Complaint,Petition: SUNCOAST CREDIT UNION Vs. BRAD L MONTGOMERY

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                                Case Number:21-002919-CO

    Filing #     124541519 E-Filed 04/08/2021                09:41:44 AM




                                    IN THE COUNTY COURT IN AND FOR PINELLAS COUNTY,
                                                   STATE OF FLORIDA, CIVIL DIVISION


                    SUNCOAST CREDIT UNION,

                             Plaintiff
                    VS.                                                       CASE NO:

                    BRAD L.     MONTGOMERY,

                             Defendant(s)
                                                                        1

                                                                    COMPLAINr

                           Plaintiff, SUNCOAST CREDIT UNION, by its undersigned attorneys, sues the

                  Defendant(s), BRAD        L.  MONTGOMERY, herein and alleges:

                           1. This is   an action for damages which does exceed           $8,000.00 but not $30,000.00

                  exclusive of costs, interest and     attorney's fees.

                           2.  Defendant requested      a Visa card from     Plaintiff, and Plaintiffissued a Visa card to

                  Defendant after Defendant(s)'s request for a card.

                           3.  Defendant(s)owes Plaintiffthe sum of $14,084.58 plus interest in connection with

                  Defendant(s)'suse of the Visa charge card under the Visa credit card plan.
                           4.  Attached hereto     as Exhibits "A" and "B"      are a statement of account showing the

                  current balance and a copy of the terms and conditions of the Visa              credit card plan.

                           5.  Defendant(s)expressly agreed to pay all          of Plaintiffs costs of collection, including

                  reasonableattorney's fees, incurred by the Plaintiff.          Plaintiff alleges that   a reasonable    attorney's
                  fee in this matter would be      a minimum of $500.00 and will seek an award of such amount in the

                  event that a default judgment is entered against the Defendant(s).             In the event that this matter is

                  contested, Plaintiff intends to seek additional attorney's fees based upon the hours spent, services

                  rendered and other reasonablefactors.

                           6.  All conditions precedent to the       filing ofthis complaint have been complied with by the
                   Plaintiff.

                           WHEREFORE,          Plaintiffdemandsjudgment against the Defendant(s) BRAD L.




   ***ELECTRONICALLYFILED 04/08/2021              09:41:42 AM:   KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
                  MONTGOMERY, in the sum of $14,084.58 together with interest, attorney's fees, and court

                  costs.


                                                                         -Jek*.1
                                                                       Jeffrey J. Mouch, Esq., FBN 814768
                                                                       KASS SHULER, P.A.
                                                                       P.O. Box 800
                                                                       Tampa, FL      33601
                                                                       Tel:  (813) 229-0900
                                                                       Fax: (813) 229-3323
                                                                       jmouch@kasslaw.com
                                                                       Attorneys for Plaintiff
                                                                       The Primary e-mail address for electronic
                                                                       service of all pleadings in this case under Rule
                                                                       2.516 is as follows:




                  G2000735/Janet M
                  P001B




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