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  • HUNTINGTON DEBT HOLDINGS LLC, As Assignee of LOANME, INC.-vs-UNTITLED 1901 INC,ANGEL FLORESBreach of Contract - Non-Jury document preview
  • HUNTINGTON DEBT HOLDINGS LLC, As Assignee of LOANME, INC.-vs-UNTITLED 1901 INC,ANGEL FLORESBreach of Contract - Non-Jury document preview
  • HUNTINGTON DEBT HOLDINGS LLC, As Assignee of LOANME, INC.-vs-UNTITLED 1901 INC,ANGEL FLORESBreach of Contract - Non-Jury document preview
  • HUNTINGTON DEBT HOLDINGS LLC, As Assignee of LOANME, INC.-vs-UNTITLED 1901 INC,ANGEL FLORESBreach of Contract - Non-Jury document preview
  • HUNTINGTON DEBT HOLDINGS LLC, As Assignee of LOANME, INC.-vs-UNTITLED 1901 INC,ANGEL FLORESBreach of Contract - Non-Jury document preview
  • HUNTINGTON DEBT HOLDINGS LLC, As Assignee of LOANME, INC.-vs-UNTITLED 1901 INC,ANGEL FLORESBreach of Contract - Non-Jury document preview
  • HUNTINGTON DEBT HOLDINGS LLC, As Assignee of LOANME, INC.-vs-UNTITLED 1901 INC,ANGEL FLORESBreach of Contract - Non-Jury document preview
  • HUNTINGTON DEBT HOLDINGS LLC, As Assignee of LOANME, INC.-vs-UNTITLED 1901 INC,ANGEL FLORESBreach of Contract - Non-Jury document preview
						
                                

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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 E {;e IRIS Y. MARTINEZ (rJ (1,, (r, (x ooooo (}) z> co $.5arJ FE ooi. CIRCUIT CLERK COOK COUNTY, IL LN(',I(.rlLNLN c)oooo t< 50 aJ L-t?)= aoooo (tE !l- Et v o^ 2023L006859 lJr (.n (,r 555ss Ln (Jl EH HN- 5 FH s Calendar, Y ooooo or o) o) ot cr,! 9qI 5:HEr = o g-ru' FILED DATE: 7/11/2023 2:10 PM 2023L006859 ii. oo 6 il v) r.| 94. (a) A oa oa F' IU te CC-CC o |- .) ) I M !o ++d+; o 6++*; cDtDtDaDa r5 p ) o a- a- a. o. o. o: \o \o \o \o \o oaaoa z A' HHHH! J J U J (D ooa6a ' v4 w -ffi,ffir NNNNN oaooc) NI\,,N)I\)NJ NNNtslJ oo5,!r! !I\)NJNN H Et $65i",! (o(,FrOLn o) o s, o Fi H o) &r^,- PHt BBfA+g.E HcDor@x o bboboboE oul(Jtloo E UO va fH FU 5's P a c+ Fr cD 9, rlJ F\ lj (, -ts (,t o\ ONNOT P9i, 8e CD )-a -J lr o >o --ts CD NJN, I (,qJF 55! (r(,uJ ts1 t! 0 o@ N)@ N) (Jl F + r-99!D oo)chu, ourut(^) -{trr rDorOO u ct =.< o=-- o (] a ) q(' -l Ft goo JXX A) C) P a FI () (D r) o o .D o) -l tr l-) o c+ 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