Preview
Filing # 194442371 E-Filed 03/20/2024 02:25:38 PM
IN THE COUNTY COURT IN AND FOR BREVARD COUNTY, FLORIDA
CASE NO.:
PCA Acquisitions V, LLC
Plaintiff,
vs. COMPLA
Russell Clum,
Defendant.
/
COMES NOW the Plaintiff, PCA Acquisitions V, LLC, by and through its undersigned counsel,
and sues Defendant, Russell Clum, and states as follows:
GENERAL ALLEGATIONS
This is an action for damages that are within the jurisdictional limits of this court exclusive of
costs.
Venue of this action is proper in the county named above because the Defendant is a resident
of this county and/or because the Defendant executed the subject agreement in this county.
Upon Defendant’s request, the original creditor, Marlette Funding LLC, established a loan
and/or credit line in the name of Defendant, and pursuant to said request, issued the
aforementioned bearing the account number ___i!
Prior to the commencement of this action, Plaintiff, PCA acquired
Acquisitions V, LLC,
Defendant’s account originated by the Original Creditor, see attached Exhibit “A”, and as such
is entitled to all rights originally bestowed upon the Original Creditor.
Although numerous demands have been made by Plaintiff, PCA Acquisitions V, LLC, upon
Defendant for payment, Defendant has failed or refused to pay the amount due and owing on
the account.
Plaintiff and its predecessors have duly performed all promises, conditions precedent and
agreements as required.
A ca Acquisitions V, Lic v. Russell Clum 05-2024-SC-020925-XXSC-BC
COUNT I~ BREACH OF CONTRACT
Plaintiff readopts and re-alleges allegations one (1) through six (6) above and further states as
follows:
7. The Defendant, Russell Clum, by execution of the Agreement and/or by use of the funds
provided by the Original Creditor, has accepted the terms and conditions of the installment
loan attached hereto as Exhibit “B”.
Pursuant to the aforementioned loan and/or line of credit extended to Defendant, and in
reliance on the terms and conditions of said loan/line of credit documents attached as Exhibit
“B”, Defendant promised to repay all monies received.
The Plaintiff has purchased the debt incurred under the contract from the Original Creditor,
and now owns and holds all rights relative thereto, as evidenced by Plaintiff's previously
attached Exhibit “A”. Accordingly, the Plaintiff is lawfully entitled to enforce that contract and
receive the full benefit thereof.
10. Defendant has breached the contract by failing and/or refusing to repay either the full balance
due or the minimum monthly payment promised.
11 As of the date of this Complaint, the funds utilized by Defendant, in the amount of $3,183.21,
have not been repaid and continue to remain due and owing to Plaintiff.
12. As a direct and proximate result of the Defendant’s breach, the Defendant owes Plaintiff, PCA
Acquisitions V, LLC, the amount of $3,183.21.
WHEREFORE Plaintiff, PCA Acquisitions V, LLC, respectfully requests this Honorable Court
enter Judgment in its favor against Defendant, Russell Clum, in the sum of $3,183.21, together with court
costs as described herein and any other just and further relief as this Honorable Court deems just and
proper.
Respectfully submitted,
ANDREU, PALMA, LAVIN, & SOLIS, PLLC
/d Alaw Miller, Esq. - FBN 0249637
887 Donald Ross Road
Juno Beach, FL 33408
Tel. (877)229-5972
Fax. (800)391-2178
Email: eservice@andreupalma.com
2354001171
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC.
EXHIBIT A
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
BILL OF SALE
DATED AS OF THE CLOSING DATE
Seller(s) listed below (each a “Seller” and, collectively the “Sellers”), for value received and
pursuant to the Forward Flow Account Purchase Agreement, dated as of October 24, 2022,
(the “Agreement”), between Marlette Servicing LLC, as Servicer on behalf of Sellers
identified therein, and PCA Acquisitions V, LLC as buyer, hereby assign(s), effective as of
the Closing Date(s) listed on the Attachment hereto, all rights, title and interest of Seller(s)
(and including for the avoidance of doubt, all rights, title and interest of the trustee or other
agent of each Seller listed on the Attachment, if any, not in their individual capacities, but
solely in their capacity of trustee or other agent of the Seller, who is holding legal title to the
Accounts for the benefit of the Seller in such capacity) in and to those Accounts listed on the
Attachment and identified in the attached loan file(s). Capitalized terms used herein and not
otherwise defined shall have the meanings scribed to such terms in the Agreement.
SELLER(S):
1st Capital Bank
Auto Club Trust, FSB
BAWAG
Blackthorn 2018-A.
CL Trust IT
Community First Bank
Cross River Bank
Customers Bank
DL Investment Sarl
Exigent Consumer Credit Fund LP
Hudson River Trust 2017-1
Hudson River Trust 2017-3
Loan Asset Holdings Trust 2020 M-1
Loan Asset Holdings Trust 2020-1
Loan Asset Holdings Trust 2021-M-1
Loan Asset Holdings Trust 2021-M-2
Loan Asset Holdings Trust II 2020-1
Loan Asset Holdings Trust II 2021-1
Loan Asset Holdings Trust II 2022-1
MAPT 2019-11A
MAPT 2019-12A
MAPT 2020-1A
1
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
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Marlette Funding Consumer Loan Trust
Marlette Funding Grantor Trust 2018-1
Marlette Funding Grantor Trust 2018-2
Marlette Funding Grantor Trust 2018-3
Marlette Funding Grantor Trust 2019-1
Marlette Funding Grantor Trust 2019-2
Marlette Funding Grantor Trust 2019-3
Marlette Funding Grantor Trust 2019-4
Marlette Funding Grantor Trust 2020-1
Marlette Funding Grantor Trust 2020-2
Marlette Funding Grantor Trust 2021-1
Marlette Funding Grantor Trust 2021-2
Marlette Funding Grantor Trust 2021-3
Marlette Funding Grantor Trust 2022-1
Marlette Funding Grantor Trust 2022-2
Marlette Funding Trust
MCL Borrower Trust
MPL Trust I
MPLI Capital Holdings II
Pagaya Acquisition Trust
Pagaya Acquisition Trust II
Pagaya AI Debt Grantor Trust 2021-5
Pagaya AI Debt Grantor Trust 2022-1
Pagaya AI Debt Grantor Trust 2022-2
Pagaya AI Debt Selection Grantor Trust 2021-1
Pagaya AI Debt Selection Grantor Trust 2021-2
Pagaya AI Debt Selection Grantor Trust 2021-3
Pagaya AI Debt Selection Grantor Trust 2021-HG1
Pagaya Funding Trust
Pagaya Funding Trust IT
PML Trust I
Red Marble Trust
Seacoast National Bank
SPC Receivables Funding Trust I
Stone Ridge Alternative Lending Risk Premium Fund US Holdings III LLC
Theorem Main Master Fund LP
Theorem Prime + Yield Fund Master LP
Theorem Short Duration Liquidity Fund LP
Trallem 2 Trust
2
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
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By: Marlette Servicing, LLC, as Attomey in
Fact
By: Aba bhodes
Chief Operating Officer
Title: COO
Date: As of the Closing Date listed on the Attachment
TRUSTEE(S) OR OTHER AGENT(S): See Matrix below
3
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
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OR OTHER |
LENAMES)_
‘LOSING
__ AGENT
BALAN
AS: DATE
1st Capital Bank 1st Capital Bank, a 4
California state-
chartered bank
CHARGEOFF_
SALE_inve_202211
07 11/14/2022
Auto Club Trust, Auto Club Trust, FSB 11/14/2022
FSB
CHARGEOFF_
SALE_inve_202211
07
BAWAG Wilmington Savings Fund CHARGEOFF_ 11/14/2022
Society, FSB, not in its SALE_inve_202211
individual capacity but solely 07
as trustee of US Consumer
Loan
Trust, a Delaware common
law
trust
Blackthorn 2018- CHARGEOFF_ 3 11/14/2022
A Wilmington Savings Fund SALE_inve_202211
Society, FSB, not in its 07
individual capacity but solely’
as
Trustee for the Trust
4
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
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CL Trust II UMB Bank, National 1 1/14/2022
Association
CHARGEOFF_
SALE_inve_202211
07
Community First Community First Bank, a 1/14/2022
Bank Washington state-chartered
bank CHARGEOFF_
SALE_inve_202211
07
Cross River Bank 17 1 1/14/2022
Wilmington Savings Fund
Society, FSB CHARGEOFF _
SALE_inve_202211
07
Customers Bank Customers Bank, a Pennsylvania 1 1/14/2022
banking corporation
CHARGEOFF _
SALE_inve_202211
07
DL Investment Compartment Moonstone 1, a 11/14/2022
Sarl
CHARGEOFF_
SALE_inve_202211
07
A Cayman Islands Exempted. 11/14/2022
Limited Partnership
Exigent CHARGEOFF_
Consumer Credit SALE_inve_202211
Fund LP 07
Hudson River 11/14/2022
Trust 2017-1 CHARGEOFF_
SALE_inve_202211
Cross River Bank, not in its
07
individual capacity, but solely in
its capacity as Administrator for
the Hudson River Trust Series 1-4]
5
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
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Hudson River 11/14/2022
Trust 2017-3
Cross River Bank, not in its
individual capacity, but solely in
its capacity as Administrator for CHARGEOFF_
the Hudson River Trust Series 1- SALE_inve_202211
4 07
Wilmington Savings Fund 11/14/2022
Society, FSB
Loan Asset CHARGEOFF_
Holdings Trust SALE_inve_202211
2020 M-1 07
Loan Asset Wilmington Savings Fund Society, CHARGEOFF _ 11/14/2022
Holdings Trust FSB SALE_inve_202211
2020-1 07
Wilmington Savings Fund Society, 11/14/2022
FSB
Loan Asset CHARGEOFF _
Holdings Trust SALE_inve_202211
2021-M-1 07
Loan Asset Wilmington Savings Fund Society, CHARGEOFF _ 11/14/2022
Holdings Trust FSB SALE_inve_202211
2021-M-2 07
6
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
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Loan Asset Wilmington Savings Fund CHARGEOFF _ 4 11/14/2022
Holdings Trust IT Society, FSB SALE_inve_202211
2020-1 07
Loan Asset Wilmington Savings Fund Society, CHARGEOFF _ 10 11/14/2022
Holdings Trust IT FSB SALE_inve_202211
2021-1 07
Loan Asset Wilmington CHARGEOFF _ 1 11/14/2022
Holdings Trust IT Savings Fund SALE_inve_202211|
2022-2 Society, FSB
07
MAPT 2019-
Wilmington Trust,
CHARGEOFF __ 1 11/14/2022
11A National SALE_inve_202211
Association, noot in
its individuaal 07
capacity but solely as
Owner Trustee
MAPT 2019- 11/14/2022
12A
Marlette Pass-Through Master CHARGEOFF _
Trust, Wilmington Trust, SALE_inve_202211
National Association 07
7
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
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MAPT 2020-1A 11/14/2022
Marlette Pass-Through Master CHARGEOFF __
Trust, Wilmington Trust, SALE_inve_202211
National Association 07
Marlette Funding Marlette Funding Consumer Loan 11/14/2022
Consumer Loan Trust, a Delaware statutory trust
Trust CHARGEOFF _
SALE_inve_202211
07
Marlette Funding Wilmington Savings Fund Society, 11/14/2022
Grantor Trust FSB
2018-1 CHARGEOFF _
SALE_inve_202211
07
Wilmington Savings Fund 11/14/2022
Society, FSB
Marlette CHARGEOFF _
Funding Grantor SALE_inve_202211
Trust 2018-2 07
Wilmington Savings Fund 11/14/2022
Society, FSB
Marlette CHARGEOFF __
Funding Grantor SALE_inve_202211
Trust 2018-3 07
Wilmington Savings Fund 11/14/2022
Society, FSB
Marlette CHARGEOFF __
Funding Grantor SALE_inve_202211
Trust 2019-1 07
Wilmington Savings Fund 11/14/2022
Society, FSB
Marlette CHARGEOFF _
Funding Grantor SALE_inve_202211
Trust 2019-2 07
8
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
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Marlette Funding Wilmington Savings Fund CHARGEOFF __ 4 11/14/2022
Grantor Trust Society, FSB SALE_inve_202211
2019-3 07
Marlette Funding Wilmington Savings Fund Society, CHARGEOFF_ 11/14/2022
Grantor Trust FSB SALE_inve_202211
2019-4 07
CHARGEOFF _ 11/14/2022
SALE_inve_202211 07
Wilmington Savings Fund Society,
Marlette Funding FSB, not in its individual capacity, but
Grantor Trust solely in its capacity as Grantor
2020-1 Trust Trustee of the Grantor Trust
Wilmington Savings Fund 11/14/2022
Society, FSB
Marlette Funding CHARGEOFF _
Grantor Trust SALE_inve_202211
2020-2 07
Marlette Funding Wilmington Savings Fund CHARGEOFF _ 11/14/2022
Grantor Trust Society, FSB SALE_inve_202211
2021-1 07
9
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
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Marlette Funding Wilmington Savings Fund CHARGEOFF _ 11/14/2022
Grantor Trust Society, FSB SALE_inve_202211
2021-2 07
Marlette Funding Wilmington Savings Fund CHARGEOFF __ 15 11/14/2022
Grantor Trust Society, FSB SALE_inve_202211
2021-3 07
Marlette Funding Wilmington Savings Fund CHARGEOFF _ 15 11/14/2022
Grantor Trust Society, FSB SALE_inve_202211
2022-1 07
Marlette Funding CHARGEOFF __ 11/14/2022
Grantor Trust Wilmington Savings Fund
SALE_inve_202211
2022-2 07
Society, FSB, not in its
individual capacity, but
solely in its capacity as
Grantor Trust Trustee of
the Grantor Trust
Marlette Funding} Wilmington Savings Fund CHARGEOFF _ 11/14/2022
Trust Society, FSB SALE_inve_202211
07
10
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
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MCL Borrower MCL Borrower Trust, a CHARGEOFF _ 11/14/2022
Trust Delaware statutory trust SALE_inve_202211
07
MPL Trust I UMB Bank, National CHARGEOFF _ 11/14/2022
Association SALE_inve_202211
07
MPLI Capital Wilmington Savings Fund CHARGEOFF _ 24 11/14/2022
Holdings IT Society, FSB SALE_inve_202211
07
Pagaya CHARGEOFF_ 1 11/14/2022
Acquisition Trust SALE_inve_202211
Wilmington Trust,
07
National
Association, Not in
its individual
capacity but solely
as Depositor Trustee
Pagaya CHARGEOFF _ 4 11/14/2022
Acquisition Trust SALE_inve_202211
Wilmington Trust,
II 07
National
Association, Not in
its individual
capacity but solely
as Depositor Trustee
11
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
X3901
Pagaya AI Debt CHARGEOFF_ 41 11/14/2022
Grantor Trust SALE_inve_202211
Wilmington Trust, 07
2021-5 National
Association, Not in
its individual
capacity but solely
as Depositor Trustee
Pagaya AI Debt CHARGEOFF _ 36 11/14/2022
Wilmington Trust,
Grantor Trust SALE_inve_202211
National 07
2022-1
Association, Not in
its individual
capacity but solely
s Depositor
Trustee
Pagaya AI Debt CHARGEOFF_ 3 11/14/2022
Grantor Trust SALE_inve_202211
Wilmington Trust,
2022-2 07
National
Association, not in
its individual
capacity, but solely
as Depositor Trustee
Pagaya AI Debt CHARGEOFF_ 43 11/14/2022
Selection SALE_inve_202211
Wilmington Trust,
Grantor 07
National
Trust 2021-1
Association, Not in
its individual
capacity but solely
as Depositor Trustee’
12
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
X3901
Pagaya AI Debt CHARGEOFF_ 19 11/14/2022
Selection SALE_inve_202211
Wilmington Trust,
Grantor 07
National
Trust 2021-2 Association, Not in
its individual
capacity but solely
as Depositor Trustee’
Pagaya AI Debt CHARGEOFF_ 94 11/14/2022
Selection SALE_inve_202211
Wilmington Trust,
Grantor 07
National
Trust 2021-3 Association, Not in
its individual
capacity but solely
as Depositor Trustee
Pagaya AI Debt CHARGEOFF_ 13 11/14/2022
Selection SALE_inve_202211
Wilmington Trust,
Grantor 07
National
Trust 2021-
Association, Not in
HG1
its individual
capacity but solely
as Depositor Trustee’
Pagaya Funding CHARGEOFF_ 8 11/14/2022
Trust SALE_inve_202211
Wilmington Trust,
07
National
Association, Not in
its individual
capacity but solely
as Depositor Trustee
Pagaya Funding Wilmington Trust, 11/14/2022
Trust IT National
Association, Not in
its individual
capacity but solely CHARGEOFF_
as Depositor SALE_inve_202211
Trustee 07
13
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
X3901
PML Trust I 20 11/14/2022
UMB Bank, CHARGEOFF_
National SALE_inve_202211
Association, FSB 07
Red Marble Trust 11/14/2022
Wilmington Trust, CHARGEOFF_
National SALE_inve_202211
Association 07
Secoast CHARGEOFF_ 11/14/2022
National SALE_inve_202211
Seacost National
Bank 07
Bank, a national
banking association
the successor by
merger to
Drummond
Community Bank
SPC 11/14/2022
Receivables
Funding Trust I Wilmington Trust, CHARGEOFF_
National SALE_inve_202211
Association 07
Stone Ridge
Wilmington Savings
CHARGEOFF_ 11/14/2022
Alternative SALE_inve_202211
Fund Society, FSB,
Lending Risk 07
not in its individual
Premium Fund
capacity but solely
US Holdings III as trustee of
LLC Alternative
Lending
Holdings Trust IV
14
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
X3901
Theorem Main| Theorem Partners LLC, its| CHARGEOFF _ 17 11/14/2022
Master Fund general partner SALE_inve_202211
LP 07
Theorem Prime | Theorem Partners LLC, its 11/14/2022
+ general partner
Yield Fund CHARGEOFF_
Master LP SALE_inve_202211
07
Theorem Partners LLC, its CHARGEOFF_ 6 11/14/2022
Theorem Short general partner SALE_inve_202211
07
Duration
Liquidity Fund
LP
Trallem 2 Trust CHARGEOFF_ 3 11/14/2022
SALE_inve_202211
Wilmington Trust, National 07
Association, Not in its
individual capacity but
solely as Trustee
=
15
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
X3901
EXHIBIT B
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
begtbae DATE: 3/18/2021
TRUTH IN LENDING DISCLOSURE STATEMENT
Lender Borrower
Cross River Bank Russell Clum
885 Teaneck Road
Teaneck, NJ 07666
ANNUAL FINANCE CHARGE Amount Financed Total of Payments
PERCENTAGE RATE The dollar amount the The amount of credit The amount you will
The cost of your credit
credit will cost you provided to you or on have paid after you
at a yearly rate
your behalf have made all
payments as scheduled
29.70% $1,767.72 $3,384.36 $5,152.08
Your payment schedule will be as follows:
Number of Payments. Amounts When payments are due
35 First payment is due on 4/17/2021,
$143.12
and then monthly on the same date
$142.88 thereafter.
Late charges: If your payment arrives after your 3-day grace period, you will be charged a late fee in
the amount of $15. This fee is charged only once per late payment.
Prepayment policy: If you pay off your loan in advance, you will not be charged a penalty. In the event
of a prepayment, you will not be entitled to a refund of any pre-paid finance charges or other fees.
See your Loan Agreement for any additional information about nonpayment, default or other matters
related to your loan.
3c0226¢7-800d-4531-a57a-0344226F1dae
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
Itemization of amount financed:
Amount of Your Loan: $3, 600.00
Origination Fee: $215.64
Amount Given to You Directly or your designee: $3, 384.36
Annual Loan Interest Rate: 24.99%. Interest at this Loan Interest Rate plus the Origination Fee results
in the Finance Charge and Annual Percentage Rate disclosed above.
3c0226¢7-800d-4531-a57a-0344226F1dae
Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC
Transaction History (Redacted to mit information to specifi account)
Transaction History
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Preview
Filing # 194442371 E-Filed 03/20/2024 02:25:38 PM IN THE COUNTY COURT IN AND FOR BREVARD COUNTY, FLORIDA CASE NO.: PCA Acquisitions V, LLC Plaintiff, vs. COMPLA Russell Clum, Defendant. / COMES NOW the Plaintiff, PCA Acquisitions V, LLC, by and through its undersigned counsel, and sues Defendant, Russell Clum, and states as follows: GENERAL ALLEGATIONS This is an action for damages that are within the jurisdictional limits of this court exclusive of costs. Venue of this action is proper in the county named above because the Defendant is a resident of this county and/or because the Defendant executed the subject agreement in this county. Upon Defendant’s request, the original creditor, Marlette Funding LLC, established a loan and/or credit line in the name of Defendant, and pursuant to said request, issued the aforementioned bearing the account number ___i! Prior to the commencement of this action, Plaintiff, PCA acquired Acquisitions V, LLC, Defendant’s account originated by the Original Creditor, see attached Exhibit “A”, and as such is entitled to all rights originally bestowed upon the Original Creditor. Although numerous demands have been made by Plaintiff, PCA Acquisitions V, LLC, upon Defendant for payment, Defendant has failed or refused to pay the amount due and owing on the account. Plaintiff and its predecessors have duly performed all promises, conditions precedent and agreements as required. A ca Acquisitions V, Lic v. Russell Clum 05-2024-SC-020925-XXSC-BC COUNT I~ BREACH OF CONTRACT Plaintiff readopts and re-alleges allegations one (1) through six (6) above and further states as follows: 7. The Defendant, Russell Clum, by execution of the Agreement and/or by use of the funds provided by the Original Creditor, has accepted the terms and conditions of the installment loan attached hereto as Exhibit “B”. Pursuant to the aforementioned loan and/or line of credit extended to Defendant, and in reliance on the terms and conditions of said loan/line of credit documents attached as Exhibit “B”, Defendant promised to repay all monies received. The Plaintiff has purchased the debt incurred under the contract from the Original Creditor, and now owns and holds all rights relative thereto, as evidenced by Plaintiff's previously attached Exhibit “A”. Accordingly, the Plaintiff is lawfully entitled to enforce that contract and receive the full benefit thereof. 10. Defendant has breached the contract by failing and/or refusing to repay either the full balance due or the minimum monthly payment promised. 11 As of the date of this Complaint, the funds utilized by Defendant, in the amount of $3,183.21, have not been repaid and continue to remain due and owing to Plaintiff. 12. As a direct and proximate result of the Defendant’s breach, the Defendant owes Plaintiff, PCA Acquisitions V, LLC, the amount of $3,183.21. WHEREFORE Plaintiff, PCA Acquisitions V, LLC, respectfully requests this Honorable Court enter Judgment in its favor against Defendant, Russell Clum, in the sum of $3,183.21, together with court costs as described herein and any other just and further relief as this Honorable Court deems just and proper. Respectfully submitted, ANDREU, PALMA, LAVIN, & SOLIS, PLLC /d Alaw Miller, Esq. - FBN 0249637 887 Donald Ross Road Juno Beach, FL 33408 Tel. (877)229-5972 Fax. (800)391-2178 Email: eservice@andreupalma.com 2354001171 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC. EXHIBIT A Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC BILL OF SALE DATED AS OF THE CLOSING DATE Seller(s) listed below (each a “Seller” and, collectively the “Sellers”), for value received and pursuant to the Forward Flow Account Purchase Agreement, dated as of October 24, 2022, (the “Agreement”), between Marlette Servicing LLC, as Servicer on behalf of Sellers identified therein, and PCA Acquisitions V, LLC as buyer, hereby assign(s), effective as of the Closing Date(s) listed on the Attachment hereto, all rights, title and interest of Seller(s) (and including for the avoidance of doubt, all rights, title and interest of the trustee or other agent of each Seller listed on the Attachment, if any, not in their individual capacities, but solely in their capacity of trustee or other agent of the Seller, who is holding legal title to the Accounts for the benefit of the Seller in such capacity) in and to those Accounts listed on the Attachment and identified in the attached loan file(s). Capitalized terms used herein and not otherwise defined shall have the meanings scribed to such terms in the Agreement. SELLER(S): 1st Capital Bank Auto Club Trust, FSB BAWAG Blackthorn 2018-A. CL Trust IT Community First Bank Cross River Bank Customers Bank DL Investment Sarl Exigent Consumer Credit Fund LP Hudson River Trust 2017-1 Hudson River Trust 2017-3 Loan Asset Holdings Trust 2020 M-1 Loan Asset Holdings Trust 2020-1 Loan Asset Holdings Trust 2021-M-1 Loan Asset Holdings Trust 2021-M-2 Loan Asset Holdings Trust II 2020-1 Loan Asset Holdings Trust II 2021-1 Loan Asset Holdings Trust II 2022-1 MAPT 2019-11A MAPT 2019-12A MAPT 2020-1A 1 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 Marlette Funding Consumer Loan Trust Marlette Funding Grantor Trust 2018-1 Marlette Funding Grantor Trust 2018-2 Marlette Funding Grantor Trust 2018-3 Marlette Funding Grantor Trust 2019-1 Marlette Funding Grantor Trust 2019-2 Marlette Funding Grantor Trust 2019-3 Marlette Funding Grantor Trust 2019-4 Marlette Funding Grantor Trust 2020-1 Marlette Funding Grantor Trust 2020-2 Marlette Funding Grantor Trust 2021-1 Marlette Funding Grantor Trust 2021-2 Marlette Funding Grantor Trust 2021-3 Marlette Funding Grantor Trust 2022-1 Marlette Funding Grantor Trust 2022-2 Marlette Funding Trust MCL Borrower Trust MPL Trust I MPLI Capital Holdings II Pagaya Acquisition Trust Pagaya Acquisition Trust II Pagaya AI Debt Grantor Trust 2021-5 Pagaya AI Debt Grantor Trust 2022-1 Pagaya AI Debt Grantor Trust 2022-2 Pagaya AI Debt Selection Grantor Trust 2021-1 Pagaya AI Debt Selection Grantor Trust 2021-2 Pagaya AI Debt Selection Grantor Trust 2021-3 Pagaya AI Debt Selection Grantor Trust 2021-HG1 Pagaya Funding Trust Pagaya Funding Trust IT PML Trust I Red Marble Trust Seacoast National Bank SPC Receivables Funding Trust I Stone Ridge Alternative Lending Risk Premium Fund US Holdings III LLC Theorem Main Master Fund LP Theorem Prime + Yield Fund Master LP Theorem Short Duration Liquidity Fund LP Trallem 2 Trust 2 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 By: Marlette Servicing, LLC, as Attomey in Fact By: Aba bhodes Chief Operating Officer Title: COO Date: As of the Closing Date listed on the Attachment TRUSTEE(S) OR OTHER AGENT(S): See Matrix below 3 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC XK3901 OR OTHER | LENAMES)_ ‘LOSING __ AGENT BALAN AS: DATE 1st Capital Bank 1st Capital Bank, a 4 California state- chartered bank CHARGEOFF_ SALE_inve_202211 07 11/14/2022 Auto Club Trust, Auto Club Trust, FSB 11/14/2022 FSB CHARGEOFF_ SALE_inve_202211 07 BAWAG Wilmington Savings Fund CHARGEOFF_ 11/14/2022 Society, FSB, not in its SALE_inve_202211 individual capacity but solely 07 as trustee of US Consumer Loan Trust, a Delaware common law trust Blackthorn 2018- CHARGEOFF_ 3 11/14/2022 A Wilmington Savings Fund SALE_inve_202211 Society, FSB, not in its 07 individual capacity but solely’ as Trustee for the Trust 4 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 CL Trust II UMB Bank, National 1 1/14/2022 Association CHARGEOFF_ SALE_inve_202211 07 Community First Community First Bank, a 1/14/2022 Bank Washington state-chartered bank CHARGEOFF_ SALE_inve_202211 07 Cross River Bank 17 1 1/14/2022 Wilmington Savings Fund Society, FSB CHARGEOFF _ SALE_inve_202211 07 Customers Bank Customers Bank, a Pennsylvania 1 1/14/2022 banking corporation CHARGEOFF _ SALE_inve_202211 07 DL Investment Compartment Moonstone 1, a 11/14/2022 Sarl CHARGEOFF_ SALE_inve_202211 07 A Cayman Islands Exempted. 11/14/2022 Limited Partnership Exigent CHARGEOFF_ Consumer Credit SALE_inve_202211 Fund LP 07 Hudson River 11/14/2022 Trust 2017-1 CHARGEOFF_ SALE_inve_202211 Cross River Bank, not in its 07 individual capacity, but solely in its capacity as Administrator for the Hudson River Trust Series 1-4] 5 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 Hudson River 11/14/2022 Trust 2017-3 Cross River Bank, not in its individual capacity, but solely in its capacity as Administrator for CHARGEOFF_ the Hudson River Trust Series 1- SALE_inve_202211 4 07 Wilmington Savings Fund 11/14/2022 Society, FSB Loan Asset CHARGEOFF_ Holdings Trust SALE_inve_202211 2020 M-1 07 Loan Asset Wilmington Savings Fund Society, CHARGEOFF _ 11/14/2022 Holdings Trust FSB SALE_inve_202211 2020-1 07 Wilmington Savings Fund Society, 11/14/2022 FSB Loan Asset CHARGEOFF _ Holdings Trust SALE_inve_202211 2021-M-1 07 Loan Asset Wilmington Savings Fund Society, CHARGEOFF _ 11/14/2022 Holdings Trust FSB SALE_inve_202211 2021-M-2 07 6 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 Loan Asset Wilmington Savings Fund CHARGEOFF _ 4 11/14/2022 Holdings Trust IT Society, FSB SALE_inve_202211 2020-1 07 Loan Asset Wilmington Savings Fund Society, CHARGEOFF _ 10 11/14/2022 Holdings Trust IT FSB SALE_inve_202211 2021-1 07 Loan Asset Wilmington CHARGEOFF _ 1 11/14/2022 Holdings Trust IT Savings Fund SALE_inve_202211| 2022-2 Society, FSB 07 MAPT 2019- Wilmington Trust, CHARGEOFF __ 1 11/14/2022 11A National SALE_inve_202211 Association, noot in its individuaal 07 capacity but solely as Owner Trustee MAPT 2019- 11/14/2022 12A Marlette Pass-Through Master CHARGEOFF _ Trust, Wilmington Trust, SALE_inve_202211 National Association 07 7 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 MAPT 2020-1A 11/14/2022 Marlette Pass-Through Master CHARGEOFF __ Trust, Wilmington Trust, SALE_inve_202211 National Association 07 Marlette Funding Marlette Funding Consumer Loan 11/14/2022 Consumer Loan Trust, a Delaware statutory trust Trust CHARGEOFF _ SALE_inve_202211 07 Marlette Funding Wilmington Savings Fund Society, 11/14/2022 Grantor Trust FSB 2018-1 CHARGEOFF _ SALE_inve_202211 07 Wilmington Savings Fund 11/14/2022 Society, FSB Marlette CHARGEOFF _ Funding Grantor SALE_inve_202211 Trust 2018-2 07 Wilmington Savings Fund 11/14/2022 Society, FSB Marlette CHARGEOFF __ Funding Grantor SALE_inve_202211 Trust 2018-3 07 Wilmington Savings Fund 11/14/2022 Society, FSB Marlette CHARGEOFF __ Funding Grantor SALE_inve_202211 Trust 2019-1 07 Wilmington Savings Fund 11/14/2022 Society, FSB Marlette CHARGEOFF _ Funding Grantor SALE_inve_202211 Trust 2019-2 07 8 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 Marlette Funding Wilmington Savings Fund CHARGEOFF __ 4 11/14/2022 Grantor Trust Society, FSB SALE_inve_202211 2019-3 07 Marlette Funding Wilmington Savings Fund Society, CHARGEOFF_ 11/14/2022 Grantor Trust FSB SALE_inve_202211 2019-4 07 CHARGEOFF _ 11/14/2022 SALE_inve_202211 07 Wilmington Savings Fund Society, Marlette Funding FSB, not in its individual capacity, but Grantor Trust solely in its capacity as Grantor 2020-1 Trust Trustee of the Grantor Trust Wilmington Savings Fund 11/14/2022 Society, FSB Marlette Funding CHARGEOFF _ Grantor Trust SALE_inve_202211 2020-2 07 Marlette Funding Wilmington Savings Fund CHARGEOFF _ 11/14/2022 Grantor Trust Society, FSB SALE_inve_202211 2021-1 07 9 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 Marlette Funding Wilmington Savings Fund CHARGEOFF _ 11/14/2022 Grantor Trust Society, FSB SALE_inve_202211 2021-2 07 Marlette Funding Wilmington Savings Fund CHARGEOFF __ 15 11/14/2022 Grantor Trust Society, FSB SALE_inve_202211 2021-3 07 Marlette Funding Wilmington Savings Fund CHARGEOFF _ 15 11/14/2022 Grantor Trust Society, FSB SALE_inve_202211 2022-1 07 Marlette Funding CHARGEOFF __ 11/14/2022 Grantor Trust Wilmington Savings Fund SALE_inve_202211 2022-2 07 Society, FSB, not in its individual capacity, but solely in its capacity as Grantor Trust Trustee of the Grantor Trust Marlette Funding} Wilmington Savings Fund CHARGEOFF _ 11/14/2022 Trust Society, FSB SALE_inve_202211 07 10 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 MCL Borrower MCL Borrower Trust, a CHARGEOFF _ 11/14/2022 Trust Delaware statutory trust SALE_inve_202211 07 MPL Trust I UMB Bank, National CHARGEOFF _ 11/14/2022 Association SALE_inve_202211 07 MPLI Capital Wilmington Savings Fund CHARGEOFF _ 24 11/14/2022 Holdings IT Society, FSB SALE_inve_202211 07 Pagaya CHARGEOFF_ 1 11/14/2022 Acquisition Trust SALE_inve_202211 Wilmington Trust, 07 National Association, Not in its individual capacity but solely as Depositor Trustee Pagaya CHARGEOFF _ 4 11/14/2022 Acquisition Trust SALE_inve_202211 Wilmington Trust, II 07 National Association, Not in its individual capacity but solely as Depositor Trustee 11 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 Pagaya AI Debt CHARGEOFF_ 41 11/14/2022 Grantor Trust SALE_inve_202211 Wilmington Trust, 07 2021-5 National Association, Not in its individual capacity but solely as Depositor Trustee Pagaya AI Debt CHARGEOFF _ 36 11/14/2022 Wilmington Trust, Grantor Trust SALE_inve_202211 National 07 2022-1 Association, Not in its individual capacity but solely s Depositor Trustee Pagaya AI Debt CHARGEOFF_ 3 11/14/2022 Grantor Trust SALE_inve_202211 Wilmington Trust, 2022-2 07 National Association, not in its individual capacity, but solely as Depositor Trustee Pagaya AI Debt CHARGEOFF_ 43 11/14/2022 Selection SALE_inve_202211 Wilmington Trust, Grantor 07 National Trust 2021-1 Association, Not in its individual capacity but solely as Depositor Trustee’ 12 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 Pagaya AI Debt CHARGEOFF_ 19 11/14/2022 Selection SALE_inve_202211 Wilmington Trust, Grantor 07 National Trust 2021-2 Association, Not in its individual capacity but solely as Depositor Trustee’ Pagaya AI Debt CHARGEOFF_ 94 11/14/2022 Selection SALE_inve_202211 Wilmington Trust, Grantor 07 National Trust 2021-3 Association, Not in its individual capacity but solely as Depositor Trustee Pagaya AI Debt CHARGEOFF_ 13 11/14/2022 Selection SALE_inve_202211 Wilmington Trust, Grantor 07 National Trust 2021- Association, Not in HG1 its individual capacity but solely as Depositor Trustee’ Pagaya Funding CHARGEOFF_ 8 11/14/2022 Trust SALE_inve_202211 Wilmington Trust, 07 National Association, Not in its individual capacity but solely as Depositor Trustee Pagaya Funding Wilmington Trust, 11/14/2022 Trust IT National Association, Not in its individual capacity but solely CHARGEOFF_ as Depositor SALE_inve_202211 Trustee 07 13 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 PML Trust I 20 11/14/2022 UMB Bank, CHARGEOFF_ National SALE_inve_202211 Association, FSB 07 Red Marble Trust 11/14/2022 Wilmington Trust, CHARGEOFF_ National SALE_inve_202211 Association 07 Secoast CHARGEOFF_ 11/14/2022 National SALE_inve_202211 Seacost National Bank 07 Bank, a national banking association the successor by merger to Drummond Community Bank SPC 11/14/2022 Receivables Funding Trust I Wilmington Trust, CHARGEOFF_ National SALE_inve_202211 Association 07 Stone Ridge Wilmington Savings CHARGEOFF_ 11/14/2022 Alternative SALE_inve_202211 Fund Society, FSB, Lending Risk 07 not in its individual Premium Fund capacity but solely US Holdings III as trustee of LLC Alternative Lending Holdings Trust IV 14 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 Theorem Main| Theorem Partners LLC, its| CHARGEOFF _ 17 11/14/2022 Master Fund general partner SALE_inve_202211 LP 07 Theorem Prime | Theorem Partners LLC, its 11/14/2022 + general partner Yield Fund CHARGEOFF_ Master LP SALE_inve_202211 07 Theorem Partners LLC, its CHARGEOFF_ 6 11/14/2022 Theorem Short general partner SALE_inve_202211 07 Duration Liquidity Fund LP Trallem 2 Trust CHARGEOFF_ 3 11/14/2022 SALE_inve_202211 Wilmington Trust, National 07 Association, Not in its individual capacity but solely as Trustee = 15 Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC X3901 EXHIBIT B Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC begtbae DATE: 3/18/2021 TRUTH IN LENDING DISCLOSURE STATEMENT Lender Borrower Cross River Bank Russell Clum 885 Teaneck Road Teaneck, NJ 07666 ANNUAL FINANCE CHARGE Amount Financed Total of Payments PERCENTAGE RATE The dollar amount the The amount of credit The amount you will The cost of your credit credit will cost you provided to you or on have paid after you at a yearly rate your behalf have made all payments as scheduled 29.70% $1,767.72 $3,384.36 $5,152.08 Your payment schedule will be as follows: Number of Payments. Amounts When payments are due 35 First payment is due on 4/17/2021, $143.12 and then monthly on the same date $142.88 thereafter. Late charges: If your payment arrives after your 3-day grace period, you will be charged a late fee in the amount of $15. This fee is charged only once per late payment. Prepayment policy: If you pay off your loan in advance, you will not be charged a penalty. In the event of a prepayment, you will not be entitled to a refund of any pre-paid finance charges or other fees. See your Loan Agreement for any additional information about nonpayment, default or other matters related to your loan. 3c0226¢7-800d-4531-a57a-0344226F1dae Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC Itemization of amount financed: Amount of Your Loan: $3, 600.00 Origination Fee: $215.64 Amount Given to You Directly or your designee: $3, 384.36 Annual Loan Interest Rate: 24.99%. Interest at this Loan Interest Rate plus the Origination Fee results in the Finance Charge and Annual Percentage Rate disclosed above. 3c0226¢7-800d-4531-a57a-0344226F1dae Filing 194442371 Pca Acquisitions V, Llc v. Russell Clum 05-2024-SC-020925-XXSC-BC Transaction History (Redacted to mit information to specifi account) Transaction History sre eect snmp sects pane tons anat tele scion anon Apdo, ch agrees dare of as Pinball sei a ane a Pa Cum raat. 03182021 1110), Boating ‘RAR nen en meena sete cone en sen | FAA Russel un ‘nea (wT 210. Seti Pant 1B.12 TTAPRON an BY a spt ncn nmin sna nnn arn |e Cum H7sen88 O72021 210. Sete Pam 1G.12 ‘AON NB na ror ae promenemerren rcerehensesarnsntsfmennenn:hrnn seen ete RGD Rusel Cun re amon 210) Stel ant 13.2 TUN Hn 18 Ba fees nln nt nnn in aan nn HM Rasel Cum Tat 210 Shida 1G.12 man a 8H ene sn spent meinen rt nent ob is Cun ‘ete orate 210) Stel an 18.12 ‘frocraoa Bm ABI ncn patric nan sents | $38. Russel Chun GTM tran 210 Shi Pans 142 ‘tone BIG HL ore rhs artnet tintin mainstem mnt se ‘EGY. 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