Filing # 195404979 E-Filed 04/03/2024 02:40:53 PM
`
`16-2024-SC-006446-AXXX-MA Div: CC-O
`
`
`
`
`PORTFOLIO RECOVERY ASSOCIATES, LLC,
`
`Plaintiff,
`
`vs.
`
`NATASHA PEREZ
`
`Defendant.
`
`
`IN THE COUNTY COURT IN AND FOR
`DUVAL COUNTY, FLORIDA
`
`
`CASE NO.:
`
`
`
`
`
`
`
`
`/
`
`
`
`
`
`
`
`
`
`Complaint
`
`Plaintiff sues Defendant for damages, and would allege:
`
`1. This is an action for damages less than $8,000.
`
`2. Defendant obtained and used a SYNCHRONY BANK/ SYNCHRONY BANK/ AMERICAN
`
`SIGNATURE FURN revolving credit account, XXXXXXXXXXXXX8746 (the "Account").
`
`3. 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 within a reasonable time, resulting in an Account Stated
`
`in the sum of $1,812.99 (See Attached).
`
`4. Plaintiff is 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).
`
`5. Plaintiff received the attached records of the original creditor pursuant to its purchase of the
`
`Defendant’s account. Plaintiff independently checked the records for accuracy, and then integrated
`
`the records into their own business records.
`
`6. Plaintiff has declared Defendant to be in default and demands payment of the balance due on the
`
`Account. Defendant has refused said demand.
`
`7. Defendant is indebted to Plaintiff in the sum of $1,812.99.
`
`8. All conditions precedent to this action have occurred.
`
`
`
`
`ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 04/04/2024 08:42:19 AM
`
`

`

`9. Pursuant to 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 Address: LitigationService@Portfoliorecovery.com and Secondary Address:
`
`Florida_RA@portfoliorecovery.com.
`
`WHEREFORE, Plaintiff demands Judgment against Defendant for $1,812.99, plus costs.
`
`Date: 03/04/2024
`/s/ John Bacus De Jesus
`John Bacus De Jesus, Esq. Bar No. 0111446
`Anthony Joseph Maniscalco, Esq. Bar No. 548707
`Giuseppe Cataudella, Esq. Bar No. 088976
`Jacqueline Elizabeth Ligas, Esq. Bar No. 030009
`Jessica Montes, Esq. Bar No. 47522
`Jorg Menriv Rivera, Esq. Bar No. 0779571
`Juliana Rodriguez, Esq. Bar No. 105514
`Kali Ann Cilli, Esq. Bar No. 1038142
`Luis Dionicio- Elera, Esq. Bar No. 1022109
`Shayna Lynn Singer, Esq. Bar No. 821101
`Attorneys for Plaintiff
`Portfolio Recovery Associates, LLC
`120 Corporate Blvd
`Norfolk, VA 23502
`Phone: 866/428-8102
`www.PRApay.com
`LitigationService@Portfoliorecovery.com
`Florida_RA@portfoliorecovery.com
`
`
`
`
`
`
`
`
`1071947
`
`
`

`

` synchrony
`
`4500 Munson St NW
`Canton OH 44718, US.
`
`BILL of SALE
`
`PRA (S2FSPRMS) — PSCC 180MP — April 2022
`IC“S2FSPRMS_DMPLADebtManager-20220424 15342695422 7000-62401
`iC_S2FSPRMS_DMPLADebtManager-2022042108554989196 1000-61381
`
`For value received andin further consideration of the mutual covenants and conditions
`set forth in the Forward Flow Accounts Purchase Agreement (the “Agreement’), dated as of this
`14" day of February, 2022 by and between Synchrony Bank, formerly known as GE Capital
`Retail Bank; RFS Holding, L.L.C.; Synchrony Card Funding, LLC; and Retail Finance Credit
`Services, LLC., (“Sellers”) and Portfolio Recovery Associates, LLC (“Buyer”), Sellers hereby
`transfer, sell, convey, grant, and deliver to Buyer, its successors and assigns, without recourse
`except as set forth in the Agreement, to the extent of its ownership, the Accounts as set forth in
`the Notification Files (as defined in the Agreement), delivered by Sellers to Buyer on or about
`17" of April 2022, and as further described in the Agreement.
`
`Synchrony Bank
`
`
`
`
`By: Lyne
`Fisher (Apr 28, 2022 16:10 EDT)
`Lynne Fisher
`Title: SVP Recovery Operations
`
`RFS Holding LLC
`
`
`
`
`By: Lyne
`Fisher (Apr 28, 2022 16:10 EDT)
`Lynne Fisher
`Title: Duly Authorized Signatory
`
`Synchrony Card Funding, LLC
`
`
`
`Fisher (Apr 28, 2022 16:10 EDT)
`By: Lyne
`Lynne Fisher
`Title: Duly Authorized Signatory
`
`Retail Finance Credit Services, LLC
`
`
`
`Fisher (Apr 28, 2022 16:10 EDT)
`By: Lyne
`Lynne Fisher
`Title: Vice President
`
`

`

`Sale File: S2FSPRMS_041822.XLSX
`
`***********8746
`
`CNSMR_ACCNT_CRDTR_R
`FRNC_ID_TXT
`GERMSACCTNUM
`***********5945
`CNSMR_ACCNT_ID
`***********1110
`CNSMR_ID
`NATASHA
`CNSMR_NM_FRST_TXT
`PEREZ
`CNSMR_NM_LST_TXT
`CNSMR_IDNTFR_SSN_TXT ***************
`CNSMR_BRTH_DT
`**/**/1996
`CNSMR_ADDRSS_LN_1_TX
`4522 HIGHLAND CT
`T
`CNSMR_ADDRSS_LN_2_TX
`
`T C
`
`T C
`
`NSMR_ADDRSS_LN_3_TX
`
`NSMR_ADDRSS_CITY_TX
`
`JACKSONVILLE
`
`T
`CNSMR_ADDRSS_ST_TXT FL
`CNSMR_ADDRSS_PSTL_CD
`322072153
`_TXT
`RMSHOMEPHN
`RMSWORKPHN
`LANGIND
`EMAIL-ADDRESS
`CNSMR_ACCNT_OWNRSHP
`_TYP_CD
`CNSMR_NM_FRST_TXT_CM
`KR
`CNSMR_NM_LST_TXT_CMK
`
`***************
`ENG
`***************
`
`2/1/2018
`3/15/2021
`
`8/17/2020
`
`R C
`
`NSMR_IDNTFR_SSN_TXT_
`CMKR
`CNSMR_ADDRSS_LN_1_TX
`T_CMKR
`CNSMR_ADDRSS_LN_2_TX
`T_CMKR
`CNSMR_ADDRSS_LN_3_TX
`T_CMKR
`CNSMR_ADDRSS_CITY_TX
`T_CMKR
`CNSMR_ADDRSS_ST_TXT_
`CMKR
`CNSMR_ADDRSS_PSTL_CD
`_TXT_CMKR
`UDEFOPENDATE
`CNSMR_ACCNT_CHRG_OF
`F_DT
`CNSMR_ACCNT_LST_PYMN
`T_DTTM
`
`

`

`Sale File: S2FSPRMS_041822.XLSX
`
`CNSMR_ACCNT_LST_PYMN
`T_AMNT
`CNSMR_ACCNT_DLQNCY_
`DT
`LOSS_AMNT
`INT_RATE
`CURBAL
`NET_PRINCIPAL
`PRINC_LOSS
`ASSOC_COSTS
`ACCRD_INT
`LSTPURCDATE
`REFUDEFOFFICERCDE
`OFF_DESC
`BCLE
`BCLE_DESC
`RMSJDGDATE
`UDEFPOCBARDATE
`REFUDEFBKCHAPTER
`UDEFBKCASENUM
`UDEFDISCHGDATE
`UDEFDISMISSDATE
`UDEFBKR341MTNGD
`UDEFBKFILEDATE
`UDEFBKPOCDT
`REFUDEFCOSTCTR
`UDEFCHGOFFRSN
`STATUS
`SYSDESC
`REFUDEFBIZTYPE
`BUYERCODE
`UDEFECOA
`UDEFSALEDATE
`UDEFBHSCORE
`
`$82.00
`
`9/16/2020
`
`$1,852.99
`0
`$1,852.99
`$1,852.99
`$846.57
`
`$1,006.42
`5/31/2020
`FNI592
`American Signature Furn.
`BK1181
`Synchrony Bank
`
`CFAM
`UNPY
`SOLDFNDG
`Sold, Funding (RECOVERY TAG TYPE)
`RSF
`S2FSPRMS
`1
`4/17/2022
`000
`
`

`

`
`
`
`
`
`
`

`

`AMERICAN SIGNATURE FURNITURE/SYNCB
`
`NATASHA L PEREZ
`Account Number: HEE 2746
`Statement Closing Date:
`02/14/2021
`
`Summary of Account Activity
`Previous Balance
`+ New Purchases
`-
`Payments
`+/- Credits, Fees & Adjustments (net)
`+/-
`Interest Charge (net
`New Balance
`
`Credit Limit
`Available Credit
`Overlimit Amount
`Days in Billing Period
`
`$1,736.19
`$0.00
`$0.00
`$40.00
`$36.80
`$1,812.99
`
`$1,500.00
`$0.00
`$312.99
`28
`
`Payment Information
`New Balance
`Minimum Payment This Period
`Amount Past Due
`Total Minimum Payment Due
`Payment Due Date
`Promotion({s) expiring shortly - see promotional boxes below for
`details
`
`$1,812.99
`$95.00
`$539.00
`$634.00
`03/09/2021
`
`PAYMENT DUE BY 5 P.M. EASTERN ON THE DUE DATE.
`We may convert your payment into an electronic debit. See
`reverse side.
`
`Pay online for free at: mysynchrony.com
`For Synchrony Bank customer service or to report your
`card lost or stolen, call 1-866-396-8254.
`Best times to call are Wednesday- Friday.
`
`Late Payment Warning: If we do not receive your Total
`Minimum Payment Due by the Payment Due Datelisted above,
`you may haveto paya late fee up to $40.00.
`Minimum Payment Warning: Making only the Total Minimum
`Payment Duewill increase the amountof interest you pay and
`the time it takes to repay your balance. For example:
`If you make no
`You will pay off
`|And you will end up
`additional charges
`the balance shown paying an estimated
`on this statement
`total of ...
`using this card and
`in about...
`each month you
`Pay...
`Only the minimum
`payment
`If you would like information about credit counseling services,
`call 1-877-302-8797.
`
`
`
`TOTAL FEES FOR THIS PERIOD ontinued on next page
`
`8 years
`
`$3,667.00
`
`Promotional Expiration Notification
`YOU MUST PAY EACH PROMOTIONAL BALANCEIN FULL BY ITS EXPIRATION DATE TO AVOID PAYING DEFERRED
`INTEREST CHARGES. PLEASE SEE THE PROMOTIONAL PURCHASE SUMMARY SECTION ON THIS STATEMENT
`FOR FURTHER DETAILS. YOU HAVE A PROMOTION(S) EXPIRING ON 04/16/21 AND 06/16/21.
`
`Promotional Purchase Summary
`Promotional
`Promotional
`Deferred
`Balance
`Expiration
`Interest Charge
`Date
`
`Tran Date
`
`Description
`
`04/16/2021
`
`06/16/2021
`
`$50.79
`
`$111.88
`
`$46.23
`
`03/26/2020
`
`$26.65
`
`05/30/2020
`
`Deferred Interest/No Interest If Paid In
`Full
`Deferred Interest/No Interest If Paid In
`Full
`
`Initial
`Purchase
`Amount
`
`$363.79
`
`$111.88
`
`A summary of your promotional purchase is provided above.
`If you have a DEFERRED INTEREST/NO INTEREST IF PAID IN FULL promotion: To avoid paying Deferred Interest Charges
`on these promotion(s), you must pay the entire applicable Promotional Balance by the Promotional Expiration Date.
`
`To make more than one payment see Make Payment To address or pay online at mysynchrony.com.
`
`Transaction Summary
`Tran Date
`
`02/09/2021
`
`02/09/2021
`
`FEES
`LATE FEE
`
`“NOTICE: See reverse side and additional pages {if any) for important information concerning your account.
`CxXH
`1
`F
`14
`210214
`BX PAGE 1 of 3
`9073
`3800
`FRI9 O1DGS302
`
`5302
`
`Pay online at mysynchrony.com or enclose this coupon with your check. Please use blue or black ink.
`Account Number
`
`shortly-see above
`
`Total Minimum
`Payment Due
`
`Past Due
`Amount
`
`Payment
`Due Date
`
`Promotion(s) expiring
`
`New
`Balance
`$1,812.99
`
`|
`
`New address or e-mail?
`Checkthe boxatleft and
`Print changes on back
`
`Payment Enclosed : $
`Payment due includes $ 539.00 past due. Please pay the past due amount PROMPTLY.
`NOTE: You have a Promotional Purchase Expiring. See Promotional Purchase Summary ForDetails.
`
`NATASHA L PEREZ
`4522 HIGHLAND CT
`JACKSONVILLE FL 32207-2153
`
`Make Payment to: SYNCHRONY BANK
`PO BOX 960061
`ORLANDO, FL 32896-0061
`
`

`

`02/14/2021
`
`Transaction Summary (Continued)
`Pest Dote|Reference Number
`INTEREST CHARGED
`INTEREST CHARGE ON PURCHASES
`TOTAL INTEREST FOR THIS PERIOD
`2021 Totals Year-to-Date
`Total Fees Charged in 2021
`Total Interest Charged in 2021
`[Total Interest Paid in 2021
`
`02/14/2021
`
`Interest Charge Calculation
`
`Type of Balance
`
`Purchases
`Deferred Interest(No Interest If Paid In Full
`Deferred Interest(No Interest If Paid In Full
`
`Expiration Date
`
`NA
`04/16/2021
`06/16/2021
`
`Annual
`Percentage
`Rate (APR)
`29.99%
`29.99%
`29.99%
`
`Balance Subject to
`Interest Rate
`
`Interest Charge
`
`$1,599.67
`$95.86
`$136.89
`
`our account online.
`
`Cardholder News & Information
`You can pay your bill online or over the phone. We noticed you've been enjoying our easy paperless payment options, so we
`will no longer be including return envelopes. You can make things even easier by selecting the paperless statement option on
`
`5302
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`5302
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`

`AMERICAN SIGNATURE FURNITURE/SYNCB
`
`NATASHA L PEREZ
`Account Number: Hii 3746
`Statement Closing Date:
`08/17/2020
`
`Summary of Account Activity
`Previous Balance
`+ New Purchases
`-
`Payments
`+/- Credits, Fees & Adjustments (net)
`+/-
`Interest Charge (net
`New Balance
`
`Credit Limit
`Available Credit
`Days in Billing Period
`
`$1,375.94
`$0.00
`$82.00
`$40.00
`$29.47
`$1,363.41
`
`$1,500.00
`$0.00
`31
`
`Pay online for free at: mysynchrony.com
`For Synchrony Bank customer service or to report your
`card lost or stolen, call 1-866-396-8254.
`Best times to call are Wednesday- Friday.
`
`Payment Information
`New Balance
`$1,363.41
`$84.00
`Total Minimum Payment Due
`09/09/2020
`Payment Due Date
`PAYMENT DUE BY 5 P.M. EASTERN ON THE DUE DATE.
`We may convert your paymentinto an electronic debit. See
`reverse side.
`
`ontinued on next page
`
`Late Payment Warning: If we do not receive your Total
`Minimum Payment Due by the Payment Due Date listed above,
`you may haveto pay a late fee up to $40.00.
`Minimum Payment Warning: Making only the Total Minimum
`Payment Duewill increase the amount of interest you pay and
`the timeit takes to repay your balance. Fer example:
`If you make no
`You will pay off
`|And you will end up
`additional charges |the balance shown|paying an estimated
`using this card and| on this statement
`total of ...
`each month you
`in about...
`Pay..-
`Only the minimum
`Payment
`If you would like information about credit counseling services,
`call 1-877-302-8797.
`
`
`
`$3,363.00
`
`8 years
`
`Promotional Expiration Notification
`YOU MUST PAY EACH PROMOTIONAL BALANCE IN FULL BY ITS EXPIRATION DATE TO AVOID PAYING DEFERRED
`INTEREST CHARGES. PLEASE SEE THE PROMOTIONAL PURCHASE SUMMARY SECTION ON THIS STATEMENT
`FOR FURTHER DETAILS. YOU HAVE A PROMOTION(S) EXPIRING ON 04/16/21 AND 06/16/21.
`
`Promotional Purchase Summary
`Promotional
`Promotional
`Deferred
`Expiration
`Balance
`Interest Charge
`Date
`
`Description
`
`04/16/2021
`
`06/16/2021
`
`$50.79
`
`$111.88
`
`$32.81
`
`03/26/2020
`
`$7.52
`
`05/30/2020
`
`Deferred Interest/No Interest If Paid In
`Full
`Deferred Interest/No Interest If Paid In
`Full
`
`Initial
`Purchase
`Amount
`
`$363.79
`
`$111.88
`
`A summary of your promotional purchase is provided above.
`If you have a DEFERRED INTEREST/NO INTERESTIF PAID IN FULL promation: To avoid paying Deferred Interest Charges
`on these promotion(s), you must pay the entire applicable Promotional Balance by the Promotional Expiration Date.
`
`To make more than one payment see Make Payment To address or pay online at mysynchrony.com.
`
`Transaction Summary
`Post Date_[Reference Number
`
`08/17/2020
`
`08/17/2020
`
`8534812KN01TS2G62X
`
`08/09/2020
`
`08/09/2020
`
`PAYMENT- THANK YOU
`FEES
`LATE FEE
`TOTAL FEES FOR THIS PERIOD
`
`($82.00)
`
`$40.00
`$40.00
`
`“NOTICE: See reverse side and additional pages {if any) for important information concerning your account.
`CxXH
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`PAGE 1 of 3
`3073
`38600
`FRIQ O1DGS302
`
`5302
`
`Pay online at mysynchrony.com or enclose this coupon with your check. Please use blue or black ink.
`
`New Balance $84.00
`ramenterctores: SFTWTI IJ. CILI
`
`New address or e-mail?
`Checkthe boxatleft and
`Print changes on back
`
`If you only pay the Total Minimum Due it may not pay off the Promotional Purchase by the Expiration Date.
`
`Total Minimum
`Payment Due
`
`Payment Due Date
`
`Account Number
`
`09/09/2020
`
`$1,363.41
`
`EE 8746
`
`NATASHA L PEREZ
`4522 HIGHLAND CT
`JACKSONVILLE FL 22207-2153
`
`Make Payment to: SYNCHRONY BANK
`PO BOX 960061
`ORLANDO, FL 32896-0061
`
`

`

`08/17/2020
`
`Transaction Summary (Continued)
`Pest Dote|Reference Number
`INTEREST CHARGED
`INTEREST CHARGE ON PURCHASES
`TOTAL INTEREST FOR THIS PERIOD
`2020 Totals Year-to-Date
`‘Total Fees Charged in 2020
`Total Interest Charged in 2020
`[Total Interest Paid in 202G
`
`08/17/2020
`
`Interest Charge Calculation
`
`Type of Balance
`
`Purchases
`Deferred Interest/No Interest If Paid In Full
`Deferred Interest/No Interest If Paid In Full
`
`Expiration Date
`
`NA
`04/16/2021
`06/16/2021
`
`Annual
`Percentage
`Rate (APR)
`29.99%
`29.99%
`29.99%
`
`Balance Subject to
`Interest Rate
`
`Interest Charge
`
`$1,156.95
`$160.86
`$117.83
`
`please contact us to discuss how we can help.
`
`Cardholder News & Information
`We are here to support you and are working hard to ensure our Synchrony Team members can continue to provide you with
`uninterrupted, dependable service. We encourage you to use our online and mobile servicing tools. To register or log in te your
`account, navigate to "Login" at the top of the www.MySynchrony.com home page.
`
`As COVID-19 andits impact continue to evolve and develop, we remain focused on the health and safety of our employees and
`our communities, as well as our commitment to you, our customers.
`
`We are also aware that some of our customers may experience financial hardship as a result of COVID-19. If you are impacted,
`
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`5302
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`93073
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