On December 31, 2014 a
Complaint,Petition
was filed
involving a dispute between
Portfolio Recovery Associates Llc,
and
Ferrell, Kisha,
for SMALL CLAIMS 3 - $501 - $2,500
in the District Court of Pinellas County.
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Case Number: 15-000022-SC
Filing # 22097155 E-Filed 12/31/2014 04:17:50 PM
IN THE COUNTY COURT IN AND FOR
PINELLAS COUNTY, FLORIDA
PORTFOLIO RECOVERY ASSOCIATES, LLC, CASE NO.:
Plaintiff,
vs.
KISHA FERRELL,
Defendant(s).
/
COMPLAINT
Plaintiff sues Defendant for damages, and would allege:
1, This is an action for damages less than $5,000.
2. Defendant obtained and used a GE CAPITAL RETAIL BANK / GE CAPITAL RETAIL BANK / OLD NAVY revolving credit
account, NE (the "Account’).
3. Plaintiffis the successor in interest of said Account having purchased said Account in good faith, for value, and in the ordinary
course of business. (See Attached).
4. Defendant did make purchases and charged same to the Account, but after statements were provided to Defendant, Defendant
failed to make the monthly payments due upon the Account and failed to object to the balance then owing, resulting in an
Account Stated in the sum of $1,194.56. (See Exhibit B).
5. Plaintiffhas declared Defendant to be in default and demands payment of the balance due on the Account. Defendant has
refused said demand.
6. Defendantis indebted to Plaintiff in the sum of $1,194.56.
7. Allconditions precedent to this action have occurred.
8. Pursuantto Rule 2.516, Plaintiff designates the following email addresses for the purpose of service of all documents required
to be served pursuant to Rule 2.516 in this proceeding. Primary E-Mail Addresses: David M. Greenbaum,
dmgreenbaum @portfoliorecovery.com, Racquel A White, rawhite@portfoliorecovery.com, Chantel C. Wonder,
ccwonder@portfoliorecovery.com, Jessica L. Montes, jlmontes @portfoliorecovery.com, Secondary E-Mail Address:
LitigationService@portfoliorecovery.com.
WHEREFORE, Plaintiff demands Judgment against Defendant for $1,194.56, plus costs.
By: /s/ Chantel C. Wonder
Portfolio Recovery Associates, LLC [ ]David M. Greenbaum, ESQ., FBN 0044057 Date: October 30.
120 Corporate Blvd, Norfolk, VA23502 [ ]Racquel A White, ESQ., FBN 0392669 2014
Telephone: 1-866-428-8102 Fax: (757) 518-0860 [Chantel C. Wonder, ESQ., FBN 87601
LitigationService@portfoliorecovery.com [ Jessica L. Montes, ESQ., FBN 47522
17-29852
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that Purpose,
***ELECTRONICALLY FILED 12/31/2014 4:17:47 PM: KEN BURKE, CLERK OF CIRCUIT COURT, PINELLAS COUNTY***
Document Filed Date
December 31, 2014
Case Filing Date
December 31, 2014
Category
SMALL CLAIMS 3 - $501 - $2,500
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Case Number: 15-000022-SC Filing # 22097155 E-Filed 12/31/2014 04:17:50 PM IN THE COUNTY COURT IN AND FOR PINELLAS COUNTY, FLORIDA PORTFOLIO RECOVERY ASSOCIATES, LLC, CASE NO.: Plaintiff, vs. KISHA FERRELL, Defendant(s). / COMPLAINT Plaintiff sues Defendant for damages, and would allege: 1, This is an action for damages less than $5,000. 2. Defendant obtained and used a GE CAPITAL RETAIL BANK / GE CAPITAL RETAIL BANK / OLD NAVY revolving credit account, NE (the "Account’). 3. Plaintiffis the successor in interest of said Account having purchased said Account in good faith, for value, and in the ordinary course of business. (See Attached). 4. Defendant did make purchases and charged same to the Account, but after statements were provided to Defendant, Defendant failed to make the monthly payments due upon the Account and failed to object to the balance then owing, resulting in an Account Stated in the sum of $1,194.56. (See Exhibit B). 5. Plaintiffhas declared Defendant to be in default and demands payment of the balance due on the Account. Defendant has refused said demand. 6. Defendantis indebted to Plaintiff in the sum of $1,194.56. 7. Allconditions precedent to this action have occurred. 8. Pursuantto Rule 2.516, Plaintiff designates the following email addresses for the purpose of service of all documents required to be served pursuant to Rule 2.516 in this proceeding. Primary E-Mail Addresses: David M. Greenbaum, dmgreenbaum @portfoliorecovery.com, Racquel A White, rawhite@portfoliorecovery.com, Chantel C. Wonder, ccwonder@portfoliorecovery.com, Jessica L. Montes, jlmontes @portfoliorecovery.com, Secondary E-Mail Address: LitigationService@portfoliorecovery.com. WHEREFORE, Plaintiff demands Judgment against Defendant for $1,194.56, plus costs. By: /s/ Chantel C. Wonder Portfolio Recovery Associates, LLC [ ]David M. Greenbaum, ESQ., FBN 0044057 Date: October 30. 120 Corporate Blvd, Norfolk, VA23502 [ ]Racquel A White, ESQ., FBN 0392669 2014 Telephone: 1-866-428-8102 Fax: (757) 518-0860 [Chantel C. Wonder, ESQ., FBN 87601 LitigationService@portfoliorecovery.com [ Jessica L. Montes, ESQ., FBN 47522 17-29852 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that Purpose, ***ELECTRONICALLY FILED 12/31/2014 4:17:47 PM: KEN BURKE, CLERK OF CIRCUIT COURT, PINELLAS COUNTY***