Hackler v. Tolteca Enterprises, Inc. D/b/a Phoenix Recovery Group

Western District of Texas, txwd-5:2018-cv-00911


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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION SADIE HACKLER, on behalf of herself § and all others similarly situated, § § Plaintiff, § § v. § Case No. 5:18-CV-00911-XR § TOLTEGA ENTERPRISES, INC. d/b/a § PHOENIX RECOVERY GROUP, § § Defendant. § DECLARATION OF SADIE HACKLER I, Sadie Hackler, state as follows: 1. I am over 18 years of age and am competent to make this Declaration. The facts stated in this Declaration are within my personal knowledge and are true and correct. I submit this Declaration in support of Plaintiffs motion for summary judgment on liability. (the "Motion"). 2. Attached hereto as Exhibit 1 is a true and correct copy of a letter I received in June 2018 from Phoenix Recovery Group concerning a debt that Phoenix claims I owe to Larsen Properties. This was the first or initial communication that I received from Phoenix Recovery Group concerning the alleged debt referenced in the letter. 3. In accordance with 28 U.S.C. § 1746, I certify under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on .this_\_ day of Af..n \ 2019. "--;>PHOENIX I045 CHEEVER BLVD .• SUITE 204 SAN ANTONIO. TX 78217 (210) 822-8272. (800) 810-7623 June 5, 2018 --1 SADIE HACKLER Deur SADIE HACKLER, CREDITOR: LARSEN PROPERTIES TOTAL DUE: $590.00 • ACCT#: . . . . .)159 This account has been turned over lo our agency for collections. Please respond to this notice with your payment in full to avoid fu1iher collection efforts. Ir you dispute the validity of this debt within 30 days, from receipt of this notice. we will mail verification of the debt lo you. Ir you do not dispute the validity of this debt within 30 days, from receipt of this notice, we will assume it is valid. At your request, we will provide you with the name and address of the original creditor if different from the current creditor. Protect your credit rating by contacting our office today. Unless your account cannot be validated in accordance with the FCRA and FDCPA requirements our company will be reporting your account to all three national credit bureaus within the next 30 days. This is a matter of serious magnitude which wanants your prompt attention. This is an attempt to collect a debt and any information obtained will be used for that purpose. Your balance 111ay reflect a onc-tirnc agency collection tee. Please note there arc various payment options to meet your needs. You may pay by: > Credit or Debit Card > ACH > Mail-In-Money Order I Cashier's Check I Personal Check > Pay directly onlinc via http://www.phocnixrecovcrygroup.com/ > Rank Wire > Money Gram > Bill Pay (Auto-deducted through your financial institution) ........ "· . ·*-~.~. .r.?.~~~g.b...~Q.W.~J. PQ.~!.9D..A.D.9J~~-!Y.HJ.WJ~.hJ~~Y.rn~nt*-~-~---- 1967-DNTPRG10·1N-01/15/18 If YOU WISH TO PJ\Y BY CREfllT l;A,RO, CIRCLE ON.E ANO Fill IN THE INFOR!JIATION BEi.OW. Y20A76SS06 IPOlllllBox llllll 505 lllll llllll llll lllll lllll lllll llllll llll llll llll CARO NUMBER 1e1 [vis.Al DISCOVER" ...'..A ··1 I r"';, EXP. DATE Linden Ml 48451-0505 "" ______ ADDRESS SERVICE REQUESTED EARD HOLDER NAME cw Rouling IChecking Account# istGNATURE IAMOUNT PAID. Creditor: LARShN PROPERTll:S ' Total Due: $590.00 Acct ff: 260580-240t59 '' 11·I1It1I.t11tI'11 111·1111. 1It1. ''I' 1II1t 111,. 1. 111111tI·I'1' ·' Ol)()B l'J0.:1:24007511 I01354~24 l:J.412&· IVI\ t-V20/\7!lll606 1%7 IN - 1967 II,,, II.. I, .. 1,1,,, 111,,, I, 11, "'I, I,,, 11,, 11,, I, I,, I,, I, I.. 11 SADIE HACKLER The Phoenix Recovery Group I $;arca 11 I 045 Cheever Blvd Suite 204 San Antonio TX 78217 PLAINTIFF'S ~ EXHIBIT jl 1