So You're Being Sued?

So You're Being Sued? STATE OF NEW MEXICO DISTRICT OF SANTA FE FIRST JUDICIAL DISTRICT COURT MIDLAND CREDIT MANAGEMENT, INC Plaintiff, VS. Defendant(s) CIVIL COMPLAINT (BREACH OF CONTRACT) Plaintiff, through undersigned counsel, alleges as follows: 1. This Court has subject matter and personal jurisdiction. All pertinent acts and omissions giving rise to this lawsuit occurred in this jurisdiction, and/or Defendant(s) are residents of this jurisdiction. 2. The full name and address of Defendant(s) is as follows: 3. The last two (2) digits of the Defendant's social security number, contained in the original creditor's records are as follows: 91 4. By accepting and using an offered extension of credit, Defendant entered into a credit account with Citibank, N.A. Diamond Preferred. Defendant is in default under the terms of the debt. Plaintiff is the successor-in-interest and current owner of the debt. Let Me Tell You Why This Complaint is Funny WANNA KNOW HOW THE COURT HAS JURISDICTION. TRANSLATION: WE ARE IN THE RIGHT COURTHOUSE. NEXT, YOU OPENED CITY BANK CREDIT CARD. FAIR ENOUGH. BUT IMPORTANT SENTENCE. WE ARE THE SUCCESSOR IN INTEREST. TRANSLATION: WE WEREN'T BORROWED FROM, DEBT. LATER, THAT'S GONNA MATTER. 5. The Plaintiff in this action is NOT the original creditor and the name and address under which the original creditor did business with the Defendant is: Citibank, N.A. Sioux Falls, SD 57108 6. The last four (4) digits of the Defendant's account number, used by the original creditor as of the date of default are as follows: 5672 7. The balance due at the time of default is as follows: $3,556.16. 8. The total amount of the debt claimed, is $3,556.16, itemized as follows: Principal amount due: $3,556.16 Other charges, fees and expenses: $0.00 9. The termination of the amount claimed set forth above does not include attorney fees and court costs. 10. The date of last payment made by Defendant is as follows: November 26, 2024. 11. Plaintiff status, consistent with Rule 1-011 NMBRA, that the applicable statute of limitations on this claim has not run. 12. The name and address of the current owner of this debt is as follows: Midland Credit Management, Inc. 1200 W. 7th Street, Suite 100 San Diego, CA 92108 13. PlaintiffIS NOT a collection agency. 14. A copy of the instrument of writing on which the action is founded IS attached as Exhibit A. 15. Plaintiff alleges entitlement to enforce the debt but is not the original creditor. Plaintiff has attached an affidavit showing the chain of title or assignment of the debt. TRY AND PROVE OWNERSHIP. THE ORIGINAL CREDITOR WAS CITY BANK. THE BALANCE IS THREE THOUSAND FIFTY SIX DOLLARS AND SIXTEEN CENTS. NOTICE SOMETHING. NO NO FEES. JUST SAY YOU OWE. THE STATUTE OF LIMITATIONS HASN'T EXPIRED. TRANSLATION PLEASE DON'T DISMISS THIS BECAUSE WE WAITED TOO LONG TO SUE. THEN MY FAVORITE LINE. THE PLAINTIFF IS NOT A COLLECTION AGENCY. INTERESTING CHOICE OF WORDS. APPARENTLY, THEY SAY, WE'VE ATTACHED AN AFFIDAVIT SHOWING THE CHAIN OF TITLE. THAT'S LAWYERS SPEAK FOR TRUST US. WE REALLY OWN THIS DEBT. WHETHER THAT AFFIDAVIT IS ACTUALLY ENOUGH, QUESTION. NOW THEY ASK EVERYTHING. THE MONEY, THE COURT COSTS, INTEREST AFTER JUDGMENT, AND ANY OTHER RELIEF THE COURT THINKS IS FAIR. TRANSLATION WE'LL TAKE WHATEVER YOU GIVE US. Even if this complaint is funny, it's deadly to your Wallet and credit if you don't answer COMPLAINT, REMEMBER? THIS ISN'T PROOF THAT THEY WIN. THEY'RE CLAIMING. AND IF YOU FILE AN ANSWER Sample Templates in Bio TO PROVE EVERY CLAIMS WITH ADMISSIBLE EVIDENCE.