COMPLAINT July 23, 2024 (2024)

On July 23, 2024 aComplaint,Petitionwas filedinvolving a dispute betweenAccelerated Inventory Management, Llc,andThomas Raucci,for C40 - Contracts - Collectionsin the District Court of New Haven County.

 
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 RETURN DATE: July 30, 2024 SUPERIOR COURT ACCELERATED INVENTORY JUDICIAL DISTRICT MANAGEMENT, LLC OF ANSONIA- MILFORD VS. AT MILFORD THOMAS RAUCCI June 19, 2024 COMPLAINTCOUNT ONE - Breach of Contract 1 Atall relevant times. Plaintiff, Accelerated Inventory Management, LLC (“Plaintiff”) was and is a Limited Liability Company organized and existing under the laws of Texas the assignee of the original creditor, WebBank. A true and correct copy of the Bill of Sale is attached to this complaint as Exhibit "A". 2. Upon information and belief, Defendant Thomas Raucci is an individual residing in Orange in the state of Connecticut. 3 The Defendant applied for a Loan Agreement issued by WebBank. 4 As the applicant for a Loan Agreement issued by WebBank, the Defendant provided personal financial disclosures required by the Plaintiff's application procedure. 5 WebBank and Defendant on or about November 24, 2017 entered into an installment loan agreement in the amount $21,000.00, 6 The Account number issued ended in 7125. 7 The Account was opened by the Defendant on November 24, 2017. 8 The last payment on the Account was made on July 24, 2019, This is an attempt to collect a debt. Any information obtained will be used for that purpose. This is acommunication from a debt collector. 17942 - Thomas Raucci9 Use of the Account binds the Defendant to the terms and conditions set forth in theWebBank Agreement (“Agreement”). A true and correct copy of the Agreement is attached.to this complaint as Exhibit "B".10. By use of said Account, Defendant became indebted in the sum of $11,227.01. A trueandcorrect copy of an Account Statement is attached to this complaint as Exhibit "C”.Il. The Defendant defaulted in making payments pursuant to the Agreement.12, That the Plaintiff made demand for payment of the installment loan agreement.13, Asaresult of Defendant's default, Plaintiff accelerated all payments thereafter in accordancewith the terms of the installment loan agreement.14, That there is now due and owing from the Defendant to Plaintiff the sum of $11,227.01.This is an attempt to collect a debt. Any information obtained will be used for that purpose. This is a communication from a debt collector. 17942 - Thomas RaucciCOUNT TWO - Account Stated1-14 Paragraphs | through 14 of Count One are re-alleged and incorporated as Paragraphs 1-14 of this Second Count. 15. The Plaintiff regularly generated account statements reflecting an unpaid balance and mailedthem to the Defendant; said statements were neither disputed nor retumed. COUNT THREE — Unjust Enrichment 1-14 Paragraphs | through 14 of Count One are re-alleged and incorporated as Paragraphs 1-14 of this Third Count. 15. The Plaintiff provided the Defendant with a revolving credit line requested by the Defendant’s application and thereby relied upon the Defendant's promise to pay. 16. The Defendant used the credit extended by the Plaintiff which resulted in a balance due to the Plaintiffin the amount of $11,227.01. 17. The Defendant has unjustly neglected and refused to pay the sum of $11,227.01despite demand, although the Defendant has received the benefit of the extended credit. 18. The Plaintiff relied on the Defendant's promise to pay for the extended credit to itsdetriment. 19. As a result of the aforementioned, the Defendant has been unjustly enriched and thePlaintiff has suffered monetary damages,WHEREFORE, the Plaintiff Claims: 1 Monetary damages.2. Costs of action.3 An order on the Defendant for reasonable weekly payments out of sums earned or to be earned, This is an attempt to collect a debt. Any information obtained will be used for that purpose. This is a communication from a debt collector. 17942 - Thomas RaucciThe amount in demand is greater than TWO THOUSAND FIVE HUNDRED AND 00/100 ($2,500.00).5 The remedy sought is based upon an express or implied promise to pay a definite sum.This is an attempt to collect a debt. Any information obtained will be used for that purpose. This is a communication from a debt collector. 17942 - Thomas Raucci1, Adam R. Kravet, Esq., the subscribing authority, hereby certify that 1 have personal knowledge as to the financial responsibility of the Plaintiff and deem it sufficient to pay the costs in this action. Of this Writ, with your doings thereon, make due service and return.June 19, 2024 LEOPOLD & ASSOCIATES, PLLC haf es By dam R. t, Esq. 80 Busines¢’ ark Dr., Ste 110 Armonk, XY 10504914-219-5787 Attorneys for Plaintiff Accelerated Inventory Management, LLC This is an attempt to collect a debt. Any information obtained will be used for that purpose. This is acommunication from a debt collector. 17942 - Thomas RaucciEXHIBIT AThis is an attempt to collect a debt. Any information obtained will be used for that purpose. This is a communication from a debt collector. 17942 - Thomas RaucciDocuSign Envelope ID: 855E724F-4D75-453F-BA84-5A2460627631 BILL OF SALE LendingClub Corporation, a Delaware corporation (“LendingClub”) and Accelerated Inventory Management, LLC, a Delaware limited liability company (“Buyer”) executed an Account Purchase Agreement — Forward Flow dated as of Qctaber 21, 2019 (“Agreement”). The terms of the Agreement will govern this Bill of Sale and any capitalized but undefined terms herein will have the meanings given to such terms in the Agreement. For value received and in further consideration of the mutual covenants and conditions set forth in the Agreement, the Investors referenced in the data file named Lot20- 102_LendingClub_FinalData.xlsx hereby transfer(s), sell(s), conveys(s), grant(s), and deliver(s) to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Accounts as set forth in the Account Schedule attached hereto as Exhibit I delivered by Seller to Buyer on the Closing Date, and as further described in the Agreement. Pursuant to the Agreement, on January 24, 2020, the Closing Date, each Investor will sell (or cause to be sold) a pool of Accounts held by such Investors and described in the Account Schedule attached to this Bill of Sale; LendingClub represents and warrants that each of the undersigned Investors (other than LendingClub, where LendingClub is the Investor) has cxccuted a limited power of attorney between such Investor and LendingClub wherein a designated power is for LendingClub to act as attorney-in-fact for such Investor and to execute this Bill of Sale on behalf of such Investor and take any action and execute any instruments or documents that LendingClub may deem reasonably necessary or advisable in connection with the transfers contemplated thereby. Lot Number: 20-102 Total Unpaid Balance: a Number of Accounts: 2,805 DATED: January 24, 2020 SELLER: LC Trust I By: LENDINGCLUB CORPORATION, as Administrator ‘DocuSigned by: By: Browdon Pace Name (prin) Brendon! Page Title: General Counsel SELL odeQdipgClub Corporation | Brandon Pace Name (prnily” randon ATCT Pace Title: General CounselDocuSign Envelope ID: 855E724F-4D75-453F-BA84-5A2460627631 SELLER: 590 Consumer Lending Corp, LLC By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSigned By: bri he Pate Name ¢prittt@BFaniatin Pace Title: General Counsel SELLER: ACL Consumer Loan Trust III By: LENDINGS cheAB CORPORATION, as attorney-in-fact B or we Pate Name (printf BfndGn' Pace Title: General Counsel SELLER: ACL Consumer Loan Trust IV By:LI WNGHebhJB CORPORATION, as attorney-in-fact Brandon Pace Nene GRTEBEBrandon Pace Title: General ome SELLER: ACL Consumer Loan Trust VI By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSigned by: andon oy _{ brand Pate Name (brint):cBeandow Pace Title: General Counsel SELLER: Arcadia Receivables Credit Trust 2017-1 By: LEI [erm iB: CORPORATION, as attorney-in-fact Brondow Paw By: Name (print): ‘Brandon Pace Title: General Counsel SELLER: ARCADIA RECEIVABLES CREDIT TRUST 2018-1 By: L [ened 1 ‘YB CORPORATION, an db, fate as attorney-in-fact By: OCF EGAGEA10C417. Name (print): Brandon Pace Title: General CounselDocuSign Envelope ID: 855E724F-4D75-453F-BA84-5A2460627631 SELLER: Banco Popular de Puerto Rico By: LENRINGCI.UB CORPORATION, as attorney-in-fact py. | Drandon Pace Name (prifit}' Britton Pace Title: General Counsel SELLER: Banco Popular North America By: L fi BB CORPORATION, as attorney-in-fact Brovdow Paw By: Name (print): Brandon Pace Title: General Counsel SELLER: Bank of Bennington By: LEN} INGC. jocusignec UBVE CORPORATION, as attorney-in-fact By: Brandon, Pate Name (prititf@ssraitdidh Pace Title: General Counsel SELLER: BankNewport By: L IRINGGLJJB CORPORATION, as attorney-in-fact | Brandon Pace Name (panyBi ran ATG: doit Pace Title: General Counsel SELLER: BULLION INVESTMENTS LIMITED PARTNERSHIP By: LENDINGCLUB CORPORATION, as attorney-in-fact ‘DocuSigned by: By: Brondow Pate Name (printpBrandon Pace Title: General Counsel SELLER: Carter Bank & Trust (tm By: L GGdebJB CORPORATION, as attorney-in-fact B Brandon Pate Name (paige rain Ea10G417 jon’ Pace Title: General CounselDocuSign Envelope ID: 855E724F-4D75-453F-BA84-5A2460627631 SELLER: CONGRESSIONAL BANK By: LE) Gifelr4J.B CORPORATION, as attorney-in-fact B | Brandow Pace Name (prin Bh randon ATO 7 Pace Title: General Counsel SELLER: Consumer Lending Receivables Trust 2016-A Does a signe By: LENDIN CLI ad UB CORPORATION, as attorney-in-fact By: Brondow Pate Name (brit "Bsa Pace Title: General Counsel SELLER: Consumer Lending Receivables Trust 2016-B By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSigned by: By: Brandon Pace Name (print}rBxendenPace Title: General Counsel SELLER: Consumer Loan Underlying Bond (Club) Certificate Issuer Trust I By: L ENGEELWB CORPORATION, as attorney-in-fact Brandon Pater By: E seatocas Name (print): Brandon Pace Title: General Counsel SELLER: Consumer Loan Underlying Bond (Club) Certificate Issuer Trust I Series 2019-SLCT1 G Hi C) UB CORPORATION, as attorney-in-fact By: LENDINacu! igne By: Brandow Par Name (prift)Ssraifdoi Pace Title: General Counsel SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2017-NP1 By: LE) GfcduLJB CORPORATION, as attorney-in-fact Brovdon Pace Name (pritt) Brandon Pace Title: General CounselDocuSign Envelope ID: 855E724F-4D75-453F-BA84-5A2460627631 SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2017-NP2 By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSigned by: By: Brandon Pau Name (prntenBratieent Pace Title: General Counsel SELLER: Consumer Loan Underlying Bond (CLUB) Grantor Trust 2017-P1 By: LENDINGGI,UB. CORPORATION, as attorney-in-fact B Drondow Paw Name (print Brandon Pace Title: General Counsel SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2017-P2 By: LENDINGCIdB. CORPORATION, as attorney-in-fact B Brovdow Paw Name (print) BERGGH Pace Title: General Counsel SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2018-NP1 By: LENDINGCLUB CORPORATION, as attorney-in-fact ‘DocuSigned by: By: Brandon Pau Name (pringjeBremetont Pace Title: General Counsel SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2018-P1 G By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSigned by: By: Brow, a Pace Name (pkint)scBeandoo. Pace Title: General Counsel SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2018-P2 By: LENDIN gnC) Je UB CORPORATION, as attorney-in-fact py, | Crandon Pau Name (pH HVindon Pace Title: General CounselDocuSign Envelope ID: 855E724F-4D75-453F-BA84-5A2460627631 SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2018-P3 By: LEI iGighdall3. CORPORATION, as attorney-in-fact By: bri we Pate Name (print): Brandon’ Pace Title: General Counsel SELLER: CONSUMER UNDERLYING BOND SECURITIZATION, SERIES 2018-1 GRANTOR TRUST By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSigned by: By: (¢Brow, dow. Powe Name int}oBeandon Pace Title: General Counsel SELLER: COPPER CANYON TRUST By: LENDINGCLUB CORPORATION, as attorney-in-fact ‘DocuSigned by: py| Brandon Pace Na PuitEPBIatidon Pace Title: General Counsel SELLER: Crescent Sky Consumer Lending Fund LP By: LENDINGCLYB CORPORATION, as attorney-in-fact py, | Ovando Pau Name prints’ Brandon Pace Title: General Counsel SELLER: Crescent Sky Lending Facility -1 LLC By: LENDINGCLUB CORPORATION, as attorney-in-fact ‘DocuSigned by: By: Brandon Pate Name \seB¥amdon.Pace Title: General Counsel SELLER: CresCom Bank By: LENDINjooug (igre CL 4¥B CORPORATION, as attorney-in-fact B Brandow Par Name (Drip BERIUGH Pace Title: General CounselDocuSign Envelope ID: 855E724F-4D75-453F-BA84-5A2460627631 SELLER: Denali State Bank By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSigned by: By: Brandon Pate Name (printeBrandon Pace Title: General Counsel SELLER: DIRECT LENDING INVESTMENT DLS By: 1,UB CORPORATION, as attorney-in-fact | Brandon Pace TOC Name (prin): ran don Pace Title: General Counsel SELLER: DL INVESTMENT SARL, ACTING ON BEHALF COMPARTMENT MOONSTONE 2 By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSianed by: By: br w Pa Name ¥prittye3raridon Pace Title: General Counsel SELLER: DL Investment Sarl, Compartment Moonstone | By: LENDING iCignHi UB CORPORATION, as attorney-in-fact Prondow Pace Name (pri BEANUOH Pace Title: General Counsel SELLER: Elkhorn Valley Bank & Trust STD By: LENDING C) LUB CORPORATION, as attorney-in-fact igie B Brovdow Paw Name (pri) "BEaeiol Pace Title: General Counsel SELLER: First Bank By: LEND) INGC! jocuSignec UB CORPORATION, as attorney-in-fact By: or we Pate Name {pritit*raiididh Pace Title: General CounselDocuSign Envelope ID: 855E724F-4D75-453F-BA84-5A2460627631 SELLER: First Trust Marketplace Lending Partners. LP By: LEI B CORPORATION, as attorney-in-fact By: Brondon Par SEAT Name (print). ‘Brandon Pace Title: General Counsel SELLER: FRANKLIN INVESTORS SECURITIES TRUST - FRANKLIN LOW DURATION TOTAL RETURN FUND By: L Cifci4JB CORPORATION, as attorney-in-fact Brandon Powe B Name (print): Brandon Pace Title: General Counsel SELLER: GLC II Trust 2014-1 By: LENDINGCLUB CORPORATION, as attorney-in-fact ‘DocuSigned by: ay _{ tr dow Paw Name (prieepsBeandrr Pace Title: General Counsel SELLER: GOLDEN CAPS TRUST By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSigned or oa AGN Pace Title: General Counsel SELLER: HALMAN-ALDUBI I2P1ST, LIMITED PARTNERSHIP By: L WNGGCIJB CORPORATION, as attorney-in-fact Brondow Pour Name (print); Brandon Pace Title: General Counsel SELLER: HCG Consumer Credit II Trust By: L INGeLB CORPORATION, as attorney-in-fact B Brandon Pau. Name (print) "Brandon Pace Title: General CounselDocuSign Envelope ID: 855E724F-4D75-453F-BA84-5A2460627631 SELLER: HCG CONSUMER CREDIT IV, LLC By: LENDINjoeGs igne C! LUBye CORPORATION, as attorney-in-fact B Brandon Paw Name (pri BRaeOH Pace Title: General Counsel SELLER: HCG CONSUMER CREDIT V TRUST By: LENRINGCGIJB CORPORATION, as attorney-in-fact | Brandow Paw Name Gan “TTOCATT. ran id lon Pace Title: General Counsel SELLER: Heritage Bank NA By: LE) SrdaLJB CORPORATION, as attorney-in-fact B Brandon Pate BEA TOGAT Name (print): ‘Bi randon Pace Title: General Counsel SELLER: IBI Consumer Credit, LP By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSigned by: By: Brandon Paw Name (priipsBtenidin Pace Title: General Counsel SELLER: ILA CAPITAL TRUST By: LENDINGCLUB DocuSigned by: CORPORATION, as attorney-in-fact By: or we Pate Name (prittt/S8raindidh: Pace Title: General Counsel SELLER: INCLINE FUND II TRUST By: LENDINGCLUB DocuSigned By: CORPORATION, as attorney-in-fact By: | Drandow Pace Name (parte Brandon Pace Title: General CounselDocuSign Envelope ID: 855E724F-4D75-453F-BA84-5A2460627631 SELLER: Kearny Bank By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSigr Brow, i Pate ane Pace Title: General Counsel SELLER: KiWi Private Credit Fund LP By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSigned by: By: bri we Pate Name (pring sBranideny Pace Title: General Counsel SELLER: KOOKMIN BANK AS TRUSTEE OF HANWHA CONSUMER CREDIT PRIVATE FUND 1 By: LENRISGGLUB CORPORATION, as attorney-in-fact Brandon Paw Non GEOFEED Pace Title: General Counsel SELLER: LENDINGCLUB ISSUANCE GRANTOR TRUST, SERIES 2016-NP2 By: LENDINGGS,UB CORPORATION, as attorney-in-fact Crandon Paw NaS EP ERon Pace Title: General Counsel SELLER: MountainOne Bank By: LENDINGCL.UB CORPORATION, as attorney-in-fact Brondow Powe Naa Tints BAMAGN Pace Title: General Counsel SELLER: MPLI CAPITAL HOLDINGS By: Givey:B CORPORATION, as attorney-in-fact Brandon Powe By: Name (print): ‘Brandon Pace Title: General CounselDocuSign Envelope ID: 855E724F-4D75-453F-BA84-5A2460627631 SELLER: Murray Hill Grantor Trust 2016-LC1 By: ,UB CORPORATION, as attorney-in-fact By. Brandon Pau Name (print): Brandon Pace Title: General Counsel SELLER: MW-EW Financing Trust I By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSigned by: py:| Crandon Pace Namit (piiresBrattdon Pace Title: General Counsel SELLER: NBSF 2018-1 By: LENDINGCLUB CORPORATION, as attorney-in-fact DocuSigned by: By: Brandow Pate Naine (print}Brandon Pace Title: General Counsel SELLER: NBSF 2018-2,acting solely with respect to NBSF 2018-2, SERIES 2018-1 By: LENDINGCLUB CORPORATION, as attorney-in-fact by. Brovdow 6 DocuSigned by: Paw Name-(pringseBrandon Pace Title: General Counsel SELLER: NBT Bank, National Association By: LENRINGCILYB CORPORATION, as attorney-in-fact i Brondow Pate Name (pri Brandon Pace Title: General Counsel SELLER: Nelnet Unsecured Personal Loan Warehouse Trust By: LENDINGCLUB DocuSigned by: CORPORATION, as attorney-in-fact py, | Brandon Pace Name ¢priftBiatdGn Pace Title: General CounselDocuSign Envelope ID: 855E724F-4D75-453F-BA84-5A2460627631 SELLER: Newburyport Five Cents Savings Bank By: L SNGLIJB CORPORATION, as attorney-in-fact or we Pate By: Name (print): Brandon Pace Title: General Counsel SELLER: North Easton Savings Bank By: LENRIN GCLUB CORPORATION, as attorney-in-fact Brandon Pate Name (pritif}“Btatidon Pace Title: General Counsel SELLER: PAGAYA AI DEBT SELECTION GRANTOR TRUST 2019-1 By: LENDINGCLUB CORPORATION, as attorney-in-fact Brandon Par NAS GH SBon Pace Title: General Counsel SELLER: PAGAYA AI DEBT SELECTION GRANTOR TRUST 2019-3 By: LENDINGCLUB ‘Docusignedby: CORPORATION, as attorney-in-fact Brandan. Pau 

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