Bridget A. King v. National Collegiate Student Loan Trust 2006-4, National Collegiate Student Loan Trust 2006-2, National Collegiate Student Loan Trust 2007-1, National Collegiate Student Loan Trust 2006-1, National Collegiate Student Loan Trust 2007-4

CourtIndiana Court of Appeals
DecidedFebruary 21, 2024
Docket23A-CC-1482
StatusPublished

This text of Bridget A. King v. National Collegiate Student Loan Trust 2006-4, National Collegiate Student Loan Trust 2006-2, National Collegiate Student Loan Trust 2007-1, National Collegiate Student Loan Trust 2006-1, National Collegiate Student Loan Trust 2007-4 (Bridget A. King v. National Collegiate Student Loan Trust 2006-4, National Collegiate Student Loan Trust 2006-2, National Collegiate Student Loan Trust 2007-1, National Collegiate Student Loan Trust 2006-1, National Collegiate Student Loan Trust 2007-4) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bridget A. King v. National Collegiate Student Loan Trust 2006-4, National Collegiate Student Loan Trust 2006-2, National Collegiate Student Loan Trust 2007-1, National Collegiate Student Loan Trust 2006-1, National Collegiate Student Loan Trust 2007-4, (Ind. Ct. App. 2024).

Opinion

IN THE

Court of Appeals of Indiana Bridget A. King, FILED Feb 21 2024, 10:09 am Appellant-Defendant CLERK Indiana Supreme Court Court of Appeals v. and Tax Court

National Collegiate Student Loan Trust 2006-4, National Collegiate Student Loan Trust 2006-2, National Collegiate Student Loan Trust 2007-1, National Collegiate Student Loan Trust 2006-1, National Collegiate Student Loan Trust 2007-4, Appellees-Plaintiffs

February 21, 2024 Court of Appeals Case No. 23A-CC-1482 Appeal from the Marion Superior Court

The Honorable Ian L. Stewart, Magistrate

Court of Appeals of Indiana | Opinion 23A-CC-1482 | February 21, 2024 Page 1 of 15 Trial Court Cause Nos. 49D05-1812-CC-50543 49D07-1812-CC-50545 49D07-1812-CC-50546 49D06-1812-CC-50571 49D04-1812-CC-50575 49D13-1812-CC-50587 49D06-1812-CC-50596

Opinion by Judge Foley Judges Pyle and Tavitas concur.

Foley, Judge.

[1] Bridget A. King (“Student”) appeals the order granting summary judgment to

the plaintiffs, National Collegiate Student Loan Trusts (collectively,

“Creditor”), 1 on claims that Student was liable to Creditor on several student

loans (“the Debt”). Student presents two issues, which we restate as follows:

I. Whether Creditor designated inadmissible evidence in support of its motion for summary judgment; and

II. Whether Student’s designated evidence established a genuine issue of material fact regarding Creditor’s right to collect on the Debt or whether Student was in default.

[2] We affirm.

1 Across various actions, the plaintiffs were National Collegiate Student Loan Trust 2006-4, National Collegiate Student Loan Trust 2006-2, National Collegiate Student Loan Trust 2007-1, National Collegiate Student Loan Trust 2006-1, and National Collegiate Student Loan Trust 2007-4.

Court of Appeals of Indiana | Opinion 23A-CC-1482 | February 21, 2024 Page 2 of 15 Facts and Procedural History [3] Creditor filed seven lawsuits claiming Student was in default on the Debt. The

cases were consolidated, and Creditor eventually moved for summary

judgment. In support, Creditor designated an affidavit (“the Affidavit”) from

Aaron Motin (“Motin”), who was employed by “the appointed [s]ubservicer”

of the Debt, Transworld Systems Inc. (“TSI”). Appellant’s App. Vol. 2 p. 68.

The purpose of the Affidavit was to admit several attached loan documents,

including documents that outlined Student’s payment history and demonstrated

that Student was in default. The evidence indicated that the Debt consisted of

several loans for which JPMorgan Chase Bank, N.A. (“Chase”) was the

originator. The evidence further indicated that Chase pooled and sold the loans

to National Collegiate Funding, LLC, which then sold the loans to Creditor.

[4] As to the attached records, the Affidavit indicated that some of the records were

not created by Creditor or TSI. Rather, they “include[d] electronic data that

prior servicers of the educational loan provided to TSI related to the

educational loan,” along with certain “business records[.]” Id. at 68. 2 The

Affidavit collectively refers to the attachments as the “loan records,” and

specifies that the loan records “include loan origination documents [Creditor]

obtained at acquisition.” Id. at 69. Motin testified that the prior servicer of the

loan was known as American Education Services (“AES”), and that AES

2 Creditor designated an affidavit for each loan. Because the affidavits were substantially the same in all pertinent respects, we cite herein to a single affidavit.

Court of Appeals of Indiana | Opinion 23A-CC-1482 | February 21, 2024 Page 3 of 15 “began servicing the [Debt] upon the first disbursement and continued to

service the [Debt] until it was charged-off.” Id. at 70. “Upon charge-off, the

loan records were transmitted to and incorporated within the records of TSI (or

its predecessor) as part of its regularly-conducted business practice,” and TSI

“began servicing the [Debt].” Id. Motin further averred that it was “TSI’s

regularly-conducted business practice to incorporate prior servicers’ loan

records into the system of record it maintains on [Creditor’s] behalf when TSI

assumes [the] role of [s]ubservicer.” Id. at 69–70.

[5] Motin addressed the way in which AES created and maintained the loan

records, testifying that he “ha[d] access to”—and “training and experience

using”— “the system of record utilized by [AES] . . . to enter, maintain[,] and

access the loan records during its role as servicer,” and that he was “familiar

with the transaction codes reflected in [AES] records.” Id. at 69. Motin also

addressed the way in which TSI obtained those records, testifying that he was

“familiar with the process by which TSI receives access to loan records from

[the] prior servicers and incorporates those records into TSI’s system of record.”

Id. at 70. He testified that “the loan records were transmitted to and

incorporated within the records of TSI (or its predecessor) as part of its

regularly-conducted business practice” when it began servicing the Debt. Id.

[6] Motin testified that TSI “regularly relies upon these integrated loan records in

performance of its services on behalf of [Creditor].” Id. He further testified that

the loan records, “including records entered and maintained by AES,” were

created, compiled or recorded, and kept as part of regularly conducted business

Court of Appeals of Indiana | Opinion 23A-CC-1482 | February 21, 2024 Page 4 of 15 activity at or near the time of the event recorded.” Id. Moreover, Motin

averred that the loan records “were created, compiled[,] or recorded from

information transmitted by a person with personal knowledge of such event

who had a business duty to accurately report it, from information transmitted

by a person with personal knowledge of such event,” and that “[s]uch records

are created, kept[,] maintained, accessed[,] and relied upon in the course of

ordinary and regularly conducted business activity.” Id. at 70–71.

[7] Student filed a response asserting that the loan records could not be properly

considered in ruling on summary judgment. Student specifically claimed that

Motin lacked personal knowledge regarding the loan records, resulting in a

deficient foundation such that the records constituted inadmissible hearsay.

[8] Student also designated evidence in response to summary judgment, asserting

that the evidence created a genuine issue of material fact regarding whether

Student was in default and whether Creditor actually controlled the Debt. The

designated evidence included Student’s own affidavit, which contained a

statement that she “ha[d] no recollection of having ever made any of the

payments . . . reflected in the[] account histories” depicted in the loan records.

Appellant’s App. Vol. 4 p. 84. Student also provided five documents that

appear to be 1099-C tax documents (“the 1099s”) that Chase—rather than

Creditor—issued to Student or her co-signer. See id. at 85–89. The 1099s

indicate that Chase discharged certain student loan debt in 2019. Each of the

1099s contains a different account number. Student’s affidavit did not refer to

the 1099s. However, Student did discuss the 1099s in her briefing on summary

Court of Appeals of Indiana | Opinion 23A-CC-1482 | February 21, 2024 Page 5 of 15 judgment. Although the 1099s contain account numbers, Student did not

address in briefing how those account numbers correspond to the Debt.

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Bridget A. King v. National Collegiate Student Loan Trust 2006-4, National Collegiate Student Loan Trust 2006-2, National Collegiate Student Loan Trust 2007-1, National Collegiate Student Loan Trust 2006-1, National Collegiate Student Loan Trust 2007-4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bridget-a-king-v-national-collegiate-student-loan-trust-2006-4-national-indctapp-2024.