Preview
45D10-2403-CC-002295 Filed: 3/14/2024 6:39 AM
Clerk
Lake Superior Court, Civil Division 6 Lake County, Indiana
STATE OF INDIANA ) LAKE CIRCUIT COURT
) SS:
COUNTY OF LAKE ) Case Number:
)
MIDLAND CREDIT MANAGEMENT, INC. )
Plaintiff )
)
v. )
)
TEDERIAN BROWN )
Defendant )
COMPLAINT
Plaintiff, MIDLAND CREDIT MANAGEMENT, INC., by counsel, sues Defendant, TEDERIAN
BROWN , under Account Stated and in support thereof states:
1. Plaintiff is authorized to file this Complaint in this Court. Plaintiff owns portfolios of
consumer receivables, which it attempts to collect. Plaintiff strives to treat its consumers, such as
Defendant, with respect, compassion and integrity, hoping to provide mutually-beneficial opportunities
for consumers to repay their debts and attain financial recovery.
2. Defendant is subject to this Court's jurisdiction.
3. Defendant established an account with CELTIC BANK, under redacted account number
XXXXXXXXXXXX-7112.
4. Defendant was provided statements delineating Defendants use of the account and stating
the current balance due.
5. Defendant defaulted on the account.
6. A statement of account balance was sent to Defendant and not paid.
7. Plaintiff has acquired all right, title and interest to Defendant's account, and has
attempted to contact Defendant through several means in an effort to resolve the account with Defendant,
but has been unsuccessful. Defendant has not repaid the balance owed on the account. Plaintiff remains
willing to discuss various options to resolve the outstanding obligation, although the options may be
different than they were prior to the initiation of litigation.
8. Defendant owes Plaintiff $1,027.16.
9. In support of the allegations, Plaintiff incorporates herein by reference the attached
Exhibits.
GL_0100G File No.: 24-29562 SCP
The undersigned certifies that this and any attached document complies with the requirements of
Trial Rule 5(G) with regard to information excluded from the public record under Administrative
Rule 9(G).
WHEREFORE, Plaintiff requests judgment against the Defendant for $1,027.16 and costs of the
action and post judgment interest at the statutory rate.
By:
JOHN F. GILLESPIE Bar No. 31983-49
JASON E. TAYLOR Bar No. 30160-22
Attorneys for Plaintiff
P.O. BOX 70069
LOUISVILLE, KY 40270-0069
Phone: (866) 300-8750
Fax: (855) 488-1523
E mail: IL_IN@mcmcg.com
PLEASE UNDERSTAND THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
THIS IS AN ATTEMPT TO COLLECT A DEBT.
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
GL_0100G File No.: 24-29562 SCP
AFFIDAVIT OF DEBT
Comes now afiiant, and states:
I, Casey Cornwall, am of adult age and am an employee of Midland Credit Managemem, Inc. ("Plaintifi" or
"MCM"), and am fully authorized by Plaintiff" to make the following representations. l am familiar with the
recordkeeping practices of Plaintiff. The following representations are true according to documents kept in the
normal course of business and/or my personal knowledge.
I have access to and have reviewed the electronic records pertaining to the account maintained by MCM and
am authorized to make this afiidavit on MCM's behalf. The electronic records reviewed consist of (i) data and
records acquired from the seller or assignor when MCM purchased or was assigned the account, which were
incorporated into MCM's business records upon purchase or assignment, and (ii) data and records generated by
MCM in connection with servicing the account since the date the account was purchased by or was assiyied to
MCM. In addition, I reviewed the documents that are attached to this affidavit.
l) The Plaintifi' has obtained this debt from Genesis FS Card Services, Inc. and the original creditor of
this debt was CELTIC BANK. Evidence of the debt, as required in Rule 9.2(A) (2), is attached as
one or more Exhibits to this Afi'ldavit.
2) TEDERIAN BROWN, Defendant, had an account balance of $1,027.16 as of 2024-02.] l, which is
owed to Plaintiff on account W71 12 (hereinafier "the Account").
3) MCM's records show that the Account was opened on 2021-03-30 and the last payment posted to
the Account on 2022-07-12 in the amount of $62.00. MCM's records show that the Defendant
defaulted on the Account on or afier 202206-20 and the Account was charged ofi' on 2022-12-23.
4) The type of account is:
E Credit card account (e.g. Visa, MasterCard, Deparunent Store).
Company issuing credit card: CELTIC BANK
D Other:
5) The account balance includes:
X MCM's records show that there are no late fees afler 202301-30.
X Interest at a rate of 0% beginning on 2022-12-23.
6) The Plaintifi' is not seeking attorney's fees.
7) MCM's records do not show that Defendant is a minor or mentally incapacitated person.
8) If the Defendant is an individual, Plaintiff states and declares that pursuant to the attachment,
Defendant is not in active duty status of the military.
("Active military service" includes fulltime duty in the military (including the National Guard and
reserves) and, for members of the National Guard, service under a call to active service authorized
by the President or Secretary of Defense. For further information, see the definition of "military
service" in the Servicemernbers Civil Relief Act, as amended, 50 USCA Appx. §521.)
AFFIDAVIT OF CASEY CORNWELL -1
llllllllllllllllllllllllllllllllll M 11 Ifllfllflllllfllllllllllllllllll
320434227 AFFRECA'ITACH 24-29562
9) As set forthin the records attached hereto, the complete chain of title including CELTIC BANK, the
original creditor, and all post-charge-ofi' purchasers/assimees of the debt are as follows:
l. CELTIC BANK 2022-12-23
2. Genesis FS Card Services,
Inc. 2023-01-30
3. Midland Credit Management, Inc.
10) Attached hereto are the following records regarding the Account:
a) Bill(s) of Sale, Assimment and/or Afiidavit(s) of Sale
b) Seller data sheet reflecting the individual Account information from the electronic
records provided by the seller or assignor pursuant to the Bil|(s) of Sale, Assignment")
and/or Afidavit(s) of Sale in connection with the sale or assignment of the Account to
Plaintiff
c) Records regarding the Account and/or payments received:
i) Contract, application, or other document evidencing the consumer's agreement to the
debt; and/or
ii) Statement(s) and/or Account records reflecting: l) the charge-ofl' balance; and 2) the
last purchase transaction, payment, or balance transfer.
l l) The documents attached hereto are true and correct copies of the originals, being a reproduction
of Plaintifi's records, 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.
I swear or affirm under the penalties of perjury that the foregoing representations are true.
"MIMI
Date
asey Cornw
/M
CA137
AFFIDAVIT OF CASEY CORNWELL -
2
Illlllllllllllllllllfllllll Illllllllllllllllll
320434227 AFFRECA'ITACH llllllglllllllMllllllll
-29562
BILL 0F SALE AND ASSIGNMENT 0F ACCOUNTS
FROM CELTIC BANK TO GENESIS F S CARD SERVICES, INC.
Pursuant to Section 4.3 of that certain Receivables Sale Agreement (the "RSA"), effective as of
September l, 2021, by and between Celn'c Bank Corporation ("Seller") and Genesis FS Card
Services, lnc. ("Buyer"), as of the applicable account charge off date, for good and valuable
consideration, the receipt and sufliciency of which is hereby acknowledged, Seller transferred,
assigned and set-over to Buyer all right, title and interest of Seller in and to those certain charged-
off accounts specified in Exhibit A, which were originated by Seller.
Dated: Mar 15, 2023 CELTIC BANK
By: @T .'u'.
Name: Cory Tauiliili
Title: Accountant
EXHIBIT A
ACCOUNT SCHEDULE
Those accounts pursuant to the RSA and this BILL OF SALE AND ASSIGNMENT 0F
ACCOUNTS FROM CELTIC BANK TO GENESIS FS CARD SERVICES, INC. that are
specifically identified in the electronic file named 'Account Data (CO-1033) Midland GPCC
- - -
F low 5' with such electronic file incorporated herein by reference.
Exhibit 2 to
Receivables Sale Agreement dated October 12, 2022
BILL OF SALE
Closing Date: January 30, 2023
Genesis FS Card Services, Inc., an Oregon corporation ("Seller"), in consideration of the
Purchase Price (as defined in the Agreement referred to below) and other valuable consideration,
the receipt of which is hereby acknowledged, hereby s'ells, assigns and transfers all right, title and
interest in and to (i) the Accounts identified in the Sale File entitled 'Account Data (CO-1033) -
Midland GPCC Flow 5' (which may be in electronic fonn) to Midland Credit Management,
- -
Inc., a Kansas Corporation ("Buyer"), without recourse or representation except as expressly
provided herein or pursuant to the terms, and subject to the conditions, set forth in the Agreement
(the "Accounts), and (ii) all proceeds of such Accounts.
The information contained in the Sale File (collectively, "Account Information") is true
and complete in all material respects as of the Closing Date. Further, the information contained in
the Account Information (a) constitutes business records regarding the Accounts maintained by
the Seller and (b) accurately reflects in all material respects the information about the Accounts in
Seller's possession. The Account Information, whether acquired or created, has been kept in the
regular course of business by Seller and was made or compiled at or near the time of the event and
recorded by (or fi'om information transmitted by) a person (i) with knowledge of the data entered
into and maintained in business records maintained by Seller, or (ii) who caused the data to be
entered into and maintained in business records maintained by the Seller. All capitalized terms
used, but not defined, in this Bill of Sale shall have the meanings assigned to such term in the
Ageement.
This Bill of Sale is delivered pursuant to that certain Receivables Sale Agreement, dated
as of October 12, 2022, by and between Seller and Buyer (as amended, restated, supplemented, or
otherwise modified from time to time, the "Agreement"). All capitalized terms used but not defined
in this Bill of Sale shall have the meanings assigned to such terms in the Ageement.
MIDLAND CREDIT MANAGEMENT, INC. GENESIS FS CARD SERVICES, INC.
By
Name:
xflamflo
Danielle Wohlfehrt
Syn.
Name:
fleflb
GEEGG ATKINSON", .,
Title: MVP u ine D v Tide252CEQ«:;:é'ng_ ,3,
Receivables Sale Agreement dated October 12, 2022
AFFIDAVIT OF SALE OF ACCOUNT BY DEBT SELLER
State of Ohio, County of Summit.
M. Graham Flynn being duly sworn, deposes and says:
I am over 18 and not a party to this action. I am the Director of Debt Salas [title] of Genesis
Financial Solutions, Inc, parent company of Genesis FS Card Services ("Debt Seller"). In that
position I am the custodian of Debt Seller's books and records and am aware of the procedures
used for the sale and assignment of electronically stored business records.
On Q! / 20 l 2033 Debt Seller sold a pool of charged-off accounts (the "Accounts")
by a Loan Sale Agreement and a Bill of Sale to Midland Credit Management, Inc. ("Buyer").
All records were kept in the regular course of business.
I am not aware of any errors in these Accounts. The above statements are true to the best of my
knowledge.
Dated: 3 1H IZDZ3
M.Gr amFlynn
S m to before me 3 I [4/
/ / Zfl Z3 \t-';§&W"II,,
ANGELA WISE
'
.
.
Notary Public. State of Ohio
.
My Commission Expires
(NotaFy Stamp) \t 12/08/2025
CERTIFICATE OF CONFORMITY
I Benjamin Cornston, an attorney duly licensed to practice law in the State of Ohio, affirm under
penalty of perjury and certify that I witnessed the signature of M. Graham Flynn as applied to the
Affidavit annexed to this Certificate, which was signed and dated on / l 3 / .
The manner in which same was signed was, and is, in accordance with, and conforms to, the
%
laws for taking oaths and acknowledgments, in the State of Ohio.
/
Dated: 3 /H/ 9~3
Field Field Data
Account Number 71 12
Seller Account ID
First Name
TEDERIAN
Last Name BROWN
SSN -I -3382
Date of Birth
Address 1
I I - AVE
5401 W 7TH
City GARY
State IN
Zip 46406
Open Date 03/30/2021
Last Purchase Date 04/12/2022
Last Purchase Amount $4.00
Last Payment Date 07/12/2022
Last Payment Amount $62.00
Sale Amount $1,027.16
Charge Off Date 12/23/2022
Charge off Balance $1,027.16
Post Charge Off Interest $0.00
Post Charge off Fee $0.00
Post Charge off Payments $0.00
Post Charge off Payments and Credits $0.00
Post Charge off Credits $0.00
Affinity INDIGO
Alternate Account #1 -7112
Account information provided by Genesis FS Card Services. Inc. pursuant to the Bill of Sale/Assignment of Accounts
transferred on or about 01/30/2023 in connection with the sale of accounts from Genesis FS Card Services. Inc. to
Midland Credit Management, Inc.
Account Data (CO-1033) Midland GPCC Flow 5
- - -
indigo'
{I
iE
TEDERIAN BROWN Account number ending in 7112
IACCOUN'I' SUMMARY IPAYMENT INFORMATION
Credit Limit $500.00 New Balance $1,027.16
Available Credit $0.00 Minimum Payment Due $449.00
Past Due Amount $377.00 Payment Due Date January 21. 2023
Overlimit Amount 552736 Late Payment Warning: II we do not receive your minimum
Statement Closing Date Deceniber 22- 2°22 payment by the date listed above. you may have to pay a late lee
Days In Billing Cycle 30 of "9'0 $40.00.
83'3"" 5963"" Minimum Payment Warning: Ir you make onty the mirinum
-
Payments Credits
8. $0.00 . . . .
# Purchases 3. Other Charges $000 payment each penod. you wIII pay more In Interest and It will take
'+ FEES CHARGED $40.00 you onger r 0 pay oft your bal ance. Forexan'IpIe.
I
_
INTEREST CHARGED $24.00 "you make no
= New Balance $1,027.16 additional charges Youwiflpayoflltne AndyouwilleMup
balance shown on this paying an estimated
using "is card and statement in about.. Mal of...
QUESTIONS? Cal 1-800-353-5920 eachmonlhyoupay
Please mail billing lnoulrles to: Onty the rnininum
Genesis FS Card Services payrnem
20mm 31 .2121!)
PO. Box 4499
ltyou would like information about credit oounseing services, call
Beaverton. OR 97076-4499 1-800-353-5920.
ww.indigocard.oom
Notice: SEE REVERSE SIDE FOR MORE IMPORTANT INFORMATION
1
TRANSACTION
Tran Post
Date Date Reference Number Transaction Detonation Amount
FEES '
. _ .
12/22 1222 LATE FEE . '40.00
TOTAL FEES FOR ms PERIOD ,.'
j '
, INTEREST CHARGED -
'
.
c
12122 1212 Interest Charge on Purchases 24.00
12/22 12/22 Interest Charge on Cash Advances 0.00
'
TOTAL INTEREST FOR THIS PERIOD 24.00
Pleasedetach bottomponionandsubnitwithpaymeruusingendosedenvelope
I
PAYMENT IN FORMATION
Geneeio F5 Card Services
. . . PO BOX "77
.
Account number ending In
.
7112
I n d '90 Bomrton on 97076-4477 Payment Due Date
New Balance
January 21, 2023
$1,027.16
Minimum Paymem Due $449.00
Make Check Amount Enclosed:
Payable to: [3 _|
TEDERIAN BROWN
5601 H 7TH AVE GENESIS F5 CARD SERVICES
GARY IN 46606-1434
PO BOX 23039
Columbus GA 31902-3039
53030500300355? 000091000 001027150
Your Account is issued by Celtic Bank and sauteed by PAYING lNTEltEST
Genesis rs Card Services. Inc. Your due date is at least 25 days alter the close ot each Billing cycle. We will not charge
PAYMENTS you any interest on Purchases it you pay your entire balance by the due date each
month. We will begin charging interest on Cash Advances on the transaction this
Payments should be mailed with the payment coupon and in the envelope provided to
the Genesis FS Card Services payment address indicated on the payment coupon. Any OTNElt DISCLOSURES
payment received in that torm and at that address on or belore 5:00 PM. Eastern Time on For AR. HI. IA. hf Residents: This communication is from a debt collector. "is
is an
a normal banking day will be credited to your Account that day. It your payment is received attempt to collect debt and any inlormatlon obtained will be used tor that purpose.
in that torm and at that address after 5:00 PM. Eastern Time on a normal banking day,
What To Do it You Think You Find A Mistake On Your Statement
or anytime on a nonbanking day. we will credit it to your Account the next banking day.
it you mink there is an error on your statement. write to us at Genesis F5 Card Services.
Payments can also be made online by visiting indigocardcom. When you provide a check
P.O. Box 4499. Beeverton. Oregon 970764499.
as payment. you authorize us either to use the inlormation lrorn your check to make a
in your letter. give us the lollowing inlorrnation:
one-time electronic iund trarisler lrorn your awount or to process the payrnent as a check
. Acooant lnlomtation: Your name and Account number.
transaction. When we use intomiah'on lrorn you check to make an electronic lund
v Dollar Amount The dollar amount oi the
suspected error.
transler, lunds may be withdrawn from your account as soon as the some daywe receive 0
Description oi Problem: It you think there is an error on your bil. describe what
your payment and you will not receive your check back lrorn your financial institution.
Payments received at other than the remittance address on the lace at this statement may
youbelieveiswrcngandwhyyoubelieveit 'sa mistake.
You must contact us:
besubjecttoadelayincreditingoiuptoSdaysatterthedateolreceipt. - Within 60
days alter the error appeared on your shterrtent.
ANNUAL FE (it applicable) You must notily us at any potential errors in writing. You may all us, but it you do we
it you wish to close yourAcoount to turther Purchases and Cash Advances in order are not required to investigateany potent'al errors and you my have to paythe amount
to avoid paying the renewal Annual Fee. you must deliver written notice at closure (instruc- it question.
tions below) to us within thirty (30) days irorn the mailing date at the statement or letter Whileweinvesligalewhetherornotthere hasheenanerronthelollowingaretruec
containing the renewal Annual Fee notice. (This does not apply to the initial Annual Fee . We cannot try to colect the amount in question. or report you as delinquent on
charged in connection with the opening at your Amount.) that amount.
. Thecnarge in question mayremainonyotrstatemcnt.andwe mayccminueto
MONTHLY FEE (if applicable)
it you wish to close your Account to lurthar Purchases and Cash Advances in order to charge you interest on that amount But. it we determine that we made a mistake.
avoiii paying the Monlhty Fee. you must deliver written notice at closure (instnictions you will not inve to pay the amount in question or any interest or other lees
relaud to that amount.
below)tous priorto lheendola Billingcycle. Othenuise. yourAcoountwll bechargeda - While you do not have to pay the amount it direction. you are responsible lor the
Monthty Fee.
remainder at your bahnce.
NOTICE OF ACCOtMT CLOSIINE - We can
apply any unpaid amount against your credit Irnit.
Written notice oi closure must be sent to Genesis F5 Card Services. PO Box 4477,
Your Rights It You Are Dissatisfied Witli Your Credit Card Purchases
Beaverton. OR 97076. Upon receipt. we will close your Account and the renewal Annual
Fee and/or Monthty Fee (as applicable) will not be charged to your Account. Closing your it you are dissatislied with the goods or services that you have purchased with your
Account will not cancel your obligations to pay amounts outstanding on your Account, and credit card. and you love tried in good laith to correct the problern with the merchant.
you will be required to pay your outstanding bahnce with interest in accordance with the you may have the right not to pay the remaining amount due on the purchase. To use
terms oi your Grdholder Agreement. this right, all at the lollowing must be true:
1. The purchase must have been made in your home state or within 100 miles
CREDIT BUREAU WONG at your current mailing address. and the purctnse price must have been more
We may report intormation about your Account to credit bureaus. late payments, missed than 850. (Note: Neither oi these is necessary it your purchase was based on
payments. or other delaults on your Account may be rellected in your credit report. an advertisement we mailed to you, or it we own the comperry that sold you the
BALANCE SUBJECT To INTEREST RATE goods or services.)
We use the Average Daily Balance (including new purchases) method to calctriate the 2. You must have used your credit card for the purchase. Purchases made with cash
balance on which we charge interest. To lind out more about the balance computation advances trorn an ATM or with a check that accesses your credit card amount do
method and how interest charges were detannined. call us at the toll-tree telephone not quality.
number on the lront ol the lirst page oi your billing statement 3. You must not yet have lully paid lor the purchase
It all of the criteria above are met and you are still dissatisfied with the purchase. contact
MINIMUM iNTENEST CHANGE us in writing at: Genesis FS Card Services, PO. Box 4499. Beaverlon. Oregon. 97076.
ltyouarachargedirmresuhechargewiibenolesthan SOSO While we investigate. the same rules apply to the disputed amount as discussed above
Alter we linish our investigation, we will tell you our decision. At that point. it we thitlr
you owe an amount and you do not pay, we may report you as delinquent.
OIAII202 "[04002]
-
Detach here v and return below portion with your remittance. After detaching. retain upper portion for your future relerence.
ADDRESS / PHONE NUMBER CHANGE FORM
By providing I cellular phone number or a number that is later convened to a cellular phone number, you are capmsly
consenting that we (and any other owners or servicers of your Account) my contact you via phone or text message.
"'"
.theusool." and cake and messages usirig an Mounted dialing system.
ADDRESS
CITY STATE ZIP CODE
( )
( )
HOME PHONE BUSINESS PHONE
EMAIL ADDRESS
TEDERIAN BROWN Account number ending in 7112
A 1%?
0&7 2;"
rain
5) "311T
Toulfeuchugedmm 5474 (I)
Toulmmtchmgodhm $20104
"
EIMPORTANT ACCOUNT INFORMATION
YOUR ACCOUNT IS PAST DUE; THE PAST DUE AMOUNT IS INCLUDED IN THE MINIMUM PAYMENT.
PLEASE REMIT IMMEDIATELY.
YOUR ACCOUNT IS CURRENTLY OVER YOUR CREDIT LIMIT.
[INTEREST CHARGE CALCULATION
Your AnnuaI Percentage Rate (APR) is the annual interest rate'on your accwnt
Annual Percentage Balance Subject to
Two of Baht-u Rate (APR) Interest Rate Interest Charon
Purchases , >
29.90% 8963.16 $24.00
Cash Advances 29.90% ,
$0.00 $0.00
(v) = variable
indigo'
TEDEFIIAN BROWN Account number ending in 7112
[ACCOUNT SUMMARY. [PAYMENT INFORMATION
-
] I
Credit Limit $500.00 New Balance $0.00
Available Credit $0.00 Minimum Payment Due $0.00
Past Due Amount $0.00 Payment Due Date January 21. 2023
Overlimit Amunt 50-00 Late Payment Warning: If we do not receive your minimum
Statement CIOSIDQ Date December 23- 2°22 payment by the date listed above, you my have to pay a late fee
Days in Billing Cycle 30 at up to 540.00.
P'ev'ws Balance . 51'027'16
Minimum Paynient Warning: It you make only the minimm
-
Payments 8. Credits $1,027.16 . . . .
+ Purchases 8. Other Charges $0.00 payment each period, you Will pay more an interest and rt will take
+ FEES CHARGED $0.00 V°° "9° r to pay 0" V°° ' balance '
I F "me' l
_
+ INTEREST CHARGED $0.00 If you wake no
= New Balame $0.00 additional charges
You will pay oflttte MywMIendup
balance shown on this paying an estimated
using this card and statement in about... total of...
QUESTIONS? Cal 1-800-353-5920 eachmonthyoupay
Please mail billing Inquiries to: Ontythemininum
Genesis FS Card Services
14mm 51 .027 .00
paymnt
PO. Box 4499 If you would like information about credit counseling services. cal
Beaverton. OR 97076-4499 1-3003535920.
wwwjndigocard.cotn
Nofioe: SEE REVERSE SIDE FOR MORE IMPORTANT INFORMATION
ITRANSACTIONS
Tran Post
Date Date Reference Number Transaction Description Amount
12/23 12!23 F852100PM00999990 CHARGE OFF ACCOUNT-PRINCIPALS 477.55-
12I23 12/23 F852100PM00999990 CHARGE OFF ACCOUNT 'FINANCE CHARGES' 549.61-
TOTAL FEES FOR THIS PERIOD 0.00
. INTEREST CHARGED
. 1223 Interest Charge on Purchases 0.00
12/2?
12/23 12/23 Interest Charge on Cash Advances 0.00
TOTAL INTEREST FOR THIS PERIOD
'
'
. 0.00
Totals 2022 Year-to-Date
Total lees charged in 2022 $474.00
Total interesl charged in 2022 5201'"
Please detach bottom portion and submitwltl'l payment using enclosed envelope
[PAYMENT INFORMATION
. . g3;:§7g'w Account number ending 'm 7112
ndI g0
0
I eemm on 97070-4477 Payment Due Date January 21, 2023
New Balance $0.00
Minimun Payment Due $0.00
Make Check Amount Enclosed: s
Payable to:
TEDERIAN BRDHN
5401 H 7TH AVE GENESIS F5 CARD SERVICES
GARY IN 66406-1634 PO BOX 23039
"I"IlllIIlullllllllllllhllllllim'" I" Columbus GA 31902-3039
SBHBHGODEDOBBBL? 000000002 000000002
You Account is Issued by Celtic Bank and serviced by PAYING INTatEST
Genesis FS Card Services. Inc. Your due date is at least as days alter the close ol each Billing thycle. We will not charge
PAYMENTS you any interest on Purchases it you pay your entire balance by the due date each
Preview
45D10-2403-CC-002295 Filed: 3/14/2024 6:39 AM Clerk Lake Superior Court, Civil Division 6 Lake County, Indiana STATE OF INDIANA ) LAKE CIRCUIT COURT ) SS: COUNTY OF LAKE ) Case Number: ) MIDLAND CREDIT MANAGEMENT, INC. ) Plaintiff ) ) v. ) ) TEDERIAN BROWN ) Defendant ) COMPLAINT Plaintiff, MIDLAND CREDIT MANAGEMENT, INC., by counsel, sues Defendant, TEDERIAN BROWN , under Account Stated and in support thereof states: 1. Plaintiff is authorized to file this Complaint in this Court. Plaintiff owns portfolios of consumer receivables, which it attempts to collect. Plaintiff strives to treat its consumers, such as Defendant, with respect, compassion and integrity, hoping to provide mutually-beneficial opportunities for consumers to repay their debts and attain financial recovery. 2. Defendant is subject to this Court's jurisdiction. 3. Defendant established an account with CELTIC BANK, under redacted account number XXXXXXXXXXXX-7112. 4. Defendant was provided statements delineating Defendants use of the account and stating the current balance due. 5. Defendant defaulted on the account. 6. A statement of account balance was sent to Defendant and not paid. 7. Plaintiff has acquired all right, title and interest to Defendant's account, and has attempted to contact Defendant through several means in an effort to resolve the account with Defendant, but has been unsuccessful. Defendant has not repaid the balance owed on the account. Plaintiff remains willing to discuss various options to resolve the outstanding obligation, although the options may be different than they were prior to the initiation of litigation. 8. Defendant owes Plaintiff $1,027.16. 9. In support of the allegations, Plaintiff incorporates herein by reference the attached Exhibits. GL_0100G File No.: 24-29562 SCP The undersigned certifies that this and any attached document complies with the requirements of Trial Rule 5(G) with regard to information excluded from the public record under Administrative Rule 9(G). WHEREFORE, Plaintiff requests judgment against the Defendant for $1,027.16 and costs of the action and post judgment interest at the statutory rate. By: JOHN F. GILLESPIE Bar No. 31983-49 JASON E. TAYLOR Bar No. 30160-22 Attorneys for Plaintiff P.O. BOX 70069 LOUISVILLE, KY 40270-0069 Phone: (866) 300-8750 Fax: (855) 488-1523 E mail: IL_IN@mcmcg.com PLEASE UNDERSTAND THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. GL_0100G File No.: 24-29562 SCP AFFIDAVIT OF DEBT Comes now afiiant, and states: I, Casey Cornwall, am of adult age and am an employee of Midland Credit Managemem, Inc. ("Plaintifi" or "MCM"), and am fully authorized by Plaintiff" to make the following representations. l am familiar with the recordkeeping practices of Plaintiff. The following representations are true according to documents kept in the normal course of business and/or my personal knowledge. I have access to and have reviewed the electronic records pertaining to the account maintained by MCM and am authorized to make this afiidavit on MCM's behalf. The electronic records reviewed consist of (i) data and records acquired from the seller or assignor when MCM purchased or was assigned the account, which were incorporated into MCM's business records upon purchase or assignment, and (ii) data and records generated by MCM in connection with servicing the account since the date the account was purchased by or was assiyied to MCM. In addition, I reviewed the documents that are attached to this affidavit. l) The Plaintifi' has obtained this debt from Genesis FS Card Services, Inc. and the original creditor of this debt was CELTIC BANK. Evidence of the debt, as required in Rule 9.2(A) (2), is attached as one or more Exhibits to this Afi'ldavit. 2) TEDERIAN BROWN, Defendant, had an account balance of $1,027.16 as of 2024-02.] l, which is owed to Plaintiff on account W71 12 (hereinafier "the Account"). 3) MCM's records show that the Account was opened on 2021-03-30 and the last payment posted to the Account on 2022-07-12 in the amount of $62.00. MCM's records show that the Defendant defaulted on the Account on or afier 202206-20 and the Account was charged ofi' on 2022-12-23. 4) The type of account is: E Credit card account (e.g. Visa, MasterCard, Deparunent Store). Company issuing credit card: CELTIC BANK D Other: 5) The account balance includes: X MCM's records show that there are no late fees afler 202301-30. X Interest at a rate of 0% beginning on 2022-12-23. 6) The Plaintifi' is not seeking attorney's fees. 7) MCM's records do not show that Defendant is a minor or mentally incapacitated person. 8) If the Defendant is an individual, Plaintiff states and declares that pursuant to the attachment, Defendant is not in active duty status of the military. ("Active military service" includes fulltime duty in the military (including the National Guard and reserves) and, for members of the National Guard, service under a call to active service authorized by the President or Secretary of Defense. For further information, see the definition of "military service" in the Servicemernbers Civil Relief Act, as amended, 50 USCA Appx. §521.) AFFIDAVIT OF CASEY CORNWELL -1 llllllllllllllllllllllllllllllllll M 11 Ifllfllflllllfllllllllllllllllll 320434227 AFFRECA'ITACH 24-29562 9) As set forthin the records attached hereto, the complete chain of title including CELTIC BANK, the original creditor, and all post-charge-ofi' purchasers/assimees of the debt are as follows: l. CELTIC BANK 2022-12-23 2. Genesis FS Card Services, Inc. 2023-01-30 3. Midland Credit Management, Inc. 10) Attached hereto are the following records regarding the Account: a) Bill(s) of Sale, Assimment and/or Afiidavit(s) of Sale b) Seller data sheet reflecting the individual Account information from the electronic records provided by the seller or assignor pursuant to the Bil|(s) of Sale, Assignment") and/or Afidavit(s) of Sale in connection with the sale or assignment of the Account to Plaintiff c) Records regarding the Account and/or payments received: i) Contract, application, or other document evidencing the consumer's agreement to the debt; and/or ii) Statement(s) and/or Account records reflecting: l) the charge-ofl' balance; and 2) the last purchase transaction, payment, or balance transfer. l l) The documents attached hereto are true and correct copies of the originals, being a reproduction of Plaintifi's records, 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. I swear or affirm under the penalties of perjury that the foregoing representations are true. "MIMI Date asey Cornw /M CA137 AFFIDAVIT OF CASEY CORNWELL - 2 Illlllllllllllllllllfllllll Illllllllllllllllll 320434227 AFFRECA'ITACH llllllglllllllMllllllll -29562 BILL 0F SALE AND ASSIGNMENT 0F ACCOUNTS FROM CELTIC BANK TO GENESIS F S CARD SERVICES, INC. Pursuant to Section 4.3 of that certain Receivables Sale Agreement (the "RSA"), effective as of September l, 2021, by and between Celn'c Bank Corporation ("Seller") and Genesis FS Card Services, lnc. ("Buyer"), as of the applicable account charge off date, for good and valuable consideration, the receipt and sufliciency of which is hereby acknowledged, Seller transferred, assigned and set-over to Buyer all right, title and interest of Seller in and to those certain charged- off accounts specified in Exhibit A, which were originated by Seller. Dated: Mar 15, 2023 CELTIC BANK By: @T .'u'. Name: Cory Tauiliili Title: Accountant EXHIBIT A ACCOUNT SCHEDULE Those accounts pursuant to the RSA and this BILL OF SALE AND ASSIGNMENT 0F ACCOUNTS FROM CELTIC BANK TO GENESIS FS CARD SERVICES, INC. that are specifically identified in the electronic file named 'Account Data (CO-1033) Midland GPCC - - - F low 5' with such electronic file incorporated herein by reference. Exhibit 2 to Receivables Sale Agreement dated October 12, 2022 BILL OF SALE Closing Date: January 30, 2023 Genesis FS Card Services, Inc., an Oregon corporation ("Seller"), in consideration of the Purchase Price (as defined in the Agreement referred to below) and other valuable consideration, the receipt of which is hereby acknowledged, hereby s'ells, assigns and transfers all right, title and interest in and to (i) the Accounts identified in the Sale File entitled 'Account Data (CO-1033) - Midland GPCC Flow 5' (which may be in electronic fonn) to Midland Credit Management, - - Inc., a Kansas Corporation ("Buyer"), without recourse or representation except as expressly provided herein or pursuant to the terms, and subject to the conditions, set forth in the Agreement (the "Accounts), and (ii) all proceeds of such Accounts. The information contained in the Sale File (collectively, "Account Information") is true and complete in all material respects as of the Closing Date. Further, the information contained in the Account Information (a) constitutes business records regarding the Accounts maintained by the Seller and (b) accurately reflects in all material respects the information about the Accounts in Seller's possession. The Account Information, whether acquired or created, has been kept in the regular course of business by Seller and was made or compiled at or near the time of the event and recorded by (or fi'om information transmitted by) a person (i) with knowledge of the data entered into and maintained in business records maintained by Seller, or (ii) who caused the data to be entered into and maintained in business records maintained by the Seller. All capitalized terms used, but not defined, in this Bill of Sale shall have the meanings assigned to such term in the Ageement. This Bill of Sale is delivered pursuant to that certain Receivables Sale Agreement, dated as of October 12, 2022, by and between Seller and Buyer (as amended, restated, supplemented, or otherwise modified from time to time, the "Agreement"). All capitalized terms used but not defined in this Bill of Sale shall have the meanings assigned to such terms in the Ageement. MIDLAND CREDIT MANAGEMENT, INC. GENESIS FS CARD SERVICES, INC. By Name: xflamflo Danielle Wohlfehrt Syn. Name: fleflb GEEGG ATKINSON", ., Title: MVP u ine D v Tide252CEQ«:;:é'ng_ ,3, Receivables Sale Agreement dated October 12, 2022 AFFIDAVIT OF SALE OF ACCOUNT BY DEBT SELLER State of Ohio, County of Summit. M. Graham Flynn being duly sworn, deposes and says: I am over 18 and not a party to this action. I am the Director of Debt Salas [title] of Genesis Financial Solutions, Inc, parent company of Genesis FS Card Services ("Debt Seller"). In that position I am the custodian of Debt Seller's books and records and am aware of the procedures used for the sale and assignment of electronically stored business records. On Q! / 20 l 2033 Debt Seller sold a pool of charged-off accounts (the "Accounts") by a Loan Sale Agreement and a Bill of Sale to Midland Credit Management, Inc. ("Buyer"). All records were kept in the regular course of business. I am not aware of any errors in these Accounts. The above statements are true to the best of my knowledge. Dated: 3 1H IZDZ3 M.Gr amFlynn S m to before me 3 I [4/ / / Zfl Z3 \t-';§&W"II,, ANGELA WISE ' . . Notary Public. State of Ohio . My Commission Expires (NotaFy Stamp) \t 12/08/2025 CERTIFICATE OF CONFORMITY I Benjamin Cornston, an attorney duly licensed to practice law in the State of Ohio, affirm under penalty of perjury and certify that I witnessed the signature of M. Graham Flynn as applied to the Affidavit annexed to this Certificate, which was signed and dated on / l 3 / . The manner in which same was signed was, and is, in accordance with, and conforms to, the % laws for taking oaths and acknowledgments, in the State of Ohio. / Dated: 3 /H/ 9~3 Field Field Data Account Number 71 12 Seller Account ID First Name TEDERIAN Last Name BROWN SSN -I -3382 Date of Birth Address 1 I I - AVE 5401 W 7TH City GARY State IN Zip 46406 Open Date 03/30/2021 Last Purchase Date 04/12/2022 Last Purchase Amount $4.00 Last Payment Date 07/12/2022 Last Payment Amount $62.00 Sale Amount $1,027.16 Charge Off Date 12/23/2022 Charge off Balance $1,027.16 Post Charge Off Interest $0.00 Post Charge off Fee $0.00 Post Charge off Payments $0.00 Post Charge off Payments and Credits $0.00 Post Charge off Credits $0.00 Affinity INDIGO Alternate Account #1 -7112 Account information provided by Genesis FS Card Services. Inc. pursuant to the Bill of Sale/Assignment of Accounts transferred on or about 01/30/2023 in connection with the sale of accounts from Genesis FS Card Services. Inc. to Midland Credit Management, Inc. Account Data (CO-1033) Midland GPCC Flow 5 - - - indigo' {I iE TEDERIAN BROWN Account number ending in 7112 IACCOUN'I' SUMMARY IPAYMENT INFORMATION Credit Limit $500.00 New Balance $1,027.16 Available Credit $0.00 Minimum Payment Due $449.00 Past Due Amount $377.00 Payment Due Date January 21. 2023 Overlimit Amount 552736 Late Payment Warning: II we do not receive your minimum Statement Closing Date Deceniber 22- 2°22 payment by the date listed above. you may have to pay a late lee Days In Billing Cycle 30 of "9'0 $40.00. 83'3"" 5963"" Minimum Payment Warning: Ir you make onty the mirinum - Payments Credits 8. $0.00 . . . . # Purchases 3. Other Charges $000 payment each penod. you wIII pay more In Interest and It will take '+ FEES CHARGED $40.00 you onger r 0 pay oft your bal ance. Forexan'IpIe. I _ INTEREST CHARGED $24.00 "you make no = New Balance $1,027.16 additional charges Youwiflpayoflltne AndyouwilleMup balance shown on this paying an estimated using "is card and statement in about.. Mal of... QUESTIONS? Cal 1-800-353-5920 eachmonlhyoupay Please mail billing lnoulrles to: Onty the rnininum Genesis FS Card Services payrnem 20mm 31 .2121!) PO. Box 4499 ltyou would like information about credit oounseing services, call Beaverton. OR 97076-4499 1-800-353-5920. ww.indigocard.oom Notice: SEE REVERSE SIDE FOR MORE IMPORTANT INFORMATION 1 TRANSACTION Tran Post Date Date Reference Number Transaction Detonation Amount FEES ' . _ . 12/22 1222 LATE FEE . '40.00 TOTAL FEES FOR ms PERIOD ,.' j ' , INTEREST CHARGED - ' . c 12122 1212 Interest Charge on Purchases 24.00 12/22 12/22 Interest Charge on Cash Advances 0.00 ' TOTAL INTEREST FOR THIS PERIOD 24.00 Pleasedetach bottomponionandsubnitwithpaymeruusingendosedenvelope I PAYMENT IN FORMATION Geneeio F5 Card Services . . . PO BOX "77 . Account number ending In . 7112 I n d '90 Bomrton on 97076-4477 Payment Due Date New Balance January 21, 2023 $1,027.16 Minimum Paymem Due $449.00 Make Check Amount Enclosed: Payable to: [3 _| TEDERIAN BROWN 5601 H 7TH AVE GENESIS F5 CARD SERVICES GARY IN 46606-1434 PO BOX 23039 Columbus GA 31902-3039 53030500300355? 000091000 001027150 Your Account is issued by Celtic Bank and sauteed by PAYING lNTEltEST Genesis rs Card Services. Inc. Your due date is at least 25 days alter the close ot each Billing cycle. We will not charge PAYMENTS you any interest on Purchases it you pay your entire balance by the due date each month. We will begin charging interest on Cash Advances on the transaction this Payments should be mailed with the payment coupon and in the envelope provided to the Genesis FS Card Services payment address indicated on the payment coupon. Any OTNElt DISCLOSURES payment received in that torm and at that address on or belore 5:00 PM. Eastern Time on For AR. HI. IA. hf Residents: This communication is from a debt collector. "is is an a normal banking day will be credited to your Account that day. It your payment is received attempt to collect debt and any inlormatlon obtained will be used tor that purpose. in that torm and at that address after 5:00 PM. Eastern Time on a normal banking day, What To Do it You Think You Find A Mistake On Your Statement or anytime on a nonbanking day. we will credit it to your Account the next banking day. it you mink there is an error on your statement. write to us at Genesis F5 Card Services. Payments can also be made online by visiting indigocardcom. When you provide a check P.O. Box 4499. Beeverton. Oregon 970764499. as payment. you authorize us either to use the inlormation lrorn your check to make a in your letter. give us the lollowing inlorrnation: one-time electronic iund trarisler lrorn your awount or to process the payrnent as a check . Acooant lnlomtation: Your name and Account number. transaction. When we use intomiah'on lrorn you check to make an electronic lund v Dollar Amount The dollar amount oi the suspected error. transler, lunds may be withdrawn from your account as soon as the some daywe receive 0 Description oi Problem: It you think there is an error on your bil. describe what your payment and you will not receive your check back lrorn your financial institution. Payments received at other than the remittance address on the lace at this statement may youbelieveiswrcngandwhyyoubelieveit 'sa mistake. You must contact us: besubjecttoadelayincreditingoiuptoSdaysatterthedateolreceipt. - Within 60 days alter the error appeared on your shterrtent. ANNUAL FE (it applicable) You must notily us at any potential errors in writing. You may all us, but it you do we it you wish to close yourAcoount to turther Purchases and Cash Advances in order are not required to investigateany potent'al errors and you my have to paythe amount to avoid paying the renewal Annual Fee. you must deliver written notice at closure (instruc- it question. tions below) to us within thirty (30) days irorn the mailing date at the statement or letter Whileweinvesligalewhetherornotthere hasheenanerronthelollowingaretruec containing the renewal Annual Fee notice. (This does not apply to the initial Annual Fee . We cannot try to colect the amount in question. or report you as delinquent on charged in connection with the opening at your Amount.) that amount. . Thecnarge in question mayremainonyotrstatemcnt.andwe mayccminueto MONTHLY FEE (if applicable) it you wish to close your Account to lurthar Purchases and Cash Advances in order to charge you interest on that amount But. it we determine that we made a mistake. avoiii paying the Monlhty Fee. you must deliver written notice at closure (instnictions you will not inve to pay the amount in question or any interest or other lees relaud to that amount. below)tous priorto lheendola Billingcycle. Othenuise. yourAcoountwll bechargeda - While you do not have to pay the amount it direction. you are responsible lor the Monthty Fee. remainder at your bahnce. NOTICE OF ACCOtMT CLOSIINE - We can apply any unpaid amount against your credit Irnit. Written notice oi closure must be sent to Genesis F5 Card Services. PO Box 4477, Your Rights It You Are Dissatisfied Witli Your Credit Card Purchases Beaverton. OR 97076. Upon receipt. we will close your Account and the renewal Annual Fee and/or Monthty Fee (as applicable) will not be charged to your Account. Closing your it you are dissatislied with the goods or services that you have purchased with your Account will not cancel your obligations to pay amounts outstanding on your Account, and credit card. and you love tried in good laith to correct the problern with the merchant. you will be required to pay your outstanding bahnce with interest in accordance with the you may have the right not to pay the remaining amount due on the purchase. To use terms oi your Grdholder Agreement. this right, all at the lollowing must be true: 1. The purchase must have been made in your home state or within 100 miles CREDIT BUREAU WONG at your current mailing address. and the purctnse price must have been more We may report intormation about your Account to credit bureaus. late payments, missed than 850. (Note: Neither oi these is necessary it your purchase was based on payments. or other delaults on your Account may be rellected in your credit report. an advertisement we mailed to you, or it we own the comperry that sold you the BALANCE SUBJECT To INTEREST RATE goods or services.) We use the Average Daily Balance (including new purchases) method to calctriate the 2. You must have used your credit card for the purchase. Purchases made with cash balance on which we charge interest. To lind out more about the balance computation advances trorn an ATM or with a check that accesses your credit card amount do method and how interest charges were detannined. call us at the toll-tree telephone not quality. number on the lront ol the lirst page oi your billing statement 3. You must not yet have lully paid lor the purchase It all of the criteria above are met and you are still dissatisfied with the purchase. contact MINIMUM iNTENEST CHANGE us in writing at: Genesis FS Card Services, PO. Box 4499. Beaverlon. Oregon. 97076. ltyouarachargedirmresuhechargewiibenolesthan SOSO While we investigate. the same rules apply to the disputed amount as discussed above Alter we linish our investigation, we will tell you our decision. At that point. it we thitlr you owe an amount and you do not pay, we may report you as delinquent. OIAII202 "[04002] - Detach here v and return below portion with your remittance. After detaching. retain upper portion for your future relerence. ADDRESS / PHONE NUMBER CHANGE FORM By providing I cellular phone number or a number that is later convened to a cellular phone number, you are capmsly consenting that we (and any other owners or servicers of your Account) my contact you via phone or text message. "'" .theusool." and cake and messages usirig an Mounted dialing system. ADDRESS CITY STATE ZIP CODE ( ) ( ) HOME PHONE BUSINESS PHONE EMAIL ADDRESS TEDERIAN BROWN Account number ending in 7112 A 1%? 0&7 2;" rain 5) "311T Toulfeuchugedmm 5474 (I) Toulmmtchmgodhm $20104 " EIMPORTANT ACCOUNT INFORMATION YOUR ACCOUNT IS PAST DUE; THE PAST DUE AMOUNT IS INCLUDED IN THE MINIMUM PAYMENT. PLEASE REMIT IMMEDIATELY. YOUR ACCOUNT IS CURRENTLY OVER YOUR CREDIT LIMIT. [INTEREST CHARGE CALCULATION Your AnnuaI Percentage Rate (APR) is the annual interest rate'on your accwnt Annual Percentage Balance Subject to Two of Baht-u Rate (APR) Interest Rate Interest Charon Purchases , > 29.90% 8963.16 $24.00 Cash Advances 29.90% , $0.00 $0.00 (v) = variable indigo' TEDEFIIAN BROWN Account number ending in 7112 [ACCOUNT SUMMARY. [PAYMENT INFORMATION - ] I Credit Limit $500.00 New Balance $0.00 Available Credit $0.00 Minimum Payment Due $0.00 Past Due Amount $0.00 Payment Due Date January 21. 2023 Overlimit Amunt 50-00 Late Payment Warning: If we do not receive your minimum Statement CIOSIDQ Date December 23- 2°22 payment by the date listed above, you my have to pay a late fee Days in Billing Cycle 30 at up to 540.00. P'ev'ws Balance . 51'027'16 Minimum Paynient Warning: It you make only the minimm - Payments 8. Credits $1,027.16 . . . . + Purchases 8. Other Charges $0.00 payment each period, you Will pay more an interest and rt will take + FEES CHARGED $0.00 V°° "9° r to pay 0" V°° ' balance ' I F "me' l _ + INTEREST CHARGED $0.00 If you wake no = New Balame $0.00 additional charges You will pay oflttte MywMIendup balance shown on this paying an estimated using this card and statement in about... total of... QUESTIONS? Cal 1-800-353-5920 eachmonthyoupay Please mail billing Inquiries to: Ontythemininum Genesis FS Card Services 14mm 51 .027 .00 paymnt PO. Box 4499 If you would like information about credit counseling services. cal Beaverton. OR 97076-4499 1-3003535920. wwwjndigocard.cotn Nofioe: SEE REVERSE SIDE FOR MORE IMPORTANT INFORMATION ITRANSACTIONS Tran Post Date Date Reference Number Transaction Description Amount 12/23 12!23 F852100PM00999990 CHARGE OFF ACCOUNT-PRINCIPALS 477.55- 12I23 12/23 F852100PM00999990 CHARGE OFF ACCOUNT 'FINANCE CHARGES' 549.61- TOTAL FEES FOR THIS PERIOD 0.00 . INTEREST CHARGED . 1223 Interest Charge on Purchases 0.00 12/2? 12/23 12/23 Interest Charge on Cash Advances 0.00 TOTAL INTEREST FOR THIS PERIOD ' ' . 0.00 Totals 2022 Year-to-Date Total lees charged in 2022 $474.00 Total interesl charged in 2022 5201'" Please detach bottom portion and submitwltl'l payment using enclosed envelope [PAYMENT INFORMATION . . g3;:§7g'w Account number ending 'm 7112 ndI g0 0 I eemm on 97070-4477 Payment Due Date January 21, 2023 New Balance $0.00 Minimun Payment Due $0.00 Make Check Amount Enclosed: s Payable to: TEDERIAN BRDHN 5401 H 7TH AVE GENESIS F5 CARD SERVICES GARY IN 66406-1634 PO BOX 23039 "I"IlllIIlullllllllllllhllllllim'" I" Columbus GA 31902-3039 SBHBHGODEDOBBBL? 000000002 000000002 You Account is Issued by Celtic Bank and serviced by PAYING INTatEST Genesis FS Card Services. Inc. Your due date is at least as days alter the close ol each Billing thycle. We will not charge PAYMENTS you any interest on Purchases it you pay your entire balance by the due date each