Redacted by Clerk of Court
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`_———————————
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`Cn
`
`INTHEMONTGOMERYCOUNTYMUNICIPALCOURT,EASTERN.
`
`| |
`
`LVNV FUNDING LLC
`C/O 55 BEATTIE PLACE SUITE 110
`GREENVILLE,SC 29601
`
`Plaintiff
`vs.
`
`JEREMIAH C HEDLUND
`4133 FOREST RIDGE BLVD
`RIVERSIDE,OH 45424-4836
`
`Defendant
`
`MONTGOMERY COUNTY, OHIO
`)
`CASE NUMBER:24+1c.vFAAA
`
`JUDGE:
`
`COMPLAINT
`
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`FIRST COUNT
`NONPAYMENT OF ACCOUNT
`
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`1. Plaintiff is the assignee of Defendant’s Account, Account numberiiX1013, an
`
`Account which wasused for the Defendant's benefit. The Account was formerly with Comenity Bank.
`
`This court is the proper court because Plaintiff is informed and believes that Defendant Jeremiah C
`2.
`Hedlundis a resident of Montgomery County, State of Ohio.
`
`Defendant used the Accountat various times, and thereby requested loans, advances, services, and/or
`3.
`payments of various sums of moneyfor the use and benefit of the Defendant.
`
`4.
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`The account documentation is attached hereto as Exhibit A.
`
`Upon information and belief, Defendant madethe last payment on the account on or about November23,
`5.
`2019 and the Account was charged-off by the Original Creditor on or about June 30, 2020.
`
`6.
`
`Defendanthas defaulted on the repaymentobligation and has failed to repay the balance of $2,946.74.
`
`7.
`Defendant.
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`As a result of the assignment, Plaintiff became, and nowis entitled to recover the amount owed by the
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`There is presently due the Plaintiff from the Defendant for the money loaned/money paid out on
`8.
`Defendant’s Account, the sum of $2,946.74.
`
`SECOND COUNT
`UNJUST ENRICHMENT
`
`9.
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`10.
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`Plaintiff incorporates by reference herein, each allegation set forth above.
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`Defendantreceived billing statement(s), but has failed to repay the unpaid balance.
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`Defendant knowingly retained the benefits derived from the use of the Account, without having repaid the
`11.
`balance outstanding on the Account.
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`Retention of the benefits conferred upon the Defendant under these circumstances would be unjust
`12.
`without requiring the Defendant to make payments for the same.
`
`THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY
`INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 24-115774 VMIIEIAILIIVIVNINNICNVANONUSHAAT00000C0000
`
`

`

`Defendant has been unjustly enriched in the amountof the outstanding balance set forth above, as
`13.
`Defendant knew or should have knownthat the credit was not being provided gratuitously.
`
`WHEREFORE,Plaintiff prays for judgment against Defendant in the amount of $2,946.74 with statutory interest
`from the date ofjudgment, costs of this action, and such other and further relief as the Court deems just and proper under
`the circumstances.
`
`Respectfully Submitted,
`
`STENGER & STENGE
`
`
`Attorneys for Phaintif
`
`Dated:
`
`File No. 24-115774
`
` By:
`
`:
`
`id B. Bokor(
`Stenger & Stenger, P.C.
`Attorneys for Plaintiff
`2618 East Paris Avenue SE
`Grand Rapids, MI 49546
`Court Inquiries Ph: (877) 988-2280
`Defendant/Counsel Ph: (877) 375-4220
`Email: ohio@stengerlaw.com
`
`PRAECIPE FOR SERVICE
`Please issue a Summonsfor each Defendantaslisted in the above case caption via U.S. Certified Mail, return
`receipt requested. If service of process by certified mail is returned by the postal authorities with an endorsement of
`"refused" or "unclaimed", the undersigned waives notice of same by the Clerk and requests ordinary mail service in
`accordance with Civil Rule 4.6 (C) or 4.6 (D).
`Respectfully Submitted,
`
`Dated:
`
`File No. 24-115774
`
`STENGER & STENGER, P.C.
`Attorneys for
`
`
`
`By:
`
`avid B. Bokor (OSCR#: 0061515)
`Stenger & Stenger, P.C.
`Attorneys for Plaintiff
`2618 East Paris Avenue SE
`Grand Rapids, MI 49546
`Court Inquiries Ph: (877) 988-2280
`Defendant/Counsel Ph: (877) 375-4220
`Email: ohio@stengerlaw.com
`
`THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. WE ARE ATTEMPT
`
`INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.24-115774AGA
`
`OLLECT
`
`

`

`EXHIBIT A
`
`THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY
`INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.24-115774
`
`

`

`thee
`
`Summary.of account activity
`Accountno.
`0043-438
`
`aoe
`
`PAGE 1 OF 4
`
`Paymentinformation
`New balance
`Minimum payment due
`Payment due date
`
`$2,946.74
`$1,008.50
`07/07/2020
`
`$2,846.91
`Previous batance
`0.00
`Payments
`Late paymentwarning:
`0.00
`Othercredits
`If we do not receive your minimum payment by 07/07/2020 you may
`0.00
`Purchases
`; havetoPayup|toa$40.00fatefee.
`_.
`0.00
`Otherdebits
`Minimum paymentwarning: it youmakeonlythemminimum
`40.00
`Fees charged
`payment for each period, you will pay morein interest andit will take
`Interestcharged oe , 89.88
`you longer topay off your balances. Forexample: |
`New balance
`$2,946.74
`:
`Ttyou makeno additional |You will pay of) Andyou will
`Past due amount
`863.50
`} charges using this card
`=; the balance shown= end up paying an:
`Credit limit
`$2,290.00
`; and each month you pay:
`i; onthe statement
`! estimated total
`:
`Available credit
`$0.00
`tone
`Statementclosing date
`o@/11/2020
`tinabout=k
`
`
`
`Daysin billing cycle ‘! Onlytheminimum:Payment“Frye7years30 4. $5077
`eneromeeetome Sra
`ae ee ee Fes a ee
`For information regarding credit“counseling services,
`calt 1-800-284-1706,
`
`.
`
`AMOUNT
`
`{\
`
`ke
`
`|Lo
`Skip signing in to pay and use Comarity’'S EasyPay. Ws sale and¢convenient.1. Useyyoursmartphone camera orcode
`ureader to scan the GR codeprinted on your payment stub belowto gel starled.
`Details of your transactions
`TRANSQATE
`TRANSACTION DESCRIPTION/.OCATION
`Fees
`06/07/2020
`
`40.00
`$40.00
`
`LATE FEE
`Total fees charged for this period
`Interest charged
`Interest charge on purchases.
`Total Interestfor this perlod
`ro ceec eeineni ng
`:
`2020totals year to date
`:
`: Tolal fees charged in 2020
`$237.00 }
`+ om aed
`; Total interest charged in 2020
`$343.97 :
`Interest charge calculation
`Your Annuat Percentage Rate (APR)is the annualinterest rate on your account. See BALANCE COMPUTATION METHOD
`on page 2 for more details. Minimum interest charge may exceed interest charge below, per your credit card agreement.
`TYPE OF
`BALANCE SUBJECT
`INTEREST
`BALANGE
`APR
`TO INTEREST RATE
`CHARGE
`Purchasesprior to 10/06/2019
`24.9900% iv)
`2,495.45
`51.25
`Purchases
`26,9900% (v)
`986.88
`8.58
`
`$59.83
`$59.83
`
`Additional important messages
`Affected by COVID-19? Comenity Bank Offers Support
`As the bank that manages yourcredit card, our hearts go out to those affected by the coronavirus
`(COVID-19) pandemic.
`The support we're extending to you.If you're experiencing financial hardship because of COVID-19,
`please call 1-888-252-5484 (TDD/TTY:1-800-695-1788) to discuss how we may beable to help.
`(CONTINUED)
`NOTICE: Gea reverse side far impartant infurmation
`
`
`
`l/,beau
`.
`t+Newbalance
`iL1 Minimumpayment !;
`fullbeau “go
`[$2,946.74 _$1,008.50|
`Payment must reach us by
`6 pm ET on 07/07/2020.
`Amountenciozed:
`ite nnaPecans
`s
`‘
`Pisasemakecheckpayableto.~—SOSSSSCSsS
`COMENITY - fullbeauty
`Please return this portion along with your paymentta:
`PO BOX 659728
`SAN ANTONIO TX 78265-9728
`
`roy
`j_}
`
`.
` Yese havemovedorupdated my
`
`We YTLaaaDeenadeedDaeenDaedate] EadyfogLpy
`JEREMIAH G HEDLUND
`859 REVERE VILLAGE CT
`DAYTON OH 45458-3445
`
`a
`
`8,5
`
`994
`
`Aoooergbiepeedeaf leetEEElee
`
`

`

`
`
`records,
`‘Keep itisportionfor your
`CREDIT REPORTING. We nay iepoil infeuenalion about your arecale
`What To Do It You Think You Find A Mistake On Your Statement
`credit bureaus,Lale payments, missed payments, or cther detaults on your
`accaunt may be sellected in yourcredit report...
`A you Think these is onetror ur your slelement, virile ta us at: Comenily
`NOTICE OF CREDIT REPORT DiSPUTES
`Bank PO Box 182/82, Coluibus, Qhiy 43218-2/82.
`U you betieve (he account intarnation we mported ly a corsumer reporting
`Ie your tetfer, give us Ihe (ollowing infarmalion:
`wagynry ts inaccurale, you inay subinil a direc! dispule [a Cumenity Bank 70
`* Accountinformation: Your name and account number.
`Box 182489, Columbus, Ohio $3218-2/89. Your waiilen dispute must
`© Doliar amount:The dollar amount of the susprctod ener,
`provide sullicten| insuimnation ty identity Ihe accgunl and specily whythe
`informationis inaccurate:
`.
`© Dessiption of Problem: Wf you (honk Uae: és an eror an your dill,
`© Account infarmation: Your name and accam! number
`describe what you believe iswrong and why you tetieve it is a mistake,
`* Contact Information: Your autiress and iuitphone auraher
`You must contact us wilhin 60 days atter the error appeared on your
`© Disputed Information: tdertify the aecaunl mlormestion hsputed amt
`statement,
`.
`explain why you befieve it is inaccurate
`You must notify us uf aby polvotial enacs siwrilieg. You maycall us, bul if
`* Supporting Documentation: st available, provide a copy of the section ot
`you do we are nol requiredto investigate any potential errors and you may
`the credit report showing the account infgemation you ame disputing
`haye to pay the ammount in question,
`We will isrzestigate the disputed intormation‘and report the results to you
`While we investigala wtelter ur not there tras Leenan ere, Ue followings
`within 30 days of receipt ot the information needed tor ourinvestigation.It
`are lrue;
`we find that the account information wa reperted is inaccurate, ws wilt
`© We canal ry do catlee! the amount it question, ur reporl you as
`promptly provide the necessary correction to each consumerreporting
`delinquenton thal amount.
`agency to which wereported the information.
`© The charpe in question may remain on your statement, and we may.
`PAYMENTS MARKED °PAID EN FULL”. All sritten communications regarding
`continue to charge you interest an that amount. But, it wa deternine that
`disputed amounts that include any check of olher payment instrument
`we made a mistake, you will not have to pay lhe amount in question or
`masked with “paymentin full”or similar tanguane, must be sent to: 6690
`any interestor otherfees related to that amount.
`North Loop 1604 East, Suite 161, San Antorito, TX 78247-9004,
`DO NOT USE THE ENCLOSED REMITTANCE ENVELOPE.
`© While you da not havete pay the amount in question, you areresponsible
`
`for
`Ite remainder of your balance.
`- We may accept paymentsent to any other addiess without losing, any of
`
`out tiphts.
`-
`*¥
`1 apply ety anpaid arneunl agained your credil Jimil,
`~ No paymentshall operate as‘an accord and satisfaction wathout prior
`Your Rights tf You Are Dissatisfied WithYour Credit Card Purchases
`written approval,
`{f you are dissatistied with the goods or services thal you have purchased
`CUSTOMER SERVICE. Visit comenity.net/ullbeauty of call 1-488-252-0484
`with your credit card, and you have tried in good faith to connect the
`(TOD/TTY 1-800-695-1788).
`.
`.
`peobiem vith the merchant, you may have the right notto pay the remaining
`amount dun nn the pauchase.
`TELEPHONE MONITORING.Toprovide you with high-qualily service, phone
`communication with us is monitared and/or reconded,
`To use this right, all of the faltowing must ba true:
`ADDITIONAL INFGAMATION.Tha: followin; designations, when appearing
`1. The purchase must have been made in your home state or within 100
`‘on the Front of your stateinent, meanLhe tollowing: ¥V means variable rate
`tiles of your current mailing address, and the purchase price must have
`ithis rate may vary); WV INI PAY RQ ineans WAIVE INJERESI, PAYMENT
`been more than $44). (Nofe: Neitherof these is necessary it your purchase
`REQUIRED; WV EN EG PY neans WAIVE INTEREST, EQUAL PAYMENT; WV
`was based on an advertisement ye mailed to you,cr if we avn the company
`(NY LOWPAIL means WAIVE INTERKES!, LOV@ PAYMENT; DE INE EY 2Q
`that sold you the gouds or services.)
`means DEFER (NILES, PAYMENT 2 QUIRED; D&t INT EQ PY means
`DEFUR INTEREST, LQUAL PAYMEN; OF IN] LOW UM) means DEFER
`2. You must have used yourcradil card for the purchase. Purchases made
`INTEREST, LOWPAYMENT and LUW APE EG PAY means LOYAlt, EQUAL
`with cash advances from an ATM on with a check thal accesses your credit
`PAYMLNI.It you have a variable rale account, your periodic rates may vary.
`card account do notqualify.
`You maypay all ol your Account balance al any lime withoul penalty.
`3. You must notyet have fully paid tor the purchase.
`Send all inquiries to: CUSTOMER SERVICE, PO Box 182273, Columbus,
`{1 all of the criteria above are met and you are still dissatistied with the
`Ohio 43218-2273.
`purchase, cotalus in wrifing al: Comanily Bank PO Bax 187782,
`Columbus, Ohio 43218-2/82,
`Send all bankruptey notices and related correspondence to Comenity Bank,
`Banksuptey Department, PO Sox 182125, Columbus, Ohio 43218-2125.
`Vhhile we investigate,lle same rules apply tu the dispuled antuunt as
`NOTICE ABOUT ELECTRONIC CHECK CONVERSION,When youprovide a
`discussed above. Alter we tinish aur investigation, we will teil you our
`decision. At that point, it we think you owe an amount and you du not pay
`
`
`la urakeao
`
`CK aS pay
`Nui
`pittver lu use: iteforrtalions (ease yout
`we mayreporl you as delinquent.
`
`
`HOW TO AVOID PAYING INTEREST. Your duc dateis at least 26 days attr
`fureeds steay beewithidraven
`
`
`S
`the close of eact:
`Yi
`Valling cycle. We will not chan you interest yer gute!
`
` frat your ancountl as sue In: day var rective
`
`your
`paymnsl, ated
`
`
`y thayvandeer: Yur Yay” 3
`
`
`
`you pay your entire balance by the due date each mnt, We will begin lo
`you wifi pol mceive your check back fom your fiteneial institution,
`charge iilerest on new puictiases madeunder 3 Lew AUR, Equal Payitiert
`or Budgel Payinenst Credil Plan rin Lhe dale of purctiase.
`.
`
`BALANCE COMPUTATION METHOD. ‘We catculateinterts!
`separately for
`each lype ol balamee on your account using 4 “Caity Balance” lo delenming
`interes! cdaigeslar eacts bijling period. We lgure tte inletes| charge on-
`your account by applying (he periodic rale to the “daily Uslance"ol your
`account fa sacl: day in the tilling cycle. tyget the “daily Lalance” wa
`lake Ube beginning balaciee ul your ascuunt! each day, odd any new
`purchases and lees, and subtract aty payments o crevils (beating any nel
`otadil balance as 4% zero balance), Ohis gives us Ihe daily balance,
`
`PAYMENTS.Pay your Account by Ihe payment due date by Ube time tisled belvw,[1 we du nul receive yout payment ita comect lounat (oulfiaed betow) IL
`tay hot be credited fo yaur Account foe up to Frve days, or may 5¢ rejected, Also, your payment mus! reach us by the payment cutoff time that applies to
`Correct Format. Ceseseh forrtiat for different payment cnelboets includ: es,
`Nae greayreend inetbod you selact,
`Malling or Overnight: Send a personalcheck, moneyonder.traveler's check or cashter's check payable in U.S,dollars, to the name and adkiiess shown of
`This Skafemnent in We: payinstub ates eunkaning your balance and ininimum paymen! aneunt, fhe sure foinclude your payrend stub, do nol slapic or
`clip your paymentto thestub, include your account number on your check, use the envelope provided with your Slaiemenl, send one payment with one
`payment stub and do pct send any coirespandence with your payment. You should ovemipht a payment to’6550 North Loop 1604 East, Suite 10), San
`dnlonio, TX 78247 5004 and the additionalformatrequirements ate the same as other mailed payments uninssthere is a dispute, in which rase you fallow
`the Paymenlx Marked *Paid In Pull" section above. Do onl send cashor gill certiticates. Pay By Phone: You cancallustatlfrre at 1 RRR 252 5484
`CIDE TTY 1-800-694-1 £88) to make 2 payment ly telephone, which mney include a lee, Online: You can make a paytuent ontine al comenity.net/tullbeauty.
`Payment Cutoff Times.Payment cutolf timesfdeadlines forus to receive payments are by the due daie cn this Stalementin the payment stub area at the
`foltinvirg limes: Mailing and Overnight: By 6:00 pan Paxslemn Titne (1); Pay By Phone: Ry 8:00 pin(TT); Ontine: By 8:00 pm (1).
`
`New Information
`
`Title optional}First Name
`eeel Cd
`
`Last Name ee Soc. Sec. No.
`
`
`re
`Street Address
`
`Apt. No, |
`wee RROPO Bo
`
`
`ee
`... Forelgn-Map Code _.
`City
`State
`‘Zip Code
`
`Home Phone
`: , Work Phone
`-
`
`Email Address
`
`

`

`"PAGES OF4
`
`Additional important messages - continued
`Account Centeris available 24/7 for you to manage your futibeauty account online. You can
`make payments and viewyour balance, transactions and statements online. Notyet registered? Visit
`comenity.nevfullbeauty, enter your fullbeauty credit card account numberand ZIP code,then verify your
`identity.
`We're looking out for you. We remain focused on the health and well-being of our customers and
`associates, and we'll continue to stay on top of what's happening during the pandemic so we canbest
`support you.
`
`IMMEDIATE ATTENTION REQUIRED! Your Accountis extremely past due and will be written off as a
`bad debt at the endofthis month. To avold this, you can pay the Minimum amount shown on this
`statement before the end of this month.If you are not able to pay the Minimum Payment amount, wewill
`still be able to assist you and prevent your accountfrom being written off. Call us at 1-855-617-8089
`(TOD/TTY 1-800-695-1788) and wewill find a suitable paymentbefore the endof this month.If written off,
`the bad debt will be reported to the three major credit bureaus and our Recovery team will determine the
`appropriate steps, as permitted and available under applicable law, to protect ourinterests.
`
`06400309
`
`go0d0114e
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`O000000408173434
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`000100850 000e94%b74
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`