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DEFAULT ENTERED CIV-105
ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO
AS REQUESTED
FOR COURT USE ONLY
NAME Christopher D. Mandarich SB 220693
FIRM NAME:
M8nd8rich Lavr Group
LLP
60610
sTREETADDREss: P.Q. Box 109032 Chicago,
IL
clTYChicago STATE:IL ZIP CODE:F)0611 ELECTRONICALLY
TELEPHONE NO.:877 286 4g18 FAx No-
818-888-1260 F I L E D
E-MAIL ADDRESS: Superior Court of California,
MIDLAND FUNDING
ATTQRNEY FOR(name): LLC FILE BY FAX County of San Francisco
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO 01/21/2020
Clerk of the Court
MAILING ADDREss: 400
M CALLI STE R STRE ET BY: NADITA MASON
coDE.SAN
clTY AND zIP FRANCISCO CA 94102 Deputy Clerk
" " " "CIVIC CENTER COURTHOUSE
Plaintiff/Petitioner: IVIIDI AND
FUNDING LL(
sP " nt TABU BUGGS, an individua
REQUEST FOR (Applicati») ~x Entry Df e aul ~ u"gmen
CASE NUMBER
CGC-19-577665
For use only in actions under the Fair Debt Buying Practices Act (Civ. Code, g 1788.50 et seq.)
1. On the complaint or cross-complaint filed
a. on (date):
07/f16/f2p19
y(na
C.
d.
~
~ I
):MIDLAND FUNDING LLC
Enter default Of defendant (nameS): TABLI individual
BLIGGS, an
request a judgment under Civil Code section 1788.60 and Code of Civil Procedure section 585 against defendant
(names):
(Testimony may be required. Check with the clerk regarding whether a hearing date is needed.)
2.
e. ~ Default was previously entered on
Judgment to be entered.
(date):
Amount Credits acknowled ed ~salnce
Demand of complaint* $ 2,974.89 $ 0.00 $ 2,974.89
b. Interest $ 0.00 $ 0.00 $ 0.00
c. Costs (see page 3) $ 276.00 $ 0.00 $ 276.00
d. Attorney fees $ 0.00 $ 0.00 $ 0.00
e. TOTALS $ 3,250.89 $ 0.00 $ 3,250.89
(* Must'e established by business records, authenticated through a sworn declaration, submitted with this application. (Civ.
Code, Q 1788.58(a)(4), 1788. 60(a).))
3. This action is not barred by the applicable statute of limitations (Civ. Code, g 1788.56),
4. Requirements for the complaint.
a. The complaint alleges ALL of the following (Civ. Code,
H 1788.58, 1?88.60):
(1) That the plaintiff is a debt buyer;
(2) A short, plainstatement regarding the nature of the underlying debt and the consumer transaction from which is
it
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
01/21/2020
the charge-off creditor, and the charge-off creditor's account number associated with
the debt;
Page 1 of 3
Form Adopted for Mandatory Use
REQUEST FOR ENTRY OF DEFAULT NADITA MASON Code of Civii Procedure, rI 585;
Judicial Council of California Civil Code, ti 1788.60
CIV-105 [New January 1, 2018] (Fair Debt Buying Practices Act) www. courts.ca.go|r
IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII
CIV-105
t't'o"erMIDLAND FUNDING LLC
CASE NUMBER:
Defendant/Respondent: CG C-19-577665
4. a. (7) The name and last known address of the debtor as they appeared inthe 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, g 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, induding for revolving credit accounts.
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: December 12, 2019
Christopher D. Mandarich SB 220693
{TYPE OR PRINT NAME) {SIGNATURE OF PLAiNTIFF OR ATTORNEY FOR PLAINTIFF)
Fpp COUp7
USE ONLY
(1)
(2)
~
~ Default entered as requested on (date):
Default NOT entered as requested(state reason):
Clerk, by , Deputy
6.
unlawful detainer assistant~
Legal document assistant or unlawful detainer assistant (Bus. & Prof. Code, Q 6400 et seq.). A legal document assistant or
did ~x 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., g 585.5 (for entry of default under Code Civ. Proc., $ 585(a)). This action
~x
a. ~ is~ is not sale for goods or services subject to Civ, Code, g 1801
on a contract or installment et seq. (Unruh Act).
b. ~ is ~x is not on a conditional sales contract subject to Civ. Code, g 2981
et seq. (Rees-Levering Motor Vehicle Sales
c. ~ is ~ and Finance Act).
is noton an obligation for goods, services, loans, or extensions of credit subject to Code Civ. Proc., g 395(b),
CIV-105 [New January 1, 2018]
REQUEST FOR ENTRY OF DEFAULT Page 2 of 3
(Fair Debt Buying Practices Act)
CIV-105
PlaintN/Petitioner: MIDLAND FUNDING LLC
CASE NUMBER:
DefendantlRespon ent TABU CG C-19-577665
BUGGS
8. Declaration of mailing (Code Civ. Proc., g 587). A copy of this Request for Entry of Default was
a.
b.
~
~x
not mailed to the following defendants, whose addresses are unknown to plaintiff or plaintiff s attorney (names):
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): (2) To (specify names and addresses shown on the envelopes):
TABU BUGGS
1391 GILMAN AVE
SAN FRANCISCO CA 94124
Ideclare 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:JAN y 6 )go
Assisat Alimi
(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. g 3911(2), or California Military and
Veterans Code section 400(b).
10. Memorandum of costs (requiredif moneyjudgment requested). Costs and disbursements are as follows (Code Civ. Proc.,
5 1033,5):
a. fees,
Clerk's filing $ 181.00
b. Process server's fees . $ 95.00
c. Other (specify): $
$
e. TOTAL
f.
g.
~
l
Costs and disbursements are waived.
$ 276.00
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,
ldeclare under penalty of perjury under the laws of the State of California that the foregoing items 9 and 10 are true and correct.
Date: December 12, 2019
Christopher D. Mandarich SB 220693
(TYPE OR PRINT NAME)
(SIGNATURE OF DECLARANT)
CIV-105 (New January 1, 2018)
REQUEST FOR ENTRY OF DEFAULT Page 3 of 3
(Fair Debt Buying Practices Act)
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DEFAULT ENTERED CIV-105 ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO AS REQUESTED FOR COURT USE ONLY NAME Christopher D. Mandarich SB 220693 FIRM NAME: M8nd8rich Lavr Group LLP 60610 sTREETADDREss: P.Q. Box 109032 Chicago, IL clTYChicago STATE:IL ZIP CODE:F)0611 ELECTRONICALLY TELEPHONE NO.:877 286 4g18 FAx No- 818-888-1260 F I L E D E-MAIL ADDRESS: Superior Court of California, MIDLAND FUNDING ATTQRNEY FOR(name): LLC FILE BY FAX County of San Francisco SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO 01/21/2020 Clerk of the Court MAILING ADDREss: 400 M CALLI STE R STRE ET BY: NADITA MASON coDE.SAN clTY AND zIP FRANCISCO CA 94102 Deputy Clerk " " " "CIVIC CENTER COURTHOUSE Plaintiff/Petitioner: IVIIDI AND FUNDING LL( sP " nt TABU BUGGS, an individua REQUEST FOR (Applicati») ~x Entry Df e aul ~ u"gmen CASE NUMBER CGC-19-577665 For use only in actions under the Fair Debt Buying Practices Act (Civ. Code, g 1788.50 et seq.) 1. On the complaint or cross-complaint filed a. on (date): 07/f16/f2p19 y(na C. d. ~ ~ I ):MIDLAND FUNDING LLC Enter default Of defendant (nameS): TABLI individual BLIGGS, an request a judgment under Civil Code section 1788.60 and Code of Civil Procedure section 585 against defendant (names): (Testimony may be required. Check with the clerk regarding whether a hearing date is needed.) 2. e. ~ Default was previously entered on Judgment to be entered. (date): Amount Credits acknowled ed ~salnce Demand of complaint* $ 2,974.89 $ 0.00 $ 2,974.89 b. Interest $ 0.00 $ 0.00 $ 0.00 c. Costs (see page 3) $ 276.00 $ 0.00 $ 276.00 d. Attorney fees $ 0.00 $ 0.00 $ 0.00 e. TOTALS $ 3,250.89 $ 0.00 $ 3,250.89 (* Must'e established by business records, authenticated through a sworn declaration, submitted with this application. (Civ. Code, Q 1788.58(a)(4), 1788. 60(a).)) 3. This action is not barred by the applicable statute of limitations (Civ. Code, g 1788.56), 4. Requirements for the complaint. a. The complaint alleges ALL of the following (Civ. Code, H 1788.58, 1?88.60): (1) That the plaintiff is a debt buyer; (2) A short, plainstatement regarding the nature of the underlying debt and the consumer transaction from which is it 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 01/21/2020 the charge-off creditor, and the charge-off creditor's account number associated with the debt; Page 1 of 3 Form Adopted for Mandatory Use REQUEST FOR ENTRY OF DEFAULT NADITA MASON Code of Civii Procedure, rI 585; Judicial Council of California Civil Code, ti 1788.60 CIV-105 [New January 1, 2018] (Fair Debt Buying Practices Act) www. courts.ca.go|r IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII CIV-105 t't'o"erMIDLAND FUNDING LLC CASE NUMBER: Defendant/Respondent: CG C-19-577665 4. a. (7) The name and last known address of the debtor as they appeared inthe 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, g 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, induding for revolving credit accounts. 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: December 12, 2019 Christopher D. Mandarich SB 220693 {TYPE OR PRINT NAME) {SIGNATURE OF PLAiNTIFF OR ATTORNEY FOR PLAINTIFF) Fpp COUp7 USE ONLY (1) (2) ~ ~ Default entered as requested on (date): Default NOT entered as requested(state reason): Clerk, by , Deputy 6. unlawful detainer assistant~ Legal document assistant or unlawful detainer assistant (Bus. & Prof. Code, Q 6400 et seq.). A legal document assistant or did ~x 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., g 585.5 (for entry of default under Code Civ. Proc., $ 585(a)). This action ~x a. ~ is~ is not sale for goods or services subject to Civ, Code, g 1801 on a contract or installment et seq. (Unruh Act). b. ~ is ~x is not on a conditional sales contract subject to Civ. Code, g 2981 et seq. (Rees-Levering Motor Vehicle Sales c. ~ is ~ and Finance Act). is noton an obligation for goods, services, loans, or extensions of credit subject to Code Civ. Proc., g 395(b), CIV-105 [New January 1, 2018] REQUEST FOR ENTRY OF DEFAULT Page 2 of 3 (Fair Debt Buying Practices Act) CIV-105 PlaintN/Petitioner: MIDLAND FUNDING LLC CASE NUMBER: DefendantlRespon ent TABU CG C-19-577665 BUGGS 8. Declaration of mailing (Code Civ. Proc., g 587). A copy of this Request for Entry of Default was a. b. ~ ~x not mailed to the following defendants, whose addresses are unknown to plaintiff or plaintiff s attorney (names): 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): (2) To (specify names and addresses shown on the envelopes): TABU BUGGS 1391 GILMAN AVE SAN FRANCISCO CA 94124 Ideclare 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:JAN y 6 )go Assisat Alimi (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. g 3911(2), or California Military and Veterans Code section 400(b). 10. Memorandum of costs (requiredif moneyjudgment requested). Costs and disbursements are as follows (Code Civ. Proc., 5 1033,5): a. fees, Clerk's filing $ 181.00 b. Process server's fees . $ 95.00 c. Other (specify): $ $ e. TOTAL f. g. ~ l Costs and disbursements are waived. $ 276.00 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, ldeclare under penalty of perjury under the laws of the State of California that the foregoing items 9 and 10 are true and correct. Date: December 12, 2019 Christopher D. Mandarich SB 220693 (TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT) CIV-105 (New January 1, 2018) REQUEST FOR ENTRY OF DEFAULT Page 3 of 3 (Fair Debt Buying Practices Act)