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CIV-105
DEFAULT ENTERED
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NO:
NAME: EMILY PIERCE, ESQ.
BAR NO. 240084/ JORDAN COOK, ESQ.
BAR NO. 179720/ KRISTEN BRINKERHOFF, ESQ.
BAR AS REQUESTED
FOR COURT USE ONLY
NO. 263579/ LORI WILLIAMS, ESQ.
BAR NO. 242985/ MICHELLE MITCHELL, ESQ.
BAR NO. 221841
FIRM NAME:
STREET ADDRESS: 10680 TREENA ST., SUITE 500
CITY: SAN DIEGO STATE: CA ZIP CODE: 92131
TELEPHONE NO.: 866/428-8102
FAX NO.: ELECTRONICALLY
F I L E D
E-MAIL ADDRESS: LITIGATIONFILINGCA@PORTFOLIORECOVERY.COM
ATTORNEY FOR (name): PORTFOLIO RECOVERY ASSOCIATES, LLC
Superior Court of California,
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO County of San Francisco
STREET ADDRESS: 400 MCALLISTER ST
MAILING ADDRESS: 06/13/2022
CITY AND ZIP CODE: SAN FRANCISCO 94102
BRANCH NAME: CIVIC CENTER COURTHOUSE
Clerk of the Court
BY: STACY GEE
Plaintiff/Petitioner: PORTFOLIO RECOVERY ASSOCIATES, LLC Deputy Clerk
Defendant/Respondent: JOE ZAMORA; AND DOES 1 TO 25
CASE NUMBER:
CGC-21-596991
REQUEST FOR (Application) Entry of Default Judgment
For use only in actions under the Fair Debt Buying Practices Act (Civ. Code, § 1788.50 et seq.)
1. On the complaint or cross-complaint filed
a. on (date): DECEMBER 07, 2021
b. by (name): PORTFOLIO RECOVERY ASSOCIATES, LLC
c. Enter default of defendant (names): JOE ZAMORA
d. I request a judgment under Civil Code section 1788.60 and Code of Civil Procedure section 585 against defendant
(names): JOE ZAMORA
(Testimony may be required. Check with the clerk regarding whether a hearing date is needed.)
e. Default was previously entered on (date):
2. Judgment to be entered. Amount Credits acknowledged Balance
a. Demand of complaint* $ 2,661.90 $ 0.00 $ 2,661.90
b. Interest $ $ $
c. Costs (see page 3) $ 239.50 $ $ 239.50
d. Attorney fees $ $ $
e. TOTALS $ 2,720.40 $ 0.00 $ 2,720.40
(* Must be established by business records, authenticated through a sworn declaration, submitted with this application. (Civ.
Code, §§ 1788.58(a)(4), 1788.60(a).))
3. This action is not barred by the applicable statute of limitations (Civ. Code, § 1788.56).
4. Requirements for the complaint.
a. The complaint alleges ALL of the following (Civ. Code, §§ 1788.58, 1788.60):
(1) That the plaintiff is a debt buyer;
(2) A short, plain statement regarding the nature of the underlying debt and the consumer transaction from which it is
derived;
(3) That the plaintiff is EITHER the sole owner of the debt OR has the authority to assert the rights of all owners of the debt;
(4) The debt balance at charge-off and an explanation of the amount and nature of, and reason for, all post-charge-off
interest and fees, if any, imposed by the charge-off creditor or any subsequent purchasers of the debt;
(5) The date of the default OR the date of the last payment;
(6) The name and address of the charge-off creditor at the time of charge-off in sufficient form so as to reasonably identify
the charge-off creditor, and the charge-off creditor's account number associated with the debt;
06/13/2022
STACY GEE
Page 1 of 3
Form Adopted for Mandatory Use
Judicial Council of California
REQUEST FOR ENTRY OF DEFAULT Code of Civil Procedure, § 585;
Civil Code, § 1788.60
CIV-105 [Rev. January 1, 2020] (Fair Debt Buying Practices Act) www.courts.ca.gov
CIV-105
Plaintiff/Petitioner: PORTFOLIO RECOVERY ASSOCIATES, LLC CASE NUMBER:
Defendant/Respondent: JOE ZAMORA; AND DOES 1 TO 25 CGC-21-596991
4. a. (7) The name and last known address of the debtor as they appeared in the charge-off creditor's records prior to the sale of
the debt;
(8) The names and addresses of all persons or entities that purchased the debt after charge-off, including the plaintiff debt
buyer, in sufficient form so as to reasonably identify each such purchaser; and
(9) That the plaintiff has complied with Civil Code section 1788.52.
b. A copy of the contract or other document described in Civil Code section 1788.52(b) is attached to the complaint.
5. Documentation requirements for default judgment. ALL of the following documents are submitted with this request for default
judgment (Civ. Code, § 1788.60(a)–(c)):
a. A copy of the contract or other document evidencing the debtor's agreement to the debt, authenticated through a sworn
declaration. See Civil Code section 1788.52(b) regarding documentation, including for revolving credit accounts.
b. Business records, authenticated through a sworn declaration, to establish:
(1) That the plaintiff is EITHER the sole owner of the debt OR has the authority to assert the rights of all owners of the debt;
(2) The debt balance at charge-off, and an explanation of the amount and nature of, and reason for, all post-charge-off
interest and fees, if any, imposed by the charge-off creditor or any subsequent purchasers of the debt;
(3) The date of the default OR the date of the last payment;
(4) The name and address of the charge-off creditor at the time of charge-off in sufficient form so as to reasonably identify
the charge-off creditor, and the charge-off creditor's account number associated with the debt;
(5) The name and last known address of the debtor as they appeared in the charge-off creditor's records prior to the sale of
the debt; and
(6) The names and addresses of all persons or entities that purchased the debt after charge-off, including the plaintiff debt
buyer, in sufficient form so as to reasonably identify each such purchaser.
Date: MAY 25, 2022
EMILY PIERCE, ESQ. BAR NO. 240084
(TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY FOR PLAINTIFF)
FOR COURT (1) Default entered as requested on (date):
USE ONLY (2) Default NOT entered as requested(state reason):
Clerk, by , Deputy
6. Legal document assistant or unlawful detainer assistant (Bus. & Prof. Code, § 6400 et seq.). A legal document assistant or
unlawful detainer assistant did did not for compensation give advice or assistance with this form. If declarant has
received any help or advice for pay from a legal document assistant or unlawful detainer assistant, state:
a. Assistant's name: c. Telephone no.:
b. Street address, city, and zip code: d. County of registration:
e. Registration no.:
f. Expires on (date):
7. Declaration under Code Civ. Proc., § 585.5 (for entry of default under Code Civ. Proc., § 585(a)). This action
a. is is not on a contract or installment sale for goods or services subject to Civ. Code, § 1801 et seq. (Unruh Act).
b. is is not on a conditional sales contract subject to Civ. Code, § 2981 et seq. (Rees-Levering Motor Vehicle Sales
and Finance Act).
c. is is not on an obligation for goods, services, loans, or extensions of credit subject to Code Civ. Proc., § 395(b).
CIV-105 [Rev. January 1, 2020] Page 2 of 3
REQUEST FOR ENTRY OF DEFAULT
(Fair Debt Buying Practices Act)
CIV-105
CASE NUMBER:
Plaintiff/Petitioner: PORTFOLIO RECOVERY ASSOCIATES, LLC
CGC-21-596991
Defendant/Respondent: JOE ZAMORA; AND DOES 1 TO 25
8. Declaration of mailing (Code Civ. Proc., § 587). A copy of this Request for Entry of Default was
a. not mailed to the following defendants, whose addresses are unknown to plaintiff or plaintiff's attorney (names):
b. mailed first-class, postage prepaid, in a sealed envelope addressed to each defendant's attorney of record or, if none,
to each defendant's last known address as follows:
(1) Mailed on (date): May 25, 2022 (2) To (specify names and addresses shown on the envelopes):
JOE ZAMORA
2306 MARKET ST APT 409
SAN FRANCISCO, CA 94114-1554
I declare under penalty of perjury under the laws of the State of California that the foregoing items 6, 7, and 8 are true and correct.
Date: MAY 25, 2022
EMILY PIERCE, ESQ. BAR NO. 240084
(TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT)
9. Declaration of nonmilitary status (required for a judgment). No defendant named in item 1c of the application is in the military
service as that term is defined by either the Servicemembers Civil Relief Act, 50 U.S.C. App. § 3911(2), or California Military and
Veterans Code sections 400 and 402(f).
10. Memorandum of costs (required if money judgment requested). Costs and disbursements are as follows (Code Civ. Proc.,
§ 1033.5):
a. $
Clerk's filing fees ............................................
$181.00
b. $
Process server's fees .....................................
58.50
c. Other (specify): Electronic filing fees $ $0.00
d. $
e. $
TOTAL ..........................................................
$239.50
f. ☐ Costs and disbursements are waived.
g. I am the attorney, agent, or party who claims these costs. To the best of my knowledge and belief this memorandum of costs
is correct and these costs were necessarily incurred in this case.
I declare under penalty of perjury under the laws of the State of California that the foregoing items 9 and 10 are true and correct.
Date: MAY 25, 2022
EMILY PIERCE, ESQ. BAR NO. 240084
(TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT)
CIV-105 [Rev. January 1, 2020] Page 3 of 3
REQUEST FOR ENTRY OF DEFAULT
(Fair Debt Buying Practices Act)
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CIV-105 DEFAULT ENTERED ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NO: NAME: EMILY PIERCE, ESQ. BAR NO. 240084/ JORDAN COOK, ESQ. BAR NO. 179720/ KRISTEN BRINKERHOFF, ESQ. BAR AS REQUESTED FOR COURT USE ONLY NO. 263579/ LORI WILLIAMS, ESQ. BAR NO. 242985/ MICHELLE MITCHELL, ESQ. BAR NO. 221841 FIRM NAME: STREET ADDRESS: 10680 TREENA ST., SUITE 500 CITY: SAN DIEGO STATE: CA ZIP CODE: 92131 TELEPHONE NO.: 866/428-8102 FAX NO.: ELECTRONICALLY F I L E D E-MAIL ADDRESS: LITIGATIONFILINGCA@PORTFOLIORECOVERY.COM ATTORNEY FOR (name): PORTFOLIO RECOVERY ASSOCIATES, LLC Superior Court of California, SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO County of San Francisco STREET ADDRESS: 400 MCALLISTER ST MAILING ADDRESS: 06/13/2022 CITY AND ZIP CODE: SAN FRANCISCO 94102 BRANCH NAME: CIVIC CENTER COURTHOUSE Clerk of the Court BY: STACY GEE Plaintiff/Petitioner: PORTFOLIO RECOVERY ASSOCIATES, LLC Deputy Clerk Defendant/Respondent: JOE ZAMORA; AND DOES 1 TO 25 CASE NUMBER: CGC-21-596991 REQUEST FOR (Application) Entry of Default Judgment For use only in actions under the Fair Debt Buying Practices Act (Civ. Code, § 1788.50 et seq.) 1. On the complaint or cross-complaint filed a. on (date): DECEMBER 07, 2021 b. by (name): PORTFOLIO RECOVERY ASSOCIATES, LLC c. Enter default of defendant (names): JOE ZAMORA d. I request a judgment under Civil Code section 1788.60 and Code of Civil Procedure section 585 against defendant (names): JOE ZAMORA (Testimony may be required. Check with the clerk regarding whether a hearing date is needed.) e. Default was previously entered on (date): 2. Judgment to be entered. Amount Credits acknowledged Balance a. Demand of complaint* $ 2,661.90 $ 0.00 $ 2,661.90 b. Interest $ $ $ c. Costs (see page 3) $ 239.50 $ $ 239.50 d. Attorney fees $ $ $ e. TOTALS $ 2,720.40 $ 0.00 $ 2,720.40 (* Must be established by business records, authenticated through a sworn declaration, submitted with this application. (Civ. Code, §§ 1788.58(a)(4), 1788.60(a).)) 3. This action is not barred by the applicable statute of limitations (Civ. Code, § 1788.56). 4. Requirements for the complaint. a. The complaint alleges ALL of the following (Civ. Code, §§ 1788.58, 1788.60): (1) That the plaintiff is a debt buyer; (2) A short, plain statement regarding the nature of the underlying debt and the consumer transaction from which it is derived; (3) That the plaintiff is EITHER the sole owner of the debt OR has the authority to assert the rights of all owners of the debt; (4) The debt balance at charge-off and an explanation of the amount and nature of, and reason for, all post-charge-off interest and fees, if any, imposed by the charge-off creditor or any subsequent purchasers of the debt; (5) The date of the default OR the date of the last payment; (6) The name and address of the charge-off creditor at the time of charge-off in sufficient form so as to reasonably identify the charge-off creditor, and the charge-off creditor's account number associated with the debt; 06/13/2022 STACY GEE Page 1 of 3 Form Adopted for Mandatory Use Judicial Council of California REQUEST FOR ENTRY OF DEFAULT Code of Civil Procedure, § 585; Civil Code, § 1788.60 CIV-105 [Rev. January 1, 2020] (Fair Debt Buying Practices Act) www.courts.ca.gov CIV-105 Plaintiff/Petitioner: PORTFOLIO RECOVERY ASSOCIATES, LLC CASE NUMBER: Defendant/Respondent: JOE ZAMORA; AND DOES 1 TO 25 CGC-21-596991 4. a. (7) The name and last known address of the debtor as they appeared in the charge-off creditor's records prior to the sale of the debt; (8) The names and addresses of all persons or entities that purchased the debt after charge-off, including the plaintiff debt buyer, in sufficient form so as to reasonably identify each such purchaser; and (9) That the plaintiff has complied with Civil Code section 1788.52. b. A copy of the contract or other document described in Civil Code section 1788.52(b) is attached to the complaint. 5. Documentation requirements for default judgment. ALL of the following documents are submitted with this request for default judgment (Civ. Code, § 1788.60(a)–(c)): a. A copy of the contract or other document evidencing the debtor's agreement to the debt, authenticated through a sworn declaration. See Civil Code section 1788.52(b) regarding documentation, including for revolving credit accounts. b. Business records, authenticated through a sworn declaration, to establish: (1) That the plaintiff is EITHER the sole owner of the debt OR has the authority to assert the rights of all owners of the debt; (2) The debt balance at charge-off, and an explanation of the amount and nature of, and reason for, all post-charge-off interest and fees, if any, imposed by the charge-off creditor or any subsequent purchasers of the debt; (3) The date of the default OR the date of the last payment; (4) The name and address of the charge-off creditor at the time of charge-off in sufficient form so as to reasonably identify the charge-off creditor, and the charge-off creditor's account number associated with the debt; (5) The name and last known address of the debtor as they appeared in the charge-off creditor's records prior to the sale of the debt; and (6) The names and addresses of all persons or entities that purchased the debt after charge-off, including the plaintiff debt buyer, in sufficient form so as to reasonably identify each such purchaser. Date: MAY 25, 2022 EMILY PIERCE, ESQ. BAR NO. 240084 (TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY FOR PLAINTIFF) FOR COURT (1) Default entered as requested on (date): USE ONLY (2) Default NOT entered as requested(state reason): Clerk, by , Deputy 6. Legal document assistant or unlawful detainer assistant (Bus. & Prof. Code, § 6400 et seq.). A legal document assistant or unlawful detainer assistant did did not for compensation give advice or assistance with this form. If declarant has received any help or advice for pay from a legal document assistant or unlawful detainer assistant, state: a. Assistant's name: c. Telephone no.: b. Street address, city, and zip code: d. County of registration: e. Registration no.: f. Expires on (date): 7. Declaration under Code Civ. Proc., § 585.5 (for entry of default under Code Civ. Proc., § 585(a)). This action a. is is not on a contract or installment sale for goods or services subject to Civ. Code, § 1801 et seq. (Unruh Act). b. is is not on a conditional sales contract subject to Civ. Code, § 2981 et seq. (Rees-Levering Motor Vehicle Sales and Finance Act). c. is is not on an obligation for goods, services, loans, or extensions of credit subject to Code Civ. Proc., § 395(b). CIV-105 [Rev. January 1, 2020] Page 2 of 3 REQUEST FOR ENTRY OF DEFAULT (Fair Debt Buying Practices Act) CIV-105 CASE NUMBER: Plaintiff/Petitioner: PORTFOLIO RECOVERY ASSOCIATES, LLC CGC-21-596991 Defendant/Respondent: JOE ZAMORA; AND DOES 1 TO 25 8. Declaration of mailing (Code Civ. Proc., § 587). A copy of this Request for Entry of Default was a. not mailed to the following defendants, whose addresses are unknown to plaintiff or plaintiff's attorney (names): b. mailed first-class, postage prepaid, in a sealed envelope addressed to each defendant's attorney of record or, if none, to each defendant's last known address as follows: (1) Mailed on (date): May 25, 2022 (2) To (specify names and addresses shown on the envelopes): JOE ZAMORA 2306 MARKET ST APT 409 SAN FRANCISCO, CA 94114-1554 I declare under penalty of perjury under the laws of the State of California that the foregoing items 6, 7, and 8 are true and correct. Date: MAY 25, 2022 EMILY PIERCE, ESQ. BAR NO. 240084 (TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT) 9. Declaration of nonmilitary status (required for a judgment). No defendant named in item 1c of the application is in the military service as that term is defined by either the Servicemembers Civil Relief Act, 50 U.S.C. App. § 3911(2), or California Military and Veterans Code sections 400 and 402(f). 10. Memorandum of costs (required if money judgment requested). Costs and disbursements are as follows (Code Civ. Proc., § 1033.5): a. $ Clerk's filing fees ............................................ $181.00 b. $ Process server's fees ..................................... 58.50 c. Other (specify): Electronic filing fees $ $0.00 d. $ e. $ TOTAL .......................................................... $239.50 f. ☐ Costs and disbursements are waived. g. I am the attorney, agent, or party who claims these costs. To the best of my knowledge and belief this memorandum of costs is correct and these costs were necessarily incurred in this case. I declare under penalty of perjury under the laws of the State of California that the foregoing items 9 and 10 are true and correct. Date: MAY 25, 2022 EMILY PIERCE, ESQ. BAR NO. 240084 (TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT) CIV-105 [Rev. January 1, 2020] Page 3 of 3 REQUEST FOR ENTRY OF DEFAULT (Fair Debt Buying Practices Act)