On August 29, 2022 a
Complaint,Petition
was filed
involving a dispute between
Onemain Financial Group, Llc,
and
Does 1 To 10, Inclusive,
Manzo, Baltazar Victoriano,
for Rule 3.740 Collections $10,000 or Less Limited
in the District Court of San Bernardino County.
Preview
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File No. 22—11584-0
Robert Scott Kennard AU52-92022
State Bar No. 11701] '
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NELSON & KENNARD 5y L331¢mkx {EyqjaL
5011 Dudley Blvd., Bldg. 250, Bay G "‘"”““”"“‘“““EE;U$;
McClellan, CA 9565§
P.O. Box 13807 y
Sacramento, CA 95853
Telephone: (916) 920—2295
Facsimile: (916) 320—0682
Attorneys for Plaintiff
OneMain Financial Group, LLC
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
10 SAN BERNARDINO DISTRICT - LIMITED CIVIL CASE
11
OneMain Financial Group, LLC CASE NOCIV SB 2 2 1 8 1
{,3
12
Plaintiff, COMPLAINT FOR BREACH OF
13 PROMISSORY NOTE, OPEN BOOK
vs. ACCOUNT AND ACCOUNT STATED
14
BALTAZAR VICTORIANO MANZO (Complaint Demand: $8,497.86)
15
and DOES 1 to 10, Inclusive,
16 6
Defendanfis.
17
18
Plaintiff alleges and complains as follows:
19
20 ,e I PRELIMINARY ALLEGATIONS
21
1. Plaintiff is, and at all times herein mentioned was, a
22
lawfully organized and existing corporation or limited liability
23
company, duly authorized and existing under and by virtue of the
24
laws of the State 0% California.
25
26 2. Plaintiff‘alleges that it is qualified to do business in
27 the State of Califdrnia. Plaintiff’s counsel’s application for
28 license pursuant to Financial Code Section 100000 et. seq. is
l
COMPLAINT
pending issuance with the Nationwide Multistate Licensing and
Registry and/or the California Department of Financial Protection
and Innovation.
3. Plaintiff is informed and believes that Defendant resided
within this jurisdiction and venue at the time of the commencement
of the within actiog or, alternatively, entered into the promissory
note agreement which is the subject of this action in this
jurisdiction and venue.
10 4. The true names of Defendants sued herein as Does 1 to 10
11
are currently unknown to Plaintiff and therefore Plaintiff sues such
12
Defendants by such fictitious names. Plaintiff will seek leave to
13
amend its Complaint at such time as the true names and identities of
14
such Doe Defendants and their capacities are ascertained.
15
16
5. Prior to commencement of this action, the Defendant was
17 informed in writingjthat if an action were commenced Plaintiff may
18 be entitled to recover its court costs and/or its attorney’s fees
19
where allowed by law in addition to the balance on the note
20
otherwise owed.
21
6. At all times herein relevant, ONEMAIN FINANCIAL GROUP, LLC
22
was and is theVduly authorized and appointed servicing agent for
23
24
Plaintiff.
25 FIRST CAUSE OF ACTION
(Breach of Promissory Note)
26
27
28
2
COMPLAINT
Document Filed Date
August 29, 2022
Case Filing Date
August 29, 2022
Category
Rule 3.740 Collections $10,000 or Less Limited
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F5 Risa} w l§uaawon fififlfififiafigk— File No. 22—11584-0 Robert Scott Kennard AU52-92022 State Bar No. 11701] ' fl NELSON & KENNARD 5y L331¢mkx {EyqjaL 5011 Dudley Blvd., Bldg. 250, Bay G "‘"”““”"“‘“““EE;U$; McClellan, CA 9565§ P.O. Box 13807 y Sacramento, CA 95853 Telephone: (916) 920—2295 Facsimile: (916) 320—0682 Attorneys for Plaintiff OneMain Financial Group, LLC SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO 10 SAN BERNARDINO DISTRICT - LIMITED CIVIL CASE 11 OneMain Financial Group, LLC CASE NOCIV SB 2 2 1 8 1 {,3 12 Plaintiff, COMPLAINT FOR BREACH OF 13 PROMISSORY NOTE, OPEN BOOK vs. ACCOUNT AND ACCOUNT STATED 14 BALTAZAR VICTORIANO MANZO (Complaint Demand: $8,497.86) 15 and DOES 1 to 10, Inclusive, 16 6 Defendanfis. 17 18 Plaintiff alleges and complains as follows: 19 20 ,e I PRELIMINARY ALLEGATIONS 21 1. Plaintiff is, and at all times herein mentioned was, a 22 lawfully organized and existing corporation or limited liability 23 company, duly authorized and existing under and by virtue of the 24 laws of the State 0% California. 25 26 2. Plaintiff‘alleges that it is qualified to do business in 27 the State of Califdrnia. Plaintiff’s counsel’s application for 28 license pursuant to Financial Code Section 100000 et. seq. is l COMPLAINT pending issuance with the Nationwide Multistate Licensing and Registry and/or the California Department of Financial Protection and Innovation. 3. Plaintiff is informed and believes that Defendant resided within this jurisdiction and venue at the time of the commencement of the within actiog or, alternatively, entered into the promissory note agreement which is the subject of this action in this jurisdiction and venue. 10 4. The true names of Defendants sued herein as Does 1 to 10 11 are currently unknown to Plaintiff and therefore Plaintiff sues such 12 Defendants by such fictitious names. Plaintiff will seek leave to 13 amend its Complaint at such time as the true names and identities of 14 such Doe Defendants and their capacities are ascertained. 15 16 5. Prior to commencement of this action, the Defendant was 17 informed in writingjthat if an action were commenced Plaintiff may 18 be entitled to recover its court costs and/or its attorney’s fees 19 where allowed by law in addition to the balance on the note 20 otherwise owed. 21 6. At all times herein relevant, ONEMAIN FINANCIAL GROUP, LLC 22 was and is theVduly authorized and appointed servicing agent for 23 24 Plaintiff. 25 FIRST CAUSE OF ACTION (Breach of Promissory Note) 26 27 28 2 COMPLAINT