On June 08, 2023 a
Complaint,Petition
was filed
involving a dispute between
Citibank, N.A.,
and
Salazar, Monique D,
for Rule 3.740 Collections $10,000 or Less Limited
in the District Court of San Bernardino County.
Preview
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PLD-C-001
ATTORNEY 0R PARTY VWTHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Hunt & Henriques, LLP
Donald Sherri” #266038 | |
VWIliam Bliss #341046
7017 Realm Drive
.
San Jose CA 951 1 9. F l L E;
"‘”
CA Debt Collectlon Llcense No. t
10136—99
SUPERIOR coum c:r aLFORMA
COUNTY OF SAN BERNARDINO
TELEPHONE N0: (800) 680—2426 FAX No. (Optionao; (408) 362—2299
SAN BER"—’T~RD"~-O DISTRICT
E-MAILADDRESS (Optional):
ATrORNEY FOR
STREET ADDRESS-
MAILING ADDRESS:
CITY AND ZIP CODE:
BRANCH NAME:
(Name):
,
Plaintiff
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
247 West Third
San Bernardino CA 92415-0210
Str ee‘
A
By
"‘
Jhelsea Nuss
JUN U 82023
W _‘
wean ‘y'
San Bernardino
FM
District—Civil Division
pLAmTIFF: CITIBANK, N.A. U}
DEFENDANT: MONIQUE D SALAZAR
E
y
E DOES 1 To
CONTRACT
E] COMPLAINT E AMENDED COMPLAINT (Number):
E CRoss—COMPLAINT E AMENDED CRoss-COMPLAINT (Number):
E
Jurisdiction (check all that apply):
ACTION Is A LIMITED CIVIL CASE
Amount demanded does not exceed m $7,248.04
CASE ”UMBER:
$1 0,000 Is
D ACTION Is AN UNLIMITED
exceeds $10,000, but does not exceed $25,000
CIVIL
(exceeds $25,000) CASE
2 3 \ 3 \
l
gfi
5'
ACTION
E IS RECLASSIFIED by this amended complaint or cross-complaint
C‘V 88
from limited to unlimited
from unlimited to limited
1. Plaintiff* (name ornames): CITIBANK, N.A.
alleges causes of action against defendant* (name or names): MONIQUE D SALAZAR
2. This pleading, including attachments and exhibits, consists ofthe following number of pages: 4
3. a. Each plaintiff named above is a competent adult
except (name): CITIBANK, N.A.
(1) E
E
plaintiff
a corporation qualified to do business in California
(2)
(3) m an unincorporated
other (specify): A
entity (describe):
National Banking Association organized and existing under and by virtue of the laws of the
b. EE
a.
Plaintiff (name):
has complied with the
United States of America
fictitious business name laws and is doing business under the fictitious name of (specify):
c. EE
b. has complied with
Information about additional plaintiffs
all licensing requirements as a licensed (specify):
who are not competent adults is shown in Attachment 3c.
4. a.
E E
Each defendant named above is a
except defendant (name):
natural person
except defendant (name):
E
D
E
(1)
(2)
(3)
a business organization, form unknown
a corporation
an unincorporated entity (describe):
(1)
(2)
(3)
E
E
a business organization, form
a corporation
an unincorporated
unknown
entity (describe):
E (4) a public entity (describe): (4) E a public entity (describe):
E (5) other (specify): (5) E other (specify):
*If this form is used as a cross-complaint, plaintiff means cross~complainant and defendant means cross-defendant. Page 1 of 2
FOSTd/igrg‘éflgrogg'aonrffrlnlijase
COMPLAINT—ContraCt Code of Civn Procedure, § 425.12
ImmImummnumummumlmmnmmmum
4 .
1 - .
I
PLD-C-OO1
SHORT TITLE: CITIBANK, N.A. v. MONIQUE D SALAZAR CASE NUMBER:
CIVSB 23131“
4. (Continued)
b. The true names of defendants sued as Does are unknown to plaintiff.
E
(1) Doe defendants (specify Doe numbers):
defendants and acted within the scope of that agency or employment.
were the agents or employees of the named
E
(2) Doe defendants
plaintiff.
(specify Doe numbers): are persons whose capacities are unknown to
c.
d.
E
E Information about additional defendants
Defendants who are joined under Code
who are natural persons
of Civil Procedure section
iscontained in Attachment
382 are (names):
4c.
5. E E Plaintiff is required to comply with a claims statute, and
has complied with applicable claims statutes, or
E a.
b. is excused from complying because (specify):
6. I: This action is subject to E Civil Code section 1812.10 E Civil Code section 2984.4.
7. This court is the proper court because
a defendant entered into the contract here.
a defendant lived here when the contract was entered into.
a defendant lives here now.
Eifiiéifi the contract was to be performed here.
a defendant is a corporation or unincorporated association and its principal place of business is here.
real propeny that is the subject of this action is located here.
other (specify):
8. The following causes of action are attached and the statements above apply to each (each complaint must have one or
more causes of action attached):
E Breach of Contract
E Common Counts
E Other (specify):
9. m Other allegations: On
and
July
is
1, 2022, Citibank, N.A, became the successor by merger to Department Stores National Bank
the current owner of this Macy's American Express Card branded credit account and all rights
to pursue collection from Defendant.
10. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for
a. [E damages $7,248.04 of:
[E interest on the damages
b.
E
m (1) according to the proof
c. E E (2)
attorney‘s fees
(1)
at the rate of (specify):
of: $
0.0000 percent per year from (date): February 20, 2023
d. E E] (2)
other (specify):
according to proof.
11. The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers):
CC-1.a.(1), CC-1.a.(2), CC-1.b.(4), CC-1.b.(5)
Date: May 25, 2023
William Bliss #341 046 //
’
(TYPE OR PRINT NAME) (SIGNATURE OVQINTIFF OR ATTORNEY)
(If you wish to ven'fy this pleading, affix a verification.)
PLD»c-oo1 [Rev January 1, 2007] COMPLAINT—Contract Page 2 of 2
1520160001
Document Filed Date
June 08, 2023
Case Filing Date
June 08, 2023
Category
Rule 3.740 Collections $10,000 or Less Limited
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' ‘ o ‘ o PLD-C-001 ATTORNEY 0R PARTY VWTHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Hunt & Henriques, LLP Donald Sherri” #266038 | | VWIliam Bliss #341046 7017 Realm Drive . San Jose CA 951 1 9. F l L E; "‘” CA Debt Collectlon Llcense No. t 10136—99 SUPERIOR coum c:r aLFORMA COUNTY OF SAN BERNARDINO TELEPHONE N0: (800) 680—2426 FAX No. (Optionao; (408) 362—2299 SAN BER"—’T~RD"~-O DISTRICT E-MAILADDRESS (Optional): ATrORNEY FOR STREET ADDRESS- MAILING ADDRESS: CITY AND ZIP CODE: BRANCH NAME: (Name): , Plaintiff SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO 247 West Third San Bernardino CA 92415-0210 Str ee‘ A By "‘ Jhelsea Nuss JUN U 82023 W _‘ wean ‘y' San Bernardino FM District—Civil Division pLAmTIFF: CITIBANK, N.A. U} DEFENDANT: MONIQUE D SALAZAR E y E DOES 1 To CONTRACT E] COMPLAINT E AMENDED COMPLAINT (Number): E CRoss—COMPLAINT E AMENDED CRoss-COMPLAINT (Number): E Jurisdiction (check all that apply): ACTION Is A LIMITED CIVIL CASE Amount demanded does not exceed m $7,248.04 CASE ”UMBER: $1 0,000 Is D ACTION Is AN UNLIMITED exceeds $10,000, but does not exceed $25,000 CIVIL (exceeds $25,000) CASE 2 3 \ 3 \ l gfi 5' ACTION E IS RECLASSIFIED by this amended complaint or cross-complaint C‘V 88 from limited to unlimited from unlimited to limited 1. Plaintiff* (name ornames): CITIBANK, N.A. alleges causes of action against defendant* (name or names): MONIQUE D SALAZAR 2. This pleading, including attachments and exhibits, consists ofthe following number of pages: 4 3. a. Each plaintiff named above is a competent adult except (name): CITIBANK, N.A. (1) E E plaintiff a corporation qualified to do business in California (2) (3) m an unincorporated other (specify): A entity (describe): National Banking Association organized and existing under and by virtue of the laws of the b. EE a. Plaintiff (name): has complied with the United States of America fictitious business name laws and is doing business under the fictitious name of (specify): c. EE b. has complied with Information about additional plaintiffs all licensing requirements as a licensed (specify): who are not competent adults is shown in Attachment 3c. 4. a. E E Each defendant named above is a except defendant (name): natural person except defendant (name): E D E (1) (2) (3) a business organization, form unknown a corporation an unincorporated entity (describe): (1) (2) (3) E E a business organization, form a corporation an unincorporated unknown entity (describe): E (4) a public entity (describe): (4) E a public entity (describe): E (5) other (specify): (5) E other (specify): *If this form is used as a cross-complaint, plaintiff means cross~complainant and defendant means cross-defendant. Page 1 of 2 FOSTd/igrg‘éflgrogg'aonrffrlnlijase COMPLAINT—ContraCt Code of Civn Procedure, § 425.12 ImmImummnumummumlmmnmmmum 4 . 1 - . I PLD-C-OO1 SHORT TITLE: CITIBANK, N.A. v. MONIQUE D SALAZAR CASE NUMBER: CIVSB 23131“ 4. (Continued) b. The true names of defendants sued as Does are unknown to plaintiff. E (1) Doe defendants (specify Doe numbers): defendants and acted within the scope of that agency or employment. were the agents or employees of the named E (2) Doe defendants plaintiff. (specify Doe numbers): are persons whose capacities are unknown to c. d. E E Information about additional defendants Defendants who are joined under Code who are natural persons of Civil Procedure section iscontained in Attachment 382 are (names): 4c. 5. E E Plaintiff is required to comply with a claims statute, and has complied with applicable claims statutes, or E a. b. is excused from complying because (specify): 6. I: This action is subject to E Civil Code section 1812.10 E Civil Code section 2984.4. 7. This court is the proper court because a defendant entered into the contract here. a defendant lived here when the contract was entered into. a defendant lives here now. Eifiiéifi the contract was to be performed here. a defendant is a corporation or unincorporated association and its principal place of business is here. real propeny that is the subject of this action is located here. other (specify): 8. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): E Breach of Contract E Common Counts E Other (specify): 9. m Other allegations: On and July is 1, 2022, Citibank, N.A, became the successor by merger to Department Stores National Bank the current owner of this Macy's American Express Card branded credit account and all rights to pursue collection from Defendant. 10. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. [E damages $7,248.04 of: [E interest on the damages b. E m (1) according to the proof c. E E (2) attorney‘s fees (1) at the rate of (specify): of: $ 0.0000 percent per year from (date): February 20, 2023 d. E E] (2) other (specify): according to proof. 11. The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers): CC-1.a.(1), CC-1.a.(2), CC-1.b.(4), CC-1.b.(5) Date: May 25, 2023 William Bliss #341 046 // ’ (TYPE OR PRINT NAME) (SIGNATURE OVQINTIFF OR ATTORNEY) (If you wish to ven'fy this pleading, affix a verification.) PLD»c-oo1 [Rev January 1, 2007] COMPLAINT—Contract Page 2 of 2 1520160001