Preview
562022SC002154AXXXHC
Filing # 152407529 E-Filed 06/29/2022 11:19:35 AM
IN THE COUNTY COURT IN AND FOR
SAINT LUCIE COUNTY, FLORIDA
PORTFOLIO RECOVERY ASSOCIATES, LLC, CASE NO.:
Plaintiff,
vs.
ROSE BRENENSON
Defendant.
/
Complaint
Plaintiff sues Defendant for damages, and would allege:
1. This is an action for damages less than $8,000.
2. Defendant obtained and used a SYNCHRONY BANK/ SYNCHRONY BANK/ PC RICHARD
revolving credit account, XXXXXXXXXXXXX3793 (the "Account").
3. Defendant did make purchases and charged same to the Account, but after statements were
provided to Defendant, Defendant failed to make the monthly payments due upon the Account and
failed to object to the balance then owing within a reasonable time, resulting in an Account Stated
in the sum of $3,317.72 (See Attached).
4. Plaintiff is the successor in interest of said Account having purchased said Account in good faith,
for value, and in the ordinary course of business. (See Attached).
5. Plaintiff received the attached records of the original creditor pursuant to its purchase of the
Defendant's account. Plaintiff independently checked the records for accuracy, and then integrated
the records into their own business records.
6. Plaintiff has declared Defendant to be in default and demands payment of the balance due on the
Account. Defendant has refused said demand.
7. Defendant is indebted to Plaintiff in the sum of $3,317.72.
8. All conditions precedent to this action have occurred.9.
Pursuant to Rule 2.516, Plaintiff designates the following email addresses for the purpose of
service of all documents required to be served pursuant to Rule 2.516 in this proceeding.
Primary E-Mail Address: LitigationService@Portfoliorecovery.com and Secondary Address:
Florida_RA@portfoliorecovery.com.
WHEREFORE, Plaintiff demands Judgment against Defendant for $3,317.72, plus costs.
304708
/s/ Steven Cullen Date: 06/15/2022
Steven Cullen, Esq. Bar No. 0362204
Anthony Joseph Maniscalco, Esq. Bar No. 548707
Jacqueline Elizabeth Ligas, Esq. Bar No. 030009
Jessica Montes, Esq. Bar No. 47522
John Bacus Dejesus, Esq. Bar No. 0111446
Jorg Menriv Rivera, Esq. Bar No. 0779571
Juliana Rodriguez, Esq. Bar No. 105514
Shayna Lynn Singer, Esq. Bar No. 821101
Attorneys for Plaintiff
Portfolio Recovery Associates, LLC
120 Corporate Blvd
Norfolk, VA 23502
Phone: 866/428-8102
www.PRApay.com
LitigationService@Portfoliorecovery.com
Florida_RA@portfoliorecovery.comsynchrony
4500 Munson St NW
Canton OH 44718, U.S.
BILL of SALE
PRA (PRMS) — PSCC 180MP — June 2020 — ms847670
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 this
10" day of February 2020 by and between Synchrony Bank formerly known as GE Capital
Retail Bank; RFS Holding, L.L.C., Synchrony Card Funding, LLC and Retail Finance Credit
Services, LLC., (“Seller”) and Portfolio Recovery Associates, 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, to the extent of its ownership, the Accounts as set
forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on or
about 19th day of June 2020, and as further described in the Agreement.
Synchrony Bank
Fisher
By: bptisher (iun3s, 2020 1150807
Lynne Fisher
Title: SVP Recovery Operations
RFS Holding LLC
By ‘yypffisher (aun79, 20201150807)
Lynne Fisher
Title: Duly Authorized Signatory
Synchrony Card Funding, LLC
By: bptisher (iun3s, 2020 1150807
Lynne Fisher
Title: Duly Authorized Signatory
Retail Finance Credit Services, LLC
By: ifs
Lynne Fisher
Title: Vice PresidentSale File: MS847670.DL
ACCOUNT NUMBER
HIE 793
FORMER GE ACCOUNT
NUMBER
eEHHOOOO
CUSTOMER_TYPE
NAME
BRENENSON ROSE
BIRTH DATE
*“/**/1963
CUSTOMER _ID
Jonndonnonneine
LIABLE
ACCOUNT ADDRESS 1
203 SE COURANCES DR
ACCOUNT ADDRESS 2
CITY
PORT SAINT LUCIE
COUNTY
STATE
FL
ZIP_CODE
349846663
HOME_PHONE_NUMBER
Tonnddnnoneine
WORK PHONE NUMBER
Teneonnonnenee
HOME _PHONE_ FLAG
WORK_PHONE_FLAG
ADDRESS _ FLAG
LANG _IND
EN
MOBILE PHONE
DEBTOR E-MAIL ADDRESS
CO CUSTOMER TYPE
CO_NAME
CO_BIRTH_ DATE
CO_ CUSTOMER ID
CO ACCOUNT ADDRESS 1
CO_ACCOUNT ADDRESS 2
CO_CITY
CO COUNTY
CO_STATE
CO_ZIP_CODE
CO_HOME_PHONE_NUMBE
R
CO_WORK_PHONE_NUMBE
R
INTEREST_RATE
0000
CONTRACT_DATE
20150223
CHARGE OFF DATE
20190526
LAST PAYMENT DATE
20181018
CHARGE _OFF_AMOUNT
0000296355
ASSOCIATED COSTS
000000000
ACCRUED_ INTEREST
CURRENT_BALANCE
0000335672
NET_PRINCIPAL
000296355
NET ASSOCIATED COSTS
000000000
NET_INTERESTSale File: MS847670.DL
LAST_INTEREST DATE
00000000
LPA
00000003500
FDOD
20181127
LAST PURCHASE DATE
20181118
POST C/O PAYMENTS
POST C/O CREDITS
POST C/O INTEREST
POST C/O FEES
LENDING OFFICER CODE
ELI550
USER_FIELD
1181
DPS_ID_AGENCY_ATTY_C
ODE
PRMS
AGENCY CODE
DEBTOR ATTORNEY
DEBTOR ATTORNEY
ADDRESS 1
DEBTOR ATTORNEY
ADDRESS 2
DEBTOR ATTORNEY
ADDRESS 3
DEBTOR ATTORNEY CITY
DEBTOR ATTORNEY STATE
DEBTOR ATTORNEY ZIP.
DEBTOR ATTORNEY
PHONE NUMBER
DEBTOR ATTORNEY FAX
NUMBER
CO AGENCY CODE
EMPLOYERS NAME
EMPLOYERS_ADDRESS
CO_ EMPLOYERS NAME
CO_EMPLOYERS_ADDRES
Ss
MONTHLY_INCOME
000000000
MONTHLY_PAYMENT
000000000
NEXT_PAYMENT_ DATE
00000000
RECORD_TYPE
A
SEQUENCE NUMBER
00
TITLE
LOAN TYPE CODE
CARD
DEALER CODE
CHARGE_OFF_REASON_C
ODE
SKIP
ACCOUNT STATUS
SF2
SOURCE CODE
A
RECEIPT_DATE
20190528
LAST COMMENT LINE _1
LAST COMMENT LINE 2Sale File: MS847670.DL
LAST COMMENT LINE 3
LAST COMMENT _ DATE 00000000
SECOND_NAME_1
SECOND _NAME_2
OTHER INCOME 000000000
OTHER OBLIGATIONS 000000000
OWN_RENT_CODE
RECOVERY _ SCORE 000
LAST CONTACT DATE 20190502
COMMISSION_RATE 0000
FILLER
FORMAT CODE B
CO_ RECORD TYPE
CO_SEQUENCE_NUMBER
CO TITLE
FILLER1
FILLER2
CO_FORMAT_CODEDECLARATION OF CUSTODIAN OF RECORDS
I, the undersigned, Custodian of Records, for Portfolio Recovery Associates, LLC hereby declare, certify, and state as
follows:
1. Iam competent to testify to the matters contained herein.
2. Jam an authorized employee of Portfolio Recovery Associates, LLC, (“Account Assignee”) which is doing business
at Riverside Commerce Center, 120 Corporate Boulevard, Norfolk, Virginia. I am familiar with the policies and practices,
as well as the books and records of Account Assignee with respect to the matters stated herein. This declaration is based
upon my personal knowledge of Account Assignee’s record keeping system and my review of the business records of the
Original Creditor SYNCHRONY BANK/PC RICHARD, including a review of the business records transferred to Account
Assignee from SYNCHRONY BANK (“Account Seller”), which have become a part of and have integrated into Account
Assignee’s business records, in the ordinary course of business.
3. According to the business records, which are maintained in the ordinary course of business, the account, and all
proceeds of the account are now owned by the Account Assignee, all of the Account Seller’s interest in such account having
been sold, assigned and transferred by the Account Seller on 6/19/2020. Further, the Account Assignee has been assigned
all of the Account Seller’s power and authority to do and perform all acts necessary for the settlement, satisfaction,
compromise, collection or adjustment of said account, and the Account Seller has retained no further interest in said account
or the proceeds thereof, for any purpose whatsoever.
4. According to the records transferred to the Account Assignee from Account Seller, and maintained in the ordinary
course of business by the Account Assignee, there was due and payable from BRENENSON; ROSE (“Debtor and Co-Debtor’”)
to the Account Seller the sum of $3,356.72 with the respect to account number ending in Il as of the date of 5/26/2019
with there being no known un-credited payments, counterclaims or offsets against the said debt as of the date of the sale.
5. According to the account records of said Account Assignee, after all known payments, counterclaims, and/or setoffs
occurring subsequent to the date of sale, Account Assignee claims the sum of $3,317.72 as due and owing as of the date of
this declaration,
6. Plaintiff believes that the defendant is not a minor or an incompetent individual and declares that the Defendant is
not on active military service of the United States.
7. I declare under penalty of perjury under the laws of the State of Florida that the foregoing is true and correct.
Danville, VA
Executed on 6/9/2022 at
Portfolio Recovery Associates, LLC
Barth ringer
By: Hutchings, Glenda, Custodian of Records.
v1ROSE A BRENENSON
P C RICHARD & SON/SYNCHRONY BANK Ont lurnbar 3793
Statement Closing Date: 04/26/2019
Summary of Account Activity Payment Information
Previous Balance $3,169.87 || New Balance $3,317.72
+ New Purchases $0.00 | | Minimum Payment This Period $108.00
- Payments $0.00 | | Amount Past Due $531.00
+/- Credits, Fees & Adjustments (net) $39.00 | | Total Minimum Payment Due $639.00
+/-_Interest Charge (net) $108.85 || Payment Due Date 08/20/2019
New Balance $3,317.72] | promotion(s) expiring shortly - see promotional boxes below for
Credit Limit $3,000.00 | | Ct's
Available Credit $0.00 | | PAYMENT DUE BY 5 P.M. EASTERN ON THE DUE DATE.
Overlimit Amount $317.72 | | We may convert your payment into an electronic debit. See
Days In Billing Period 29 | | reverse side.
Pay online for free at: mysynchrony.com
For: ‘Synchrony Bank ‘customer ‘service or to report your | | Late Payment Warning: If we do not receive your Total
card lest or stolen, call 1-877-800-4727. Minimum Payment Due by the Payment Due Date listed above,
you may have to pay a late fee up to $39.00.
Minimum Payment Warning: Making only the Total Minimum
Payment Due will increase the amount of interest you pay and
the time it takes to repay your balance. For exempie:
Best times to call are Wednesday - Friday.
W you make no You will pay off [And you will end up|
additional charges |the balance shown|paying an estimated
using this card and| on this statement total of ...
each month you In about...
pay...
‘Only the minimum 16 years $9,791.00
Payment
If you would like information about credit counseling services,
call 1-877-302-8797.
Promotional Expiration Notification
YOU MUST PAY EACH PROMOTIONAL BALANCE IN FULL BY iTS EXPIRATION DATE TO AVOID PAYING DEFERRED
INTEREST CHARGES. PLEASE SEE THE PROMOTIONAL PURCHASE SUMMARY SECTION ON THIS STATEMENT
FOR FURTHER DETAILS. YOU HAVE A PROMOTION(S) EXPIRING ON 11/27/20 AND 05/28/19.
Promotional Purchase Summary
Promotional Promotional Billed Interest Deferred Descriptions
Expiration Balance Charge Interest Charge | Tran Date
Date
Deferred Interest/No Interest If Paid In
Full
EXPIRED $786.06 $101.99 $0.00 | 10/21/2018 $684.07
Deferred Interest/No Interest If Paid In
Full
05/28/2019 $528.69 $0.00 $66.39 | 11/18/2018 $528.69
Deferred Interest/No Interest If Paid In
Full
41/27/2020 $1,649.77 $0.00 $207.14 | 11/18/2018 $1,649.77
‘A summary of your promotional purchase is provided above.
If you have a DEFERRED INTEREST/NO INTEREST IF PAID IN FULL promotion: To avoid paying Deferred Interest Charges.
on these promotion(s), you must pay the entire applicable Promotional Balance by the Promotional Expiration Date.
‘To make more than one payment see Make Payment To address or pay online at mysynchrony.com.
* NOTICE: See reverse side and additional pages (if any) for important information concerning your account.
ey ontna at mreynctvony.com or encose tia coupon with your chaok, Please use bie of back nk
FR FOUCTRAT OP Sn Account Number SH 3795
2; RECIPE Se ocr | Pact ous eayment xo
Payment Due Amount Due Date ur unt Balance
Promotion(s) expiring:
$839.00 $531.00 08/20/2019 mI oace above, $3,317.72
Payment Enclosed:
oO New address or e-mail? — Payment due inciudes § 531.00 past due. Please pay the past due amount PROMPTLY.
‘Check the box at loft and 2
the Dox at NOTE: You have a Promotional Purchase Expiring. See Promotional Purchase Summary For Detalls.
ROSE A BRENENSON
203 SE COURANCES DR
Make Payment to: SYNCHRONY BANK
PORT ST LUCIE FL 34984-6663 PO BOX 860061
ORLANDO, FL 32896-0061[Transaction Summary
2019 Totals Year-to-Date
[Total Fees Charged in 2019
[Totat Interest Charged in 2019
[Totat Interest Paid in 2019
$155.00]
$124.26
$0.00}
Tran Date | PostDate | Reference Number Description Amount
FEES
04/20/2019 04/20/2018 LATE FEE $39.00
TOTAL FEES FOR THIS PERIOD $39.00}
INTEREST CHARGED
04/26/2019 04/26/2019 INTEREST CHARGE ON PURCHASES $108.65
TOTAL INTEREST FOR THIS PERIOD $108.85)
Interest Charge Calculation
Expiration Date Annual Balance Subject to | Interest Charge
Type of Balance Percentage Interest Rate
Rate (APR)
Purchases NA 26.99% $319.96 $6.66
Deferred Interest/No Interest If Paid In Full EXPIRED 26.99% $777.39 $101.99
05/28/2019 26.99% $588.53 $0.00
11/27/2020 26.98% $1,836.45 $0.00
Cardholder News & Information
You can pay your bill
your account online.
YOUR ACCOUNT IS PAST DUE. PLEASE PAY THE MINIMUM PAYMENT DUE OR
CONTACT THIS OFFICE AT THE PHONE NUMBER LISTED ON YOUR STATEMENT.
ine or over the phone. We noticed you've been enjoying our easy paperless payment options, so we
will no longer be including return envelopes. You can make things even easier by selecting the papertess statement option on
5302 oxn 2 7
25
190426
EX PAGE 2 of 3
9072
0300 Pcs2 01pGs3025302 coxn 1 7 25 190426 EX PAGE 3 of 3 9071 0300 Pca2 o1pGs302PC RICHARD & SON/SYNCHRONY BANK
ROSE A BRENENSON
Account Number: i’ 3°
Statement Closing 10/28/2018
793
Summary of Account Activity
Payment Information
Previous Balance $217.12
+ New Purchases $684.07
- Payments $35.00
+/- Credits, Fees & Adjustments (net) ($81.10)
+/-_Interest Charge (net) $4.04
New Balance $789.13
‘Credit Limit $3,000.00
Available Credit $2,210.00
Days In Billing Period 34
Pay online for free at: mysynchrony.com
For Bank customer service or to report your
card lost or stolen, call 1-877-800-4727.
Best times to call are Wednesday - Friday.
New Balance $789.13
Total Minimum Payment Due $27.00
Payment Due Date 11/20/2018
PAYMENT DUE BY 5 P.M. EASTERN ON THE DUE DATE.
We may convert your payment into an electronic debit. See
reverse side.
Late Payment Warning: If we do not receive your Total
Minimum Payment Due by the Payment Due Date listed above,
you may have to pay a late fee up to $38.00.
Minimum Payment Warning: Making only the Total Minimum
Payment Due will increase the amount of interest you pay and
the time it takes to repay your balance. For exemple:
If you make no You will pay off [And you wii
\dditional charges |the balance shown/paying
using this card and| on this statement
up|
end
mated
est
of...
each month you In about...
pay...
‘Only the minimum 4 years $1,341.00
payment
$32.00 3 years $1,166.00
(Savings = $445.00)
If you would like information about credit counseling services,
call 1-877-302-8797.
Promotional Expiration Notification
YOU MUST PAY EACH PROMOTIONAL BALANCE IN FULL BY (TS EXPIRATION DATE TO AVOID PAYING DEFERRED
INTEREST CHARGES. PLEASE SEE THE PROMOTIONAL PURCHASE SUMMARY SECTION ON THIS STATEMENT
FOR FURTHER DETAILS. YOU HAVE A PROMOTION(S) EXPIRING ON 04/26/19.
* NOTICE: See reverse side and additional pages (if any) for important information concerning your account.
5302 cova 1 7 25 181028
PAGE 1 of 5
9071 0300 Pcg2 01DG5302
Pay online st mysynchrony.com or enciose this coupon with your check. Please use blue or black ink.
Pex Total Minimum Payment Due Date Now Balance ‘Account Number
Sie Company You Com Frweti> Payment Due
$27.00 11/20/2018 $789.13 es
Payment Enclosed : $
New address or e-mal
Check the box at oft and
Print changes on back
ROSE A BRENENSON
203 SE COURANCES DR
PORT ST LUCIE FL 34984-6663
If you only pay the Tota! Minimum Due it may not pey off the Promotional Purchase by the Expiration Date.
Make Payment to: SYNCHRONY BANK
PO BOX 960061
ORLANDO, FL 32896-0061Promotional Purchase Summary
‘Promotional ‘Promotional Deferred Tran Date | Description Initial
Expiration Balance Interest Charge Purchase
Date Amount
04/26/2019 $684.07 $4.06 | 10/21/2018 | Dererred Interest/No Interest If Paid In $684.07
‘A summary of your promotional purchase is provided above.
If you have a DEFERRED INTEREST/NO INTEREST IF PAID IN FULL promotion: To avoid paying Deferred Interest Charges
‘on these promotion(s), you must pay the entire applicable Promotional Balance by the Promotional Expiration Date.
‘To make more than one payment see Make Payment To address or pay online at mysynchrony.com.
[Transaction Summary
Tran Date | PostDate | Reference Number | Peseription Amount
7048/2018 10/16/2016 8534812MKOOZMFOES PAYMENT - THANK YOU ($35.00)
40/18/2018 10/18/2018 + FS07100MKOOOLF291 REFUND OF LATE FEES ($27.00)
10/27/2018 10/27/2018 8534812MXOOXTN2KS PC RICHARD AND SON 015 LEVITTOWN ($54.10)
CREDIT
ELECTRONICS/APPLIANCES
10/21/2018 = 10/21/2018 &534812MNOOXTNGQY PC RICHARD AND SON 015 LEVITTOWN $684.07
NY
DEFERRED INTEREST/NO INTEREST IF
PAID IN FULL
ELECTRONICS/APPLIANCES
FEES
TOTAL FEES FOR THIS PERIOD $0.00
INTEREST CHARGED
10/28/2018 = 10/28/2018 INTEREST CHARGE ON PURCHASES, $4.04
TOTAL INTEREST FOR THIS PERIOD $4.04]
2018 Totals Year-to-Date
[Total Fees Charged in 2018 ‘$0.00
[Total Intorest Charged in 2018 $66.77]
[Total Interest Paid in 2018 $139.45}
Interest Charge Calculation
Expiration Date Annual Balance Subject to | Interest Charge
‘Type of Batance Percentage Interest Rate
Rate (APR)
Purchases NA 26.89% $176.16 $4.04
Deferred Interest/No Interest If Paid In Full 04/26/2019 26.99% $176.99 $0.00
New Promotional Financing Plans
This notice is to let you know about some promotional financing plans that may be available for you when you use your card for
future purchases. This is only a summary of key terms. At times, we may offer you other promotional financing plans for
certain purchases. OCetails of available promotions will be provided to you at the time of your transactions. Not all plans or all
plan periods will be available at every retailer. For purposes of this notification, your. Purchase Annual Percentage Rate
("APR") is 26.99% See the Interest Charge Calculation section of this billing statement to determine if this APR is variable. If a
(v) is shown next to your APR, this APR will vary with the market based on the prime rate. Subject to credit approval. Regular
account terms apply to non-promotional purchases and, after promotion ends, to promotional purchase.
No Interest if Paid Within Promotional Period
(These can be advertised as Deferred Interest promotions)
be assessed if the promotional purchase balance (including any promotional fee)
is paid in full within the promotional period. If the promotional purchase balance is not paid in full by the end of the promotional
period, interest will be imposed from the date of purchase at the APRstated above. Minimum monthly payments are
required. This promotion may be offered for periods of 6, 9, 12, 15, 18, or 24 months.
Please keep this for your records. If you have any questions, please call us at the Customer Service number shown on your
statement
5302 oxn 2 7 25 161026 PAGE 2 of 5 9071 0300 Pcgs2 o1pGs302Cardholder News & Information
You can pay your bill online or over the phone. We noticed you've been enjoying our easy paperless payment options, so we.
will no longer be including return envelopes. You can make things even easier by selecting the paperless statement option on
your account online.
Synchrony Bank may continue to obtai
includ juesting reports from consumer rej
formation, including employment and income information from others about you
yenci \d_ other sources) to review, maintain or collect your account.
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