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1 REESE LAW GROUP
D. Wilson Jordan, Esq., Bar #279959
2 3168 Lionshead Ave
3 Carlsbad CA 92010 ELECTRONICALLY
7601842-5850 F I L E D
4 Attorneys for Plaintiff, Superior Court of California,
County of San Francisco
Wells Fargo Bank, N.A.
5 01/11/2022
Clerk of the Court
BY: STACY GEE
6 Deputy Clerk
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8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
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SAN FRANCISCO DISTRICT
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Wells Fargo Bank, N.A. Case No. CGC-19-574399
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Plaintiff, DECLARATION PURSUANT TO 1033(b)
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V.
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ELINA M BACKALLY LEVY
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Defendants.
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16 I,D. Wilson Jordan,, Esq., declare as follows:
17 1. I am an attorney licensed to practice before all of the Courts of the State of California.
18 I am an attorney with the law firm of Reese Law Group, A Professional Law Corporation, the
19 attorneys of record for the Plaintiff herein. I have been primarily responsible for monitoring and
20 prosecuting this action on behalf of the Plaintiff. This Declaration is offered in support of Plaintiff's
21 request for Court Judgment to include Plaintiff's costs pursuant to C.C.P. §1033. All of the facts
22 set-forth below are known to me personally. If called upon to testify to the truth thereof, I could and
23 would be willing to do so.
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Declaration Pursuant to 1033(b)
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1 2. Plaintiff could not have brought the action within small claims court because itis a
2 corporate entity, represented by counsel. Pursuant to C.C.P. §1033(b )(2), Plaintiff is limited to the
3 actual cost of the filing fee, the actual cost of service of process, and when allowed by law,
4 reasonable attorney fees.
5 3. On January 18, 2019, pursuant to C.C.P. §1033(b)(2), a demand letter was mailed to
6 defendant. This letter informed the defendant of the intended legal action and the potential liability
7 for plaintiff's costs. A true and accurate copy of this demand letter is attached hereto and labeled
8 as Exhibit "A".
9 I declare under penalty of perjury under the laws of the State of California that th
10 foregoing is true and correct. Executed on this _ _8/3/2020_, at Carlsbad, California
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D. Wilson Jordan, Esq.
13 Attorney for Plaintiff
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Declaration Pursuant to 1033(b)
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EXHlBITA
REESE LAW GROUP
Harlan M Breanne L. Reese, FEsq.
Joseph M. Pleasant,
A Professional Law Corporation Go/naz Heidari, Esq
James E Delaney, 3168 Uonshead Avenue Shiv Samtani, Esq.
Jenny R. Loura, Esq Carlsbad, CA 92010
Telephone: (760) 842-5850
Facsimile: (760) 842-5865
January 18, .2019
EUNA M BACKALLY LEVY Re: Wells Fargo Bank, NA
50 LUPINE AVE APT 7 Our File Number: 560627
SAN FRANCISCO CA 94118-2792 Clafm: $8,303.01
Account Number Ending: 1124
Dear EUNA M BACKAI..LY LEVY;
Ttiis law firm re.presents Wells Fargo Bank, NA . Your file was forwarded to us for collection. The amount of your
debt you owe to Welts Fargo Bank, NA rs $8,303.07, Please note that If a lawsuit is initiated to collect the claim
amount, and if our client prevails, a Judgment may be entered against you which may include not only the principal
amount but also the cost of filing the lawsuit, the cost of serving the lawsuit and, when allowed by law, reasonable
attorney's fees. We urge you to contact Bianca Gutierrez, Ext .248, a non-attorney collection assistant.
This Communication is from a Debt Collector
IMPORTANT LEGAL NOTICE
FEDERAL .NOTICE
Unless you notify us, within 30 days after receipt of this notice, that you dispute the
validity of this debt or any portion thereof. the debt will be assumed to be valid. If you
notify us, in writing, within the 30 day period, that the debt or portion thereof, is disputed,
We will obtain verification of the debt or obtain a copy of the judgment against you and
a copy of such verification of the debt or Judgment will be mailed to you. If you notify us,
in writing, within 30 days following receipt of this notice, we will also provide you with
the name and address of the original creditor, if different from the current creditor. This
letter is an attempt to collect a debt and any information obtained will be used for that
purpose,
CALIFORNIA NOTICE
The state Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt
Collection Practices Act require that, except under unusual circumstances, collectors
may not contact you before 8 a.m. or after 9 p.m. They may not ha.rass you by using
threats ofviolence or arrest or by using obscene language. Collectors may not use false
or .misleading statements or call you at work if they know or have reason to know that
you may not receive personal calls at work. For the most part, collectors may not ten
another person, other than your atto.rney or spouse; about your debt. Collectors may
conta.ct another person to confirm your location or enfo.rce a judgment, For more
information about debt coll.ection activities, you may contact the Federal Trade
Commission at 1~877~FTC ..HELP or www.ftc.gov.
DWF100A
Preview
1 REESE LAW GROUP D. Wilson Jordan, Esq., Bar #279959 2 3168 Lionshead Ave 3 Carlsbad CA 92010 ELECTRONICALLY 7601842-5850 F I L E D 4 Attorneys for Plaintiff, Superior Court of California, County of San Francisco Wells Fargo Bank, N.A. 5 01/11/2022 Clerk of the Court BY: STACY GEE 6 Deputy Clerk 7 8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO 9 SAN FRANCISCO DISTRICT 10 Wells Fargo Bank, N.A. Case No. CGC-19-574399 11 Plaintiff, DECLARATION PURSUANT TO 1033(b) 12 V. 13 ELINA M BACKALLY LEVY 14 Defendants. 15 16 I,D. Wilson Jordan,, Esq., declare as follows: 17 1. I am an attorney licensed to practice before all of the Courts of the State of California. 18 I am an attorney with the law firm of Reese Law Group, A Professional Law Corporation, the 19 attorneys of record for the Plaintiff herein. I have been primarily responsible for monitoring and 20 prosecuting this action on behalf of the Plaintiff. This Declaration is offered in support of Plaintiff's 21 request for Court Judgment to include Plaintiff's costs pursuant to C.C.P. §1033. All of the facts 22 set-forth below are known to me personally. If called upon to testify to the truth thereof, I could and 23 would be willing to do so. 24 Ill 25 26 27 28 Declaration Pursuant to 1033(b) 1 1 2. Plaintiff could not have brought the action within small claims court because itis a 2 corporate entity, represented by counsel. Pursuant to C.C.P. §1033(b )(2), Plaintiff is limited to the 3 actual cost of the filing fee, the actual cost of service of process, and when allowed by law, 4 reasonable attorney fees. 5 3. On January 18, 2019, pursuant to C.C.P. §1033(b)(2), a demand letter was mailed to 6 defendant. This letter informed the defendant of the intended legal action and the potential liability 7 for plaintiff's costs. A true and accurate copy of this demand letter is attached hereto and labeled 8 as Exhibit "A". 9 I declare under penalty of perjury under the laws of the State of California that th 10 foregoing is true and correct. Executed on this _ _8/3/2020_, at Carlsbad, California 11 12 D. Wilson Jordan, Esq. 13 Attorney for Plaintiff 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration Pursuant to 1033(b) 2 EXHlBITA REESE LAW GROUP Harlan M Breanne L. Reese, FEsq. Joseph M. Pleasant, A Professional Law Corporation Go/naz Heidari, Esq James E Delaney, 3168 Uonshead Avenue Shiv Samtani, Esq. Jenny R. Loura, Esq Carlsbad, CA 92010 Telephone: (760) 842-5850 Facsimile: (760) 842-5865 January 18, .2019 EUNA M BACKALLY LEVY Re: Wells Fargo Bank, NA 50 LUPINE AVE APT 7 Our File Number: 560627 SAN FRANCISCO CA 94118-2792 Clafm: $8,303.01 Account Number Ending: 1124 Dear EUNA M BACKAI..LY LEVY; Ttiis law firm re.presents Wells Fargo Bank, NA . Your file was forwarded to us for collection. The amount of your debt you owe to Welts Fargo Bank, NA rs $8,303.07, Please note that If a lawsuit is initiated to collect the claim amount, and if our client prevails, a Judgment may be entered against you which may include not only the principal amount but also the cost of filing the lawsuit, the cost of serving the lawsuit and, when allowed by law, reasonable attorney's fees. We urge you to contact Bianca Gutierrez, Ext .248, a non-attorney collection assistant. This Communication is from a Debt Collector IMPORTANT LEGAL NOTICE FEDERAL .NOTICE Unless you notify us, within 30 days after receipt of this notice, that you dispute the validity of this debt or any portion thereof. the debt will be assumed to be valid. If you notify us, in writing, within the 30 day period, that the debt or portion thereof, is disputed, We will obtain verification of the debt or obtain a copy of the judgment against you and a copy of such verification of the debt or Judgment will be mailed to you. If you notify us, in writing, within 30 days following receipt of this notice, we will also provide you with the name and address of the original creditor, if different from the current creditor. This letter is an attempt to collect a debt and any information obtained will be used for that purpose, CALIFORNIA NOTICE The state Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt Collection Practices Act require that, except under unusual circumstances, collectors may not contact you before 8 a.m. or after 9 p.m. They may not ha.rass you by using threats ofviolence or arrest or by using obscene language. Collectors may not use false or .misleading statements or call you at work if they know or have reason to know that you may not receive personal calls at work. For the most part, collectors may not ten another person, other than your atto.rney or spouse; about your debt. Collectors may conta.ct another person to confirm your location or enfo.rce a judgment, For more information about debt coll.ection activities, you may contact the Federal Trade Commission at 1~877~FTC ..HELP or www.ftc.gov. DWF100A