On April 22, 2013 a
Motion,Ex Parte
was filed
involving a dispute between
Grow Financial Federal Credit Union,
and
Salas, Jeff A,
Salas, Karina A,
for CONTRACTS AND INDEBTEDNESS - COUNTY
in the District Court of Pinellas County.
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IN THE COUNTY COURT IN AND FOR PINELPAS:GRIERNY Filed 09/10/2013 09:57:08 AM ET
STATE OF FLORIDA, CIVIL DIVISION
GROW FINANCIAL FEDERAL
CREDIT UNION FKA MACDILL
FEDERAL CREDIT UNION
Plaintiff,
vs. CASE NO: 13-003205-CO
JEFF A. SALAS AKA JEFF SALAS
AND KARINA A. SALAS AKA KARINA SALAS
Defendant(s)
/
MOTION FOR SUMMARY JUDGMENT.
Plaintiff, by and through its undersigned attorneys, pursuant to Rule 1.510 of the Florida Rules of Civil
Procedure, moves this Court for the entry of a Summary Final Judgment in its favor on the grounds that there is no
genuine issue as to any material fact and that Plaintiff is entitled to Judgment as a matter of law. Plaintiff attaches to this
Motion a copy of an Affidavit as to indebtedness setting forth the amount due to Plaintiff, the original of which has been
previously filed with the Court. The substantial matters of law to be argued are as follows:
1, That Defendant(s) executed and delivered to Plaintiff an application for a credit card account.
2. That Defendant(s) have defaulted in payment pursuant to the terms and conditions of the credit card
agreement.
3. That Defendant(s) are bound by law to pay the sums set forth in Plaintiff's Complaint.
WHEREFORE, Plaintiff moves this Honorable Court for the entry of a Summary Judgment in the amount set
forth in Plaintiff's Complaint, together with interest and Court costs and for such further relief as the Court deems just
and appropriate in the circumstances.
Sasenter I oe CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail or Email
2013, to JEFF A. SALAS AKA JEFF SALAS, 3520 32nd Ave N. Apt. 109, Saint Petersburg FL
3713 -2430and KARINA A. SALAS AKA KARINA SALAS, N 3520 32nd Ave N. Apt, 109, Saint Petersburg FL
33713-2430.
J MY PA.
P.O. Box 800
Tampa, FL 33601
(813) 229-0900/Ext. 5240
jmouch@kasslaw.com
Attomeys for Plaintiff
Jeffrey J, Mouch-814768
9:57:08 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY ***
The Primary e-mail address for electronic service of
all pleadings in this case under Rule 2.516 is as
follows:
CollectionsService@kasslaw.com
J1300298-EC
P906
ce: judicial assistant
{NM ET
CAVA EA A
tO
*#*ELECTRONICALLY FILED 9/IN THE COUNTY COURT IN AND FOR PINELLAS COUNTY,
STATE OF FLORIDA, CIVIL DIVISION
GROW FINANCIAL FEDERAL
CREDIT UNION FKA MACDILL
FEDERAL CREDIT UNION
Plaintiff,
vs. case vo: | 5-903 2057 co
JEFF A. SALAS AKA JEFF SALAS
AND KARINA A. SALAS AKA KARINA SALAS
Defendant(s)
AFFIDAVIT IN PROOF OF CLAIM AND NON-MILITARY SERVICE
COUNTY OF HILLSBOROUGH
STATE OF FLORIDA
BEFORE ME, the undersigned authority, duly authorized to take acknowledgments and administer oaths, personally
appeared Jenny Tumer, who, after being duly swarm upon oath, and upon personal knowledge of the facts herein, deposes
and 3
1. That he/she fs the Collections Supervisor for the Plaintiff, GROW FINANCIAL FEDERAL CREDIT UNION FKA
MACDILL FEDERAL CREDIT UNION, and makes all statements contained herein from matters which are within his/her
personal knowledge.
2. That the Defendant(s), JEFF A. SALAS AKA JEFF SALAS and KARINA A. SALAS AKA KARINA SALAS,
is/are indebted to the Plaintiff in the principal sum of $8,300.85 .
3. That interest in the sum of $213.42 has accrued through April 15, 2013, and will continue to accrue at the
fate of $0.00 per diem.
4. That these amounts are a just demand and are actually due.
5. That attached hereto and made a part hereof |s a true copy or original of the contract or account upon which
this suit is based, or that the attachments to Plaintiff's complaint are true and correct copies of the originals,
. That this action has been brought in the proper venue in accordance with Chapter 47 of the Florida Statutes.
7, The Defendant(s) is/are not In any branch of the United States Military Services or its allies.
8. That the documents attached to this Affidavit were prepared by a person with knowledge, or fram Information
transmitted by a person with knowledge, at or near the time of the event that the exhibits document.
9. That the documents attached to this Affidavit were prepared and kept in the course of regularly conducted
business activity.
10. That it is the regular business practice of Plaintiff 10 prepare the attached documents.
Jue
ACEJANT
SWORN TO AND SUBSCRIBED before me on April 15, 2013, by Jenny Tumer, who is personally known to me,
and who took an oath.gules. We
NoraRy PUBLIC
J1300298/EC
Pai?
*J1300298*
*AFFIDAVIT IN PROOF OF CLAIM*
*EOD*
Document Filed Date
September 10, 2013
Case Filing Date
April 22, 2013
Category
CONTRACTS AND INDEBTEDNESS - COUNTY
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IN THE COUNTY COURT IN AND FOR PINELPAS:GRIERNY Filed 09/10/2013 09:57:08 AM ET STATE OF FLORIDA, CIVIL DIVISION GROW FINANCIAL FEDERAL CREDIT UNION FKA MACDILL FEDERAL CREDIT UNION Plaintiff, vs. CASE NO: 13-003205-CO JEFF A. SALAS AKA JEFF SALAS AND KARINA A. SALAS AKA KARINA SALAS Defendant(s) / MOTION FOR SUMMARY JUDGMENT. Plaintiff, by and through its undersigned attorneys, pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, moves this Court for the entry of a Summary Final Judgment in its favor on the grounds that there is no genuine issue as to any material fact and that Plaintiff is entitled to Judgment as a matter of law. Plaintiff attaches to this Motion a copy of an Affidavit as to indebtedness setting forth the amount due to Plaintiff, the original of which has been previously filed with the Court. The substantial matters of law to be argued are as follows: 1, That Defendant(s) executed and delivered to Plaintiff an application for a credit card account. 2. That Defendant(s) have defaulted in payment pursuant to the terms and conditions of the credit card agreement. 3. That Defendant(s) are bound by law to pay the sums set forth in Plaintiff's Complaint. WHEREFORE, Plaintiff moves this Honorable Court for the entry of a Summary Judgment in the amount set forth in Plaintiff's Complaint, together with interest and Court costs and for such further relief as the Court deems just and appropriate in the circumstances. Sasenter I oe CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail or Email 2013, to JEFF A. SALAS AKA JEFF SALAS, 3520 32nd Ave N. Apt. 109, Saint Petersburg FL 3713 -2430and KARINA A. SALAS AKA KARINA SALAS, N 3520 32nd Ave N. Apt, 109, Saint Petersburg FL 33713-2430. J MY PA. P.O. Box 800 Tampa, FL 33601 (813) 229-0900/Ext. 5240 jmouch@kasslaw.com Attomeys for Plaintiff Jeffrey J, Mouch-814768 9:57:08 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY *** The Primary e-mail address for electronic service of all pleadings in this case under Rule 2.516 is as follows: CollectionsService@kasslaw.com J1300298-EC P906 ce: judicial assistant {NM ET CAVA EA A tO *#*ELECTRONICALLY FILED 9/IN THE COUNTY COURT IN AND FOR PINELLAS COUNTY, STATE OF FLORIDA, CIVIL DIVISION GROW FINANCIAL FEDERAL CREDIT UNION FKA MACDILL FEDERAL CREDIT UNION Plaintiff, vs. case vo: | 5-903 2057 co JEFF A. SALAS AKA JEFF SALAS AND KARINA A. SALAS AKA KARINA SALAS Defendant(s) AFFIDAVIT IN PROOF OF CLAIM AND NON-MILITARY SERVICE COUNTY OF HILLSBOROUGH STATE OF FLORIDA BEFORE ME, the undersigned authority, duly authorized to take acknowledgments and administer oaths, personally appeared Jenny Tumer, who, after being duly swarm upon oath, and upon personal knowledge of the facts herein, deposes and 3 1. That he/she fs the Collections Supervisor for the Plaintiff, GROW FINANCIAL FEDERAL CREDIT UNION FKA MACDILL FEDERAL CREDIT UNION, and makes all statements contained herein from matters which are within his/her personal knowledge. 2. That the Defendant(s), JEFF A. SALAS AKA JEFF SALAS and KARINA A. SALAS AKA KARINA SALAS, is/are indebted to the Plaintiff in the principal sum of $8,300.85 . 3. That interest in the sum of $213.42 has accrued through April 15, 2013, and will continue to accrue at the fate of $0.00 per diem. 4. That these amounts are a just demand and are actually due. 5. That attached hereto and made a part hereof |s a true copy or original of the contract or account upon which this suit is based, or that the attachments to Plaintiff's complaint are true and correct copies of the originals, . That this action has been brought in the proper venue in accordance with Chapter 47 of the Florida Statutes. 7, The Defendant(s) is/are not In any branch of the United States Military Services or its allies. 8. That the documents attached to this Affidavit were prepared by a person with knowledge, or fram Information transmitted by a person with knowledge, at or near the time of the event that the exhibits document. 9. That the documents attached to this Affidavit were prepared and kept in the course of regularly conducted business activity. 10. That it is the regular business practice of Plaintiff 10 prepare the attached documents. Jue ACEJANT SWORN TO AND SUBSCRIBED before me on April 15, 2013, by Jenny Tumer, who is personally known to me, and who took an oath.gules. We NoraRy PUBLIC J1300298/EC Pai? *J1300298* *AFFIDAVIT IN PROOF OF CLAIM* *EOD*