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RETURN DATE: 09/21/2021 SUPERIOR COURT
PORTFOLIO RECOVERY ASSOCIATES, JUDICIAL DISTRICT OF
LLC MIDDLESEX
Plaintiff AT MIDDLETOWN
Vv. DATE: 07/27/2021
DOUGLAS P BENEDICT
Defendant(s)
Our File No. 4331958
COMPLAINT
Now comes the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, who hereby
submits the following as its Complaint against Defendant, DOUGLAS P BENEDICT:
PARTIES
1. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is a Foreign Corporation having
a principal place of business at PO BOX 12914, NORFOLK VA 23541.
2. Defendant, DOUGLAS P BENEDICT, is a natural person residing at 194 ROUND HILL
RD, MIDDLETOWN CT 06457-6118.
COUNT 1. ACCOUNT STATED
3. On or about January 14, 2018, DOUGLAS P BENEDICT ("Defendant") entered into an
agreement with CITIBANK, N.A. (“Original Creditor") for the extension of credit through the use
of a credit card or line of credit, account ending in ************7776 ("Account").
4. Defendant's use of the Account bound the Defendant by the terms and conditions of the
agreement; including, an obligation to pay the minimum amount due on time, to pay any finance
charges at an annual percentage rate, and to raise any disputes as to any statement received within
a reasonable amount of time.
5. Defendant used the Account for the purchases of goods, merchandise, services and/or cash
advances.
6. The Original Creditor, in connection with the Account, mailed, delivered, sent or otherwise
transmitted monthly billing statements setting forth the charges and amounts due on the Account,
which is the subject of this action.
7. The Defendant received and held these account statements for an unreasonable time without
any objection, as defined by 15 U.S.C. 1666(a), requiring submission of written notice of objection
within sixty (60) days of transmission of the account statement.
8. As no proper written objection was made, the statements are presumed accurate, and
constitute an "account stated" which is prima facie evidence of the correctness of the Account.
9. On or about April 24, 2020, Defendant made his/her last payment to the Original Creditor
in the amount of $170.00.
10. On or about January 19, 2021, Original Creditor sold Defendant's Account with a balance
of $6,154.28 to PORTFOLIO RECOVERY ASSOCIATES, LLC ("Plaintiff"). Pursuant to this
purchase and sale, Original Creditor assigned all of its contractual rights between Original Creditor
and Defendant to the Plaintiff.
11. Plaintiff has demanded payment from Defendant, but has not received satisfaction of this
outstanding debt.
12. Pursuant to the purchase, sale and assignment of contractual rights given to the Plaintiff,
Plaintiff seeks damages for the account stated less any credit(s) on the Account occurring after the
last statement was transmitted.
WHEREFORE, the Plaintiff claims:
1. Money damages in the amount of $6,154.28;
2. Court Costs;
3. Such other relief as this Court deems proper.
Date: 07/27/2021 Plaintiff, PORTFOLIO RECOVERY ASSOCIATES,
LLC
By and through counsel,
/s/ Loren M. Bisberg
RAUSCH STURM LLP (Juris No. 440474)
Elliot A. Dubin (Juris No. 440596)
Loren M. Bisberg (Juris No. 421326)
Joseph M. Hall (Juris No. 440823)
44 Bearfoot Road, Suite 350, Northborough, MA 01532
Phone: (877) 215-2552 TTY: 711
Attorney Direct Phone No.: (262) 693-4004
Email: LawfirmCT@rsiech.com
Our File No. 4331958
RETURN DATE: 09/21/2021 SUPERIOR COURT
PORTFOLIO RECOVERY ASSOCIATES, JUDICIAL DISTRICT OF
LLC MIDDLESEX
Plaintiff AT MIDDLETOWN
Vv. DATE: 07/27/2021
DOUGLAS P BENEDICT
Defendant(s)
Our File No. 4331958
STATEMENT OF AMOUNT IN DEMAND
In the above entitled matter, the Plaintiff seeks money damages. The amount in demand is
greater than TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00) but less than
FIFTEEN THOUSAND DOLLARS ($15,000.00), exclusive of interest and costs.
Date: 07/27/2021 Plaintiff, PORTFOLIO RECOVERY ASSOCIATES,
LLC
By and through counsel,
45/ Loren M. Bisberg
RAUSCH STURM LLP (Juris No. 440474)
Elliot A. Dubin (Juris No. 440596)
Loren M. Bisberg (Juris No. 421326)
Joseph M. Hall (Juris No. 440823)
44 Bearfoot Road, Suite 350, Northborough, MA 01532
Phone: (877) 215-2552 TTY: 711
Attorney Direct Phone No.: (262) 693-4004
Email: LawfirmCT@rsieh.com
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RETURN DATE: 09/21/2021 SUPERIOR COURT PORTFOLIO RECOVERY ASSOCIATES, JUDICIAL DISTRICT OF LLC MIDDLESEX Plaintiff AT MIDDLETOWN Vv. DATE: 07/27/2021 DOUGLAS P BENEDICT Defendant(s) Our File No. 4331958 COMPLAINT Now comes the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, who hereby submits the following as its Complaint against Defendant, DOUGLAS P BENEDICT: PARTIES 1. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is a Foreign Corporation having a principal place of business at PO BOX 12914, NORFOLK VA 23541. 2. Defendant, DOUGLAS P BENEDICT, is a natural person residing at 194 ROUND HILL RD, MIDDLETOWN CT 06457-6118. COUNT 1. ACCOUNT STATED 3. On or about January 14, 2018, DOUGLAS P BENEDICT ("Defendant") entered into an agreement with CITIBANK, N.A. (“Original Creditor") for the extension of credit through the use of a credit card or line of credit, account ending in ************7776 ("Account"). 4. Defendant's use of the Account bound the Defendant by the terms and conditions of the agreement; including, an obligation to pay the minimum amount due on time, to pay any finance charges at an annual percentage rate, and to raise any disputes as to any statement received within a reasonable amount of time. 5. Defendant used the Account for the purchases of goods, merchandise, services and/or cash advances. 6. The Original Creditor, in connection with the Account, mailed, delivered, sent or otherwise transmitted monthly billing statements setting forth the charges and amounts due on the Account, which is the subject of this action. 7. The Defendant received and held these account statements for an unreasonable time without any objection, as defined by 15 U.S.C. 1666(a), requiring submission of written notice of objection within sixty (60) days of transmission of the account statement. 8. As no proper written objection was made, the statements are presumed accurate, and constitute an "account stated" which is prima facie evidence of the correctness of the Account. 9. On or about April 24, 2020, Defendant made his/her last payment to the Original Creditor in the amount of $170.00. 10. On or about January 19, 2021, Original Creditor sold Defendant's Account with a balance of $6,154.28 to PORTFOLIO RECOVERY ASSOCIATES, LLC ("Plaintiff"). Pursuant to this purchase and sale, Original Creditor assigned all of its contractual rights between Original Creditor and Defendant to the Plaintiff. 11. Plaintiff has demanded payment from Defendant, but has not received satisfaction of this outstanding debt. 12. Pursuant to the purchase, sale and assignment of contractual rights given to the Plaintiff, Plaintiff seeks damages for the account stated less any credit(s) on the Account occurring after the last statement was transmitted. WHEREFORE, the Plaintiff claims: 1. Money damages in the amount of $6,154.28; 2. Court Costs; 3. Such other relief as this Court deems proper. Date: 07/27/2021 Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC By and through counsel, /s/ Loren M. Bisberg RAUSCH STURM LLP (Juris No. 440474) Elliot A. Dubin (Juris No. 440596) Loren M. Bisberg (Juris No. 421326) Joseph M. Hall (Juris No. 440823) 44 Bearfoot Road, Suite 350, Northborough, MA 01532 Phone: (877) 215-2552 TTY: 711 Attorney Direct Phone No.: (262) 693-4004 Email: LawfirmCT@rsiech.com Our File No. 4331958 RETURN DATE: 09/21/2021 SUPERIOR COURT PORTFOLIO RECOVERY ASSOCIATES, JUDICIAL DISTRICT OF LLC MIDDLESEX Plaintiff AT MIDDLETOWN Vv. DATE: 07/27/2021 DOUGLAS P BENEDICT Defendant(s) Our File No. 4331958 STATEMENT OF AMOUNT IN DEMAND In the above entitled matter, the Plaintiff seeks money damages. The amount in demand is greater than TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00) but less than FIFTEEN THOUSAND DOLLARS ($15,000.00), exclusive of interest and costs. Date: 07/27/2021 Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC By and through counsel, 45/ Loren M. Bisberg RAUSCH STURM LLP (Juris No. 440474) Elliot A. Dubin (Juris No. 440596) Loren M. Bisberg (Juris No. 421326) Joseph M. Hall (Juris No. 440823) 44 Bearfoot Road, Suite 350, Northborough, MA 01532 Phone: (877) 215-2552 TTY: 711 Attorney Direct Phone No.: (262) 693-4004 Email: LawfirmCT@rsieh.com