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Answer to Complaint Help - Midland Funding LLC and Johnson Mark LLC

Guest Jtuck003

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Guest Jtuck003

Hi everyone! 

I recently moved to Utah. Before I moved, I was in Illinois and I opened an account with Citibank in 2016. I had a credit balance with them of approximately $400. I was unable to make any payments on this amount and moved to Utah. 

I then received this Summons at my residence in Utah. I'm hoping to make this go away as best I can and am working on a response to their complaint. Would someone be able to assist in the best way to respond to this complaint? Also, is the format important? Are there things I need to include/exclude in my response so that I don't screw myself? 

Would it be worth working consulting with an attorney on this or is that too expensive for the amount in question?

Thanks for your assistance!


1.       Defendant resides in this county and/or signed the contract giving rise to this action in this county. Jurisdiction and venue are proper in this court.


2.       Defendant entered into an agreement with CITIBANK, N.A., opening a credit account ending in XXXXXXXX-XX-XXX.


3.       CITIBANK, N.A. extended credit to Defendant, who agreed to make payments on the credit extended.


4.       Defendant used the credit account to obtain goods, services, and/or money, by which Defendant became indebted to CITIBANK, N.A. in the amount of $1000.


5.       CITIBANK, N.A. assigned the account to Plaintiff.


6.       The amount charged off on the account was $1000. There is now due and owing to the Plaintiff the amount of $1000 less any payments made.


7.       There is an account stated by operation of law, wherein CITIBANK, N.A. billed Defendant for the credit balance, and Defendant did not dispute the balance owing.


8.       The account has not been satisfied and is now due and owing from Defendant.


Demand: Plaintiff requests judgement as follows:

A.      For damages in the amount of $1000, less any payments made;


B.      For costs of court both prejudgment and post-judgement; and


C.      Any other relief as the Court deems just and equitable.

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