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22090002
All Law Division initial Case Management Dates will be heard via ZOOM.
IN THE
For more information and Zoom Meeting IDs goCIRCUIT COURT OF COOK COUNTY, ILLINOIS
to https://www.cookcountycourt.org/HOME/Zoom-Links/Agg4906_SelectTab/12
Remote Court date: 9/11/2023 9:00 AM
COUNTY DEPARTMENT, LAW DIVISION
FILED
7/11/2023 2:10 PM
HUNTINGTON DEBT HOLDINGS ) IRIS Y. MARTINEZ
LLC, As Assignee of LOANME, INC. ) CIRCUIT CLERK
) No.:
2023L006859 COOK COUNTY, IL
FILED DATE: 7/11/2023 2:10 PM 2023L006859
2023L006859
Plaintiff, )
Calendar, Y
) Amount: $36,000.00 plus interest plus
23484058
v. ) reasonable attorney’s fees plus continuing
) interest plus court costs
UNTITLED 1901 INC , and )
ANGEL FLORES, )
Personal Guarantor )
)
Defendant. )
COMPLAINT
COUNT I
NOW COMES the Plaintiff, HUNTINGTON DEBT HOLDINGS LLC, As Assignee
of LOANME, INC., by and through its attorneys, Law Offices of Mark E. Abrams, P.C., and as
for its Verified Complaint against the Defendant(s), UNTITLED 1901 INC , alleges as follows:
l. Plaintiff is engaged in the business of purchasing promissory notes.
2. LOANME, INC. sold and deliver to Defendant, at the specific instance and
request of said Defendant, on December 15, 2021, as specifically set forth and incorporated
herein in Exhibit “A”, attached hereto and made a part hereof.
3. On or about November 9, 2022, Plaintiff purchased the account receivable from LoanMe,
Inc. which was due from the Defendant in the amount of $36,000.00 plus applicable interest.
4. Defendant has received all credits due, if any, leaving a balance due and owing to
the Plaintiff from the Defendant in the amount of $36,000.00, said balance representing said
money loaned, as more specifically set forth in Exhibit “A”.
5. Plaintiff has demanded payment from Defendant(s) for monies due and owing
under the Promissory Note, however, Defendant has repeatedly failed and refused to repay the
balance due and owing under the note.
6. Pursuant to the note, Plaintiff is entitled to collect interest due on the loan and
reasonable attorney’s fees.
WHEREFORE, the Plaintiff, HUNTINGTON DEBT HOLDINGS LLC, As Assignee
of LOANME, INC., prays for Judgment against the Defendant, UNTITLED 1901 INC , in the
sum of $36,000.00 plus interest plus reasonable attorney fees plus accumulating interest plus
court costs.
COUNT I
As and for Court II of its Complaint, Plaintiff alleges against the Defendant, ANGEL
FLORES, Personal Guarantor, alleges as follows:
l. As and for its Paragraph 1 of Count II, Plaintiff restates and realleges paragraphs
1 through 6, and each of them of Count I.
7. Defendant at all times mentioned herein was the principal owner and/or officer of
FILED DATE: 7/11/2023 2:10 PM 2023L006859
a business being operated under the name and style of UNTITLED 1901 INC .
8. On or about December 15, 2021, Defendant offered to personally guarantee the
small business loan made by LOANME, INC. to UNTITLED 1901 INC in the future and in
consideration thereof agreed to loan money to UNTITLED 1901 INC . Defendant then and there
executed its written guaranty which is attached hereto marked Exhibit “A”, and made a part
hereof.
9. While the Defendant’s guaranty continued in full force and effect, and in reliance
upon said guaranty, Plaintiff purchased the Promissory Note described in the Exhibit “A” and
attached hereto and made part hereof, in the amount of $36,000.00.
10. UNTITLED 1901 INC accepted the funds loaned, but thereafter failed and
refused, and continues to refuse, to pay as required under the terms of the promissory note.
11. Pursuant to the Promissory Note, Plaintiff is entitled to collect interest due under
the note and reasonable attorney’s fees.
12. By reason of aforesaid, the sum of $36,000.00 became, and is due ad owing from
this Defendant to Plaintiff and not withstanding repeated demands by Plaintiff, this Defendant
has failed and refused to pay said sum or any part hereof.
WHEREFORE, the Plaintiff, HUNTINGTON DEBT HOLDINGS LLC, AS
ASSIGNEE OF LOANME, INC., prays for Judgment against the Defendant, ANGEL
FLORES, Personal Guarantor, in the sum of $36,000.00 plus interest plus reasonable
attorney’s fees plus accumulating interest plus court costs
HUNTINGTON DEBT HOLDINGS LLC, As
Assignee of LOANME, INC.
By: /s/ Mark E. Abrams
Law Offices of Mark E. Abrams, P.C.
Attorney for Plaintiff
1200 N. Ashland Ave., #403
Chicago, IL 60622
(773) 252-6977
Atty No.: 63295
Email: abramspclaw@gmail.com
FILED DATE: 7/11/2023 2:10 PM 2023L006859
Exhibit “A”
FILED
7/11/2023 2:10 PM
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Owner AcctNbr Client AcctNbr BorrowerFirstName BorrowerLastName BorrowerAddress BorrowerCity
Huntington Debt Holdings, LLC 315019624 10111419
Huntington Debt Holdings, LLC 305004512 10114399
Huntington Debt Holdings, LLC 315017163 10096493
FILED DATE: 7/11/2023 2:10 PM 2023L006859
Huntington Debt Holdings, LLC 315018380 10103744
Huntington Debt Holdings, LLC 325002322 10022212
Huntington Debt Holdings, LLC 315020401 10115841
Huntington Debt Holdings, LLC 315011610 10072166
Huntington Debt Holdings, LLC 325005355 10039795
Huntington Debt Holdings, LLC 315014936 10087217
Huntington Debt Holdings, LLC 320023074 4528745
Huntington Debt Holdings, LLC 320017917 4208231
Huntington Debt Holdings, LLC 325010419 10066255
Huntington Debt Holdings, LLC 315012919 10078266
Huntington Debt Holdings, LLC 320029041 4896983
Huntington Debt Holdings, LLC 305003761 10093001
Huntington Debt Holdings, LLC 315006719 10046799
Huntington Debt Holdings, LLC 315017107 10097934
Huntington Debt Holdings, LLC 315019093 10108604
Huntington Debt Holdings, LLC 315019702 10110261
Huntington Debt Holdings, LLC 305003657 10088692
Huntington Debt Holdings, LLC 315017534 10100470
Huntington Debt Holdings, LLC 305001094 10010667
Huntington Debt Holdings, LLC 315012615 10076871
Huntington Debt Holdings, LLC 325016758 10088367
Huntington Debt Holdings, LLC 325000357 10009896
Huntington Debt Holdings, LLC 315016767 10096475
Huntington Debt Holdings, LLC 315020106 10114190
Huntington Debt Holdings, LLC 315017269 10099053
Huntington Debt Holdings, LLC 305002454 10041694
Huntington Debt Holdings, LLC 315017508 10099965
Huntington Debt Holdings, LLC 315008090 10054245
Huntington Debt Holdings, LLC 325001459 10013846
Huntington Debt Holdings, LLC 325009713 10062552
Borrower State Borrower Zip FundDate DueDate Last Payment Date Original Rate Current Rate Original Term Current Term Remaining Term
FILED DATE: 7/11/2023 2:10 PM 2023L006859
Days Past Due LoanStatus Sold Off Date Investor ID B1 Cell B1 Home B1 Work B1 Email FirstPmt DueDate
FILED DATE: 7/11/2023 2:10 PM 2023L006859
Processing Date CurrentPBal Accrued Interest Computed Payoff OriginalPBAL LastPmtAmt OriginalPmt CurrentPmt ChargeOff PRN ChargeOff Int
$4,003.40
$39,363.39
$3,001.81
FILED DATE: 7/11/2023 2:10 PM 2023L006859
$1,496.02
$1,787.73
$2,100.91
$1,494.78
$2,915.24
$4,150.10
$9,769.05
$2,699.21
$1,918.18
$1,663.05
$625.63
$9,778.37
$1,456.40
$4,178.67
$3,004.22
$3,995.10
$14,896.08
$2,070.34
$1,100.45
$1,490.29
$2,992.56
$2,176.73
$2,390.39
$3,004.22
$2,069.90
$3,416.70
$1,701.07
$1,241.00
$992.32
$2,082.76
FirstPmt DueAmt LateCharges OtherFees ReleaseFee Chargeoff Interest Amount Owed New Balance Issuer
$7,800.28 $7,271.93 Loan Me
$53,022.47 $50,532.41 Loan Me
$6,112.19 $5,696.35 Loan Me
FILED DATE: 7/11/2023 2:10 PM 2023L006859
$3,020.35 $2,813.13 Loan Me
$3,822.06 $3,516.79 Loan Me
$4,108.09 $3,615.49 Loan Me
$2,906.38 $2,698.79 Loan Me
$6,142.46 $5,732.47 Loan Me
$8,280.80 $7,509.56 Loan Me
$14,594.47 $13,617.17 Loan Me
$5,068.28 $4,525.97 Loan Me
$5,057.62 $4,777.67 Loan Me
$3,465.89 $3,208.10 Loan Me
$1,187.88 $881.58 Loan Me
$11,834.31 $11,312.84 Loan Me
$2,553.78 $2,391.80 Loan Me
$7,319.09 $6,861.04 Loan Me
$6,116.59 $5,700.61 Loan Me
$7,357.76 $6,920.83 Loan Me
$24,492.46 $22,642.05 Loan Me
$3,739.93 $3,511.75 Loan Me
$1,926.78 $1,626.90 Loan Me
$2,897.80 $2,690.91 Loan Me
$6,560.91 $6,126.10 Loan Me
$4,067.28 $3,583.85 Loan Me
$4,564.64 $4,233.29 Loan Me
$5,874.60 $5,458.62 Loan Me
$4,026.68 $3,737.38 Loan Me
$5,562.67 $5,040.89 Loan Me
$3,434.15 $3,198.48 Loan Me
$2,391.57 $2,175.83 Loan Me
$3,390.14 $3,292.56 Loan Me
$4,433.98 $4,105.83 Loan Me
Huntington Debt Holdings, LLC 325009762 10062606
Huntington Debt Holdings, LLC 305005167 10127287
Huntington Debt Holdings, LLC 315007166 10048843
Huntington Debt Holdings, LLC 305005484 10129581
FILED DATE: 7/11/2023 2:10 PM 2023L006859
Huntington Debt Holdings, LLC 315016247 10093677
Huntington Debt Holdings, LLC 320007094 3041099
Huntington Debt Holdings, LLC 315008523 10056571
Huntington Debt Holdings, LLC 305004624 10115009
Huntington Debt Holdings, LLC 315001266 10012177
Huntington Debt Holdings, LLC 305005406 10128851 ANGEL FLORES 1348 S NAPERVILLE RD WHEATON
Huntington Debt Holdings, LLC 305003288 10074639
Huntington Debt Holdings, LLC 315020828 10117994
Huntington Debt Holdings, LLC 320026692 4741981
Huntington Debt Holdings, LLC 320022440 4483244
Huntington Debt Holdings, LLC 325006236 10044138
Huntington Debt Holdings, LLC 325002735 10025378
Huntington Debt Holdings, LLC 305003524 10083609
Huntington Debt Holdings, LLC 325002485 10023640
Huntington Debt Holdings, LLC 325006264 10044349
Huntington Debt Holdings, LLC 315011956 10074182
Huntington Debt Holdings, LLC 325004072 10032592
Huntington Debt Holdings, LLC 305001730 10018050
Huntington Debt Holdings, LLC 320016720 4128261
Huntington Debt Holdings, LLC 315016814 10096696
Huntington Debt Holdings, LLC 320029149 4904786
Huntington Debt Holdings, LLC 315003518 10029673
Huntington Debt Holdings, LLC 320010217 3511226
Huntington Debt Holdings, LLC 315021705 10122090
Huntington Debt Holdings, LLC 320021541 442995
Huntington Debt Holdings, LLC 315018067 10103384
Huntington Debt Holdings, LLC 315022230 10125223
Huntington Debt Holdings, LLC 320014515 3964989
Huntington Debt Holdings, LLC 320017416 4173969
Huntington Debt Holdings, LLC 325001327 10012816
FILED DATE: 7/11/2023 2:10 PM 2023L006859
IL 60189 12/15/2021 2/1/2022 12/30/2021 104 104 120 120 119
FILED DATE: 7/11/2023 2:10 PM 2023L006859
159 SOLD 6/30/2022 29 6302460490 cut2blackproductions@gmail.com 1/1/2022
$2,676.64
$2,657.52
$937.16
$2,998.71
FILED DATE: 7/11/2023 2:10 PM 2023L006859
$2,092.67
$2,072.56
$1,761.01
$74,468.89
$1,933.99
7/11/2022 $39,884.44 $39,909.44 $40,000.00 $1,848.89 $3,466.85 $3,466.85 $39,884.44 $20,739.90
$49,299.99
$2,995.40
$4,325.69
$2,150.63
$1,484.60
$910.20
$7,117.03
$988.25
$1,853.52
$2,982.88
$2,025.91
$43,596.26
$826.27
$2,990.90
$157.05
$2,434.10
$606.38
$1,497.16
$3,687.00
$1,196.85
$1,996.97
$2,725.82
$2,214.96
$2,015.18
$6,076.61 $5,753.20 Loan Me
$5,199.28 $4,798.34 Loan Me
$1,941.00 $1,806.32 Loan Me
$6,104.94 $5,690.15 Loan Me
FILED DATE: 7/11/2023 2:10 PM 2023L006859
$4,260.90 $3,970.91 Loan Me
$3,951.89 $3,433.07 Loan Me
$3,721.23 $3,350.01 Loan Me
$110,813.39 $104,214.36 Loan Me
$3,441.16 $3,219.78 Loan Me
$1,848.89 $25.00 $0.00 $0.00 $20,739.90 $65,268.41 $60,624.34 Loan Me
$84,419.61 $78,687.50 Loan Me
$6,201.89 $5,787.28 Loan Me
$6,986.10 $6,288.20 Loan Me
$3,599.13 $3,215.19 Loan Me
$2,883.74 $2,600.80 Loan Me
$2,575.36 $2,442.28 Loan Me
$8,617.22 $8,225.91 Loan Me
$2,800.15 $2,662.58 Loan Me
$5,320.49 $5,044.26 Loan Me
$6,142.66 $5,728.77 Loan Me
$6,022.20 $5,350.83 Loan Me
$72,118.85 $66,762.55 Loan Me
$1,103.44 $833.44 Loan Me
$6,193.11 $5,778.76 Loan Me
$482.12 $271.30 Loan Me
$4,680.56 $4,338.69 Loan Me
$801.06 $606.38 Loan Me