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02D09-2406-CC-002119 Filed: 6/13/2024 10:26 AM
Clerk
Allen Superior Court 9 Allen County, Indiana
KG
STATE OF INDIANA IN THE ALLEN SUPERIOR COURT
SS:
COUNTY OF ALLEN CAUSE NO.
CREDITMAX, INC.,
(as Assignee of American
International Finance, Inc.)
Plaintiff, )
VS. )
AHMED JONES
Defendant
COMPLAINT
COMES NOW Plaintiff, CreditMax, Inc., by counsel, and for its Complaint and cause of action
against the Defendant, alleges and says:
1. That Plaintiff is a corporation duly organized and existing under and by virtue of the laws of
the State of Indiana, and as such is authorized to do business within the State.
2. On or about October 22, 2022, in Fort Wayne, IN, Defendant, Ahmed Jones, made, executed
and delivered to Carplex, Inc. (hereinafter referred to as "Seller") a written Retail Installment
Contract (hereinafter referred to as "Agreement") a true and accurate copy of which is
attached hereto as Exhibit "A", and made a part hereof, wherein the Defendant promised to
pay Seller the sum of thirty-one thousand, five hundred, eighty dollars and fiftyfour cents
($31,580.54) as shown in Exhibit "A".
3. In exchange for the abovementioned promise to pay, Defendant, Ahmed Jones, received the
subject motor vehicle namely a 2021 Kia Sportage, more particularly described and identified
in Exhibit "A" attached hereto and made a part hereof.
4. Defendant did not pay thereon as agreed, and Seller declared a principal balance of nine
thousand, eight hundred, fifteen dollars and zero cents ($9,815.00) due and payable.
5. Interest due on the Agreement will continue to accrue at the contract rate of 12.90%. The
interest earned to date on the balance due is zero dollars and zero cents ($0.00).
6. The contract provides for the reimbursement of collateral disposition fees expended. The
total cost of disposition, including but not limited to repossession and reconditioning costs is
zero dollars and zero cents ($0.00).
7. 0n or about October 22, 2022, all rights, title and interest of the Seller in and to the
Agreement was sold, transferred, conveyed and assigned to American International Finance,
Inc. for good and valuable consideration and the Defendant was notified immediately
thereafter.
8. On or about December 18, 2023, American International Finance, Inc. assigned to Plaintiff,
CreditMax, Inc., for valuable consideration, its interest in this matter, for the purpose of
collecting upon the amount due as demonstrated by the Assignment and by the Affidavit of
Debt both of which are attached hereto and made part hereof as Exhibits "B" and "C".
WHERFORE, Plaintiff demands judgment against the Defendant for the principal of nine
thousand, eight hundred, fifteen dollars and zero cents ($9,815.00), prej udgment interest earned
of
zero dollars and zero cents ($0.00), and collateral disposition fees of zero dollars and zero cents
zero cents ($9,815.00), and all
($0.00), for a total of nine thousand, eight hundred, fifteen dollars and
other proper relief.
/s/Michael E. Cook
Dated: June 7, 2024
Michael E. Cook (Attorney ID 15720-43)
Attorney for Plaintiff
12820 Goldwater Road, Suite G
Fort Wayne, IN 46845-8755
(260) 637-0257
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02D09-2406-CC-002119 Filed: 6/13/2024 10:26 AM Clerk Allen Superior Court 9 Allen County, Indiana KG STATE OF INDIANA IN THE ALLEN SUPERIOR COURT SS: COUNTY OF ALLEN CAUSE NO. CREDITMAX, INC., (as Assignee of American International Finance, Inc.) Plaintiff, ) VS. ) AHMED JONES Defendant COMPLAINT COMES NOW Plaintiff, CreditMax, Inc., by counsel, and for its Complaint and cause of action against the Defendant, alleges and says: 1. That Plaintiff is a corporation duly organized and existing under and by virtue of the laws of the State of Indiana, and as such is authorized to do business within the State. 2. On or about October 22, 2022, in Fort Wayne, IN, Defendant, Ahmed Jones, made, executed and delivered to Carplex, Inc. (hereinafter referred to as "Seller") a written Retail Installment Contract (hereinafter referred to as "Agreement") a true and accurate copy of which is attached hereto as Exhibit "A", and made a part hereof, wherein the Defendant promised to pay Seller the sum of thirty-one thousand, five hundred, eighty dollars and fiftyfour cents ($31,580.54) as shown in Exhibit "A". 3. In exchange for the abovementioned promise to pay, Defendant, Ahmed Jones, received the subject motor vehicle namely a 2021 Kia Sportage, more particularly described and identified in Exhibit "A" attached hereto and made a part hereof. 4. Defendant did not pay thereon as agreed, and Seller declared a principal balance of nine thousand, eight hundred, fifteen dollars and zero cents ($9,815.00) due and payable. 5. Interest due on the Agreement will continue to accrue at the contract rate of 12.90%. The interest earned to date on the balance due is zero dollars and zero cents ($0.00). 6. The contract provides for the reimbursement of collateral disposition fees expended. The total cost of disposition, including but not limited to repossession and reconditioning costs is zero dollars and zero cents ($0.00). 7. 0n or about October 22, 2022, all rights, title and interest of the Seller in and to the Agreement was sold, transferred, conveyed and assigned to American International Finance, Inc. for good and valuable consideration and the Defendant was notified immediately thereafter. 8. On or about December 18, 2023, American International Finance, Inc. assigned to Plaintiff, CreditMax, Inc., for valuable consideration, its interest in this matter, for the purpose of collecting upon the amount due as demonstrated by the Assignment and by the Affidavit of Debt both of which are attached hereto and made part hereof as Exhibits "B" and "C". WHERFORE, Plaintiff demands judgment against the Defendant for the principal of nine thousand, eight hundred, fifteen dollars and zero cents ($9,815.00), prej udgment interest earned of zero dollars and zero cents ($0.00), and collateral disposition fees of zero dollars and zero cents zero cents ($9,815.00), and all ($0.00), for a total of nine thousand, eight hundred, fifteen dollars and other proper relief. /s/Michael E. Cook Dated: June 7, 2024 Michael E. Cook (Attorney ID 15720-43) Attorney for Plaintiff 12820 Goldwater Road, Suite G Fort Wayne, IN 46845-8755 (260) 637-0257