Electronically Filed
`1/28/2021 3:41 PM
`Ward, Mary S.
`Justice of the Peace, Pct 1 Place 2
`Fort Bend County, Texas
`
`21-JDC12-04773
`
`Professional Civil Process Of Texas, Inc103 Vista View TrailSpicewood TX 78669(512) 477-3500Jan 28, 2021 ORIGINAL PETITION FILING REQUESTJUDGE MARY S WARDJustice Court 1/2 of FORT BEND County1517 EUGENE HEIMANN CIRCLE#100RICHMOND TX 77469Re: MIDLAND CREDIT MANAGEMENT INC.vs.WADHHA BASHRAHILDear Court Clerk,Please find enclosed Plaintiff's Original Petition with Attachment(s) for filingwith the Court and a copy for each defendant to be to be filed stamped andreturned. We have also enclosed a check for filing fee cost and the issuuance ofthe citation(s). Pursuant to TRCP 502.4(b) if the address does not belong to youprecinct, please do not forward to another court for filing, but return thedocuments unfiled back to our office.Please issue a citation on the following person or entity:BASHRAHIL, WADHHA3410 RIVER RANCH NORTH DR ROSENBERG TX 77471-4476Pursuant to TRCP 501.1 (a) and 501.3 (a) please retain the original citation inthe courts file. We respectfully request that the court only return the servicecopy of the citation to our office along with the file stamped copy of thePetition with Attachment(s). Also, please file stamp and attach this Clerk Letterand filing fee receipt to the citation and: PLEASE EMAIL THE CITATION BACK TO EFILING@PCPUSA.NETWe will be using a JBCC Certified Process Server, or a person already authorizedto serve the citation. Please feel free to contact our office if you have anyquestions or concerns about this request.Sincerely,PCP Team1-866-PROCESSPCP#: A21105035CLT#: 20-272640
`
`

`

`21-JDC12-04773
`
`Electronically Filed
`1/28/2021 3:41 PM
`Ward, Mary S.
`Justice of the Peace, Pct 1 Place 2
`Fort Bend County, Texas
`
`CAUSE NO.
`
`MIDLAND CREDIT MANAGEMENT, INC.
`Plaintiff,
`
`IN THE JUSTICE COURT
`
`vs.
`
`WADHHA BASHRAHIL
`Defendant
`
`PRECINCT 1, PLACE 2
`
`FORT BEND COUNTY, TEXAS
`
`PLAINTIFF S ORIGINAL PETITION
`
`TO T HE HONORABLE COURT:
`
`MIDLAND CREDIT MANAGEMENT, INC., the Plaintiff, complains of WADHHA BASHRAHIL, the
`Defendant, and for cause of action shows:
`
`Discovery Level
`
`Plaintiff reserves the right to petition this Court to engage in pretrial discovery pursuant to Rule
`1.
`500.9 of the Texas Rules of Civil Procedure.
`
`Parties and Service of Citation
`
`The Plaintiff is a foreign limited liability company duly authorized to conduct business in the State
`2.
`of Texas.
`
`The Defendant resides within the venue of the above referenced court and may be served at the
`3.
`following address, or wherever the Defendant may be found:
`WADHHA BASHRAHIL
`3410 RIVER RANCH NORTH DR
`ROSENBERG, TX 774714476
`
`Venue and Jurisdiction; Relief Sought
`
`Venue is proper in this county because Defendant, a natural person, resides in this county. The
`4.
`amount in controversy is within the jurisdictional limit of this court. The Plaintiff seeks only monetary relief
`of $10,000.00 or less, including damages of any kind, penalties, cost, expenses if any. Plaintiff does not seek
`pre-judgment interest or attorney's fees.
`
`Plaintiffs Efforts To Resolve
`The Underlying Obligation
`
`Plaintiff, MIDLAND CREDIT MANAGEMENT, INC., owns portfolios of consumer receivables,
`5.
`which it attempts to collect. When working with individual consumers, Plaintiff, MIDLAND CREDIT
`MANAGEMENT, INC., and its affiliates (collectively, "Plaintiff) generally attempt to contact consumers
`like Defendant through several means, all in an effort to establish contact and to resolve the underlying
`obligation. In doing so, Plaintiff attempts to assess each consumer's willingness to pay, through phone calls,
`
`TX 0120G File No.: 20-272640
`
`

`

`letters or other means. Plaintiff attempts to exclude consumers from its collection efforts, where Plaintiff
`believes those consumers are facing extenuating circumstances or hardships that would prevent them from
`making any payments.
`
`When Plaintiff contacts consumers, it strives to treat consumers with respect, compassion and
`6.
`integrity. Plaintiff works with consumers in an effort to find mutually-beneficial solutions, often offering
`discounts, hardship plans, and payment options. Plaintiffs efforts are aimed at working with consumers to
`repay their obligations and to attain financial recovery. Plaintiff strives to engage in dialogue that is
`honorable and constructive, and to play a positive role in consumers' lives.
`
`Despite Plaintiffs efforts to reach consumers and resolve the consumer's obligations, only a
`7.
`percentage of consumers choose to engage with Plaintiff. Those who do are often offered discounts or
`payment plans that are intended to suit their needs. Plaintiff would prefer to work with consumers to
`establish voluntary payment arrangements resulting in the resolution of any underlying obligations.
`However, the majority of Plaintiffs consumers ignore calls or letters, and some simply refuse to repay their
`obligations despite an apparent ability to do so. When this happens, Plaintiff must decide then whether to
`pursue collection through legal channels, including litigation like the present action against Defendant.
`Although the account is now in litigation, Plaintiff remains willing to explore a mutually-beneficial solution
`through voluntary payment arrangements, if possible.
`Count I
`
`Defendant opened the account with COMENITY CAPITAL BANK on or about March 07, 2019.
`8.
`Plaintiff purchased Defendant's debt on or about March 19, 2020. Plaintiff has been assigned the debt, and
`Plaintiff is now owed money from Defendant. MIDLAND CREDIT MANAGEMENT, INC. is the current
`owner of the debt, and any prior holders of the debt are listed in the attached Affidavit Relating to Damages
`and Business Records and are incorporated by reference.
`
`Relevant information related to the account is as follows:
`
`ORIGINAL CREDITOR:
`ORIGINAL ACCOUNT NO.:
`DATE OF CHARGE-OFF:
`CHARGE-OFF BALANCE:
`
`COMENITY CAPITAL BANK
`XXXXXXXXXXXXX-4931
`February 29, 2020
`$1,727.97
`
`Account Stated
`
`TXJM20G File No.: 20-272640
`
`

`

`Plaintiff is the owner and beneficiary of all claims related to the account opened by Defendant with
`9.
`Plaintiff's predecessor-in-interest. Thus, Plaintiff is entitled to relief under the common law cause of action
`account stated because (i) transactions between the parties or their predecessors-in-interest gave rise to
`indebtedness of the Defendant to the Plaintiff (ii) there existed an agreement, express or implied, between the
`parties establishing a fixed amount due, and (iii) the Defendant made a promise, express or implied, to pay
`the indebtedness, but has failed to do so.
`
`Demand for payment has been made by Plaintiff, and as of November 27, 2020, Defendant has
`10.
`refused and failed to remit the remaining principal amount of $1,727.97. No interest (0%) is accruing on the
`account.
`
`Damages
`
`Plaintiff seeks liquidated damages in the amount of $1,727.97 along with post judgment interest at
`11.
`the statutory rate provided by applicable law.
`Conditions Precedent
`
`12.
`
`All conditions precedent have been performed, have occurred, or should be excused.
`Prayer
`
`For these reasons, Plaintiff asks that Defendant be cited to appear and answer, and that Plaintiff have
`judgment against Defendant for the following:
`a. Actual damages in the amount of $1,727.97;
`b. All costs of suit; and
`c. All other relief, in law and equity, to which Plaintiff may be entitled.
`
`Respectfully submitted
`DIT MANAGEMENT, INC.
`
`Texas Bar No. 24042929
`Katharine Allen, Texas Bar No. 24055139
`Brian Staley, Texas Bar No. 00797483
`Michael Young, Texas Bar No. 24037759
`Peter Newman, Texas Bar No. 24106928
`Manasi Tahiliani, Texas Bar No. 24099986
`Juan Goenaga, Texas Bar No. 00797868
`Chase Hague, Texas Bar No. 24071573
`David Caviness, Texas Bar No. 04033300
`John Gillespie, Texas Bar No. 07926300
`Attorneys for MIDLAND CREDIT
`MANAGEMENT, INC.
`P.O. Box 460568
`Houston, TX 77056
`Tel: (866) 300-8750
`Fax: 877-232-9721
`Email: InternalLegal-TexasFax@MCMCG.COM
`
`TX_0120G File No.: 20-272640
`
`

`

`21-JDC12-04773
`
`CAUSE NO.
`MIDLAND CREDIT MANAGEMENT, INC.
`§
`IN THE JUSTICE COURT
`Plaintiff,
`§
`§
`§ PRECINCT 1, PLACE 2
`§
`§
`§ FORT BEND COUNTY, TEXAS
`
`WADHHA BASHRAHIL
`Defendant.
`
`vs.
`
`E X H I B IT "B"
`
`A F F I D A V IT OF N O N - M I L I T A RY S T A T US
`
`B E F O RE ME, the undersigned authority, on this day personally appeared the
`undersigned, who after being duly sworn, deposed upon oath as follows:
`
`"I am a legal specialist for MIDLAND C R E D IT MANAGEMENT, INC., the servicer for
`MIDLAND C R E D IT MANAGEMENT, INC., Plaintiff in this case. I am a competent person
`over eighteen years of age, and make the statements herein based upon personal knowledge of
`those account records maintained on Plaintiffs behalf.I have access to and have reviewed the
`electronic records pertaining to the account and am authorized to make this affidavit on
`Plaintiffs behalf. The electronic records reviewed consist of data acquired from the seller when
`Plaintiff purchased the account, together with records generated in connection with servicing the
`account since the day the account was purchased by Plaintiff. In addition, I reviewed the
`documents that are attached to this affidavit."
`
`Pursuant to the attachment, Defendant is not in active duty status of the military.
`
`Signed and sworn to and subscribed before me, the undersigned authority, before me on
`
`DANIEL R STOUT
`,
`Notary Public - Notary Seal
`(
`Jackson County • State of Missouri
`,
`Commission Number 20649976
`'
`< My Commission Expires Oct 29, 2024
`
`Notary Public
`My Commission Expires:
`
`TX_0402G Account No. 20-272640
`
`

`

`Department of Defense Manpower Data Center
`
`Results as of: Jan-07-2021 08:46:42 AM
`
`SCRA 5.6
`
`Status Report
`Pursuant to Servicemcmbers Ci vil Relief Act
`
`SSN:
`Birth Date:
`Last Name:
`First Name:
`Middle Name:
`Status As Of:
`Certificate ID:
`
`XXX-XX-6525
`Jul-XX-1982
`BASHRAHIL
`WADHHA
`
`Jan-07-2021
`NKV2QYTSVJ38P2R
`
`Active Duty Start Date
`
`NA
`
`Active Duty End Date
`
`NA
`
`Status
`
`No
`
`Service Component
`
`NA
`
`This response reflects the individuals' active duty status based on the Active Duty Status Date
`
`On Active Duty On Active Duty Status Date
`
`Active Duty Start Date
`NA
`
`Active Duty End Date
`NA
`
`Status
`
`No
`
`Service Component
`
`NA
`
`This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
`
`Left Active Duty Within 367 Days of Active Duty Status Date
`
`The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
`
`Order Notification Start Date
`
`Order Notification End Date
`
`NA
`
`NA
`
`Status
`
`No
`
`Service Component
`
`NA
`
`This response reflects whether the individual or his/her unit has received earty notification to report for active duty
`
`Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
`the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
`Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
`
`Michael V. Sorrento, Director
`
`Department of Defense - Manpower Data Center
`
`400 Gigling Rd.
`
`Seaside, CA 93955
`
`

`

`The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
`Reporting System ( D E E R S) database which is the official source of data on eligibility for military medical care and other eligibility systems.
`
`The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 U SC App. ? 501 et seq, as amended) ( S C R A) (formerly known as
`the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
`individual is currently on active duty" responses, and has experienced only a small error rate.
`In the event the individual referenced above, or any family
`member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
`protections of the S C R A, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service. Service contact
`information can be found on the S C RA website's FAQ page (Q33) via this URL: https://scra.dmdc.osd.miI/faq.xhtml#Q33.
`If you have evidence the person
`was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the S C RA may be invoked
`against you. S ee 50 U SC App. ? 521(c).
`
`This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
`Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
`duty on the Active Duty Status Date.
`
`More information on "Active Duty Status"
`Active duty status as reported in this certificate is defined in accordance with 10 U SC ? 101 (d) (1). Prior to 2010 only some of the active duty periods less
`than 30 consecutive days in length were available.
`In the case of a member of the National Guard, this includes service under a call to active service
`authorized by the President or the Secretary of Defense under 32 U SC ? 502(f) for purposes of responding to a national emergency declared by the
`President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
`unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
`Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
`Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
`
`Coverage Under the SCRA is Broader in Some Cases
`Coverage under the S C RA is broader in some cases and includes some categories of persons on active duty for purposes of the S C RA who would not be
`reported as on Active Duty under this certificate. S C RA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
`Title 32 periods of Active Duty are not covered by S C R A, as defined in accordance with 10 U SC ? 101(d)(1).
`
`Many times orders are amended to extend the period of active duty, which would extend S C RA protections. Persons seeking to rely on this website
`certification should check to make sure the orders on which S C RA protections are based have not been amended to extend the inclusive dates of service.
`Furthermore, some protections of the S C RA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
`actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the S C RA
`extend beyond the last dates of active duty.
`
`Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the S C RA
`are protected
`
`WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
`erroneous information will cause an erroneous certificate to be provided.
`
`i
`
`

`

`MIDLAND CREDIT MANAGEMENT, INC.,
`
`STATE OF TEXAS
`
`Plaintiff
`
`-vs-
`
`WADHHA BASHRAHIL,
`
`Defendant(s).
`
`AFFIDAVIT OF DONNA JARVE RELATING
`TO DAMAGES AND BUSINESS RECORDS
`
`Donna Jarve, whose business address is 16 McLeland Road Suite 101, St. Cloud, MN
`56303, certifies and says:
`1.
`I am employed as a Legal Specialist and have access to pertinent account records for
`Midland Credit Management, Inc. ("Plaintiff"). I am a competent person over eighteen
`years of age, and make the statements herein based upon personal knowledge of those
`account records maintained by Plaintiff. Plaintiff is the current owner of, and/or successor
`to, the obligation sued upon, and was assigned all the rights, title and interest to Defendant's
`COMENITY CAPITAL BANK account XXXXXXXXXXXXXX4931 (MCM Number
`304205035) (hereinafter "the account").
`
`I have access to and have reviewed the electronic records pertaining to the account
`2.
`maintained by Plaintiff and am authorized to make this affidavit on Plaintiffs behalf. The
`electronic records reviewed consist of data acquired from the seller or assignor when Plaintiff
`purchased or was assigned the account, together with records generated by Plaintiff in
`connection with servicing the account since the date Plaintiff purchased or was assigned the
`account. In addition, I reviewed the documents that are attached to this affidavit.
`3.
`I am familiar with and trained on the manner and method by which Plaintiff creates and
`maintains its business records pertaining to the Account. The records are kept in the regular
`course of business. It was in the regular course of business for a person with knowledge of the
`act or event recorded to make the record or data compilation, or for a person with knowledge
`to transmit information thereof to be included in such record. In the regular course of business,
`
`AFFIDAVIT OF DONNA JARVE -1
`llllllllllllllll
`AFFCOT
`
`llllllllllllllllllllll
`20-272640
`
`304205035
`
`

`

`the record or compilation is made at or near the time of the act or event by Plaintiff as a regular
`practice.
`4.
`Plaintiffs records show that the account was charged-off on 2020-02-29 with a balance
`of $1,727.97. On or about 2020-03-19, Plaintiff purchased or was assigned the account with a
`balance owed by Defendant of $1,727.97. As of 2020-11-27, Plaintiffs records show that the
`balance of $1,727.97 remains due and owing and no interest has been assessed to the account.
`Therefore, Plaintiff seeks the amount of $1,727.97 from Defendant. All credits and offsets for
`payments have been applied to the balance.
`5.
`The complete chain of title including COMENITY CAPITAL BANK, the original
`creditor, and all post charge-off purchasers/assignees of the debt are as follows:
`1. COMENITY CAPITAL BANK
`2020-03-19
`2. Midland Credit Management, Inc.
`Attached hereto are records regarding the account and/or payments) received, being a
`6.
`reproduction from Plaintiffs records, based upon my review. The documents attached hereto,
`are true and correct copies of the originals, except to the extent that confidential and privileged
`information is omitted or redacted and personal identifying information is omitted or redacted
`as required by local rules, and applicable state and federal law.
`7.
`Plaintiff acquired and incorporated the attached account records into its permanent
`business records as a result of its purchase or assignment of the account. These records are
`kept in Plaintiffs regular course of business and, along with the electronic records provided at
`the time of purchase or assignment, are Plaintiffs primary source of business records for this
`account.
`
`The accuracy of such documents is relied upon by Plaintiff in collecting mis account.
`8.
`These records are trustworthy and relied upon because the original creditor was required
`to keep careful records of the account at issue in this case as required by law and/or suffer
`business loss.
`
`l l l l l l l l l l l l l l i l l l l ll
`304205035
`
`AFFIDAVIT OF DONNA JARVE - 2
`llllllllllllllll
`AFFCOT
`
`l l l l l l l l l l l l l l i l l l l ll
`20-272640
`
`

`

`I certify under penalty of perjury that the foregoing statements are true and correct.
`
`SEC222H!
`
`Date
`
`STATE OF MINNESOTA
`
`COUNTY OF STEARNS
`Signed and sworn to (or affirmed) before me on DEC 2 2 a gp by Donna Jarve.
`
`y > W < W W » y M M M ^ N M M M M » A *^
`
`Ian Alexander Isaacson
`fttaiy Public-Minnesote
`) ty&iMiNioiE^M3f,2IM i
`
`u ,* * " * v ^ W Y r u v > i m n ^ i L n j u iA
`
`^ * * * * * *Ma
`
`Notary
`
`CA137
`
`llllllllllllllllllllll
`304205035
`
`AFFIDAVIT OF DONNA JARVE - 3
`IIIMIIIIIIIll
`AFFCOT
`
`1111111111111111111
`20-272640
`
`

`

`P O R T F O L IO L E V EL A F F I D A V I T OF S A LE BY O R I G I N AL C R E D I T OR
`
`STATE OF: UTAH
`COUNTY OF: SALT LAKE
`
`•On-T
`
`> Bruce Bowman ("Affiant**) being duly swom, deposes and says:
`
`1.
`
`2.
`
`3. ,
`
`4.
`
`5.
`
`6.
`
`I am over 18 and not a party to this action. I am the Chief Credit Officer of Comenity Capital
`Bank ("Seller")- In that capacity and as part of my regular job duties, I have custody of certain
`business records of Seller, routinely review such business records, and am familiar with
`Seller's processes for the sale and assignment of accounts and business records, including
`those that are maintained in electronic form.
`
`Seller owns certain accounts, and maintains and records information in the records as they
`relate to such accounts. I am authorized to make the statements and representations set forth in
`this affidavit on behalf of Seller. The statements set forth herein are true and correct to the
`best of my knowledge, information, and belief, based on either personal knowledge or review
`of the business records of the Seller. If called upon as a witness, I can testify competently to
`the facts contained herein.
`
`My regular job duties include having knowledge of, and access to, business records relating to
`the Accounts (as defined below). These records are kept by Seller in the regular course of
`business, and it was in the regular course of business of Seller, for an employee or
`representative with personal knowledge of the act, event, condition, or opinion recorded to
`m ike memorandum or records or to transmit information thereof to be included in such
`memorandum or records; and that the records were made at or near the time of the act and/or
`event recorded or reasonably soon thereafter.
`
`On or about 3/19/2020, Seller sold a pool of charged-off accounts (the "Accounts") by a Credit
`Card Account Purchase Agreement to Midland Credit Management, Inc. ("Buyer"). The
`original creditor at the time of charge-off was Comenity Capital Bank.
`
`Pursuant to the sale, Seller sold, transferred, assigned, conveyed, granted, bargained, set over
`and delivered to Buyer and its successors and assigns, good and marketable title to the
`Accounts and any unpaid balance free and clear of any encumbrance, equity, lien, pledge,
`charge, claim or security interest I am not aware of any errors in the Accounts.
`
`In connection with the sale of the Accounts, electronic and other records were transferred to or
`otherwise made available to the Buyer (the 'Transferred Records"). The Transferred Records
`have been kept in the regular course of Seller's business, and were made or compiled at or near
`the time of the event and recorded by (or from information transmitted by) a person
`(i) with knowledge of the data entered into and maintained in Seller's business records, or (ii)
`who caused the data to be entered into and maintained in Seller's business records. To the
`extent that the Transferred Records include records that were prepared by a third parry, they
`are records that were incorporated into the records of Seller as a business record and the
`accuracy of such records are relied upon by Seller in the regular course of business.
`
`

`

`7.
`
`I certify under penalty of perjury that the foregoing is true and correct.
`
`FURTHER AFFIANT SA YETH NOT.
`
`Signed this 7
`
`day of
`
`f
`
`. 2 0^
`
`Bruce Bowman (AFFIANT NAME)
`Comenhy Capital Bank
`
`day of ftf&iu, , 2W%p by
`^
`J | l j i b ^ b e U^ sworn * to before me this
`^?^/^&x><D>>^7tj * an employee of Comenity Capital Bank
`
`

`

`CERTIFICATE OF CONFORMITY
`
`STATE OF UTAH
`COUNTY OF SALT LAKE
`
`The undersigned does hereby certify that he is an attorney at law duly admitted to practice in the
`State of Utah and is a resident of Draper, County of Salt Lake, Utah; that he is a person duly
`qualified to make this certificate of conformity; that the foregoing acknowledgment by Bruce
`Bowman named in the foregoing instrument taken before Travis C. Miner a notary in the State of
`Utah duly conforms with the laws of the State of Utah, being the State in which it was taken; and
`when executed by Mr. Bowman in the manner indicated will qualify as a valid and effective
`sworn statement in such state.
`
`Date
`
`

`

`Y O UR
`
`BGBCDDD
`&
`
`Sijmrr;iry of account icliv tv
`*•**-•***-~"-4931
`Accounl no.
`
`Previous balance
`Payments
`Other credits
`Purchases
`Other debits
`Pees charged
`interest charged
`New balance
`Past due amount
`CredH ImN
`Available credft
`Statement closing date
`Days in Wong cycle
`
`$1,684.56
`0.00
`0.00
`0.00
`0.00
`3600
`6.41
`$1,727.97
`460.00
`$1,600.00
`$0.00
`02/22/2020
`29
`
`$1,727.97
`$620.00
`03/19/2020
`
`P.iyn ent mfo'rrvit on
`New balance
`MMrnurn payment due
`Payment due date
`Lets payment warning:
`H we do not receive your rrtrwrtum payment by 03/19/2020 you may
`have to pay up to a $38.00 late fee.
`Minimum payment warning: H you make only tie minimum
`payment for each period, you w» pay more in interest and it wil take
`you longer to pay off your balances. For example:
`M you make no additional
`You wHI pay off
`And you wM
`charges using Ms card
`end up paying an
`me balance shown
`estimated total
`and seen month you pay:
`on the statement
`c*
`In about:
`Only the minimum paymsrr! 7years
`$2977
`For information regarding crodM ccunseing services,
`call 1-600-264-1706.
`
`If you do nol pay your Flan 819-00001 balance of $1,440.00 by Sep 07. 2020 any remaining balance will be assessed
`interest at the standard purchase APR.
`
`TRANS M TI
`
`TRANSACTION DCSCMPT10*UlOCATION
`
`02/19/2020
`
`LATE FEE
`Total fees charged tor this period
`
`Interest charged
`Interest charge on purchases
`Total interest for this period
`
`2020 totals year to date
`Total tees charged In 2020
`Total Interest charged kt 2020
`
`$76.00
`$10.26
`
`36.00
`$M.OO
`
`$9.41
`$841
`
`Your Annual Percentage Rate (APR) is the annual interest rate on your account. See BALANCE COMPUTATION METHOD
`on page 2 for more details. Minimum interest charge may exceed Merest charge below, per your credit card agreement.
`
`Purchases
`Plan 819-00001 WV INT PY RQ
`details of your p'anri
`
`A PR
`269900%
`0.0000%
`
`252.36
`0.00
`
`5.41
`0.00
`
`S1S-0O0O1 j You must pay your plan balance of $1,440.00 in fuB by 09r07/2O20 to avoid paying interest charges
`ACCRUED
`TOTAL
`PURCHASES
`PAVsKNTS
`NEW PLAN WTEREST
`ACCRUED
`BALANCE TMSKRJOD
`SfTEREST
`SCMAROES
`SCREDITS
`1.440.00
`
`1,500.00 03A>7/2019 09/07/2020
`
`1,440.00
`
`S S t e c jD
`
`c Z i r c t a i x.
`
`•
`
`Yss, I hove moved or updated my
`e-mail address • see reverse.
`
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`WAOHHA BASHRAHIL
`3410 RIVER RANCH NORTH OR
`ROSENBERG TX 77471-4476
`
`Accounl
`numbw
`New balance
`$1,727.97
`994
`
`M
`
`-4931
`MLntnuni puytntrt
`$520.00
`
`Payment must reach us by
`6 pm ET on 0VI9/2020.
`
`$[ PtMM fTMte ct«8cfc ptytttt to:
`
`COMCNfTY - YOUR TUITION SOLUTION
`Please return this portion along with your payment to:
`PO BOX 659622
`SAN ANTONIO TX 78266-9622
`
`3300101? 00013571
`
`ItlSl 000052000 ••017S71?
`
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`
`

`

`Koop (oh portion for poor reconfi.
`RfJeef To Oe ft* tea fbMr You Find M ajfrfeft* On tear S M n n ri
`II you M r* thrm is an rrrrer cn your slelemenl. writ* to us at: Cornenily
`Capital Bar* TO Box 182620. Columbus. Ohio <t3218 2630.
`In your lariat, grw in the lollowing intareiliuii:
`• Accamt ioforwwtiort: Your name and account number
`• OMar annual.' The dorter amount of trie suspected error.
`• Description tl Ptobkm II you think there is an error on your bin.
`describe whet you beNeiMS it wrorej and why you believe it is a mistake.
`You mult contact ua within 60 day* attar the error appeared on your
`
`Cdo mt are not required to iracaUoMe any potential errors and you may
`
`row must notify us ef any potential errora in mUinc- Tou aiey call us. but if
`i to pay Pa amount In question.
`VfWIe we NwaaUfala whether or not there hat been an error, the following
`are truer
`• art cannot try to collect the amount m ojuestion. or report you as
`rjaaawaaam art that astount.
`• The charee in ojuaitlon way iwrnetn on your statement, and wa rway
`continue to Charge you interest on that amount. 8ut. il wa drtr»mine that
`we wade a relink*. you will not hove to pay the amount in question or
`any Interest or other lees related to that amount.
`• White you do not Kmc to pay the amount in rjuestion. you art responsible
`lot die rCMwindoi at your balance.
`• We can apery any unpaid amount aceinel your credit limit.
`rote- *fcM* H re* Am DkmlMfd ma> YUrn Cmdtt CMd ^UKJ»MI
`II you ara otmiislisd wilh the (oodi or tarvicat that you hew purcfwaod
`iaW your credit card, and you haw tried In good talth lo correct the
`probtaai with tha merchant, you may hove
`I ho rajftt not to pay tha rawatntnj
`amount due on the purr, hen.
`To MM Ma rtthL aH «J the Wtoarirc nwal be true:
`1. Tha purchaac raust Iwavbeen raade in your home atate or within WO
`mamc/youitiitm*mtMriuMnm,m*thipuKhMtpfamjttfiu*
`boon mora than $90. (feater Natthat af thaaa is nacaasary il your purcrtaaa
`was baaad on an ediwrtieewent wa melted to yau* ar If we own tha company
`• MI MM you ma Mods or senrteesj
`2. You mutt haw uaad your crod* card lor It* purchase. Purchases *wd»
`wHb wh adwnces boman ATM or with a chack that accaaaes your caadH
`card account do not Qualify.
`3. You mutt not yat haw lurry paid lor the purchaac.
`If all of the criteria abow are mat and you are stilt dissatisfied with die
`r^grwsi, contact ue in ar»rVajat;Comryitty CapW Ban* PQSon 1S2620.
`Ceejmfaue. Ohio 43218-262a
`tama rutas apply lo *•* disputed amount at
`dajcueeod abew. After we Hnmh our trwestigallon. we wfM ten you our
`decision. At ami point, rl wa think you owe an amount and you do not pay
`we may report you as otelnqucnt.
`
`CREDIT RtTOfmMC. we may icport intermation about your account lo
`credit bureaus, tat* ueyuamls, raiimtf payments. a» other defaults on your
`account may be reflected In your credit report.
`NOTICE or CREDIT REPORT DISPUTES
`II you bckeve the account information we reported to a consumer rcportinf
`agency is inaccurate, you may submit a direct dispute to Come wily Capital
`Bank TO Boa 182120. Cohaafcus. Ctao 43218 2120. Yaur wNtejn olapute
`must provide suffklent Information lo identify tha account and specify why
`die informal ion is Inaccunitct
`* Accaaat mformanan: Your name and account number
`* Contact Information: Your address and laiaphona number
`* Ofastdad lidannition Identify the account infrawaliui ilM|iiaail and
`ei plain why you belirw II n) inaccurato
`* Supaaftfraj Oacuntantalioa: If aMwabas. pmvlde a copy of tha section of
`the credit report thoaax the account mluiiiajliun you aic dfapulinrj
`Wt will nrestigate tha disputed ireonnsiton and report tha results to you
`within 30 day* of receipt of the Information needed lor our (rwcallfatfon. If
`wa find thai the account edomwtien wa reported a) Irwccuale. wa will
`pmroptty provide die accessary correction to each c
`agency to which wo teportod die information.
`PAYMENTS MARKED *MI0 W FULL". Alt written coaanurwtaUom
`rfifjarrHftst diaputad amounts that fncajdo my check ar other peyotent
`tnsbument worked with •pajtmanl in tutr at slmwar laaaiiaja. mutt be tew
`to-. 6300 Monti loop 1604 Cast, Suit* 101. San AraonioT T77M47-SOW.
`00 NOT USE Tftt t m O I CO ROaTTTAWCt W t l O P C.
`* Wr% rVaty ocoopt poynonl tool lo oojf othof oo^koos wittoul losing ony ol
`owrt^Mt.
`* fo> poyvtttM ohOtl opofolo so on Kcovd aWbd oMwatsUMt^on •wttaOul priov
`MittOII OpDMVOt.
`CUSTOMER tUrvtCE. nalt cawwi^jwVyaurtattliaiitarian or call
`14663080678{TOO/TTY
`I M » 8 19
`TEtEPMONE w^iTORawi. Te prnride you w» hajh oyalRy antlea.
`phono Cnyi*n*unteatiion wWi %M lo fM^nHovod ondtor focovdott.
`ISXXTIONAI, rl*i0fb)UTtON. Thafofkya*taowa^aMlan*,wiamaaMwa;
`on the front of your statement, mean the wtoaajvji V moans watabfo rate
`(this rate may «ary»i VrV INT PAY HQ atoans WWl IHTER£»T. PAYMENT
`RCOUIRCOi wVINTEOPY moan* WAIVE INTEIrEST. GQWAL PAYmtNT, WV
`INT uOW PMT means WAIVE INTEREST, LOW PAYMENT; Of tNT PT RQ
`meant DEFER INTERfTT. MYMENT WXMftah OCf HIT CO f*Y maans
`DETER INTEREST,