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45D01-2403-CC-002398 Filed: 3/12/2024 3:47 PM
Clerk
Lake Superior Court, Civil Division 1 Lake County, Indiana
STATE OF INDIANA ) IN THE LAKE COUNTY SUPERIOR COURT CIV. DIV. 4
)ss:
COUNTY OF LAKE ) CAUSE NO.
LVNV FUNDING LLC,
Plaintiff
vs.
CHARLES SHELTON,
Defendant.
COMPLAINT
1 Upon information and belief, Defendant Charles Shelton, resides at 1402 Jefferson St, Gary, Lake
County, Indiana.
2 Upon information and belief, Defendant is not in active military service. Please see the affidavit of Non-
Military Service attached as Exhil it A.
3 Credit was extended to Defendant on account number XXXXXXXXXXXX4888 formerly with Credit
One Bank, N.A..
4 Defendant has defaulted on the account and, as of March 08, 2024, Defendant owes a balance of $996.88
to Plaintiff, as is more fully set out in Plaintiff's Affidavit of Debt attached as Exhibit B and incorporated by reference.
5 Plaintiffis the assignee of Defendant’s account.
WHEREFORE, Plaintiff requests a judgment in its favor and against Defendant for total damages in the amount
of $996.88, plus any interest and costs of collection and such other relief as the court may deem appropriate.
Respectfully Submitted,
STENGER & STENGER, P.C.
Attorneys for Plaintiff
y
Dated: 03/12/2024 B
Lo Keith A. Sparks #32766-71
( Denise M. Hallett #8406-45
C1 Zachary M. Kimmel #34667-47
DL David W. Gray #32482-45
XX] David J. Hoff #35481-15,
2618 East Paris Avenue SE
Grand Rapids, MI 49546
Phone: 8883057775
Fax: (616) 942-9657
Email: indiana@stengerlaw.com
THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 24-111958 IMDM 0000 0 0 01000000
10 M100 00 0100
EXHIBIT A
THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 24-111958 [III N00 00 00 1 00000008000 110
STATE OF INDIANA ) IN THE LAKE COUNTY SUPERIOR COURT CIV. DIV. 4
)ss:
COUNTY OF LAKE ) CAUSE NO.
LVNV FUNDING LLC,
Plaintiff
vs.
CHARLES SHELTON,
Defendant.
AFFIDAVIT OF NON-MILITARY SERVICE
Comes now affiant and states:
The Defendant is not in military service. The source of my knowledge is the Department of Defense Manpower
Data Center report attached hereto as Exhibit 1. I swear or affirm under the penalties of perjury that the foregoing
representations are true to the best of my knowledge.
Respectfully Submitted,
STENGER & STENGER, P.C.
Attorneys for Plaintiff
\
Dated: 03/12/2024 By:
Co Keith #32766-71
CZ Denise M. Hallett #8406-45
CI Zachary M. Kimmel #34667-47
L] David W. Gray #32482-45
XX] David J. Hoff #35481-15,
2618 East Paris Avenue SE
Grand Rapids, MI 49546
Phone: 8883057775
Fax: (616) 942-9657
Email: indiana@stengerlaw.com
THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 24-111958
EXHIBIT 1
THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 24-111958
Department of Defense Manpower Data Center Rosutts us of Mar 12 2024 0702:43AM
SCRA 5.19
eed ey,
Ee ts
oefg Status Report
i Ase fe
e Pursuant to Servicemembers Civil Relief Act
ort
SSN: a
Birth Date: a
Last Name: SHELTON
First Name: CHARLES
Middle Name:
Status As Of: Mar-12-2024
Certificate ID: 6YGQF4FDMHBMKR4
‘On Active Duly On Active Duty Status Dato
Active Duty Star Date Active Duty End Date ‘Status Service Component
NA NA No NA
J TESThis Beoease
response reflects
mace the individ active duly statue based op the Active Duty Status Date -
Loft Active Dity Within 367 Days of Active Duty Status Date
Active Duty Siart Date Active Duty Eng Date Status Service Comporcnt
NA NA No NA
Tosponse retlocts where the individuat oR active diay stalus within 367 days precoding the Active Dixy Brats te
‘The Member or His"Her Unit Was Notitied of a Future G: p 10 Active Duty on Active Duty Status Date
(Order Notiication Start Date Onder Notification End Date Status Sarvios Component
NA NA No NA
This response saftects whelhe: the inaividual or his*her unit has received early notilication to *epo"t tor acleve Outy
Upen searching the dala banks of the Department of Defense Manpower Data Center. based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army. Navy, Mat e Corps, Air Force, Space Force, NOAA, Public
Health, and Coast Guard}. This status includes information on a Servicemember or his’her unit receiving notification of future orders to report for Active Duty.
Sam fogedde
Sam Yousetzadeh, Director
Department of Defense - Manpower Data Genter
4800 Mark Center Drive, Suite 04625
Alexandria, VA 22350
File #: 24-111958
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrolment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 3901 et seq, as amended) (SCRA) {formerly known as
the Soldiers’ and Sailors‘ Civil Relief Act of 1940). DMDC has issued hundreds of thousands of “does not possess any information indicating that the
individual is currently on active duty” responses, and has experienced only a smail error rate. In the event the individual referenced above. or any family
member, friend. or representative asserts in any manner that the individual was on active duty for the active duty status date, or is ctherwise entitled to the
protections of the SCRA, you are strangly encouraged to obtain further verification of the person's status by contacting that person's Service. Service contact
information can be found on the SCRA website's FAQ page (Q35) via this URL: hitps:/scra.dmdc.osd.mil’scra/filags. If you have evidence the person
was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked
against you. See 50 USG App. § 3921(c}.
This response reflects the following information: (1} The individual's Active Duty status on the Active Duty Status Date {2} Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3; Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty slatus as reported in this certificate is defined in accordance with 10 USC § 101t(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard. this includes service under a cail to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(F) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves {TARs). Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs}. Active Duty stalus also applies to a Uniformed Service member who is an active duty commissioned officer of the U_S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps}.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Tiile 10 and Title 14 active duty records for ail the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1)
Many times orders are amended to extend the period of active duty. which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore. some protections of the SCRA may extend to perscns who have received orders to repert for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counset to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
File #: 24-111958
EXHIBIT B
THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 24-111958 III I00 (000 000 00 000 000 0000 0 1
24-111958 723971621
LVNV Funding LLC
vs.
Charles Shelton
Defendant(s)
Comes now affiant, and states:
I Dimeshia Hook, am an employee of Resurgent Capital Services, L.P. master servicer for Plaintiff, and I am
authorized to make this affidavit on behalf of Plaintiff.
I am of adult age and am fully authorized’ by Plaintiff to make the following representations. I am familiar with
the record keeping practices of Plaintiff. The following representations are true according to documents kept in
the normal course of Plaintiff's business and/or my knowledge:
Plaintiff:
MT is the original owner of this debt.
OR
Mis not the original owner of this debt. The original creditor is Credit One Bank, N.A..
Defendant,
Charles Sheltonhas an unpaid balance of $996.88 as of 02/13/2024, on account
HOOA RRR
That amount is due and owing to Plaintiff. This account was opened on 04/25/2021. The last payment from the
Defendant was received on 11/11/2021 in the amount of $31.00. The Account was charged off on 06/09/2022.
The type of account is:
FM Credit card account (ie. Visa, Mastercard, Department Store, etc.)
List the name of the Company/Store issuing credit card: Credit One Bank, N.A.
I Account for utilities (ie. telephone, electric, sewer, etc.)
i Medical bill account(i . doctor, dentist, hospital, etc.)
Fj Account for services (i.e. attorney fees, mechanic fees, etc.)
I Judgment issued by court (a copy of the judgment is required to be attached)
i Other: Installment loan
/12915
This account balance includes:
MThe account contains no post-charge-off late fees.
MThe account contains no post-charge-off interest.
Plaintiff:
Mis not seeking attorney's fees.
Plaintiff's business records do not show that Defendant is a minor or an incompetent individual.
The following exhibits are attached hereto:
5 Copy of the contract or other writing evidencing the original debt.
If the claim is based on credit card debt, a charge-off statement and monthly statement recording the most
recent purchase transaction, payment, or balance transfer.
™ Bills) of Sale and Assignment and/or Affidavit(s) of Sale for the above referenced account.
M Seller data sheet reflecting individual account data extracted and printed from electronic records provided
by the seller to Plaintiffin connection with the sale of the account to Plaintiff,
The documents attached hereto are true and correct copies of documents provided to Plaintiff by seller. These
documents are reproductions of the records on file on behalf of Plaintiff based upon my review, except to the
extent that confidential and privileged information and/or personal identifying information is omitted or redacted
as required by local rules, and applicable state and federal law.
The following is a listing of the names of all prior owners of the debt:
Owner Date of Sale Defendant's Name Last 4 of the Account Number
Credit One Bank, N.A. 6/30/2022 Charles Shelton 4888
MHC Receivables, LLC and FNBM, LLC 7/19/2022
Sherman Originator Ill LLC 7/19/2022
Sherman Originator LLC. 79/2022
I swear or affirm under the penalties of perjury that the foregoing representations are true.
Date: 02/13/2024 Signature of A ffiant:
712915
CREDIT ONE BANK CREDIT CARD STATEMENT
“Account Number| 4
May 09,,2022 to June 08, 2022
SUMMARY OF ACCOUNT ACTIVITY PAYMENT INFORMATION
Previous Balance $940.27 New Balance $996.88
Payments $0.00 Past Due Amount $278.00
Other Credits $0.00 ‘Amount Due This Period $757.88
Purchases $0.00 Minimum Payment Due $996.88
Balance Transfers $0.00 Payment Due Date o7i0a22
Cash Advances $0.00 Late Paymont Warning:
Fees Charged $39.00 we do not receive your minimum payment by the date licted above,
Interest Chargod $17.61 you may have to pay a late fe upto $39.
New Balance $996.88 Minimum Payment Warning:
Crest Limit $600.00 you make only tho imum payment each period, you wil pay more
Available Credit $0.00 {in fears and it wi? take you longsr to pay off your balance.
Statement Closing Date 6/0822 For example:
Days in Biling Cycle ityou make no You will pay off he ‘And you wil
additional charges balance shown on ‘end up paying
‘QUESTIONS? Using this card and the statement in an estimated
Call Customer Service or Report ach month you pay. about. {otal of.
a Lost or Stolen Credit Card 1-877-825-9242 Only the minimum
Outside the U.S. Call 1-702-405-2042 payment 1 months $997.00
Please send billing inquiries and correspondenceto:
P.O. Box 98873, Las Vegas, NV 89193-8873 Ifyou would Ike a location Tor credit counseling services, cal
1-866-515-5720. Or you may visit wow justice gov/ustist
crodit-counsoling-agencies-approved-pursuant-tY-usc-11
‘TRANSACTIONS
Reference Number ‘Trans Date Post Date Description of Transaction or Credit Amount
Fees
06/08 06/08 LATE FEE 39.00
TOTAL FEES FOR THIS PERIOD 39.00
Interest Charged
06/08 06/08 Interest Charge on Purchases 17.61
06/08 06/08 {Interest Charge on Cash Advances 0.00
TOTAL INTEREST FOR THIS PERIOD 17.61
2022 Totals Year-to-Date
Total fees charged in 2022 $234.00
Total interest charged in 2022 $91.59
‘Your account is currently closed.
INTEREST CHARGE CALCULATION
Your Annual Percentage Rate (APR) is the annual interest rate on your account,
Balance Subject to
Type of Balanco Annual Percentage Rate (APR) Interest Rate Interest Charge
Purchases 24,74%v) $853.89 $17.61
Cash Advances 24.74%v) $0.00 $0.00
(v) + Variable Rate .
ses pH oor 78 2206080 EX PAGE!11 20 S7z7 620 MI98 O1GRSIES
Please urn this ponton wih you payer, ang we your account rumberon your check, made payable to CREDIT
ONE BANK,
Cryinrie
PAY YOUR BILL ONLINE at CreditOneBank.com
Account Number: aS 4825
New Balance: $996.88
Minimum Payment Due: $996.88
Fer ares, telephone and emai changes, Payment Due Date: ormosse2
Please compiote the reverse
(Or, update your contact information online
‘worw CreditOneBank com, AMOUNT ENCLOSED: |s
Usladisdele saleolloUagbeleseasloatleeH
atest oessaee
CREDIT ONE BANK CHARLES SHELTON
PO BOX 60500 1402 JEFFERSON ST
CITY OF INDUSTRY CA 91716-0500 GARY IN 46407-1241
ANU bal HH ALAM Moss bel i elle
0000000 0099688 00996¢0 NNN: Poowention
CREDIT ONE BANK CREDIT CARD STATEMENT
‘Account Number 4888
November 03, 2021 to December 08, 2021
7
‘SUMMARY OF ACCOUNT ACTIVITY PAYMENT INFORMATION
Previous Balance $650.69 New Balance $671.29
Payments $31.00 Past Due Amount $33.00
Other Credits $0.00 Amount Due This Period $73.00
é S $0.00 Minimum Payment Due $106.00
Balance Transfers $0.00 Payment Due Date 10422
Cash Advances $0.00 ‘ate Payment Warning.
Fees Charged $39.00 {Ewe do not rocolvo your minimum payment by the dato listed above,
interest Charged $12.40 You may nave to pay a late fee up to $39,
‘New Balance $671.29 Minimum Payment Warni
Credit Limit $600.00 you mal ‘only the minimum payment each period. you will pay more
Available Credit $0.00 In interest and it wil take you longer to pay of! your balance.
‘Statement Closing Date 1208/21 For example:
Days in Billing Cycle you make no You will pay off ne “And you wit
additional charges balance shown on fend up paying
‘QUESTIONS? Using this card and the statement in an estimated
Call Customer Service or Report ‘each month you pay. about, total ol.
a Lost or Stolen Credit Card 1.877-825-3242 Only the minimum
Outside the U.S. Call 4-702-405-2042 payment 2yoas $870.00
Please send billing inquiries and correspondence to:
P.O, Box 98873, Las Vegas, NV 89199-8873 Ifyou would ike a focation lor ered counseling services. ca
1-866-515-5720. Or you may visit wwaw justice govlustlist-
ctgcit-counseling-agencies-approved-pursuant-fY-usc-1 11
TRANSACTIONS
Rolerence Number Trane Osto Post Dato Dascription of Transactionor Ores Amount
74071999 VOOXTMIIY TT Wit PAYMENT - DEBITCARD LAS VEGAS NV 31.00
Fees
12/08 12/08 LATE FEE 39.00
TOTAL FEES FOR THIS PERIOD 39.00
Interest Charged
12108 12/08 Interest Charge on Purchases 12.40
12/08 12/08 Interest Charge on Cash Advances 0.00
TOTAL INTEREST FOR THIS PERIOD 12.40
2021 Totals Year-to-Date
Total fees charged in 2021 $230.24
Total interest charged in 2021 $86.83
Your account is currently closed,
INTEREST CHARGE CALCULATION
Your Annual Percentage Rate (APR) is the annual interest rate on your account
Balance Subject to,
‘Typeof Balance Annual Percentage Rate (APR) Interest Rate Interest Charge
Purchases 29.99%(v) $620.34 $12.40
Cash Advances 23.99%v) $0.00 $0.00
(¥) = Variable Rate
5385 JBH 001 78 211208 0 EXPAGE 1 of 1 20 $727 9620 A203 O1GRS3BS
Pe 30 reurs ts porvon wth your payment, an wree your Account numer On yOu! cheek, made payaRHe 10 CREDIT ONE BANK,
7 a PAY YOUR BILL ONLINE at CreditOneBank.com
>.
Credi¢ci Account Number:
New Balance:
Minimum Payment Due: $106.00
a
$671.29
4282
For address. telephone and email changes. Payment Due Date: ovoaa2
please complete the reverse side.
(Or, update your contac information onling
‘at wur.CredltOneBank.com. AMOUNT ENCLOSED: b . |
shih Hela Ll Hoots Me
CREDIT ONE BANK CHARLES SHELTON
PO BOX 60500 1402 JEFFERSON ST
CITY OF INDUSTRY CA 91716-0500 sARY IN 46407-1241
[MDL ssadatell eA Loves
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Exhibit Documentation -
BILL OF SALE AND ASSIGNMENT-OF ACCOUNTS
EROM CREDIT ONE BANK, N.A. TO MHG RECEIVABLES, LLC
As of June 30, 2022, for good and valuable consideration, the receipt
and sufficiency of which is hereby
acknowledged, Credit One Bank, N.A. (“Assignot” ) has transferred, has sold, has assigned, has conveyed, has granted
and has otherwis
e delivered to MHC Receivables, LLC (“Assignee”), all of Assignor’s right,
to (i) the charged-off title and interest in and
credit card accounts identified on an ai ccount level basis
CreditOne_Fresh_LegalRecall_072022 (the “Computer File”), a copy of which in the data file named
is attached hereto and incorporated
herein by. reference as “Exhibit A”; and, (ii ) certain related account
level media or electronic coy pies thereof (including,
but not limited to applications, statements, terms and condition), and (fii) all
claims or rights arising out of or relating
to cach account refereitced on the Computer File (collectively h ereinafter, the “Account
to, all claims and rights afforded each Account by virtue of that Account’s correspo s”) including, but not limited
nding terms and conditions.
The Accounts transferred under the terms of this Bi Il of Sale and Assignme
transfered to Assignee immediately following ch: jarge off for each applicable
nt of Accounts were each
Account, as shown in the Computer File.
With respect to information for the Accounts, Assi; ignor represents and warrants
to Assignee that the business
records conveyed to Assignee relating to: (i) the Account s issued by Assignor;
and (ii) the
Accounts by Assignor (collectively, the “Business Records’ "), are kept by Assignor in the regularsale and assignment of
11 is in the regular course of business of Assignor course of its business.
for a in employee or an authorized reypresentative with personal
knowledge of the act, event, condition, or opinion (collectively “Event”) to
be recorded, to make the appropriate
memorandum or recording of the Event at or reasonably near the ti me
of the Event. Furthermore, Assignor represents
and warrants to Assignee that the Business Records are materially complete and
accurate, and thoroughly embody the
information in Assignor’s custody and control for the Account:
's from their creation until the time of transfer to
Assignee, These representations and warranties are intended to at ugment
any other representations and warranties the
parties may have in place and not supplant any other existing wa
rranties and representations.
This Bill of Sale and Assignment of Accounts shall serv ¢ as evidence of ownership for the
conveyed hereby and shall serve as an acknowled, Accounts
lgment, as ratification, and as evidence of the intent of the Parties
transfer the Accounts. to
CREDIT ONE BANK, N.A.
Passe
Michael Wiese
Vice President
—= Set — see -———.
Exhibit Documentation -
EXHIBIT A
ACCOUNT SCHEDULE
‘The Accounts that are specifically identified in the electronic fil le named CreditOne_Fresh_
with such electronic file incorporated herein by reference.
LegalRecall_072022
a =
Exhibit Documentation -
BILL OF SALE AND ASSIGNMENT OF RECEIVABLES
EROM CREDIT ONE BANK, N.A. TO MHC RECEIVABLES,
LLC
As of June 30,.2022, for good and valuable consideration,
acknowledged, Credit One Bank, N.A. (“Assignor") fias
the recei pt and sufficiency of which is hereby
transferred, has sold, hi las assigned, has conveyed, has granted
and has otherwise delivere d to MHC Receivables, LLC (“Assignee”); all of Assignor’s right, title
to (i) the receivables and interest in and
associated with ea ich and every account referenced in
CreditOne_Fresh_LegalRecall_072022 (the “Computer File"), a copy the data file named
of which is attached hereto and incorporated
herein by reference as “Exhibit A”. + and, (ii) all claims or rights arising
out of or relating to cach of those Receivables
(hereinafter, the “Receivables").
‘The Receivables transferred under the terms of this Bill of Sale
transferred to Assignee prior to the charge off of t!the associate
and Assignment of Receivables were each
d accounts, as shown in the Computer File. This Bill of
Sale and Assignment of Receivables evidences th e intent between
the parties for the transfer of the Receivables, acts
as an acknowledgement of those transfers, and, to the extent
necessary, ratification of the transfers,
With respect to information for the Recei ivables, Assigno
r represents and warrants to Assignee that the
business records conveyed to Assignee relating to tl he
Receivables (the “Business Records”), are kept by Assigno r in
the regular course of its business. It is in the regul. lar course of busines
s of Assignor for an employee or an authorized
representative with personal knowledge of the act, event, condition,
y or opinion (collectively “Event”) to be re
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45D01-2403-CC-002398 Filed: 3/12/2024 3:47 PM Clerk Lake Superior Court, Civil Division 1 Lake County, Indiana STATE OF INDIANA ) IN THE LAKE COUNTY SUPERIOR COURT CIV. DIV. 4 )ss: COUNTY OF LAKE ) CAUSE NO. LVNV FUNDING LLC, Plaintiff vs. CHARLES SHELTON, Defendant. COMPLAINT 1 Upon information and belief, Defendant Charles Shelton, resides at 1402 Jefferson St, Gary, Lake County, Indiana. 2 Upon information and belief, Defendant is not in active military service. Please see the affidavit of Non- Military Service attached as Exhil it A. 3 Credit was extended to Defendant on account number XXXXXXXXXXXX4888 formerly with Credit One Bank, N.A.. 4 Defendant has defaulted on the account and, as of March 08, 2024, Defendant owes a balance of $996.88 to Plaintiff, as is more fully set out in Plaintiff's Affidavit of Debt attached as Exhibit B and incorporated by reference. 5 Plaintiffis the assignee of Defendant’s account. WHEREFORE, Plaintiff requests a judgment in its favor and against Defendant for total damages in the amount of $996.88, plus any interest and costs of collection and such other relief as the court may deem appropriate. Respectfully Submitted, STENGER & STENGER, P.C. Attorneys for Plaintiff y Dated: 03/12/2024 B Lo Keith A. Sparks #32766-71 ( Denise M. Hallett #8406-45 C1 Zachary M. Kimmel #34667-47 DL David W. Gray #32482-45 XX] David J. Hoff #35481-15, 2618 East Paris Avenue SE Grand Rapids, MI 49546 Phone: 8883057775 Fax: (616) 942-9657 Email: indiana@stengerlaw.com THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 24-111958 IMDM 0000 0 0 01000000 10 M100 00 0100 EXHIBIT A THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 24-111958 [III N00 00 00 1 00000008000 110 STATE OF INDIANA ) IN THE LAKE COUNTY SUPERIOR COURT CIV. DIV. 4 )ss: COUNTY OF LAKE ) CAUSE NO. LVNV FUNDING LLC, Plaintiff vs. CHARLES SHELTON, Defendant. AFFIDAVIT OF NON-MILITARY SERVICE Comes now affiant and states: The Defendant is not in military service. The source of my knowledge is the Department of Defense Manpower Data Center report attached hereto as Exhibit 1. I swear or affirm under the penalties of perjury that the foregoing representations are true to the best of my knowledge. Respectfully Submitted, STENGER & STENGER, P.C. Attorneys for Plaintiff \ Dated: 03/12/2024 By: Co Keith #32766-71 CZ Denise M. Hallett #8406-45 CI Zachary M. Kimmel #34667-47 L] David W. Gray #32482-45 XX] David J. Hoff #35481-15, 2618 East Paris Avenue SE Grand Rapids, MI 49546 Phone: 8883057775 Fax: (616) 942-9657 Email: indiana@stengerlaw.com THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 24-111958 EXHIBIT 1 THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 24-111958 Department of Defense Manpower Data Center Rosutts us of Mar 12 2024 0702:43AM SCRA 5.19 eed ey, Ee ts oefg Status Report i Ase fe e Pursuant to Servicemembers Civil Relief Act ort SSN: a Birth Date: a Last Name: SHELTON First Name: CHARLES Middle Name: Status As Of: Mar-12-2024 Certificate ID: 6YGQF4FDMHBMKR4 ‘On Active Duly On Active Duty Status Dato Active Duty Star Date Active Duty End Date ‘Status Service Component NA NA No NA J TESThis Beoease response reflects mace the individ active duly statue based op the Active Duty Status Date - Loft Active Dity Within 367 Days of Active Duty Status Date Active Duty Siart Date Active Duty Eng Date Status Service Comporcnt NA NA No NA Tosponse retlocts where the individuat oR active diay stalus within 367 days precoding the Active Dixy Brats te ‘The Member or His"Her Unit Was Notitied of a Future G: p 10 Active Duty on Active Duty Status Date (Order Notiication Start Date Onder Notification End Date Status Sarvios Component NA NA No NA This response saftects whelhe: the inaividual or his*her unit has received early notilication to *epo"t tor acleve Outy Upen searching the dala banks of the Department of Defense Manpower Data Center. based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army. Navy, Mat e Corps, Air Force, Space Force, NOAA, Public Health, and Coast Guard}. This status includes information on a Servicemember or his’her unit receiving notification of future orders to report for Active Duty. Sam fogedde Sam Yousetzadeh, Director Department of Defense - Manpower Data Genter 4800 Mark Center Drive, Suite 04625 Alexandria, VA 22350 File #: 24-111958 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrolment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 3901 et seq, as amended) (SCRA) {formerly known as the Soldiers’ and Sailors‘ Civil Relief Act of 1940). DMDC has issued hundreds of thousands of “does not possess any information indicating that the individual is currently on active duty” responses, and has experienced only a smail error rate. In the event the individual referenced above. or any family member, friend. or representative asserts in any manner that the individual was on active duty for the active duty status date, or is ctherwise entitled to the protections of the SCRA, you are strangly encouraged to obtain further verification of the person's status by contacting that person's Service. Service contact information can be found on the SCRA website's FAQ page (Q35) via this URL: hitps:/scra.dmdc.osd.mil’scra/filags. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USG App. § 3921(c}. This response reflects the following information: (1} The individual's Active Duty status on the Active Duty Status Date {2} Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3; Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty slatus as reported in this certificate is defined in accordance with 10 USC § 101t(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard. this includes service under a cail to active service authorized by the President or the Secretary of Defense under 32 USC § 502(F) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves {TARs). Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs}. Active Duty stalus also applies to a Uniformed Service member who is an active duty commissioned officer of the U_S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps}. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Tiile 10 and Title 14 active duty records for ail the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1) Many times orders are amended to extend the period of active duty. which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore. some protections of the SCRA may extend to perscns who have received orders to repert for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counset to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. File #: 24-111958 EXHIBIT B THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 24-111958 III I00 (000 000 00 000 000 0000 0 1 24-111958 723971621 LVNV Funding LLC vs. Charles Shelton Defendant(s) Comes now affiant, and states: I Dimeshia Hook, am an employee of Resurgent Capital Services, L.P. master servicer for Plaintiff, and I am authorized to make this affidavit on behalf of Plaintiff. I am of adult age and am fully authorized’ by Plaintiff to make the following representations. I am familiar with the record keeping practices of Plaintiff. The following representations are true according to documents kept in the normal course of Plaintiff's business and/or my knowledge: Plaintiff: MT is the original owner of this debt. OR Mis not the original owner of this debt. The original creditor is Credit One Bank, N.A.. Defendant, Charles Sheltonhas an unpaid balance of $996.88 as of 02/13/2024, on account HOOA RRR That amount is due and owing to Plaintiff. This account was opened on 04/25/2021. The last payment from the Defendant was received on 11/11/2021 in the amount of $31.00. The Account was charged off on 06/09/2022. The type of account is: FM Credit card account (ie. Visa, Mastercard, Department Store, etc.) List the name of the Company/Store issuing credit card: Credit One Bank, N.A. I Account for utilities (ie. telephone, electric, sewer, etc.) i Medical bill account(i . doctor, dentist, hospital, etc.) Fj Account for services (i.e. attorney fees, mechanic fees, etc.) I Judgment issued by court (a copy of the judgment is required to be attached) i Other: Installment loan /12915 This account balance includes: MThe account contains no post-charge-off late fees. MThe account contains no post-charge-off interest. Plaintiff: Mis not seeking attorney's fees. Plaintiff's business records do not show that Defendant is a minor or an incompetent individual. The following exhibits are attached hereto: 5 Copy of the contract or other writing evidencing the original debt. If the claim is based on credit card debt, a charge-off statement and monthly statement recording the most recent purchase transaction, payment, or balance transfer. ™ Bills) of Sale and Assignment and/or Affidavit(s) of Sale for the above referenced account. M Seller data sheet reflecting individual account data extracted and printed from electronic records provided by the seller to Plaintiffin connection with the sale of the account to Plaintiff, The documents attached hereto are true and correct copies of documents provided to Plaintiff by seller. These documents are reproductions of the records on file on behalf of Plaintiff based upon my review, except to the extent that confidential and privileged information and/or personal identifying information is omitted or redacted as required by local rules, and applicable state and federal law. The following is a listing of the names of all prior owners of the debt: Owner Date of Sale Defendant's Name Last 4 of the Account Number Credit One Bank, N.A. 6/30/2022 Charles Shelton 4888 MHC Receivables, LLC and FNBM, LLC 7/19/2022 Sherman Originator Ill LLC 7/19/2022 Sherman Originator LLC. 79/2022 I swear or affirm under the penalties of perjury that the foregoing representations are true. Date: 02/13/2024 Signature of A ffiant: 712915 CREDIT ONE BANK CREDIT CARD STATEMENT “Account Number| 4 May 09,,2022 to June 08, 2022 SUMMARY OF ACCOUNT ACTIVITY PAYMENT INFORMATION Previous Balance $940.27 New Balance $996.88 Payments $0.00 Past Due Amount $278.00 Other Credits $0.00 ‘Amount Due This Period $757.88 Purchases $0.00 Minimum Payment Due $996.88 Balance Transfers $0.00 Payment Due Date o7i0a22 Cash Advances $0.00 Late Paymont Warning: Fees Charged $39.00 we do not receive your minimum payment by the date licted above, Interest Chargod $17.61 you may have to pay a late fe upto $39. New Balance $996.88 Minimum Payment Warning: Crest Limit $600.00 you make only tho imum payment each period, you wil pay more Available Credit $0.00 {in fears and it wi? take you longsr to pay off your balance. Statement Closing Date 6/0822 For example: Days in Biling Cycle ityou make no You will pay off he ‘And you wil additional charges balance shown on ‘end up paying ‘QUESTIONS? Using this card and the statement in an estimated Call Customer Service or Report ach month you pay. about. {otal of. a Lost or Stolen Credit Card 1-877-825-9242 Only the minimum Outside the U.S. Call 1-702-405-2042 payment 1 months $997.00 Please send billing inquiries and correspondenceto: P.O. Box 98873, Las Vegas, NV 89193-8873 Ifyou would Ike a location Tor credit counseling services, cal 1-866-515-5720. Or you may visit wow justice gov/ustist crodit-counsoling-agencies-approved-pursuant-tY-usc-11 ‘TRANSACTIONS Reference Number ‘Trans Date Post Date Description of Transaction or Credit Amount Fees 06/08 06/08 LATE FEE 39.00 TOTAL FEES FOR THIS PERIOD 39.00 Interest Charged 06/08 06/08 Interest Charge on Purchases 17.61 06/08 06/08 {Interest Charge on Cash Advances 0.00 TOTAL INTEREST FOR THIS PERIOD 17.61 2022 Totals Year-to-Date Total fees charged in 2022 $234.00 Total interest charged in 2022 $91.59 ‘Your account is currently closed. INTEREST CHARGE CALCULATION Your Annual Percentage Rate (APR) is the annual interest rate on your account, Balance Subject to Type of Balanco Annual Percentage Rate (APR) Interest Rate Interest Charge Purchases 24,74%v) $853.89 $17.61 Cash Advances 24.74%v) $0.00 $0.00 (v) + Variable Rate . ses pH oor 78 2206080 EX PAGE!11 20 S7z7 620 MI98 O1GRSIES Please urn this ponton wih you payer, ang we your account rumberon your check, made payable to CREDIT ONE BANK, Cryinrie PAY YOUR BILL ONLINE at CreditOneBank.com Account Number: aS 4825 New Balance: $996.88 Minimum Payment Due: $996.88 Fer ares, telephone and emai changes, Payment Due Date: ormosse2 Please compiote the reverse (Or, update your contact information online ‘worw CreditOneBank com, AMOUNT ENCLOSED: |s Usladisdele saleolloUagbeleseasloatleeH atest oessaee CREDIT ONE BANK CHARLES SHELTON PO BOX 60500 1402 JEFFERSON ST CITY OF INDUSTRY CA 91716-0500 GARY IN 46407-1241 ANU bal HH ALAM Moss bel i elle 0000000 0099688 00996¢0 NNN: Poowention CREDIT ONE BANK CREDIT CARD STATEMENT ‘Account Number 4888 November 03, 2021 to December 08, 2021 7 ‘SUMMARY OF ACCOUNT ACTIVITY PAYMENT INFORMATION Previous Balance $650.69 New Balance $671.29 Payments $31.00 Past Due Amount $33.00 Other Credits $0.00 Amount Due This Period $73.00 é S $0.00 Minimum Payment Due $106.00 Balance Transfers $0.00 Payment Due Date 10422 Cash Advances $0.00 ‘ate Payment Warning. Fees Charged $39.00 {Ewe do not rocolvo your minimum payment by the dato listed above, interest Charged $12.40 You may nave to pay a late fee up to $39, ‘New Balance $671.29 Minimum Payment Warni Credit Limit $600.00 you mal ‘only the minimum payment each period. you will pay more Available Credit $0.00 In interest and it wil take you longer to pay of! your balance. ‘Statement Closing Date 1208/21 For example: Days in Billing Cycle you make no You will pay off ne “And you wit additional charges balance shown on fend up paying ‘QUESTIONS? Using this card and the statement in an estimated Call Customer Service or Report ‘each month you pay. about, total ol. a Lost or Stolen Credit Card 1.877-825-3242 Only the minimum Outside the U.S. Call 4-702-405-2042 payment 2yoas $870.00 Please send billing inquiries and correspondence to: P.O, Box 98873, Las Vegas, NV 89199-8873 Ifyou would ike a focation lor ered counseling services. ca 1-866-515-5720. Or you may visit wwaw justice govlustlist- ctgcit-counseling-agencies-approved-pursuant-fY-usc-1 11 TRANSACTIONS Rolerence Number Trane Osto Post Dato Dascription of Transactionor Ores Amount 74071999 VOOXTMIIY TT Wit PAYMENT - DEBITCARD LAS VEGAS NV 31.00 Fees 12/08 12/08 LATE FEE 39.00 TOTAL FEES FOR THIS PERIOD 39.00 Interest Charged 12108 12/08 Interest Charge on Purchases 12.40 12/08 12/08 Interest Charge on Cash Advances 0.00 TOTAL INTEREST FOR THIS PERIOD 12.40 2021 Totals Year-to-Date Total fees charged in 2021 $230.24 Total interest charged in 2021 $86.83 Your account is currently closed, INTEREST CHARGE CALCULATION Your Annual Percentage Rate (APR) is the annual interest rate on your account Balance Subject to, ‘Typeof Balance Annual Percentage Rate (APR) Interest Rate Interest Charge Purchases 29.99%(v) $620.34 $12.40 Cash Advances 23.99%v) $0.00 $0.00 (¥) = Variable Rate 5385 JBH 001 78 211208 0 EXPAGE 1 of 1 20 $727 9620 A203 O1GRS3BS Pe 30 reurs ts porvon wth your payment, an wree your Account numer On yOu! cheek, made payaRHe 10 CREDIT ONE BANK, 7 a PAY YOUR BILL ONLINE at CreditOneBank.com >. Credi¢ci Account Number: New Balance: Minimum Payment Due: $106.00 a $671.29 4282 For address. telephone and email changes. Payment Due Date: ovoaa2 please complete the reverse side. (Or, update your contac information onling ‘at wur.CredltOneBank.com. AMOUNT ENCLOSED: b . | shih Hela Ll Hoots Me CREDIT ONE BANK CHARLES SHELTON PO BOX 60500 1402 JEFFERSON ST CITY OF INDUSTRY CA 91716-0500 sARY IN 46407-1241 [MDL ssadatell eA Loves Exhibit Documentation - 0003100 0067129 0006700 SMES 888 5 7 8Z 8 a0 a9 oO 999992 8333 38 aad ao . O: Q Zz b 99 99000 O90 Q90 3 ® am ma mn $3 5 5 (| cr or aaq ae ao 2ooooD DD DA DA 22 Sobow 88 = = 88 22 eo gg eo eo ag Nv of SS 22 22 22 Oo NN oO a6 oO S NW a == =a == Ba aa aa aq QQ ao 2D 82 35 as as Ba aa DW Dw 22 aa gag go ge aa 22 2S ao as ss wD aa Bw 32 2 ga aa 22 £2 aa as a3 DW DD gs 22 ss BD BWA Qo SSB 28285585 B388 S22 BRD Exhibit Documentation - ee ee Ssssesceqeacc DD. BQDA a@>o aa aa 822832, BD BZ &5 a BD aa e QQ aa | sa BD a0 ag aa — ww Ba ao ge aa Bo as 28 sane Ba ao ae & a2 ee 33 QQ asa 2885 Baa B 855 gage 622 B33 aD a2 gagg 8Qgag Sffceeless saaaaaee ae Exhibit Documentation - eee ey ss ao ee a 2 a a2 aS gs 22 ac 3 3 a a Q 3 g BES 823283 BEEEZES 2 2 2 222 Exhibit Documentation - s339 sssasTt SSSRSRSSosF BaD aaq oo 2 2 2 —L. BD BBD S 3 agg QQ SBABBBABAOD BB aa aa a3 b8 go ga 88 8&2 33 aa QQ 222 B22 aa aD aa Qa S22 aa 228289288 BA DD aa ao ao ao B88 ao aa aa a2 =a wa Sa Da aa ga Be aa QQ S€SE8828838385 228283885 233 Exhibit Documentation - == =< Sassssessq 33 Ba = BD aa £8 nD =< aa a. &2 sc wD ae 2&2 =< Ba a ga S353 22 SS =o a3 BwDD aaa gQ 8&2 gs 22 BAD aa ag aa ag 8&8 BaD aa 222 8&2 & 2 as 228 == DAD a Baa aag Qo S833 52825 2S ee Exhibit Documentation - SSeS a3 =s SoS eee gag QQ 832 2 388 S38888 22 = 2 =a ot DA aw ag ag ag aa S853 23528282 Ba SS8S82S8825885 Exhibit Documentation - SSSSS SSS TS OSS SSS SSS of aD aOaq ag ooo 83 & sce 83 Baa aaa Qg2@QaQ 2S 22 22 22s ss55 =< Sa DDD BDA ag ao gagQaQ QQag a2 £238 £222 23 ——— 2ga 3233 aagaq gagaaQq ga 888 aoaa aa38 8S B22 Seas 2s oma son Da aaa wD BAA ag 223238 gaaggae g2ae2aq ga QQ a3 s3 03 20 QQ So S222 2228585 SBSSABRR2 2222 Exhibit Documentation - eee ssescac Sass 3 oD as a BO aa aa aa &s g8 Ba Qo SS82228520 a2 a2 ee B22 Exhibit Documentation - Sseosocce ee ssassssc 238232822 “§ 22 £2 ee 2222208 222 Exhibit Documentation - BILL OF SALE AND ASSIGNMENT-OF ACCOUNTS EROM CREDIT ONE BANK, N.A. TO MHG RECEIVABLES, LLC As of June 30, 2022, for good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, Credit One Bank, N.A. (“Assignot” ) has transferred, has sold, has assigned, has conveyed, has granted and has otherwis e delivered to MHC Receivables, LLC (“Assignee”), all of Assignor’s right, to (i) the charged-off title and interest in and credit card accounts identified on an ai ccount level basis CreditOne_Fresh_LegalRecall_072022 (the “Computer File”), a copy of which in the data file named is attached hereto and incorporated herein by. reference as “Exhibit A”; and, (ii ) certain related account level media or electronic coy pies thereof (including, but not limited to applications, statements, terms and condition), and (fii) all claims or rights arising out of or relating to cach account refereitced on the Computer File (collectively h ereinafter, the “Account to, all claims and rights afforded each Account by virtue of that Account’s correspo s”) including, but not limited nding terms and conditions. The Accounts transferred under the terms of this Bi Il of Sale and Assignme transfered to Assignee immediately following ch: jarge off for each applicable nt of Accounts were each Account, as shown in the Computer File. With respect to information for the Accounts, Assi; ignor represents and warrants to Assignee that the business records conveyed to Assignee relating to: (i) the Account s issued by Assignor; and (ii) the Accounts by Assignor (collectively, the “Business Records’ "), are kept by Assignor in the regularsale and assignment of 11 is in the regular course of business of Assignor course of its business. for a in employee or an authorized reypresentative with personal knowledge of the act, event, condition, or opinion (collectively “Event”) to be recorded, to make the appropriate memorandum or recording of the Event at or reasonably near the ti me of the Event. Furthermore, Assignor represents and warrants to Assignee that the Business Records are materially complete and accurate, and thoroughly embody the information in Assignor’s custody and control for the Account: 's from their creation until the time of transfer to Assignee, These representations and warranties are intended to at ugment any other representations and warranties the parties may have in place and not supplant any other existing wa rranties and representations. This Bill of Sale and Assignment of Accounts shall serv ¢ as evidence of ownership for the conveyed hereby and shall serve as an acknowled, Accounts lgment, as ratification, and as evidence of the intent of the Parties transfer the Accounts. to CREDIT ONE BANK, N.A. Passe Michael Wiese Vice President —= Set — see -———. Exhibit Documentation - EXHIBIT A ACCOUNT SCHEDULE ‘The Accounts that are specifically identified in the electronic fil le named CreditOne_Fresh_ with such electronic file incorporated herein by reference. LegalRecall_072022 a = Exhibit Documentation - BILL OF SALE AND ASSIGNMENT OF RECEIVABLES EROM CREDIT ONE BANK, N.A. TO MHC RECEIVABLES, LLC As of June 30,.2022, for good and valuable consideration, acknowledged, Credit One Bank, N.A. (“Assignor") fias the recei pt and sufficiency of which is hereby transferred, has sold, hi las assigned, has conveyed, has granted and has otherwise delivere d to MHC Receivables, LLC (“Assignee”); all of Assignor’s right, title to (i) the receivables and interest in and associated with ea ich and every account referenced in CreditOne_Fresh_LegalRecall_072022 (the “Computer File"), a copy the data file named of which is attached hereto and incorporated herein by reference as “Exhibit A”. + and, (ii) all claims or rights arising out of or relating to cach of those Receivables (hereinafter, the “Receivables"). ‘The Receivables transferred under the terms of this Bill of Sale transferred to Assignee prior to the charge off of t!the associate and Assignment of Receivables were each d accounts, as shown in the Computer File. This Bill of Sale and Assignment of Receivables evidences th e intent between the parties for the transfer of the Receivables, acts as an acknowledgement of those transfers, and, to the extent necessary, ratification of the transfers, With respect to information for the Recei ivables, Assigno r represents and warrants to Assignee that the business records conveyed to Assignee relating to tl he Receivables (the “Business Records”), are kept by Assigno r in the regular course of its business. It is in the regul. lar course of busines s of Assignor for an employee or an authorized representative with personal knowledge of the act, event, condition, y or opinion (collectively “Event”) to be re