‘eader to scan the OR code printed on your payment stub below to get started. ‘Account Questions? Need to make a payment? Want to know how Visit comenit oad ov cal 1864 271-2603 (TODITTY. 1 886-819'1918) Want tay in te now with credit tips and news? 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Must have a valid email address with Comenity Capital Bank in order to receive the birthday coffer, i account was opened the month prior to or during your birthday month you will receive the birthday Coffer the following month. This offer applies to a single

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FAQs

What is an example of pleading in the alternative complaint? ›

A quick definition of alternative pleading:

For example, if someone got hurt in a car accident, they might say that the other driver did it on purpose or that they just made a mistake. Both sides can do this. It's allowed in the rules of the court.

How long do you have to respond to a complaint in federal court? ›

Always check your court's local rules as well as the Federal Rules of Civil Procedure. Generally, a party served with a complaint must respond within 21 days after being served. See Fed.

How many days does a defendant have to file pleadings in response to a complaint served on that defendant in a Virginia state civil action? ›

‒ When the court has entered its order overruling all motions, demurrers and other pleas filed by a defendant as a responsive pleading, such defendant must, unless the defendant has already done so, file an answer within 21 days after the entry of such order, or within such shorter or longer time as the court may ...

How long does it take to respond to discovery in Ohio? ›

(3) Answers, objections or other responses to discovery requests shall be served within twenty-eight days after service of such requests unless the board orders or the parties agree to a different period of time.

Is a pleading the same as a complaint? ›

A complaint is the pleading that starts a case. Essentially, a document that sets forth a jurisdictional basis for the court's power, the plaintiff's cause of action, and a demand for judicial relief. A plaintiff starts a civil action by filing a pleading called a complaint.

What are the 7 types of pleadings? ›

Only these pleadings are allowed: (1) a complaint; (2) an answer to a complaint; (3) an answer to a counterclaim designated as a counterclaim; (4) an answer to a crossclaim; (5) a third-party complaint; (6) an answer to a third-party complaint; and (7) if the court orders one, a reply to an answer (b) MOTIONS AND OTHER ...

What happens if you don't respond to a complaint? ›

Although it might be tempting to ignore a summons and complaint, ignoring a lawsuit does not make it go away. And it could result in the court awarding a money judgment against you by default. That can lead to your wages being garnished, your bank accounts attached, or your property being taken!

What is the difference between a federal complaint and an indictment? ›

As opposed to a complaint, an indictment is a document authorizing the charge and trial of persons who have been shown by probable cause to have broken the law. An indictment is a requirement in every felony case under the U.S. Constitution. Unlike a complaint, indictments are issued by grand jurors.

How many days to answer a complaint in federal court? ›

Under federal rules, defendants generally have 21 days to file an answer after they are served with a complaint; the U.S. government has 60 or 90 days, depending on whether it has waived service.

What is the pleaded complaint rule? ›

Well-Pleaded Complaint Test - Mottley Rule

This means that the plaintiff's initial complaint must contain references to the federal question and the federal issue evoked. The federal question and issue cannot arise in an anticipated defense, it must be presented from the initial complaint.

How long should you take to respond to a complaint? ›

The experience of customers in other sectors shows that a response within two working days increases their confidence in a complaint handling process.

What is the reply in the pleading process a legal response to? ›

What Are Legal Response and Reply Pleadings? A Response or Reply to the Opposing Party's Pleadings is your answer to the opposing party's document filed with the court.

What is the rule 33 in Ohio? ›

Rule 33 - Interrogatories to Parties (A) Availability; procedures for use. Any party, without leave of court, may serve upon any other party up to forty written interrogatories to be answered by the party served.

Why does discovery take so long? ›

Those reasons include everything from a court's crowded docket, the limited number of available judges, and recent budgetary constraints, to pre-trial challenges regarding the sufficiency of the complaint or the validity of the cause of action, legal maneuvering with things such as summary judgment motions, and ...

What happens if discovery is not answered? ›

If the other person did not respond or didn't provide complete responses, try to work it out with them directly first. If that does not work, you can request a court order that requires them to respond or respond with more information.

What does pleaded in the alternative mean? ›

In civil proceedings, the practice of including in a statement of case two or more inconsistent allegations and inviting the court to grant relief in respect of whichever allegation it finds to be well-founded.

Which of the following is an example of a pleading? ›

Here are some examples of typical pre-trial pleadings: Complaint: also known as a petition or a bill, sets out the plaintiff's perspective on the facts and injuries due to the controversy. The plaintiff explains the issues of the lawsuit, including the cause of action and the factual and legal basis for the case.

What is pleading causes of action in the alternative? ›

To ensure the plaintiff can recover what they are entitled to, alternative pleading allows them to plead the inconsistent claims that defendant committed the intentional (and not negligent) tort of battery and that the defendant was negligent. Both the plaintiff and defendant may plead in the alternative.

What is an example of argue in the alternative? ›

In a more serious example, a lawyer might argue, not only that his client was elsewhere when a murder or other crime took place, but also that even if he had been on the scene, he would have had no way of accessing the alleged murder weapon.

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