Product: Debt collection

In accordance with [ XXXX XXXX ] Accord and Satisfaction [ XXXX XXXX Full satisfaction Of Claim ] [ FDCPA 15 USC 1692 ( c ) ( e ) & ( g ) ] XXXX XXXX moves the Court for Summary judgment on the claims contained in its complaint for Summary Judgment. The Defendant Breached an Actual contract by a broken promise without a legitimate lawful excuse. The defendant continues to collect on a debt that Plaintiff denies he owes. The Defendant is using the US post office to send debt collection letters for an invalid debt and is acting in a capacity of a 3rd party debt collector by sending illegal repossession letters through the U.S Postal Office as recent as XX/XX/XXXX. The Defendant agreed to fully satisfy the debt but did not comply and has been collecting payments under threat, duress and coercion which is in breach of the modified agreement and now in violation of the FDCPA [ FDCPA 15 USC 1692 ( c ) ( e ) & ( g ) ] The Defendant did not reposed point for point to 3 notice of claim of disputes or affidavits sent under notary presentment. Finally the defendant did not satisfy outstanding invoices presented to the defendant for overpayment of an unverified debt after Full Satisfaction of the Claim. 
On XX/XX/XXXX a check from Wells Fargo Bank for the amount {$580.00} was sent to WELLS FARGO AUTO FINANCE and the instrument contained a conspicuous statement written in the memo of the instrument For full satisfaction of claim. WELLS FARGO AUTO received the money order on XX/XX/XXXX and credited the account. ( See Exhibit A ) Payments where made to stay in honor and was Accepted and cashed.

A Second payment by Money order was sent on the amount of {$580.00} from the United States Postal Service on XX/XX/XXXX by priority mail Both Payments were sent to WELLS FARGO AUTO XXXX XXXX XXXX XXXX, CO XXXX 2. On XX/XX/XXXX XXXX, XXXX a notice of payment dispute was sent to XXXX XXXX XXXX dba along with an invoice for additional monies paid since full satisfaction of claim. CEO OF WELLS FARGO AUTO. There was no response to the notice. ( See Exhibit B ) 3. On XX/XX/XXXX, XXXX a second notice and opportunity to cure was sent along with an invoice for additional monies paid since full satisfaction of claim to the above mentioned via a correspondence via email to XXXX after they sent a offer to remove the dispute which I did not agree to after email correspondence with XXXX XXXX on and again with XXXX XXXX on XX/XX/XXXX. Also mailed on XXXX XX/XX/XXXX. 
4. On XX/XX/XXXX, and third notice of default and intent to sue was sent to the parties, and still WELLS FARGO AUTO has failed to honor the instrument and provide me with a remedy. Then I found out that the debt was paid and not my obligation and that they took {$1000.00} from me violating the TILA ACT.

NOTICE OF BILLING ERROR PURSUANT TO 15 U.S. Code 1666 Correction of Billing Errors In reflection after looking at this retail installment contract, payment history details, and considering the fact you never gave me any money and I extended you credit by giving my social security number pursuant to I require all monies I paid back to me because I was never given a loan. I request additional clarification including elementary evidence that you gave me a loan and deposited money into my bank account. I believe this is a computation error or similar error of an accounting nature of the alleged creditor on these statements.

4. Finally the attached payment schedule is inaccurate I dont see any place on this ledger or calculation that you Wells Fargo or XXXX gave me a loan. I DENY I was given a loan. Show quick proof that XXXX or Wells Fargo in fact gave me a loan. I demand a certified statement of accounting under penalty of perjury that you gave me a loan and gave me money. I dont have any evidence of a loan deposited into any bank account of mines after checking. If so produce the ledger that shows Wells Fargo or XXXX placed a loan into my bank account and I paid you. I required a certified statement of accounting not just something of a computer. 
5. I see a finance charge for a {$1000.00} downpayment thats in breach of the TILA I demand the {$1000.00} back that I gave you in addition to my signature that created the credit for this transaction. I was never to come out of pocket for a loan pursuant to 15 U.S. Code 1605 Determination of finance charge. the amount of the finance charge in connection with any consumer credit transaction shall be determined as the sum of all charges, payable directly or indirectly by the person to whom the credit is extended, and imposed directly or indirectly by the creditor as an incident to the extension of credit. Examples of charges which are included in the finance charge include any of the following types of charges which are applicable : ( 1 ) Interest, time price differential, and any amount payable under a point, discount, or other system or additional charges.

( 2 ) Service or carrying charge.

( 3 ) Loan fee, finders fee, or similar charge.

4 ) Fee for an investigation or credit report.

( 5 ) Premium or another charge for any guarantee or insurance protecting the creditor against the obligors default or other credit loss.

( 6 ) Borrower-paid mortgage broker fees, including fees paid directly to the broker or the lender ( for delivery to the broker ) whether such fees are paid in cash or financed. If you dont correct the billing error or remove it in 60 days then I expect a full refund of all monies paid since inception or I expect a clean title delivered and you agree to the terms of this agreement if you do not comply.

( 7 ) A full satisfaction of the claim was accepted in addition to the billing error pursuant to UCC 3-311. Show cause or show me what law states that you can violate the law of full satisfaction of claim under penalty of perjury. If you want the car back I will gladly return the car on the condition you refund all of the monies paid since inception because you did not give me a loan. This is a debt instrument that wasnt given with any consideration I never received a loan. Please correct the billing error and send a clear title.