Complaint,Petition: BANK OF AMERICA, N.A. v. ALDMMAD, MOHAMED M

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                                R&R File No. 1325635

BANK OF AMERICA, N.A. SUPERIOR COURT

FAIRFIELD JUDICIAL DISTRICT
AT BRIDGEPORT
Plaintiff

vs
MOHAMED M ALDMMAD

Defendant (s}

COUNT I (ACCOUNT STATED)

1. The plaintiff, Bank of America, N.A., is a national banking association
organized and existing under the laws of the United States of America and
having its principal place of business in Charlotte, North Carolina.

2. Bank of America, N.A. ("BANA") is a wholly owned subsidiary of Bank of
America Co: ration and the successor-in-interest to FIA Card Services,
N.A. formerly known as MBNA America Bank, N.A. ("FIA"). FIA was merged
into and under the charter and title of BANA effective October 1, 2014.

3. Defendant(s) used a credit account issued by plaintiff currently
identified by account No, *##tteeke#3366 and agreed to make payments
for goods and services charged and/or cash advances made upon such

credit account.

4. Defendant(s) had a credit account with Bank of America, N.A. and in
connection with that account, plaintiff mailed, delivered, sent or
otherwise transmitted periodic account statements to the defendant setting
forth all of the charges and credits applicable to the account, as well as
the balance due.

5. Upon information and belief, the defendant received and held these
statements for an unreasonable time with no known unresolved dispute,
xrotest, or objection, as defined by the Federal Truth-in-Lending

ct, 15 U.S.C 1666(a), which requires submission of written notice of
objection within sixty (60) days of transmission of the account statement.

6. Based on these circumstances, the statements are presumed accurate, and
constitute an account stated, which is prima facie evidence of the
correctness of the account.

7. The final statement transmitted to the defendant, indicating a balance
due and owing, was accepted and held by the defendant for an unreasonable
time without known unresolved dispute, protest, or notice of defect.

8. Plaintiff seeks damages for the account stated balance minus any
credit(s) on the account occurring after the last statement that was
transmitted.

9. Payment was demanded on or before 12/12/19 and $17,770.29 is due and
owing from the defendant(s) to the plaintiff.

Page 1 of 3R&R File No. 1325635

NOTICE IS HEREBY GIVEN to the defendant that the laintift intends to seek
satisfaction of any judgment rendered in plaintiff's favor in this action
from any debt accruing to the defendant by reason of the defendant's
personal services.

THE PLAINTIFF CLAIMS:

1. Money damages; and
2. Costs of suit.

Dated at Bast Hartford, Connecticut 12/12/19

 

1787 VETERANS MEMORTAL HIGHWAY
ISLANDIA, NY 11749
(800) 298-6058

THIS COMMUNICATION IS FROM A DEBT COLLECTOR

Page 2 of 3R&R File No. 1325635

BANK OF AMERICA, N.A. SUPERIOR COURT

FAIRFIELD JUDICIAL DISTRICT
AT BRIDGEPORT
Plaintiff

VS
MOHAMED M ALDMMAD
Defendant (s)

CLAIM FOR RELIEF

The amount, legal interest or property in demand is fifteen thousand
dollars ($15,000) or more, exclusive of interest and costs.

  

“ a .
KIMBERLY PETERSON, ESQ.
RUBIN & ROTHMAN, LLC.
SURIS NO. 438783
1787 VETERANS MEMORIAL HIGHWAY
ISLANDIA, NY 11749
(800) 298-6058

THIS COMMUNICATION IS FROM A DEBT COLLECTOR

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