On January 29, 2020 a
Motion-Secondary
was filed
involving a dispute between
Wells Fargo Bank N.A,
and
Watson, Jeffrey S,
for Rule 3.740 Collections$10,000.01 - $25,000 Limited
in the District Court of San Bernardino County.
Preview
\I \r
Jon O. Blanda, Esq. 217222
Hanna Kerfan, Esq. 327122
IQ Collection at Law, Inc. :‘
fSiIJ‘PERis;
3835 East Thousand Oaks Blvd
.
£35 ,v
DJ Suite R.~349 '
j.
Westlake Village, CA 9 362
a
l
I—(818)—7l6-7630 NOV 1 9 2070
1-(81 8)-7 6—7775
I
Attorneys for Plaintiff
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
Wells Fargo Bank, N.A.,
Case No. C1VDSZOO291 2
Plaintiff,
PLAINTIFF’SDECLARATION IN
V. SUPPORT OF DEFAULT JUDGMENT
PURSUANT TO CCP 585
JEFFREY S WATSON
Dcfendant(s).
I, $0»wa Mu bMOM‘Qfi, declare as follows:
I. I am a Loan Adjuster of Wells Fargo Bank, NA. (“Wells Fargo”) and am authorized
on behalf of Wells Fargo. If called t0 testify, I would competently testify
to sign this declaration
under oath as to the following:
0f my job responsibiiities For
2. I am over the age of eighteen and as part
have personal knowledge ofand am familiar with the types ofrecords maintained by
Wells Fargo I
procedures for creating those types
Wells Fargo for the purpose 0f servicing credit accounts and the
0f records.
- 1
- JEFFREY S WATSON
************9881
Account Number Ending In
PLAINTIFF’S DECLARATION IN SUPPORT OF DEFAULT JUDGMENT PURSUANT TO CCP‘585
LG LCOEOOZ (02/2020)
V \y
5
3. The information in this declaration is taken from Wells Fargo’s business records.
ix)
The records are: (a) made at 0r near the time ofthe occurrence 0f the matters recorded by persons
b.)
with personal knowledge of the information in the business record, 0r from information transmitted
the course of Wells Fargo’s regularly
by persons with personal knowledge; and (b) kept in
conducted business activities. It is the regular practice of Wells Fargo t0 create and maintain such
records. In connection with making this declaration, I have acquired personal knowledge of the
matters stated herein by personally examining the business records relating t0 the account (the
"Account”) that is the subject 0fthe Complaint filed in this action.
*="**********9881
4. The above—referenced Defendant’s(s’) Account ending with
was opened on 12/29/2005. A true and correct COpy 0f the document evidencing the Account is
attached hereto as Exhibit A.
5. The Defendant(s) was/were extended credit 0n the Account.
6. The Defendant(s) made payments 0f principal and interest on the Account up and
through 07/05/2019, the last payment of which was for $390.00. Following this date, n0 further
payments were made on the Account, and a balance of $18,964.36 remains due and owing.
Attached hereto as Exhibit B is a true and correct copy 0f the statement of account which reflects
the last payment.
7. Wells Fargo sent the Defendant(s) statements of the Account each month. The
statements reflected the. balance fi‘om the previous month, all payments and credits made since the
last statement, along with any new activity since the prior statement. Additionally, the monthly
statement showed the interest rate for the Account, the calculation 0f the interest rate 0n the
balance, and the minimum payment which would be due and payable for that month. Attached
hereto as Exhibit C is a true and correct copy of the last statement 0f account which reflects the
balance due and owing 01°31 8,964.36.
8. Wells Fargo made demand for payment.
/././
/././
/././
- 2 — JEFFREY S WATSON
Account Number Ending In ************9881
PLAINTIFF’S DECLARATION IN SUPPORT OF DEFAULT JUDGMENT PURSUANT TO CCP 585
LGLCOEOOZ (02/2020)
Document Filed Date
November 19, 2020
Case Filing Date
January 29, 2020
Category
Rule 3.740 Collections$10,000.01 - $25,000 Limited
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\I \r Jon O. Blanda, Esq. 217222 Hanna Kerfan, Esq. 327122 IQ Collection at Law, Inc. :‘ fSiIJ‘PERis; 3835 East Thousand Oaks Blvd . £35 ,v DJ Suite R.~349 ' j. Westlake Village, CA 9 362 a l I—(818)—7l6-7630 NOV 1 9 2070 1-(81 8)-7 6—7775 I Attorneys for Plaintiff SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO Wells Fargo Bank, N.A., Case No. C1VDSZOO291 2 Plaintiff, PLAINTIFF’SDECLARATION IN V. SUPPORT OF DEFAULT JUDGMENT PURSUANT TO CCP 585 JEFFREY S WATSON Dcfendant(s). I, $0»wa Mu bMOM‘Qfi, declare as follows: I. I am a Loan Adjuster of Wells Fargo Bank, NA. (“Wells Fargo”) and am authorized on behalf of Wells Fargo. If called t0 testify, I would competently testify to sign this declaration under oath as to the following: 0f my job responsibiiities For 2. I am over the age of eighteen and as part have personal knowledge ofand am familiar with the types ofrecords maintained by Wells Fargo I procedures for creating those types Wells Fargo for the purpose 0f servicing credit accounts and the 0f records. - 1 - JEFFREY S WATSON ************9881 Account Number Ending In PLAINTIFF’S DECLARATION IN SUPPORT OF DEFAULT JUDGMENT PURSUANT TO CCP‘585 LG LCOEOOZ (02/2020) V \y 5 3. The information in this declaration is taken from Wells Fargo’s business records. ix) The records are: (a) made at 0r near the time ofthe occurrence 0f the matters recorded by persons b.) with personal knowledge of the information in the business record, 0r from information transmitted the course of Wells Fargo’s regularly by persons with personal knowledge; and (b) kept in conducted business activities. It is the regular practice of Wells Fargo t0 create and maintain such records. In connection with making this declaration, I have acquired personal knowledge of the matters stated herein by personally examining the business records relating t0 the account (the "Account”) that is the subject 0fthe Complaint filed in this action. *="**********9881 4. The above—referenced Defendant’s(s’) Account ending with was opened on 12/29/2005. A true and correct COpy 0f the document evidencing the Account is attached hereto as Exhibit A. 5. The Defendant(s) was/were extended credit 0n the Account. 6. The Defendant(s) made payments 0f principal and interest on the Account up and through 07/05/2019, the last payment of which was for $390.00. Following this date, n0 further payments were made on the Account, and a balance of $18,964.36 remains due and owing. Attached hereto as Exhibit B is a true and correct copy 0f the statement of account which reflects the last payment. 7. Wells Fargo sent the Defendant(s) statements of the Account each month. The statements reflected the. balance fi‘om the previous month, all payments and credits made since the last statement, along with any new activity since the prior statement. Additionally, the monthly statement showed the interest rate for the Account, the calculation 0f the interest rate 0n the balance, and the minimum payment which would be due and payable for that month. Attached hereto as Exhibit C is a true and correct copy of the last statement 0f account which reflects the balance due and owing 01°31 8,964.36. 8. Wells Fargo made demand for payment. /././ /././ /././ - 2 — JEFFREY S WATSON Account Number Ending In ************9881 PLAINTIFF’S DECLARATION IN SUPPORT OF DEFAULT JUDGMENT PURSUANT TO CCP 585 LGLCOEOOZ (02/2020)