ComplaintCal. Super. - 3rd Dist.November 25, 2019% 1 JACK H. POGOSIAN, State Bar No.: 305741 MANASI TAHILIANI, State Bar No.: 272821 2 CHRISTINA ARNOLD, State Bar No.: 297590 HYO JIN JULIA JUNG, State Bar No.: 316090 3 MELINE GRIGORYAN, State Bar No.: 321133 A CAROLINA PINHEIRO, State Bar No.: 259875 om | 350 CAMINO DE LA REINA, SUITE 100 EF Le > 5| | SAN DIEGO, CA 92108 Superior Court of, Californie Telephone: (866) 300-8750 coun 6| | Facsimile: (858) 309-1588 NOV 25 2019 Attorneys for Plaintiff 7 Jake Chatters sari ati Ofticer & Cler 8 SUPERIOR COURT OF CALIFORNIA By: O. Lucatuorto, Deputy 9 COUNTY OF PLACER 10 BILL SANTUCCI JUSTICE CENTER IDLA N , Hl M ND FU DING LLC Case No MCVOO/75204 2 Plaintiff, COMPLAINT FOR: 13 Vs. (1) Account Stated 14 MATTHEW SERAFINI; PRAYER AMT: $1,919.40 and DOES | through 10, inclusive LIMITED 15 Defendant. 16 7 MIDLAND FUNDING LLC, ("Plaintiff"), by counsel, sues MATTHEW SERAFINI, (“Defendant”) : under Account Stated and in support thereof states: 1. Plaintiff is authorized to do business in CALIFORNIA, with its principal place of - business at 350 CAMINO DE LA REINA SUITE 100 SAN DIEGO CA 92108. Plaintiff 20 owns portfolios of consumer receivables, which it attempts to collect. Plaintiff strives to 21 treat its consumers, such as Defendant, with respect, compassion and integrity, hoping to 22 provide mutually-beneficial opportunities for consumers to repay their debts and attain 3 financial recovery. 7A 2. Defendant is a resident of PLACER County, State of California and is subject to this a Court’s jurisdiction. 3. Plaintiff is unaware of the true names and capacities of Defendants sued by the fictitious 2 names DOES 1 through 10. Plaintiff will ask leave of court to amend this complaint as 27 and when the true names and capacities of Defendants named herein as DOES | through 28 10 have been ascertained. Pursuant to California Civil Code (“CA CIVIL”) §1788.58(a)(1)-(9), Plaintiff alleges: 4. Plaintiff is a debt buyer as defined by CA CIVIL §1788.50(a). -|- COMPLAINT CA_0132G File No.: 19-233593 O o C O NN DD 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CA_0132G File No.: 19-233593 10. 11. 12 13. ~ ao Defendant established a credit account (the ““Account”) with SYNCHRONY BANK. The amount dve is the result of transactions that occurred on the Account. Defendant was provided statements evidencing Defendant’s use of the Account and the balance due. Defendant failed to make the required payments and subsequently defaulted on the Account on October 18, 2017. Thereafter, Plaintiff was assigned all rights, title, and interest in the Account. Plaintiff is the sole owner of the debt. Attached as Exhibit A is a true and correct copy of the Bill of Sale from SYNCHRONY BANK, to Plaintiff. The Account was purchased by Plaintiff on May 29, 2018. The Account balance at the time of charge-off was $1,954.40. Plaintiff alleges that the date of default is October 18, 2017 and the date of the last payment was September 09, 2017 which was made to SYNCHRONY BANK. The name of the charge-off creditor at the time of charge-off is SYNCHRONY BANK. The address utilized by SYNCHRONY BANK at the time of charge-off was P.O. BOX 965033 ORLANDO,FL 32896. At the time of charge off, the account number associated with the debt was XXXXXXXX-XX-2557. The name of the debtor as it appeared in the records of SYNCHRONY BANK is MATTHEW SERAFINI and the last known address as it appeared in the records of SYNCHRONY BANK is 6001 BENTWOOD CIR E WHITE LAKE MI 48383. The name and address of all post charge-off purchasers of the debt are as follows: Name Address MIDLAND FUNDING LLC 350 CAMINO DE LA REINA SUITE 100 SAN DIEGO CA 92108 Plaintiff has complied with the provisions of CA CIVIL §1788.52. Plaintiff informed Defendant of the assignment of the Account. Attached as Exhibit B is a true and correct copy of the first written communication sent to Defendant by Plaintiff. Pursuant to CA CIVIL §1788.58(b), attached as Exhibit C is a true and correct copy of a monthly statement recording a purchase transaction, payment, or balance transfer while the Account was active as required by CA CIVIL §1788.52(b). Attached as Exhibit D is a true and correct copy of a billing statement that was mailed to Defendant stating the balance due on the Account at or around the time of charge-off. 2: COMPLAINT Ww Nn 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CA_0132G File No.: 19-233593 14. 16. 17. 18. 19. 20. 21. 22. Plaintiff acquired all right, title, and interest to the Account. To the extent that Plaintiff acts in its capacity as successor-in-interest to the original creditor or its assigns, references herein to Plaintiff may include Plaintiff's predecessor-in-interest. Plaintiff has attempted to contact Defendant through several means in an effort to resolve the Account, but has been unsuccessful. Defendant has not repaid this debt. Plaintiff works with consumers like Defendant to find mutually acceptable solutions, often offering discounts, hardship plans, and a variety of payment options. The majority of Plaintiff's consumers ignore calls or letters, and some simply refuse to repay their obligations. When this happens, Plaintiff must decide whether to pursue collection through legal channels, including litigation such as the present action against Defendant. Nonetheless, Plaintiff remains interested in discovering a mutually beneficial solution through voluntary payments, if possible, in this case. Before commencement of this action, Plaintiff informed Defendant in writing, attached as Exhibit E, that it intended to file this action and that this action could result in a judgment against Defendant that would include court costs allowed by California Code of Civil Procedure § 1033(b)(2). FIRST CAUSE OF ACTION ACCOUNT STATED Plaintiff realleges and incorporates by reference the foregoing paragraphs. An account was stated in writing between Defendant and SYNCHRONY BANK. Defendant opened and derived benefit from the Account. By using the Account, Defendant expressly or impliedly promised to repay SYNCHRONY BANK. The consumer has made a payment on the Account within the last four(4) years. On the Account, a balance of $1,954.40 was stated to be due to SYNCHRONY BANK from Defendant. Plaintiff has no record of Defendant objecting to the balance due. Before the commencement of this action, Plaintiff was assigned the Account and indebtedness. Plaintiff is now the sole owner of the Account. Plaintiff has made a demand on Defendant for repayment of the Account, but Defendant has failed to pay the balance due. The current balance presently due and owing is $1,919.40 which includes payments, set- offs, credits or allowances, if any, at or after charge-off. LB COMPLAINT 1 2 WHEREFORE, Plaintiff requests judgment against Defendant for $1,919.40, costs of this action 3 and post judgment interest at the statutory rate. Plaintiff waives any claim for pre- judgment interest and attorney's fees. 4 5 6 71) pate: H/F/ MIDLAND FUNDING LLC 8 9 10 By: Cw LJJACK H. POGOSIAN 11 [-]MANASI TAHILIANI LJHYO JIN JULIA JUNG 12 [AMELINE GRIGORYAN [-] CHRISTINA ARNOLD 13 [] CAROLINA PINHEIRO 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4- COMPLAINT CA_0132G File No.: 19-233593 EXHIBIT A AA_0125 File No.: 19-233593 synchrony BANK BILL of SALE Midland (ENFS) - PLCC Fresh - May 2018 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Accounts Purchase Agreement (the “Agreement”), dated as of the 4" day of August, 2017 by and between Synchrony Bank formerly known as GE Capital Retail Bank; RFS Holding, L.L.C.; and Retail Finance Credit Services, LLC (collectively “Seller”) and Midland Funding LLC (“Buyer”), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, the Accounts as set forth in the Notification Files, delivered by Seller to Buyer on May 19, 2018, and as further described in the Agreement. Capitalized terms not defined herein shall have the definition ascribed in the Agreement. With respect to information for the Accounts summarized in the Notification Files, the Seller represents and warrants to Buyer that (i) the Account information constitutes the Seller’s own business records and accurately reflects in all material respects the information in the Seller's database; (ii) the Account information was kept in the regular course of business; (iii) the Account information was made at or near the time by, or from information transmitted by, a person with knowledge of the data entered into and maintained in the Account’s database; and (iv) it is the regular practice of the Seller’s business to maintain and compile such data. Retail Finance re Services, LLC By: bu Ken Wojei Title: SVP, Collections & Recovery Title: Attorney In Fact RFS Holding, LLC Midland Funding LLC v By: bs | A By:__ Ken Wojctl Name:_ {20d Randa Title: Attorney In Fact Title: Vice President, Busses Developnrert Purchase Price Reconciliation/Funding Instructions May 21, 2018 To: Midland This FORWARD FLOW ACCOUNTS PURCHASE AGREEMENT, is made this 4" day of August, 2017 (the “Effective Date”), by and between Synchrony Bank formerly known as GE Capital Retail Bank; RFS Holding, L.L.C.; and Retail Finance Credit Services, LLC (collectively, “Seller”) and Midland Funding LL' (“Buyer”) with reference to the following facts and circumstances: Portfolio RMS NG Agcy_Atty Code ENFS Total Number of Accounts Outstanding Balances on Transfer Date Cut-Off Date May 19, 2018 Transfer Date May 19, 2018 Purchase Price Factor Purchase Price 0% Holdout Amount of Wire transfer Date of Funding: May 29, 2018 Bank: ABA No. Account No: Account Holder: Location: AFFIDAVIT OF SALE OF ACCOUNT BY ORIGINAL CREDITOR State of Florida County of Seminole Paola N. Medina being duly sworn, deposes and says: I am over 18 and not a party of this action. I am a Media Representative of Synchrony Bank formerly known as GE Capital Retail Bank. In that position I have access to creditor’s books and records, and am aware of the process of the sale and assignment of electronically stored business records. On or about 05/19/2018 Synchrony Bank formerly known as GE Capital Retail Bank sold a pool of charge-off accounts (the Accounts) by a Purchase and Sale Agreement and a Bill of Sale to Midland Funding LLC. As part of the sale of the Accounts, electronic records and other records were transferred on individual Accounts to the debt buyer. These recor:'s were kept in the ordinary course of business of Synchrony Bank formerly known as GE Capital Retail Bank. The Creditor has a process to detect and correct errors on these accounts. The above statements are true to the best of my knowledge. Signed this 14th day of June, 2018 (vheoa M ter Paola N. Medina Signed and sworn to before me this 14th day of June, 2018 (Nota tamp) yy itn, . _ DIONNE Lov $ Y hy Xe% State of Floride:Notery Public < i Commission # GG 217684 \" My Commission Expire 82022" °° HEA May 1 SE Enenne Sree a” NY AOS 1.3 2/1/2017 - St. Paul CERTIFICATE OF CONFORMITY UNDER NYS CLS CPLR § 2309(c) AND NYS CLS RPL § 299-a The undersigned does hereby certify that she is an attorney-at-law duly admitted to practice in the State of Florida and residing in the State of Florida; that she is a person duly qualified to make this certificate of conformity pursuant to Section 299-a of the Real Property Law of the State of New York; that she is fully acquainted with the laws of the State of Florida pertaining to the acknowledgment or proof of affidavits; that the acknowledgement or proof upon the foregoing Affidavit of Paola N. Medina was taken by Dionne Love, a notary public in the State of Florida, in the manner prescribed by the laws of the State of Florida, being the state in which the Affidavit was taken; and, based on her review thereof, that the notarized Affidavit conforms to the laws of the State of Florida in all respects. Witness my signature this 14th day of J a Nelson V Attorney-at-law, State of Florida. AFFIDAVIT OF SALE OF ACCOUNT BY ORIGINAL CREDITOR State of Florida County of Seminole Paola N. Medina being duly sworn, deposes and says: I] am over 18 and not a party of this action. Iam a Media Representative of Synchrony Bank formerly known as GE Capital Retail Bank. In that position I have access to creditor’s books and records, and am aware of the process of the sale and assignment of electronically stored business records. On or about 05/19/2018 Synchrony Bank formerly known as GE Capital Retail Bank sold a pool of charge-off accounts (the Accounts) by a Purchase and Sale Agreement and a Bill of Sale to Midland Funding LLC. As part of the sale of the Accounts, electronic records and other records were transferred on individual Accounts to the debt buyer. These records were kept in the ordinary course of business of Synchrony Bank formerly known as GE Capital Retail Bank. The Creditor has a process to detect and correct errors on these accounts. The above statements are true to the best of my knowledge. Signed this 14th day of June, 2018 (Fhe M Meer Paola N. Medina Signed and sworn to before me this 14th day of June, 2018 uit, . DIONNE LOV $ y % State of Pekenei touu, 4 yi Cammisaton # GG 217884 , ¥ Commission & UA May 18, 2023" °" NY AOS 1.3 2/1/2017 - St. Paul CERTIFICATE OF CONFORMITY UNDER NYS CLS CPLR § 2309(c) AND NYS CLS RPL § 299-a The undersigned does hereby certify that she is an attorney-at-law duly admitted to practice in the State or Florida and residing in the State of Florida; that she is a person duly qualified to make this certificate of conformity pursuant to Section 299-a of the Real Property Law of the State of New York; that she is fully acquainted with the laws of the State of Florida pertaining to the acknowledgment or proof of affidavits; that the acknowledgement or proof upon the foregoing Affidavit of Paola N. Medina was taken by Dionne Love, a notary public in the State of Florida, in the manner prescribed by the laws of the State of Florida, being the state in which the Affidavit was taken; and, based on her review thereof, that the notarized Affidavit conforms to the laws of the State of Florida in all respects. 2018 ol 2 er Nelson V Attorney-at-law, State of Florida. Witness my signature this 14th day of J Field Field Data Account_Number First_Name Last_Name SSN Birtn_Date Account_Address_1 City State Zip_Code Contract_Date Last_Payment_Date ChargeOff_Date Current_Balance Last_Pay_Amount ChargeOff_Amount Lending_Office_Code Last_Purchase_Date Account information provided by SYNCHRONY BANK pursuant to the Bill of Sale / Assignment of Accounts transferred on or about 05/29/2018 in connection with the sale of accounts from SYNCHRONY BANK to Midland Funding, LLC. 2°57 MATTHEW SERAFINI #****2770 Saas 6001 BENTWOOD CIRE WHITE LAKE MI 48383-1083 12/11/2014 9/9/2017 4/15/2018 1954.4 87 1954.4 AMAZON 3/23/2017 EXHIBIT B AA_0126 File No.: 19-233593 le ~ am, v \ T A I Midland Midland Credit Management, Inc CLCOME, ‘1s secon ro (ram) Ses Ses Your account has a new home Management Roanoke, VA 24031-3105 ‘ werd : 10-17-2018 Account Transfer Details Original Creditor Synchrony Bank Original Account Number [qRI25S7 Matthew Serafini TiAoi2 lest Current Servicer Midland Credit Management, Inc. 875 E Summit St Apt 26 MCM Account Number 8580381842 Milford, MI 48381-1745 Current Owner Midland Funding LLC Current Balance $1,954.40 PUTT oan eC oT Flexible Payment Options Available (866) 361-0420 SSS SS RE Synchrony Bank Amazon Account at a Glance nancaartian Current Balance Welcome! On 05-29-2018, your Synchrony Bank/Amazon account was sold to Midland Funding $1,954.40 LLC, which is now the sole owner of this debt. Midland Credit Management, Inc. (“MCM”), a debt collection company, will be collecting on, and servicing your account, on behalf of Midland Funding LLC. Flexible Payment Options bay . . . . To welcome you to MCM, we'd like to offer you an opportunity to discuss flexible payment options Available to resolve this account. MCM is a different kind of debt collector. Here is what to expect: Receive Personalized Service -- Adedicated Account Manager will be assigned to your account - Wewill reach out to you by phone and mail over the months to come. - Useful tools and resources online at MCMPay.com “BILL OF RIGHTS- MCM, a partner you can trust. Sy We value your experience and understand that managing debt can be a difficult process! That s why we set standards for how you are to be treated while working with us. Visit - _ MCMPay.com to learn about our Consumer Bill of Rights or call (866) 361-0420 to experience the Reply by difference for yourself. 12-01-2018 Call (866) 361-0420 sincerely a = . . Mon-Fri: 11am-7:30pm ET; Nick Sona Nick Sondi, Assistant Vice President P.S. Any discounts or repayment options do not alter your validation rights as described on the reverse side. MCMPay.com eSSS We will not report your debt to the credit bureaus if you set up a payment plan, make a payment by 01-17-2019 and make all payments as agreed. 0 1 0 1 7 2 2 0 0 0 1 0 8 We are not obligated to renew any offers provided. : Midland Credit Management, Inc J (866) 361-0420 McMPay.com De eon PLEASE SEE REVERSE SIDE FOR IMPORTANT DISCLOSURE INFORMATION x | ‘ MCM Account Number 8580381842 | ad Manage Your Account Online | Current Balance $1,954.40 e MCMPay.com | Total Enclosed Important Payment Information Make checks payable to: Midland Credit Management MA it # on all payments Mail Payments to: Enter your MC ccount # 0 pay Midland Credit Management, Inc (866) 361-0420 P.O. Box 2000 eee S Warren, MI 48090-2000 se habla espanol | (855) 983-6352 J Pea ; ~ ~ Important Disclosure Information: Please understand this is a communication from a debt collector. This is an attempt to collect a debt. Any information ostained will be used for that purpose. Unless you notify MCM within thirty (30) days after receiving this notice that you dispute the validity of the debt, or any portion thereof, MCM will assume this debt to be valid. If you notify MCM, in writing, within thirty (30) days after receiving this notice that the debt, or any portion thereof, is disputed, MCM will obtain verification of the debt or a copy of a judgment (if there is a judgment) and MCM will mail you a copy of such verification or judgment. If you request, in writing, within thirty (30) days after receiving this notice, MCM will provide you with the name and address of the original creditor. * Calls to and/or from this company may be monitored or recorded. Basic Information Original Creditor Synchrony Bank Current Creditor Midland Funding LLC Original Account i i Gurdon 2557 Cuneat Serticer Midland Credit Management, Inc. Charge-Off Date 04-15-2018 MCM Account Number | 8580381842 Feasts Teerelae ia Slices eels) Send disputes or an instrument tendered as full satisfaction of a debt to: Attn: Consumer Support Services 2365 Northside Drive Suite 300 San Diego, CA 92108 You may also call: (866) 361-0420 The records associated with the Synchrony Bank account purchased by Midland Funding LLC, reflect that you are obligated on this account, which is in default. As the owner of this account, but subject to the rights described below, Midland Funding LLC is entitled to payment of this account. All communication regarding this account should be addressed to MCM and not the previous owner. Physical Payments for Colorado Residents: 80 Garden Center Suite 3 Broomfield, CO 80020 Phone (303) 920-4763 Send Payments to: Midland Credit Mariagement, Inc P.O. Box 2000 Warren, MI 48090-2000 If an attorney represents you with regard to this debt, please refer this letter to your attorney. Likewise, if you are involved in an active bankruptcy case, or if this debt has been discharged in a bankruptcy case, please refer this letter to your bankruptcy attorney so that we may be notified. Please remember, even if you make a payment within thirty (30) days after receiving this notice, you still have the remainder of the thirty (30) days to exercise the rights described above. If your payment method is a credit or debit card, it may be processed through our international card processor. Although our policy is to not charge consumers fees based upon their payment method, your card issuer may elect to do so due to the location of the card processor. If an international transaction fee has been charged by your card issuer, that fee is eligible for reimbursement. You may contact your Account Manager to modify your payment method to avoid these charges in the future and for information to initiate your reimbursement. As required by aw, you are hereby notified that a negative credit report reflecting on your credit record may be submitted to a credit reporting agency if you fail to fulfill the terms of your credit obligations. We are required under state law to notify consumers of the following additional rights. This list does not contain a complete list of the rights consumers have under applicable law: NMLS ID: 934164 IF YOU LIVE iN CALIFORNIA, THIS APPLIES TO YOU: IF YOU LIVE IN NEW YORK CITY, THIS APPLIES TO YOU: New PLEASE SEE INSERT FOR IMPORTANT DISCLOSURE York City Department of Consumer Affairs License Number INFORMATION. 1140603, 1207829, 1207820, 1227728, 2022587, 2023151, IF YOU LIVE IN COLORADO, THIS APPLIES TO YOU: aO2aSD, PORIE29, 2021970 .202 1882 FOR INFORMATION ABOUT THE COLORADO FAIR DEBT IF YOU LIVE IN NORTH CAROLINA, THIS APPLIES TO YOU: North COLLECTION PRACTICES ACT, SEE WWW.COAG.GOV/CAR. A Carolina Denartment of Insurance Permit #101659, #4182, consumer has the right to request in writing that a debt #4250, and #3777, #111895, and #112039. Midland Credit collector or collection agency cease further communication with Management, Inc. 2365 Northside Drive, Suite 300, San Diego, the consumer. A written request to cease communication will CA 92108 not prohibit the debt collector or collection agency from taking IF YOU LIVE IN TENNESSEE, THIS APPLIES TO YOU: This any other action authorized by law to collect the debt. collection agency is licensed by the Collection Service Board of IF YOU LiVE IN MASSACHUSETTS, THIS APPLIES TO YOU: the Department of Commerce and Insurance. NOTICE OF IMPORTANT RIGHTS: You have the right to make a written or oral request that telephone calls regarding your debt not be made to you at your place of employment. Any such oral request will be valid for only ten (10) days unless you provide written confirmation of the request postmarked or delivered within seven (7) days of such request. You may terminate this request by writing to MCM. IF YOU LIVE IN MINNESOTA, THIS APPLIES TO YOU: This collection agency is licensed by the Minnesota Department of Commerce. VALA EXHIBIT C AA_0127 File No.: 19-233593 amazon.com SYNCHRONY BANK MATTHEW J SERAFINI Visit us at www.syncbank.com/amazon Account Number (EN 2557 Customer Service: 1-866-634-8379 Summary of Account Activity Payment Information Previous Balance $1,534.86 | | New Balance $1,481.70 - Payments $87.00 | | Total Minimum Payment Due $49.00 + Interest Charges $33.84] | Payment Due Date 10/10/2017 New Balance $1,481.70 Late Payment Warning:If we do not receive your Total Credit Limit $1,600.00 | | Minimum Payment Due by the Payment Due Date listed above, Available Credit $118.00} |you may have to pay a late fee up to $35.00. Statement Closing Date 09/17/2017 | | Minimum Payment Warning: !f you make only the minimum Days in Billing Cycle 30] | payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: if you make no You will pay off And you will end additional charges the balance up paying an using this card shown on this estimated total and each month statement in of ... you pay ... about ... Only the minimum 7 years $3,110.00 payment $60.00 3 years $2,177.00 (Savings= $933.00) If you would like information about services, call 1-877-302-8775. credit counseling NOTICE: We may convert your payment into an electronic debit. See reverse for details, Billing Rights Information and other important information. 5484 X2G 7 15 170917 PAGE 1 of 3 9342 1000 5484 Detach and maii this portion with your check. Do not include any correspondence with your check. amazon.com A Number: 2557 ‘Total Minimum Payment = Payment Due Date New | Due | | sic A800) 10/10/2017 ___ $1,481.70 Payment Enclosed: Please use blue or black ink.Save a stamp, * pay on-line at www.syncbank.com/amazon. New address or email? Print Changes on back. MATTHEW J SERAFINI 6001 BENTWOOD CIR E WHITE LAKE MI 48383-1083 Make Payment to: SYNCHRONY BANK/AMAZON PO BOX 960013 ORLANDO, FL 32896-0013 Statement Credits Summary Statement Credits Explained + 5% Back $0.00 | | Amazon Prime Store Cardholders can earn 5% Back + Bonus Statement Credits $0.00 | Jon eligible Amazon.com purchases (as a Statement Credit), and also earn Bonus Statement Credits by Monthly Statement Credits $0.00 | | purchasing select items at Amazon.com. Bonus Statement Credits are earned in addition to the 5% Statement Credits YTD $1.95 | | Back benefit. Visit www.amazon.com/storecard for details and to confirm your eligibility. Transaction Summary Tran Date PostDate Reference Number Description of Transaction or Credit Amount PAYMENTS AND CREDITS 09/09 09/09 P9342007X00XTZRON PHONE PYMT-THANK YOU ATLANTA GA ($87.00) TOTAL PAYMENTS AND CREDITS ($87.00) FEES TOTAL FEES FOR THIS PERIOD $0.00 INTEREST CHARGED 09/17 09/17 INTEREST CHARGE ON PURCHASES $33.84 TOTAL INTEREST FOR THIS PERIOD $33.84 2017 Totals Year-to-Date Total Fees Charged in 2017 $95.00 Total Interest Charged in 2017 $312.84 Total Interest Paid in 2017 $247.99 Interest Charge Calculation Your Annual Percentage Rate (APRjs the annual interest rate on your account. Expiration Annual Balance Subject Interest Type of Balance Date Percentage Rate to Interest Rate Charge Regular Purchase NA 26.99% (v) $1,525.25 $33.84 (v) = Variable Rate "New Promotional Financing Plans So eee ey eee Eligible card purchases may be billed under one of the following promotions: No Interest if Paid in Full within 6, 12, or 24 months. Under each of these promotions, if the promotional balance is not paid in full within the promotional period, interest will be imposed from the date of purchase at a rate of 26.99%. If a (v) is shown after your APR in the Interest Charge Calculation section of this billing statement, the APR is a variable rate and will vary with the market based on the Prime Rate. Minimum monthly payments are required. See promotional advertising for further details. [Cardholder News and Information an Synchrony Bank may continue to obtain information, including employment and income information from others about you (including requesting reports from consumer reporting agencies and other sources) to review, maintain or collect your account. [Cardholder Benefits and Information | Manage your account online at www.syncbank.com/amazon. Check your balance, view your statements, pay your bill, update your personal information and more! Use your Amazon Prime Store Card to pay in more places! Amazon Prime Store Cardholders can now use their card to pay for transactions with many merchants who offer Pay with Amazon. When using Pay with Amazon, select your Amazon Store Card as a payment option once you've signed in using your Amazon credentials. Visit http//payments.amazon.com/storecard to see eligible sites. 5484 X2G i 7 15 17091 PAGE 2 of 3 9342 LoL APST APS? O1NF5484 EXHIBIT D AA_0128 File No.: 19-233593 ue amazon.com SYNCHRONY BANK MATTHEW J SERAFINI Visit us at www.syncbank.com/amazon Account Number (EEE 2557 Customer Service: 1-866-771-1104 Summary of Account Activity Payment Information Previous Balance $1,841.08 | | New Balance $1,919.40 + Fees Charged $35.00} | Amount Past Due $496.00 + Interest Charges $43.32] | Total Minimum Payment Due $594.00 New Balance $1,919.40] | Overlimit Amount $319.40 Payment Due Date 04/10/2018 Credit Limit $1,600.00 Available Credit $0.00| |Late Payment Warning: |f we do not receive your Totel Statement Closing Date 03/18/2018 | | Minimum Payment Due by the Payrnent Due Date listed above, Days in Billing Cycle 31| |you may have to pay a late fee up to $35.00. Minimum Payment Warning: If you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: if you make no You will pay off And you will end additional charges the balance up paying an using this card shown on this estimated total and each month Statement in of... you pay ... about ... Only the minimum 6 years $3,342.00 payment If you would like information about credit counseling services, call 1-877-302-8775. Rewards Summary Rewards Explained Rewards Earned YTD $0.00 Amazon Prime Cardholders can earn 5% Back on eligible Amazon.com purchases, and also earn Previous Rewards Balance $0.00 Bonus Rewards by purchasing select items at + 5% Rewards Earned $0.00 Amazon.com. Bonus Rewards are earned - Rewards Redeemed $0.00 in addition to the 5% Back benefit. = Current Rewards Balance $0.00 Visit amazon.com or www.syncbank.com/amazon to redeem available rewards. For more details about the 5% Back program, visit www.amazon.com/storecard. Transaction Summary Tran Date Post Date Reference Number Description of Transaction or Credit Amount FEES 03/10 03/10 LATE FEE $35.00 TOTAL FEES FOR THIS PERIOD $35.00 INTEREST CHARGED 03/18 03/18 INTEREST CHARGE ON PURCHASES $43.32 (Continued on next page) NOTICE: We may convert your payment into an electronic debit. See reverse for details, Billing Rights Information and other important information. 5484 2G 1 15 180318 E Detach and mail this portion with your check. Do not include any correspondence with your check. ° Account Number: a 2557 I 4 Date J | Payment Due | PastDue = ait | $694.00 $496.00 04/10/2018 Payment Enclosed: Please use blue or black ink.Save a stamp, > ae sa a ae $319.40 | ‘$1,919.40 pay on-line at www.syncbank.com/amazon. New address or email? Print Changes on back. MATTHEW J SERAFINI 6001 BENTWOOD CIR E WHITE LAKE MI 48383-1083 Make Payment to: SYNCHRONY BANK/AMAZON PO BOX 960013 ORLANDO, FL 32896-0013 Transaction Summary (Continued) Tran Date PostDate Reference Number Description of Transaction or Credit Amount TOTAi. INTEREST FOR THIS PERIOD $43.32 2018 Totals Year-to-Date Total Fees Charged in 2018 $105,00 Total Interest Charged in 2018 $120.31 Total Interest Paid in 2018 $0.00 Interest Charge Calculation Your Annual Percentage Rate (APRjs the annual interest rate on your account. Expiration Annual Balance Subject Interest Type of Balance Date Percentage Rate to Interest Rate Charge Regular Purchase NA 27.24% (v) $1,872.03 $43.32 (v) = Variable Rate [Cardholder News and Informati Please Note: Enclosed is the Privacy Policy for this account. Please take a moment to read it, then keep it with other financial documents. If you have previously opted-out, you do not need to do so again. p 3 a EX PAGE 3 of 3 9342 1 EXHIBIT E AA_0129 File No.: 19-233593 eee MIDLAND CREDIT MANAGEMENT Our Client: Midland Funding LLC LEGAL COLLECTIONS DEPARTMENT Original Creditor: SYNCHRONY BANK Original Account No.: XXXXXXXXXXXX2557 MidlandCredit.com Outstanding Balance: $1,919.40 (877)-898-5001 Internal Legal Account No.: 19-233593 Jack H. Pogosian, State Bar No. 305741 Jonathan Kom, State Bar No. 320369 Matthew Serafini ee Christina Arnold, State Bar No. 297590 atthew Serafini Hyo Jin Julia Jung, State Bar No. 316090 ee 698 Courtyards Loop Meline Grigoryan, State Bar No. 321133 Lincoln, CA 95648-7213 IUfyg!4UNgegfag fe foflenf Affe fotfoofogafgfyglaflafeatyoual 09/11/2019 REF: SYNCHRONY BANK Original Account Number: XXXXXXXXXXXX2557 Dear Matthew Serafini, As attorneys with Midland Credit Management, Inc. legal department, we are contacting you regarding the collection of the above balance. Your SYNCHRONY BANK Account, owned by Midland Funding LLC, has now been transferred to our litigation department due to non-payment. We are currently reviewing documentation (including the attached documents) in preparation for filing a lawsuit against you. Demand is hereby made upon you for the above payment IN FULL-this is the amount due on your original obligation when transferred to our department. Please send payment Made Payable to Midland Credit Management, Inc. by 09/21/2019. You may also make a payment online at MidlandCredit.com. If we do not receive payment IN FULL by 09/21/2019, we intend to file a lawsuit against you, seeking entry of judgment for your account’s outstanding balance as well as any incurred and recoverable court costs. We intend to continue our collection efforts through various post-judgment remedies available under your state’s laws if a judgment is obtained against you. If you are unable to nay in full by 09/21/2019 please contact our office at (877)-898-5001 to discu : affordable repayment options. Your prompt attention is necessary to avoid a lawsuit. Please call (877)-898-5001 no later than 09/21/2019. You may also make a payment online at MidlandCredit.com. Sincerely, Attorneys for Midland Funding LLC P.S. Attached are copies of some of the documents we received from the original creditor regarding this account. When your account has been paid, and if data related to the account is still being furnished to the consumer reporting agencies, a request will be made of the three major consumer reporting agencies to report the Midland Funding LLC trade line related to the above referenced account as paid. 00 11 77 Visit Us Online €§/=_ P.O. Box 2121 Warren, MI 48090 MidlandCredit.com Call (877)-898-5001 Hours of Operation: M - Fri: 8:00am - 7:30pm EST Sat: Closed Sun: Closed PLEASE SEE REVERSE SIDE FOR IMPORTANT DISCLOSURE INFORMATION re Please tear off and return lower portion with payment in the envelope provided PAYMENT CERTIFICATE Internal Legal Account Number: 19-233593 Payment Options: Original Account Number: XXXXXXXXXXXX2557 1) Pay by phone: (877)-898-5001 Current Balance: $1,919.40 2) Mail in this certificate with your payment and Amount Enclosed: $e make check payable to: Midland Credit Matthew Serafini Management, Inc. 698 Courtyards Loop Lincoln, CA 95648-7213 =£_ P.O. Box 2121 Warren, MI 48090 0103700001177 0000 0000 PRE_002 GL_0702G 19-233593 IMPORTANT DISCLOSURE INFORMATION: Please understand this is a communication from a debt collector. This is an attempt to collect a debt. Any information obtained will be used for that purpose. - - Calls to and/or from this company may be monitored or recorded. MAIL PAYMENTS TO: P.O. Box 2121 Warren, MI 48090 MAIL CORRESPONDENCE BUT NO PAYMENTS TO: P.O. Box 2121, Warren, MI 48090 If your payment method is a credit card, it may be processed through our international card processor. Although our policy is to not charge consumers fees based upon their payment method, your card issuer may elect to do so due to the location of the card processor. If an international transaction fee has been charged by your card issuer, that fee is eligible for reimbursement. You may contact your Account Manager to modify your payment method to avoid these charges in the future and for information to initiate your reimbursement. We are required under state law to notify consumers of the following additional rights. This list does not contain a complete list of the rights consumers have under applicable law: IF YOU LIVE IN CALIFORNIA, THIS APPLIES TO YOU: California Code of Civil Procedure §1033(b)(2) requires us to notify you that in the event of legal proceedings, such legal proceedings could result in a judgment against you that could include court costs and necessary disbursements under applicable law, if Midland Funding LLC is found to be legally entitled to the same. PRE_002 GL_0702G 19-233593 lll" amazon.com SYNCHRONY BANK MATTHEW J SERAFINI Visit us at www.syncbank.com/amazon Account Number (EIEN 2557 Customer Service: 1-866-771-1104 Summary of Account Activity Payment Information Previous Balance $1,841.08} |New Balance $1,919.40 + Fees Charged $35.00} | Amount Past Due $496.00 + Interest Charges $43.32! | Total Minimum Payment Due $594.00 New Balance $1,919.40} | Overlimit Amount $319.40 Payment Due Date 04/10/2018 Credit Limit $1,600.00 Available Credit $0.00} |Late Payment Warning:!f we do not receive your Total Statement Closing Date 03/18/2018 | |Minimum Payment Due by the Payment Due Date listed above, Days in Billing Cycle 31] |you may have to pay a late fee up to $35.90. Minimu:n Payment Warning: If you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: if you make no You will pay off And you will end additionai charges the balance up paying an using this card shown on this estimated total and each month statement in of... Only the minimum 6 years $3,342.00 payment if you would like information about credit counseling services, call 1-877-302-8775. Rewards Summary | Rewards Explained Rewards Earned YTD $0.00 Amazon Prime Cardholders can earn 5% Back on eligible Amazon.com purchases, and also earn Previous Rewards Balance $0.00 Bonus Rewards by purchasing select items at + 5% Rewards Earned $0.00 Amazon.com. Bonus Rewards are earned - Rewards Redeemed $0.00 in addition to the 5% Back benefit. = Current Rewards Balance $0.00 Visit amazon.com or www.syncbank.com/amazon to redeem available rewards. For more details about the 5% Back program, visit www.amazon.com/storecard. Transaction Summary Tran Date PostDate Reference Number Description of Transaction or Credit Amount FEES 03/10 03/10 LATE FEE $35.00 TOTAL FEES FOR THIS PERIOD $35.00 INTEREST CHARGED 03/18 03/18 INTEREST CHARGE ON PURCHASES $43.32 (Continued on next page) NOTICE: We may convert your payment into an electronic debit. See reverse for details, Billing Rights Information and other important information. 5484 x2 a | Detach and mail this portion with your check. Do not include any correspondence with your check. amazon.com Account ‘2557 ‘Total Minimum | | Pay Due | | New | Payment Due | PastDue | Date =| Amount. $594.00 $496.00 04/10/2018 $319.40 $1,919.40 Payment Enclosed: Please use blue or black ink.Save a stamp, $ pay on-line at . www.synebank.com/amazon. New address or email? Print Changes on back. MATTHEW J SERAFINI 6001 BENTWOOD CIR E WHITE LAKE MI 48383-1083 Make Payment to: SYNCHRONY BANK/AMAZON PO BOX 960013 ORLANDO, FL 32896-0013 0203700001177 0000 0000 GL_0702G 19-233593 Transaction Summary (Continued) Tran Date Post Date Reference Number Description of Transaction or Credit Amount TOTAL INTEREST FOR THIS PERIOD $43.32) 2018 Totals Year-to-Date Total Fees Charged in 2018 $105.00 Total Interest Charged in 2018 $120.31 Total Interest Paid in 2018 $0.00 Interest Charge Calculation Your Annual Percentage Rate (APRjs the annual interest rate on your account. Expiration Annual Balance Subject Interest Type of Balance Date Percentage Rate to Interest Rate Charge Regular Purchase NA 27.24% (v) $1,872.03 $43.32 (v) = Variable Rate Car News and | ti | Please Note: Enclosed is the Privacy Policy for this account. Please take a moment to read it, then keep it with other financial documents. If you have previously opted-out, you do not need to do so again. GL_0702G 19-233593 OO ELL e 0303700001177 900¢ 0000 5484 GL_0702G 19-233593
