IN THE IOWA DISTRICT COURT FOR SAC COUNTY

PLAINTIFF
Midland Funding LLC
33-0337177
DEFENDANT(S)
Heather Reiling
110 Westview Ave
Yetter, Iowa 51433
TO DEFENDANT(S):
vs.
ORIGINAL NOTICE AND PETITION
FOR A MONEY JUDGMENT
SMALL CLAIM NO. ______ _
If you need assistance to participate in Court due to a
disability, call the disability coordinator at 515-286-3394.
Persons who are hearing or speech impaired may call
Relay Iowa TTY (1-800-735-2942). Disability
coordinators cannot provide legal advice.
1. YOU ARE NOTIFIED that Plaintiff demands from you the Defendant the amount of $3,145.28
plus court costs based on a delinquent balance on account as stated, plus interest and costs.
Defendant(s) have defaulted in the terms of the Account as shown by the Notice to Cure attached
hereto and incorporated herein by this reference. NOTE: This legal proceeding is an attempt to
collect a debt and any information obtained will be used for that purpose.
2. JUDGMENT MAY BE ENTERED AGAINST YOU unless you file an Appearance and Answer within
20 days of the service of the Original Notice upon you. Judgment may include the amount
requested plus interest and court costs.
3. YOU MUST ELECTRONICALLY FILE an Appearance and Answer using the Iowa Judicial Branch
Electronic Document Management System (EDMS) at https://www.iowacourts.state.ia.us/EFile,
unless you obtain from the Court an exemption from electronic filing requirements.
4. If your Appearance and Answer is filed within 20 Days and you deny the claim, you will receive
electronic notification through EDMS of the place and time of the hearing on this matter.
5. If you electronically file an Appearance and Answer, EDMS will serve a copy of the form on
Plaintiff(s), unless Plaintiff(s) is (are) exempt from electronic filing, or on the attorney for
Plaintiff(s). The Notice of Electronic Filing will indicate if you must mail a copy of your Appearance
and Answer to Plaintiff(s).
6. You must also notify the Clerk's Office of any address change.
WETSCH, ABBOTI &

KEVIN ABBOTT #AT0000391
ATTORNEYS FOR PLAINTIFF
13-05041-0
974 - 73rd Street, Suite 20
Des Moines, IA 50324
Telephone (515) 223-1336
Facsimile (515) 223-6011
WAOFIRM@dsmialaw.com
E-FILED 2013 DEC 15 2:12 PM SAC - CLERK OF DISTRICT COURT
IN THE IOWA DISTRICT COURT FOR SAC COUNTY
PLAINTIFF
Midland Funding LLC
vs.
DEFENDANT($)
Heather Reiling
VERIFICATION OF ACCOUNT,
IDENTIFICATION OF JUDGMENT
DEBTOR, AND CERTIFICATE
RE MILITARY SERVICE
SMALL CLAIM NO.
For Defendant: Heather Reiling
1. I, KEVIN ABBOTT, being first duly sworn on oath, depose and state that I am the attorney for
Midland Funding LLC, the Plaintiff whose claim(s) is (are) shown in the attached statement(s). I
have personal knowledge that the attached statement(s) is (are) a true copy of the original
creditor's records showing the balance due is true and correct. I further state that the sum of
$3,145.28 is the balance due and owing from Defendant(s) to Plaintiff(s), and any interest amount
owing is accurately stated in the Petition or Original Notice.
2. I further state that the Defendant, Heather Reiling, resides at 110 Westview Ave, Yetter, Iowa
51433, is employed at unkown, and Defendant's occupation is unknown.
3. I further state that Defendant, , resides at , , , is employed at unknown, and Defendant's
occupation is unknown.
4. I also state Defendant(s) is (are) not in the Military Forces of the United States Government.
I, or a fellow employee, verified this fact by (check one):
o Checking the Defense Manpower Data Center (DMDC),
http:www.virec.research.va.gov/Non-VADataSources/DMDC,htm.
181 I have investigated, and I am unable to determine whether or not Defendant(s) is
in the military service of the United State Government.
o Regularly seeing Defendant(s) and believing Defendant(s) is (are) are not active in
the U.S. Military.
5. I also state to the best of my knowledge Defendant(s) is (are) not under any legal disability or
confined in any reformatory, jail, or penitentiary. I certify under penalty or perjury and pursuant
to the laws of the State of Iowa that these facts are true and correct.
& A
By: \l/\F)'::\J
y
KEVIN ABBOTT #AT0000391
974 - 73rd Street, Suite 20
Des Moines, IA 50324
Telephone (515) 223-1336
WAOFIRM@dsmialaw.com
E-FILED 2013 DEC 15 2:12 PM SAC - CLERK OF DISTRICT COURT
WETSCH, ABBOTT, & OSBORN, P.L.C.
DAVID L. WETSCH
KEVIN V. ABBOTT
BRETT T. OSBORN
TIMOTHY J. VAN VLIET
Heather Reiling
110 Westview Ave
Yetter, Iowa 51433
RE: CREDITOR:
ATTORNEYS AT LAW
974- 73RD STREET, SUITE 20
DES MOINES, IOWA 50324-1032
Midland Funding LLC
Regarding: Chase Bank USA, N .A.
Account Balance: $3,145.28
Account Number: 8540576027
To Whom It May Concern:
July31,2013
(515) 223-1336
FAX (515) 223-6011
You are now in default of this credit transaction. You have a right to cure this default until
September 1, 2013. If you do so, you may continue with the contract as though you did not default.
Your default consists of the failure to pay $1,258.00 due October 30, 2009.
CORRECTION OF THE DEF A ULT: Before September 1, 2013, you may cure the default by
forwarding the sum of$ l ,258.00 to Midland Funding LLC at the address noted above. If you do not
correct the default by the date stated above, Midland Funding LLC may exercise its rights against you
under the law. If you default again in the next year, Midland Funding LLC may exercise its rights
without sending you another notice like this one. If you have any questions, write or telephone the
undersigned at the address or telephone number listed above.
You presently owe Midland Funding LLC the sum of$3, 145.28. Unless you notify us within
30 days after receipt of this letter that the validity of this debt, or any portion of it is disputed, we will
assume that the debt is valid. If you notify us of a dispute, we will obtain verification of the debt and
mail it to you. Upon your request within the 30 day period, we will provide you with the name and
address of the original creditor if different than the current creditor. This communication is from a
debt collector and is an attempt to collect a debt. Any information obtained will be used for that
purpose.
W&A/sw
13-05041-0
WETSCH, ABBOTT & OSBORN, PLC
By: _____________ _
KEVIN ABBOTT
P.S. If you want to set up a payment plan on this debt, please call or write!
E-FILED 2013 DEC 15 2:12 PM SAC - CLERK OF DISTRICT COURT
State ofIOWA
MIDLAND FUNDING LLC,
AFFIDAVIT OF ACCOUNT
Plaintiff
-vs-
Reiling, Heather,
Court File No. -------
Defendant(s).
Bonnie Gohman, whose business address is 16 Mcleland Road Suite 101, St. Cloud,
MN 56303, certifies and says:
1. I am employed as a Legal Specialist and have access to pertinent account records
for Midland Credit Management, Inc. ("MCM"), servicer of this account on behalf of
plaintiff. I am a competent person over eighteen years of age, and make the statements herein
based upon personal knowledge of those account records maintained on plaintiff's behalf.
Plaintiff is the current owner of, and/or successor to, the obligation sued upon, and was
assigned all the rights, title and interest to defendant's CHASE BANK USA, N.A. account
4266841046704142 (MCM Number 8540576027) (hereinafter "the account"). I have access
to and have reviewed the records pertaining to the account and am authorized to make this
affidavit on plaintiff's behalf.
2. I am familiar with and trained on the manner and method by which MCM creates and
maintains its business records pertaining to this account. The records are kept in the regular
course of business. It was in the regular course of business for a person with knowledge
of the act or event recorded to make the record or data compilation, or for a person with
knowledge to transmit information thereof to be included in such record. In the regular course
of business, the record or compilation is made at or near the time of the act or event. The
relevant financial information concerning the account includes the following:
3. MCM's records show that the defendant(s) owed a balance of $3145.28 as of
2013-07-29.
AFFIDAVIT OF ACCOUNT - 1
1111111111111 ~ lllWlllllllll
8540576027 AFFINDEBT 13-05041-0
E-FILED 2013 DEC 15 2:12 PM SAC - CLERK OF DISTRICT COURT
4. It is in the ordinary course of business for plaintiff or its agents to send a validation
letter to defendant(s) in accordance with the Fair Debt Collection Practices Act (15 USC
1692g) setting forth the amount of the debt, identifying plaintiff as the creditor to whom
the debt is owed, and notifying defendant(s) that, in accordance with the FDCPA, unless
defendant( s) disputes the validity of the debt, or any portion of it, the debt will be assumed
valid.
5. MCM's records state that MCM sent a validation letter to defendant(s) on behalf of
plaintiff, and that defendant(s) have not contacted MCM to dispute or object to the amounts
stated in such correspondence as due and owing.
6. MCM's records state that this action is based upon a revolving credit agreement entered
into between defendant(s) and the original credit grantor. MCM's records further state that
defendant(s) used or authorized the use of the credit card account but failed to make the
payments due pursuant to the agreement.
7. MCM's business records do not state that the defendant is an infant or an incompetent
person.
8. If called to testify as a witness thereon, I could and would competently testify as to all
the facts stated herein.
LEFT BLANK INTENTIONALLY
AFFIDAVIT OF ACCOUNT - 2
1111111111111 111111111111 11100111111111
8540576027 AFFINDEBT 13-05041-0
E-FILED 2013 DEC 15 2:12 PM SAC - CLERK OF DISTRICT COURT
I certify under penalty of perjury that the foregoing statements are true and correct.
'JUL 312013
Date
STATE OF MINNESOTA
COUNTY OF STEARNS
Bonnie Gohman
Signed and sworn to (or affirmed) before me on JUL 312013 by Bonnie Gohman.
IA064
L VOGT
Notaf'I Public-Minnesota
My Commission ExllfeS a 31, 10\1
Wetsch, Abbott & Osborn, P.L.C.
AFFIDAVIT OF ACCOUNT - 3
11111111111111
8540576027

AFFINDEBT
lllMlllllllll
13-05041-0
E-FILED 2013 DEC 15 2:12 PM SAC - CLERK OF DISTRICT COURT
IN THE IOWA DISTRICT COURT FOR COUNTY
PLAINTIFF(S)
Midland Funding LLC
DEFENDANT(S)
Heather Reiling
110 Westview Ave
Yetter, Iowa 51433
DISMISSAL
vs.
CASE NO. SCSC 015381
By this filing, I (we) dismiss my (our) claim(s) (check ONLY ONE of the following):
D With Prejudice. I (we) cannot refile the claim(s).
X Without Prejudice. I (we) may refile the claim(s).
WETSCH, 01BORN, P.L.C.

KEVIN ABBOTT #AT0000391
ATTORNEYS FOR PLAINTIFF
13-05041-0
974 - 73rd Street, Suite 20
Des Moines, IA 50324
Telephone (515) 223-1336
Facsimile (515) 223-6011
WAOFIRM@dsmialaw.com
E-FILED 2014 JAN 06 1:00 PM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 JAN 14 1:20 PM SAC - CLERK OF DISTRICT COURT