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DOCKET # LLI-CV-14-6009932S SUPERIOR COURT
CAVALRY INVESTMENTS, LLC LITCHFIELD JUDICIAL DISTRICT
VS AT LITCHFIELD
MICHELLE KIOKO JANUARY 9, 2014
REQUEST FOR LEAVE TO FILE AMENDED COMPLAINT
The Plaintiff in the above-captioned matter requests leave to amend the Complaint
in accordance with the attached Amended Complaint, dated 1/9/2014.
PLAINTIFF
By:
Gregory N. Bachand(301125)
Schreiber Law Firm, LLC(434988)
189 State Street
Bridgeport, CT 06604
203-295-7664
CERTIFICATION
This is to certify that a copy of the foregoing has been mailed, pre-postage, on 1/9/2014 to the following
parties on record:
MICHELLE KIOKO
130 QUEENS RD
TORRINGTON, CT
067902821
__________________________
Gregory N. Bachand, Esq
DOCKET # LLI-CV-14-6009932S SUPERIOR COURT
CAVALRY INVESTMENTS, LLC LITCHFIELD JUDICIAL DISTRICT
VS AT LITCHFIELD
MICHELLE KIOKO JANUARY 9, 2014
COMPLAINT
COUNT ONE: BREACH OF CONTRACT
1. That HSBC CARD SERVICES, INC. issued a credit card to defendant Michelle
Kioko, account # xxxxxxxxxxxxxxxx5971.
2. Said defendant borrowed against the credit line HSBC CARD SERVICES, INC.
issued, in the amount of $6,251.49 as of March 31, 2010, the date of charge-off,
with interest accruing.
3. There is presently due and owing the sum of $6,251.49 from the defendant to the
plaintiff plus interest from March 31, 2010.
4. Although written demand for payment has been made on the defendant, the
defendant failed, refused and/or neglected to pay the same since on or about
August 10, 2009.
5. There are no setoffs, defenses or counterclaims due against said sums.
6. The Plaintiff is the owner and holder of the account by virtue of an assignment
from in accordance with the following chain of title:
Sale of Debt From: To:
HSBC CARD SERVICES, INC. Cavalry Investments, LLC
COUNT TWO: ACCOUNT STATED
1. That HSBC CARD SERVICES, INC. issued a credit card to defendant Michelle
Kioko, account # xxxxxxxxxxxxxxxx5971.
2. From May 20, 2005 to March 31, 2010 HSBC CARD SERVICES, INC. issued
monthly statements to defendant Michelle Kioko regarding use of the credit card.
3. The monthly statements provided to Michelle Kioko referenced, among other
things, the debtor(s) name, account number, address, previous balance, payment
due date, minimum payment due, and the applicable time period for the
statement.
4. Defendant Michelle Kioko received the aforementioned statements and retained
the same without objection.
5. The amount due on the account as of March 31, 2010 consistent with the
statements received by defendant Michelle Kioko is $6,251.49 with interest
accruing.
6. Despite demand, defendant Michelle Kioko failed to pay the outstanding balance
as aforestated.
7. Cavalry Investments, LLC as Assignee of HSBC CARD SERVICES, INC. is now
the owner of said debt.
8. As a result, Cavalry Investments, LLC as Assignee of HSBC CARD SERVICES,
INC. has suffered and continues to suffer damages.
WHEREFORE, the plaintiff claims:
1. Money damages; and
2. Costs of this action; and
3. Legal fees; and
4. Pre Judgment Interest at 10% interest from Charge Off to Judgment as provided by
law; and
4. Post Judgment Interest at 10% per annum as provided by law; and
5. A reasonable order of payments to be made by the said defendant out of any debts
accrued or accruing by reason of the services of the defendant, in accordance with
the statute made and provided; and
6. Such other relief that the court deems just.
PLAINTIFF
By:
Gregory N. Bachand(301125)
Schreiber Law Firm, LLC(434988)
189 State Street
Bridgeport, CT 06604
203-295-7664
This is an attempt to collect a debt and any information obtained will be used for that purpose.
DOCKET # LLI-CV-14-6009932S SUPERIOR COURT
CAVALRY INVESTMENTS, LLC LITCHFIELD JUDICIAL DISTRICT
VS AT LITCHFIELD
MICHELLE KIOKO JANUARY 9, 2014
STATEMENT OF AMOUNT IN DEMAND
The amount, legal interest or property in demand is greater than $2,500 but less than
$15,000 exclusive of interests and costs. The remedy sought is based upon an express or
implied promise to pay a definite sum.
PLAINTIFF
By:
Gregory N. Bachand(301125)
Schreiber Law Firm, LLC(434988)
189 State Street
Bridgeport, CT 06604
203-295-7664
This is an attempt to collect a debt and any information obtained will be used for that purpose.
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DOCKET # LLI-CV-14-6009932S SUPERIOR COURT CAVALRY INVESTMENTS, LLC LITCHFIELD JUDICIAL DISTRICT VS AT LITCHFIELD MICHELLE KIOKO JANUARY 9, 2014 REQUEST FOR LEAVE TO FILE AMENDED COMPLAINT The Plaintiff in the above-captioned matter requests leave to amend the Complaint in accordance with the attached Amended Complaint, dated 1/9/2014. PLAINTIFF By: Gregory N. Bachand(301125) Schreiber Law Firm, LLC(434988) 189 State Street Bridgeport, CT 06604 203-295-7664 CERTIFICATION This is to certify that a copy of the foregoing has been mailed, pre-postage, on 1/9/2014 to the following parties on record: MICHELLE KIOKO 130 QUEENS RD TORRINGTON, CT 067902821 __________________________ Gregory N. Bachand, Esq DOCKET # LLI-CV-14-6009932S SUPERIOR COURT CAVALRY INVESTMENTS, LLC LITCHFIELD JUDICIAL DISTRICT VS AT LITCHFIELD MICHELLE KIOKO JANUARY 9, 2014 COMPLAINT COUNT ONE: BREACH OF CONTRACT 1. That HSBC CARD SERVICES, INC. issued a credit card to defendant Michelle Kioko, account # xxxxxxxxxxxxxxxx5971. 2. Said defendant borrowed against the credit line HSBC CARD SERVICES, INC. issued, in the amount of $6,251.49 as of March 31, 2010, the date of charge-off, with interest accruing. 3. There is presently due and owing the sum of $6,251.49 from the defendant to the plaintiff plus interest from March 31, 2010. 4. Although written demand for payment has been made on the defendant, the defendant failed, refused and/or neglected to pay the same since on or about August 10, 2009. 5. There are no setoffs, defenses or counterclaims due against said sums. 6. The Plaintiff is the owner and holder of the account by virtue of an assignment from in accordance with the following chain of title: Sale of Debt From: To: HSBC CARD SERVICES, INC. Cavalry Investments, LLC COUNT TWO: ACCOUNT STATED 1. That HSBC CARD SERVICES, INC. issued a credit card to defendant Michelle Kioko, account # xxxxxxxxxxxxxxxx5971. 2. From May 20, 2005 to March 31, 2010 HSBC CARD SERVICES, INC. issued monthly statements to defendant Michelle Kioko regarding use of the credit card. 3. The monthly statements provided to Michelle Kioko referenced, among other things, the debtor(s) name, account number, address, previous balance, payment due date, minimum payment due, and the applicable time period for the statement. 4. Defendant Michelle Kioko received the aforementioned statements and retained the same without objection. 5. The amount due on the account as of March 31, 2010 consistent with the statements received by defendant Michelle Kioko is $6,251.49 with interest accruing. 6. Despite demand, defendant Michelle Kioko failed to pay the outstanding balance as aforestated. 7. Cavalry Investments, LLC as Assignee of HSBC CARD SERVICES, INC. is now the owner of said debt. 8. As a result, Cavalry Investments, LLC as Assignee of HSBC CARD SERVICES, INC. has suffered and continues to suffer damages. WHEREFORE, the plaintiff claims: 1. Money damages; and 2. Costs of this action; and 3. Legal fees; and 4. Pre Judgment Interest at 10% interest from Charge Off to Judgment as provided by law; and 4. Post Judgment Interest at 10% per annum as provided by law; and 5. A reasonable order of payments to be made by the said defendant out of any debts accrued or accruing by reason of the services of the defendant, in accordance with the statute made and provided; and 6. Such other relief that the court deems just. PLAINTIFF By: Gregory N. Bachand(301125) Schreiber Law Firm, LLC(434988) 189 State Street Bridgeport, CT 06604 203-295-7664 This is an attempt to collect a debt and any information obtained will be used for that purpose. DOCKET # LLI-CV-14-6009932S SUPERIOR COURT CAVALRY INVESTMENTS, LLC LITCHFIELD JUDICIAL DISTRICT VS AT LITCHFIELD MICHELLE KIOKO JANUARY 9, 2014 STATEMENT OF AMOUNT IN DEMAND The amount, legal interest or property in demand is greater than $2,500 but less than $15,000 exclusive of interests and costs. The remedy sought is based upon an express or implied promise to pay a definite sum. PLAINTIFF By: Gregory N. Bachand(301125) Schreiber Law Firm, LLC(434988) 189 State Street Bridgeport, CT 06604 203-295-7664 This is an attempt to collect a debt and any information obtained will be used for that purpose.