Preview
Filing # 156455416 E-Filed 08/30/2022 09:10:27 PM
MLG - 4587429 IN THE COUNTY COURT OF THE
EIGHTEENTH JUDICIAL CIRCUIT IN
AND FOR BREVARD COUNTY, FLORIDA
SMALL CLAIMS DIVISION
CASE NO.
UHG I LLC
Plaintiff,
vs.
BRIAN ORDNER
Defendant.
/
STATEMENT OF CLAIM
COMES NOW the Plaintiff, UHG I LLC, by and through its undersigned attorney, sues
Defendant BRIAN ORDNER , and alleges:
GENERAL ALLEGATIONS
1. This is an action for damages in an amount less than or equal to $8,000.00, exclusive of
interest, costs and attorney fees, and comes within the jurisdiction of this Court.
2. Plaintiff is a foreign corporation authorized to bring this action pursuant to Fla. Stat. §
607.1501 (2)(a).
3. Defendant is a resident of BREVARD County, Florida.
4. All conditions precedent to the bringing of this action has been performed, have
occurred or have been waived.
COUNTI
(ACCOUNT STATED)
5. Plaintiff incorporates and realleges paragraphs 1-4.
Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XX10.
11.
Defendant made purchases and/or received cash advances utilizing credit extended by
SYNCHRONY BANK (the 'Creditor’) , account number Ee
In accordance with the transactions made by Defendant on the account (the 'Account’)
heretofore mentioned, Creditor and Defendant agreed to the resulting balance.
Creditor rendered statement(s) of the Account to Defendant, copies of which are
attached hereto and incorporated herein as Exhibit 'A', and Defendant did not object to
the statement(s).
Defendant failed and/or refused to pay for said purchases or cash advances as agreed,
or otherwise.
Plaintiff has purchased the debt incurred by Defendant and now owns and holds all
rights relative thereto, as evidenced by a copy of the ownership transfer documents
attached hereto and incorporated herein as Exhibit 'B’.
Defendant owes Plaintiff $3,876.56.
WHEREFORE, Plaintiff demands judgment against Defendant for the sum of $3,876.56 plus
costs, and such other and further relief as the Court may deem just and proper.
12.
13.
14.
Filing 156455416
COUNT
(UNJUST ENRICHMENT)
Plaintiff incorporates and realleges paragraphs 1-4 and paragraph 10.
The Creditor has conferred a benefit on Defendant by providing credit for cash
advances, products and/or goods and services.
Defendant has knowledge of the benefit and the use thereof by Defendant constitutes
an unjust enrichment of Defendant at Plaintiff’s expense.
Uhg | Lic v. Brian Ordner 05-2022-SC-043239-XXXX-XX15. Defendant has accepted or retained the benefit conferred and the circumstances are
such that it would be inequitable for the Defendant to retain the benefit without paying
fair value for it. Defendant has failed to pay for said benefit and Defendant has
therefore been unjustly enriched.
16. As aresult of the unjust enrichment of Defendant, Plaintiff has been damaged in an
amount in equal to $3,876.56.
WHEREFORE, Plaintiff demands judgment against Defendant for the sum of $3,876.56
plus costs, and such other and further relief as the Court may deem just and proper.
Mandarich Law Group, LLP
/s/ Michelle K. Hines, Esq.
Harold E. Scherr, Esq. FBN 240486
Hillarey McCall, Esq. FBN 607525
Michelle K. Hines, Esq. FBN 85092
Maxxwell Tyler Hamilton, Esq. FBN 95985
Hunter Masin, Esq. FBN 1028137
P.O. Box 952289
Lake Mary, FL 32795
Phone: 407-995-3004
Facsimile: 407-583-4964
florida@mandarichlaw.com
Attorneys for Plaintiff
DESIGNATION OF EMAIL ADDRESS
Pursuant to Fla. R. Jud. Admin. 2.516 Plaintiff's Counsel hereby designates
florida@mandarichlaw.com
as its primary email address for the receipt of pleadings.
Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXEXHIBIT A
Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXPay?=i
CREDIT Need More Information?
Statement Closing Date: 04/13/21 View your account online at paypal.com
Days in Billing Period: 30 Or Call A 8 AM ET to 11 PM ET
Account Number: ,
Customer Name: BRIAN ORDNER Mon-Fri and 9 AM ET to 9 PM ET Sat-Sun
ACCOUNT SUMMARY PAYMENT INFORMATION
Previous Balance $3,767.53 | | New Balance ‘$3,876.56
- Payments & Credits $0.00 | | Amount Past Due $820.00
+ Purchases & Adjustments $0.00 | | Minimum Payment Due $967.00
+ Fees $40.00 Payment Due Date 05/08/21
+ INTEREST CHARGES $69.03 Amount to avoid Standard and Deferred Interest
= New Balance $3,876.56 | | on your next statement: $3,876.56
See Reverse
Credit Limit $3,250.00 | 11 ate Payment Warning: If we do net receive your minimum payment
Available Credit OVERLIMIT | | by 05/08/21, you may have to pay a late fee of up to $40.00.
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:
Kiyo make ne ore | You wil pay Of tie "| And you will end up peyiad
charges using this_| balance shown on this | an estimated tot
account and each _| statement in about:
month you pay:
Only the minimum
Payment 11 Years $7,860.00
If you would like information about credit counseling services, call
a
CURRENT ACTIVITY
FEES
Tran Date Posting Date Description Amount
04/13/21 04/13/21 Late Fee $40.00
Total Fees ‘$40.00
INTEREST CHARGED
Tran Date Posting Date Description Amount
04/13/21 04/13/21 Interest Charge on Purchases $69.03
Total Interest $69.03
[2021 Totals Year-To-Date
Total Fees Charged in 2021: $159.00 Total Interest Charged in 2021: $264.14
IMPORTANT ACCOUNT INFORMATION
YOUR ACCOUNT IS PAST DUE. PLEASE PAY THE MINIMUM PAYMENT DUE OR
CONTACT THIS OFFICE AT THE PHONE NUMBER LISTED ON YOUR STATEMENT.
NOTICE: We may convert your payment into an electronic debit. See reverse for details, Billing Rights Information and other important information
PoyPa! etc nd mal porn win your eck bo encase ry areepndence win your enc
Account Number:
CREDIT Account wo —
Payment Due Date: 05/08/21
Make Check Payable to PayPal Credit Minimum Payment Due: $967.00
Return this portion with your payment. i
St i rt wt ere Amount Encieed EI
To receive electronic statements or make
online payments visit paypal.com.
PAYPAL CREDIT/SYNCB BRIAN ORDNER
PO BOX 960006 1707 MANTES DR
ORLANDO, FL 32896-0006 COCOA FL 32926-5767
Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXCustomer Service: For account information, call the number on the front of this statement. For Hearing or Speech disabilities, use a TRS. Unless your name is listed on this
statement, your access to information on the account may be limited. You may also mail questions (but not payments) to” P.O. Box 965004, Orlando, FL 32896-5004. Please include
your account number on any correspondence you send to us.
Payments: Send payments to the address listed on the remit portion of this statement ot pay online at www paypal. com
Notice: See below for your Billing Rights and other important information.
Purchases, returns, and payments made just prior to billing date may not appear until next month's statement. When you provide @ check as payment, you authorize us either to use
information from your check to make a one-time electronic fund transfer from your account of to process the payment as a check transaction, When we Use information from your check
to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check back from your
financial institution. You may choose not to have your check collected electronically by sending your check (with the payment stub), in your own envelope ~ not the enclosed
window envelope, addressed to:
.0. Box 530993, Atlanta, GA 30353-0993 and not the Payment Address.
What To Do If You Think You Find A Mistake On Your Statement
Ifyou think there is an error on your statement, write fo us at
Synchrony Bank
PO. Box 965003
Orlando, FL 32896-5003
Orcallcustone sevice |
Ifyou write to us, in your letter, give us the following information:
+ Account information: Your name and account number
+ Dollar amount: The dollar amount of the suspected error,
+ Description of Problem: If you think there is an error on your bill, describe what you
believe is wrong and why you believe itis a mistake
You must contact us within 60 days after the error appeared on your statement
You must notify us of any potential errors in writing or by calling customer service at
a
While we investigate whether or not there has been an error, the following are true:
= We cannot try to collect the amount in question or report you as delinquent on
that amount
+ The charge in question may remain on your statement, and we may continue to charge
you interest on that amount. But, ifwe determine that we made a mistake, you will not
have to pay the amount in question or any interest or other fees related to that amount
+ While you do not have to pay the amount in question, you are responsible for the
remainder of your balance,
+ We can apply any unpaid amount against your credit limit.
Your Rights if You Are Dissatisfied With Your Credit Card Purchases
Ifyou are dissatisfied with the goods or services that you have purchased with your credit
card, and you have tried in good faith to correct the problem with the merchant, you may
have the right not to pay the remaining amount due on the purchase.
To.use this right, all of the following must be true:
1.The purchase must have been made in your home state or within 100 miles of
your current mailing address, and the purchase price must have been more than
$50. (Note: Neither of these are necessary if your purchase was based on an
advertisement we mailed to you, or if we own the company that sold you the goods
or services.)
2.You must have used your credit card for the purchase. Purchases made with cash
advances from an ATM or with a check that accesses your credit card account de
not qualify,
3. You must not yet have fully paid for the purchase.
Ifall of the criteria above are met and you are still dissatisfied with the purchase, contact
us in wniting at
Synchrony Bank
PO. Box 985003
Orlando, FL 32896-5003
Orcallcustoner sevice |
While we investigate, the same rules apply to the disputed amount as discussed above
After we finish our investigation, we will tell you our decision. At that point, if we think you
owe an amount and you do not pay we may report you as delinquent
Information About Payments: You may at any time pay, in whole or in part, the total
unpaid balance without any additional charge for prepayment.
Payments made by mail or made using a third-party bill pay service provider:
Payments received after 5:00 p.m. (ET) on any day will be credited as of the next day
Credit to your Account may be delayed up to five days if payment (a) is not received at
the Payment Address, (b) is not made in U.S. dollars drawn on a U.S. financial institution
located in the US. (6) is not accompanied by the remittance coupon attached to your
statement, (@) contains more than one payment or remittance coupon, (e) is not received
in the remittance envelope provided or (f) includes staples, paper clips, tape, a folded
check, or correspondence of any type.
Payments made by phone or online: |f you make a payment by phone or online before
11°59 p.m. Eastern Time, we will credit it as of the date the payment is made,
All written communications concerning disputed amounts, including
any check or other payment instrument that: (i) indicates that the payment constitutes
‘payment in full” or is tendered as full satisfaction of a disputed amount: or (i) is tendered
with other conditions or limitations (‘Disputed Payments”), must be mailed or delivered to
us at P.O. Box 965003, Orlando, FL 32896-5003
Credits To Your Account: An amount shown in parenthesis or preceded by a minus ()
sign is a credit or credit balance unless otherwise indicated. Credits will be applied to
your previous balance immediately upon receipt, but will not satisfy any required payment
that may be due,
Credit Reports And Account Information: If you believe that we have reported
inaccurate information about you to a consumer reporting agency, please contact us at
PO. Box 965005, Orlando, FL 32896-5005. In doing so, please identify the inaccurate
information and tell us why you believe it is incorrect. If you have a copy of the credit
report that includes the inaccurate information, please include a copy of that report, We.
may report information about your account to credit bureaus. Late payments, missed
payments, or other defaults on your account may be reflected in your credit report
Bankruptcy Notice: if you file bankruptcy, you must send us notice, including account
umber and all information related to the proceeding to the following address: P.O. Box
965064, Orlando, FL 32896-5064
Paying Interes:
Your due date is at least 25 days after the close of each billing cycle. We will not charge:
you any interest on non-promotional transactions if you pay your entire balance by the
due date each month. We will begin charging interest on promotional purchases on the
purchase date
How We Calculate the Balance on Which the Interest is Compute
We calculate interest on your account for each billing cycle separately for each balance
type. A separate average daily balance is calculated for the following balance types, as
applicable: standard purchases, cash advances and promotional purchases. To get the
average daily balance, we take the starting balance each day, including billed interest
and billed fees, add any new charges and adjustments posted that day and subtract
any payments or credits (treating any net credit balance as zero). This gives us the
daily balance. Then, we add up all the daily balances for the billing cycle and divide the
total by the number of days in the billing cycle. The result is the average daily balance.
The average daily balance is referred to as the Balance Subject to Interest Rate on
your statement.
Amount to Avoid Standard and Deferred interest on your next statement:
(see PAYMENT INFORMATION box on front page)
This amount includes:
Standard Purchases and Cash Advances
Purchases without any promotional offer and Cash Advances
Deferred Interest Purchases Expiring This Billing Cycle
Purchases made with ‘No Payments + No Interest if paid in full’ and ‘No Interest if paid in
full’ promotions that are about to expire
Easy Payments Purchases Monthly Plan Payments
‘Although unrelated to avoiding Standard and Deferred Interest, we include Monthly Plan
Payments to help you avoid late fees. If you have a Financed Easy Payments Purchase
balance, you will continue to be assessed interest on the Easy Payments Purchase
balance until itis paid in full
Your Account is owned and serviced by Synchrony Bank.
[WF7362464] O1DRE128 - 3- 02/21/19
This is an attempt to collect a debt and any information obtained will be used for that purpose,
“By providing a telephone number on your account, you consent to Synchrony Bank and any other owner or servicer of your account contacting you about your account, including using
any contact information or cell phone numbers you provide, and you consent to the use of any automatic telephone dialing system andlor an artificial or prerecorded voice when contacting
you, even if you are charged for the call under your phone plan
For changes of address, phone number and/or email, please check the box and print the changes below. These changes will be applied to PayPal Credit but not to your PayPal Account.
O
Street
Address:
City, State
zip
Phone #
Email
“Home Phone # “Business Phone # *Cell # or other phone # “Email Address
we can use to contact you
providing your email address, you agree to receive email communications about your account and also give permission for us to share Suen address with PayPal Credit
Filing 186455416 Uhg | Lic v. Brian Ordner )5-2022-SC-043239-XXXX-XXStatement Closing Date: 04/13/21
Days in Billing Period: 30
Account Number: Sas
Customer Name: BRIAN ORDNER
INTEREST DETAILS
INTEREST CHARGE CALCULATION
View your account online at
Paypal.com
Or call MME 8 AM ET to 11 PM ET
Mon-Fri and 9 AM ET to 9 PM ET Sat-Sun
‘Your Annual Percentage Rate (APR}s the annual interest rate on your account.
Balance Type Annual Percentage Balance Subject to Interest Charged Current Balance
Rate(APR) Interest Rate
‘Standard Purchases 23.99% (v) $2,177.99 $42.82 $2,254.73
PayPal Send Money Cash Advances 23.99% (v) $0.00 $0.00 $0.00
Balance Prior To Terms Change 19.99% $1,595.62 $26.21 $1,621.83
(V)=Variable Rate
ACCOUNTHOLDER NOTICES
This is a duplicate courtesy copy of your most recent billing statement. You can still view and pay your electronic statement online.
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 inciuding return envelopes. You can make things even easier by selecting the paperless statement option on your account
online.
Filing 156455416
6128 ang ool 7 an
210413 0
Uhg | Lic v. Brian Ordner
EX PAGE 2 of 3
10 9283 2100
POVA O1DR6128
05-2022-SC-043239-XXXX-XXFiling 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XX
6128 ABS oor 7 22 210413 0 EXPAGE 3 of 3 10 9283 2100 PSVA o1pRe128EXHIBIT B
Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XX~ synchrony
4500 Munson St NW
Canton OH 44718, U.S.
BILL of SALE
UHG (UFRS) — PLCC PayPal Fresh — June 2021
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
12" day of August, 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 UIIG I 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 16" day of June 2021 and as
further described in the Agreement.
Synchrony Bank
Lynne Fisher
Title: SVP Recovery Operations
RFS Holding LLC
Fisher (lun 29,2024 12:32 E87}
Lynne Fisher
Title: Duly Authorized Signatory
Synchrony Card Funding, LLC
Lynne Fisher
Title: Duly Authorized Signatory
Retail Finance Credit Services, LLC
He Fishvos (Aut 28, 2021 1252 EDT)
Lynne Fisher
Title: Vice President
Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXAFFIDAVIT OF SALE
OF ACCOUNT
BY ORIGINAL CREDITOR
State of Florida County of Seminole
Julio A Perez being duly sworn, deposes and says:
Jam 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 6/16/2021 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
UHG I 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 6th day of July, 2021
Julio A Perez
Signed and sworn to before me this 6th day of July, 2021
(Notary Stamp)
5
OMAIRA HERNANDEZ
tate of Floride-Notaty Public}
Commission # GG 149741
My Commission Expires
October 03, 2021
NY AOS 1.3 2/1/2017 - St. Paul
Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXNY CoC CERTIFICATE OF CONFORMITY UNDER
NYS CLS CPLR § 2309(c) AND NYS CLS RPL § 299-a
The undersigned does hereby certify that he/she is an attorney-at-law duly admitted to
practice in the State of Florida and residing in the State of Florida; that he/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 he/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 Julio A Perez was taken by Omaira Hernandez, 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 his/her review thereof, that the notarized Affidavit
conforms to the laws of the State of Florida in all respects.
Witness my signature this 6th day of July, 2021
Tyler Burich
Attorney-at-law, State of Florida.
Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXpri_acctno MKR_FN MKR_LN
es BRIAN ORDNER
CMPNY_NAME MKR_TAXID MKR_AD1
a 1707 MANTES DR
MKR_AD2 MKR_AD3 MKR_CITY
COCOA
MKR_ST MKR_ZIP MKR_HP
FL 32926-5767 0000000000
MKR_WP MKR_BARDATE MKR_BKCHAP
000000000 oO
MKR_CASENUM MKR_DISCHDTE MKR_DISMSDTE
oO oO
MKR_BKMEETDTE MKR_BKCOURT MKR_BKFILEDT
0 0
ECOA OPENDATE CHGOFF_DATE
1 20160906 20210512
RMSLASTPMT LASTPMTAMT BRANCH
20201013 129 CPPC
DOFD CHGOFFCODE LOSSAMT
20201113 SKIP 3916.56
CURBAL Principal Bal RMSFILENUM
3916.56 3916.56 98905147
ACCTSTS STSDESC JDGDATE
SF5 Sales - Final - Primary Random Sale 0
OFF_CODE OFF_DESC BCLE
PALO48 PayPal Credit 0181
BCLE_DESC BUYERCODE INT_RATE
Synchrony Bank UFRS 0
NET_COSTS NET_INTEREST NET_PRINCIPAL
oO 1077.25 2839.31
Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXPRINC_LOSS ASSOC_COSTS ACCRD_INT
2839.31 0 1077.25
CREDITSCOR LASTPURCHDT CMKR_FN
= 20200802
CMKR_LN CMKR_TAXID CMKR_ADDR1
CMKR_ADDR2 CMKR_CITY CMKR_STATE
CMKR_ZIP CMKR_LIABLE MKR_DOB
a
LANG IND RMSBRGLVL2 MkR_CP
EN RCF
OUT_OF_STATUE
11/12/2025 12:00:00 AM
Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XX
Preview
Filing # 156455416 E-Filed 08/30/2022 09:10:27 PM MLG - 4587429 IN THE COUNTY COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA SMALL CLAIMS DIVISION CASE NO. UHG I LLC Plaintiff, vs. BRIAN ORDNER Defendant. / STATEMENT OF CLAIM COMES NOW the Plaintiff, UHG I LLC, by and through its undersigned attorney, sues Defendant BRIAN ORDNER , and alleges: GENERAL ALLEGATIONS 1. This is an action for damages in an amount less than or equal to $8,000.00, exclusive of interest, costs and attorney fees, and comes within the jurisdiction of this Court. 2. Plaintiff is a foreign corporation authorized to bring this action pursuant to Fla. Stat. § 607.1501 (2)(a). 3. Defendant is a resident of BREVARD County, Florida. 4. All conditions precedent to the bringing of this action has been performed, have occurred or have been waived. COUNTI (ACCOUNT STATED) 5. Plaintiff incorporates and realleges paragraphs 1-4. Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XX10. 11. Defendant made purchases and/or received cash advances utilizing credit extended by SYNCHRONY BANK (the 'Creditor’) , account number Ee In accordance with the transactions made by Defendant on the account (the 'Account’) heretofore mentioned, Creditor and Defendant agreed to the resulting balance. Creditor rendered statement(s) of the Account to Defendant, copies of which are attached hereto and incorporated herein as Exhibit 'A', and Defendant did not object to the statement(s). Defendant failed and/or refused to pay for said purchases or cash advances as agreed, or otherwise. Plaintiff has purchased the debt incurred by Defendant and now owns and holds all rights relative thereto, as evidenced by a copy of the ownership transfer documents attached hereto and incorporated herein as Exhibit 'B’. Defendant owes Plaintiff $3,876.56. WHEREFORE, Plaintiff demands judgment against Defendant for the sum of $3,876.56 plus costs, and such other and further relief as the Court may deem just and proper. 12. 13. 14. Filing 156455416 COUNT (UNJUST ENRICHMENT) Plaintiff incorporates and realleges paragraphs 1-4 and paragraph 10. The Creditor has conferred a benefit on Defendant by providing credit for cash advances, products and/or goods and services. Defendant has knowledge of the benefit and the use thereof by Defendant constitutes an unjust enrichment of Defendant at Plaintiff’s expense. Uhg | Lic v. Brian Ordner 05-2022-SC-043239-XXXX-XX15. Defendant has accepted or retained the benefit conferred and the circumstances are such that it would be inequitable for the Defendant to retain the benefit without paying fair value for it. Defendant has failed to pay for said benefit and Defendant has therefore been unjustly enriched. 16. As aresult of the unjust enrichment of Defendant, Plaintiff has been damaged in an amount in equal to $3,876.56. WHEREFORE, Plaintiff demands judgment against Defendant for the sum of $3,876.56 plus costs, and such other and further relief as the Court may deem just and proper. Mandarich Law Group, LLP /s/ Michelle K. Hines, Esq. Harold E. Scherr, Esq. FBN 240486 Hillarey McCall, Esq. FBN 607525 Michelle K. Hines, Esq. FBN 85092 Maxxwell Tyler Hamilton, Esq. FBN 95985 Hunter Masin, Esq. FBN 1028137 P.O. Box 952289 Lake Mary, FL 32795 Phone: 407-995-3004 Facsimile: 407-583-4964 florida@mandarichlaw.com Attorneys for Plaintiff DESIGNATION OF EMAIL ADDRESS Pursuant to Fla. R. Jud. Admin. 2.516 Plaintiff's Counsel hereby designates florida@mandarichlaw.com as its primary email address for the receipt of pleadings. Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXEXHIBIT A Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXPay?=i CREDIT Need More Information? Statement Closing Date: 04/13/21 View your account online at paypal.com Days in Billing Period: 30 Or Call A 8 AM ET to 11 PM ET Account Number: , Customer Name: BRIAN ORDNER Mon-Fri and 9 AM ET to 9 PM ET Sat-Sun ACCOUNT SUMMARY PAYMENT INFORMATION Previous Balance $3,767.53 | | New Balance ‘$3,876.56 - Payments & Credits $0.00 | | Amount Past Due $820.00 + Purchases & Adjustments $0.00 | | Minimum Payment Due $967.00 + Fees $40.00 Payment Due Date 05/08/21 + INTEREST CHARGES $69.03 Amount to avoid Standard and Deferred Interest = New Balance $3,876.56 | | on your next statement: $3,876.56 See Reverse Credit Limit $3,250.00 | 11 ate Payment Warning: If we do net receive your minimum payment Available Credit OVERLIMIT | | by 05/08/21, you may have to pay a late fee of up to $40.00. 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: Kiyo make ne ore | You wil pay Of tie "| And you will end up peyiad charges using this_| balance shown on this | an estimated tot account and each _| statement in about: month you pay: Only the minimum Payment 11 Years $7,860.00 If you would like information about credit counseling services, call a CURRENT ACTIVITY FEES Tran Date Posting Date Description Amount 04/13/21 04/13/21 Late Fee $40.00 Total Fees ‘$40.00 INTEREST CHARGED Tran Date Posting Date Description Amount 04/13/21 04/13/21 Interest Charge on Purchases $69.03 Total Interest $69.03 [2021 Totals Year-To-Date Total Fees Charged in 2021: $159.00 Total Interest Charged in 2021: $264.14 IMPORTANT ACCOUNT INFORMATION YOUR ACCOUNT IS PAST DUE. PLEASE PAY THE MINIMUM PAYMENT DUE OR CONTACT THIS OFFICE AT THE PHONE NUMBER LISTED ON YOUR STATEMENT. NOTICE: We may convert your payment into an electronic debit. See reverse for details, Billing Rights Information and other important information PoyPa! etc nd mal porn win your eck bo encase ry areepndence win your enc Account Number: CREDIT Account wo — Payment Due Date: 05/08/21 Make Check Payable to PayPal Credit Minimum Payment Due: $967.00 Return this portion with your payment. i St i rt wt ere Amount Encieed EI To receive electronic statements or make online payments visit paypal.com. PAYPAL CREDIT/SYNCB BRIAN ORDNER PO BOX 960006 1707 MANTES DR ORLANDO, FL 32896-0006 COCOA FL 32926-5767 Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXCustomer Service: For account information, call the number on the front of this statement. For Hearing or Speech disabilities, use a TRS. Unless your name is listed on this statement, your access to information on the account may be limited. You may also mail questions (but not payments) to” P.O. Box 965004, Orlando, FL 32896-5004. Please include your account number on any correspondence you send to us. Payments: Send payments to the address listed on the remit portion of this statement ot pay online at www paypal. com Notice: See below for your Billing Rights and other important information. Purchases, returns, and payments made just prior to billing date may not appear until next month's statement. When you provide @ check as payment, you authorize us either to use information from your check to make a one-time electronic fund transfer from your account of to process the payment as a check transaction, When we Use information from your check to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check back from your financial institution. You may choose not to have your check collected electronically by sending your check (with the payment stub), in your own envelope ~ not the enclosed window envelope, addressed to: .0. Box 530993, Atlanta, GA 30353-0993 and not the Payment Address. What To Do If You Think You Find A Mistake On Your Statement Ifyou think there is an error on your statement, write fo us at Synchrony Bank PO. Box 965003 Orlando, FL 32896-5003 Orcallcustone sevice | Ifyou write to us, in your letter, give us the following information: + Account information: Your name and account number + Dollar amount: The dollar amount of the suspected error, + Description of Problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe itis a mistake You must contact us within 60 days after the error appeared on your statement You must notify us of any potential errors in writing or by calling customer service at a While we investigate whether or not there has been an error, the following are true: = We cannot try to collect the amount in question or report you as delinquent on that amount + The charge in question may remain on your statement, and we may continue to charge you interest on that amount. But, ifwe determine that we made a mistake, you will not have to pay the amount in question or any interest or other fees related to that amount + While you do not have to pay the amount in question, you are responsible for the remainder of your balance, + We can apply any unpaid amount against your credit limit. Your Rights if You Are Dissatisfied With Your Credit Card Purchases Ifyou are dissatisfied with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the purchase. To.use this right, all of the following must be true: 1.The purchase must have been made in your home state or within 100 miles of your current mailing address, and the purchase price must have been more than $50. (Note: Neither of these are necessary if your purchase was based on an advertisement we mailed to you, or if we own the company that sold you the goods or services.) 2.You must have used your credit card for the purchase. Purchases made with cash advances from an ATM or with a check that accesses your credit card account de not qualify, 3. You must not yet have fully paid for the purchase. Ifall of the criteria above are met and you are still dissatisfied with the purchase, contact us in wniting at Synchrony Bank PO. Box 985003 Orlando, FL 32896-5003 Orcallcustoner sevice | While we investigate, the same rules apply to the disputed amount as discussed above After we finish our investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay we may report you as delinquent Information About Payments: You may at any time pay, in whole or in part, the total unpaid balance without any additional charge for prepayment. Payments made by mail or made using a third-party bill pay service provider: Payments received after 5:00 p.m. (ET) on any day will be credited as of the next day Credit to your Account may be delayed up to five days if payment (a) is not received at the Payment Address, (b) is not made in U.S. dollars drawn on a U.S. financial institution located in the US. (6) is not accompanied by the remittance coupon attached to your statement, (@) contains more than one payment or remittance coupon, (e) is not received in the remittance envelope provided or (f) includes staples, paper clips, tape, a folded check, or correspondence of any type. Payments made by phone or online: |f you make a payment by phone or online before 11°59 p.m. Eastern Time, we will credit it as of the date the payment is made, All written communications concerning disputed amounts, including any check or other payment instrument that: (i) indicates that the payment constitutes ‘payment in full” or is tendered as full satisfaction of a disputed amount: or (i) is tendered with other conditions or limitations (‘Disputed Payments”), must be mailed or delivered to us at P.O. Box 965003, Orlando, FL 32896-5003 Credits To Your Account: An amount shown in parenthesis or preceded by a minus () sign is a credit or credit balance unless otherwise indicated. Credits will be applied to your previous balance immediately upon receipt, but will not satisfy any required payment that may be due, Credit Reports And Account Information: If you believe that we have reported inaccurate information about you to a consumer reporting agency, please contact us at PO. Box 965005, Orlando, FL 32896-5005. In doing so, please identify the inaccurate information and tell us why you believe it is incorrect. If you have a copy of the credit report that includes the inaccurate information, please include a copy of that report, We. may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report Bankruptcy Notice: if you file bankruptcy, you must send us notice, including account umber and all information related to the proceeding to the following address: P.O. Box 965064, Orlando, FL 32896-5064 Paying Interes: Your due date is at least 25 days after the close of each billing cycle. We will not charge: you any interest on non-promotional transactions if you pay your entire balance by the due date each month. We will begin charging interest on promotional purchases on the purchase date How We Calculate the Balance on Which the Interest is Compute We calculate interest on your account for each billing cycle separately for each balance type. A separate average daily balance is calculated for the following balance types, as applicable: standard purchases, cash advances and promotional purchases. To get the average daily balance, we take the starting balance each day, including billed interest and billed fees, add any new charges and adjustments posted that day and subtract any payments or credits (treating any net credit balance as zero). This gives us the daily balance. Then, we add up all the daily balances for the billing cycle and divide the total by the number of days in the billing cycle. The result is the average daily balance. The average daily balance is referred to as the Balance Subject to Interest Rate on your statement. Amount to Avoid Standard and Deferred interest on your next statement: (see PAYMENT INFORMATION box on front page) This amount includes: Standard Purchases and Cash Advances Purchases without any promotional offer and Cash Advances Deferred Interest Purchases Expiring This Billing Cycle Purchases made with ‘No Payments + No Interest if paid in full’ and ‘No Interest if paid in full’ promotions that are about to expire Easy Payments Purchases Monthly Plan Payments ‘Although unrelated to avoiding Standard and Deferred Interest, we include Monthly Plan Payments to help you avoid late fees. If you have a Financed Easy Payments Purchase balance, you will continue to be assessed interest on the Easy Payments Purchase balance until itis paid in full Your Account is owned and serviced by Synchrony Bank. [WF7362464] O1DRE128 - 3- 02/21/19 This is an attempt to collect a debt and any information obtained will be used for that purpose, “By providing a telephone number on your account, you consent to Synchrony Bank and any other owner or servicer of your account contacting you about your account, including using any contact information or cell phone numbers you provide, and you consent to the use of any automatic telephone dialing system andlor an artificial or prerecorded voice when contacting you, even if you are charged for the call under your phone plan For changes of address, phone number and/or email, please check the box and print the changes below. These changes will be applied to PayPal Credit but not to your PayPal Account. O Street Address: City, State zip Phone # Email “Home Phone # “Business Phone # *Cell # or other phone # “Email Address we can use to contact you providing your email address, you agree to receive email communications about your account and also give permission for us to share Suen address with PayPal Credit Filing 186455416 Uhg | Lic v. Brian Ordner )5-2022-SC-043239-XXXX-XXStatement Closing Date: 04/13/21 Days in Billing Period: 30 Account Number: Sas Customer Name: BRIAN ORDNER INTEREST DETAILS INTEREST CHARGE CALCULATION View your account online at Paypal.com Or call MME 8 AM ET to 11 PM ET Mon-Fri and 9 AM ET to 9 PM ET Sat-Sun ‘Your Annual Percentage Rate (APR}s the annual interest rate on your account. Balance Type Annual Percentage Balance Subject to Interest Charged Current Balance Rate(APR) Interest Rate ‘Standard Purchases 23.99% (v) $2,177.99 $42.82 $2,254.73 PayPal Send Money Cash Advances 23.99% (v) $0.00 $0.00 $0.00 Balance Prior To Terms Change 19.99% $1,595.62 $26.21 $1,621.83 (V)=Variable Rate ACCOUNTHOLDER NOTICES This is a duplicate courtesy copy of your most recent billing statement. You can still view and pay your electronic statement online. 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 inciuding return envelopes. You can make things even easier by selecting the paperless statement option on your account online. Filing 156455416 6128 ang ool 7 an 210413 0 Uhg | Lic v. Brian Ordner EX PAGE 2 of 3 10 9283 2100 POVA O1DR6128 05-2022-SC-043239-XXXX-XXFiling 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XX 6128 ABS oor 7 22 210413 0 EXPAGE 3 of 3 10 9283 2100 PSVA o1pRe128EXHIBIT B Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XX~ synchrony 4500 Munson St NW Canton OH 44718, U.S. BILL of SALE UHG (UFRS) — PLCC PayPal Fresh — June 2021 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 12" day of August, 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 UIIG I 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 16" day of June 2021 and as further described in the Agreement. Synchrony Bank Lynne Fisher Title: SVP Recovery Operations RFS Holding LLC Fisher (lun 29,2024 12:32 E87} Lynne Fisher Title: Duly Authorized Signatory Synchrony Card Funding, LLC Lynne Fisher Title: Duly Authorized Signatory Retail Finance Credit Services, LLC He Fishvos (Aut 28, 2021 1252 EDT) Lynne Fisher Title: Vice President Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXAFFIDAVIT OF SALE OF ACCOUNT BY ORIGINAL CREDITOR State of Florida County of Seminole Julio A Perez being duly sworn, deposes and says: Jam 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 6/16/2021 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 UHG I 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 6th day of July, 2021 Julio A Perez Signed and sworn to before me this 6th day of July, 2021 (Notary Stamp) 5 OMAIRA HERNANDEZ tate of Floride-Notaty Public} Commission # GG 149741 My Commission Expires October 03, 2021 NY AOS 1.3 2/1/2017 - St. Paul Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXNY CoC CERTIFICATE OF CONFORMITY UNDER NYS CLS CPLR § 2309(c) AND NYS CLS RPL § 299-a The undersigned does hereby certify that he/she is an attorney-at-law duly admitted to practice in the State of Florida and residing in the State of Florida; that he/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 he/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 Julio A Perez was taken by Omaira Hernandez, 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 his/her review thereof, that the notarized Affidavit conforms to the laws of the State of Florida in all respects. Witness my signature this 6th day of July, 2021 Tyler Burich Attorney-at-law, State of Florida. Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXpri_acctno MKR_FN MKR_LN es BRIAN ORDNER CMPNY_NAME MKR_TAXID MKR_AD1 a 1707 MANTES DR MKR_AD2 MKR_AD3 MKR_CITY COCOA MKR_ST MKR_ZIP MKR_HP FL 32926-5767 0000000000 MKR_WP MKR_BARDATE MKR_BKCHAP 000000000 oO MKR_CASENUM MKR_DISCHDTE MKR_DISMSDTE oO oO MKR_BKMEETDTE MKR_BKCOURT MKR_BKFILEDT 0 0 ECOA OPENDATE CHGOFF_DATE 1 20160906 20210512 RMSLASTPMT LASTPMTAMT BRANCH 20201013 129 CPPC DOFD CHGOFFCODE LOSSAMT 20201113 SKIP 3916.56 CURBAL Principal Bal RMSFILENUM 3916.56 3916.56 98905147 ACCTSTS STSDESC JDGDATE SF5 Sales - Final - Primary Random Sale 0 OFF_CODE OFF_DESC BCLE PALO48 PayPal Credit 0181 BCLE_DESC BUYERCODE INT_RATE Synchrony Bank UFRS 0 NET_COSTS NET_INTEREST NET_PRINCIPAL oO 1077.25 2839.31 Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XXPRINC_LOSS ASSOC_COSTS ACCRD_INT 2839.31 0 1077.25 CREDITSCOR LASTPURCHDT CMKR_FN = 20200802 CMKR_LN CMKR_TAXID CMKR_ADDR1 CMKR_ADDR2 CMKR_CITY CMKR_STATE CMKR_ZIP CMKR_LIABLE MKR_DOB a LANG IND RMSBRGLVL2 MkR_CP EN RCF OUT_OF_STATUE 11/12/2025 12:00:00 AM Filing 156455416 Uhg | Llc v. Brian Ordner 05-2022-SC-043239-XXXX-XX