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`Redacted by Clerk of Court
`
`AEE
`
`IN THE MONTGOMERY COUNTY MUNICIPAL COURT, EASTERN
`MONTGOMERY COUNTY, OHIO
`)
`CASE NUMBER: &4{ CvF24 35-
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`LVNV FUNDING LLC
`C/O 55 BEATTIE PLACESUITE 110
`GREENVILLE,SC 29601
`
`Plaintiff
`
`JUDGE:
`
`COMPLAINT
`
`JEREMIAH HEDLUND
`4133 FOREST RIDGE BLVD
`RIVERSIDE, OH 45424-4836
`Defendant
`
`)
`)
`)
`)
`)
`
`FIRST COUNT
`NONPAYMENT OF ACCOUNT
`
`Plaintiff is the assignee of Defendant’s Account, Account numberiSX0333, an
`1.
`Account which was used 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 Hedlund
`2.
`is 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,
`
`The account documentation is attached hereto as Exhibit A.
`
`Uponinformation and belief, Defendant made the last payment on the account on or about November 23
`5.
`2019 and the Account was charged-off by the Original Creditor on or about June 30, 2020.
`
`6:
`
`Defendant has defaulted on the repaymentobligation and hasfailed to repay the balance of $2,706.96
`
`7.
`Defendant.
`
`Asa result of the assignment, Plaintiff became, and nowis entitled to recover the amount owed by the
`
`Thereis presently due the Plaintiff from the Defendant for the money loaned/moneypaid out on
`8.
`Defendant’s Account, the sum of $2,706.96.
`
`SECONDCOUNT
`UNJUST ENRICHMENT
`
`9.
`
`10.
`
`Plaintiff incorporates by reference herein, each allegation set forth above.
`
`Defendantreceivedbilling statement(s), but has failed to repay the unpaid balance.
`
`Defendant knowingly retained the benefits derived from the use of the Account, without having repaid the
`Il.
`balance outstanding on the Account.
`
`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 A’
`
`INFORMATION OBTAINED WILL BE USED FOR THATPURPOSE.24-114917 HOANLLll
`
`

`

`Defendanthas been unjustly enriched in the amountofthe outstanding balance set forth above, as
`13,
`Defendant knewor should have knownthat the credit was not being provided gratuitously.
`
`WHEREFORE,Plaintiff prays for judgmentagainst Defendant in the amount of $2,706.96 with statutory interest
`from the date ofjudgment, costs ofthis action, and such other and furtherrelief as the Court deemsjust and proper under
`the circumstances.
`
`Respectfully Submitted,
`
`Dated:
`
`File No. 24-114917
`
`STENGER & STENGE
`
`Attorneys for Plaintiff.
`
`By:
`
`
`
`Davjd'B. Bokor (OSCR#:
`Stenger & Stenger, PC.
`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 Defendantas listed 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. 24-114917
`
`
`
`DayAd 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 ATTEM
`
`INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 24-114917 HRSRCAAE
`
`OLLECT
`
`A DEBT AND ANY
`
`

`

`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.24-114917
`
`

`

`PAGE 1 OF 4
`
`Summary
`Accountno.
`
`of account activity
`“MSS
`
`Payment information
`New balance
`Minimum payment due
`Payment due date
`$2,608.61
`Previous balance
`0.00
`Paymenis
`Late payment warning:
`0.00
`Other credits
`lf we do not receive your minimum payment by 07/07/2020 you may
`0.00
`Purchases
`havetotopayup|toa$40.00lalefee. .
`oeeeessttsecettee tute te
`0.00
`Otherdebits
`Minimum payment warning: If youmakeonlyTheminimum
`40.00
`Fees charged
`Interestcharged= 88S payment for each period, you will pay more in interest and it will take
`Newbalance
`$2,708.96
`you longerto pay off your balances. For sxample:
`Past due amount
`773.50
`iifyou makenoadditional!°TYou witlpepayyooy"And}youuwill :
`
`Credit simit } charges using this card=the balance shown; end up paying ani$2,050.00
`
`Available credit
`$0.00
`and each month you pay;
`on the statement: estimated total
`Statementclosing date
`06/11/2020
`poem aeen eeeINOUEao
`Daysin billing cycle
`30
`|Only the minimum payment ! 7 years
`$4772
`For information regarding creditditcounselingservices, oo
`call 1-800-284-1706.
`
`$2,706.98
`$903.50
`07/07/2020
`
`\
`
`.
`Skip signing in to pay and use Comenity’s EasyPay.It's safe and convenient. Use your smartphone camera or code
`| reader fo scan the QR code printed on your payment stub below to gel started.
`
`Leoeie
`
`te
`
`Details of your transactions
`TRANS DATE
`TRANSACTION DESGRIPTION/LOCATION
`Fees
`06/07/2020
`
`LATE FEE
`Total fees chargedfor this pertod
`
`Interest charged
`Interest charge on purchases
`Total interestfor this period
`
`t
`2020totals year to date
`{
`$238.00 }
`} Total fees chargedin 2020
`$333.13 i
`3 Total interes charged in 2020
`bantt te eet
`
`.
`
`AMOUNT
`
`40.00
`$40.00
`
`$58.35
`$58.35
`
`Interest charge calculation
`Your Annual Percentage Rate (APR) is the annual interest rale on your account. See BALANCE COMPUTATION METHOD
`on page 2 for more details. Minimum interest charge may exceedinteres! charge below, per your credit card agreement.
`TYPE OF
`BALANCE SUBJECT
`INTEREST
`BALANCE
`APR
`TO INTEREST RATE
`CHARGE
`Purchasesprior to 04/12/2015
`24.9900% (v)
`172.51
`3.54
`Purchases
`26.9900% (v}
`2,470.81
`54.81
`
`Additional important messages
`Aflected by COVID-19? Comenity Bank Offers Support
`Asthe bankthat managesyour credit card, our hearts go out to those affected by the coronavirus
`(COVID-79) pandemic.
`The support we're extending to you.If you're experiencingfinancial hardship because of COVID-19,
`Please call 1-800-695-0466 (TDD/TTY:1-800-695-1788) to discuss how we may be able to help.
`(CONTINUED)
`lAccomt
`jnumbertenet881
`: Newbalance.
`TYMinimumpayment #
`($2,708.68| , $903.50,
`994
`
`KINGSIZE
`a FULLBEAUTYtxand™
`
`8
`
`
`
`-
`qo
`bo aaa Bateseereverse my
`
`Payment must reach us by
`
`6 pm ET on 07/07/2020.
`Amount enclosed:
`oo er
`fo
`Plaasa make check payable to:
`COMENITY - KING SIZE
`
`peggEPLEU Yeboda(AINA NafUUd a flogUg DPA]ES]eof fog
`JEREMIAH HEDLUND
`859 REVERE VILLAGE CT
`DAYTON OH 45458-3445
`
`Please return this portion along with your paymentta:
`PO BOX 659728
`SAN ANTONIO TX 78265-9728
`
`EagtUpyaderepafengyalglove beggfogeapfaPEt oQUlfeafegggfT
`
`

`

`Keep this‘portion for yous records.
`What To Do ff You Think You Find& Mistake On Your Statement
`LU you Ehitc Qrese és an error on your stalemeni, vale lous al: Conrenity
`Yank UD Box 162/82, Colurebus, Ohiv 43218-2782.
`tte your fetles, give us Ihe folfowing information:
`© Accourtinformation: Your name and account number.
`© Dotiaramount: The dollar amount of the suspected error.
`© Desapdion ef Probfcrn: | you think (hereis an error enyout bill,
`describe what you betieve is wiong and why you believe it is a mistake.
`You must contact ns within 60 days alter the error arpeared on your
`statement, Yuu mus) nality as of any polontial euoes inniting. You way
`call us, but it you do we are aot required to investigate any potential esrors
`and you may have to pay the amountin question, While we investigate
`whether of not there hat been an error, the tollowing are tree:
`* Yie cannot Uy to collect the amount in question, or report you as
`delinquent an that amount.
`© The chame in question may remain on your statement, and we may
`cantinue to charge you interest on that amount. But. if we determine that
`we made a mistake, you will not have te pay the amountin question or
`any interest 09 other foes selated to that amount,
`© White you do nol havele pay {tre ammount in question, you ate cesponsible
`for Me cersider of your toslance.
`© Ve can epply arg empaid amount agaied your credit Jimil.
`Your Rights {! You Are Dissatisfied With Your Credit Cand Purchases
`Uh you are dissalisfied will the gools on senoces the! you tue purchased
`
`withyoun credtit card,
`atuyou fave Iriedits good faith to correct the
`probleare wilh tee 1
`HH), you inay have Ihe rigkd nel fo pay the semnalre
`amraundue on ther purctrasa.
`To ust Unis righ, aff of the (olloring must be fruc:
`1. The purchase mus! have been made in your bome state or within 100
`tuiles af your cuzrent mailing address, and the purchase price raust have
`been more than $50. {Note: Neither of these is necessary if your purchase
`was hased an an advertisemont we mailed to yeu, or ii x own the company
`Slat sold you the poods ar services.)
`2. You must have used your crodit card for the puchase. Purchases made
`‘with cash advancesfrom an ATMof with a chock that accesses your credit
`card account do not qualify.
`3. You must notyet have fully paid tor the purchase.
`It all of the criteria above are met and you are still dissatisfied with the
`purchase, cantact us in writing at: Comenity Bank IX) Bex 182/82,
`Columbus, Ohio 43218-2782.
`Vhile we mvestigate, the same rules apply to the disputed amounlas
`discussed above. Alter we finish our investipation, we will tell yuu our
`decision. At that point, if we think you owe an amount and you do not pay
`we may teport you as delinquenl.
`HOW TO AVOID PAYING INTEREST. Yourdus Hale is al Jess! 2% clays aller
`the close ot each billing cycle. We will aul charge you interest on purchases
`i) you pay your entire balance by the due date each month. We will begin to
`chame interest on new purchases made under a Lor AlN, Equat Payment
`on Budget Vezyinent Credit I’lan trom the date of purchase.
`
`BALANCE COMPUTATION METHOD,Wer catcutate interes! s:paralcly for
`each type ut balance on your accountusing a "Usily Balance” to delerinine
`interasi charges tor eachbilling period. We tigure the interest change on.
`your account by applying the periodic rate to the “daily balance” of your
`accounttor each day 11 the billing cycle. Jo get the “daily balance” we
`take the beginning balarice ot your account each day, add any new
`purchases and tres, and subtract any payments or credils (treating any ret
`ciedit balance as a zerc balance). this gives us the daily balance,
`
`CREDIT REPORTING.We oray icgunt inlorrstion abel yout weceunl la
`tradit bureaus. Late paymenls, missed payments, a gthes deteulls on your
`account mey be setlected in your credit rebort,
`NOTICE OF CREDIT REPORT DISPUTES
`Uyou believe [he account! inlusinaliun we teporled le a cusumer ceporlire,
`agumrcyts insccurale, you tnay subail ¢ direcdispute to Cumenily Bark PO
`Bux 192/89, Columbus, Ship 43213-2/89. Your written dispute aust
`provide sutlicten! inluination to identily Ur account and specily why he
`inlarinationis aceurale:
`*® Account Information: Your name and acresnl number
`* Contact Information: Your atldtess anil bslephons mumime
`® Disputed Information: Icetitify Ihe encoun! tnlornutiondisputed ated
`explain why you believe it is tnaccurate
`© Supporting Documentation:It available, pravice a copy of the section at
`the credit report showing the account inturmalion you are disputing
`Wewill investigate the disputed information and te:port the results to you
`s¥ithin 30 days af receipt of the information needed tor aurinvestigation.It
`yee find that Ihe accountinformation we reposted is iraccurate, ws wilt
`promptly provide the necessary correction to each consumer teporting.
`agency to which we reported the information,
`PAYMENTS MARKED "PAID IN FULL". All eaillen communications regarding
`disputed amounts that include ary check or other payment instrument
`macked with “payment in sull* or similar language. must be sent 10: 6590
`North Loon 1604 Last, Suite 101, San Antorio, TX 78247-5001,
`DO NOT USE THE ENCLOSED REMITTANCE ENVELOPE.
`- We may accept payment sent lo any other address withoutlosing: any ot
`our rights.
`- No paymentshall operate as an accord and satisfaction without prior
`written approval.
`CUSTOMER SERVICE. Visit comenity.net/kingsize ur call 1-800-695-0266
`CDDITTY 1-800-495-1788),
`TELEPHONE MONITORING,Ta pride you with high-qestily servic, polioriet
`communication with us is monitored andor recorded.
`ADDITIONAL INFORMATION, Thefollowing designalions, when appearing
`on the front of your statement, mean the following: ¥ means variable rate
`his rate may vary); WV INT PAY RQ means WAIVE INTEREST, PAYMENT
`REQUIAED; WY INT EQ PY means WAIVE INTEREST, EQUAL PAYMENT; WV
`INT LOW PRT means WAIVE INTEREST, LOW PAYMENT;DF INT PY RQ
`means DEFER INTEREST, PAYMENT REQUIRED; DEF INT EQ PY means
`DEFER INTEREST, EQUAL PAYMENT; OF INT LOW PMT means DEFEA
`INTEREST, LOW PAYMENTand LOW APR EG PAY means LOW APR, EQUAL
`PAYMENT. ff you have a variable rate accounl. your periodic rates may vary.
`You may pay all of your Account balance at any ime without penaily.
`Send all inquiries to: CUSTOMER SERVICE, PO Sox 182273, Columbus,
`Obie 43218-2273.
`Send all bankruptcy notices and related conespandence to Comenity Bank,
`Banksupicy Department, PO Box 182125, Columbus, Chio 43218-2125.
`
`NOTICE ABOUT ELECTRONIC CHECK CONVERSION.When you provide a
`cheek as payment, you authorize us either to use information [ram your
`chock lo make a une time alectsonic: Gund Wansfer fram your acceunl ar to
`process the payment as a check transaction. When we use Infarmatian from
`your check to make an electronic fund tanster, funds may he withdrawn
`from your accoun! as Sonn as the same day we Mmceive your payment, and
`you will not receive your check back (son yous finzncial tnshitulion.
`
`1 {oulbined below) it
`ime that applics to
`
`PAYMENTS. ay yuur Acvoutil by Lhe payrnenit due dale by the time listed Gelow.IIew du nol receive your paytnenil ina correct for
`
`may not be credited ta your Accountfor up to five days, oF may be rejected.Also, your payment mus! reach us by the payment cuto
`Ite: prrymeo! inetfead you select,
`Correct Format, Carica) formal far stifferen! payment ioetbods includ;
`Afaiting or Overnight: Sens) a persurral check, money oder, lraveler's check of cashier's check payable in U.S, dollars,to the tranard eddress shownon
`this Statementin th payment stub area containing your balance and minimum payment amount. Be sure to include your paymentstub, da not staple or
`clipyour penaren fothe stub, (oclude your xccounl pumber an your check, use Ibe envelope paovided wilh your Stalament, serus aret pesyment valle ore
`payrrentstub and do nat send any corespandence with your payment. You should overnipht 2 payment to 6LU0 North Loop 1604 East, Suite 101, San
`
`antonio, TX 78247-5004 and the additional format mequirer#ats ate the same as other mailed payments unless there ts a dispute, in which case you follow
`the
`Payments Marked *Paid tn Full" section above. Do not ¢end cash or gitt certificates. Pay ByPhone: You can call us toll free at 1-800-695-0466
`CINEATY 1 80 6951782) to cake 3 payment by Irlephune, which muy itecluds a for. Orfize: You ratmake a preyttontdl ontinn al comenity.neUkingsize.
`Payment Cutoff Times. Payment cutull times/deadlines fur us lo receive payments are by Ure die date unthis Slalztment in the paginent stub atea of lhe
`tolluwing linws: Bailing and Qvemight: By 6400 pin Lxslern lime <b}; Pay By Phone: Uy 8:00 pm {L125 Online: By 8-00 pm (bt).
`New Information
`
`MI
`Title (optional)__.. First Name.
`
`Soc. See. No.
`Last Name
`
`Street Address
`
`
`RR
`PO Box
`Apt. No.
`Foreign Map Code __
`State
`Zip Code
`Cily
`
`Home Phone
`, Work Phone ___
`
`Email Address
`
`

`

`:
`
`"pagesOFS
`
`Additional important messages - continued
`Account Centeris available 24/7 for you to manage your KING SIZE accountonline. You can
`make payments and view your balance, transactions and statements online. Not yet registered? Visit
`comenity.nevkingsize, enter your KING SIZEcredit 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 can best
`support you..
`
`IMMEDIATE ATTENTION REQUIRED! Your Accountis extremely past due andwill be written off as a
`bad debtat the end of this month.To avoid this, you can pay the Minimum amount shown onthis
`statement before the endof 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
`(TDD/TTY 1-800-695-1788) and we will find a suitable payment before the end of this month.If written off,
`the bad debtwill be reported to the three major credit bureaus and our Recovery team will determine the
`appropriate steps, as permitted and avallable under applicable law, to protact ourinterests.
`
`03400109
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`d000179%6b
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`OOO0000040S03S8L1
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`o00090350 oo0e70b4b
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`PAGE 4OF4
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