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Sued by Midland. All related info needed


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we are being sued by Midland. Need to get enough info to prove that they violated the FDCA. Does anyone have an affidavit signed by Sonja Williams?  We looked up her business address and it's just a road. There is nothing there.  Notary public Angela L Reese, who notorized the affidavit has the same business address.  Please comment,  we may be able to prove that these affidavits are robosigned.  

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1 minute ago, Yana said:

Yes.  

That is the address for Midland.

https://www.google.com/maps/place/16+McLeland+Rd,+St+Cloud,+MN+56303/@45.5636461,-94.2223306,17z/data=!3m1!4b1!4m5!3m4!1s0x52b45ee171c104eb:0x4d91e216d6c98d2c!8m2!3d45.5636461!4d-94.2201419

Look on the left of the page in the link where it says "At this location".

What is stated in your affidavit?

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Hi, 

 

I found your "legal specialist".  Here's her linkedin profile:

https://www.linkedin.com/in/sonjaw?authType=NAME_SEARCH&authToken=W4AO&locale=en_US&srchid=2056393351463953312899&srchindex=26&srchtotal=175&trk=vsrp_people_res_name&trkInfo=VSRPsearchId%3A2056393351463953312899%2CVSRPtargetId%3A115577188%2CVSRPcmpt%3Aprimary%2CVSRPnm%3Atrue%2CauthType%3ANAME_SEARCH

What is the date on your affidavit?  She stopped being a legal specialist in December 2015.  Not sure how much weight that would carry, probably not much at all, but if she moved on from that job title and her name is still being used as a legal specialist, it could point to robo-signing, which Midland is famous for, especially at the St. Cloud, MN office.

Was not able to find any more of her signature to compare yours to.  I was, however, able to find this:

https://www.linkedin.com/in/angela-reese-53966866

that is probably your notary.

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2 hours ago, BV80 said:

That is the address for Midland.

https://www.google.com/maps/place/16+McLeland+Rd,+St+Cloud,+MN+56303/@45.5636461,-94.2223306,17z/data=!3m1!4b1!4m5!3m4!1s0x52b45ee171c104eb:0x4d91e216d6c98d2c!8m2!3d45.5636461!4d-94.2201419

Look on the left of the page in the link where it says "At this location".

What is stated in your affidavit?

The 16 mcleland rd.  

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2 hours ago, BV80 said:

That is the address for Midland.

https://www.google.com/maps/place/16+McLeland+Rd,+St+Cloud,+MN+56303/@45.5636461,-94.2223306,17z/data=!3m1!4b1!4m5!3m4!1s0x52b45ee171c104eb:0x4d91e216d6c98d2c!8m2!3d45.5636461!4d-94.2201419

Look on the left of the page in the link where it says "At this location".

What is stated in your affidavit?

So, they have the same address as the afiant and the notary public? 

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11 minutes ago, kraftykrab said:

Hi, 

 

I found your "legal specialist".  Here's her linkedin profile:

https://www.linkedin.com/in/sonjaw?authType=NAME_SEARCH&authToken=W4AO&locale=en_US&srchid=2056393351463953312899&srchindex=26&srchtotal=175&trk=vsrp_people_res_name&trkInfo=VSRPsearchId%3A2056393351463953312899%2CVSRPtargetId%3A115577188%2CVSRPcmpt%3Aprimary%2CVSRPnm%3Atrue%2CauthType%3ANAME_SEARCH

What is the date on your affidavit?  She stopped being a legal specialist in December 2015.  Not sure how much weight that would carry, probably not much at all, but if she moved on from that job title and her name is still being used as a legal specialist, it could point to robo-signing, which Midland is famous for, especially at the St. Cloud, MN office.

Was not able to find any more of her signature to compare yours to.  I was, however, able to find this:

https://www.linkedin.com/in/angela-reese-53966866

that is probably your notary.

Thank you for your help.  She signed it in November,  2015. In the application of attorney general of TX regarding Midland fraudulent practices there employees testified that they were robo -signing from 300-400 affidavits a day.  The same in the case of attorney general of Minnesota.. we will use it in our response.  

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19 minutes ago, kraftykrab said:

Hi, 

 

I found your "legal specialist".  Here's her linkedin profile:

https://www.linkedin.com/in/sonjaw?authType=NAME_SEARCH&authToken=W4AO&locale=en_US&srchid=2056393351463953312899&srchindex=26&srchtotal=175&trk=vsrp_people_res_name&trkInfo=VSRPsearchId%3A2056393351463953312899%2CVSRPtargetId%3A115577188%2CVSRPcmpt%3Aprimary%2CVSRPnm%3Atrue%2CauthType%3ANAME_SEARCH

What is the date on your affidavit?  She stopped being a legal specialist in December 2015.  Not sure how much weight that would carry, probably not much at all, but if she moved on from that job title and her name is still being used as a legal specialist, it could point to robo-signing, which Midland is famous for, especially at the St. Cloud, MN office.

Was not able to find any more of her signature to compare yours to.  I was, however, able to find this:

https://www.linkedin.com/in/angela-reese-53966866

that is probably your notary.

She works for Encore,  which is the parent of Midland.  So she is an employee of Encore / Midland.  Thank you! 

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If the linkedin profile says employee of Encore but the affidavit says Midland to match the Plaintiff, there's something to go after. Two different entities even if one is the parent.

Seth v. Midland Funding, LLC, 997 NE 2d 1139 - Ind: Court of Appeals 2013- Degel's employment with Midland's servicing agent, MCM, does not establish her personal knowledge of any of the facts pertaining to Midland's complaint against Seth. Indeed, Degel states that she based her affidavit on her "personal knowledge of those account records maintained" by MCM on Midland's behalf.

Midland Funding LLC v. Loreto, 2012 NY Slip Op 50338 - NY: City Court, Civil Court 2012 - In the "certification" Kohls states "I am employed as a Legal Specialist and have access to pertinent account records for Midland Credit Management, Inc. ("MCM") servicer of this account on behalf of plaintiff." It should be noted that Midland Credit Management, Inc., is apparently a separate entity from the two Midland's listed in the caption. It is registered with the New York State Secretary of State, Division of Corporations since May 8, 2003 as a Kansas corporation with its principal executive office at the same place as plaintiff's San Diego, California address. Interestingly, the acknowledgment of Kohls' signature states that "Midland Credit Management, Inc.," is a "corporation under the laws of the State of Minnesota" and not "Kansas" as it is registered in New York.

Kohls states that she is making her statements "based upon personal knowledge of those account records maintained on plaintiff's behalf." It is unclear whether she is speaking about her knowledge of plaintiff's records or MCM's records in regard to defendant's account. It is also unclear whether it is the records of the alleged account owner Midland Funding LLC or its New York counterpart Midland Funding of Delaware LLC or of MCM. If they are the records of either of the two Midland Funding businesses, then Ms. Kohls lacks the personal knowledge as to their content as she is not an employee of either of those entities. It would also make it impossible for her to have the necessary knowledge to verify the accuracy of the documents provided by Citibank as they would then be Citibank's records. If they are MCM's records, then she is seeking to verify the accuracy of documents of an entity other than the plaintiff.

 

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