Preview
1 DAVID J. COOK, ESQ. (State Bar # 060859)
COOK COLLECTION ATTORNEYS
2 A PROFESSIONAL LAW CORPORATION
165 Fell Street, San Francisco, CA 94102-5106
3 P.O. Box 270, San Francisco, CA 94104-0270
Tel.: (415) 989-4730
4 Fax: (415) 989-0491
Email: Cook@JSqueezeBloodFromTumip.com
5 File No. 58,740
Attorneys for Plaintiff RIGGS DISTRIBUTING, INC., a corporation
6
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
7
COUNTY OF SAN MATEO
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UNLIMITED CIVIL JURISDICTION
9
10 RIGGS DISTRIBUTING, INC., a ) CASE NO.
corporation )
11 Plaintiff,
) COMPLAINT FOR GOODS SOLD AND
12 vs. ) DELIVERED AND BREACH
)
13 ASIEN'S APPLIANCE, INC., a ) The amount prayed for is more than $25,000.00:
corporation, AND DOES I THROUGH ) $306,149.12
14
X, AND EACH OF THEM, )
15 INCLUSIVE, )
)
16 Defendants. )
_______________________________________________________ )
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)
18 )
)
19 )
)
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21 Plaintiff RIGGS DISTRIBUTING, INC., a corporation, hereby complains of Defendants
22 ASIEN'S APPLIANCE, INC., a corporation, and DOES I THROUGH X, AND EACH OF
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THEM, INCLUSIVE, for the following causes of action and each of the same as follows:
24
FIRST CAUSE OF ACTION
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26 GOODS and SERVICES HAD AND RECEIVED UNDER A CONTRACT: ASIEN'S
APPLIANCE, INC., a corporation and Does 1 Through X, and each of them
27
28
1
COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED
1 1. Plaintiff RIGGS DISTRIBUTING, INC., a corporation is a corporation, doing business
2
in the State of California, whose appropriate regulatory licensing or political subdivisions,
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agencies, departments, or the like, if any, have issued to Plaintiff the appropriate licenses,
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certificates, permits or permissions to sell or furnish the above GOODS and SERVICES.
5
6 2. Plaintiff is unaware of the true names or capacities of Defendants named DOES I
7 THROUGH X, AND EACH OF THEM, praying leave to amend this Complaint when their true
8
names and capacities are ascertained.
9
3. At all times herein mentioned, Defendant ASIEN'S APPLIANCE, INC., a corporation
10
doing business in this judicial District. Venue is properly within this judicial district in that the
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12 sale and/or furnishing of the GOODS and SERVICES or advance of money as set forth below
13 occurred herein; that the transaction which is the subject of the action herein was consummated in
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the judicial district herein.
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4. Prior to the commencement of this action within this judicial district, Defendants
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ASIEN'S APPLIANCE, INC., a corporation and each of them, became and still are indebted to
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18 Plaintiff who furnished, rendered and supplied to Defendants, and each of the same, at their special
19 instance and request and written contract, purchased from the Plaintiff the GOODS and/or
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SERVICES, which consist of restaurant, residential and related equipment, kitchen and home
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fixtures, hardware, furnishings and other goods to open and operate a appliance, retail and business
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23 of the Defendants for purpose of resale to other customer of the Defendants and related services
24 related thereof on credit or cash and the like, to Defendants, and each of them, at agreed prices
25 upon open book accounts in the sums set forth opposite their names, for which said GOODS and
26
GOODS and SERVICES had a total price of$306,149.12 at the time of their sale and/or delivery,
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likewise in the amount set forth below, and which said GOODS and GOODS and SERVICES had
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2
COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED
1
a reasonable value all as set forth in the attached Statement, marked Exhibit ~~"and incorporated
2
by reference indicating the liability for each of the Defendants, and all of the same, in the amounts
3
4 set forth in their names. The invoices which support and integrated in to the Statement are
5 attached hereto, marked Exhibits ''B-1" to "B-34" and incorporated herein.
6 5. Although demand has been made, Defendants, ASIEN'S APPLIANCE, INC., a
7
corporation and each of the same, has failed and refused and continues to fail and refuse, to pay
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9 said indebtedness, and every part thereof, even though the same and every part thereof are now
1o due, payable and unpaid. Interest has accrued in the amount all as set forth in Exltibit "A" and
11 Exltibits "B-1" to "B-3if' and at the rate set forth therein and accrues from and after the date set
12
forth therein, until judgment is taken. Interest accrues are the rate of 10% from and after the date of
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September 20, 2023 until judgment is entered.
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6. The claim of indebtedness sued herein is not subject to the provisions of Civil Code
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16 Sections 1812.10 and 2984.4 because said indebtedness did not arise from a retail installment
17 contract or under a contract for the purchase and/or financing of a motor vehicle.
18
7. At all times herein mentioned, Defendants, ASIEN'S APPLIANCE, INC., a corporation
19
and each of the same, is agents, employees, and servants of each other and has undertaken the acts
20
as described herein in the course and scope of their agency, employment and serving hereunder.
21
22 SECOND CAUSE OF ACTION
23 ACCOUNT STATED: ASIEN'S APPLIANCE, INC., a corporation. and Does 1 Through X,
24 and each of them
25 8. Plaintiff hereby incorporates the First Cause of Action as though fully set forth herein.
26 9. Within four years last past and prior to the commencement of this action, an account
27
was stated in writing by and between Plaintiff and Defendants, AS lEN'S APPLIANCE, INC., a
28
3
COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED
1
corporation and each of the same, in the amounts as set forth in Exltibit "A," and Exhibits "B-1"
2
to nB-34'' which is attached hereto and incorporated by reference as though fully set forth herein.
3
4 THIRD CAUSE OF ACTION
QUANTUM MERUIT: ASIEN'S APPLIANCE, INC., a corporation and Does 1 Through X,
5 and each of them
6
10. Plaintiff hereby incorporates all prior causes of action as though fully set forth herein.
7
11. Within four years last past and prior to the commencement of this action, Plaintiff
8
delivered, furnished, rendered or supplied GOODS and SERVICES to Defendants, ASIEN'S
9
1o APPLIANCE, INC., a corporation and each of the same, at their special instance and request.
11 12. At all times mentioned said GOODS and GOODS and SERVICES, for credit, had a
12
reasonable value as set forth in Exltibit ~~"and Exltibits ''B-1" to "B-34'' which is attached
13
hereto and incorporated by reference as though fully set forth herein.
14
WHEREFORE, Plaintiff prays for judgment against said Defendants, and each of the same,
15
16 jointly and severally, as follows:
17 I. For damages in the principal amount of$306,149.12 as set forth in Exllibit "A" and
18
Exhibits "B-1" to "B-34'' which is attached hereto and incorporated by reference as though fully
19
set forth herein for each of the Defendants, and all of them.
20
2. For accrued interest in the amount, interest accruing at the rate from the date so accruing
21
22 of 10% from and after September 20, 2023 until judgment is taken, all as set forth in Exllibit ~~"
23 and Exltibits "B-1" to "B-34'' which is attached hereto and incorporated by reference as though
24
fully set forth herein.
25
3. For reasonable attorneys fees and costs of suit herein.
26
27 4. For other and further relief as the Court deems just and proper.
28 //
4
COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED
1
DATED: October 24,2023 COOK COLLEO'fiO ORNEYSPLC
By:_-+-/.....,-..=...-~+-----Â
2
3
, DAVID J[CQoFC, ESQ
4 __Attorneys-tor Plaintiff GGS
DISTRIBUTING, IN ., a corporation
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COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED
EXHIBIT '~A"
r.:~RIGGS Statement
lflpila~--
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Page I of2
Riggs Distributing, Inc.
839 Mitten Rd, Ste 200
Burlingame CA 94010
United States
Phone: 650·240-3000
Bill To
ASIEN'S APPLIANCE, INC.
1801 Piner Road
Santa Rosa CA 95403
United States
2020-01-01 Balance Forward 0.00
2023-08-14 Invoice #783801 443.70 443.70
2023-08-14 Invoice #783800 13,285.50 13,729.20
2023-08-16 Invoice #784953 22,368.60 36,097.80
2023-08-17 Invoice #785226 3,728.10 39,825.90
2023-08-18 Invoice #785595 8,129.40 47,955.30
2023-08-21 Invoice #786019 1,728.90 49,684.20
2023-08-21 Invoice #786018 5,553.14 55,237.34
2023-08-22 Invoice #786390 13,229.40 68,466.74
2023-08-22 Invoice #786391 515.10 68,981.84
2023-08-23 Invoice #787256 186.41 69,168.25
2023-08-23 Invoice #787255 6,451.50 75,619.75
2023-08-24 Invoice #787614 8,843.40 84,463.15
2023-08-25 Invoice ##787988 10,785.48 95,248.63
2023-08-25 Invoice #787989 2,417.40 97,666.03
2023-08-28 Invoice ##788709 9,868.50 107,534.53
2023-08-28 Invoice ##788708 7,721.40 115,255.93
2023-08-28 Invoice ##788707 7,318.50 . 122,574.43
2023-08-29 Invoice #789032 299.88 122,874.31
2023-08-29 Invoice ##789031 8,843.40 131,717.71
2023-08-30 Invoice #789828 6,451.50 138,169.21
2023-08-31 Invoice #790275 9,414.60 147,583.81
2023-08-31 Invoice #790276 9,409.50 156,993.31
2023-09-06 Invoice #792060 2,901.90 159,895.21
2023-09-06 Invoice #792059 20.40 159,915.61
2023-09-06 Invoice #792058 5,448.25 165,363.86
2023-09-06 Invoice #792057 4,725.66 170,089.52
2023-09-06 Invoice #792056 3,330.30 173,419.82
2023-09-06 Invoice #792055 76.50 173,496.32
2023-09-06 Invoice #792054 10,184.70 183,681.02
2023-09-06 Invoice #792053 11,622.90 195,303.92
2023-09-06 Invoice ##792052 8,124.30 ' 203,428.22
2023-09-06 Invoice ##792050 8,833.20 212,261.42
2023-09-06 Invoice ##79205 1 11,622.90 223,884.32
2023-09-07 Invoice ##792566 7,665.30 231,549.62
2023-09-07 Invoice ##792567 8,843.40 240,393.02
2023-09-11 Invoice ##793538 5,936.40 246,329.42
2023-09-11 Invoice ##793540 3,666.90 249,996.32
2023-09-13 Invoice ##794978 11,367.90 261,364.22
2023-09-13 Invoice #794979 1,728.90 263,093.12
2023-09-13 Invoice #794977 1,162.80 264,255.92
2023-09-14 Invoice #795188 7,665.30 271,921.22
2023-09-18 Invoice #796283 21,133.14 293,054.36
2023-09-19 Invoice #796721 10,771.20 303,825.56
2023-09-20 Invoice ##797491 2,323.56 306,149.12
Statement
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Page2of2
Riggs Distributing, Inc.
839 Mitten Rd, Ste 200
Burlingame CA 94010
United States
Phone: 650-240-3000
EXHIBIT "B-1" TO "B-34"
Riggs Distributing, Inc. Invoice No ... 796283
RIGGS 839 Mitten Rd, Ste 200
SHOWROOM+ Burlingame CA 94010 Invoice Date.. 2023-09-18
DISTRIBUTING Unitecf States
Phone: 650-240-3000 Order Date.. 2022-06-08
Invoice
Bill To Ship To
Acct. 3048 ASIEN'S APPLIANCE, INC.
ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403
1801 Piner Road United States
Santa Rosa CA 95403
United States
cuitomer-Pio'.filo . _l~fl~~·-y.t _ -T~r,~s':.· 'terrltC»r&~Mar)ag~t
........ _ ..· _,__...
-~·--,:t·· _.._ ·,.
____ .·
-~'·
15365 Display Pilot Freight Net30 Nikki Cunningham
System
. 91'ciQW. .Shlp:Qty :, '!~;~:-- ._- ' -.- -: Sertai;N~n,~~r,- -' : :~D,~_ctlRlf~n: . ,.
· :pftce. ~UIM~
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•. ·- ..._·~·_ .. '.:..:.~:-.·:... . ___ ·.. ----
~·.. -~·__;,_ ... ·_.~ ..··~ ..~- --~-·; ____ ;': ..._·__ ...,~·;:._ __ ------
1 1 CL3650UID/S/P/ 4815475 36" CLASSIC OVER-AND- $8,954.75 EA $8,954.75
R UNDER REFRIGERATOR/
FREEZER WITH INTERNAL
DISPENSER
1 DEC1850FI/L 24444716 18" DESIGNER COLUMN $5,376.25 EA $5,376.25
FREEZER WITH ICE MAKER-
PANEL READY
1 DEC3050RID/R 24386302 30" DESIGNER COLUMN $6,387.75 EA $6,387.75
REFRIGERATOR WITH
INTERNAL DISPENSER-
PANEL READY
Memo All UNITS ARE FOR DISPLAY! (6/13: Pricing updated) I Subtotal $20,718.75
Discount $0.00
Ship/Handling $414.39
Tax Total (%) $0.00
Total $21,133.14
Total Due $21,133.14
Dear Customer:
We are invoicing you for the products and services as listed in the attached invoices. The terms of the conditions of the sale of
the products ani:l7or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT
APPLICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the buyer, whether in a purchase order, online, or otherwise,
which varies or differs from, contradicts, or conflicts with the DEALER AGREEMENT and CREDIT APPLICATION OF RDI are
expressly rejected and not part of any agreement by and between the parties.
Warehouse hours: Monday 1:00 p.m. - 4:00 p.m., Tuesday- Friday 8:00 a.m.- 12:00 p.m. and 1:00 p.m. - 4:00 p.m.
Hours are subject to change on holidays.
Page 1 of 1
Riggs Distributing, Inc. Invoice No ... 796721
RIGGS 839 Mitten Rd, Ste 200
SHOWROOM+ Burlingame CA 9401 0 Invoice Date .. 2023-09-19
DISTRIBUTING United States
Phone: 650-240-3000 Order Date .. 2022-09-09
Invoice
Bill To Ship To
Acct. 3048 ASIEN'S APPUANCE, INC.
ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403
1801 Piner Road United States
Santa Rosa CA 95403
United States
CU!~Ol'tiJ!!'~IO:if"D -(~~J:''Mi~ :terms;
------- ~
-~ ~!!';~~~~)JtM~.t!~~ _, .
15917 Pilot Freight Net30 Nikki Cunningham
System
,.·- · . . ·;:·."
.~ ..· . :-- :· II. :
.A'·! :~ .•. ··.' . :·::r>~c~l~ti~<
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- -~-:~~- -- ~:-~··I ~---~_,; ___ _, ___ _,_ ___;__ ___ ::.., ___:_·~..". - -· .
1 CL4250S/S/P 4820435 42" CLASSIC SIDE-BY-SIDE $10,560.00 EA $10,560.00
REFRIGERATOR/FREEZER
Subtotal $10,560.00
Discount $0.00
Ship/Handling $211.20
Tax Total (%) $0.00
Total $10,771.20
Total Due $10,771.20
Dear Customer:
We are invoicing you for the products and services as listed in the attached invoices. The terms of the conditions of the sale of
the products and7or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT
APPUCATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the buyer, whether in a purchase order, online, or otherwise,
which varies or differs from, contradicts, or conflicts with the DEALER AGREEMENT and CREDIT APPUCATION OF RDI are
expressly rejected and not part of any agreement by and between the parties.
Warehouse hours: Monday 1:00 p.m. - 4:00 p.m., Tuesday- Friday 8:00a.m.- 12:00 p.m. and 1:00 p.m. -4:00p.m.
Hours are subject to change on holidays.
Page 1 of 1
Riggs Distributing, Inc. Invoice No ... 786390
~~~ RIGGS 839 Mitten Rd, Ste 200
SHOWROOM+ BurlinJame CA 9401 0 Invoice Date.. 2023-08-22
q-~ DISTRIBUTING Unite States
&
(Allf"OR'Il!A
Phone: 650-240-3000
•H•WAII
Order Date.. 2023-06-14
Invoice
Bill To Ship To
Acct. 3048 ASIEN'S APPUANCE, INC.
ASIEN'S APPUANCE, INC. Santa Rosa CA 95403
1801 Piner Road United States
Santa Rosa CA 95403
United States
. '. .~· a.:r· -~-~~-~--" · · ·· ·-· ··" -..
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17325-C Pilot Freight Net 30
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. ~~,~9~~:.-:.:~s~!~~~::::.:tfe~~:___ ~:·;~.! _··::.. ~~i~~~;~~_r?!t~~:: --l~·i~~,~~~~·<
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1 1 DF486SOC/S/P 18783011 48" DUAL FUEL RANGE- 6 $12,970.00 EA $12,970.00
BURNERS AND INFRARED
CHARBROILER- NG
-~-~--~- -·-~·--- --·~-.
Subtotal $12,970.00
Discount $0.00
Ship/Handling $259.40
Tax Total (%) $0.00
Total $13,229.40
Total Due $13,229.40
Dear Customer:
We are invoicing you for the products and services as listed in the attached invoices. The terms of the conditions ofthe sale of
the products and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT
APPLICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the buyer, whether in a purchase order, online, or otherwise,
which varies or differs from, contradicts, or conflicts with the DEALER AGREEMENT and CREDIT APPLICATION OF RDI are
expressly rejected and not part of any agreement by and between the parties.
Warehouse hours: Monday 1:00 p.m.- 4:00 p.m., Tuesday- Friday 8:00 a.m.- 12:00 p.m. and 1:00 p.m.- 4:00 p.m.
Hours are subject to change on holidays.
Page 1 of 1
Riggs Distributing, Inc. Invoice No... 786391
~~~~ RIGGS 839 Mitten Rd, Ste 200
SHOWROOM+ Burlir:fame CA 9401 0 Invoice Date.. 2023-08-22
·-~
DISTRIBUTING Unite States
CAtlf"OI'HiiA
Phone: 650-240-3000
& ••.t.WAtl
Order Date.. 2023-08-08
Invoice
Bill To Ship To
Acct. 3048 ASIEN'S APPLIANCE, INC.
ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403
1801 Piner Road United States
Santa Rosa CA 95403
United States
~ustom!!fr!C?~~~: ~ s~!RY!.~~---- _,_ "- ~:!~ro~~-
17050 Pilot Freight Net 30
.: :·~~)t~!!!lto;~lf(~j~~t;·· _; . ' '·
Nikki Cunningham
System
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- • ·_· - · :J _ _:__ - - ~~ --·- ·- -~-- - - ~ ..... ... .;.;. ..-. ___ .___..::. _ __ i.;::_~ --
1 1 9016121 36" X 20" DUAL FUEL $505.00 EA $505.00
RANGE RISER WITH SHELF
Subtotal $505.00
Discount $0.00
Ship/Handling $10.10
Tax Total (%) $0.00
Total $515.10
Total Due $515.10
Dear Customer:
We are invoicing you for the products and services as listed in the attached invoices. The terms of the conditions of the sale of
the products ana/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT
APPLICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the buyer, whether in a purchase order, online, or otherwise,
which varies or differs from, contradicts, or conflicts with the DEALER AGREEMENT and CREDIT APPLICATION OF RDI are
expressly rejected and not part of any agreement by and between the parties.
Warehouse hours: Monday 1:00 p.m.- 4:00 p.m., Tuesday- Friday 8:00a.m.- 12:00 p.m. and 1:00 p.m.- 4:00 p.m.
Hours are subject to change on holidays.
Page 1 of 1
Riggs Distributing, Inc. Invoice No... 795188
~~-~ RIGGS 839 Mitten Rd, Ste 200
SHOWROOM+ Burlin3ame CA 9401 o Invoice Date .. 2023-09-14
~-~
DISTRIBUTING Unite States
CAUFORUII• & .. AWAII
Phone: 650-240-3000 Order Date .. 2022-09-15
Invoice
Bill To Ship To
Acct. 3048 ASIEN'S APPUANCE, INC.
ASIEN'S APPUANCE, INC. Santa Rosa CA 95403
1801 Piner Road United States
Santa Rosa CA 95403
United States
· Cus~~~~r':!{:qt~~' :.::·.·:·:f~hj~~,y!t.:: __ -~- ·- ·. ~~--rri~'; :...:..:.· __ -L~·:~-- '~·: t~~~~t9.~iM~i~g~f: 1
15948 Pilot Freight Net 30 Nikki Cunningham
System
or~ QtY ,s~lp Q~-·~ l~ern, '<,l _ ·. s•rJai:Nt.~m§!!r ,iR.,_cr!pUJo~ '·; ·· i. _ ---- - 'Pr._lc~: -:l)fM· Amount
... ..._. ~~·-~--··---~· ---·-- ...... _ .• ._ ...... ~--.....:...:.._~ .•• ~ ... __ ....~;.~~~- ~~-· __.:,_ .. ~- ·-· :..... -~ ..... *J _____ ....~l'~. :..-~~-~- ' - --~ -- - ~-~-...:. -- ---~---~- -~-- - . .:'.....,. ____ ~_:..__ ________ _
1 DEC3050RID/R 24431873 30" DESIGNER COLUMN $7,515.00 EA $7,515.00
REFRIGERATOR WITH
INTERNAL DISPENSER·
PANEL READY
Subtotal $7,515.00
Discount $0.00
Ship/Handling $150.30
Tax Total (%) $0.00
Total $7,665.30
Total Due $7,665.30
Dear Customer:
We are invoicing you for the products and services as listed in the attached invoices. The terms of the conditions of the sale of
the products ana/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT
APPLICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the buyer, whether in a purchase order, online, or otherwise,
which varies or differs from, contradicts, or conflicts with the DEALER AGREEMENT and CREDIT APPLICATION OF RDI are
expressly rejected and not part of any agreement by and between the parties.
Warehouse hours: Monday 1:00 p.m. - 4:00 p.m., Tuesday- Friday 8:00a.m. - 12:00 p.m. and 1:00 p.m. -4:00p.m.
Hours are subject to change on holidays.
Page 1 of 1
Riggs Distributing, Inc. Invoice No ... 787614
~~-~ RIGGS
SHOWROOM+
839 Mitten Rd, Ste 200
BurlincPame CA 94010 Invoice Date.. 2023-08-24
·-~
DISTRIBUTING Unite States
,_- AllffJAt;oA & 044YII. A. II
Phone: 650-240-3000 Order Date.. 2022-06-14
Invoice
Bill To Ship To
Acct. 3048 ASIEN'S APPLIANCE, INC.
ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403
1801 Piner Road United States
Santa Rosa CA 95403
United States
· cu-~~~m~ii~;c)J~9-_~ _i~M~~!!i.·: ~.,:/,.;._ ~',~~rfu~: c - -.·I
15404 Pilot Freight Net 30
System
,_ ... "
~_hlp,~ty- · 4tent'· . - ·__ :s:~daf~U.mJJeJ''
-- - ~·-- --··~0 -· • __••!,_ __ , --- ----'-- -~ --- ~ --~ ··---
Dffi6SOOID/L 24413481 36" Designer Over-and- $8,670.00 EA $8,670.00
Under Refrigerator/Freezer
with Ice Mal:··· ·-.~~~~~I~~ro~elf.'-_ .~~-~~!·~~~~~-- · '· ·
- __ ._ --------· ·- --- __ :..,_____ ·~------~ ~- ~....;___.__..;~...;......__;._ --------
1 1 7023628 Dual Install Kit Handle- $182.75 EA $182.75
Handle (IC, IT & IW)
Memo FOR DISPLAY I Display pricing updated I 8/17/231 Subtotal $182.75
Discount $0.00
Ship/Handling $3.66
Tax Total (%) $0.00
Total $186.41
Total Due $186.41
Dear Customer:
We are
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1 DAVID J. COOK, ESQ. (State Bar # 060859) COOK COLLECTION ATTORNEYS 2 A PROFESSIONAL LAW CORPORATION 165 Fell Street, San Francisco, CA 94102-5106 3 P.O. Box 270, San Francisco, CA 94104-0270 Tel.: (415) 989-4730 4 Fax: (415) 989-0491 Email: Cook@JSqueezeBloodFromTumip.com 5 File No. 58,740 Attorneys for Plaintiff RIGGS DISTRIBUTING, INC., a corporation 6 SUPERIOR COURT FOR THE STATE OF CALIFORNIA 7 COUNTY OF SAN MATEO 8 UNLIMITED CIVIL JURISDICTION 9 10 RIGGS DISTRIBUTING, INC., a ) CASE NO. corporation ) 11 Plaintiff, ) COMPLAINT FOR GOODS SOLD AND 12 vs. ) DELIVERED AND BREACH ) 13 ASIEN'S APPLIANCE, INC., a ) The amount prayed for is more than $25,000.00: corporation, AND DOES I THROUGH ) $306,149.12 14 X, AND EACH OF THEM, ) 15 INCLUSIVE, ) ) 16 Defendants. ) _______________________________________________________ ) 17 ) 18 ) ) 19 ) ) 20 21 Plaintiff RIGGS DISTRIBUTING, INC., a corporation, hereby complains of Defendants 22 ASIEN'S APPLIANCE, INC., a corporation, and DOES I THROUGH X, AND EACH OF 23 THEM, INCLUSIVE, for the following causes of action and each of the same as follows: 24 FIRST CAUSE OF ACTION 25 26 GOODS and SERVICES HAD AND RECEIVED UNDER A CONTRACT: ASIEN'S APPLIANCE, INC., a corporation and Does 1 Through X, and each of them 27 28 1 COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED 1 1. Plaintiff RIGGS DISTRIBUTING, INC., a corporation is a corporation, doing business 2 in the State of California, whose appropriate regulatory licensing or political subdivisions, 3 agencies, departments, or the like, if any, have issued to Plaintiff the appropriate licenses, 4 certificates, permits or permissions to sell or furnish the above GOODS and SERVICES. 5 6 2. Plaintiff is unaware of the true names or capacities of Defendants named DOES I 7 THROUGH X, AND EACH OF THEM, praying leave to amend this Complaint when their true 8 names and capacities are ascertained. 9 3. At all times herein mentioned, Defendant ASIEN'S APPLIANCE, INC., a corporation 10 doing business in this judicial District. Venue is properly within this judicial district in that the 11 12 sale and/or furnishing of the GOODS and SERVICES or advance of money as set forth below 13 occurred herein; that the transaction which is the subject of the action herein was consummated in 14 the judicial district herein. 15 4. Prior to the commencement of this action within this judicial district, Defendants 16 ASIEN'S APPLIANCE, INC., a corporation and each of them, became and still are indebted to 17 18 Plaintiff who furnished, rendered and supplied to Defendants, and each of the same, at their special 19 instance and request and written contract, purchased from the Plaintiff the GOODS and/or 20 SERVICES, which consist of restaurant, residential and related equipment, kitchen and home 21 fixtures, hardware, furnishings and other goods to open and operate a appliance, retail and business 22 23 of the Defendants for purpose of resale to other customer of the Defendants and related services 24 related thereof on credit or cash and the like, to Defendants, and each of them, at agreed prices 25 upon open book accounts in the sums set forth opposite their names, for which said GOODS and 26 GOODS and SERVICES had a total price of$306,149.12 at the time of their sale and/or delivery, 27 likewise in the amount set forth below, and which said GOODS and GOODS and SERVICES had 28 2 COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED 1 a reasonable value all as set forth in the attached Statement, marked Exhibit ~~"and incorporated 2 by reference indicating the liability for each of the Defendants, and all of the same, in the amounts 3 4 set forth in their names. The invoices which support and integrated in to the Statement are 5 attached hereto, marked Exhibits ''B-1" to "B-34" and incorporated herein. 6 5. Although demand has been made, Defendants, ASIEN'S APPLIANCE, INC., a 7 corporation and each of the same, has failed and refused and continues to fail and refuse, to pay 8 9 said indebtedness, and every part thereof, even though the same and every part thereof are now 1o due, payable and unpaid. Interest has accrued in the amount all as set forth in Exltibit "A" and 11 Exltibits "B-1" to "B-3if' and at the rate set forth therein and accrues from and after the date set 12 forth therein, until judgment is taken. Interest accrues are the rate of 10% from and after the date of 13 September 20, 2023 until judgment is entered. 14 6. The claim of indebtedness sued herein is not subject to the provisions of Civil Code 15 16 Sections 1812.10 and 2984.4 because said indebtedness did not arise from a retail installment 17 contract or under a contract for the purchase and/or financing of a motor vehicle. 18 7. At all times herein mentioned, Defendants, ASIEN'S APPLIANCE, INC., a corporation 19 and each of the same, is agents, employees, and servants of each other and has undertaken the acts 20 as described herein in the course and scope of their agency, employment and serving hereunder. 21 22 SECOND CAUSE OF ACTION 23 ACCOUNT STATED: ASIEN'S APPLIANCE, INC., a corporation. and Does 1 Through X, 24 and each of them 25 8. Plaintiff hereby incorporates the First Cause of Action as though fully set forth herein. 26 9. Within four years last past and prior to the commencement of this action, an account 27 was stated in writing by and between Plaintiff and Defendants, AS lEN'S APPLIANCE, INC., a 28 3 COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED 1 corporation and each of the same, in the amounts as set forth in Exltibit "A," and Exhibits "B-1" 2 to nB-34'' which is attached hereto and incorporated by reference as though fully set forth herein. 3 4 THIRD CAUSE OF ACTION QUANTUM MERUIT: ASIEN'S APPLIANCE, INC., a corporation and Does 1 Through X, 5 and each of them 6 10. Plaintiff hereby incorporates all prior causes of action as though fully set forth herein. 7 11. Within four years last past and prior to the commencement of this action, Plaintiff 8 delivered, furnished, rendered or supplied GOODS and SERVICES to Defendants, ASIEN'S 9 1o APPLIANCE, INC., a corporation and each of the same, at their special instance and request. 11 12. At all times mentioned said GOODS and GOODS and SERVICES, for credit, had a 12 reasonable value as set forth in Exltibit ~~"and Exltibits ''B-1" to "B-34'' which is attached 13 hereto and incorporated by reference as though fully set forth herein. 14 WHEREFORE, Plaintiff prays for judgment against said Defendants, and each of the same, 15 16 jointly and severally, as follows: 17 I. For damages in the principal amount of$306,149.12 as set forth in Exllibit "A" and 18 Exhibits "B-1" to "B-34'' which is attached hereto and incorporated by reference as though fully 19 set forth herein for each of the Defendants, and all of them. 20 2. For accrued interest in the amount, interest accruing at the rate from the date so accruing 21 22 of 10% from and after September 20, 2023 until judgment is taken, all as set forth in Exllibit ~~" 23 and Exltibits "B-1" to "B-34'' which is attached hereto and incorporated by reference as though 24 fully set forth herein. 25 3. For reasonable attorneys fees and costs of suit herein. 26 27 4. For other and further relief as the Court deems just and proper. 28 // 4 COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED 1 DATED: October 24,2023 COOK COLLEO'fiO ORNEYSPLC By:_-+-/.....,-..=...-~+----- 2 3 , DAVID J[CQoFC, ESQ 4 __Attorneys-tor Plaintiff GGS DISTRIBUTING, IN ., a corporation 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED EXHIBIT '~A" r.:~RIGGS Statement lflpila~-- - ~ Page I of2 Riggs Distributing, Inc. 839 Mitten Rd, Ste 200 Burlingame CA 94010 United States Phone: 650·240-3000 Bill To ASIEN'S APPLIANCE, INC. 1801 Piner Road Santa Rosa CA 95403 United States 2020-01-01 Balance Forward 0.00 2023-08-14 Invoice #783801 443.70 443.70 2023-08-14 Invoice #783800 13,285.50 13,729.20 2023-08-16 Invoice #784953 22,368.60 36,097.80 2023-08-17 Invoice #785226 3,728.10 39,825.90 2023-08-18 Invoice #785595 8,129.40 47,955.30 2023-08-21 Invoice #786019 1,728.90 49,684.20 2023-08-21 Invoice #786018 5,553.14 55,237.34 2023-08-22 Invoice #786390 13,229.40 68,466.74 2023-08-22 Invoice #786391 515.10 68,981.84 2023-08-23 Invoice #787256 186.41 69,168.25 2023-08-23 Invoice #787255 6,451.50 75,619.75 2023-08-24 Invoice #787614 8,843.40 84,463.15 2023-08-25 Invoice ##787988 10,785.48 95,248.63 2023-08-25 Invoice #787989 2,417.40 97,666.03 2023-08-28 Invoice ##788709 9,868.50 107,534.53 2023-08-28 Invoice ##788708 7,721.40 115,255.93 2023-08-28 Invoice ##788707 7,318.50 . 122,574.43 2023-08-29 Invoice #789032 299.88 122,874.31 2023-08-29 Invoice ##789031 8,843.40 131,717.71 2023-08-30 Invoice #789828 6,451.50 138,169.21 2023-08-31 Invoice #790275 9,414.60 147,583.81 2023-08-31 Invoice #790276 9,409.50 156,993.31 2023-09-06 Invoice #792060 2,901.90 159,895.21 2023-09-06 Invoice #792059 20.40 159,915.61 2023-09-06 Invoice #792058 5,448.25 165,363.86 2023-09-06 Invoice #792057 4,725.66 170,089.52 2023-09-06 Invoice #792056 3,330.30 173,419.82 2023-09-06 Invoice #792055 76.50 173,496.32 2023-09-06 Invoice #792054 10,184.70 183,681.02 2023-09-06 Invoice #792053 11,622.90 195,303.92 2023-09-06 Invoice ##792052 8,124.30 ' 203,428.22 2023-09-06 Invoice ##792050 8,833.20 212,261.42 2023-09-06 Invoice ##79205 1 11,622.90 223,884.32 2023-09-07 Invoice ##792566 7,665.30 231,549.62 2023-09-07 Invoice ##792567 8,843.40 240,393.02 2023-09-11 Invoice ##793538 5,936.40 246,329.42 2023-09-11 Invoice ##793540 3,666.90 249,996.32 2023-09-13 Invoice ##794978 11,367.90 261,364.22 2023-09-13 Invoice #794979 1,728.90 263,093.12 2023-09-13 Invoice #794977 1,162.80 264,255.92 2023-09-14 Invoice #795188 7,665.30 271,921.22 2023-09-18 Invoice #796283 21,133.14 293,054.36 2023-09-19 Invoice #796721 10,771.20 303,825.56 2023-09-20 Invoice ##797491 2,323.56 306,149.12 Statement - ~ Page2of2 Riggs Distributing, Inc. 839 Mitten Rd, Ste 200 Burlingame CA 94010 United States Phone: 650-240-3000 EXHIBIT "B-1" TO "B-34" Riggs Distributing, Inc. Invoice No ... 796283 RIGGS 839 Mitten Rd, Ste 200 SHOWROOM+ Burlingame CA 94010 Invoice Date.. 2023-09-18 DISTRIBUTING Unitecf States Phone: 650-240-3000 Order Date.. 2022-06-08 Invoice Bill To Ship To Acct. 3048 ASIEN'S APPLIANCE, INC. ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403 1801 Piner Road United States Santa Rosa CA 95403 United States cuitomer-Pio'.filo . _l~fl~~·-y.t _ -T~r,~s':.· 'terrltC»r&~Mar)ag~t ........ _ ..· _,__... -~·--,:t·· _.._ ·,. ____ .· -~'· 15365 Display Pilot Freight Net30 Nikki Cunningham System . 91'ciQW. .Shlp:Qty :, '!~;~:-- ._- ' -.- -: Sertai;N~n,~~r,- -' : :~D,~_ctlRlf~n: . ,. · :pftce. ~UIM~ ·~ •. ·- ..._·~·_ .. '.:..:.~:-.·:... . ___ ·.. ---- ~·.. -~·__;,_ ... ·_.~ ..··~ ..~- --~-·; ____ ;': ..._·__ ...,~·;:._ __ ------ 1 1 CL3650UID/S/P/ 4815475 36" CLASSIC OVER-AND- $8,954.75 EA $8,954.75 R UNDER REFRIGERATOR/ FREEZER WITH INTERNAL DISPENSER 1 DEC1850FI/L 24444716 18" DESIGNER COLUMN $5,376.25 EA $5,376.25 FREEZER WITH ICE MAKER- PANEL READY 1 DEC3050RID/R 24386302 30" DESIGNER COLUMN $6,387.75 EA $6,387.75 REFRIGERATOR WITH INTERNAL DISPENSER- PANEL READY Memo All UNITS ARE FOR DISPLAY! (6/13: Pricing updated) I Subtotal $20,718.75 Discount $0.00 Ship/Handling $414.39 Tax Total (%) $0.00 Total $21,133.14 Total Due $21,133.14 Dear Customer: We are invoicing you for the products and services as listed in the attached invoices. The terms of the conditions of the sale of the products ani:l7or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT APPLICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the buyer, whether in a purchase order, online, or otherwise, which varies or differs from, contradicts, or conflicts with the DEALER AGREEMENT and CREDIT APPLICATION OF RDI are expressly rejected and not part of any agreement by and between the parties. Warehouse hours: Monday 1:00 p.m. - 4:00 p.m., Tuesday- Friday 8:00 a.m.- 12:00 p.m. and 1:00 p.m. - 4:00 p.m. Hours are subject to change on holidays. Page 1 of 1 Riggs Distributing, Inc. Invoice No ... 796721 RIGGS 839 Mitten Rd, Ste 200 SHOWROOM+ Burlingame CA 9401 0 Invoice Date .. 2023-09-19 DISTRIBUTING United States Phone: 650-240-3000 Order Date .. 2022-09-09 Invoice Bill To Ship To Acct. 3048 ASIEN'S APPUANCE, INC. ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403 1801 Piner Road United States Santa Rosa CA 95403 United States CU!~Ol'tiJ!!'~IO:if"D -(~~J:''Mi~ :terms; ------- ~ -~ ~!!';~~~~)JtM~.t!~~ _, . 15917 Pilot Freight Net30 Nikki Cunningham System ,.·- · . . ·;:·." .~ ..· . :-- :· II. : .A'·! :~ .•. ··.' . :·::r>~c~l~ti~< ·ordiQ~y.·· -~h.ip•Qty, Item'•::- ··~-~ ~~rr~.tN~mb.e_~ .. __ . ~- -~ _,..., - -~-:~~- -- ~:-~··I ~---~_,; ___ _, ___ _,_ ___;__ ___ ::.., ___:_·~..". - -· . 1 CL4250S/S/P 4820435 42" CLASSIC SIDE-BY-SIDE $10,560.00 EA $10,560.00 REFRIGERATOR/FREEZER Subtotal $10,560.00 Discount $0.00 Ship/Handling $211.20 Tax Total (%) $0.00 Total $10,771.20 Total Due $10,771.20 Dear Customer: We are invoicing you for the products and services as listed in the attached invoices. The terms of the conditions of the sale of the products and7or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT APPUCATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the buyer, whether in a purchase order, online, or otherwise, which varies or differs from, contradicts, or conflicts with the DEALER AGREEMENT and CREDIT APPUCATION OF RDI are expressly rejected and not part of any agreement by and between the parties. Warehouse hours: Monday 1:00 p.m. - 4:00 p.m., Tuesday- Friday 8:00a.m.- 12:00 p.m. and 1:00 p.m. -4:00p.m. Hours are subject to change on holidays. Page 1 of 1 Riggs Distributing, Inc. Invoice No ... 786390 ~~~ RIGGS 839 Mitten Rd, Ste 200 SHOWROOM+ BurlinJame CA 9401 0 Invoice Date.. 2023-08-22 q-~ DISTRIBUTING Unite States & (Allf"OR'Il!A Phone: 650-240-3000 •H•WAII Order Date.. 2023-06-14 Invoice Bill To Ship To Acct. 3048 ASIEN'S APPUANCE, INC. ASIEN'S APPUANCE, INC. Santa Rosa CA 95403 1801 Piner Road United States Santa Rosa CA 95403 United States . '. .~· a.:r· -~-~~-~--" · · ·· ·-· ··" -.. -c·u"·s···-t·i.·~r~····J!i-;. ,;;.-._o··..ii.o· ~ -~~:~·. :·~·~~ . . ~~~(':':~:· .. ~~---· ·_ -~~~~-~1?2·~~~-~~j:~·-~-- ~ ~ .. ~~-t:~~~-~~ -~·-- ___ ·.~ -~~.._."..:_-__ -·--~·_---'~- ... -·· · ·s"ti. ·..... ,-_.d>1•· · 1 .~' = :~~'!JlP-~--- :. ....... _ ·- _=.. • ____ . __ -~ ~ 17325-C Pilot Freight Net 30 System ·:l ·: ·: .. ~ 1 •• • ~- ._.~ ~,,. ,~ ~- ·-,f,. . ·_·--.~~-:_~/:~ •• _ \- - - · ·:· J ·r · ·' . ... - · ~-... · · · ·" ·, · . ~~,~9~~:.-:.:~s~!~~~::::.:tfe~~:___ ~:·;~.! _··::.. ~~i~~~;~~_r?!t~~:: --l~·i~~,~~~~·< .. __ ·---~·- ---- . -- :~· ;p_tJ.~~t.:W~:::;i~I~- ~:~mQ_~~t 1 1 DF486SOC/S/P 18783011 48" DUAL FUEL RANGE- 6 $12,970.00 EA $12,970.00 BURNERS AND INFRARED CHARBROILER- NG -~-~--~- -·-~·--- --·~-. Subtotal $12,970.00 Discount $0.00 Ship/Handling $259.40 Tax Total (%) $0.00 Total $13,229.40 Total Due $13,229.40 Dear Customer: We are invoicing you for the products and services as listed in the attached invoices. The terms of the conditions ofthe sale of the products and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT APPLICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the buyer, whether in a purchase order, online, or otherwise, which varies or differs from, contradicts, or conflicts with the DEALER AGREEMENT and CREDIT APPLICATION OF RDI are expressly rejected and not part of any agreement by and between the parties. Warehouse hours: Monday 1:00 p.m.- 4:00 p.m., Tuesday- Friday 8:00 a.m.- 12:00 p.m. and 1:00 p.m.- 4:00 p.m. Hours are subject to change on holidays. Page 1 of 1 Riggs Distributing, Inc. Invoice No... 786391 ~~~~ RIGGS 839 Mitten Rd, Ste 200 SHOWROOM+ Burlir:fame CA 9401 0 Invoice Date.. 2023-08-22 ·-~ DISTRIBUTING Unite States CAtlf"OI'HiiA Phone: 650-240-3000 & ••.t.WAtl Order Date.. 2023-08-08 Invoice Bill To Ship To Acct. 3048 ASIEN'S APPLIANCE, INC. ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403 1801 Piner Road United States Santa Rosa CA 95403 United States ~ustom!!fr!C?~~~: ~ s~!RY!.~~---- _,_ "- ~:!~ro~~- 17050 Pilot Freight Net 30 .: :·~~)t~!!!lto;~lf(~j~~t;·· _; . ' '· Nikki Cunningham System . . ,. -. ···- .. <-· r ~ -,~·· .. ~ ~ . ,•·. or~·qty.' iRrice:- ~ .-:;- .. . Ji/M'. :. ·': . . . - ~. ' ·'Amount - • ·_· - · :J _ _:__ - - ~~ --·- ·- -~-- - - ~ ..... ... .;.;. ..-. ___ .___..::. _ __ i.;::_~ -- 1 1 9016121 36" X 20" DUAL FUEL $505.00 EA $505.00 RANGE RISER WITH SHELF Subtotal $505.00 Discount $0.00 Ship/Handling $10.10 Tax Total (%) $0.00 Total $515.10 Total Due $515.10 Dear Customer: We are invoicing you for the products and services as listed in the attached invoices. The terms of the conditions of the sale of the products ana/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT APPLICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the buyer, whether in a purchase order, online, or otherwise, which varies or differs from, contradicts, or conflicts with the DEALER AGREEMENT and CREDIT APPLICATION OF RDI are expressly rejected and not part of any agreement by and between the parties. Warehouse hours: Monday 1:00 p.m.- 4:00 p.m., Tuesday- Friday 8:00a.m.- 12:00 p.m. and 1:00 p.m.- 4:00 p.m. Hours are subject to change on holidays. Page 1 of 1 Riggs Distributing, Inc. Invoice No... 795188 ~~-~ RIGGS 839 Mitten Rd, Ste 200 SHOWROOM+ Burlin3ame CA 9401 o Invoice Date .. 2023-09-14 ~-~ DISTRIBUTING Unite States CAUFORUII• & .. AWAII Phone: 650-240-3000 Order Date .. 2022-09-15 Invoice Bill To Ship To Acct. 3048 ASIEN'S APPUANCE, INC. ASIEN'S APPUANCE, INC. Santa Rosa CA 95403 1801 Piner Road United States Santa Rosa CA 95403 United States · Cus~~~~r':!{:qt~~' :.::·.·:·:f~hj~~,y!t.:: __ -~- ·- ·. ~~--rri~'; :...:..:.· __ -L~·:~-- '~·: t~~~~t9.~iM~i~g~f: 1 15948 Pilot Freight Net 30 Nikki Cunningham System or~ QtY ,s~lp Q~-·~ l~ern, '<,l _ ·. s•rJai:Nt.~m§!!r ,iR.,_cr!pUJo~ '·; ·· i. _ ---- - 'Pr._lc~: -:l)fM· Amount ... ..._. ~~·-~--··---~· ---·-- ...... _ .• ._ ...... ~--.....:...:.._~ .•• ~ ... __ ....~;.~~~- ~~-· __.:,_ .. ~- ·-· :..... -~ ..... *J _____ ....~l'~. :..-~~-~- ' - --~ -- - ~-~-...:. -- ---~---~- -~-- - . .:'.....,. ____ ~_:..__ ________ _ 1 DEC3050RID/R 24431873 30" DESIGNER COLUMN $7,515.00 EA $7,515.00 REFRIGERATOR WITH INTERNAL DISPENSER· PANEL READY Subtotal $7,515.00 Discount $0.00 Ship/Handling $150.30 Tax Total (%) $0.00 Total $7,665.30 Total Due $7,665.30 Dear Customer: We are invoicing you for the products and services as listed in the attached invoices. The terms of the conditions of the sale of the products ana/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT APPLICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the buyer, whether in a purchase order, online, or otherwise, which varies or differs from, contradicts, or conflicts with the DEALER AGREEMENT and CREDIT APPLICATION OF RDI are expressly rejected and not part of any agreement by and between the parties. Warehouse hours: Monday 1:00 p.m. - 4:00 p.m., Tuesday- Friday 8:00a.m. - 12:00 p.m. and 1:00 p.m. -4:00p.m. Hours are subject to change on holidays. Page 1 of 1 Riggs Distributing, Inc. Invoice No ... 787614 ~~-~ RIGGS SHOWROOM+ 839 Mitten Rd, Ste 200 BurlincPame CA 94010 Invoice Date.. 2023-08-24 ·-~ DISTRIBUTING Unite States ,_- AllffJAt;oA & 044YII. A. II Phone: 650-240-3000 Order Date.. 2022-06-14 Invoice Bill To Ship To Acct. 3048 ASIEN'S APPLIANCE, INC. ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403 1801 Piner Road United States Santa Rosa CA 95403 United States · cu-~~~m~ii~;c)J~9-_~ _i~M~~!!i.·: ~.,:/,.;._ ~',~~rfu~: c - -.·I 15404 Pilot Freight Net 30 System ,_ ... " ~_hlp,~ty- · 4tent'· . - ·__ :s:~daf~U.mJJeJ'' -- - ~·-- --··~0 -· • __••!,_ __ , --- ----'-- -~ --- ~ --~ ··--- Dffi6SOOID/L 24413481 36" Designer Over-and- $8,670.00 EA $8,670.00 Under Refrigerator/Freezer with Ice Mal:··· ·-.~~~~~I~~ro~elf.'-_ .~~-~~!·~~~~~-- · '· · - __ ._ --------· ·- --- __ :..,_____ ·~------~ ~- ~....;___.__..;~...;......__;._ -------- 1 1 7023628 Dual Install Kit Handle- $182.75 EA $182.75 Handle (IC, IT & IW) Memo FOR DISPLAY I Display pricing updated I 8/17/231 Subtotal $182.75 Discount $0.00 Ship/Handling $3.66 Tax Total (%) $0.00 Total $186.41 Total Due $186.41 Dear Customer: We are