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Help needed... Being sue by a JDB

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I need help filing an answer to the below Bill of particular in Virginia, they also sent along with Bill of particular the following items:

_ Bill of sale (From chase to Turtle Creek Assets, Ltd)

_ Bill of sale (Turtle Creek Asset to current Forward properties International, LLC) and then selling the Credit Card Account to the Current JDB which is taking me to court.

NONE of the bill of sale reflect the account Number in question.

_ Statement of Account from the JDB. (Exhibit "A")

_ Chase Bank credit card statement and information about the account (Exhibit "B")

_ A notarized affidavit by someone claiming to have knowledge of the account (BS) (Exhibit "C")

all suggestion are welcome..... Please help me defeat this JDB!




Xxxxx,xxx. Assignee of Chase Bank USA, NA.



Trial Date: December 5, 2011





COMES NOW the Plaintiff, XXXXXXXXXXXX. Assignee of Chase Bank USA, NA., and for its Bill of Particulars does state the following:

1. That Chase Bank USA, NA. assignor of plaintiff, did provide credit services to the defendant, My Name goes here, requested by the defendant on or about October 17, 2002, via account ############, and pursuant to the Statement of account marked as Exhibit “A” and heretofore attached and made a part thereof.

2. That said credit services were accepted by the defendant as evidenced by the activation, use, and payment of said credit card account.

3. That Chase Bank USA, NA. provided said services to defendant and defendant accepted these service without complaint.

4. That the last payment on the above account was received on or about April 17, 2009.

5. That monthly statement were sent to the defendant at the following Address: Somewhere in Virginia and are attached hereto as Exhibit “B”.

6. That the above account was charge off for non-payment on or about January 31, 2008.

7. That the Plaintiff, XXXXXXXXXXXX, purchased said account on or about December 16, 2010.

8. That Plaintiff had made demand for payment to the Defendant and as of this date, there is a balance owing $3231.64 Pursuant to the affidavit marked as Exhibit “C” heretofore attached and a part of thereof.

9. That all demands for payment of the balance have been ignored and /or refused.

10. That the Plaintiff reserved the right to supplement their bill of particulars WHEREFORE, the Plaintiff ask for judgment in the amount of $3231.64 plus interest at the 6% judgment rate for the date of judgment, and court cost expended.

By: Counsel for the plaintiff

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