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MISHAELA J. GRAVES, State Bar No.: 259765
KRISTY GABRIELOVA, State Bar No.: 274827
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PATRICK T. SULLIVAN, State Bar No.: 263613 F
F Superior Court of California
DEANNA FRASER, State Bar No.: 270362
CHAD K. CASEY, State Bar No.: 297552 | County of Butte \
10601-G TIERRASANTA BLVD, #4540 L JUN, 22 2017 L
SAN DIEGO, CA 92124 E
Telephone: (866) 300-8750
Facsimile: (858) 309-1588
D
By
yf Hey
Deputy
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Attorneys for Plaintiff
SUPERIOR COURT OF CALIFORNIA
COUNTY OF BUTTE
CHICO COURTHOUSE
MIDLAND FUNDING LLC Case No. VF 0 17 44
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Plaintiff, COMPLAINT FOR:
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vs. (1) Account Stated
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13 URIEL VELEZ; PRAYER AMT: $1,262.43
and DOES 1through 10, inclusive LIMITED
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Defendant.
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16 1 Plaintiff, MIDLAND FUNDING LLC ("Plaintiff"), is a Limited Liability Company
17 qualified to do business in California.
18 2. This court is the proper court because Plaintiff is informed and believes that Defendant
URIEL VELEZ ("Defendant"), is a resident of BUTTE County, State of California.
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3 Plaintiff is unaware of the true names and capacities of Defendants sued by the fictitious
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names DOES | through 10. Plaintiff will ask leave of court to amend this complaint as and when the true
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names and capacities of Defendants named herein as DOES | through 10 have been ascertained.
22 4 At all times herein mentioned, Defendants, and each of them, were the principals, agents,
23 employers, employees, masters, or servants of each of their co-defendants and ratified, adopted or
24 approved the acts or omissions alleged herein, and each defendant, in doing the things alleged, were
25 acting in the course and scope of said authority of such agents, servants, and employees.
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5 Pursuant to California Civil Code §1788.58(a)(1), Plaintiff is a debt buyer as defined by
California Civil Code §1788.50(a).
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28
ale
COMPLAINT
CA_0132G File No.: 17-51726
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6. Pursuant to California Civil Code §1788.58(a)(2), is seeking to recover the amount of
$1,262.43. This is the amount due on credit card account number XXXXXXXXXXXX-6755
("Account")! which was originally issued by CITIBANK, N.A.. The amount due is the result of
transactions that occurred on the Account.
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Pursuant to California Civil Code §1788.58(a)(3), Plaintiff is the sole owner of the debt.
Attached hereto and incorporated herein by reference as Exhibit A is a true and correct copy of the Bill of
Sale from CITIBANK, N.A. to Plaintiff. The account was purchased by the Plaintiff on May 21, 2015.
8. Pursuant to California Civil Code §1788.58(a)(4), the Account balance at the time of
charge-off was $1,262.43.
9 Plaintiff is not seeking to recover any post charge-off interest and/or fees. However, in
accordance with California Civil Code §1788.58(a)(4), the following is explanation of the amount that
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the Plaintiff is seeking to recover:
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Charge-off Balance? $1,262.43
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Total Post Charge-Off Interest $0.00
13 Total Post Charge-Off Fees? $0.00
14 10. Pursuant to California Civil Code §1788.58(a)(5), Plaintiff alleges that the date of default
15 is August 01, 2014 and the date of the last payment was July 05, 2014 which was made to CITIBANK,
16 N.A..
11. Pursuant to California Civil Code §1788.58(a)(6), Plaintiff alleges that the name of the
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charge-off creditor at the time of the charge-off is CITIBANK, N.A.. On information and belief the
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Plaintiff alleges that an address utilized by CITIBANK, N.A. at the time of charge-off was 701 EAST
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60TH STREET NORTH SIOUX FALLS SD 57117. At the time of charge off the account number
20 associated with the debt was XXXXXXXXXXXX-6755.
21 12. Pursuant to California Civil Code §1788.58(a)(7), Plaintiff alleges that the name of the
22 debtor as it appeared in the records of CITIBANK, N.A. is URIEL VELEZ and the last known address as
23 it appeared in the records of CITIBANK, N.A. is 3276 NORD AVE CHICO CA 95973.
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} Pursuant to California Rule of Court and California Civil Code §1788.58(c) the Account number has
25 been redacted to protect the Defendant's confidential information.
? This amount may include the charged-off principal amount and pre-charge-off accrued interest as set
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forth in the seller data sheet attachedhereto and incorporated herein by reference as Exhibit A.
27 3 This amount is not reflective of the costs incurred in the filing and service of this action which are
recoverable pursuant to California Code of Civil Procedure §1033.5.
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2.
COMPLAINT
(CA_0132G File No.: 17-51726
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13. Pursuant to California Civil Code §1788.58(a)(8), Plaintiff alleges that the name and address of
all post charge-off purchasers of the debt are as follows:
Name Address
ATLANTIC CREDIT & FINANCE SPECIAL 3353 ORANGE AVE ROANOKE VA 24012
FINANCE UNIT, LLC
MIDLAND FUNDING LLC 2365 NORTHSIDE DRIVE SUITE 300 SAN DIEGO CA
92108
14, Pursuant to California Civil Code §1788.58(a)(9) Plaintiff alleges that it has complied
with the provisions of Civil Code §1788.52 and that it informed Defendant of the assignment of the
account. Attached hereto and incorporated herein by reference as Exhibit B is a true and correct copy of
the first written communication sent to the consumer by Plaintiff.
15. Pursuant to California Civil Code §1788.58(b) attached hereto and incorporated herein
10 by reference as Exhibit C is a true and correct copy of a monthly statement recording a purchase
Il transaction, payment or balance transfer while the account was active as required by California Civil
12 Code §1788.52(b).
16. The Account balance at the time of charge-off was $1,262.43, attached hereto and
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incorporated herein by reference as Exhibit D is a true and correct copy of a billing statement that was
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mailed to Defendant stating the balance due on the Account at or around the time of charge-off.
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17. By this complaint, Plaintiff seeks to recover amounts of $1,262.43 from Defendant.
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18. As alleged above, before filing this suit, all right, title and interest to the Account were
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sold and assigned to Plaintiff. Plaintiff owns the Account and is entitled to collect on the Account as if it
18 were the original creditor. To the extent that Plaintiff acts in its capacity as successor-in-interest to the
19 original creditor or its assigns, references herein to Plaintiff may include Plaintiff's predecessor-in-
20 interest.
21 19, Before commencement of this action, Plaintiff informed Defendant in writing that it
22 intended to file this action and that this action could result in a judgment against Defendant that would
include court costs allowed by California Code of Civil Procedure § 1033(b)(2). Attached hereto and
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incorporated herein by reference as Exhibit E is a copy of Plaintiff’s most recent attempt at resolving the
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underlying obligation.
25
MIDLAND'S EFFORTS TO RESOLVE THE UNDERLYING OBLIGATION
26 20. Plaintiff MIDLAND FUNDING LLC owns portfolios of consumer receivables, which it
27 attempts to collect. Plaintiff MIDLAND FUNDING LLC and its affiliates (collectively, “MIDLAND”)
28 generally attempt to contact consumers like Defendant through several means, such as phone calls,
letters, or other means, all in an effort to establish contact and to resolve the underlying obligation.
COMPLAINT
CA_0132G File No.: 17-51726
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In doing so, MIDLAND attempts to assess each consumer’s willingness to pay, through phone calls,
letters or other means. MIDLAND attempts to exclude consumers from its collection efforts, where
MIDLAND believes those consumers are facing extenuating circumstances or hardships that would
prevent them from making any payments.
21. When MIDLAND contacts consumers, it strives to treat consumers with respect,
compassion, and integrity. MIDLAND works with consumers in an effort to find mutually-beneficial
solutions, often offering discounts, hardship plans, and payment options. MIDLAND’s efforts are aimed
at working with consumers to repay their obligations and to attain financial recovery. MIDLAND strives
to engage in dialogue that is honorable and constructive, and to play a positive role in consumers’ lives.
22. Despite MIDLAND’ efforts to reach consumers and resolve the consumer’s obligations,
only a percentage of consumers choose to engage with MIDLAND. Those who do are often offered
discounts or payment plans that are intended to suit their needs. MIDLAND would prefer to work with
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consumers to establish voluntary payment arrangements resulting in the resolution of any underlying
M1
obligations.
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23. However, the majority of MIDLAND’s consumers ignore calls or letters, and some
13 simply refuse to repay their obligations despite an apparent ability to do so. When this happens,
14 MIDLAND must decide then whether to pursue collection through legal channels, including litigation
15 like the present action against Defendant. Although the Account is now in litigation, Plaintiff remains
16 willing to explore a mutually-beneficial solution through voluntary payment arrangements, if possible.
FIRST CAUSE OF ACTION
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ACCOUNT STATED - AGAINST ALL DEFENDANTS
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24, Plaintiff realleges and incorporates by reference the foregoing paragraphs.
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25. Defendant opened, used, and derived benefit from the Account through Defendant’s own
20 use of the Account or by another’s use at Defendant’s direction. By using the Account, Defendant
21 expressly agreed or impliedly promised to repay Plaintiff.
22 26. Within the last four (4) years, Defendant became indebted on the Account to Plaintiff in
23 the sum of $1,262.43 on an account stated in writing by and between Plaintiff and Defendant in which it
was agreed that Defendant was indebted to Plaintiff.
24
27. Regular monthly statements were mailed to Defendant listing the debits, credits, and
25
balance due on the Account, attached as Exhibit D.
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COMPLAINT
CA_0132G File No.: 17-51726
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28. Defendant last made a payment on the Account on July 05, 2014 to CITIBANK, N.A..
1 29. Plaintiff has no record of Defendant objecting to the monthly statements after receipt.
30. Plaintiff has made demand on Defendant for repayment of the account stated but
Defendant has failed to pay the balance due. Attached hereto and incorporated herein by reference as
Exhibit B is a true and correct copy of first written communication requesting payment that was sent to
the consumer by Plaintiff.
31. As of the date of this complaint there is due and owing the unpaid sum of $1,262.43.
This amount was arrived by subtracting all payments and applying all credits (if any) to the charge-off
balance of $1,262.43 as indicated on the charge-off statement, attached here to as Exhibit D.
WHEREFORE, Plaintiff prays for judgment against Defendant as follows:
On the First Cause of Action:
1 For the unpaid balance of $1,262.43;
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2. Costs of suit;
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3 Such other relief as the Court may deem just and proper.
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14 Dated: JUN 1 1 2017 MIDLAND FUNDING LLC
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16 ‘Andrew E. Asch #198857
By
MISHAELA J. GRAVES
17 LIKRISTY GABRIELOVA
18 CIPATRICK T. SULLIVAN
(DEANNA FRASER
19 LICHAD K. CASEY
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COMPLAINT
CA_0132G File No.: 17-51726
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EXHIBIT A
AA_0125 File No.: 17-51726
BILL OF SALE
FOR GOOD AND VALUABLE CONSIDERATION, the receipt and sufficiency of
which is hereby acknowledged, [ATLANTIC CREDIT & FINANCE SPECIAL FINANCE
UNIT, LLC, a Virginia limited liability company], (“Seller”) hereby sells, assigns, transfers,
conveys and delivers to MIDLAND FUNDING LLC, a Delaware limited liability company
(“Buyer”) all rights, title and interests in and to each and every one of the purchased accounts
described in the purchased accounts files identificd on Schedule A, attached hereto and
incorporated by this reference (“Purchased Accounts”).
To the best of Seller’s knowledge and belief, all of the information contained in the files
for the Purchased Accounts, Seller’s chain of title file, and Seller’s accounts information, is and
shall be true, complete, accurate and not misleading in any material respect, Further, all of the
information contained in the files for the Purchased Accounts, Seller’s chain of title file, and
Seller’s accounts information (a) constitutes Seller’s own business records regarding the
Purchased Accounts; and (b) accurately reflects in all material respects the information about the
purchased accounts in Seller’s possession. All of the files for the Purchased Accounts, Seller’s
chain of title file, and Seller’s accounts information have been kept in the regular course of
Seller’s business,.and were made or compiled at or near the time of the event and recorded by (or
from information transmitted by) a person (i) with knowledge of the data entered into and
maintained in Seller’s business records, or (ii) who caused the data to be entered into and
maintained in Seller’s business records. It is the regular practice of Seller’s business to maintain
and compile such data.
IN WITNESS WHEREOF, the parties hereto have executed this Bill of Sale as of May 21, 2015
{ATLANTIC CREDIT & FINANCE SPECIAL
FINANCE UNIT, LLC,
a Virginia limited liability company]
By:
Name: as
Title
Buyer hereby accepts and agrees to all matters set forth herein.
MIDLA FUNDING LLC,
a Dela limited liability company
By: =
Name:
Title: “PRES Ser
CHI 65769192v2
~
HEDULE A
Purchased Accounts
Of dE
EXert-re]
CHI 65169192v2
@ e
AFFIDAVIT OF TRANSFER OF ACCOUNTS
Commonwealth of Virginia, City of Roanoke
1, Shawn Thomas, being duly swom, deposes and says:
Lam over 18 and nota party to this action, I am the General Manager of Atlantic Credit & Finance, Inc., sole
member of Atlantic Credit & Finance Special:Finance Unit, LLC:. In that capacity, I have access to certain
books and records of Atlantic Credit & Finance Special Finance Unit, LLC, and am generally aware of the
to Atlantic Credit & Finance Special Finance Unit, LLC's electronically stored business records.
process relating
Atlantic Credit & Finance Special Finance Unit, LLC owns certain accounts, and maintains and records
information in the records as they relate to such accounts. I am authorized to make the statements and
representations set forth in this affidavit on behalf of Atlantic Credit & Finance Special Finance Unit,
LLC. The statements set forth herein are true and correct based on either personal knowledge or a
personal review of the business records of Atlantic Credit & Finance Special Finance Unit, LLC.
On August 6, 2014, Encore Capital Group, Inc., the parent company of Midland Funding LLC, acquired
Atlantic Credit & Finance, Inc, Pursuant to the acquisition, Encore Capital Group, Inc. also acquired Atlantic
to Atlantic Credit & Finance, Inc.
Credit & Finance Special Finance Unit, LLC, a wholly owned subsidiary
Pursuant to the acquisition, on August 6, 2014, Atlantic Credit & Finance Special Finance Unit, LLC
transférred a poo! of charged-off accounts (the Accounts") to Midland Funding LLC. Pursuant to the
corp orate acquisition, Atlantic Credit & Finance Special Finance Unit, LLC assigned and transferred to
Midland Funding LLC good and marketable title to the Accounts and any unpaid balance free and clear of
all liens, encumbrances, security interests and pledges of any kind. I am not aware of any errors in the
Accounts.
In connection with the transfer of the Accounts, electronic and other records were transferred to or
otherwise made available to Midland Funding LLC (the "Transferred Records"). The Transferred
Records are kept by Atlantic Credit & Finance Special Finance Unit, LLC in the regular course of
business, and it was in the regular course of business of Atlantic Credit & Finance Special Finance Unit,
LLC for an employee or representative with personal knowledge of, or from information transmitted by
someone with personal knowledge of, the act, event, condition, or opinion recorded to make memoranda
or records thereof, and the memoranda or records were made at or near the time the information was
received by Atlantic Credit & Finance Special Finance Unit, LLC or the time of the act, event, condition
or opinion recorded, or reasonably soon thereafter. To the extent that the Transferred Records include
records that were prepared by a third party, they are records that were incorporated into the records of
Atlantic Credit & Finance Special Finance Unit, LLC as a business record and the accuracy of such
records are relied upon by Atlantic Credit & Finance Special Finance Unit, LLC in the regular course of
business.
‘The above statements are true to the best of my knowledge.
Signed this 2W day Aon.
of 21
LE
Shawn mas
Sworn fo ti
Se
eres fhe,rice of Mop 2015
IOTARY
PUBLIC KE
EG. #7055 =
MY COMMISSION F Pay Today andaes: g
5 ne $1,262.43 $126.24 4
Purchase Date: Offer Expiration Date:
(eam
arr 860 05-21-2015 . 40-34-2015
PLEASE SEE REVERSE SIDE FOR IMPORTANT DISCLOSURE INFORMATION
ra ey Vier ianiteri a
MCIM Account Number: 8565791199 irec: nS:
Original Account Number:
Current Balance: $1,262.43 1) Make your ‘check payable to: Midiand Credit Management, In
2) Fill out the amount enclosedof the Payment Certificate.
Due Date: 10-3: 3) Place your check and Payment Certificate in the provided envelope
Amount Enclosed: <4) Mail Payment Cenificale fo: i
‘Midland
msn P.O. Box 60578 Credit Management, Inc. -
Uriet Velez * %
3276 Nord Ave Los Angeles, CA 90060-0576
Chico, CA 95973-8645
2 a a ceo: ce ue
Important Disclosure Information:
(i lease understand this is a communication from a debt collector. T!
Any information obtained will be used for that purpose.
an attempt to collect a debt.
( PLEASE SEE REVERSE SIDE FOR IMPORTANT DISCLOSURE INFORMATION
Calls to and/or from this company may be monitored or recorded.
‘The records associated with the Citibank, N.A. account purchased by MIDLAND FUNDING LLC, reflect that you are
obligated on this account, which is in default.
‘As the owner of this account, but subject to the rights described below, MIDLAND FUNDING LLC is entitled to payment of
this account. All communication regarding this account should be addressed to MCM and not the previous owner.
Unless you notify MCM within thirty (30) days after receiving this notice that you dispute the validity of the debt, or any
Portion thereof, MCM will assume this debt to be valid.
Ifyou nolify MCM, in writing, within thirty (30) days after receiving this notice that the debt, or any portion thereof, is disputed,
MCM will obtain verification of the debt or a copy of a judgment (if there is a judgment) and MCM will mail you a copy of such
verification or judgment.
Ifyou request, in writing, within thirty (30) days after receiving this notice, MCM will provide you with the name and address
of the original creditor.
Ifan attorney represents you with regard to this debt, please refer this letter to your attomey. Likewise, if you are involved in
an active bankrupicy case, of if this debt has been discharged in a bankruptey case, please refer this letter to your
bankruptcy attomey so that we may be notified
Please remember, even if you make a payment within thirty (30) days after receiving this notice, you still have the remainder
Cf the thirty (30) days to exercise the rights described above.
‘You are hereby notified that a negative credit report reflecting on your credit record may be submitted to a credit reporting
agency if you fail to fulfill the terms of your credit obligations.
RETAIN THE FOLLOWING ADDRESS INFORMATION FOR YOUR RECORDS:
Communications concer ing disputed debts, including an instrument tendered as full satisfaction of a debt, are to
be sent to: 2365 Northside Drive, Suite 300, San Diego, CA 92108; Attn: Consumer Support Services.
MAIL PAYMENTS TO: P.O. Box 60578, Los Angeles, CA 90060-0578
MAIL CORRESPONDENCE BUT NO PAYMENTS TO: 2365 Northside Drive, Suite 300, San Diego, CA92108
MAIL CREDIT REPORTING CORRESPONDENCE TO: MCM CREDIT REPORTING DEPARTMENT, 2365 Northside Drive,
Suite 300, San Diego, CA 92108
‘We are required under state law to notify consumers of the following rights. This list does not contain a complete
list of the rights consumers have under state and federal law:
IF YOU LIVE IN CALIFORNIA, THIS APPLIES TO YOU:
‘The state Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt Collection Practices Act require that, except
under unusual circumstances, collectors may not contact you before 8 a.m. or after 9 p.m. They may not harass you by using
threats of violence or arrest or by using obscene language. Collectors may not use false or misleading statements or call you
at work if they know or have reason to know that you may not receive personal calls at work. For the most part, collectors
‘may not tell another person, other than your attorney or spouse, about your debt. Collectors may contact another person to
confirm your location or enforce a judgment. For more information about debt collection activities, you may contact the
Federal Trade Commission at 1-877-FTC-HELP or hito:
“Nonprofit credit counseling services may be available in the area.”
As required by law, you are hereby notified that a negative credit report reflecting on your credit record may be submitted toa
credit-reporting agency if you fail to fulfil the terms of your credit obligations.
ADDITIONAL ACCOUNT INFORMATION:
Charge-Otf Balance: $1,262.43 Principal Balance: $s 1,262.43
Charge-Off Date: 02-27-2015 Total Post Charge-Off Interest: $ 0.00
Interest Rate*: 0.00% Total Post Charge-Off Fees: 0.00
Last Payment Date: 07-05-2014 $
Date of Default: 08-01-2014 MCM Interest Balance: $ 0.00
MCM Fees: 00. s
“Interest Rate used to calculate interest portion of Current Balance: $ 1,262.43
the current balance due.
Debtor's Name and Last Known Address As They Appeared In the Charge-Off Creditor's Records Prior to the S: of
This Debt:
Debtor's Name: URIEL VELEZ
Debtor's Last Known Address: 3276 NORD AVE, CHICO, CA, 95973
Charge-Off Creditor’s Account Number Associated with Debt: maNNNNING755
Reason For Post Charge-Off interest andlor Fees, if any: N/A
Name and Address of Charge-Off Creditor at Time of Charge-Off:
CITIBANK, N.A.; 701 East 60th Street North, Sioux Falls, SD 57117
Complete Chain of Title Including All Post Charge-Off Purchasers of This Debt:
Citibank, NA.
Atlantic Credit & Finance Special Finance Unit, LL 3353 Orange Ave, Roanoke, VA 24012
MIDLAND FUNDING LLC; 2365 Northside Dr. Suit '300, San Diego, CA 921
EXHIBIT C
AA_0127 File No.: 17-51726
®
Account Statement
‘Sond Notice of Billing Errors and Customer Servico Inquiioe to:
Customer Service: BEST BUY CREDIT SEAY C=S
Bio My Best Buy’ bestbuy.2ecountondine.com PO Box 700441, St. oui, MO 63179
rm a 7 7
eer Credit Card a Account Inquiries:
1-888-574-1301 mber:
Summary of Account Activity Payment Information
Previous Balance $374.22 lew Balance $955.21
Payments -$100.00 Minimum Payment Due $25.00
Other Credits. $0.00
Payment Due Date August 23, 2014
Purchases +$644.97
Cash Advances +S0.00 Late Payment Warning: It we do not receive your minimum payment by the
Fees Charged +80.00 date listed above, you may have to pay alate tee up to $35,
Interest Charged +$36.02 Minimum Payment Warning: I you make only the minimum payment each
New Balance $955.21 period, you will pay more in interest and it will take you longer to pay off your
balance, For example:
Past Due Amount $0.00 ‘if you make no addtional= ‘You wil pay_off the. Andyou wilt:
charges using this, cai |: balarice shown ‘this
{each‘month you tatement
en ted total,
Only the minimum payment B years $2,341
Credit Limit $2,000.00 $1,441
$40 S years {Savings=$900)
Available Credit $1,044.00
Statement Closing Date. 07/29/2014 _} | tt you would ike information about credit counseling services. call 1 8// ¥3/ B18/.
Next Statement Closing Date 09/29/2014
Days in Billing Cycle Be
aS eer fell Nic} Enjoy alt of the benefits that come with your My Best Buy’
pore d a PNP Credit Card. Visit BestBuy.com/CreditCard to learn more.
‘You must pay your promotional balance of $644.97 in full by 07/23/16 to avoid paying deferred interest charges.
TRANSACTIONS
Trans Date Description Reference # Amount
ovtvs PAYMENT - THANK YOU *U200197 140 /LOUU40UG9E6 Ss 100.00.
07105, BEST BUY, CHICO, "0100191 140705004007001 s 644.97
; ORLY
Y)
Fay
t
LOW PRICE
GUARANTEE FIND A LOWER PRICE AND WE'LL MATCH IT
| We'll match prices on qualifying products. Learn more at BestBuy.com’
BH 20
PLEASE SEt IMPOHIANI INFOHMALION ON PAGES2 AND 4. Page1 of6 This Account is Issued by Citibank. NA.
yf wer, ayment
ayment | 10| fit. Sel ur rezords. aeee
Your Account Number is —
ER
8755
IN IMAM
Payment Due Date August 23, 2014
PO Le a> rt New Balance $955.21
ST.LOUIS, MM 63179 rtka
u PAPERLESS | Past Due Amount
Minimum Payment Due
$0.00
$25.00
B Sign up for online services that make ee PAT reer
&
‘Statement Enclosed it easy to manage your account at
Buy AcconntOy ine.com.
lamount Enc!
Seite Sc ot uteae bh
mosey: SEES smc
Please print address changes on the reverse side.
Make Checks Payable tow
BEST BUY CREDIT SERVICES
URIEL VELEZ PO BOX 688910
3276 NORD AVE DES MOINES, IA 50358-8910
GHICO. SA 95973-8545,
Gan Bene Genes Gee Be Bie
e
Information About Your Account. Proper Form, For é payment sent by mail or courier to oe in proper form,
How to Avold Paying Interest on Purchases. Your paynient due you must:
date is at least 25 days after the ciase of each ditiing cycle. We will nat + Enctose a vaiid check or money order. No cash, gift cards,
eharge you any interest an purchases If you nay your Ne aatance by
the p mont due da 2 each month, nis is called a ara periad on
oF foreign currency Se,
+ Inctude your nema and tne fast tour digits of your account number,
purchases. If you do not pay the New Balance in full
by the payment
due date, you ot gel & grace period on purchases until you pay (he Payment Other Than By Mail.
ew Balance in ft ‘twa billing cy tes in row. * In-Store (Where Available). Any payment in proper form accepted
if you have 2 balance subject to a deferred interest promotion and that in-store will be credited es af hat day, However, credit availability
romotion does nst expire before the payment due date, that balance may be subject to verification of funds, Not ali stores accept payments.
{an “excluded balance”) is excluded from the amount you must pay in Contact y« local store to see if in-store payments are accepted at
futl to get a grace period on a purcitase bslance ether than an excluded that location.
bala In addition, it you have a reduced rate credit plan, that balance Online. Go to the URL on Page ! of your statement to make a payment.
fn" ded balance”) is excluded from the amount you must pay in For security reasons, you may rat be able to your entire New
{ull to geta grace period on a ‘chase balance other than an excluded Balance the fir time you make a payment ontine. The payment cutoft
Hower i", yOu must still pay any separately required payment on time for Catire Bit} Payments is midni nt Eastern time. This meansti
the excluded balance. In billing cycies in which payments are allocated we will cre it your account as of the calendar day, based on Eastern
to deferred interest balances first, the detarrad interest balance will time, that we rece've your payment request.
be reduced before any otner balance ont account. However, you will AutoPay. Sign up at Account Cnfina to have your payment smount
continue to get 6 grace period on purchases, other than an excluded automaticaly jucted each month from the atcount yau choose.
balance soiong YOu Pi then ewe lance (less any excluded balance, Your card accaunt will be credited on the due date with that amount.
plus any separately od payment on an excluded 53lence) in full by Phene. Cail tite pone number on Page | of your statement to make
the payment due date each billing cycie. Deterred interest offers may 2 payment. We may process your payment electronically after we
a'sa be called Same As Cash or No Interest. verily your identity, Tre payment cutoff time for Phone Payments is
In addition, ce: promotional offers not described chove may also midnight Ezstem time. This means that we will credit your account
allow you to have a grace period on ourchases withaut naving to pay as of the calendar day, based on Eastern time, that we receive your
ail or 8 portion of the promotional baiance by the peymient due dete. payment request.
if tnat is the case, the promotional offer describe what happens. Express Mail. Send payment by courier or express mail to: Payments:
How We Calculate Your Balance Subject fo Interest Rate. We use & Department, 1500 Boltontield Street, Columbus, OH 43228. Payment
daily balance method (including current transactions) to calculate interest must received in proper form at the proper address by 5 p.
charges. To tind out mare ‘mation about the balance con tation Easter time to be 7 dited as of the jay. All payments received in
method and how the resulti interest charges were determined, contact proper form at the proper address after that tiene will be Credited as
us at the Account Inquirles number on the front. of the next day.
Other Account and Payment Information. H you send an eligible check with this payment coupon, you authorize
Payment Amount. You may pay ali or part of your accaunt balance at us ta camplete your payment by electronic debit. If we do, the checking
any time. However, you must pay, by the payment due date, at least the account will be debited In the amount on the check. We may do this as
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- ? MISHAELA J. GRAVES, State Bar No.: 259765 KRISTY GABRIELOVA, State Bar No.: 274827 aol PATRICK T. SULLIVAN, State Bar No.: 263613 F F Superior Court of California DEANNA FRASER, State Bar No.: 270362 CHAD K. CASEY, State Bar No.: 297552 | County of Butte \ 10601-G TIERRASANTA BLVD, #4540 L JUN, 22 2017 L SAN DIEGO, CA 92124 E Telephone: (866) 300-8750 Facsimile: (858) 309-1588 D By yf Hey Deputy 7 Attorneys for Plaintiff SUPERIOR COURT OF CALIFORNIA COUNTY OF BUTTE CHICO COURTHOUSE MIDLAND FUNDING LLC Case No. VF 0 17 44 10 Plaintiff, COMPLAINT FOR: 11 vs. (1) Account Stated 12 13 URIEL VELEZ; PRAYER AMT: $1,262.43 and DOES 1through 10, inclusive LIMITED 14 Defendant. 15 16 1 Plaintiff, MIDLAND FUNDING LLC ("Plaintiff"), is a Limited Liability Company 17 qualified to do business in California. 18 2. This court is the proper court because Plaintiff is informed and believes that Defendant URIEL VELEZ ("Defendant"), is a resident of BUTTE County, State of California. 19 3 Plaintiff is unaware of the true names and capacities of Defendants sued by the fictitious 20 names DOES | through 10. Plaintiff will ask leave of court to amend this complaint as and when the true 21 names and capacities of Defendants named herein as DOES | through 10 have been ascertained. 22 4 At all times herein mentioned, Defendants, and each of them, were the principals, agents, 23 employers, employees, masters, or servants of each of their co-defendants and ratified, adopted or 24 approved the acts or omissions alleged herein, and each defendant, in doing the things alleged, were 25 acting in the course and scope of said authority of such agents, servants, and employees. 26 5 Pursuant to California Civil Code §1788.58(a)(1), Plaintiff is a debt buyer as defined by California Civil Code §1788.50(a). 27 28 ale COMPLAINT CA_0132G File No.: 17-51726 Y @ e 6. Pursuant to California Civil Code §1788.58(a)(2), is seeking to recover the amount of $1,262.43. This is the amount due on credit card account number XXXXXXXXXXXX-6755 ("Account")! which was originally issued by CITIBANK, N.A.. The amount due is the result of transactions that occurred on the Account. 7 Pursuant to California Civil Code §1788.58(a)(3), Plaintiff is the sole owner of the debt. Attached hereto and incorporated herein by reference as Exhibit A is a true and correct copy of the Bill of Sale from CITIBANK, N.A. to Plaintiff. The account was purchased by the Plaintiff on May 21, 2015. 8. Pursuant to California Civil Code §1788.58(a)(4), the Account balance at the time of charge-off was $1,262.43. 9 Plaintiff is not seeking to recover any post charge-off interest and/or fees. However, in accordance with California Civil Code §1788.58(a)(4), the following is explanation of the amount that 10 the Plaintiff is seeking to recover: I Charge-off Balance? $1,262.43 12 Total Post Charge-Off Interest $0.00 13 Total Post Charge-Off Fees? $0.00 14 10. Pursuant to California Civil Code §1788.58(a)(5), Plaintiff alleges that the date of default 15 is August 01, 2014 and the date of the last payment was July 05, 2014 which was made to CITIBANK, 16 N.A.. 11. Pursuant to California Civil Code §1788.58(a)(6), Plaintiff alleges that the name of the 17 charge-off creditor at the time of the charge-off is CITIBANK, N.A.. On information and belief the 18 Plaintiff alleges that an address utilized by CITIBANK, N.A. at the time of charge-off was 701 EAST 19 60TH STREET NORTH SIOUX FALLS SD 57117. At the time of charge off the account number 20 associated with the debt was XXXXXXXXXXXX-6755. 21 12. Pursuant to California Civil Code §1788.58(a)(7), Plaintiff alleges that the name of the 22 debtor as it appeared in the records of CITIBANK, N.A. is URIEL VELEZ and the last known address as 23 it appeared in the records of CITIBANK, N.A. is 3276 NORD AVE CHICO CA 95973. 24 } Pursuant to California Rule of Court and California Civil Code §1788.58(c) the Account number has 25 been redacted to protect the Defendant's confidential information. ? This amount may include the charged-off principal amount and pre-charge-off accrued interest as set 26 forth in the seller data sheet attachedhereto and incorporated herein by reference as Exhibit A. 27 3 This amount is not reflective of the costs incurred in the filing and service of this action which are recoverable pursuant to California Code of Civil Procedure §1033.5. 28 2. COMPLAINT (CA_0132G File No.: 17-51726 ~ . > @ e 13. Pursuant to California Civil Code §1788.58(a)(8), Plaintiff alleges that the name and address of all post charge-off purchasers of the debt are as follows: Name Address ATLANTIC CREDIT & FINANCE SPECIAL 3353 ORANGE AVE ROANOKE VA 24012 FINANCE UNIT, LLC MIDLAND FUNDING LLC 2365 NORTHSIDE DRIVE SUITE 300 SAN DIEGO CA 92108 14, Pursuant to California Civil Code §1788.58(a)(9) Plaintiff alleges that it has complied with the provisions of Civil Code §1788.52 and that it informed Defendant of the assignment of the account. Attached hereto and incorporated herein by reference as Exhibit B is a true and correct copy of the first written communication sent to the consumer by Plaintiff. 15. Pursuant to California Civil Code §1788.58(b) attached hereto and incorporated herein 10 by reference as Exhibit C is a true and correct copy of a monthly statement recording a purchase Il transaction, payment or balance transfer while the account was active as required by California Civil 12 Code §1788.52(b). 16. The Account balance at the time of charge-off was $1,262.43, attached hereto and 13 incorporated herein by reference as Exhibit D is a true and correct copy of a billing statement that was 14 mailed to Defendant stating the balance due on the Account at or around the time of charge-off. 15 17. By this complaint, Plaintiff seeks to recover amounts of $1,262.43 from Defendant. 16 18. As alleged above, before filing this suit, all right, title and interest to the Account were 17 sold and assigned to Plaintiff. Plaintiff owns the Account and is entitled to collect on the Account as if it 18 were the original creditor. To the extent that Plaintiff acts in its capacity as successor-in-interest to the 19 original creditor or its assigns, references herein to Plaintiff may include Plaintiff's predecessor-in- 20 interest. 21 19, Before commencement of this action, Plaintiff informed Defendant in writing that it 22 intended to file this action and that this action could result in a judgment against Defendant that would include court costs allowed by California Code of Civil Procedure § 1033(b)(2). Attached hereto and 23 incorporated herein by reference as Exhibit E is a copy of Plaintiff’s most recent attempt at resolving the 24 underlying obligation. 25 MIDLAND'S EFFORTS TO RESOLVE THE UNDERLYING OBLIGATION 26 20. Plaintiff MIDLAND FUNDING LLC owns portfolios of consumer receivables, which it 27 attempts to collect. Plaintiff MIDLAND FUNDING LLC and its affiliates (collectively, “MIDLAND”) 28 generally attempt to contact consumers like Defendant through several means, such as phone calls, letters, or other means, all in an effort to establish contact and to resolve the underlying obligation. COMPLAINT CA_0132G File No.: 17-51726 @ In doing so, MIDLAND attempts to assess each consumer’s willingness to pay, through phone calls, letters or other means. MIDLAND attempts to exclude consumers from its collection efforts, where MIDLAND believes those consumers are facing extenuating circumstances or hardships that would prevent them from making any payments. 21. When MIDLAND contacts consumers, it strives to treat consumers with respect, compassion, and integrity. MIDLAND works with consumers in an effort to find mutually-beneficial solutions, often offering discounts, hardship plans, and payment options. MIDLAND’s efforts are aimed at working with consumers to repay their obligations and to attain financial recovery. MIDLAND strives to engage in dialogue that is honorable and constructive, and to play a positive role in consumers’ lives. 22. Despite MIDLAND’ efforts to reach consumers and resolve the consumer’s obligations, only a percentage of consumers choose to engage with MIDLAND. Those who do are often offered discounts or payment plans that are intended to suit their needs. MIDLAND would prefer to work with 10 consumers to establish voluntary payment arrangements resulting in the resolution of any underlying M1 obligations. 12 23. However, the majority of MIDLAND’s consumers ignore calls or letters, and some 13 simply refuse to repay their obligations despite an apparent ability to do so. When this happens, 14 MIDLAND must decide then whether to pursue collection through legal channels, including litigation 15 like the present action against Defendant. Although the Account is now in litigation, Plaintiff remains 16 willing to explore a mutually-beneficial solution through voluntary payment arrangements, if possible. FIRST CAUSE OF ACTION 17 ACCOUNT STATED - AGAINST ALL DEFENDANTS 18 24, Plaintiff realleges and incorporates by reference the foregoing paragraphs. 19 25. Defendant opened, used, and derived benefit from the Account through Defendant’s own 20 use of the Account or by another’s use at Defendant’s direction. By using the Account, Defendant 21 expressly agreed or impliedly promised to repay Plaintiff. 22 26. Within the last four (4) years, Defendant became indebted on the Account to Plaintiff in 23 the sum of $1,262.43 on an account stated in writing by and between Plaintiff and Defendant in which it was agreed that Defendant was indebted to Plaintiff. 24 27. Regular monthly statements were mailed to Defendant listing the debits, credits, and 25 balance due on the Account, attached as Exhibit D. 26 27 28 4 COMPLAINT CA_0132G File No.: 17-51726 e@ 28. Defendant last made a payment on the Account on July 05, 2014 to CITIBANK, N.A.. 1 29. Plaintiff has no record of Defendant objecting to the monthly statements after receipt. 30. Plaintiff has made demand on Defendant for repayment of the account stated but Defendant has failed to pay the balance due. Attached hereto and incorporated herein by reference as Exhibit B is a true and correct copy of first written communication requesting payment that was sent to the consumer by Plaintiff. 31. As of the date of this complaint there is due and owing the unpaid sum of $1,262.43. This amount was arrived by subtracting all payments and applying all credits (if any) to the charge-off balance of $1,262.43 as indicated on the charge-off statement, attached here to as Exhibit D. WHEREFORE, Plaintiff prays for judgment against Defendant as follows: On the First Cause of Action: 1 For the unpaid balance of $1,262.43; 10 2. Costs of suit; ll 3 Such other relief as the Court may deem just and proper. 12 13 14 Dated: JUN 1 1 2017 MIDLAND FUNDING LLC 15 16 ‘Andrew E. Asch #198857 By MISHAELA J. GRAVES 17 LIKRISTY GABRIELOVA 18 CIPATRICK T. SULLIVAN (DEANNA FRASER 19 LICHAD K. CASEY 20 21 22 23 24 25 26 27 28 -5- COMPLAINT CA_0132G File No.: 17-51726 @ EXHIBIT A AA_0125 File No.: 17-51726 BILL OF SALE FOR GOOD AND VALUABLE CONSIDERATION, the receipt and sufficiency of which is hereby acknowledged, [ATLANTIC CREDIT & FINANCE SPECIAL FINANCE UNIT, LLC, a Virginia limited liability company], (“Seller”) hereby sells, assigns, transfers, conveys and delivers to MIDLAND FUNDING LLC, a Delaware limited liability company (“Buyer”) all rights, title and interests in and to each and every one of the purchased accounts described in the purchased accounts files identificd on Schedule A, attached hereto and incorporated by this reference (“Purchased Accounts”). To the best of Seller’s knowledge and belief, all of the information contained in the files for the Purchased Accounts, Seller’s chain of title file, and Seller’s accounts information, is and shall be true, complete, accurate and not misleading in any material respect, Further, all of the information contained in the files for the Purchased Accounts, Seller’s chain of title file, and Seller’s accounts information (a) constitutes Seller’s own business records regarding the Purchased Accounts; and (b) accurately reflects in all material respects the information about the purchased accounts in Seller’s possession. All of the files for the Purchased Accounts, Seller’s chain of title file, and Seller’s accounts information have been kept in the regular course of Seller’s business,.and were made or compiled at or near the time of the event and recorded by (or from information transmitted by) a person (i) with knowledge of the data entered into and maintained in Seller’s business records, or (ii) who caused the data to be entered into and maintained in Seller’s business records. It is the regular practice of Seller’s business to maintain and compile such data. IN WITNESS WHEREOF, the parties hereto have executed this Bill of Sale as of May 21, 2015 {ATLANTIC CREDIT & FINANCE SPECIAL FINANCE UNIT, LLC, a Virginia limited liability company] By: Name: as Title Buyer hereby accepts and agrees to all matters set forth herein. MIDLA FUNDING LLC, a Dela limited liability company By: = Name: Title: “PRES Ser CHI 65769192v2 ~ HEDULE A Purchased Accounts Of dE EXert-re] CHI 65169192v2 @ e AFFIDAVIT OF TRANSFER OF ACCOUNTS Commonwealth of Virginia, City of Roanoke 1, Shawn Thomas, being duly swom, deposes and says: Lam over 18 and nota party to this action, I am the General Manager of Atlantic Credit & Finance, Inc., sole member of Atlantic Credit & Finance Special:Finance Unit, LLC:. In that capacity, I have access to certain books and records of Atlantic Credit & Finance Special Finance Unit, LLC, and am generally aware of the to Atlantic Credit & Finance Special Finance Unit, LLC's electronically stored business records. process relating Atlantic Credit & Finance Special Finance Unit, LLC owns certain accounts, and maintains and records information in the records as they relate to such accounts. I am authorized to make the statements and representations set forth in this affidavit on behalf of Atlantic Credit & Finance Special Finance Unit, LLC. The statements set forth herein are true and correct based on either personal knowledge or a personal review of the business records of Atlantic Credit & Finance Special Finance Unit, LLC. On August 6, 2014, Encore Capital Group, Inc., the parent company of Midland Funding LLC, acquired Atlantic Credit & Finance, Inc, Pursuant to the acquisition, Encore Capital Group, Inc. also acquired Atlantic to Atlantic Credit & Finance, Inc. Credit & Finance Special Finance Unit, LLC, a wholly owned subsidiary Pursuant to the acquisition, on August 6, 2014, Atlantic Credit & Finance Special Finance Unit, LLC transférred a poo! of charged-off accounts (the Accounts") to Midland Funding LLC. Pursuant to the corp orate acquisition, Atlantic Credit & Finance Special Finance Unit, LLC assigned and transferred to Midland Funding LLC good and marketable title to the Accounts and any unpaid balance free and clear of all liens, encumbrances, security interests and pledges of any kind. I am not aware of any errors in the Accounts. In connection with the transfer of the Accounts, electronic and other records were transferred to or otherwise made available to Midland Funding LLC (the "Transferred Records"). The Transferred Records are kept by Atlantic Credit & Finance Special Finance Unit, LLC in the regular course of business, and it was in the regular course of business of Atlantic Credit & Finance Special Finance Unit, LLC for an employee or representative with personal knowledge of, or from information transmitted by someone with personal knowledge of, the act, event, condition, or opinion recorded to make memoranda or records thereof, and the memoranda or records were made at or near the time the information was received by Atlantic Credit & Finance Special Finance Unit, LLC or the time of the act, event, condition or opinion recorded, or reasonably soon thereafter. To the extent that the Transferred Records include records that were prepared by a third party, they are records that were incorporated into the records of Atlantic Credit & Finance Special Finance Unit, LLC as a business record and the accuracy of such records are relied upon by Atlantic Credit & Finance Special Finance Unit, LLC in the regular course of business. ‘The above statements are true to the best of my knowledge. Signed this 2W day Aon. of 21 LE Shawn mas Sworn fo ti Se eres fhe,rice of Mop 2015 IOTARY PUBLIC KE EG. #7055 = MY COMMISSION F Pay Today andaes: g 5 ne $1,262.43 $126.24 4 Purchase Date: Offer Expiration Date: (eam arr 860 05-21-2015 . 40-34-2015 PLEASE SEE REVERSE SIDE FOR IMPORTANT DISCLOSURE INFORMATION ra ey Vier ianiteri a MCIM Account Number: 8565791199 irec: nS: Original Account Number: Current Balance: $1,262.43 1) Make your ‘check payable to: Midiand Credit Management, In 2) Fill out the amount enclosedof the Payment Certificate. Due Date: 10-3: 3) Place your check and Payment Certificate in the provided envelope Amount Enclosed: <4) Mail Payment Cenificale fo: i ‘Midland msn P.O. Box 60578 Credit Management, Inc. - Uriet Velez * % 3276 Nord Ave Los Angeles, CA 90060-0576 Chico, CA 95973-8645 2 a a ceo: ce ue Important Disclosure Information: (i lease understand this is a communication from a debt collector. T! Any information obtained will be used for that purpose. an attempt to collect a debt. ( PLEASE SEE REVERSE SIDE FOR IMPORTANT DISCLOSURE INFORMATION Calls to and/or from this company may be monitored or recorded. ‘The records associated with the Citibank, N.A. account purchased by MIDLAND FUNDING LLC, reflect that you are obligated on this account, which is in default. ‘As the owner of this account, but subject to the rights described below, MIDLAND FUNDING LLC is entitled to payment of this account. All communication regarding this account should be addressed to MCM and not the previous owner. Unless you notify MCM within thirty (30) days after receiving this notice that you dispute the validity of the debt, or any Portion thereof, MCM will assume this debt to be valid. Ifyou nolify MCM, in writing, within thirty (30) days after receiving this notice that the debt, or any portion thereof, is disputed, MCM will obtain verification of the debt or a copy of a judgment (if there is a judgment) and MCM will mail you a copy of such verification or judgment. Ifyou request, in writing, within thirty (30) days after receiving this notice, MCM will provide you with the name and address of the original creditor. Ifan attorney represents you with regard to this debt, please refer this letter to your attomey. Likewise, if you are involved in an active bankrupicy case, of if this debt has been discharged in a bankruptey case, please refer this letter to your bankruptcy attomey so that we may be notified Please remember, even if you make a payment within thirty (30) days after receiving this notice, you still have the remainder Cf the thirty (30) days to exercise the rights described above. ‘You are hereby notified that a negative credit report reflecting on your credit record may be submitted to a credit reporting agency if you fail to fulfill the terms of your credit obligations. RETAIN THE FOLLOWING ADDRESS INFORMATION FOR YOUR RECORDS: Communications concer ing disputed debts, including an instrument tendered as full satisfaction of a debt, are to be sent to: 2365 Northside Drive, Suite 300, San Diego, CA 92108; Attn: Consumer Support Services. MAIL PAYMENTS TO: P.O. Box 60578, Los Angeles, CA 90060-0578 MAIL CORRESPONDENCE BUT NO PAYMENTS TO: 2365 Northside Drive, Suite 300, San Diego, CA92108 MAIL CREDIT REPORTING CORRESPONDENCE TO: MCM CREDIT REPORTING DEPARTMENT, 2365 Northside Drive, Suite 300, San Diego, CA 92108 ‘We are required under state law to notify consumers of the following rights. This list does not contain a complete list of the rights consumers have under state and federal law: IF YOU LIVE IN CALIFORNIA, THIS APPLIES TO YOU: ‘The state Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt Collection Practices Act require that, except under unusual circumstances, collectors may not contact you before 8 a.m. or after 9 p.m. They may not harass you by using threats of violence or arrest or by using obscene language. Collectors may not use false or misleading statements or call you at work if they know or have reason to know that you may not receive personal calls at work. For the most part, collectors ‘may not tell another person, other than your attorney or spouse, about your debt. Collectors may contact another person to confirm your location or enforce a judgment. For more information about debt collection activities, you may contact the Federal Trade Commission at 1-877-FTC-HELP or hito: “Nonprofit credit counseling services may be available in the area.” As required by law, you are hereby notified that a negative credit report reflecting on your credit record may be submitted toa credit-reporting agency if you fail to fulfil the terms of your credit obligations. ADDITIONAL ACCOUNT INFORMATION: Charge-Otf Balance: $1,262.43 Principal Balance: $s 1,262.43 Charge-Off Date: 02-27-2015 Total Post Charge-Off Interest: $ 0.00 Interest Rate*: 0.00% Total Post Charge-Off Fees: 0.00 Last Payment Date: 07-05-2014 $ Date of Default: 08-01-2014 MCM Interest Balance: $ 0.00 MCM Fees: 00. s “Interest Rate used to calculate interest portion of Current Balance: $ 1,262.43 the current balance due. Debtor's Name and Last Known Address As They Appeared In the Charge-Off Creditor's Records Prior to the S: of This Debt: Debtor's Name: URIEL VELEZ Debtor's Last Known Address: 3276 NORD AVE, CHICO, CA, 95973 Charge-Off Creditor’s Account Number Associated with Debt: maNNNNING755 Reason For Post Charge-Off interest andlor Fees, if any: N/A Name and Address of Charge-Off Creditor at Time of Charge-Off: CITIBANK, N.A.; 701 East 60th Street North, Sioux Falls, SD 57117 Complete Chain of Title Including All Post Charge-Off Purchasers of This Debt: Citibank, NA. Atlantic Credit & Finance Special Finance Unit, LL 3353 Orange Ave, Roanoke, VA 24012 MIDLAND FUNDING LLC; 2365 Northside Dr. Suit '300, San Diego, CA 921 EXHIBIT C AA_0127 File No.: 17-51726 ® Account Statement ‘Sond Notice of Billing Errors and Customer Servico Inquiioe to: Customer Service: BEST BUY CREDIT SEAY C=S Bio My Best Buy’ bestbuy.2ecountondine.com PO Box 700441, St. oui, MO 63179 rm a 7 7 eer Credit Card a Account Inquiries: 1-888-574-1301 mber: Summary of Account Activity Payment Information Previous Balance $374.22 lew Balance $955.21 Payments -$100.00 Minimum Payment Due $25.00 Other Credits. $0.00 Payment Due Date August 23, 2014 Purchases +$644.97 Cash Advances +S0.00 Late Payment Warning: It we do not receive your minimum payment by the Fees Charged +80.00 date listed above, you may have to pay alate tee up to $35, Interest Charged +$36.02 Minimum Payment Warning: I you make only the minimum payment each New Balance $955.21 period, you will pay more in interest and it will take you longer to pay off your balance, For example: Past Due Amount $0.00 ‘if you make no addtional= ‘You wil pay_off the. Andyou wilt: charges using this, cai |: balarice shown ‘this {each‘month you tatement en ted total, Only the minimum payment B years $2,341 Credit Limit $2,000.00 $1,441 $40 S years {Savings=$900) Available Credit $1,044.00 Statement Closing Date. 07/29/2014 _} | tt you would ike information about credit counseling services. call 1 8// ¥3/ B18/. Next Statement Closing Date 09/29/2014 Days in Billing Cycle Be aS eer fell Nic} Enjoy alt of the benefits that come with your My Best Buy’ pore d a PNP Credit Card. Visit BestBuy.com/CreditCard to learn more. ‘You must pay your promotional balance of $644.97 in full by 07/23/16 to avoid paying deferred interest charges. TRANSACTIONS Trans Date Description Reference # Amount ovtvs PAYMENT - THANK YOU *U200197 140 /LOUU40UG9E6 Ss 100.00. 07105, BEST BUY, CHICO, "0100191 140705004007001 s 644.97 ; ORLY Y) Fay t LOW PRICE GUARANTEE FIND A LOWER PRICE AND WE'LL MATCH IT | We'll match prices on qualifying products. Learn more at BestBuy.com’ BH 20 PLEASE SEt IMPOHIANI INFOHMALION ON PAGES2 AND 4. Page1 of6 This Account is Issued by Citibank. NA. yf wer, ayment ayment | 10| fit. Sel ur rezords. aeee Your Account Number is — ER 8755 IN IMAM Payment Due Date August 23, 2014 PO Le a> rt New Balance $955.21 ST.LOUIS, MM 63179 rtka u PAPERLESS | Past Due Amount Minimum Payment Due $0.00 $25.00 B Sign up for online services that make ee PAT reer & ‘Statement Enclosed it easy to manage your account at Buy AcconntOy ine.com. lamount Enc! Seite Sc ot uteae bh mosey: SEES smc Please print address changes on the reverse side. Make Checks Payable tow BEST BUY CREDIT SERVICES URIEL VELEZ PO BOX 688910 3276 NORD AVE DES MOINES, IA 50358-8910 GHICO. SA 95973-8545, Gan Bene Genes Gee Be Bie e Information About Your Account. Proper Form, For é payment sent by mail or courier to oe in proper form, How to Avold Paying Interest on Purchases. Your paynient due you must: date is at least 25 days after the ciase of each ditiing cycle. We will nat + Enctose a vaiid check or money order. No cash, gift cards, eharge you any interest an purchases If you nay your Ne aatance by the p mont due da 2 each month, nis is called a ara periad on oF foreign currency Se, + Inctude your nema and tne fast tour digits of your account number, purchases. If you do not pay the New Balance in full by the payment due date, you ot gel & grace period on purchases until you pay (he Payment Other Than By Mail. ew Balance in ft ‘twa billing cy tes in row. * In-Store (Where Available). Any payment in proper form accepted if you have 2 balance subject to a deferred interest promotion and that in-store will be credited es af hat day, However, credit availability romotion does nst expire before the payment due date, that balance may be subject to verification of funds, Not ali stores accept payments. {an “excluded balance”) is excluded from the amount you must pay in Contact y« local store to see if in-store payments are accepted at futl to get a grace period on a purcitase bslance ether than an excluded that location. bala In addition, it you have a reduced rate credit plan, that balance Online. Go to the URL on Page ! of your statement to make a payment. fn" ded balance”) is excluded from the amount you must pay in For security reasons, you may rat be able to your entire New {ull to geta grace period on a ‘chase balance other than an excluded Balance the fir time you make a payment ontine. The payment cutoft Hower i", yOu must still pay any separately required payment on time for Catire Bit} Payments is midni nt Eastern time. This meansti the excluded balance. In billing cycies in which payments are allocated we will cre it your account as of the calendar day, based on Eastern to deferred interest balances first, the detarrad interest balance will time, that we rece've your payment request. be reduced before any otner balance ont account. However, you will AutoPay. Sign up at Account Cnfina to have your payment smount continue to get 6 grace period on purchases, other than an excluded automaticaly jucted each month from the atcount yau choose. balance soiong YOu Pi then ewe lance (less any excluded balance, Your card accaunt will be credited on the due date with that amount. plus any separately od payment on an excluded 53lence) in full by Phene. Cail tite pone number on Page | of your statement to make the payment due date each billing cycie. Deterred interest offers may 2 payment. We may process your payment electronically after we a'sa be called Same As Cash or No Interest. verily your identity, Tre payment cutoff time for Phone Payments is In addition, ce: promotional offers not described chove may also midnight Ezstem time. This means that we will credit your account allow you to have a grace period on ourchases withaut naving to pay as of the calendar day, based on Eastern time, that we receive your ail or 8 portion of the promotional baiance by the peymient due dete. payment request. if tnat is the case, the promotional offer describe what happens. Express Mail. Send payment by courier or express mail to: Payments: How We Calculate Your Balance Subject fo Interest Rate. We use & Department, 1500 Boltontield Street, Columbus, OH 43228. Payment daily balance method (including current transactions) to calculate interest must received in proper form at the proper address by 5 p. charges. To tind out mare ‘mation about the balance con tation Easter time to be 7 dited as of the jay. All payments received in method and how the resulti interest charges were determined, contact proper form at the proper address after that tiene will be Credited as us at the Account Inquirles number on the front. of the next day. Other Account and Payment Information. H you send an eligible check with this payment coupon, you authorize Payment Amount. You may pay ali or part of your accaunt balance at us ta camplete your payment by electronic debit. If we do, the checking any time. However, you must pay, by the payment due date, at least the account will be debited In the amount on the check. We may do this as minimum payment due. ‘soon as the day we receive the check, Also, the check will be destroyed, When Your Payment Will Be Credited, If we ret ive your paym in proper form at our processing tacilily by 5 p.m. local time thera, it will be credited es of t it day. A payment received there in proper form atter that time w be credited as of the next day. Allow Sto 7 days for payments by regutar mail to rea hus. There may be 2 delay of upto 5 days in crediting a payment receive that is nat in proper form or is not sent to the correct address, Vie correct address for regular mail is tne address on the front of the peyment coun he correct artdress for cou ier oF express mail is the Express Mait Address shown in the Express Mail section. Tou77 PLEASE SCE. IMPORTANT INFORMATION ON PAGE 4 BBY PLINA AUGIS ~ Page 20t6 me prio a ui a rea Change of Address a Please print address changes in blue or black ink. Fa nag ex Bs iat a gts rea os aes ae - iv Fs a cal fe ee i eats Le fe a lea 462) Iie R: eo we ¥ie P| fs (9) altisg i S is aoe is ke)