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BUSINESS AND TRIAL LAWYERS
Schreiber Law, LLC
53 Stiles Road, Suite A102
Salem, NH 03079
‘TELEPHONE (603) 870-5333. TOLL FREE (800) 423-8142
TTY (866)718-3328 FACSIMILE (603) 870-0077
HOURS: MON.-FRI. 8:30 A.M. TO 5:30 P.M. (ET)
December 30, 2023
Vincent LaBella
26 Mason St Apt B
Coventry, CT 06238-3190
Re: LVNV Funding LLC / Vincent LaBella
Dear Vincent LaBella:
Enclosed is a Writ and Complaint for a debt incurred and unpaid. There is still time to resolve this matter and
avoid further litigation. If you would like to make arrangement, please call us at 800-423-8142.
Very ty yours,
SCI ER LAW, LLC
Ole fy A. Schreiber
( feather Q. Wallace
Laurie D. Baron
Attorney at Law
7500/HRO
4356333
THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
SMALL CLAIMS WRI STATE OF CONNECTICUT
AND NOTICE OF SUIT SUPERIOR COURT
JDC) Re e419 SMALL CLAIMS SESSION
C.G.S. 3§ 51-18, 51-3489) vasw.jud.chgov nga
Type or print ibly. This Smat! Chai ims Writ and Notice of Suit must be served on {delivered fo)
the defendant(s) 2 = fing the court. See instructions to Plaintiff
on reverse.
1.) Location formation that will determine whee the triai will be: 2.) Case type code /See list on reverse page 1)
Defendant's Residence Major: Ss ino 15
3.) is ths a daim between aiandlord and 3 tenant (renter}? | 4.) if vou answered “Yes” to cueston #3. state the town woere the rental oremsses 's located:
iSelect one) | Yes IX] Ne
Parties Name (Last Fire Middle Inidal) and Address of Fach Panty (Number, Street. P.O. Box, Town, Sax ‘ounby. if nor USA,
‘Name: LVNV Funding LLC (Selectone) [x] LLC (i Parmership |p94
5) First ‘Address: 6801 S. Cimarron Road Suite 424-I Las Vegas, NV 89113
Plaintiff Cl inaviduat [J] DBA [7 Corporation
Telephone:
6.) Name, address, and zip code of Attomey for Plants) ‘Atiomey’s Juris Number | Telephone number (w/area code)
SCHREIBER LAW, LLC, 53 STILES RD., A-L02 434988 603-870-5333 _
SALEM, NH, 03079 = 2
Name: Vincent LaBella (Sefectone) [] LLC [7 Partnershp Dat
7) First Address: /§ Mason St Apt B Coventry, CT 06238-3190
Defendant Xl individual (] DBA [| Corporation
Telephone:
Foe more thar 1 plaintficefendant, attach Contnustion of Parties {form JD-CV-87) and select this box. a
8.) if ths claim is a consumer debt, which is 3 debt or obligation made primarily for personal, famity, or household reasons, give the reasons why you believe
that the statute of limtations has not expired
DEFENDANT'S LAST PAYMENT TOWARDS THE ACCOUNT OCCURRED ON 05/18/2021, WHICH IS WITHIN THE APPLICABLE STATUTE OF LIMITATIONS
PERIOD.
6.) How did you cheek in the last 8 months that the address given for defendant(s) is accurate?
Select all boxes that apply and provide the dates that the address was checked.
[1] Nenecked town or city records {for example, checking 3 street list or tax recorcs} a _{date checked)
[_] | checked with the Department of Motor Vehicles (date checked)
[7] t received correspondence (letters or other mail] from the defendant with that setum address (date checked)
[LJ | received other proof from the defendant that the address is currert
(description of
and date che a
‘] | mailed by fest class mail, at least4 weeks before this small clsims action was filed, a letier to the defendant at the
for retumed ee
f (last
11/03/2023 date oh.
address used and the letter has not been retumed to me by the United States Postal Service _ zs
TO) Amount claimed TC] Pus prejudgment interest"
$695.25 Plus Costs [Ci Plus double damages for security deposit withheld”*
‘The Amount Claimed may not be more than $5,000. Do not include amounts ‘tif you select one or more baxas, you MUST explain
for prejudgment interest or doubling the seountty deposit in box 10. how much you want for each it2m in section 34 below.
To Defendant(s):
11.) You are being sued. The Plaintiffjs) daims you one the above Int plus costs and prejudgment interest andior double damages fora withheld
seoutty deposi (ff seicted}for the following reasons:
Credit One Bank, N.A. (“original creditor”) issued defendant a ("Ae int") with the Account number XXXXXXXXXXXX7475 and upon use of that
Account, defendant became obligated to make timely payt idan faulted on that obligation and owes the balance due on the Account. Plaintiff
acquired the Account and is the bona fide owner of the A@&Qunt. De: Yh defendant failed to, or was unable to, pay. Plaintiff demands judgment
for the amount claimed together with costs and post-judgme! iter in es with CT Gen, Stat. Sec. 37-3a. Plaintiff requests that the Court further
order a nominal payment order commencing three (3) weeks frol Egatot nt. Defendant is also not in the military. (See all supporting
documents.). 95°,
6,
on Se a aa a
The person Saning wi, being duly sworn. ststes that he or she has read ton contained inthis form and,to thebest of his
or her kn edge. nférmation and belief, there ‘s good ground to support the a = ati True. aS
12.) we Type naene oT PERG aan ie , Wapplicable|” For Court Use Only (Date/Siamp)
41 Jeffrey ichreiber
[Heather a. walle, Esq. Lavi ron, Esq.
‘Subscnibed fd Date ighe = Notary, Commi E4fF of the Superior Court]
sworn to 2 me on, 1-S96
ADA NOTICE
The Judicial Branch of the State of Cannectiout complies with the Amerans with
Disabilites Act (ADA). ff you need a reasonable accomenadaticn in accordance with the Decks: Number
ADA contact a court clerk or an ADA contact person listed at wwwjud.ctgowADA,
Print Form, Pagelds Reset rm
INSTRUCTIONS TO DEFENDANT
(NOTICE TO PERSON BEING SUED)
JD-CV-121 Rev. 7-12
Please read the instructions carefully.
For more information, get a copy of HOW SMALL CLAIMS COURT WORKS (form JDP-CV-45) from the Clerk's Office
or from our website at www jud.ct. ‘smaliciaims.html.
What Do | Have To Do To Defend This Case?
The person suing you (the Plaintiff) delivered to you (served you with)'a copy of the Small Claims Writ and Notice of
Suit; and related documents, if any. The plaintiff will now file the Small Claims Writ and Notice of Suit and related
documents with the court. The court will send you an Answer form and a Counterclaim form with the number the court
assigns to the case, called the "docket number" of the case, and the date you must file your Answer, and Counterclaim
if you make one, by. The Answer form and the Counterclaim form should be sent to you soon but it could take up to 6
weeks depending on when the plaintiff files the case with the court.
The Answer is your response or reply to the plaintiff's claim. If you claim the plaintiff owes you money, this is called a
Counterclaim. There is a $90.00 fee to file a Counterclaim. Your Answer, and your Counterclaim if you make one,
should be specific but brief. Fill out the entire Answer form, and the Counterclaim form if you make a Counterclaim,
and sign them. Keep a copy of each for yourself and send a copy to each attorney or other representative of the
plaintiff, or if the plaintiff is representing himself or herself, to the plaintiff. Send the original Answer form to the court by
mail, fax or hand delivery at the address or fax number shown below on or before the answer date. If you makea
Counterclaim, mail the original Counterclaim with the $90.00 fee to the court or hand deliver them to the address
shown below on or before the answer date. You cannot fax a Counterclaim and its filing fee to the court. Please
be suré to give us any change of your address.
Do not answer until you get the Answer form and Counterclaim form from the court but if you do not get an Answer
form and Counterclaim form within 6 weeks of being served, contact the court to ask why. If you do not file an Answer
in writing with the court, a money judgment could enter against you. This is called a default judgment.
You may make an agreement with the plaintiff before the plaintiff files the lawsuit in court or at any time before the
court enters a judgment. You may hire a lawyer to represent you if you want to.
You can find helpful information on our website at: http:/Awww.jud.ct.gov/faq/smailclaims.htm| and you may check the
status of-your case after it has been given a docket number at:http :/Avww.jud2.ct.gow/Small_Claims/.
If you have any questions, you can visit or call the Centralized Small Claims Office at 80 Washington Street,
Hartford, CT 06106. The telephone number in the Hartford area is 860-756-7800. The toll free telephone number in
Connecticut is 866-383-5927. The fax number is (860) 756-7805.
You do not need an attorney even if the plaintiff has one. However, you can have an attorney if you want to hire one.
If you want to use the regular rules of court in this case or if you want the right to appeal this case, you must file a
motion to transfer the case to the regular civil or housing docket of the superior court. You may need an attorney to
help you in filing that motion and you will have to pay fees to file it. The motion to transfer must be filed, in writing, with
an affidavit and with the correct fees, on or before the answer date.
What Happens If! Do Not File An Answer? If you do not file an Answer, the file will be reviewed by a magistrate who
will decide whether a judgment can enter without a hearing for the full amount of the claim plus court costs, or ifa trial
needs to be scheduled.
What Happens If | File An Answer? If you file an Answer, do not go to court on the answer date. After the court
receives your Answer, a trial will be scheduled if one is required. Cases are scheduled for trial as quickly as possible.
What Should| Do If The Plaintiff Owes Me Money? If you claim the plaintiff owes you money, this is called a
Counterclaim. Explain how much the plaintiff owes you and why on the Counterclaim form. Fill out the entire
Counterclaim form and sign it. Keep a copy for yourself and send a copy to each attorney or other representative of the
plaintiff, or if the plaintiff is representing himself or herself, to the plaintiff. Mail the original Counterclaim form with the
Page 1 of2
Please be sure
$90.00 fee to the court or hand deliver them to the address shown above on or before the answer date.
to give us any change of your address.
you do not agree
What If | Know | Owe The Plaintiff Some Money? If you know you owe the plaintiff something, but
the plaintiff, you should file a written
with the amount the plaintiffis asking for or you are not sure how much you owe
how the plaintiff added up the amount claimed.
Answer. This gives you a chance to come to court for a trial to question
owe the whole
What Should | Do If| Admit That | Owe The Plaintiff The Whole Amount? If you are sure that you
file an Answer not later than the Answer date, stating that you want time
amount but you want time to pay, you must
you are asking for the extra time to pay. You may ask for a period of time during which you
to pay the claim and why
judgment with an
can make payments that you suggest. If you do not, and you are an individual, the court will enter a
less than $35.00 per week and the
order of payments of $35.00 each week until the judgment is paid. If you ask to pay
plaintiff does not agree, a trial will be scheduled.
for return of a
A judgment against a business entity, for example, a corporation, or a judgment against a landlord
security deposit, will be ordered paid in the full amount. This will be entered as a judgment of the court.
date, tell the court
If you pay the plaintifffplaintiff's attomey the full amount owed plus costs, if any, before the answer
on the Answer form. Do not send payment(s) to the court.
Where And When Do | Have To Go To Court? If a trial is required, you will be sent a notice of the date, time and
against you if
place of the trial. Even if you filed an Answer or a request for time to pay, the court can enter a judgment
you do not come to court on the date and time set for the trial.
(bills,
What Do! Need To Bring To Court? On the day of the trial, you must bring allyour witnesses and evidence
This includes any defective or damaged goods that can be brought to court safely
invoices, checks) to court with you.
of damages, pictures, and anything else that you want the court to look at. Be complete and
and easily, estimates
organized in your case. A small claims judgment cannot be appealed.
ADA Notice
The Judicial Branch of the State of Connecticut complies with the Americans with Disabilities Act
(ADA). If you need a reasonable accommodation in accordance with the ADA, contact a court
clerk or an ADA contact person listed at www.jud.ct.gow/ADA/.
Preview
BUSINESS AND TRIAL LAWYERS Schreiber Law, LLC 53 Stiles Road, Suite A102 Salem, NH 03079 ‘TELEPHONE (603) 870-5333. TOLL FREE (800) 423-8142 TTY (866)718-3328 FACSIMILE (603) 870-0077 HOURS: MON.-FRI. 8:30 A.M. TO 5:30 P.M. (ET) December 30, 2023 Vincent LaBella 26 Mason St Apt B Coventry, CT 06238-3190 Re: LVNV Funding LLC / Vincent LaBella Dear Vincent LaBella: Enclosed is a Writ and Complaint for a debt incurred and unpaid. There is still time to resolve this matter and avoid further litigation. If you would like to make arrangement, please call us at 800-423-8142. Very ty yours, SCI ER LAW, LLC Ole fy A. Schreiber ( feather Q. Wallace Laurie D. Baron Attorney at Law 7500/HRO 4356333 THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. SMALL CLAIMS WRI STATE OF CONNECTICUT AND NOTICE OF SUIT SUPERIOR COURT JDC) Re e419 SMALL CLAIMS SESSION C.G.S. 3§ 51-18, 51-3489) vasw.jud.chgov nga Type or print ibly. This Smat! Chai ims Writ and Notice of Suit must be served on {delivered fo) the defendant(s) 2 = fing the court. See instructions to Plaintiff on reverse. 1.) Location formation that will determine whee the triai will be: 2.) Case type code /See list on reverse page 1) Defendant's Residence Major: Ss ino 15 3.) is ths a daim between aiandlord and 3 tenant (renter}? | 4.) if vou answered “Yes” to cueston #3. state the town woere the rental oremsses 's located: iSelect one) | Yes IX] Ne Parties Name (Last Fire Middle Inidal) and Address of Fach Panty (Number, Street. P.O. Box, Town, Sax ‘ounby. if nor USA, ‘Name: LVNV Funding LLC (Selectone) [x] LLC (i Parmership |p94 5) First ‘Address: 6801 S. Cimarron Road Suite 424-I Las Vegas, NV 89113 Plaintiff Cl inaviduat [J] DBA [7 Corporation Telephone: 6.) Name, address, and zip code of Attomey for Plants) ‘Atiomey’s Juris Number | Telephone number (w/area code) SCHREIBER LAW, LLC, 53 STILES RD., A-L02 434988 603-870-5333 _ SALEM, NH, 03079 = 2 Name: Vincent LaBella (Sefectone) [] LLC [7 Partnershp Dat 7) First Address: /§ Mason St Apt B Coventry, CT 06238-3190 Defendant Xl individual (] DBA [| Corporation Telephone: Foe more thar 1 plaintficefendant, attach Contnustion of Parties {form JD-CV-87) and select this box. a 8.) if ths claim is a consumer debt, which is 3 debt or obligation made primarily for personal, famity, or household reasons, give the reasons why you believe that the statute of limtations has not expired DEFENDANT'S LAST PAYMENT TOWARDS THE ACCOUNT OCCURRED ON 05/18/2021, WHICH IS WITHIN THE APPLICABLE STATUTE OF LIMITATIONS PERIOD. 6.) How did you cheek in the last 8 months that the address given for defendant(s) is accurate? Select all boxes that apply and provide the dates that the address was checked. [1] Nenecked town or city records {for example, checking 3 street list or tax recorcs} a _{date checked) [_] | checked with the Department of Motor Vehicles (date checked) [7] t received correspondence (letters or other mail] from the defendant with that setum address (date checked) [LJ | received other proof from the defendant that the address is currert (description of and date che a ‘] | mailed by fest class mail, at least4 weeks before this small clsims action was filed, a letier to the defendant at the for retumed ee f (last 11/03/2023 date oh. address used and the letter has not been retumed to me by the United States Postal Service _ zs TO) Amount claimed TC] Pus prejudgment interest" $695.25 Plus Costs [Ci Plus double damages for security deposit withheld”* ‘The Amount Claimed may not be more than $5,000. Do not include amounts ‘tif you select one or more baxas, you MUST explain for prejudgment interest or doubling the seountty deposit in box 10. how much you want for each it2m in section 34 below. To Defendant(s): 11.) You are being sued. The Plaintiffjs) daims you one the above Int plus costs and prejudgment interest andior double damages fora withheld seoutty deposi (ff seicted}for the following reasons: Credit One Bank, N.A. (“original creditor”) issued defendant a ("Ae int") with the Account number XXXXXXXXXXXX7475 and upon use of that Account, defendant became obligated to make timely payt idan faulted on that obligation and owes the balance due on the Account. Plaintiff acquired the Account and is the bona fide owner of the A@&Qunt. De: Yh defendant failed to, or was unable to, pay. Plaintiff demands judgment for the amount claimed together with costs and post-judgme! iter in es with CT Gen, Stat. Sec. 37-3a. Plaintiff requests that the Court further order a nominal payment order commencing three (3) weeks frol Egatot nt. Defendant is also not in the military. (See all supporting documents.). 95°, 6, on Se a aa a The person Saning wi, being duly sworn. ststes that he or she has read ton contained inthis form and,to thebest of his or her kn edge. nférmation and belief, there ‘s good ground to support the a = ati True. aS 12.) we Type naene oT PERG aan ie , Wapplicable|” For Court Use Only (Date/Siamp) 41 Jeffrey ichreiber [Heather a. walle, Esq. Lavi ron, Esq. ‘Subscnibed fd Date ighe = Notary, Commi E4fF of the Superior Court] sworn to 2 me on, 1-S96 ADA NOTICE The Judicial Branch of the State of Cannectiout complies with the Amerans with Disabilites Act (ADA). ff you need a reasonable accomenadaticn in accordance with the Decks: Number ADA contact a court clerk or an ADA contact person listed at wwwjud.ctgowADA, Print Form, Pagelds Reset rm INSTRUCTIONS TO DEFENDANT (NOTICE TO PERSON BEING SUED) JD-CV-121 Rev. 7-12 Please read the instructions carefully. For more information, get a copy of HOW SMALL CLAIMS COURT WORKS (form JDP-CV-45) from the Clerk's Office or from our website at www jud.ct. ‘smaliciaims.html. What Do | Have To Do To Defend This Case? The person suing you (the Plaintiff) delivered to you (served you with)'a copy of the Small Claims Writ and Notice of Suit; and related documents, if any. The plaintiff will now file the Small Claims Writ and Notice of Suit and related documents with the court. The court will send you an Answer form and a Counterclaim form with the number the court assigns to the case, called the "docket number" of the case, and the date you must file your Answer, and Counterclaim if you make one, by. The Answer form and the Counterclaim form should be sent to you soon but it could take up to 6 weeks depending on when the plaintiff files the case with the court. The Answer is your response or reply to the plaintiff's claim. If you claim the plaintiff owes you money, this is called a Counterclaim. There is a $90.00 fee to file a Counterclaim. Your Answer, and your Counterclaim if you make one, should be specific but brief. Fill out the entire Answer form, and the Counterclaim form if you make a Counterclaim, and sign them. Keep a copy of each for yourself and send a copy to each attorney or other representative of the plaintiff, or if the plaintiff is representing himself or herself, to the plaintiff. Send the original Answer form to the court by mail, fax or hand delivery at the address or fax number shown below on or before the answer date. If you makea Counterclaim, mail the original Counterclaim with the $90.00 fee to the court or hand deliver them to the address shown below on or before the answer date. You cannot fax a Counterclaim and its filing fee to the court. Please be suré to give us any change of your address. Do not answer until you get the Answer form and Counterclaim form from the court but if you do not get an Answer form and Counterclaim form within 6 weeks of being served, contact the court to ask why. If you do not file an Answer in writing with the court, a money judgment could enter against you. This is called a default judgment. You may make an agreement with the plaintiff before the plaintiff files the lawsuit in court or at any time before the court enters a judgment. You may hire a lawyer to represent you if you want to. You can find helpful information on our website at: http:/Awww.jud.ct.gov/faq/smailclaims.htm| and you may check the status of-your case after it has been given a docket number at:http :/Avww.jud2.ct.gow/Small_Claims/. If you have any questions, you can visit or call the Centralized Small Claims Office at 80 Washington Street, Hartford, CT 06106. The telephone number in the Hartford area is 860-756-7800. The toll free telephone number in Connecticut is 866-383-5927. The fax number is (860) 756-7805. You do not need an attorney even if the plaintiff has one. However, you can have an attorney if you want to hire one. If you want to use the regular rules of court in this case or if you want the right to appeal this case, you must file a motion to transfer the case to the regular civil or housing docket of the superior court. You may need an attorney to help you in filing that motion and you will have to pay fees to file it. The motion to transfer must be filed, in writing, with an affidavit and with the correct fees, on or before the answer date. What Happens If! Do Not File An Answer? If you do not file an Answer, the file will be reviewed by a magistrate who will decide whether a judgment can enter without a hearing for the full amount of the claim plus court costs, or ifa trial needs to be scheduled. What Happens If | File An Answer? If you file an Answer, do not go to court on the answer date. After the court receives your Answer, a trial will be scheduled if one is required. Cases are scheduled for trial as quickly as possible. What Should| Do If The Plaintiff Owes Me Money? If you claim the plaintiff owes you money, this is called a Counterclaim. Explain how much the plaintiff owes you and why on the Counterclaim form. Fill out the entire Counterclaim form and sign it. Keep a copy for yourself and send a copy to each attorney or other representative of the plaintiff, or if the plaintiff is representing himself or herself, to the plaintiff. Mail the original Counterclaim form with the Page 1 of2 Please be sure $90.00 fee to the court or hand deliver them to the address shown above on or before the answer date. to give us any change of your address. you do not agree What If | Know | Owe The Plaintiff Some Money? If you know you owe the plaintiff something, but the plaintiff, you should file a written with the amount the plaintiffis asking for or you are not sure how much you owe how the plaintiff added up the amount claimed. Answer. This gives you a chance to come to court for a trial to question owe the whole What Should | Do If| Admit That | Owe The Plaintiff The Whole Amount? If you are sure that you file an Answer not later than the Answer date, stating that you want time amount but you want time to pay, you must you are asking for the extra time to pay. You may ask for a period of time during which you to pay the claim and why judgment with an can make payments that you suggest. If you do not, and you are an individual, the court will enter a less than $35.00 per week and the order of payments of $35.00 each week until the judgment is paid. If you ask to pay plaintiff does not agree, a trial will be scheduled. for return of a A judgment against a business entity, for example, a corporation, or a judgment against a landlord security deposit, will be ordered paid in the full amount. This will be entered as a judgment of the court. date, tell the court If you pay the plaintifffplaintiff's attomey the full amount owed plus costs, if any, before the answer on the Answer form. Do not send payment(s) to the court. Where And When Do | Have To Go To Court? If a trial is required, you will be sent a notice of the date, time and against you if place of the trial. Even if you filed an Answer or a request for time to pay, the court can enter a judgment you do not come to court on the date and time set for the trial. (bills, What Do! Need To Bring To Court? On the day of the trial, you must bring allyour witnesses and evidence This includes any defective or damaged goods that can be brought to court safely invoices, checks) to court with you. of damages, pictures, and anything else that you want the court to look at. Be complete and and easily, estimates organized in your case. A small claims judgment cannot be appealed. ADA Notice The Judicial Branch of the State of Connecticut complies with the Americans with Disabilities Act (ADA). If you need a reasonable accommodation in accordance with the ADA, contact a court clerk or an ADA contact person listed at www.jud.ct.gow/ADA/.