Complaint,Petition: CAVALRY SPV I LLC AS ASSIGNEE OF DEPARTMENT STORES NATIONAL BANK VS LARRY MOORE, AN INDIVIDUAL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 01/02/2020 03:47 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Van,Deputy Clerk

                                                                               20NWLC00068
                                Assigned for all purposes to: Norwalk Courthouse, Judicial Officer: Lillian Vega Jacobs




       1      Christopher D. Mandarich SB 220693
              Christine S. Siduguen SB240380
       2      Gissela Arrincon-Tepeli SB309803
              Amber Swearingen-Ojuri SB324653
       3      MANDARICH LAW GROUP, LLP
              P.O. Box 109032 Chicago, IL 60610
       4      Phone: 877.285.4918
              Facsimile: 818-888-1260
       5      Attorneys for Plaintiff: Cavalry SPV I, LLC
       6                               SUPERIOR COURT OF THE STATE OF CALIFORNIA
       7                             IN AND FOR THE COUNTY OF LOS ANGELES - LIMITED

       8        CAVALRY SPV I, LLC, AS ASSIGNEE OF                                                 Case No.
                DEPARTMENT STORES NATIONAL BANK,
       9        Plaintiff,                                                                         COMPLAINT FOR:

     10         vs.                                                                                1. ACCOUNT STATED
                                                                                                   2. OPEN BOOK ACCOUNT
     11         LARRY MOORE, an individual;
     12         and DOES 1 through 10 inclusive.
                      Defendant.                                                                 DEMAND: $3,041.61
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              Plaintiff alleges:
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                                             FACTS COMMON TO ALL CAUSES OF ACTION
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                         1.Plaintiff is and at all times herein mentioned, CAVALRY SPV I, LLC, AS ASSIGNEE
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              OF DEPARTMENT STORES NATIONAL BANK, and successor in interest to original creditor,
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              Department Stores National Bank.
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                         2.Plaintiff is the only entity that purchased the debt after charge-off and its name and
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              address is as follows: CAVALRY SPV I, LLC, AS ASSIGNEE OF DEPARTMENT STORES
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              NATIONAL BANK 500 Summit Lake Drive Valhalla NY 10595.
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                         3.Plaintiff is a debt buyer, and is the sole owner of the debt at issue.
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                         4.The charge-off creditor at the time of charge-off is DEPARTMETN STORES
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              NATIONAL BANK and CITIBANK, N.A., 701 E 60TH ST NORTH SIOUX FALLS, SD 57117,
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     26       and the account number associated with this debt is XXXXXXXX4290.

     27                  5.Plaintiff is informed and believes that Defendant are individuals who currently reside

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