Midland Credit Management Inc. vs Marcus Guein

5. Defendant had an account (the "Account"). The amount due is the result of transactions that occurred on the Account. Defendant was provided statements evidencing Defendant's use of the Account and the balance due. Defendant failed to make the required payments and subsequently defaulted on the Account on May 03, . Thereafter, Plaintiff was assigned all rights, title, and interest in the Account.

6. Plaintiff is the sole owner of the debt. Attached as Exhibit A is a true and correct copy of the Bill of Sale from THE BANK OF MISSOURI, to Plaintiff. The Account was purchased by Plaintiff on October 28, .

7. The Account balance at the time of charge-off was $1,655.46. Plaintiff alleges that the date of default is May 03, 2024 and the date of the last payment was February 26, 2024 .

8. The name of the charge-off creditor at the time of charge-off is THE BANK OF MISSOURI. The address utilized by THE BANK OF MISSOURI at the time of charge- off was 916 NORTH KINGSHIGHWAY PERRYVILLE,MO . At the time of charge off, the redacted account number associated with the debt was XXXXXXXX- XX- .

9. The name of the debtor as it appeared in the records of THE BANK OF MISSOURI is MARCUS GUEIN and the last known address as it appeared in the records of THE BANK OF MISSOURI is .

10. The name and address of all post charge-off purchasers of the debt are as follows:

Address NW GREENBRIER PKWY BEAVERTON OR 350 CAMINO DE LA REINA SUITE 100 SAN DIEGO CA

Name CONCORA CREDIT INC.

MIDLAND CREDIT MANAGEMENT, INC.

11. Plaintiff has complied with the provisions of CA CIVIL § 1788 .52. Plaintiff informed Defendant of the assignment of the Account.

12 Pursuant to CA CIVIL § 1788 .58(b), attached as Exhibit B is a true and correct copy of a monthly statement recording a purchase transaction, payment, or balance transfer while the Account was active as required by CA CIVIL § .52(b).

13. Pursuant to CA CIVIL § 1788 .58(b), attached as Exhibit C is a true and correct copy of a billing statement that was mailed to Defendant stating the balance due on the Account at or around the time of charge-off.

14. Plaintiff acquired all right, title, and interest to the Account. To the extent that Plaintiff acts in its capacity as successor-in-interest to the original creditor or its assigns, references herein to Plaintiff may include Plaintiff's predecessor-in-interest.

15. Plaintiff has attempted to contact Defendant through several means in an effort to resolve the Account, but has been unsuccessful. Defendant has not repaid this debt. Plaintiff works with consumers like Defendant to find mutually acceptable solutions, often offering discounts, hardship plans, and a variety of payment options. The majority of Plaintiff's consumers ignore calls or letters, and some simply refuse to repay their obligations. When this happens, Plaintiff must decide whether to pursue collection through legal channels, including litigation such as the present action against Defendant. Nonetheless, Plaintiff remains interested in discovering a mutually beneficial solution through voluntary payments, if possible, in this case.

16. Before commencement of this action, Plaintiff informed Defendant in writing, that it intended to file this action and that this action could result in a judgment against Defendant that would include court costs allowed by California Code of Civil Procedure $ 1033 (b)(2).