Filing # 207695132 E-Filed 09/25/2024 04:31:27 PM
`
`IN THE COUNTY COURT OF THE NINTH JUDICIAL CIRCUIT
`IN AND FOR ORANGE COUNTY, FLORIDA
`CIVIL DIVISION
`
`CKS Prime Investments, LLC
`Plaintiff,
`
`VS.
`
`JOSELYNE RODRIGUEZOLAN
`Defendant(s).
`
`CASE NUMBER:
`
`JUDGE:
`
`Our File # 5023634
`
`COMPLAINT
`
`COMES NOW, the Plaintiff, CKS Prime Investments, LLC, by and through its undersigned Counsel, and
`sues Defendant(s), JOSELYNE RODRIGUEZOLAN, and states as follows:
`
`GENERAL ALLEGATIONS
`
`This is an action for damages that does not exceed $8,000.00 and is within the jurisdictional limits of
`this Honorable Court.
`
`2. Plaintiff has been informed and believes that Defendant(s), JOSELYNE RODRIGUEZOLAN, currently
`reside(s) within the jurisdictional boundaries of ORANGE County, therefore making this Court the
`proper venue to bring the instant action.
`
`in the name of
`3. Upon Defendant' s(s') request, THE BANK OF MISSOURI established a credit account
`Defendant(s), JOSELYNE RODRIGUEZOLAN, either by application, telephone, or
`internet, and
`pursuant to the terms of said application issued a credit account bearing the
`
`4. Prior to the commencement of this action, Plaintiff, CKS Prime Investments, LLC, acquired
`Defendant's(s') account originated by THE BANK OF MISSOURI.
`demands have been made by Plaintiff upon Defendant(s) for payment, there
`5. Although numerous
`remains an amount due and owing.
`6. Plaintiff and its predecessors have duly performed all promises, conditions precedent, and agreements as
`required.
`
`7. This is an attempt to collect a debt and any information obtained herein will be used for that purpose.
`COUNT 1- ACCOUNT STATED
`
`Plaintiff re-adopts and re-alleges allegations one
`
`(1) through seven (7) and further states as follows:
`
`8. The current outstanding balance is $1,427.41. The account was charged off on March 31, 2023. See
`Attached.
`
`

`

`9. Defendant(s) used or made payments on the subject account. A final statement was sent to the
`Defendant(s) to which the Defendant(s) did not object.
`
`WHEREFORE, Plaintiff, CKS Prime Investments, LLC, respectfully requests this Honorable Court enter
`Judgment in its favor against Defendant(s), JOSELYNE RODRIGUEZOLAN, in the sum of $1,427.41 together
`with court costs, post-judgment interest at the statutory rate and any other just and further relief as this
`Honorable Court deems just and proper.
`
`Date: 09/21/2024 I
`
`CONTACT
`ATTORNEY
`Susan Sparks
`Phone: (656) 400-5185
`E-mail: SSparksrdTauschsturm_com
`
`INFO:
`
`•
`
`Siisan Sparks
`Richard A. Russell - Bar #586651
`Kaelin L. Richard - Bar #1018432
`Adrianna M. Lopez-Colon - Bar #1049425
`Susan Sparks - Bar #0033626
`Ryan Enage - Bar #1038439
`Erik Zogg - Bar #0088888
`Alexandra Flinn - Bar #0965250
`Dalton Clark - Bar #1023237
`J. Mark Laczewski - Bar #42919
`
`RAUSCH STURM LLP
`ATTORNEY FOR PLAINTIFF
`100 Second Avenue South, Suite 306S
`Saint Petersburg, FL 33701
`(855) 560-6866 TTY: 711
`lawfirml-L@rauschsturm.com
`
`

`

`VERVE
`
`SUMMARY
`
`XXXX
`
`XXXX
`
`Limit
`Credit
`Available
`Credit
`Days this Billing Cycle
`Closing Date
`Statement
`Amount
`Past Due
`Previous
`Balance
`- Payments
`Credits
`-1- Purchases
`+ Fees
`+ Cash
`
`Advances
`
`-
`
`+
`
`=
`
`INTEREST
`New Balance
`
`CHARGES
`
`-----
`
`•-,.r.
`
`Questions:
`Services
`Cardholder
`or Stolen
`
`Lost
`
`1-866-449-4514
`1-800-556-5678
`
`Account
`
`Trans
`
`Date
`
`Activity Since
`Post Date
`
`Last Statement
`
`Reference
`
`Number
`
`04/19
`04/19
`
`04/19
`04/19
`
`INTEREST
`
`Your
`
`Annual
`
`JOSELYNE
`
`RODRIGUEZOLAN
`
`XXXX XXXX
`Closing Date: April 19, 2023
`
`ge i
`
`titreard.
`
`INFORMATION
`
`PAYMENT
`New Balance
`Minimum Payment Due
`Payment
`Due Date
`Late Payment Warning:
`date listed above, you may
`
`$1,42TA1
`$632.00
`May 16, 2023
`payment by the
`your minimum
`receive
`do not
`to pay up to a $40.00 late fee.
`
`If we
`have
`
`the
`You will pay off
`this
`balance
`shown
`on
`statement
`in about...
`
`And you will end up
`paying an
`estimated
`total
`of...
`
`payment each
`If you make only the minimum
`Payment Warning:
`Minimum
`period, you will
`you longer to pay off your
`in interest
`and it will
`take
`pay more
`For example:
`balance.
`no additional
`If you make
`charges using this
`card
`you pay...
`and each month
`Only the minimum
`payment
`like information
`If you would
`1-877-413-6322
`
`2 years
`credit counseling services,
`
`about
`
`1,427.00
`
`call
`
`$0
`30
`April 19, 2023
`$574.00
`$1,427.41
`$0.00
`$0.00
`$0.00
`$0-00
`$0.00
`$0.00
`$1,427.41
`
`,....J Send Correspondence to:
`
`Cardholder
`PO Box
`Buffalo
`
`Services
`3220
`NY 14240
`
`Mail Payments to:
`Verve
`6812
`PO Box
`Carol Stream IL 60197-6812
`
`Description
`Transaction
`Fees & Other Charges
`TOTAL
`FEES
`FOR THIS
`Interest Charges
`Interest Charge on Purchases
`Interest Charge on Cash Advances
`TOTAL
`INTEREST
`FOR THIS
`PERIOD
`
`PERIOD
`
`Amount
`
`1
`
`0.00
`
`0.00
`0.00
`0.00
`
`Totals
`2023
`fees charged in 2023
`charged in 2023
`interest
`
`Total
`
`Total
`
`Year-to-Date
`
`$150.00
`$106.63
`
`CHARGES
`Percentage Rate
`Type of Balance
`Purchases
`Cash Advances
`(v) = Variable
`Rate
`Method:
`Balance
`Calculation
`We will not charge you interest
`
`(APR) is the annual
`interest
`Annual
`
`account.
`rate
`on your
`Percentage Rate
`(APR)
`34.40%
`(v)
`34.40% (v)
`
`Subject to
`Balance
`Interest Rate
`$0.00
`$0.00
`
`Interest
`
`Charge
`$0.00
`$0.00
`
`of page
`side
`See reverse
`1
`on purchases if you pay
`your
`
`subject
`for explanation of how the
`balances
`entire
`balance
`by the payment due date.
`
`to interest
`
`rate is calculated.
`
`NOTICE:
`
`SEE REVERSE
`
`SIDE
`
`FOR IMPORTANT
`
`INFORMATION
`
`AND BILLING
`
`RIGHTS
`
`SUMMARY.
`
`Visit
`
`us
`
`on
`
`the web
`
`at:WWW
`
`VERVECARDINFO_com
`
`1070
`
`NISH
`
`001
`
`3
`
`19
`
`230419
`
`0
`
`Z X PAGE
`
`1 of 3
`
`0
`
`1
`
`PLEASE DETACH
`
`COUPON AND RETURN PAYMENT
`
`USING THE ENCLOSED
`
`ENVELOPE
`
`- ALLOW 5 DAYS FOR MAIL DELIVERY
`
`Verve
`PO BOX 6812
`Carol Stream IL 60197-6812
`
`Check
`box
`change on
`
`to indicate
`back of
`
`address
`this coupon
`
`Mail Payments to:
`
`PAYMENT
`
`INFORMATION
`
`Balance:
`New
`Payment Due:
`Minimum
`Payment Due
`Date:
`Amount
`Enclosed:
`
`$
`
`XXXX
`
`XXXX
`
`$1,427.41
`$632.00
`May 16, 2023
`
`PLEASE MAKE YOUR PAYMENT
`VERVE
`
`PAYABLE
`
`TO:
`
`Verve
`PO Box 6812
`Carol Stream IL 60197-6812
`1-I11I
`11111111411111.1111.11111111114"1111111111" 111111111
`
`1-1
`
`RODRIGUEZOLAN
`JOSELYNE
`1179 BLACK FOOT AVE
`ORLANDO
`FL 32825-6228
`
`Exhibit
`
`A
`
`

`

`of
`
`on
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`the Balance Subiect to the Interest Rate
`Interest Charge Calculation
`and Determination
`separately for purchases,
`The amount
`charged is determined
`cash advances
`of
`interest
`by
`and is calculated
`transfers
`and balance
`subject to interest
`applying the monthly periodic rate to the respective balance
`The monthly periodic rate is deterrnined
`by dividing
`rate.
`the Annual Percentage Rate applicable to the type of balance
`by 12.
`The Balance Subject
`cash
`is calculated
`Interest Rate
`separately for purchases,
`and is figured by
`transfers
`and balance
`advances
`to
`adding the respective outstanding balance
`for each day of the billing cycle, and then dividing the sum
`the daily balances
`by the number
`of
`of days in the billing cycle. Each daily outstanding balance
`by adding to the previous days balance
`is determined
`the amount
`of new
`purchases,
`cash advances,
`transfers,
`respectively and deducting payments and credits.
`balance
`new
`or
`new
`Payment Crediting and Credit Balance. Payments received
`by 5:00 p.m. prevailing Eastern
`specified on
`the front
`Time
`at
`the location
`the phrase "MAIL PAYIV1ENTS
`of
`the statement
`after
`TO'' will be credited
`the date of receipt to the account
`specified on
`the payment
`as
`Payments received
`specified or payments that do not conform to the requirements set
`at
`locations
`other
`than the address
`forth
`coupon.
`(e.g. missing payment stub, payment envelope other
`or with the periodic statement
`than as provided with your statement, multiple
`on
`or multiple coupons
`checks
`envelope) may be subject
`five days of receipt.
`to delay in crediting, but shall be credited
`in the same
`within
`If there
`balance
`is a credit
`you may request,
`in writing, a full
`due on your account,
`refund.
`Submit
`indicated
`request to the address
`your
`the phrase "SEND CORRESPONDENCE
`on the front of this statement
`after
`TO."
`By sending your check, you are authorizing the use
`debit
`from the account
`of the information
`on your check
`electronic
`to make a one-time
`debit, which rnay be posted to your account
`the check
`This electronic
`to which
`is drawn.
`as early as the date your check
`is received, will
`be only for
`The original check will be destroyed, and we will
`check.
`the amount
`of your
`its image in our
`retain
`records.
`If you have
`questions please call
`this billing statement.
`the Cardholder
`number
`the front of
`Services
`on
`fee, you may avoid paying this annual
`fee by sending written
`notification
`has been assessed
`an annual
`Annual
`Fee.
`If your
`account
`termination, within
`30 days following the mailing date of
`this statement
`to the address
`found indicated
`on the front of
`this statement
`the phrase "SEND
`your card(s) during this 30 day period but
`immediately thereafter
`CORRESPONDENCE
`TO".
`You may use
`send your card(s), which
`in half,
`to this same
`you have cut
`address.
`Negative Credit Reports. We may report information
`Late payments, missed payments, or other
`to credit bureaus.
`about
`your account
`defaults
`report.
`on your account may be reflected
`in your credit
`What To Do if You Think You Find A Mistake
`On Your Statement
`there is an
`If you think
`write to
`the "SEND CORRESPONDENCE
`on your staternent,
`error
`us at
`letter, give us
`the following inforrnation:
`statement
`In your
`Account
`information:
`Your
`and account
`number.
`name
`the suspected error.
`Dollar
`amount:
`The dollar amount
`of
`Description of Problem:
`If you think
`there is an
`error
`on
`believe
`it is a mistake.
`You must contact
`us within 60 days after
`the error appeared on your statement.
`You must notify us of any potential errors
`in writing. You may call
`if you do we
`us, but
`in question.
`and you may have to pay the amount
`errors
`investigate whether
`While we
`the following are
`true:
`or not
`there has been an error,
`in question, or report you as delinquent on that amount.
`We cannot
`try to collect
`the amount
`The charge in question may remain
`and we may continue
`to charge you interest
`statement,
`your
`that we made a mistake, you will not have to pay the amount
`determine
`in question or any interest
`amount.
`in question, you are
`responsible for the remainder
`While you do not have to pay the amount
`of your balance.
`We can apply any unpaid amount
`against your credit
`limit.
`Your Riohts
`If You Are Dissatisfied
`With Your Credit
`Card Purchases
`with the goods or services
`that you have purchased with your credit card, and you have tried in good faith to correct
`if you are dissatisfied
`problem with the merchant, you may have the right not
`to pay the remaining amount
`due on the purchase.
`the following must be true:
`To use
`this right, all of
`100 miles of your current mailing address, and the
`1. The purchase must have been made in your home state
`or within
`purchase price must have been more
`(Note: Neither of
`than $50.
`these are necessary if your purchase was
`based
`on an
`that sold you the goods or services.)
`advertisement
`if we own
`we mailed to you, or
`the company
`2. You rnust
`the purchase. Purchases made with cash advances
`have used your credit card for
`do not qualify.
`that accesses
`your
`not yet have fully paid for
`the purchase.
`3. You must
`with the purchase, contact
`If all of
`the criteria above are
`rnet and you are still dissatisfied
`shown
`on the front of
`TO" address
`this statement.
`investigate, the same
`While we
`rules apply to the disputed amount
`finish our
`After we
`above.
`as discussed
`and you do not pay we may report you as delinquent_
`our decision. Atthat point, if we think you owe
`an amount
`your VantageScore® Credit
`About
`Score
`Your Vantagescore® credit
`in your Experian credit
`report, so it's important to rnake sure
`that
`information
`is based
`report is
`score
`on
`Remember, your Vantagescore credit
`a general snapshot of your credit history at a specific point in time and can
`accurate.
`reflects
`score
`owed, length of credit history, new credit opened,
`types of credit, and other
`be influenced
`found on your
`factors
`by payment history, amount
`fluctuate month to month. However,
`It can
`there
`if you believe
`is an error,
`account.
`you can:
`report at www.annualcreditreport.com
`free annual Experian credit
`a.Request your
`reviewing your
`information
`that may have affected
`h. After
`report, if you find inaccurate
`Experian credit
`report at www.experian.com
`
`of
`after
`must
`
`TO" address
`
`shown
`
`on the front of
`
`this
`
`your bill, describe
`
`what you believe
`
`is wrong
`
`and why you
`
`are
`
`not
`
`required to investigate any potential
`
`that
`on
`or other
`
`But, if we
`amount.
`fees related to that
`
`the
`
`from an ATM or with a check
`
`us in writing at the ''SEN D CORRESPONDENCE
`investigation, we will
`
`tell you
`
`your score,
`
`you can
`
`dispute your
`
`NAME CHANGE
`
`ADDRESS CHANGE
`
`Last
`First
`Street
`
`Please use blue or black ink
`
`to complete form
`
`LLI_LL1111111_L_JII
`
`City
`Home Phone
`(
`REQUIRED
`SIGNATURE
`TO AUTHORIZE
`CHANGES
`
`)
`
`Signature
`
`-1_1_1_1_1
`
`Statel_j_IZipCode
`Business Phone
`(
`)
`
`I
`
`I
`
`OM 1070001
`
`07 06 21
`
`IIIIIIII
`11111111
`
`-
`
`Exhibit
`
`A
`
`

`

`VERVE
`
`Important News
`
`JOSELYNE
`
`RODRIGUEZOLAN
`
`XXXX XXXX
`Closing Date: April 19, 2023
`
`Cell/
`
`mostemard.
`
`FOR A FREE, EASY AND SECURE WAY TO ACCESS
`YOUR
`COM.
`VISIT WWW VERVECARDINFO
`DELIVERY, VIEW CURRENT
`ELECTRONIC
`STATEMENT
`INFORMATION, MAKE PAYMENTS
`AND MUCH MORE!
`
`INCLUDE
`FEATURES
`TRANSACTION
`
`1070
`
`MSH
`
`001
`
`3
`
`19
`
`230419
`
`0
`
`Z X PAGE
`
`2 of 3
`
`0
`
`1
`
`Exhibit
`
`A
`
`

`

`1070
`1070
`
`MSH
`MSH
`
`001
`001
`
`63)
`3
`
`«19°
`19
`
`230419
`230419
`
`0
`0
`
`Z X PAGE 3 of 3 10
`Z X PAGE
`3 of 3
`1 0
`
`Exhibit A
`Exhibit
`A
`
`