Preview
System Generated Hearing Date: 1/9/2025 9:00 AM
Location: Court Room 1101
Judge: Allegretti, ) ohn Michael
FILED
4/11/2024 12:05 PM
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS IRIS Y. MARTINEZ
CIRCUIT CLERK
FIRST MUNICIPAL FOR GT oo05
COOK COUNTY, IL
20241109005
SYNCHRONY BANK Case No. —-----------_-_____ Courtroom,
Courtroom 1101
Plaintiff 27219793
vs
Amount Claimed: $2,832.05
FELICE L WALLACE
Defendant
VERIFIED COMPLAINT AT LAW
SYNCHRONY BANK ("Plaintiff"), by and through its attorneys, Lloyd & McDaniel,
PLC, complains of FELICE L WALLACE ("Defendant"), as follows:
1 Pursuant to 735 ILCS 5/2-101, venue is proper with this Court based on the Defendant
residing within the jurisdiction of this Court and the State of Illinois.
On or about January 10, 2022, Plaintiff issued a credit card account in the Defendant's
name.
Defendant used or authorized use of the account and thereby became obligated to pay for
the charges incurred with the card.
Monthly account statements were sent from Plaintiff to the Defendant, stating, inter alia,
charges incurred with the credit card account, the monthly payment due, and the total
balance. To the best of Plaintiff’s knowledge, there are no unresolved disputes in relation
to the monthly bills or the charges contained therein. W.E. Erickson Construction, Inc. v.
Congress-Kenilworth Corp., 477 N.E.2d 513, 520 (Ill. App. Ct. 1st Dist. 1985); Motive
Parts Co. of Am., Inc. v. Robinson, 369 N.E.2d 119, 122 (Ill. App. Ct. 1st Dist. 1977).
On or about August 16, 2023, said account was charged off after Defendant defaulted by
failing to pay for the indebtedness incurred on said account.
This Complaint is filed within the relevant statute of limitations.
The account has an unpaid balance of $2,832.05, as set forth in the Affidavit and
additional documentation attached hereto.
Due demand has been made on Defendant to pay this amount, and Defendant has failed
to do so.
WHEREFORE, Plaintiff, SY NCHRONY BANK, prays that a judgment against the
Defendant, FELICE L WALLACE, be entered for $2,832.05, plus court costs; and for such other
and further relief as this Court deems just and proper.
Respectfully Submitted,
/s/ Scott Burns
—--- +
Courtney E. Carr
Scott T. Burns
Louis S. Freedman
Jonathan Kutilek
Eric Spagnuolo
Megan Urban
Ashley M. Nonis-Hartman
Firm No.: 64626
LLOYD & McDANIEL, PLC
Attorneys for Plaintiff
P.O. Box 23200 | Louisville, KY 40223-0200
Toll Free: 866.585.1880 | Fax: 502.585.3054
courts@ lloydmc.com
586267/PILCP1/CJ2
This communication is from a debt collector.
EXHIBIT I
SYNCHRONY BANK , FILED
4/11/2024 12:05 PM
Plaintiff IRIS Y. MARTINEZ
v. CIRCUIT CLERK
COOK COUNTY, IL
FELICE L WALLACE 20241109005
Defendant(s) Courtroom, 1101
CREDIT CARD OR DEBT BUYER COLLECTION ACTION AFFIDAVIT
(SUPREME COURT RULE 280.2)
INSTRUCTIONS: Provide the following information and documents. Supreme Court Rule 280.1
provides the definitions of the terms in this Affidavit.
Comes now Affiant, and states:
X_ Jama designated Agent of SYNCHRONY BANK (Plaintiff)
Iam 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 Plaintiffs business and/or my personal
knowledge:
1 IDENTIFICATION ABOUT THE CONSUMER DEBT OR ACCOUNT
Complete the tables below.
a. As of charge-off date:
Full name of the defendant Last four Date the account was Nature of the debt,
as it appears on the account digits of the opened or the debt (credit card debt,
Full name of payday loan, retail inst|
the creditor account originated
allment loan, etc.
number
SYNCHRONY | FELICE L WALLACE 2351 01/10/2022 credit card debt
BANK
Version: 1.0_IL_06_07_2020
b. The most recent activity on the account prior to or after charge-off, includes:
Charge-off Balance | Charge-off Date Date of Last Amount of Last Total Amount of credits
Payment Payment
and/or Payments Since
Charge-off Date*
$2,832.05 08/16/2023 vnsran2 $40.00 $0.00
*Last payment on the account, pre or post charge off.
**Credits or payments made within 30 days of the signing of this affidavit may not be reflected
c.For a revolving credit account, plaintiff further certifies that it has in its possession and can
produce on request the most recent monthly statement recording a purchase, transaction, last
payment or balance transfer.
2 PROOF OF OWNERSHIP OR RIGHT TO SUE FOR DEBT BUYERS
Complete the table and list the prior owners or creditors since the charge-off date.
Start with the first assignment through the current creditor or owner of the consumer
debt. List in chronological order, beginning with the first assignment:
From (Name) To (Name) Date of Assignment
(On or About)
X_ Does not apply - Plaintiff is the charge-off creditor.
Version: 1.0_IL_06_07_2020
'
3. ADDITIONAL ACCOUNT INFORMATION AFTER CHARGE-OFF
xX NO '
__YES
_— Total amount of interest accrued: $ 4
__ Total amount of non-interest charges or fee accrued $
Plaintiff is seeking attorney's fees in the amount of $
__ Returned payment(s) in the amount of $.
Balance due and owing as of date of affidavit: $2,832.05
* Costs paid for in the Complaint will not be reflected.
uy
CRISTOPHER DEJESUS Monday, March 18, 2024
Name of Affiant Signature of Affiant Date
Notary Public
UL sa Notary RISTIAN DELAY
Public - Stat te Of
seal
Florid
‘Ommission # Hj 1H 47325; a
Expires Dec 14, 2027
National N
atary Assn,
My commission expires: lP7
Version: 1.0_IL_06_07_2020
)_IL._06_{
P creo
Statement Closing Date: 07/18/23
Need More Information?
View your account online at paypal.com
Days in Billing Period: 32 Or call 1-844-377-4136 8 AM ET to 11 PMET
Account Number j2354
Customer Name: FELICE L WALLACE
Mon-Fri and 9 AM ET to 9 PM ET Sat-Sun
ACCOUNT SUMMARY PAYMENT INFORMATION
Previous Balance $2,680.77 New Balance $2,791.05
= Payments & Credits $0.00 Amount Past Due $641.00
+ Purchases & Adjustments $0.00 Minimum Payment Due ‘$778.00
+ Fees $41.00 Payment Due Date 08/10/23
+ INTEREST CHARGES $69.28 Amount to avoid Standard and Deferred Interest
= New Balance $2,791.05 ‘on your next statement: $2,791.05
See Reverse
Credit Limit $2,200.00 Late Payment Waming: If we do not receive your minimum payment
Available Credit OVERLIMIT by 08/10/23, you may have to pay a late fee of up to $41.00,
Minimum Payment Warning: If you make only the minimum
payment each period, you will pay more in interest and it will
take you longer to pay off your balance. For example:
TK dob
a ‘
‘Only the minimum 9 Years $5,929.00
Payment
If you would like information about credit counseling services, call
4-877-302-8775.
aR es aE oe
TAC Bas Bs se oa
Preview
System Generated Hearing Date: 1/9/2025 9:00 AM Location: Court Room 1101 Judge: Allegretti, ) ohn Michael FILED 4/11/2024 12:05 PM IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS IRIS Y. MARTINEZ CIRCUIT CLERK FIRST MUNICIPAL FOR GT oo05 COOK COUNTY, IL 20241109005 SYNCHRONY BANK Case No. —-----------_-_____ Courtroom, Courtroom 1101 Plaintiff 27219793 vs Amount Claimed: $2,832.05 FELICE L WALLACE Defendant VERIFIED COMPLAINT AT LAW SYNCHRONY BANK ("Plaintiff"), by and through its attorneys, Lloyd & McDaniel, PLC, complains of FELICE L WALLACE ("Defendant"), as follows: 1 Pursuant to 735 ILCS 5/2-101, venue is proper with this Court based on the Defendant residing within the jurisdiction of this Court and the State of Illinois. On or about January 10, 2022, Plaintiff issued a credit card account in the Defendant's name. Defendant used or authorized use of the account and thereby became obligated to pay for the charges incurred with the card. Monthly account statements were sent from Plaintiff to the Defendant, stating, inter alia, charges incurred with the credit card account, the monthly payment due, and the total balance. To the best of Plaintiff’s knowledge, there are no unresolved disputes in relation to the monthly bills or the charges contained therein. W.E. Erickson Construction, Inc. v. Congress-Kenilworth Corp., 477 N.E.2d 513, 520 (Ill. App. Ct. 1st Dist. 1985); Motive Parts Co. of Am., Inc. v. Robinson, 369 N.E.2d 119, 122 (Ill. App. Ct. 1st Dist. 1977). On or about August 16, 2023, said account was charged off after Defendant defaulted by failing to pay for the indebtedness incurred on said account. This Complaint is filed within the relevant statute of limitations. The account has an unpaid balance of $2,832.05, as set forth in the Affidavit and additional documentation attached hereto. Due demand has been made on Defendant to pay this amount, and Defendant has failed to do so. WHEREFORE, Plaintiff, SY NCHRONY BANK, prays that a judgment against the Defendant, FELICE L WALLACE, be entered for $2,832.05, plus court costs; and for such other and further relief as this Court deems just and proper. Respectfully Submitted, /s/ Scott Burns —--- + Courtney E. Carr Scott T. Burns Louis S. Freedman Jonathan Kutilek Eric Spagnuolo Megan Urban Ashley M. Nonis-Hartman Firm No.: 64626 LLOYD & McDANIEL, PLC Attorneys for Plaintiff P.O. Box 23200 | Louisville, KY 40223-0200 Toll Free: 866.585.1880 | Fax: 502.585.3054 courts@ lloydmc.com 586267/PILCP1/CJ2 This communication is from a debt collector. EXHIBIT I SYNCHRONY BANK , FILED 4/11/2024 12:05 PM Plaintiff IRIS Y. MARTINEZ v. CIRCUIT CLERK COOK COUNTY, IL FELICE L WALLACE 20241109005 Defendant(s) Courtroom, 1101 CREDIT CARD OR DEBT BUYER COLLECTION ACTION AFFIDAVIT (SUPREME COURT RULE 280.2) INSTRUCTIONS: Provide the following information and documents. Supreme Court Rule 280.1 provides the definitions of the terms in this Affidavit. Comes now Affiant, and states: X_ Jama designated Agent of SYNCHRONY BANK (Plaintiff) Iam 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 Plaintiffs business and/or my personal knowledge: 1 IDENTIFICATION ABOUT THE CONSUMER DEBT OR ACCOUNT Complete the tables below. a. As of charge-off date: Full name of the defendant Last four Date the account was Nature of the debt, as it appears on the account digits of the opened or the debt (credit card debt, Full name of payday loan, retail inst| the creditor account originated allment loan, etc. number SYNCHRONY | FELICE L WALLACE 2351 01/10/2022 credit card debt BANK Version: 1.0_IL_06_07_2020 b. The most recent activity on the account prior to or after charge-off, includes: Charge-off Balance | Charge-off Date Date of Last Amount of Last Total Amount of credits Payment Payment and/or Payments Since Charge-off Date* $2,832.05 08/16/2023 vnsran2 $40.00 $0.00 *Last payment on the account, pre or post charge off. **Credits or payments made within 30 days of the signing of this affidavit may not be reflected c.For a revolving credit account, plaintiff further certifies that it has in its possession and can produce on request the most recent monthly statement recording a purchase, transaction, last payment or balance transfer. 2 PROOF OF OWNERSHIP OR RIGHT TO SUE FOR DEBT BUYERS Complete the table and list the prior owners or creditors since the charge-off date. Start with the first assignment through the current creditor or owner of the consumer debt. List in chronological order, beginning with the first assignment: From (Name) To (Name) Date of Assignment (On or About) X_ Does not apply - Plaintiff is the charge-off creditor. Version: 1.0_IL_06_07_2020 ' 3. ADDITIONAL ACCOUNT INFORMATION AFTER CHARGE-OFF xX NO ' __YES _— Total amount of interest accrued: $ 4 __ Total amount of non-interest charges or fee accrued $ Plaintiff is seeking attorney's fees in the amount of $ __ Returned payment(s) in the amount of $. Balance due and owing as of date of affidavit: $2,832.05 * Costs paid for in the Complaint will not be reflected. uy CRISTOPHER DEJESUS Monday, March 18, 2024 Name of Affiant Signature of Affiant Date Notary Public UL sa Notary RISTIAN DELAY Public - Stat te Of seal Florid ‘Ommission # Hj 1H 47325; a Expires Dec 14, 2027 National N atary Assn, My commission expires: lP7 Version: 1.0_IL_06_07_2020 )_IL._06_{ P creo Statement Closing Date: 07/18/23 Need More Information? View your account online at paypal.com Days in Billing Period: 32 Or call 1-844-377-4136 8 AM ET to 11 PMET Account Number j2354 Customer Name: FELICE L WALLACE Mon-Fri and 9 AM ET to 9 PM ET Sat-Sun ACCOUNT SUMMARY PAYMENT INFORMATION Previous Balance $2,680.77 New Balance $2,791.05 = Payments & Credits $0.00 Amount Past Due $641.00 + Purchases & Adjustments $0.00 Minimum Payment Due ‘$778.00 + Fees $41.00 Payment Due Date 08/10/23 + INTEREST CHARGES $69.28 Amount to avoid Standard and Deferred Interest = New Balance $2,791.05 ‘on your next statement: $2,791.05 See Reverse Credit Limit $2,200.00 Late Payment Waming: If we do not receive your minimum payment Available Credit OVERLIMIT by 08/10/23, you may have to pay a late fee of up to $41.00, Minimum Payment Warning: If you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: TK dob a ‘ ‘Only the minimum 9 Years $5,929.00 Payment If you would like information about credit counseling services, call 4-877-302-8775. aR es aE oe TAC Bas Bs se oa