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  • J.P. Morgan Chase Bank, N.A, vs. Miguel A RodriquezConsumer/Commercial Debt - Under $250,000 document preview
  • J.P. Morgan Chase Bank, N.A, vs. Miguel A RodriquezConsumer/Commercial Debt - Under $250,000 document preview
  • J.P. Morgan Chase Bank, N.A, vs. Miguel A RodriquezConsumer/Commercial Debt - Under $250,000 document preview
  • J.P. Morgan Chase Bank, N.A, vs. Miguel A RodriquezConsumer/Commercial Debt - Under $250,000 document preview
  • J.P. Morgan Chase Bank, N.A, vs. Miguel A RodriquezConsumer/Commercial Debt - Under $250,000 document preview
  • J.P. Morgan Chase Bank, N.A, vs. Miguel A RodriquezConsumer/Commercial Debt - Under $250,000 document preview
  • J.P. Morgan Chase Bank, N.A, vs. Miguel A RodriquezConsumer/Commercial Debt - Under $250,000 document preview
  • J.P. Morgan Chase Bank, N.A, vs. Miguel A RodriquezConsumer/Commercial Debt - Under $250,000 document preview
						
                                

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OTICE: THIS D MENT CONTAINS SENSITIVE DATA NO. JPMORGAN CHASE BANK, N.A. § IN THE COUNTY COURT vs. 8 ATLAW NO. OF MIGUEL A RODRIGUEZ § MONTGOMERY COUNTY, TEXAS PLAIN F'S ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, JPMORGAN CHASE BANK, N.A. (‘Plaintiff’), and files this, its. Original Petition, complaining of MIGUEL A RODRIGUEZ, Defendant herein ("Defendant"), and for cause of action would respectfully show this Honorable Court the following: PARTIES. Plaintiff is JIMORGAN CHASE BANK, N.A.. Defendant is MIGUEL A RODRIGUEZ, who may be. served with process at 1161 COURTEOUS CREEK DR, MONTGOMERY TX 77316-2257, or any other valid address. I, DISCOVERY LEVEL 1, Plaintiff intends discovery to be conducted under Level 1 of Rule 190 of the Texas Rules of Civil Procedure. IL VENUE AND JURISDICTION Venue is proper in this. Court because Montgomery County, Texas is where. the Defendant resides. The amountin controversy is within the jurisdictional limits of this Court. « Plaintiff seeks only monetary relief of $250,000.00 or less, including damages of any kind, penalties, costs, expenses, pre-judgment interest, and attorney fees. Ill. FACTS PLAINTIFF'S ORIGINAL PETITION - Page 1 In the usual course of business, Defendant entered into an agreement for the credit account that forms the basis of this suit on or about April 9, 2022. At all times relevant hereto, Defendant was the primary cardholder under the account. Defendant requested that the account currently bearing number XXXXXXXXXXXX5474 (the "“Account") be opened, and the account was opened. ‘The term "account number" means the full and complete account number assigned to the credit card account by the bank. The Account is governed by the applicable Terms and Conditions ("Terms and Conditions"), as they may be amended from time to time. Defendant is responsible for repayment of extensions of credit, as set out by the Terms and Conditions. The Account was used to make purchases of goods and/or services and/or to receive cash advances. The Account represents a transaction or series of transactions, of which a systematic record has been kept. Inaccordance with the Terms and Conditions, Defendant was properly billed for payment of the extensions of credit on the Account. 10. Defendant has failed to pay the amounts due and owing. 11 The amount being sought on the Account is $21,250.09. A true and correct copy of the Account statement showing the balance sought is attached hereto and marked as Exhibit "1" and is incorporated herein by reference. (This is not a suit on a sworn account). 12. As a result of Defendant's failure to pay, Plaintiff found it necessary to employ an attorney to collect such amounts. 13 All conditions precedent have been performed or have occurred. IV. CAUSE OF ACTION -- ACCOUNT STATED PLAINTIFF'S ORIGINAL PETITION - Page 2 14, Plaintiff alleges that it should recover from Defendant for an account stated. Defendant's series of transactions on the Account has resulted in thé indebtedness of Defendant to Plaintiff. A written statement of the amount owed was transmitted to Defendant. Defendant has failed to pay. V. ATTORNEY'S FEES, COURT COST, & POST JUDGMENT INTEREST 15 JPMorgan Chase Bank, N.A. expressly disclaims any request for attorney’s fees, court cost, and/or post judgment interest whether or not JPMorgan Chase Bank, N.A. is entitled to such an award by law. VI. PRAYER WHEREFORE, Plaintiff, JPMORGAN CHASE BANK, N.A., prays that -- A. Defendant be cited to appear and answer herein; B. Plaintiff be granted judgment for the amount due; C. ‘Plaintiff be granted such other and further relief, special or general, legal or equitable, to which Plaintiff may be justly entitled. Respectfully Submitted, MOSS LAW FIRM, P.C. P.O. Box 3790 Lubbock, Texas 79464 (806) 796-7375 FAX (806) 771-0062 QuoGe Email: e-Service nyoss|ayyfigapp-com B C:24092918 “MICHAEL A. MOSS, ATTORNEY IN CHARGE per TRCP 8, SBN 24054360 ATTORNEYS FOR PLAINTIFF THE DEFENDANT IS PUT ON NOTICE THAT THE TEXAS RULES OF CIVIL PROCEDURE REQUIRE THAT A COPY OF ALL DOCUMENTS FILED WITH THE COURT BE SENT TO OPPOSING COUNSEL. PLAINTIFF'S ORIGINAL PETITION - Page 3 | CHASES ‘Manage your account ontine a: Customer Service: 1-800-499-3910 Mobile: Download the ‘Chase Mobile app today SAPPHIRE’ New Balance ULTIMATE REWARDS® sMTWT $21,250.09 SUMMARY a7 28 2990 3 Minimum Payment Due $5,365.00 Previous points balance 0 #1 Point per $1 oarnod on ailpurchases—— Payment Duo Dato "+ 2x Points eamed on| oe 10 " 12 19 “4 16 16 "7 16 Ki > a 09s Total points available for 2 2627 redemption 0 6 ‘Loam more about your rewarda and start redeoming today. Visit Chase Ultimate Rewardsat www.Ultiatel Late Payment Warning: we do nol receive your minimum payment With Sapphire Proferred, you'l eam 2x pointson travel worldwide by the date fisted above, you may have to pay a tale fee of up to and a tolal of 6x pointa when you purchase travel on Ulimate ‘$40.00 and your APA's will be subject fo increase to a maximum Rowarda®, Eam 3x pointe on dining al rostaurante, inckiding Penalty APR: eligiie delivery servives and takeout - around the comer or Minimum Payment Warning: Hl you make only the minimum ‘around the world. Plis, eam Sx poinis on selec! slraaming [payment each peitod, you wil pay more In interest and itil take you arco andl oni proatypurchases (enchiing Target®, longer fo pay off your belance, For oxamplo: Walmant@ and wholesal you make no ‘You will pay off the | And you willendup. additional charges ance showin on thie | paying an estimated Using this card and statement in about. tolal of, Jeach month you pay. ‘Only the minimum 28 yearo $69,012 payment you would like Information sboul credit counseling sarvices, call 41-866 ACCOUNT SUMMARY Account Number: QED 6474. Previous Balanco $20,746.15 Payment, Crodits Purchases $0.00 ‘Cash Advancos 0.00 Balance Tranefers Fees Charged $2.00 Inleresi Charged New Balance $21,250.00 Spening’Closing Dato ‘O72923 - C8228 Credit Access Lina. ‘$18,900 Avallable Credit Cash Aooass Line Available for Cash Past Due Amount ‘$4649. Balance over the Credit Acoees Line. $2,850,09 YOUR ACCOUNT MESSAGES ‘You are over your credit Iine/credit access line by $2,950.09, You can pay down your balance fasterby including this amount wilh your payment ‘Your account ia closed and no longet available for use. ww e900 am == 2 ee CHASEO LSE aaa SAPPHIRE P.0. BOX 15123 The Past Due Payment Due Date: 09/19/23 WILMINGTON, DE 19850-6129 amount of $4,649,008 New Balance; For Undelivorable Mal Only included in your $21,250.09 Minimum Payment Due; $5,365.00 Minimum Payment. Account number: aD 5474 Enclosed Wakoral to Chase Gard Serves at the address bekow: MIGUEL A RODRK 1161 IRTEQUS, K DR NTGOMERY TX 77316-2267 CARDVEMBER SERVICE PO BOX CAROL STREAM iBT Lae = ‘To contact us regarding your account: THUS Tor Customer Service nus. 1-800-493-3319. ? ® ‘Spanish $-800-499-3318 38-7958 ‘Send inquitlesto: Mall Paymonte ‘Vial Our Website: Internation nl 14-776-7050 P.O, Box 16298 P.O. Box 6294 ‘We accept opetator tafny cals ‘Wieingion, DE 19850-5298 Carol Sueam, K. 60197-6204 [WermalionAbeat Your Account cash ade enh nan nh ano aa nut Aco Aton Pane Yo Fema: Tarun of ut pre oat bt at ou acs eof 2 fe US. twee fy ran dn, pya US. dolar ad drazn om 0 papal Winaalon Sore scones Passa st yor Account Agrearant freon stor ta tes ren tsa eaten en heat ase ets, ay den uesite by paying mos han Tb skrun payment ft ‘We add ansatons ad esto yoo day blanca meats han ‘wepadbobnee on you couch Tourn oa part try rego waa bert toe 4th a oth ansaton—for ae phates tae asi, ovr sea phone rumets shove [natn any! tesa cane You ara, cash adrances, of lo wire leas aba one en sectors nde ‘eae Waratl rm yt ark et ve 2. dae tho payne depose te cheek = for new eash advance chuck of Ine azomaled phon prem the naborbatan&prAded ws ey of pusoral ‘lane rose eta, NevtTcton rumba, Yo ay ht suhoroalin ‘eau wobta ocarar wes tnpore potenncallg pet yorhe pp payee Baca amid nee slo, Fu te they at pasted to Your seoourt of cyl, when ay choose tor bee srocerting. Hv tedin your nl rqued thaigh one of thet ‘hana by 11.8 pi. Easun To, we wi ad your payment vo Thal. 1 ‘ow eave Paying lelaras On Puchacer: Your doe dale wilbe a mieinum of 24 ‘we nate your segue ser 14:56 i Eastin Th, wit red yeu 9 ater a ach bingeye you pay your accu (nae Si abel he nt ca you apety aut diel you eae i eect ance) be i ech ig ps 0 la cine a, no nares i aon yu pyran as al dy. ‘onnecrpurhases month to moat Aa wa wool ipo intra charges on ay {uy a yea US. oth Pays sey sons on Bn sare, porlnnot a phase bulaece you epay wtb Wat babes sutec i andalvest- ‘wrt year cena ner on out che oF money onde and dchde the payment {tea paid. Subject to aay Laretae ptod lor naw purchases, we vel gia 1 canaply 1 wnpald uot age your er br, te af asooecba foc Maar Yat Your AccouR! & open. We Wl 46 pour You i You A Dad Wik Yow Gua ad Pasa aan YoU Ue your secon Your anal member ft wl nse beadedata hehe oF ok sy tne test aR ceric geet vee tha youve purchased wth your ced lace ounoly rca ieee. The are merase is carlin ues us al ugh ect ayo na roy a tbe lg nolo pay the rerabieg arovnt dun an th phase, uma ee he ‘Yo use Ii ltt, aol Ue tntegmust bet: fal Me Yo anol Bana mec es iat i 4. The purchase mst hava buen radia your bon sea win 100 mes a clea your Asourt and ont your rh to noeoun ‘of your eusec maing uses, afb gucchase prea mual nave Deen Myo Asosed by ev oray mel antes wlolongess ‘eta an S50, (ole: Refer of theye ae necessary ¥ your puchase wes bile ta you Accound based onan adeno maid you oF owe company Bat Satin hres ohOtclg clo yk wn lf Sg uo ae ‘ld you Ihe goods. on anc) mene, wo ust 2. You must he uaed your crt ca fr Be purctass. Purchases made wih ‘Safer h a ee hrs ory po tox maton Tg yr ede oat uth advances tom bm ATM ot wih &chack al acess yet eid ed ‘es, ‘Accounl deol ual. 14a Gaya bat, alin of ‘iter rtd, about parca ‘Haren, pese cal alles canone Keres charge niet ed oe sence pons 3. You as oot yet have ty pl orb puch, Ma ay pt sce spy fe ch te fo eng, {Wel tte eter nbavaertancyou ace stitnaliadihe purchate, conte pextuses, baboce taster, cath acanesof ‘ws inutting al Cuero Srv, 0. Bax 1829, Wigton, DE 19450-3209, cetkedatone conte els citgnis waht som rode ees).Vole These ‘ite wo invest, the sam rales apply lath cpus aroun as ices {ale wll vry wih Ue mural Sate gn he Pre ab eh ne dese Bed sev. Atrovent deen. Aha poe, 4 you Account Ageerent, Thee ea (or each balance tana, ‘eI you ene an amour and yu do ol pay wn yer yoU Is eloguet oososea2t To manage your account, including card payments, alerts, and change of address, visit ea or call the customer service number which appears on your account statement. CS | CHASE ‘Manage your account online al! Customer Service: $-800-493.9919, Mobile: Downioadthe Chase Mobile app today SAPPHIRE’ ACCOUNT ACTIVITY Dato of Transaction Merchant Namo or Transaction Description $ Amount INTEREST,CHARGED _ pire are RRR naa oe » PURCHASE INTE REST CHARGE “494.89 owz2 ‘CASH ADVANCE INTEREST CI 9.05 TOTAL INTEREST FOR THIS PERIOD. $503.94 2023 Totala Year-to-Date Total tees charged in 2023 5964.00 Total interest charged in 2023 $3,548.96 ‘Yeat-to-dale totals do not reflect any tee oF inlerest refunds you may have. INTEREST CHARGES Your Annual Percentage Rato (APR) Is the annual interest rele on your account. Annu Balance Balance Type centage Subject To Interost Rate (AP! * Interest Rate Charges PURCHASES na oo me ae Purchases CASH ADVANCE: pa 2aie) $20,699.56 $494.89 jas epee ee —s "2.99% (0) $9.05 BALANCE TRANSFI — —mee = seen —; afer (ey(d) (¥) = Vatiable Rato 1 Days in Billing Portod (@) = Dally Belance Method ing (a) = Avorage Dally Balance Method (irIncluding new transact Pteave 600 Information About Your Account section for the Calculation of Balance Subject to Interee! Rate, Annual Renewal Notice, How {0 Avoid Intereston Purchases, and olher important information, a9: IMPORTANT NEWS F (id you know you can rake paymoni a Chase.com ota our 8p? If you continue to eend check paymenio, ploase do not inckade staples, clips, cash of fokled checks as this can delay processing your payment. Abvay@ inolude your 16-digit ‘card numbor and just 1 check per etalemont. } MIGUEL A RODRIGUEZ Page 201 2 ‘Statement Date; 08/22/29 an ae eco qu ia- a fae