Preview
System Generated Hearing Date: 1/3/2025 9:00 AM MLG-4695851
Location: Court Room 1101
Judge: Allegretti, John Michael
FILED
2/9/2024 7:49 AM
IRIS Y. MARTINEZ
CIRCUIT CLERK
COOK COUNTY, IL
FILED DATE: 2/9/2024 7:49 AM 20241103852
20241103852
Courtroom, 1101
26339813
IN THE CIRCUIT COURT OF COOK COUNTY
FIRST MUNICIPAL DISTRICT
CKS Prime Investments, LLC, 20241103852
Plaintiff, Case No.
v. Amount Claimed $1,081.23
plus Costs
MARCUS GRIFFIN
Defendant,
Complaint
Account Stated
NOW comes Plaintiff, CKS Prime Investments, LLC by and through its counsel,
Mandarich Law Group, LLP, and in support of its claim against MARCUS GRIFFIN states as
follows:
1. That Plaintiff, CKS Prime Investments, LLC is a foreign LLC registered to conduct
business in the State of Illinois.
2. That Defendant MARCUS GRIFFIN is an individual believed to be a resident of
Cook County, Illinois at the commencement of this cause and venue is proper in the Circuit Court
of Cook County, Illinois.
3. That on or about June 22, 2021, a Credit Card was issued by THE BANK OF
MISSOURI. The Credit Card was designated by account number XXXXXXXXXXXX8645.
4. That THE BANK OF MISSOURI and Defendant engaged in previous transactions
of a monetary nature and the existence of accounts embodying said monetary transactions are set
forth more fully in copies of the monthly billing statements attached hereto and by reference
incorporated herein. Defendant used the credit card to make purchases and/or receive cash
advances.
5. That the monthly billing statements are true and accurate, were sent to the
Defendant and were retained by the Defendant without objection creating an account stated.
This communication is from a debt collector and is an attempt to collect a debt.
6. That Defendant expressly and or impliedly promised to pay for the charges incurred
by use of the credit card, and based on this promise, THE BANK OF MISSOURI paid the
FILED DATE: 2/9/2024 7:49 AM 20241103852
merchants for the charges incurred by Defendant by his use of the credit card.
7. That Defendant defaulted on his/her obligation to make payments on the Credit
Card account having made his last payment on or about January 14, 2022 and the account was
subsequently charged off to Profit and Loss by THE BANK OF MISSOURI on or about June
14,2022.
8. That Plaintiff, CKS Prime Investments, LLC became owner of the charged off
account by virtue of a purchase entered into by Plaintiff and its predecessor(s) in interest.
9. That all credits and payments have been properly applied. Defendant is not entitled
to any additional credits or set offs on the account of any kind and the balance set forth herein is
currently due and owing.
10. That demand has been made on Defendant to pay the balance due and owing by
Plaintiff’s counsel and said demand for payment has been refused.
11. This suit is filed within the relevant statute of limitations.
WHEREFORE, Plaintiff, CKS Prime Investments, LLC prays that this Honorable Court enter an
Order granting the following relief:
A. That judgment be entered in favor of Plaintiff, CKS Prime Investments, LLC and
against MARCUS GRIFFIN in the amount of $1,081.23.
B. That Costs of Suit be awarded Plaintiff.
C. Any further relief that this Honorable Court deems is fair and equitable.
_______________________________________
Attorney No.: 59794 George Petrilli
Mandarich Law Group, LLP Attorney For Plaintiff
P.O. Box 109032
Chicago, IL 60610
877.285.4918
Email: Illinois@mandarichlaw.com
This communication is from a debt collector and is an attempt to collect a debt.
Rule 280.2. Complaint in Credit Card or Debt Buyer Collection Actions.
FILED DATE: 2/9/2024 7:49 AM 20241103852
CKS Prime Investments, LLC,
Plaintiff, Case No. 20241103852
v.
MARCUS GRIFFIN
Defendant,
CREDIT CARD OR DEBT BUYER COLLECTION ACTION AFFIDAVIT
(SUPREME COURT RULE 280.2)
INSTRUCTIONS: Provide the following information. Supreme Court Rule 280.1 provides the
definitions of the terms in this Affidavit.
Comes now affiant and states:
I am a designated agent of CKS Prime Investments, LLC (Plaintiff)
I am of adult age and am fully authorized by Plaintiff to make the following representations. I am
familiar with the record keeping practices of Plaintiff. The following representations are true
✁✁✂✄☎✆✝✞ ✟✂ ☎✂✁✠✡☛✝✟☞ ✌☛✍✟ ✆✝ ✟✎☛ ✝✂✄✡ ✏ ✁✂✠✄☞☛ ✂✑ ✒✏ ✆✝✟✆✑✑✓☞ ✔✠☞✆✝☛☞☞ ✝☎✕✂✄ ✡✖ ✍☛✄☞✂✝ ✏
knowledge:
1. IDENTIFICATION ABOUT THE CONSUMER DEBT OR ACCOUNT
Complete the tables.
a. As of charge-off date:
Nature of the
Full name of the Date the account debt, (credit card
Full name of the Defendant as it Last four digits of the was opened or debt, payday
creditor appears on the account number the debt loan, retail
account originated installment loan,
etc.)
THE BANK OF MARCUS XXXXXXXXXXXX8645 06/22/2021 Consumer Credit
MISSOURI GRIFFIN Card
1 of 3
b. The most recent activity on the account prior to or after charge-off, includes:
FILED DATE: 2/9/2024 7:49 AM 20241103852
Charge-off Charge-off Date Date of Last Amount of Last Payment Total Amount of
Balance Payment* Credits and/or
Payments Since
Charge-off Date**
$1,081.23 06/14/2022 January 14, 2022 $140.00 $0.00
*Last payment on the account, pre- or post-charge-off.
**Credits or payments made within 30 days of the signing of this affidavit may not be reflected.
c. For a revolving credit account, Plaintiff further certifies that it has in its possession
and can produce on request the most recent monthly statement recording a purchase,
transaction, last payment, or balance transfer.
2. PROOF OF OWNERSHIP OR RIGHT TO SUE FOR DEBT BUYERS
Complete the table and list the prior owners or creditors since the charge-off date. Start
with the first assignment through the current creditor or owner of the consumer debt. List
in chronological order, beginning with the first assignment:
From (Name): To (Name): Date of Assignment:
(On or About)
THE BANK OF MISSOURI GENESIS FS CARD SERVICES, INC 12:00:00 AM
GENESIS FS CARD SERVICES, INC CKS Prime Investments, LLC 06/29/2022
✞ Does not apply Plaintiff is the charge-off creditor.
3. ADDITIONAL ACCOUNT INFORMATION AFTER CHARGE-OFF
Plaintiff is seeking additional amounts after the charge-off date:
✁ No*
✂ Yes.
✄ Total amount of interest accrued: $____________;
✄ Total amount of non-interest charges or fees accrued $___________;
✄ ☎✆✝✟✠✡✟☛☛ ✟☞ ☞✌✌✍✟✠✎ ✝✡✡✏✑✠✌✒✓☞ ☛✌✌☞ ✟✠ ✡✔✌ ✝✕✏✖✠✡ ✏☛ ✗✘✘✘✘✘✘✘✘✘✘✘✘✙
✄ Returned payment(s) in the amount of $____________.
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Preview
System Generated Hearing Date: 1/3/2025 9:00 AM MLG-4695851 Location: Court Room 1101 Judge: Allegretti, John Michael FILED 2/9/2024 7:49 AM IRIS Y. MARTINEZ CIRCUIT CLERK COOK COUNTY, IL FILED DATE: 2/9/2024 7:49 AM 20241103852 20241103852 Courtroom, 1101 26339813 IN THE CIRCUIT COURT OF COOK COUNTY FIRST MUNICIPAL DISTRICT CKS Prime Investments, LLC, 20241103852 Plaintiff, Case No. v. Amount Claimed $1,081.23 plus Costs MARCUS GRIFFIN Defendant, Complaint Account Stated NOW comes Plaintiff, CKS Prime Investments, LLC by and through its counsel, Mandarich Law Group, LLP, and in support of its claim against MARCUS GRIFFIN states as follows: 1. That Plaintiff, CKS Prime Investments, LLC is a foreign LLC registered to conduct business in the State of Illinois. 2. That Defendant MARCUS GRIFFIN is an individual believed to be a resident of Cook County, Illinois at the commencement of this cause and venue is proper in the Circuit Court of Cook County, Illinois. 3. That on or about June 22, 2021, a Credit Card was issued by THE BANK OF MISSOURI. The Credit Card was designated by account number XXXXXXXXXXXX8645. 4. That THE BANK OF MISSOURI and Defendant engaged in previous transactions of a monetary nature and the existence of accounts embodying said monetary transactions are set forth more fully in copies of the monthly billing statements attached hereto and by reference incorporated herein. Defendant used the credit card to make purchases and/or receive cash advances. 5. That the monthly billing statements are true and accurate, were sent to the Defendant and were retained by the Defendant without objection creating an account stated. This communication is from a debt collector and is an attempt to collect a debt. 6. That Defendant expressly and or impliedly promised to pay for the charges incurred by use of the credit card, and based on this promise, THE BANK OF MISSOURI paid the FILED DATE: 2/9/2024 7:49 AM 20241103852 merchants for the charges incurred by Defendant by his use of the credit card. 7. That Defendant defaulted on his/her obligation to make payments on the Credit Card account having made his last payment on or about January 14, 2022 and the account was subsequently charged off to Profit and Loss by THE BANK OF MISSOURI on or about June 14,2022. 8. That Plaintiff, CKS Prime Investments, LLC became owner of the charged off account by virtue of a purchase entered into by Plaintiff and its predecessor(s) in interest. 9. That all credits and payments have been properly applied. Defendant is not entitled to any additional credits or set offs on the account of any kind and the balance set forth herein is currently due and owing. 10. That demand has been made on Defendant to pay the balance due and owing by Plaintiff’s counsel and said demand for payment has been refused. 11. This suit is filed within the relevant statute of limitations. WHEREFORE, Plaintiff, CKS Prime Investments, LLC prays that this Honorable Court enter an Order granting the following relief: A. That judgment be entered in favor of Plaintiff, CKS Prime Investments, LLC and against MARCUS GRIFFIN in the amount of $1,081.23. B. That Costs of Suit be awarded Plaintiff. C. Any further relief that this Honorable Court deems is fair and equitable. _______________________________________ Attorney No.: 59794 George Petrilli Mandarich Law Group, LLP Attorney For Plaintiff P.O. Box 109032 Chicago, IL 60610 877.285.4918 Email: Illinois@mandarichlaw.com This communication is from a debt collector and is an attempt to collect a debt. Rule 280.2. Complaint in Credit Card or Debt Buyer Collection Actions. FILED DATE: 2/9/2024 7:49 AM 20241103852 CKS Prime Investments, LLC, Plaintiff, Case No. 20241103852 v. MARCUS GRIFFIN Defendant, CREDIT CARD OR DEBT BUYER COLLECTION ACTION AFFIDAVIT (SUPREME COURT RULE 280.2) INSTRUCTIONS: Provide the following information. Supreme Court Rule 280.1 provides the definitions of the terms in this Affidavit. Comes now affiant and states: I am a designated agent of CKS Prime Investments, LLC (Plaintiff) I am of adult age and am fully authorized by Plaintiff to make the following representations. I am familiar with the record keeping practices of Plaintiff. The following representations are true ✁✁✂✄☎✆✝✞ ✟✂ ☎✂✁✠✡☛✝✟☞ ✌☛✍✟ ✆✝ ✟✎☛ ✝✂✄✡ ✏ ✁✂✠✄☞☛ ✂✑ ✒✏ ✆✝✟✆✑✑✓☞ ✔✠☞✆✝☛☞☞ ✝☎✕✂✄ ✡✖ ✍☛✄☞✂✝ ✏ knowledge: 1. IDENTIFICATION ABOUT THE CONSUMER DEBT OR ACCOUNT Complete the tables. a. As of charge-off date: Nature of the Full name of the Date the account debt, (credit card Full name of the Defendant as it Last four digits of the was opened or debt, payday creditor appears on the account number the debt loan, retail account originated installment loan, etc.) THE BANK OF MARCUS XXXXXXXXXXXX8645 06/22/2021 Consumer Credit MISSOURI GRIFFIN Card 1 of 3 b. The most recent activity on the account prior to or after charge-off, includes: FILED DATE: 2/9/2024 7:49 AM 20241103852 Charge-off Charge-off Date Date of Last Amount of Last Payment Total Amount of Balance Payment* Credits and/or Payments Since Charge-off Date** $1,081.23 06/14/2022 January 14, 2022 $140.00 $0.00 *Last payment on the account, pre- or post-charge-off. **Credits or payments made within 30 days of the signing of this affidavit may not be reflected. c. For a revolving credit account, Plaintiff further certifies that it has in its possession and can produce on request the most recent monthly statement recording a purchase, transaction, last payment, or balance transfer. 2. PROOF OF OWNERSHIP OR RIGHT TO SUE FOR DEBT BUYERS Complete the table and list the prior owners or creditors since the charge-off date. Start with the first assignment through the current creditor or owner of the consumer debt. List in chronological order, beginning with the first assignment: From (Name): To (Name): Date of Assignment: (On or About) THE BANK OF MISSOURI GENESIS FS CARD SERVICES, INC 12:00:00 AM GENESIS FS CARD SERVICES, INC CKS Prime Investments, LLC 06/29/2022 ✞ Does not apply Plaintiff is the charge-off creditor. 3. ADDITIONAL ACCOUNT INFORMATION AFTER CHARGE-OFF Plaintiff is seeking additional amounts after the charge-off date: ✁ No* ✂ Yes. ✄ Total amount of interest accrued: $____________; ✄ Total amount of non-interest charges or fees accrued $___________; ✄ ☎✆✝✟✠✡✟☛☛ ✟☞ ☞✌✌✍✟✠✎ ✝✡✡✏✑✠✌✒✓☞ ☛✌✌☞ ✟✠ ✡✔✌ ✝✕✏✖✠✡ ✏☛ ✗✘✘✘✘✘✘✘✘✘✘✘✘✙ ✄ Returned payment(s) in the amount of $____________. 2 of 3 FILED DATE: 2/9/2024 7:49 AM 20241103852 FILED DATE: 2/9/2024 7:49 AM 20241103852 FILED DATE: 2/9/2024 7:49 AM 20241103852 FILED DATE: 2/9/2024 7:49 AM 20241103852 FILED DATE: 2/9/2024 7:49 AM 20241103852 FILED DATE: 2/9/2024 7:49 AM 20241103852 FILED DATE: 2/9/2024 7:49 AM 20241103852 FILED DATE: 2/9/2024 7:49 AM 20241103852