On October 04, 2017 a
Order to Show Cause
was filed
involving a dispute between
Synchrony Bank,
and
Gomez, Claudia,
for Rule 3.740 Collections $10,000 or Less Limited
in the District Court of San Bernardino County.
Preview
LAW OFFICES OlF
PATENAUDE FELIX A P C
2 Michael R Boulanger Esq 226294
Michael D Kal n Esq 236898 f p
3 Ste phanie T Boone Es 9 160182 SUPERIOR COURT OF CAUFORNIA
COUNTY OF SAN BERNARDINO
Jessica F Flynn Esq 270304 SAN BERNARDINO DISTRICT
4
Gregory J Cobb Esq 133328
MAR 2 3 2018
5 4545 Murphy Canyon Road 3rd Floor
San Diego California 92123
BY
6 Tele 858 244 7600 Fax 858 836 0318
LISETTE ORTEGA DEPUTY
Attorneys for Plaintiff
SYNCHRONY BANK
g
9 SUPERIOR COURT OF CALIFORNIA
10 COUNTY OF SAN BERNARDINO SAN BERNARDINO JUSTICE CENTER
SI NCHRONY BANK Case No CIVDS1719514
a Plaintiff
8 12 DECLARATION IN RESPONSE TO ORDER
Q v TO SHOW CAUSE RE SERVICE
3 3
CLAUDIA GOMEZ Date 4 4 2018
w DOES 1 15 inclusive Time 8 30 AM
Op
a 14 and through
De t S17
AzzW
a Q 15 Defendant s
U
z 0
Qd 16
W I Jessica F Flynn declare as follows
a
h 17
1
I am an attorney at law duly licensed to practice before all courts in the State of
18
California and am an associate with the Law Offices of Patenaude Felix P F counsel of record
l9
for the plaintiff herein
20
2
21 If called to testify as a witness thereon I could and would competently testify as to all
22 facts stated in this declaration except as to those matters testified to upon information and belief
23
and as to those matters I believe them to be true
24
25
26
27
28
1
DECLARATION IN RESPONSE TO ORDER TO SHOW CAUSE
CA 98B Dec OSC P F File No17 38520
3 This Declaration is in response to the OSC re SERVICE currently set far 4 4 18
1
2 According to my review of the file Plaintiff filed this action for an Account Stated on or about
3 10 4 17 and thereafter sent the Summons and Complaint out for service with a registered process
4
server At the time the defendant s lastknown address was 10703 Cypress Ave Hesperia CA
5
92345 According to the process server sonline database service was attempted at the address on 7
6
occasions but on 10 30 17 the current occupant reported that the defendant moved did not reside at
7
the address and her forwarding address was unknown
g
4 On 1 OS 2018 a skip trace was performed and a potential new address was located
9
10 11818 Cypress Ave Hesperia CA 92345 Service was sent out at the new address on the same date
11
I reviewed the process server s online dateabase today and service at 11818 Cypress has been
12
a
g o
attempted on fourteen 14 occasions between 1 19 18 and 3 6 18 There has been no response at the
3 3
Q N o
a door so far Service attempts are continuing at the address
w 14
Uw
5
W w c o
Plaintiff and counsel apologize for the delay in service but Plaintiff has diligently
a Q 15
rzN
Q
W Q 6 sought to serve the defendant and service is currently pending at 11818 Cypress Ave Plaintiff and
a
a
1 counsel respectfully request a sixty 60 day continuance to allow time to serve and request that no
1g sanctions be issued
19
20
I declare under the penalty of perjury under the laws of the State of California that the
21
foregoing is true and correct Executed on March 21 2018 San ego alifornia
22
23
24
Jessica F Flynn Esq
25
26
27
28
2
DECLARATION IN RESPONSE TO ORDER TO SHOW CAUSE
CA 98 3 Dec OSC P F File No17 38520
Document Filed Date
March 23, 2018
Case Filing Date
October 04, 2017
Category
Rule 3.740 Collections $10,000 or Less Limited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
LAW OFFICES OlF PATENAUDE FELIX A P C 2 Michael R Boulanger Esq 226294 Michael D Kal n Esq 236898 f p 3 Ste phanie T Boone Es 9 160182 SUPERIOR COURT OF CAUFORNIA COUNTY OF SAN BERNARDINO Jessica F Flynn Esq 270304 SAN BERNARDINO DISTRICT 4 Gregory J Cobb Esq 133328 MAR 2 3 2018 5 4545 Murphy Canyon Road 3rd Floor San Diego California 92123 BY 6 Tele 858 244 7600 Fax 858 836 0318 LISETTE ORTEGA DEPUTY Attorneys for Plaintiff SYNCHRONY BANK g 9 SUPERIOR COURT OF CALIFORNIA 10 COUNTY OF SAN BERNARDINO SAN BERNARDINO JUSTICE CENTER SI NCHRONY BANK Case No CIVDS1719514 a Plaintiff 8 12 DECLARATION IN RESPONSE TO ORDER Q v TO SHOW CAUSE RE SERVICE 3 3 CLAUDIA GOMEZ Date 4 4 2018 w DOES 1 15 inclusive Time 8 30 AM Op a 14 and through De t S17 AzzW a Q 15 Defendant s U z 0 Qd 16 W I Jessica F Flynn declare as follows a h 17 1 I am an attorney at law duly licensed to practice before all courts in the State of 18 California and am an associate with the Law Offices of Patenaude Felix P F counsel of record l9 for the plaintiff herein 20 2 21 If called to testify as a witness thereon I could and would competently testify as to all 22 facts stated in this declaration except as to those matters testified to upon information and belief 23 and as to those matters I believe them to be true 24 25 26 27 28 1 DECLARATION IN RESPONSE TO ORDER TO SHOW CAUSE CA 98B Dec OSC P F File No17 38520 3 This Declaration is in response to the OSC re SERVICE currently set far 4 4 18 1 2 According to my review of the file Plaintiff filed this action for an Account Stated on or about 3 10 4 17 and thereafter sent the Summons and Complaint out for service with a registered process 4 server At the time the defendant s lastknown address was 10703 Cypress Ave Hesperia CA 5 92345 According to the process server sonline database service was attempted at the address on 7 6 occasions but on 10 30 17 the current occupant reported that the defendant moved did not reside at 7 the address and her forwarding address was unknown g 4 On 1 OS 2018 a skip trace was performed and a potential new address was located 9 10 11818 Cypress Ave Hesperia CA 92345 Service was sent out at the new address on the same date 11 I reviewed the process server s online dateabase today and service at 11818 Cypress has been 12 a g o attempted on fourteen 14 occasions between 1 19 18 and 3 6 18 There has been no response at the 3 3 Q N o a door so far Service attempts are continuing at the address w 14 Uw 5 W w c o Plaintiff and counsel apologize for the delay in service but Plaintiff has diligently a Q 15 rzN Q W Q 6 sought to serve the defendant and service is currently pending at 11818 Cypress Ave Plaintiff and a a 1 counsel respectfully request a sixty 60 day continuance to allow time to serve and request that no 1g sanctions be issued 19 20 I declare under the penalty of perjury under the laws of the State of California that the 21 foregoing is true and correct Executed on March 21 2018 San ego alifornia 22 23 24 Jessica F Flynn Esq 25 26 27 28 2 DECLARATION IN RESPONSE TO ORDER TO SHOW CAUSE CA 98 3 Dec OSC P F File No17 38520