Pet Filed in Associate Ct August 06, 2024 (2024)

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On August 06, 2024 aPet Filed in Associate Ctwas filedinvolving a dispute betweenMidland Credit Management, Inc.,andMcmullin, Melissa,for AC Breach of Contractin the District Court of Warren County.

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24BB-AC00537 IN THE CIRCUIT COURT OF WARREN COUNTY, MISSOURI ASSOCIATE CIRCUIT DIVISION MIDLAND CREDIT MANAGEMENT, INC. Case No: Plaintiff, vs. MELISSA MCMULLIN aka MELISSA R MCMULLIN Defendant. COMPLAINT Plaintiff, MIDLAND CREDIT MANAGEMENT, INC., by counsel, sues Defendant MELISSAMCMULLIN aka MELISSA R MCMULLIN, under Account Stated and in support thereof states: 1 Plaintiff is authorized to file this Complaint in this Court. Plaintiff owns portfolios of consumerreceivables, which it attempts to collect. Plaintiff strives to treat its consumers, such as Defendant, withrespect, compassion and integrity, hoping to provide mutually-beneficial opportunities for consumers torepay their debts and attain financial recovery. 2. Defendant is subject to this Court's jurisdiction. COUNT 1 3. Defendant established an account with COMENITY BANK under redacted account numberXXXXXXXXXXXXX-XXXX. 4. Defendant was provided statements delineating Defendants use of the account and stating thecurrent balance due. 5. Defendant defaulted on the account. 6. A statement of account balance was sent to Defendant and not paid. 7. The amount due under this account is $1,832.23. COUNT 2 8. Defendant established an account with COMENITY BANK under redacted account numberXXXXXXXXXXXXX-XXXX. 9. Defendant was provided statements delineating Defendants use of the account and stating thecurrent balance due. 10. Defendant defaulted on the account. 11. A statement of account balance was sent to Defendant and not paid. 12. The amount due under this account is $924.45.GL_0100M File No 24-136494 SCP.COUNT 3 13. Defendant established an account with COMENITY BANK under redacted account numberXXXXXXXXXXXXX-XXXX, 14. Defendant was provided statements delineating Defendants use of the account and stating thecurrent balance due. 15. Defendant defaulted on the account. 16. A statement of account balance was sent to Defendant and not paid. 17. The amount due under this account $1,777.20. COUNT 4 18. Defendant established an account with CITIBANK, N.A. under redacted account numberXXXXXXXXXXXX-XXXX. 19. Defendant was provided statements delineating Defendants use of the account and stating thecurrent balance due. 20. Defendant defaulted on the account. 21. A statement of account balance was sent to Defendant and not paid. 22. The amount due under this account $815.56. 23. Plaintiff acquired all right, title and interest to Defendant's accounts, and has attempted to contactDefendant through several means in an effort to resolve the account with Defendant, but has beenunsuccessful. Defendant has not repaid the balance owed on the accounts. Plaintiff remains willing todiscuss various options to resolve the outstanding obligation, although the options may be different thanthey were prior to the initiation of litigation. 24. Defendant owes Plaintiff the combined balance of $5,349.44. 25. In support of the allegations, Plaintiff incorporates herein by reference the attached Exhibits.GL_0100M File No 24-136494 SCPWHEREFORE, Plaintiff requests judgment against the Defendant for $5,349.44 and costs of theaction and post judgment interest at the statutory rate. DAVID D. BACKER 41685 Attorneys for Plaintiff P.O. BOX 410949 KANSAS CITY, MO 64141 Phone: (866) 300-8750 Fax: (866) 629-6496 IL_MissouriFax @ memcg.com PLEASE UNDERSTAND THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.GL_O100M File No -24-136494 SCPDepartment of Defense Manpower Data Center Results as of Jul-11-2024 08 4847 AM SCRA S21 Ss 0 m Re ey wm Status Report Pursuant to Servicemembers Civil Relief ActSSN: XXX-XX-Birth Date: an XX apLast Name: MCMULLINFirst Name: MELISSAMiddle Name:Status As Of: Jul-11-2024Certificate ID: 3F1QLPHD4J7YPJD ‘On Active Duty On Active Duty Status Date ‘Actwe Duty Start Date Active Duty End Date Status ‘Service Component NA NA No NA This response rellecs the individuals’ actwve duly status based on the Actwe Duty Status Date, ‘Lett Active Duty Within 367 Days of Active Duty Status Date ‘Active Duty Start Date Active Duty End Date Salus Service Component NA NA No This response rellects where the individual let actwe duty status within 367 days preceding the Active Outy Status Date ‘The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Actwe Duty Status Dale ‘Order Notficabon Start Date. ;dor Noulbcation End Date Status ‘Service Component NA NA No NA This response rellects whether the indndual or husher unit has received earty nobfication 10 repo for active dutyUpon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status ofthe individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, Space Force, NOAA, PublicHealth, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active DutySam rusespgactehSam Yousetzadeh, DirectorDepartment of Defense - Manpower Data Center4800 Mark Center Drive, Suite 04E25Alexandna, VA 22350The Delense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and EligibilityReporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibilly systemsThe DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 3901 et seq, as amended) (SCRA) (formerly known asthe Soldiers’ and Sailors’ Civil Relief Act of 1940) DMDC has issued hundreds of thousands of “does not possess any information indicating that theindividual 1s currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any familymember, fend, or representative asserts in any manner thal the individual was on active duly for the active duty status date, or 1s otherwise entitled to theprotections of the SCRA, you are strongly encouraged to obtain further ventlication of the person's status by contacting that person's Service Service contactinformation can be found on the SCRA website's FAQ page (Q35) via this URL: https ‘//scra.dmdc.osd.mil/scra/#/taqs. If you have evidence the personwas on active duly for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invokedagainst you See 50 USC App. § 3921(c)This response reflects the following information (1) The individual's Active Duly status on the Active Duly Status Date (2) Whether the individual left ActiveDuty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for activeduty on the Active Duty Status DateMore information on "Active Duty Status"Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods lessthan 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 serviceauthorized by the President or the Secretary of Delense under 32 USC § 502(1) for purposes of responding to a national emergency deciared by thePresident and supported by Federal funds All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in theunit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard ReserveProgram Administrator (RPAs) Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.SPublic Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).Coverage Under the SCRA is Broader in Some CasesCoverage under the SCRA 1s broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not bereported as on Active Duty under this certificate. SCRA 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 SCRA, as defined in accordance with 10 USC § 101(d)(1).Many times orders are amended to extend the period of active duty, which would extend SGRA protections. Persons seeking to rely on this websitecertification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have notactually begun active duly or actually reported for induction The Last Date on Active Duty entry 1s important because a number of protections of the SCRAextend beyond the last dates of active dutyThose who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRAare protectedWARNING. This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providingerroneous information will cause an erroneous certificate to be providedSTATE OF MISSOURI Midland Credit Management, Inc., Plaintiff -vs- AFFIDAVIT OF ALEXANDRIA BRUCE MELISSA MCMULLIN, Defendant(s). Alexandria Bruce, whose business address is 13008 Telecom Drive Suite 350, Tampa, FL 33637, certifies and says: 1 Tam employed as a Legal Specialist and have access to pertinent account records for Midland Credit Management, Inc. ("Plaintiff" or "MCM"). I am acompetent 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 was assigned all the rights, title and interest to Defendant's COMENITY BANK account XXXXXXXXXXXXXX MB (MCM Number WME) (hereinafter "the Account"). 2 T have access to and have reviewed the electronic records pertaining to the Account maintained by MCM and am authorized to make this affidavit on MCM's behalf. The electronic records reviewed consist of (i) data and records acquired from the seller or assignor when MCM purchased or was assigned the Account, which were incorporated into MCM's business records upon purchase or assignment, and (ii) data and records generated by MCM in connection with servicing the Account since the date the Account was purchased by or was assigned to MCM. 3 Tam familiar with and trained on the manner and method by which MCM creates and maintains its business records pertaining to the Account, which consist of (i) data and documents acquired from the seller or assignor, and (si) subsequent collection and/or servicing activities by MCM. The records are acquired or created, and are kept in the regular course of MCM's business. It was in the regular course of MCM's business for a person with knowledge of the subsequent collection and/or servicing activities recorded, and a business duty to report, AFFIDAVIT OF ALEXANDRIA BRUCE - |INNER TVS EA ‘MM A FILAto make the record or data compilation, or to transmit information thereof to be included in such record, or for such information to be posted in MCM's records by a computer or similar digital means. In the regular course of MCM's business, the record or compilation of the subsequent collection activities is made at or near the time of the act or event by MCM asa regular practice. 4 MCM's records show that Defendant(s) owed a balance of $1,832.23 as of 2024-06-10. LEFT BLANK INTENTIONALLY AFFIDAVIT OF ALEXANDRIA BRUCE - 2MOEOUAON GD LAT A (Ma a OER RATAI certify under penalty of perjury that the foregoing statements are true and correct JUL 03 2024 Date Alexandr: ice STATE OF FLORIDA COUNTY OF HILLSBOROUGH Signed and sworn to (or affirmed) before me on JUL 0 3 2024 by Alexandria Bruce. tetas RwilSOM Notary Pubiic- State of F'onda Commission # 4H 315¢24 My Comm, Expires Seo 22 2026 h gtary Pdblic MG_|/U ASD WV Bor ced through Natlerai Notzr Assn CA137 AFFIDAVIT OF ALEXANDRIA BRUCE - 3ARETE ANB InN A intain TOVQUABLAEUNU 4-136494STATE OF MISSOURI Midland Credit Management, Inc., Plaintiff -vs- AFFIDAVIT OF ALEXANDRIA BRUCE MELISSA MCMULLIN, Defendant(s). Alexandria Bruce, whose business address is 13008 Telecom Drive Suite 350, Tampa, FL. 33637, certifies and says: 1 Jam employed as a Legal Specialist and have access to pertinent account records for Midland Credit Management, Inc. ("Plaintiff" or "MCM"). 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 was assigned all the rights, title and interest to Defendant's COMENITY BANK account XXXXXXXXXXXXXX A (MCM Numbe A (hereinafter "the Account"). 2 I have access to and have reviewed the electronic records pertaining to the Account maintained by MCM and am authorized to make this affidavit on MCM's behalf. The electronic records reviewed consist of (i) data and records acquired from the seller or assignor when MCM purchased or was assigned the Account, which were incorporated into MCM's business records upon purchase or assignment, and (ii) data and records generated by MCM in connection with servicing the Account since the date the Account was purchased by or was assigned to MCM. 3 Tam familiar with and trained on the manner and method by which MCM creates and maintains its business records pertaining to the Account, which consist of (i) data and documents acquired from the seller or assignor, and (i1) subsequent collection and/or servicing activities by MCM. The records are acquired or created, and are kept in the regular course of MCM's business. It was in the regular course of MCM's business for a person with knowledge of the subsequent collection and/or servicing activities recorded, and a business duty to report, AFFIDAVIT OF ALEXANDRIA BRUCE - |IAEOVO RH EGY EH TE TOU (AUTREto make the record or data compilation, or to transmit information thereof to be included in such record, or for such information to be posted in MCM's records by a computer or similar digital means. In the regular course of MCM's business, the record or compilation of the subsequent collection activities is made at or near the time of the act or event by MCM as a regular practice. 4 MCM's records show that Defendant(s) owed a balance of $924.45 as of 2024-06-10. LEFT BLANK INTENTIONALLY AFFIDAVIT OF ALEXANDRIA BRUCE - 2IOAN SUEY aE AO a ima LMT 4-1365221 certify under penalty of perjury that the foregoing statements are true and correct. GUL 0 8 2024 Date lexandri ruce STATE OF FLORIDA COUNTY OF HILLSBOROUGH Signed and sworn to (or affirmed) before me on JUL 0 8 2024 by Alexandria Bruce. LATASHA 3 WILSON oe Notary Public - State of Floriea a (Seat)*i 3 My Commission # iy 315424 Comm, Expires Sep 22, 2026 Borcec through Netlonai Notary Assn lotaty Public CAI37 AFFIDAVIT OF ALEXANDRIA BRUCE - 3INLAND aia AO a EUV GIEO OD ROREE DE 24-136522STATE OF MISSOURI Midland Credit Management, Inc., Plaintiff -Vs- AFFIDAVIT OF ALEXANDRIA BRUCE MELISSA MCMULLIN, Defendant(s). Alexandria Bruce, whose business address is 13008 Telecom Drive Suite 350, Tampa, FL 33637, certifies and says: 1 T am employed as a Legal Specialist and have access to pertinent account records for Midland Credit Management, Inc. ("Plaintiff' or "MCM"). 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 was assigned all the rights, title and interest to Defendant's COMENITY BANK account XXXXXXXXXXXXX XG (MCM Number) (hereinafter “the Account"). 2. T have access to and have reviewed the electronic records pertaining to the Account maintained by MCM and am authorized to make this affidavit on MCM's behalf. The electronic records reviewed consist of (i) data and records acquired from the seller or assignor when MCM purchased or was assigned the Account, which were incorporated into MCM's business records upon purchase or assignment, and (ii) data and records generated by MCM in connection with servicing the Account since the date the Account was purchased by or was assigned to MCM. 3 T am familiar with and trained on the manner and method by which MCM creates and maintains its business records pertaining to the Account, which consist of (i) data and documents acquired from the seller or assignor, and (ii) subsequent collection and/or servicing activities by MCM. The records are acquired or created, and are kept in the regular course of MCM's business. It was in the regular course of MCM's business for a person with knowledge of the subsequent collection and/or servicing acttvities recorded, and a business duty to report, AFFIDAVIT OF ALEXANDRIA BRUCE - |UIE a0 DA IEAto make the record or data compilation, or to transmit information thereofto be included in such record, or for such information to be posted in MCM's records by a computer or similar digital means. In the regular course of MCM's business, the record or compilation of the subsequent collection activities is made at or near the time of the act or event by MCM as a regular practice.4 MCM's records show that Defendant(s) owed a balance of $1,777.20 as of 2024-06-10. LEFT BLANK INTENTIONALLY AFFIDAVIT OF ALEXANDRIA BRUCE - 2ATAU AE OAAUCEATE TAO 24-136523I certify under penalty of perjury that the foregoing statements are true and correct. JUL 0 8 2024 Dae OOOC~CSSSS Wynele Alexandrid Bruce Coevee STATE OF FLORIDA COUNTY OF HILLSBOROUGH Signed and sworn to (or affirmed) before me on dUL 0 8 2024 by Alexandria Bruce. 2 é LATASHA R WILSON “Notary Puoiic - State of Florida Commission # rH 315424 NEED NC ry Ref bhic DO {yo omy Comm, Expires Sep 22, 2026 Jor ded through National Notary Asst CAI37 AFFIDAVIT OF ALEXANDRIA BRUCE - 3IINVER SHEA OVALE UIA EE OUMNHSTATE OF MISSOURI Midland Credit Management, Inc., Plaintiff -Vs- AFFIDAVIT OF ALEXANDRIA BRUCE MELISSA R MCMULLIN, Defendant(s). Alexandria Bruce, whose business address is 13008 Telecom Drive Suite 350, Tampa, FL 33637, certifies and says: 1 Tam employed as a Legal Specialist and have access to pertinent account records for Midland Credit Management, Inc. ("Plaintiff' or "MCM"). 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. Plaintiffis the current owner of, and was assigned all the rights, title and interest to Defendant's CITIBANK, N.A. account XXXXXXXXXXX XW (MCM Number (hereinafter "the Account”). 2 I have access to and have reviewed the electronic records pertaining to the Account maintained by MCM and am authorized to make this affidavit on MCM's behalf. The electronic records reviewed consist of (i) data and records acquired from the seller or assignor when MCM purchased or was assigned the Account, which were incorporated into MCM's business records upon purchase or assignment, and (ii) data and records generated by MCM. in connection with servicing the Account since the date the Account was purchased by or was. assigned to MCM. 3 Tam familiar with and trained on the manner and method by which MCM creates and maintains its business records pertaining to the Account, which consist of (i) data and documents acquired from the seller or assignor, and (ii) subsequent collection and/or servicing activities by MCM. The records are acquired or created, and are kept in the regular course of MCM's business. It was in the regular course of MCM's business for a person with knowledge of the subsequent collection and/or servicing activities recorded, and a business duty to report, AFFIDAVIT OF ALEXANDRIA BRUCE - |‘AROSE OE ‘OM LANE ADULT ERE FFREC 24-137086to make the record or data compilation, or to transmit information thereof to be included in such record, or for such information to be posted in MCM's records by a computer or similar digital means. In the regular course of MCM's business, the record or compilation of the subsequent collection activities is made at or near the time of the act or event by MCM asa regular practice. 4 MCM's records show that Defendant(s) owed a balance of $815.56 as of 2024-06-10. LEFT BLANK INTENTIONALLY AFFIDAVIT OF ALEXANDRIA BRUCE - 2(DUVALL EE AO (OVATE IMI 24-1370I certify under penalty of perjury that the foregoing statements are true and correct JUL 0 3 2024 Date te Alexandra Brice = ewe STATE OF FLORIDA COUNTY OF HILLSBOROUGH Signed and sworn to (or affirmed) before me on GUL 0 3 2024 by Alexandria Bruce. LATASHA, ALSON Notary Pubic 12 of Florida Commissior 425 wy Comm 5e2 77, 2026 lotary Pu Ic Boreec thraegh nasiene Notary ASE CA137 AFFIDAVIT OF ALEXANDRIA BRUCE - 3IANO ATAU AEE COU ‘MUOPAGE 1 OF 4 Bienes Aecour Ro meee New balance $189223 Minimum payment due $60000 Previous balance $1747 45 Payment due date 10/12/2023 Payments 0.00, Minimum Payment Warning: if you make only the minimum Other credits -000 payment for each pend, you will pay more m interest and st wi Purchases +000 Other debits +000 take you longer to pay off your balance For example +4100 if you make no addaional You will pay off ‘And you will E Fees charged charges using this card | the balance shown enc! up payingan Interost charged _ +4378 and each month you pay on the statement estimated tota New balance ¥81,892.23 tn about: of SY Past due amount 510.00 ivi [yea 2 ne Credit limit $1,490 00 For information eg) ard 9 credit Counseling services, Available credit “$342 00 call 1-800-284-1706 Statement closing date 09/97/2023 Days m biling cycle 30 TRANS DATE TRANSACTION DESCRIPTION/LOCATION AMOUNT Fees 09/12/2023 LATE FEE 41.00 TOTAL FEES FOR THIS PERIOD. $41.00 Interest charged Interest Charge on Purchases 43.78 Total interest For This Period $43.78 - _[ 020 totais year to date Total foes charged im 2023 $26700 Total interest charged in 2023 $332 83 ersten ‘Your Annual Percentage Rate (APR) 's the annual interest rate on your account See BALANCE COMPUTATION METHOD on page 2 for more details Minimum interes! charge may exceed mterest charge below, per your credil card ‘agreement TYPE OF BALANCE SUBJECT INTEREST BALANCE APR TO INTEREST RATE CHARGE Purchases 29.99% (v} 1776.63 (DA) 43.78 Find out how to shop safely online at onguardonine gov We noticed you prefer to pay online To better serve you, wo will no longer include a remittance envelope with biling statements If you stil prefer to recawe one, contac ‘ustomer Care and we will include it with future statements CONTINUED) NOTICE See rever se for mportant information Pease at at perferavon above jun sere a number ROAMANS 2 /ULLBEAUTY brane lew bal nce $1,832 23 Winimom payment $600.00 ) Yes, [have moved 0 updated my Mailed payments must reach us l oma address see reverse ‘Amount enclosed ~ ay6 pm : ET on 10/12/2028, J $| ‘ease manec payabie to _] MENITY - RC MANS ALA ta De pete A tab had MELISSA MCMULLIN Please return this portion along with your payment to 14327 STONE CRECK LN P.O Box 65% 972 WRIGHT CITY MO 63390-2194 Dallas TX 7? 265-0872 sgl telat LEU! of gf teeepottpta ssc9b35000513 O92 ee DOOULOO0O 000183223Kodi nis pom di 16F yoie eeorde ow To aivou0 Paviic INTEREST Youre dite innei Sis air What To Oo It You Think You Find & insane On Your Starement the‘fouUosepay ofsourechentrablingbalance eye byWe thewildu nochange yoU mierest on purenases teach mont We wi begin Hr you Bon there an tr on you statement vine to us at Comanly Bait “charge interest on new purchases made under a Low APR. Equal Payment PO Box thz7Az Columbus ONAIIA7h 1” Buxigol Payment Cras Plan tom be date of purchase Ao your ler gia us De fale lmaon : ‘account wma oe Your nama and wecOun UMBC BALANCE COMPUTATION METHOD. We colcsate interest separatelyfo! : Paiacmyae? The doiae aunt he suspend emo ‘nari balance using the mathosis) dascrisag below Tha ho iter : Deere 6 1 ya Baek heresan en your bi Detcuwevesnea othe Batance Subject 1 I 10s Rate column me Gescribe what you Daeve muon) And why yon el E¥E 8 8 Interest che Caleataton section on ths stslement conesponds to Bie rustake fallowea ‘You must contact us von 60 days ahr he emer appeates on your DA} Wa fgue Ie ntraat chargeon hs balance by applying he peroae statement You must pty vs of wr otent.t ems a sonny You rity cal rate to da “aly balance”fe each cay i ha bing pared To get he ly Gs bul you eo we ate nol segue to nveslignts any polenta wrors Ons Lslance’ we take the begining beance each day, 3 any new Wansactons youmiay nave o pay tha amount n quesben fn fans ang kadar! any pyar of rene (raat any Aa Cr ‘itte we vestigate wheter a there ha ban an ear Die follow halance as.0 zero balance} This gves us tho doy Balance are mua INC) we Route te interest chargeon ths halance By apbying the peioge : ‘¥e cannotty Wo cl*t Die amount m uveston oF eb you 9s ‘eo ho “average any Boiance” forme bling paneg To pa Nt “averHDe doting on that amount “daly balance” we lode the beginnng balance eaeh day ded amy New The charge mn queaon al temata on gow siatement and we may. Uansactions ane fees and subtiac any payments or cma r4atng any pet conunn to charge you infernal on Ina amount But i we dale lod! beionce es 8 are balance) Ths gives uethe day alanea Then, we tat we mado a mistake you wll tot have to pay the ment 188 up all he dy alacesfor na biling period ana aiviae the total by The ‘question ao her fees lated that arn hhumber of daysin the bing pened Ths gves Us ie “aserage gay inte you doseynotiehava ts pay me amc*ntin questan you a6 oF balance” responsive for Bie remmarie’ of your aatance (CUSTOMER SERVICE. viet COMENITY NETROAMANS of cat . Wie can apply any urge aroun again your raat ht 1 80d 695-0105 (TOOITTY 7 800-695 1742} Send al nquirieg CUSTOMER SERVICE, PO Box 197273, Columbus, OH 42218-2272 Your Rights # You Are Dissatefed Win Your Cred Card Purchase Ityou ara ncaa wi the gore or serene But you have purchased TELEPHONE MONITORING To prowde you weh hgh qusity sence phone nth your eset cand od yu we wed ya ty comete problem commis tua rs montored andi recor nn the meer hank you may have the rh ols gay Doe ramainng amount TONAL INFORMATION. Abbrevavons on your slaernani mean Pe ‘ue on ine purchase faicwnna (v7) means vanabie rat (ths ave ay vavy) WV INT PAY BO smeare WAIVE INTEHEST PAYMENT HEGUBE-D WV INI EO PY mean To.use dys night al ofthe fling must be rue WANE NTEREST EQUAL PAYMENT WY 2VT LOW PAST means WAIVE 1 The patchese must hase been mae n you home state or wn 100 IIHR LOW PAYMEAIT UF INT PY RO means OCFEH BVTEHES ‘les of your ean mang addons ad Ihe purcnake pice must have PAYMENT REQUSIED DEF INT EO PY means OCFER INTEREST EQUAL Coon ms 7 ake Neher of seb eaves if your pura PAYMENT OF INT LOW PNT meant OEFER INTEREST LOW PAYMENT Gras based on an adverssem*ntwe mated Ia you oF fe oun the company ‘and LOW APR EO PAY means LOW APR EQUAL PAYMENT You may pay ‘hat sla you the goods oF services| ‘kof your 2 "You must hove used you crest cars fr the purchase Purchoaes mode NOTICE ABOUT ELECTRONIC CHECK CONVERSION When you prove wth cash advances fom an ATM or wih a check lal accesses your erect 2 check as gaymenl. you auhonze us either lo use information from your Cand account do not quality ‘check tormake a onacbme electron fund ara from your accounter 3'You must not yet hve Nay pa for he pac hase process iba paymant as a check transaction Hall othe entena above re met and you ae tll desauafed withthe PAYMENTS. Payments US douara recewved bythe applicable due date urease conlact us #3) at Comeny Bank FO Bex 182782 ‘and culo une wl be cradle oof the Gale ecewved Maled or oveagh Colombe, OF 43998-2782 Daymenta mus 10 mest the requrement Balow payment ‘ay not be crested fr vp to five days oF maybe Wu wo investigate the same ees apply tothe icputed amount 3s ating of Overnight (eof ume 6.00 pm. Eastern Time (ET) Giscussed above Aer we fan our avestgaton we wilt you cur ' persona! check, money order vavele's check or cashier's Gecasion AL hal pont sf we Dink you ows an amount and yeu de wat poy we ‘hack Io he nome and adareus on the payment std regular mano ‘may repon you as deinauent 3000 Kellaay Dnve Sura 120, Canton, TX 75008. Include your payment sub, uae the relum envelope provided with your CGREDIT REPORTING We may report information about your accountto Salerment. wrte Your account number on the check and send one rede bureaus Late paymenis sea payments cr other davis on Your [payment wah one payment sub ‘ecounl ety be rectnd in your crt moor ‘Docorrespondence not staple ox cpwth your your eayment paymett othe on stubcashsandOF gMany cerefestesNOTICE OF CREOIT REPORT DISPUTES It you beter information we rebar fo 4 consumer erg agency Is Py By Phone (cutol! ume S 00 m ET) Callus tl reeat‘naceyrate eoby us al Comenty Bank PO Box 182788 Columbus OM 1-800-696-0195 TDOITTY #-£00-695.123216-2789 Please prowde: "Yous name an 3e¢c*nt umber ‘Onnine (cute time 5.00 pm ET) Viet COMENITY NETROAMAKS : ‘Your sdaress and telephone mambee : What information yo pute and why you eleva9 Inacewate : acon a ogy ote vest ofthe cn cert showing the informatan you ae aspunng‘Sond all bankruptcy noncos ana related correspondonco to ComonityBank Bonkruptey Deparment PO Sox 182125 Columous, OMante 215PAYMENTS MARKEQ “PAID IN FULL” 6 antler communi¢abunsregarding disputed amounts tat elude ary chack or other ayantInstrument marked wth paymentin fal" oe alr language must be sent Yo W000 Ketnany Ovve Sua "20 Cavaiton 1X 75006DO NOT USE THE ENCLOSED REIsITTANCE ENVELOPE. We may accept payment sent ie any thet ater what 080g any of eurgris New Information Tile foptional) First Name . MI Last Name - Sou Sec No Street Adaress Apt No RR a PO Box - . cay State dip Cone Foreign Map Code - Home Prone Work Phone ae Enuad Agaress a.PAGE 3 OF 4Tn mee)IMMEDIATE ATTENTION REQUIRED! Your Account is extemaly past due and will be witten off as a bad debt SOON,To avoid this, you must pay the Minimum payment amount shown on this statement at least 4 days pnor to the end of the‘monih in which this statement closed You can tind the Statement closing date in the Summary of account activity onpage 1 of this statement If you are not able to pay the Minimum payment amount, we may still be able to assist you Callus immediately at 1-855-617-8089 (TDD/TTY 1-800-695-1788) to discuss your payment options If written off, the badebt will be reported tothe three major credit bureaus and our Recovery team will determine the appropnate steps, aspermitted and available under applicable law, to protect our interestsIMPORTANT INFORMATION ABOUT LATE FEE CREDITS 2‘We may occasionally provide a credit for the amount, part or all, of @ late fee charged to your account, If we do, we wall‘charge a fee of up to $41 00 for any subsequent late payment In additon, we may reverse the credit and repost the‘charge to your account if you fal to make the minimum payment due on o¢ before the due date in the next bling penodROAMAN'S CARDHOLDERS GET FREE SHIPPING 4x Per Year! ($75 mnininun, radaomable online onl) CSXSSEEE RMsHIPPING 2022 TO USE: SELECT YOUR ROAMAN'S CREDIT CARD AND ADD THIS COUPON IN CHECKOUI, YOU CAN COMBINE WITH OTHER COUPONS 100! SEL DETAILS ON BACK PAGE 1 OF 4 Sr Ace ade unt no = New balance $1 27871 Minimum payment due $60.00 Previous balance $1,310 ‘ayment due date 03/12/2023 Payments -6500 Late payment warning: Other credits 0.00 If wa do not receive your mirwnum payment by 03/12/2023 you Purchases 0 fay have to pay up toa $41 00 late foo Other debits +000 Fees charged +000 ‘Minimum Payment Warning: Ifyou make only the minimum Interest charged +3016 payment for each penod, you will pay more in interest and it wall New balance +34.275.71 take you longer to pay off your balance For example, Past due amount $0.00 you make no additional You will pay off ‘And you wil cchaiges using this card the balance shown | end up paying an ech het $1,49000 and each month you pay. ‘on the statement estimated total Available credit $214.00 in about of Statement closing date 02/15/2023, Only the minimum payment ‘4 years — ” Days in billing ycle 28 [ee Beas a Save 214 For information regard

Case Info

Case No.

(Subscribe to View)

Document Filed Date

August 06, 2024

Case Filing Date

August 06, 2024

County

Parties

  • MCMULLIN, MELISSADefendant

  • MIDLAND CREDIT MANAGEMENT, INC.Plaintiff

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STANLEY vs KIA AMERICA, Motion for Attorney's Fees by SHERRYCVRI2302931INC. STANLEYTentative Ruling:GRANT Plaintiff’s motion and award attorney’s fees in the reduced but reasonable amount of$16,590.00 and award costs and expenses in the requested amount of $917.16, for a total awardof $17,507.16.

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Diamond PEO, LLC vs. Sandra Romero

Aug 20, 2024 |22CECG03098

Re: Diamond PEO, LLC v. Romero, et al. Superior Court Case No. 22CECG03098Hearing Date: August 20, 2024 (Dept. 501)Motion: Default Prove-UpTentative Ruling: To deny without prejudice. If oral argument is timely requested, such argument will be entertained on August21, 2024, at 3:30 p.m.Explanation: Judgment Sought Exceeds Relief Demanded in Complaint Plaintiff’s request for court judgment seeks $154,741.39 and for damages aftercomplaint of $32,024.27. However, the Complaint prays for “damages in excess of$154,741.39…) (Compl., ¶ 25.) “In all default judgments the demand sets a ceiling on recovery.” (Greenup v.Rodman (1986) 42 Cal.3d 822, 824 [including default judgments entered as discoverysanction]; Reedy v. Bussell (2007) 148 Cal.App.4th 1272, 1294 [including default judgmententered as terminating sanction].) Relief that is not demanded in the complaint cannotbe granted by default judgment, even if that relief otherwise would have been proper.(Code Civ. Proc., § 580, subd. (a); Airs Aromatics, LLC v. CBL Data Recovery Technologies,Inc. (2018) 23 Cal.App.5th 1013, 1018 [default judgment for sum in excess of thatdemanded in complaint is void].) Also, a prayer for “damages in excess of $154,741.39 will not support a defaultjudgment for more than that amount, i.e. $154,741.39. (Becker v. S.PV. Const. Co., Inc.(1980) 27 Cal.3d 489, 494-495; Electronic Funds Solutions v. Murphy (2005) 134 Cal.App.4th1161, 1173.) “[I]n Becker v. S.P.V. Construction Co. (1980) 27 Cal.3d 489, 493–494, wherea complaint sought damages ‘ “in excess of $20,000,” ‘ the Supreme Court held that adefault judgment awarding $26,457.50 violated [Code of Civil Procedure] section 580.”(Air Aromatics, LLC v. CBL Data Recovery Technologies, Inc. (2018) 23 Cal.App.5th 1013,1018-1019.) Accordingly, no damages exceeding $154,741.39 may be awarded. Alternatively,plaintiff may amend the complaint to seek the damages that were incurred after thefiling of the complaint; however, this would serve to re-open the default againstdefendants. Settlement Allocations Plaintiff further discloses that it has reached settlement with co-defendant,Claudia Perez, who has since been dismissed from the action, in an amount of $120,000.Plaintiff claims that her settlement amount does not offset any portion of damagesrecoverable from South Bay Safety, Inc. (“South Bay”) and Ms. Romero, since thesettlement agreement between plaintiff and Ms. Perez provides that plaintiff mayallocate the funds from her settlement payment towards any category of damages thatit desires. Plaintiff further indicates that it has allocated these settlement proceedstowards only punitive damages against Ms. Perez. In the ordinary case, “[t]o prevent a double recovery, equity demands credit begiven for payments received on the judgment. Such a balance acts as an offset againstthe judgment.” (Jhaveri v. Teitelbaum (2009) 176 Cal.App.4th 740, 753.) “It is the rule that‘if one joint tortfeasor satisfies a judgment against all joint tortfeasors the judgmentcreditor cannot obtain a double recovery by collecting the same judgment from anotherof the tortfeasors.’ [Citation.]” (Ibid., citations omitted.) Similarly, “[w]here fewer than allof the joint tortfeasors satisfy less than the entire judgment, such satisfaction will not relievethe remaining tortfeasors of their obligation under the judgment. Stated otherwise,‘partial satisfaction has the effect of a discharge pro tanto [for so much].’ ” (Id., p. 755,italics in original.) Plaintiff has not provided any authority showing that its allocation provision in thesettlement is sufficient to deviate from the usual rule for an offset based on Ms. Perez’spartial satisfaction. While parties may contract to whatever terms they see fit, the generalapproach for punitive damages requires that they “bear a reasonable relation to theactual injury suffered. (Gagnon v. Continental Casualty Co. (1989) 211 Cal.App.3d 1598,1602, emphasis added, fn. omitted.) Plaintiff’s allocation provision, which allocates $0 indamages to compensatory damages and $120,000 to punitive damages is at odds withthis principle. Unless plaintiff provides authority to support its contention that an offset isunnecessary where an allocation provision allocates the entirety of a settling party’ssettlement funds to punitive damages, plaintiff’s recovery of compensatory damages islimited to $34,741.39 ($154,741.39 - $120,000). Election of Remedies “Generally speaking, election of remedies is the act of choosing between two ormore concurrent but inconsistent remedies based upon the same state of facts.Ordinarily a plaintiff need not elect, and cannot be compelled to elect betweeninconsistent remedies during the course of trial.” (Wallis v. Superior Court (1984) 160Cal.App.3d 1109, 1114.) “In an action for the breach of an obligation not arising from contract, where it isproven by clear and convincing evidence that the defendant has been guilty ofoppression, fraud, or malice, the plaintiff, in addition to the actual damages, may recoverdamages for the sake of example and by way of punishing the defendant. (Civ. Code,§ 3294 , emphasis added.) Accordingly, as a general rule, “[i]n the absence of anindependent tort, punitive damages may not be awarded for breach of contract ‘evenwhere the defendant's conduct in breaching the contract was wilful, fraudulent, ormalicious.’ ” (Cates Construction, Inc. v. Talbot Partners (1999) 21 Cal.4th 28, 61.) “To date, application of this tortious characterization has been confined for themost part to insurance contracts.” (Wallis v. Superior Court (1984) 160 Cal.App.3d 1109,1116.) However, some courts have “intimated that a non-insurance contract could betortiously breached if it contained characteristics similar to those which allow a finding ofa tortious breach in an insurance contract. [Citation.]” (Wallis v. Superior Court (1984) 160Cal.App.3d 1109, 1118, citations omitted [discussing the bad faith breach of contract].) Alternatively, where it is shown that the “operative facts giving rise to each causeof action are different…” “the cause of action for fraud was not inconsistent with theremedy for breach of contract…” (Baker v. Superior Court (1983) 150 Cal.App.3d 140,145.) Here, plaintiff seeks remedies for its fraud claims (punitive damages) and for itsbreach of contract claims (attorneys’ fees and costs). Ordinarily, plaintiff must elect itsremedies at judgment. However, if plaintiff can show the existence of an independenttort, that the contract could be tortiously breached, or a difference in operative factsgiving rise to each cause of action, then plaintiff may proceed in its request for remediesfor both causes of action. Any future application for default judgment must contain abrief discussing this issue. Punitive Damages In determining the amount necessary to impose the appropriate punitive effect,the court must consider the wealth of the defendant. (Adams v. Murakami (1991) 54Cal.3d 105, 109-116.) The plaintiff bears the burden of presenting evidence of thedefendant's financial condition (Id. at 119-123; see Evid. Code § 500.) This includesshowing not just the defendant's financial assets, but financial liabilities as well. (Baxter v.Peterson (2007) 150 Cal.App.4th 673, 680-681—punitive damages award reversed whenplaintiff failed to present evidence of defendant's financial liabilities.) This burden cannotbe waived by a defendant's failure to object to a plaintiff's inadequate showing,because of the public interest in meaningful judicial oversight of punitive damagesawards. (Tomaselli v. Transamerica Ins. Co. (1994) 25 Cal.App.4th 1269, 1283.) Therefore,this requirement is present even in the context of a default judgment. Here, plaintiff has presented information pertaining to South Bay’s gross sales inthree of its nine business locations as follows: $245,000 for one location in Alhambra, CA,$805,000 for one location in City of Industry, CA, and $806,000 for one location in VanNuys, CA. Counsel’s declaration clarifies that these numbers represent each location’sestimated annual gross sales. (Barsamian Decl., ¶ 5 and Ex. 2.) While plaintiff haspresented some (albeit, a scarce amount of) information pertaining to South Bay’sfinancial condition, no information has been presented for Ms. Romero. Plaintiff onlyindicates that a search regarding Ms. Romero’s bank account information is ongoing.The information pertaining to the cars registered to Ms. Romero’s husband, AndreasCarlos Jacobo is insufficient to shed light on Ms. Romero’s financial condition. There is simply insufficient information to allow the court to make a determinationon an award of punitive damages. It should be noted that this determination is furthercomplicated by plaintiff’s purported allocation of the entirety of Ms. Perez’s settlementtowards punitive damages, as the court’s determination on punitive damages must beara reasonable relation to the actual damages suffered. (Gagnon v. Continental CasualtyCo. (1989) 211 Cal.App.3d 1598, 1602, emphasis added, fn. omitted.) Attorneys’ Fees and Costs Plaintiff seeks $99,935 in attorneys’ fees and $15,698.40 in costs. Counsel indicates that he has spent 304.7 hours on this matter and that his hourlyrate is $350 per hour. He also submits billing statements in support of his declaration. Thus,the attorneys’ fees actually incurred in this case were $106,645. Plaintiff credits $6,710 todefendants in an amount already previously paid. There is no challenge to the reasonableness of counsel’s hourly fee, and the courtdetermines the time spent on the case to be appropriate. However, it does not appearappropriate to shift the attorneys’ fees incurred during settlement negotiations with Ms.Perez to South Bay and Ms. Romero. Consequently, $3,780 is deducted from the feerequest for the time spent on settlement negotiations between plaintiff and Ms. Perez. The costs are sufficiently proven. In sum, plaintiff has proven only $34,741.39 in damages, $96,155 in attorneys, and$15,698.40 in costs. Pursuant to California Rules of Court, rule 3.1312(a), and Code of Civil Proceduresection 1019.5, subdivision (a), no further written order is necessary. The minute orderadopting this tentative ruling will serve as the order of the court and service by the clerkwill constitute notice of the order.Tentative RulingIssued By: DTT on 8/19/2024 . (Judge’s initials) (Date)

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CITIBANK, N.A., A NATIONAL ASSOCIATION VS STEPHAN GRIGORIAN MD, INC., A CALIFORNIA CORPORATION, ET AL.

Aug 23, 2024 |23GDCV01927

Case Number: 23GDCV01927 Hearing Date: August 23, 2024 Dept: D TENTATIVE RULING Calendar: 6 Date: 8/23/2024 Case No. 23 GDCV01927 Trial Date: None Set (Judgment entered) Case Name: Citibank, N.A. v. Stephan Grigorian MD, Inc., et al. MOTIONS TO BE RELIEVED AS COUNSEL (2) Moving Party: The Green Firm, P.C. Name of Client: Defendant Stephan Grigorian MD, Inc. Defendant Stephan Grigorian (No Opposition) RELIEF REQUESTED: Order permitting attorney to be relieved as attorney of record in this action GROUNDS FOR MOTION: Client and attorney have irreconcilable differences regarding the handling of the case. DECLARATION BY MOVING ATTORNEY: Reasons why motion is necessary: ok Address recently confirmed (within last 30 days) By conversation PROPOSED ORDER: Address and phone number of client set forth: ok, last known, should be current Proper warning: ok Future dates filled in: ok ANALYSIS: The paperwork is in order, with the exception that the proposed orders purport to provide the clients last known address and telephone number, when the declarations in support of the motion represent that the currency of the addresses has been confirmed within the last 30 days by conversation. [See Orders, paras. 6; Declarations, paras. (3)(b)(1)(c)]. Counsel will be ordered to modify the orders to check the box before current at paragraphs 6, and delete the selection of last known. Once the orders are modified, the court will sign the orders, and the attorney will be relieved as attorney of record effective upon the filing of proofs of service of the signed orders upon each client. RULING: [No Opposition] UNOPPOSED Motion to be Relieved as Counsel for defendant Stephan Grigorian MD, Inc. is GRANTED. The Court will sign the proposed Order Granting Attorneys Motion to be Relieved as Counsel-Civil with the following modification: (1) in paragraph 6, the Order will indicate that the address and telephone number provided are the clients current, information, not last known. As so modified, the Court will sign the Order and counsel will be relieved effective upon the efiling of the proof of service of the signed order upon the client. UNOPPOSED Motion to be Relieved as Counsel for defendant Stephan Grigorian is GRANTED. The Court will sign the proposed Order Granting Attorneys Motion to be Relieved as Counsel-Civil with the following modification: (1) in paragraph 6, the Order will indicate that the address and telephone number provided are the clients current, information, not last known. As so modified, the Court will sign the Order and counsel will be relieved effective upon the efiling of the proof of service of the signed order upon the client. DEPARTMENT D IS CONTINUING TO CONDUCT AND ENCOURAGE AUDIO OR VIDEO APPEARANCES Please make arrangement in advance if you wish to appear via LACourtConnect by visiting www.lacourt.org to schedule a remote appearance. Please note that LACourtConnect offers free audio and video appearances. However, ADVANCE REGISTRATION IS REQUIRED. If no appearance is set up through LACourtConnect, or no appearance is otherwise made, then the Court will assume the parties are submitting on the tentative.

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Aug 20, 2024 |23CV-0203221

REDDING CITY BALLET VS. CHRISTENSEN, ET AL.Case Number: 23CV-0203221This matter is on calendar for a trial setting conference. The Court notes that there is no Proof of Service ofSummons on file for Defendants Redding Arts Project and Redding City Ballet Theatre. The matter is continuedto Monday, October 21, 2024 at 9:00 a.m. in Department 63 for trial setting. Plaintiff is ordered to get thematter at issue prior to the next hearing. No appearance is necessary on today’s calendar.

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Aug 25, 2024 |24CV-0205226

BLUM, ET AL. VS. FORD MOTOR COMPANY, ET AL.Case Number: 24CV-0205226Tentative Ruling on Motion to Compel Arbitration: This matter is on calendar for hearing onDefendant Crown Motors’ Motion to Compel Arbitration and Stay Action. On August 14, 2024,Plaintiffs filed a Request for Dismissal of Crown Motors from the action. The Clerk entered theDismissal on August 14, 2024. Therefore, Crown Motors is no longer party to the action.Defendant Ford Motors did not join in the Motion to Compel Arbitration. The Motion is moot.Today’s hearing is VACATED. Additionally, a Notice of Removal of Action to Federal Courtwas recently filed on August 21, 2024, suspending this Court’s jurisdiction. This matter istherefore removed from the Court’s control. No other appearances are required by the partiesunless or until this matter is remanded back to state court. Plaintiff is ordered to dismiss this actionwhen the Federal matter resolves. No appearance is necessary on today’s calendar.CREDITORS ADJUSTMENT BUREAU, INC. VS. STRIKE FIRST SNIPERS LLC, ET

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ALPINE BLUE VS. HURLEY, ET AL

Aug 19, 2024 |CVCV21-0198057

ALPINE BLUE VS. HURLEY, ET ALCase Number: CVCV21-0198057This matter is on calendar for review regarding status of service and trial setting. This Court has previouslyrecused in this matter. The matter is continued to Monday, September 30, 2024 at 9:00 a.m. in Department 63for review regarding status of service and trial setting. No appearance is necessary on today’s calendar.

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Michael A. Thompson et al vs. Kamajie Miller et al

Aug 21, 2024 |CU24-05339

CU24-05339Petition to Compel ArbitrationTENTATIVE RULINGPlaintiffs’ petition to compel arbitration is denied without prejudice.Plaintiffs have failed to establish that Defendant has refused to arbitrate. (Mansouri v.Superior Court (2010) 181 Cal.App.4th 633, 641-642.) The court notes that Plaintiffs,not Defendant, initiated this action by filing the complaint for damages and, althoughPlaintiffs claim to have made a demand to arbitrate the matter (Decl. of Thompson, ¶19), they make no attempt to show that Defendant refused this demand however it mayhave been made.

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FAQs

How long to file an answer in CT? ›

In all cases except foreclosure actions, the deadline to file the Answer to file the Answer Complaint (JD-CV-106) is within 30 days of the “Return Date” shown in the box on the top right corner of the Summons. In foreclosure actions, the deadline is within 15 days of the Return Date.

How many dogs can you legally own in Connecticut? ›

Dogs, cats, and similar domestic pets, provided that no more than six (6) animals are kept and no commercial kennel is operated. Ducks, geese, chickens, etc., provided that no more than twelve (12) such animals are kept. No roosters or peaco*cks are allowed.

What is the Connecticut dog tethering law? ›

Connecticut PROHIBITS dog tethering under each of the following circ*mstances: The tether does not allow the dog to walk at least eight feet in any one direction. The tether does not have swivels on both ends to prevent twisting and tangling, unless a person is in the presence of the dog.

Do you have to stop if you hit a dog in CT? ›

Any person who has knowledge of causing, by the operation of a motor vehicle, injury or death to a dog shall at once stop and render such assistance as may be possible, shall immediately report such injury or death to such dog's owner or such owner's representative and shall give his name, address and operator's ...

What is the time limit for a defendant to file an answer? ›

The Defendant's Answer

Under federal rules, defendants generally have 21 days to file an answer after they are served with a complaint; the U.S. government has 60 or 90 days, depending on whether it has waived service.

How long does a plaintiff have to respond to an answer? ›

The parties may stipulate without leave of court to one 15-day extension beyond the 30-day time period prescribed for the response after service of the initial complaint. The court, on its own motion or on the application of a party, may extend or otherwise modify the times provided in (b)-(d).

How long can a dog bark legally in CT? ›

7. Connecticut. Connecticut does not set a duration for how long dogs can bark legally, but a dog owner whose pet is a nuisance to the neighborhood may be fined $60 to $100 in addition to a month in prison for the second offense.

Is it illegal to leave dog in car in CT? ›

Generally, the person may use reasonable force to rescue the animal given the circ*mstances. In Connecticut, depending on the facts and circ*mstances of the case, a person leaving an animal confined in a parked vehicle in adverse weather (e.g., extreme heat or cold), may be charged with animal cruelty.

Is there a leash law for dogs in CT? ›

Know The Canine Leash Laws

The general statutes of Connecticut do not mandate that dogs remain on leashes at all times. However, a dog's owner must not allow their dog to roam on another person's property, state parks, sidewalks or public highways if it is not under their control.

Can I tie my dog in my backyard? ›

You need to check your local laws in this. Most places I've lived, it's illegal to keep a dog on a chain attached to a stationary post, but ok to keep them on a run line. A run line is where you have a line attached to two stationary posts (or trees, or whatever), and the dog is in a leash that's looped over that line.

Is it illegal to not pick up dog poop in Connecticut? ›

It shall be unlawful for any person to allow or permit any dog to defecate upon any sidewalk, public street, median divider within public streets, grass or paved strips between streets and sidewalks, public parks and other public property, unless such person shall remove all feces so deposited by such animal ...

Do dogs need to be registered in CT? ›

Connecticut state law requires all pet owners to license their dogs. All dogs over six months must be licensed. Licensing provides vaccination and sterilization benefits for pets. All dogs must be licensed by June 30th of each year.

Is it legal to bury your dog in CT? ›

To report dead animals found on state roads, contact the CT Department of Transportation. Do not attempt to remove the animal yourself. Small dead pets may be buried in your yard, disposed of by your veterinarian, cremated, buried in a pet cemetery, or secured in a black plastic garbage bag and thrown in the garbage.

What happens if you accidentally hit a dog with your car? ›

Generally, if you have comprehensive coverage, your insurance will pay for any damage to your vehicle. Depending on the circ*mstances of the accident, your liability coverage may cover the dog's vet bills and other expenses if you're found responsible for them.

What happens if your dog bites someone in CT? ›

If a dog bites someone, it must be quarantined for 14 days. An animal control officer or the Department of Agriculture (DOA) commissioner may also order a biting dog restrained or killed.

How long do you have to file a police report in CT? ›

Quick decisions need to be made after the accident so that you are covered legally and financially. In some states, you have 5 days to file a police report and in others 10. Connecticut falls in the latter.

How long do you have to file an Appearance in CT? ›

Court rules state that defendants should file an appearance within 2 days after the Return date. When you file an Appearance, you are agreeing that the Court has authority over you and you are expected to follow the rules and decisions of the Court.

How long do you have to sue someone in CT? ›

Generally, you have two years to file a case but there are circ*mstances where you have much less time to notify the parties that you are intending to sue. For a quasi-governmental agency, you might have notice periods as short as 90 days.

What is the difference between a reply and a response in law? ›

A Response will address the Motion and provide the party's position on the points raised in the Motion. This can include a rebuttal to issues of fact or law raised in the Motion. A Reply will address the points raised in the Response and provide the party's position on the points raised in the Response.

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