Complaint Narrative Midland Funding , LLC and Midland Credit knowingly and willfully committed multiple violations of CFPB Consent Order XXXX/XXXX/XXXX, Administrative Proceeding XXXX in filing a consumer debt lawsuit against Consumer. Clear implication of systematic nature of these violations is that Midland Funding is systematically violating Consent Order in several XXXX consumer debt lawsuits in XXXX XXXX Courts filed since the XXXX XXXX, XXXX Consent Order filing date. Current number of Midland Funding open cases in XXXX XXXX XXXX as of XXXX XXXX, XXXX -- XXXX. 

Summary of Consent Order violations committed in filing of XXXX vs XXXX [ hereafter Consumer ], XXXX XXXX XXXX Case # -- XXXX. 
1. Used False and Generic Complaint Affidavit ( the Complaint ) in filing lawsuit. Attachment, MCM complaint affidavit.pdf XXXX. Made false claim to Court and Consumer in Complaint Affidavit of a 'right '' to [ continue to ] use Account Stated doctrine as done by Midland before Consent Order -- when Midland knows Consent Order now supervenes said claim. attachment Consent Order versus Account Stated.docx 3. Used False Affidavit of Service of Summons as created & questionably notarized by workers at XXXX XXXX XXXX XXXX Possible robo-notarization of high volume affidavits by XXXX XXXX XXXX XXXX XXXX XXXX 
Attachments : ... Refutation of False Affidavit of Service ... XXXX XXXX XXXX XXXX job description XXXX XXXX Sec State Registration Number and Address.pdf Sec XXXX XXXX XXXX XXXX ( lists business address same as XXXX ) 4. Used prohibited generic XXXX XXXX XXXX. XXXX XXXX XXXX XXXX is Generic -- except for date & buyer name. Does not refer to XXXX XXXX. Attachment : XXXX. 
5. Submitted False Affidavit of Review of Account. Documents as required were clearly not reviewed as Affidavit claims since by Midland statements they do not have those documents to give Consumer. Attachment : Midland Account Doc Review XXXX. 
6. Acted fraudulently for financial advantage by false affidavits & withholding existence of Consent Order from XXXX XXXX XXXX and Consumer and XXXX ) not conforming to & admitting governing stipulations. Attachment : MCM Complaint Affidavit.pdf. 
XXXX. Midland Attorney XXXX XXXX falsely claimed XXXX XXXX, XXXX to Consumer that Consent Order only applies in Federal Court and not in effect before XXXX XXXX, XXXX. Conversation : Court " Return Date '', XXXX XXXX XXXX. 
7. Noncompliant with having required account level documentation available prior to filing lawsuit. Midland only sent to Consumer and stated they only have charge-off statement amount, [ generic ] bill of sale - and denied having other account level documents. Attachment : MCM XXXX avoids providing acct information.pdf 8. Failed to offer account level documentation in advance of initiating lawsuit. 
9. Refused to provide account level documentation as requested by consumer. In-house attorney for Midland, XXXX said three times he would not even try. XXXX XXXX conversation and my complaint to court. 
XXXX. Coercive Use of pre-lawsuit Letter of Collection ( XXXX XXXX, XXXX ) to intimidate Consumer by false threat of litigation & saying account is in Legal Department. Attachment : mcm XXXX XXXX XXXX false threat of litigation.pdf XXXX. XXXX illegally sold debt to XXXX without questions by XXXX. Did not check validity when disputed by XXXX. Account invalid before sold as XXXX unlawfully defaulted on workout plan about XXXX XXXX. Account illegally sold by XXXX without information on work-out plan -- 0 % APR on first and then a second plan. XXXX XXXX refused XXXX XXXX, XXXX to provide XXXX in XXXX sales file. Midland only provided charge-off amount as " extra information '' on or about XXXX/XXXX/XXXX by letter ( copy n/a ) Ref : XXXX Consent Order.