On February 07, 2022 a
Complaint,Petition
was filed
involving a dispute between
Lobel Financial Corp.,
and
Bello, Jovanni,
Does 1-10,
for Rule 3.740 Collections$10,000.01 - $25,000 Limited
in the District Court of San Bernardino County.
Preview
GARY DEAN LOBEL CBN 105983 \
F 5 uogom
RONALD J- GREEN JR- CBN 177043 SUPER|0RCOURT0FCALIFORNm
SHIAo—WEN HUANG CBN 211357 COUNTY 0F SAN BERNARDINO
SANBERNARDWKDDBTRET
1150 N. MAGNOLIA AVE.
ANAHEIM, CA 92801-2605
(714) 995-3333 FEB O7 2022
Attorneys for Plaintiff, M;
LOBEL FINANCIAL CORPORATION
SUPERIOR COURT OF CALIFORNIA
SAN BERNARDINO JUSTICE CENTER
lO
ll
LOBEL FINANCIAL CORP., Case No. CIV SB 2 Z 0 3 1 85
a California Corporation,
12 Complaint for Money; Account Stated
Plaintiff, and Open Book Account
l3 vs.
(Collection rule 3.740)
l4 JOVANNI BELLO
vvvvvvvvvvvvvvvvv
Demand is for $10,830.43
15
16
Limited Civil
Does l to 10
l7
l8 Defendant(s)
l9
Plaintiff complains and alleges as follows:
20
1. At all times herein mentioned Plaintiff was and now is a corporation
21
duly organized and existing under and by virtue of the laws of the State of
22
California.
23
2. The true names of Defendants Does l to 10, are unknown to Plaintiff and
24
they are therefore sued herein under the foregoing names, which are fictitious,
25
and upon ascertaining their names, leave will be asked to amend this complaint by
26
inserting the same.
27
3. Each Defendant named above is a natural person.
28
Complaint for Money
-1-
Lo hel
Financial
Corporation
« -
v \a
CIVSB 220313?
4. This action is subject to Civil Code Section 2984.4.
5. This action is filed in this judicial district because the Defendant(s)
entered into the contract here.
First Cause of Action
Breach of Contract
6. Plaintiff realleges paragraphs l through 5 as those fully set
forth herein.
7. On or about November 24, 2020 a written agreement was made between
Subsequent
Jordan Auto Wholesales, Inc. as seller and Jovanni Bello as buyer(s).
to the execution thereof, the said agreement was for valuable consideration sold,
lO
is now the
assigned and transferred to Plaintiff by said seller and Plaintiff
ll
holder thereof.
l2
in the
8. Pursuant to the terms of the written agreement referenced above
13
a(n) 12 DODGE
previous paragraph, said seller sold and delivered to Defendant(s)
l4
of $27,576.72 payable in
DURANGO, VIN No. 1C4SDHCT7CC188245 for a contract balance
15
2020.
monthly installments of $510.68 commencing December 24,
16
l7 agreement by
9 On or about May 24, 2021 Defendant(s) breached the
18 the terms of the
failing to make further payments to Plaintiff pursuant to
l9 repossessed
written agreement previously agreed to. Plaintiff thereafter
2O
seeks to recover for
and sold the vehicle pursuant to the Civil Code, and
21
the deficiency balance.
22 except those
10. Plaintiff has performed all obligations to Defendant(s)
23 performing.
obligations Plaintiff was prevented or excused from
24
breach of the
11. Plaintiff suffered damages legally caused by Defendant(s)
25
agreement in the amount of $10,830.43.
26
27
28
Complaint for Money
-2-
Lobel
Financial
Corporation
Document Filed Date
February 07, 2022
Case Filing Date
February 07, 2022
Category
Rule 3.740 Collections$10,000.01 - $25,000 Limited
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Preview
GARY DEAN LOBEL CBN 105983 \ F 5 uogom RONALD J- GREEN JR- CBN 177043 SUPER|0RCOURT0FCALIFORNm SHIAo—WEN HUANG CBN 211357 COUNTY 0F SAN BERNARDINO SANBERNARDWKDDBTRET 1150 N. MAGNOLIA AVE. ANAHEIM, CA 92801-2605 (714) 995-3333 FEB O7 2022 Attorneys for Plaintiff, M; LOBEL FINANCIAL CORPORATION SUPERIOR COURT OF CALIFORNIA SAN BERNARDINO JUSTICE CENTER lO ll LOBEL FINANCIAL CORP., Case No. CIV SB 2 Z 0 3 1 85 a California Corporation, 12 Complaint for Money; Account Stated Plaintiff, and Open Book Account l3 vs. (Collection rule 3.740) l4 JOVANNI BELLO vvvvvvvvvvvvvvvvv Demand is for $10,830.43 15 16 Limited Civil Does l to 10 l7 l8 Defendant(s) l9 Plaintiff complains and alleges as follows: 20 1. At all times herein mentioned Plaintiff was and now is a corporation 21 duly organized and existing under and by virtue of the laws of the State of 22 California. 23 2. The true names of Defendants Does l to 10, are unknown to Plaintiff and 24 they are therefore sued herein under the foregoing names, which are fictitious, 25 and upon ascertaining their names, leave will be asked to amend this complaint by 26 inserting the same. 27 3. Each Defendant named above is a natural person. 28 Complaint for Money -1- Lo hel Financial Corporation « - v \a CIVSB 220313? 4. This action is subject to Civil Code Section 2984.4. 5. This action is filed in this judicial district because the Defendant(s) entered into the contract here. First Cause of Action Breach of Contract 6. Plaintiff realleges paragraphs l through 5 as those fully set forth herein. 7. On or about November 24, 2020 a written agreement was made between Subsequent Jordan Auto Wholesales, Inc. as seller and Jovanni Bello as buyer(s). to the execution thereof, the said agreement was for valuable consideration sold, lO is now the assigned and transferred to Plaintiff by said seller and Plaintiff ll holder thereof. l2 in the 8. Pursuant to the terms of the written agreement referenced above 13 a(n) 12 DODGE previous paragraph, said seller sold and delivered to Defendant(s) l4 of $27,576.72 payable in DURANGO, VIN No. 1C4SDHCT7CC188245 for a contract balance 15 2020. monthly installments of $510.68 commencing December 24, 16 l7 agreement by 9 On or about May 24, 2021 Defendant(s) breached the 18 the terms of the failing to make further payments to Plaintiff pursuant to l9 repossessed written agreement previously agreed to. Plaintiff thereafter 2O seeks to recover for and sold the vehicle pursuant to the Civil Code, and 21 the deficiency balance. 22 except those 10. Plaintiff has performed all obligations to Defendant(s) 23 performing. obligations Plaintiff was prevented or excused from 24 breach of the 11. Plaintiff suffered damages legally caused by Defendant(s) 25 agreement in the amount of $10,830.43. 26 27 28 Complaint for Money -2- Lobel Financial Corporation