MouthWashInfo
New Member
- Jurisdiction
- Massachusetts
I defaulted on a credit card and I need to respond to the following Complaint:
Statement of Damages
Complaint:
Plaintiff, Name Hidden Plaintiff (NHP), complaining of the Defendant, Name Hidden Defendant (NHD), hereby alleges as follows:
1. Plaintiff is a Limited Liability Company having a usual place of business at Address Hidden Plaintiff (AHP).
2. Defendant is an individual residing at Address Hidden Defendant (AHD).
COUNT I
(Breach of Credit Card Agreement)
3. Defendant entered into a credit card agreement ("agreement") account no. ending in XXXXXXXXXXXXXXX with Bank ("original creditor").
4. Under the terms of the agreement, original creditor agreed to extend credit and/or advance money in consideration of Defendant's promise to pay for the goods and/or services and/or conditions amount borrowed plus interest in accordance with the terms and of the agreement.
5.Defendant failed to make timely payments as required under the terms of the agreement. Defendant is in default of the agreement.
6. Plaintiff acquired or purchased the delinquent credit account and is the bona fide owner of this account.
7. Defendant's last payment towards the account occured on 09/17/2018, in the amount of $200.00.
8. Defendant is indebted to Plaintiff in the total amount of 9539.01, plus post judgment interest and court costs.
COUNT II
(On Account)
9. Plaintiff repeats, reiterates and realleges each and every allegation set forth in paragraphs 1 through 8 of the complaint.
10. Defendant established a credit card account with "original creditor" which he/she used to obtain goods, services, and/or borrow money providing that he/she would pay "original creditor" for the goods, services, and money obtained.
"original creditor"
11. "original creditor" provided written monthly billing statements to Defendant containing balances due, to which Defendant expressly or impliedly assented.
12. Defendant has an outstanding balance owed on this account which, to date, remains unpaid.
13. Plaintiff has demanded payment but Defendant has, to date, failed to pay Plaintiff. Accordingly, Defendant owes Plaintiff the total amount of $9539.01 plus post judgment interest and court
costs.
WHEREFORE, with respect to Counts I, and II, Plaintiff demands judgment against Defendant, in an amount to be determined by the Court, plus post judgment interest and court costs, and for such other relief as the court deems to be just.
Statement of Damages
Complaint:
Plaintiff, Name Hidden Plaintiff (NHP), complaining of the Defendant, Name Hidden Defendant (NHD), hereby alleges as follows:
1. Plaintiff is a Limited Liability Company having a usual place of business at Address Hidden Plaintiff (AHP).
2. Defendant is an individual residing at Address Hidden Defendant (AHD).
COUNT I
(Breach of Credit Card Agreement)
3. Defendant entered into a credit card agreement ("agreement") account no. ending in XXXXXXXXXXXXXXX with Bank ("original creditor").
4. Under the terms of the agreement, original creditor agreed to extend credit and/or advance money in consideration of Defendant's promise to pay for the goods and/or services and/or conditions amount borrowed plus interest in accordance with the terms and of the agreement.
5.Defendant failed to make timely payments as required under the terms of the agreement. Defendant is in default of the agreement.
6. Plaintiff acquired or purchased the delinquent credit account and is the bona fide owner of this account.
7. Defendant's last payment towards the account occured on 09/17/2018, in the amount of $200.00.
8. Defendant is indebted to Plaintiff in the total amount of 9539.01, plus post judgment interest and court costs.
COUNT II
(On Account)
9. Plaintiff repeats, reiterates and realleges each and every allegation set forth in paragraphs 1 through 8 of the complaint.
10. Defendant established a credit card account with "original creditor" which he/she used to obtain goods, services, and/or borrow money providing that he/she would pay "original creditor" for the goods, services, and money obtained.
"original creditor"
11. "original creditor" provided written monthly billing statements to Defendant containing balances due, to which Defendant expressly or impliedly assented.
12. Defendant has an outstanding balance owed on this account which, to date, remains unpaid.
13. Plaintiff has demanded payment but Defendant has, to date, failed to pay Plaintiff. Accordingly, Defendant owes Plaintiff the total amount of $9539.01 plus post judgment interest and court
costs.
WHEREFORE, with respect to Counts I, and II, Plaintiff demands judgment against Defendant, in an amount to be determined by the Court, plus post judgment interest and court costs, and for such other relief as the court deems to be just.
