On March 04, 2019 a
Memorandum (name extension) - Memorandum Memorandum of Case in Support of Request for Judgment
was filed
involving a dispute between
Unifund Ccr Llc As Assignee Of Distressed Asset Portfolio Iii Llc As Assignee Of Citibank N.A.,
and
Galvan Juan,
for Collections Case - Purchased Debt (Charged Off Consumer Debt Purchased on or after January 1,2014) (Limited Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 10/13/2020 06:29 AM Sherri R. Carter, Executive Officer/Clerk of Court, by J. De La Rosa,Deputy Clerk
Brian N. Winn (State Bar No. 86779)
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Laura M. Hoalst (State Bar No. 101082)
Jacky P. Wang (State Bar No. 222464)
Jason M. Burrows (State Bar No. 309882)
Cherrie Y. Tan (State Bar No. 324871)
Katrina Trinh (State Bar No. 327357)
Juan Villanueva (State Bar No. 328049)
Winn Law Group, A Professional Corporation -
110 E Wilshire Ave Ste 212, Fullerton CA 92832
Telephone: (714) 446-6686, Fax No.: (714) 446-6680
File No: 18—17974-0-CDG—KVP- (2020-01)
Attorneys for Plaintiff
SUPERIOR COURT OF CALIFORNIA
LOS ANGELES COUNTY, NORWALK DISTRICT
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UNIFUND CCR, LLC, as assignee of
DISTRESSED ASSET PORTFOLIO III, LLC, as Case No. 19NWLC08887
assignec of CITIBANK, N.A.,
Limited Civil Case
Plaintiff,
PLAINTIFF'S MEMORANDUM OF
vs. CASE IN SUPPORT OF REQUEST
FOR JUDGMENT
JUAN GALVAN, et al.,
Complaint Filed: 3/04/19
Defendant(s).
Plaintiff hereby applies to the Court for entry of a judgment in a limited civil collection
case. This memorandum:
1) summarizes the evidence presented in the declaration filed pursuant to
California Code of Civil Procedure section 585 (default judgment ) or section 98 (in lieu of
testimony at trial) and status of the case;
2) establishes that Plaintiff has standing to sue as the real party in interest and current
owner/assignee of the account;
3) verifies compliance with California Civil Code §l788.60 because the required
statement of the debt is attached as a business record, and authenticated in a sworn declaration of
Plaintiff’s employee. The legislative history of the statute clarifies a declaration from the original
Page 1
PLAINTIFF'S MEMORANDUM OF CASE ]N SUPPORT OF REQUEST FOR JUDGMENT
Document Filed Date
October 13, 2020
Case Filing Date
March 04, 2019
Category
Collections Case - Purchased Debt (Charged Off Consumer Debt Purchased on or after January 1,2014) (Limited Jurisdiction)
Status
Default Judgment By Court - Before Trial
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