Preview
Electronically
by Superior ua H PBN (7 of San Mateo
DAVID J. COOK, ESQ. (State Bar # 060859)
COOK COLLECTION ATTORNEYS By. /s/ Jennifer Torres
A PROFESSIONAL LAW CORPORATION Deputy Clerk
165 Fell Street, San Francisco, CA 94102-5106
P.O. Box 270, San Francisco, CA 94104-0270
Tel.: (415) 989-4730
Fax: (415) 989-0491
Email: Cook@SqueezeBloodFromTurnip.com
File No. 58,740
Attomeys for Plaintiff RIGGS DISTRIBUTING, INC., a corporation
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
UNLIMITED CIVIL JURISDICTION
10 RIGGS DISTRIBUTING, INC., a CASE NO. 23-CIV-05051
corporation
FIRST AMENDED COMPLAINT FOR
1 Plaintiff,
GOODS SOLD AND DELIVERED
12 vs.
13 ASIEN’S APPLIANCE, INC., a
corporation, AND DOES I THROUGH The amount prayed for is more than $25,000.00
14
X, AND EACH OF THEM, $306,149.12
15 INCLUSIVE, Date of Filing: October 24, 2023.
Judge: Honorable Susen Greenberg
16 Defendants. Dept. 3, Court Room 2 B
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. USE OF
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, Plaintiff RIGGS DISTRIBUTING, INC., a corporation is a corporation, doing business
in the State of California, whose appropriate regulatory licensing or political subdivisions,
agencies, departments, or the like, if any, have issued to Plaintiff the appropriate licenses,
certificates, permits or permissions to sell or furnish the'‘above GOODS and SERVICES.
2. Plaintiff is unaware of the true names or capacities of Defendants named DOES |
THROUGH X, AND EACH OF THEM, praying leave to amend this Complaint when their true
names and capacities are ascertained.
3. Atall 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
a reasonable value all as set forth in the attached Statement, marked Exhibit “A” and incorporated
by reference indicating the liability for each of the Defendants, and all of the same, in the amounts
set forth in their names. The invoices which support and integrated in to the Statement are
attached hereto, marked Exhibits “B-1" to “B-44" and incorporated herein.
5. Although demand has been made, Defendants, ASIEN’S APPLIANCE, INC., a
corporation and each of the same, has failed and refused and continues to fail and refuse, to pay
said indebtedness, and every part thereof, even though the same and every part thereof are now
10 due, payable and unpaid. Interest has accrued in the amount all as set forth in Exhibit “A” and ‘
11 Exhibits “B-1" to “B-44” 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,
and each of them
24
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
was stated in writing by and between Plaintiff and Defendants, ASIEN’S APPLIANCE, INC., a
28
3
COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED
corporation and each of the same, in the amounts as set forth in Exhibit “A,” and Exhibits “B-1"
to “B-44” which is attached hereto and incorporated by reference as though fully set forth herein.
T iT ISE OF ACTION
QUANTUM MERIUIT: ASIEN’S APPLIANCE, INC., a corporation and Does 1 Through X,
and each of them
10. Plaintiff hereby incorporates all prior causes of action as though fully set forth herein.
11. Within four years last past and prior to the commencement of this action, Plaintiff
delivered, furnished, rendered or supplied GOODS and SERVICES to Defendants, ASIEN’S
10 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 Exhibit “A” and Exhibits “B-1" to “B-44” 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 1. For damages in the principal amount of $306,149.12 as set forth in Exhibit “A” and
18
Exhibits “B-1" to “B-44” 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
21 2. For accrued interest in the amount, interest accruing at the rate from the date so accruing
22 of 10% from and after September 20, 2023 until judgment is taken, all as set forth in Exhibit “A”
23 and Exhibits “B-1" to “B-44” 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
4
COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED
DATED: October 25, 2023 COOK couse ORNEYS PLC
a “4
DA VI"14-20
Atto:
OK, FSQ.
ys for Plaiptiff RIGGS
DISTRIBUTING, INC., a corporation
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”
Sy Statement
2 é RIGGS Breltc;
iow Bue-zene]
Gove)
[posi020 |
Page | of 2
3 Distributing, Inc.
itten Rd, Ste 201
Burlins me CA 94010
Phone: 650-240-3000
ASIEN’S APPLIANCE, INC.
1801
Santa Rosa CA 95403
United States
Pvesiele) 1) yavanelelalaa=talel| SU efilela
Le $305,149.12] RIGGS
Distributing,
Bish} iBy-ssteigel (celal Ola trel-1 ere WZait=nN4 Srl
El ale
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- 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 #792051 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 2323.56 306,149.12
B sSy Statement
Qe RIGGS
Goued Bue-zese] Cove
es
Page
2 of 2
Distributing, Inc.
oom itten Rd, Ste 200
Burlingame CA
United States
Phone: 650-240-3000
lenhicciala sESiOn BIN 3 SelM BIyr9 oe COM Bry (ONT 0mBI-W7s) Pavaaelelaja BIOL)
2,323.56 255,870.26 47,955.30 0.00 0.00 $306,149.12
EXHIBIT “B-1” TO “B-44”
gi gs Distributing, Inc. Invoice No.. 796283
RIGGS Mitten Rd, Ste 200
Burlingame CA 94010 2023-09-18
Use
SHOWROOM + Invoice Date.
DISTRIBUTING United States
Phone: 650-240-3000 Order Date. 2022-06-08
Invoice
Bill To Ship To
Ac . ASIEN'S APPLIANCE, INC.
ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403
1801 Piner Road United States
Santa Rosa CA 95403
United States
Customer P/O No Ship via Terms Shipped Territory Manager
15365 Display Pilot Freight Net 30 Nikki Cunningham
system
Ord Qty Ship Qty Item Serial Number Description Price uM Amount
1 1 GLS6SOUID/SIP/ 4815475 36" CLASSIC OVER-AND- $8,954.75 EA $8,954.75
UNDER REFRIGERATOR/
FREEZER WITH INTERNAL
DISPENSER
1 OEC1850FI/L 24444716 18" DESIGNER COLUMN $5,376.25 $5,376.25
"REEZER WITH ICE MAKER -
PANEL READY
1 DEC30S50RID/R 24386302 30" DESIGNER COLUMN $6,387.75 $6,387.75
REFRIGERATOR WITH
INTERNAL DISPENSER -
PANI DY
Memo ALL UNITS ARE FOR DISPLAY| (6/13: Pricing updated)| Subtotal $20,718.75
Discount $0.00
Ship/Handling $414.39
Tax Total (%) $0.00
Total $21,133.14
Total Due $21,133.14
2
(M0004
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 and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CRED!
APPLICATION OF RIGGS DISTRIBUTING INC. (ROI). 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
eSy RIGGS ase is Distributing, Inc.
Mitten Rd, Ste 200
Burlingame CA 94010
Invoice No..
Invoice Date.
796721
2023-09-19
Qs
SHOWROOM +
DISTRIBUTING Unites States
Phone: 650-240-3000 Order Date. 2022-09-09
Invoice
Bill To Ship To
ASIEN'S APPLIANCE, INC.
ASTEN'S APPLIANCE, INC, Santa Rosa CA 95403
1801 Piner Road United States
Santa Rosa CA 95403
United States
Customer P/O No Ship Via Terms Shipped Territory Manager
15917 Pilot Freight Net 30 Nikki Cunningham
stem
Ord Qty Ship Qty Item Serial Number Description Price U/M Amount
1 1 CL4250S/S/P 4820435 }2" 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
BOLO
Dear Customer:
We are invoicing
fi fo u for the products and services as listed in the attached invoices. The terms of the conditions of the sale of
the re ‘oducts ani /or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CRI
APP ICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the bi er, 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
aBurlingame
iggs Distributing, Inc. Invoice No. 786390
sy RIGGS Mitten Rd, Ste 200
CA 94010 Invoice Date.. 2023-08-22
tse
SHOWROOM +
DISTRIBUTING United States
Phone: 650-240-3000 Order Date. 2023-06-14
Invoice
Bill To Ship To
Acct, ASIEN'S APPLIANCE, INC.
ASIEN’S APPLIANCE, INC. Santa Rosa CA 95403
1801 Piner Roa United States
Santa Rosa CA 95403
United States
Customer P/O No Ship Via Terms Shipped Territory Manager
17325-C Pilot Freight Net 30 Nikki Cunningham
System
Ord Qty — Ship Qty Item Serial Number Description Price U/M Amount
1 1 DF486S0C/S/P 18783011 48" DUAL FUEL RANGE - 6 $12,970.00 EA $12,970.00
URNERS 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
goes
Dear Customer:
We are invoicing u for the products and services as listed in the attached invoices. The terms of the conditions of the sale of
the products and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT
CATION 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
Ri gs Distributing, Inc. Invoice No.. 786391
Sy RIGGS Mitten Rd, Ste 200
Burlingame CA 94010 Invoice Date. 2023-08-22
Use
SHOWROOM +
DISTRIBUTING Unite States
Phone: 650-240-3000 Order Date. 2023-08-08
Invoice
Bill To Ship To
ASIEN'S APPLIANCE, INC.
ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403
1801 Piner Roa United States
Santa Rosa CA 95403
United States
Customer P/O No Ship Via Terms Shipped Territory Manager
17050 Pilot Freight Net 30 Nikki Cunningham
System
Ord Qty Ship Qty Item Serial Number Description Price U/M Amount
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
oo0cA
Dear Customer:
i fi
We are invoicing you for the products and services as listed in the attached invoices. The terms of the conditions of the sale of
re ‘oducts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CRED
PI ICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the bu r, whether in a purchase order, online, or otherwise,
which varies or differs from, contradicts, or conflicts with the DEALERAG REEMENT and REDIT 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
Ri gs Distributing, Inc. Invoice No.. 795188
Sy RIGGS Mitten Rd, Ste 200
Burlingame CA 94010 2023-09-14
ds?
SHOWROOM + Invoice Date.
DISTRIBUTING Unite States
Phone: 650-240-3000 Order Date. 2022-09-15
Invoice
Bill To Ship To
Acct. ASIEN'S APPLIANCE, INC.
ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403
1801 Piner Road United States
Santa Rosa 9!
United States
Customer P/O No Ship Via Terms Shipped Territory Manager
15948 Pilot Freight Net 30 Nikki Cunningham
System
773 AGA
Ord Qty Ship Qty Item Serial Number Description Price U/M Amount
1 1 DEC30S0RID/R 24431873 30" DESIGNER COLUMN $7,515.00 EA $7,515.00
REFRIGERATOR
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
DNGLS
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
fi
the re ‘oducts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT
APPI [CATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the btOG r, whether in a purchase order, online, or otherwise,
which varies or differs from, contradicts, or conflicts with the DEALER \GREEMENT and REDIT 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
Sy RIGGS
SHOWROOM +
BF s Distributing, Inc.
Mitten Rd, Ste 200
Burlingame CA 94010
Invoice No...
Invoice Date.
787614
2023-08-24
thee DISTRIBUTING United States
Phone: 650-240-3000 Order Date. 2022-06-14
Invoice
Bill To Ship To
ASIEN'S APPLIANCE, INC.
ASTEN'S APPLIANCE, INC, Santa Rosa CA 9540:
1801 Piner Road United States
Santa Rosa CA 95403
United States
Customer P/O No Ship Via Terms Shipped Territory Manager
15404 Pilot Freight Net 30 Nikki Cunningham
system
Ord Qty Ship Qty Item Serial Number Description Price U/M Amount
1 1 DET36SOCHD/L 24413481 36" Designer Over-and- $8,670.00 EA $8,670.00
Under Refrigerator/Freezer
with Ice Maker and Internal
Dispenser - Panel Ready
Subtotal $8,670.00
Discount $0.00
Ship/Handling $173.40
Tax Total (%) $0.00
Total $8,843.40
Total Due $8,843.40
Sar,
é
Dear Customer:
We are invoicing u for the products and services as listed in the attached invoices. The terms of the conditions of the sale of
the roducts ani r services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT
a
APPLICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the b er, whether in a purchase order, online, or otherwise,
which varies or differs from, contradicts, or conflicts with the DEALER \GREEMENT and REDIT 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 &Burlingame
‘iggs Distributing, Inc.
Mitten Rd, Ste 200
CA 94010
Invoice No...
Invoice Date..
783801
2023-08-14
We
SHOWROOM +
DISTRIBUTING Unite: States
Phone: 650-240-3000 Order Date.. 2023-08-09
Invoice
Bill To Ship To
Acct. ASIEN'S APPLIANCE, INC.
ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403
1801 Piner Road United States
Santa Rosa CA 95403
United States
Customer P/O No Ship Via Terms Shipped Territory Manager
17512-C Pilot Freight Net 30 Nikki Cunningham
System
Ord Qty — Ship Qty Item Serial Number Description Price U/M Amount
2 2 7025228 SS Tubular Handle 33 1/4" $145.00 EA $2
(3/4" Diameter) - Sq
itandot
1 1 7025229 SS Tubular Handle 27 1/4" $145.00 EA $145.00
(3/4" Diameter) - Sq
Stando'
Subtotal $435.00
Discount $0.00
Ship/Handling $8.70
Tax Total (%) $0.00
Total $443.70
Total Due $443.70
00007
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
Apehi re oducts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT
rh
[CATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the bi er, whether in a purchase order, online, or otherwise,
which varies or differs from, contradicts, or conflicts with the DEALER AGREEMENT and REDIT 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
Invoice No.. 784953
aa s Distributing, Inc.
gy
We
RIGGS
SHOWROOM
DISTRIBUTING
+
Mitten Rd, Ste 200
Burlingame CA 94010
United States
Invoice Date. 2023-08-16
Phone: 650-240-3000 Order Date. 2022-11-16
Invoice
Bill To Ship To
ASIEN'S APPLIANCE, INC.
ASIENS APPLIANCE, INC. Santa Rosa CA
1801 Piner Road United States
Santa Rosa CA 3
United States
Customer P/O No Ship Via Terms Shipped Territory Manager
16363 Pilot Freight Net 30 Nikki Cunningham
System
Ord Qty Ship Qty Item Serial Number Description Price U/M Amount
2 2 CIBES0UFDID/ 4g0ge4s 36" Classic French Door $10,965.00 EA $21,930.00
Refrigerator/Freezer with
Internal Dispenser
Subtotal $21,930.00
Discount $0.00
Ship/Handling $438.60
Tax Total (%) $0.00
Total $22,368.60
Total Due $22,368.60
00008
Dear Customer:
ti a
We are invoicing ou for the products and services as listed in the attached invoices. The terms of the conditions of the sale of
the re ‘oducts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT
APP| [CATION 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
Ri igs Distributing, Inc. Invoice No... 785595
ey RIGGS Mitten Rd, Ste 200
Burlingame CA 94010 2023-08-18
Ase
SHOWROOM + Invoice Date.
DISTRIBUTING Unite States
Phone: 650-240-3000 Order Date. 2022-01-04
Invoice
Bill To Ship To
ASIEN'S APPLIANCE, INC.
ASiEN'S APPLIANCE, INC. Santa Rosa CA 95403
1801 Piner Roa United States
Santa Rosa CA 95403
United States
Customer P/O No Ship Via Terms Shipped Territory Manager
14455 Pilot Freight Net 30 Nikki Cunningham
System
Ord Qty — Ship Qty Item Serial Number Description Price U/M Amount
1 1 DET30S50RID/R 24390682 30" Designer Over-and- $7,970.00
Preview
Electronically by Superior ua H PBN (7 of San Mateo DAVID J. COOK, ESQ. (State Bar # 060859) COOK COLLECTION ATTORNEYS By. /s/ Jennifer Torres A PROFESSIONAL LAW CORPORATION Deputy Clerk 165 Fell Street, San Francisco, CA 94102-5106 P.O. Box 270, San Francisco, CA 94104-0270 Tel.: (415) 989-4730 Fax: (415) 989-0491 Email: Cook@SqueezeBloodFromTurnip.com File No. 58,740 Attomeys for Plaintiff RIGGS DISTRIBUTING, INC., a corporation SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF SAN MATEO UNLIMITED CIVIL JURISDICTION 10 RIGGS DISTRIBUTING, INC., a CASE NO. 23-CIV-05051 corporation FIRST AMENDED COMPLAINT FOR 1 Plaintiff, GOODS SOLD AND DELIVERED 12 vs. 13 ASIEN’S APPLIANCE, INC., a corporation, AND DOES I THROUGH The amount prayed for is more than $25,000.00 14 X, AND EACH OF THEM, $306,149.12 15 INCLUSIVE, Date of Filing: October 24, 2023. Judge: Honorable Susen Greenberg 16 Defendants. Dept. 3, Court Room 2 B 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. USE OF 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, Plaintiff RIGGS DISTRIBUTING, INC., a corporation is a corporation, doing business in the State of California, whose appropriate regulatory licensing or political subdivisions, agencies, departments, or the like, if any, have issued to Plaintiff the appropriate licenses, certificates, permits or permissions to sell or furnish the'‘above GOODS and SERVICES. 2. Plaintiff is unaware of the true names or capacities of Defendants named DOES | THROUGH X, AND EACH OF THEM, praying leave to amend this Complaint when their true names and capacities are ascertained. 3. Atall 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 a reasonable value all as set forth in the attached Statement, marked Exhibit “A” and incorporated by reference indicating the liability for each of the Defendants, and all of the same, in the amounts set forth in their names. The invoices which support and integrated in to the Statement are attached hereto, marked Exhibits “B-1" to “B-44" and incorporated herein. 5. Although demand has been made, Defendants, ASIEN’S APPLIANCE, INC., a corporation and each of the same, has failed and refused and continues to fail and refuse, to pay said indebtedness, and every part thereof, even though the same and every part thereof are now 10 due, payable and unpaid. Interest has accrued in the amount all as set forth in Exhibit “A” and ‘ 11 Exhibits “B-1" to “B-44” 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, and each of them 24 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 was stated in writing by and between Plaintiff and Defendants, ASIEN’S APPLIANCE, INC., a 28 3 COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED corporation and each of the same, in the amounts as set forth in Exhibit “A,” and Exhibits “B-1" to “B-44” which is attached hereto and incorporated by reference as though fully set forth herein. T iT ISE OF ACTION QUANTUM MERIUIT: ASIEN’S APPLIANCE, INC., a corporation and Does 1 Through X, and each of them 10. Plaintiff hereby incorporates all prior causes of action as though fully set forth herein. 11. Within four years last past and prior to the commencement of this action, Plaintiff delivered, furnished, rendered or supplied GOODS and SERVICES to Defendants, ASIEN’S 10 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 Exhibit “A” and Exhibits “B-1" to “B-44” 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 1. For damages in the principal amount of $306,149.12 as set forth in Exhibit “A” and 18 Exhibits “B-1" to “B-44” 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 21 2. For accrued interest in the amount, interest accruing at the rate from the date so accruing 22 of 10% from and after September 20, 2023 until judgment is taken, all as set forth in Exhibit “A” 23 and Exhibits “B-1" to “B-44” 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 4 COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED DATED: October 25, 2023 COOK couse ORNEYS PLC a “4 DA VI"14-20 Atto: OK, FSQ. ys for Plaiptiff RIGGS DISTRIBUTING, INC., a corporation 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” Sy Statement 2 é RIGGS Breltc; iow Bue-zene] Gove) [posi020 | Page | of 2 3 Distributing, Inc. itten Rd, Ste 201 Burlins me CA 94010 Phone: 650-240-3000 ASIEN’S APPLIANCE, INC. 1801 Santa Rosa CA 95403 United States Pvesiele) 1) yavanelelalaa=talel| SU efilela Le $305,149.12] RIGGS Distributing, Bish} iBy-ssteigel (celal Ola trel-1 ere WZait=nN4 Srl El ale 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- 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 #792051 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 2323.56 306,149.12 B sSy Statement Qe RIGGS Goued Bue-zese] Cove es Page 2 of 2 Distributing, Inc. oom itten Rd, Ste 200 Burlingame CA United States Phone: 650-240-3000 lenhicciala sESiOn BIN 3 SelM BIyr9 oe COM Bry (ONT 0mBI-W7s) Pavaaelelaja BIOL) 2,323.56 255,870.26 47,955.30 0.00 0.00 $306,149.12 EXHIBIT “B-1” TO “B-44” gi gs Distributing, Inc. Invoice No.. 796283 RIGGS Mitten Rd, Ste 200 Burlingame CA 94010 2023-09-18 Use SHOWROOM + Invoice Date. DISTRIBUTING United States Phone: 650-240-3000 Order Date. 2022-06-08 Invoice Bill To Ship To Ac . ASIEN'S APPLIANCE, INC. ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403 1801 Piner Road United States Santa Rosa CA 95403 United States Customer P/O No Ship via Terms Shipped Territory Manager 15365 Display Pilot Freight Net 30 Nikki Cunningham system Ord Qty Ship Qty Item Serial Number Description Price uM Amount 1 1 GLS6SOUID/SIP/ 4815475 36" CLASSIC OVER-AND- $8,954.75 EA $8,954.75 UNDER REFRIGERATOR/ FREEZER WITH INTERNAL DISPENSER 1 OEC1850FI/L 24444716 18" DESIGNER COLUMN $5,376.25 $5,376.25 "REEZER WITH ICE MAKER - PANEL READY 1 DEC30S50RID/R 24386302 30" DESIGNER COLUMN $6,387.75 $6,387.75 REFRIGERATOR WITH INTERNAL DISPENSER - PANI DY Memo ALL UNITS ARE FOR DISPLAY| (6/13: Pricing updated)| Subtotal $20,718.75 Discount $0.00 Ship/Handling $414.39 Tax Total (%) $0.00 Total $21,133.14 Total Due $21,133.14 2 (M0004 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 and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CRED! APPLICATION OF RIGGS DISTRIBUTING INC. (ROI). 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 eSy RIGGS ase is Distributing, Inc. Mitten Rd, Ste 200 Burlingame CA 94010 Invoice No.. Invoice Date. 796721 2023-09-19 Qs SHOWROOM + DISTRIBUTING Unites States Phone: 650-240-3000 Order Date. 2022-09-09 Invoice Bill To Ship To ASIEN'S APPLIANCE, INC. ASTEN'S APPLIANCE, INC, Santa Rosa CA 95403 1801 Piner Road United States Santa Rosa CA 95403 United States Customer P/O No Ship Via Terms Shipped Territory Manager 15917 Pilot Freight Net 30 Nikki Cunningham stem Ord Qty Ship Qty Item Serial Number Description Price U/M Amount 1 1 CL4250S/S/P 4820435 }2" 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 BOLO Dear Customer: We are invoicing fi fo u for the products and services as listed in the attached invoices. The terms of the conditions of the sale of the re ‘oducts ani /or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CRI APP ICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the bi er, 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 aBurlingame iggs Distributing, Inc. Invoice No. 786390 sy RIGGS Mitten Rd, Ste 200 CA 94010 Invoice Date.. 2023-08-22 tse SHOWROOM + DISTRIBUTING United States Phone: 650-240-3000 Order Date. 2023-06-14 Invoice Bill To Ship To Acct, ASIEN'S APPLIANCE, INC. ASIEN’S APPLIANCE, INC. Santa Rosa CA 95403 1801 Piner Roa United States Santa Rosa CA 95403 United States Customer P/O No Ship Via Terms Shipped Territory Manager 17325-C Pilot Freight Net 30 Nikki Cunningham System Ord Qty — Ship Qty Item Serial Number Description Price U/M Amount 1 1 DF486S0C/S/P 18783011 48" DUAL FUEL RANGE - 6 $12,970.00 EA $12,970.00 URNERS 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 goes Dear Customer: We are invoicing u for the products and services as listed in the attached invoices. The terms of the conditions of the sale of the products and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT CATION 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 Ri gs Distributing, Inc. Invoice No.. 786391 Sy RIGGS Mitten Rd, Ste 200 Burlingame CA 94010 Invoice Date. 2023-08-22 Use SHOWROOM + DISTRIBUTING Unite States Phone: 650-240-3000 Order Date. 2023-08-08 Invoice Bill To Ship To ASIEN'S APPLIANCE, INC. ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403 1801 Piner Roa United States Santa Rosa CA 95403 United States Customer P/O No Ship Via Terms Shipped Territory Manager 17050 Pilot Freight Net 30 Nikki Cunningham System Ord Qty Ship Qty Item Serial Number Description Price U/M Amount 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 oo0cA Dear Customer: i fi We are invoicing you for the products and services as listed in the attached invoices. The terms of the conditions of the sale of re ‘oducts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CRED PI ICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the bu r, whether in a purchase order, online, or otherwise, which varies or differs from, contradicts, or conflicts with the DEALERAG REEMENT and REDIT 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 Ri gs Distributing, Inc. Invoice No.. 795188 Sy RIGGS Mitten Rd, Ste 200 Burlingame CA 94010 2023-09-14 ds? SHOWROOM + Invoice Date. DISTRIBUTING Unite States Phone: 650-240-3000 Order Date. 2022-09-15 Invoice Bill To Ship To Acct. ASIEN'S APPLIANCE, INC. ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403 1801 Piner Road United States Santa Rosa 9! United States Customer P/O No Ship Via Terms Shipped Territory Manager 15948 Pilot Freight Net 30 Nikki Cunningham System 773 AGA Ord Qty Ship Qty Item Serial Number Description Price U/M Amount 1 1 DEC30S0RID/R 24431873 30" DESIGNER COLUMN $7,515.00 EA $7,515.00 REFRIGERATOR 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 DNGLS 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 fi the re ‘oducts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT APPI [CATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the btOG r, whether in a purchase order, online, or otherwise, which varies or differs from, contradicts, or conflicts with the DEALER \GREEMENT and REDIT 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 Sy RIGGS SHOWROOM + BF s Distributing, Inc. Mitten Rd, Ste 200 Burlingame CA 94010 Invoice No... Invoice Date. 787614 2023-08-24 thee DISTRIBUTING United States Phone: 650-240-3000 Order Date. 2022-06-14 Invoice Bill To Ship To ASIEN'S APPLIANCE, INC. ASTEN'S APPLIANCE, INC, Santa Rosa CA 9540: 1801 Piner Road United States Santa Rosa CA 95403 United States Customer P/O No Ship Via Terms Shipped Territory Manager 15404 Pilot Freight Net 30 Nikki Cunningham system Ord Qty Ship Qty Item Serial Number Description Price U/M Amount 1 1 DET36SOCHD/L 24413481 36" Designer Over-and- $8,670.00 EA $8,670.00 Under Refrigerator/Freezer with Ice Maker and Internal Dispenser - Panel Ready Subtotal $8,670.00 Discount $0.00 Ship/Handling $173.40 Tax Total (%) $0.00 Total $8,843.40 Total Due $8,843.40 Sar, é Dear Customer: We are invoicing u for the products and services as listed in the attached invoices. The terms of the conditions of the sale of the roducts ani r services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT a APPLICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the b er, whether in a purchase order, online, or otherwise, which varies or differs from, contradicts, or conflicts with the DEALER \GREEMENT and REDIT 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 &Burlingame ‘iggs Distributing, Inc. Mitten Rd, Ste 200 CA 94010 Invoice No... Invoice Date.. 783801 2023-08-14 We SHOWROOM + DISTRIBUTING Unite: States Phone: 650-240-3000 Order Date.. 2023-08-09 Invoice Bill To Ship To Acct. ASIEN'S APPLIANCE, INC. ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403 1801 Piner Road United States Santa Rosa CA 95403 United States Customer P/O No Ship Via Terms Shipped Territory Manager 17512-C Pilot Freight Net 30 Nikki Cunningham System Ord Qty — Ship Qty Item Serial Number Description Price U/M Amount 2 2 7025228 SS Tubular Handle 33 1/4" $145.00 EA $2 (3/4" Diameter) - Sq itandot 1 1 7025229 SS Tubular Handle 27 1/4" $145.00 EA $145.00 (3/4" Diameter) - Sq Stando' Subtotal $435.00 Discount $0.00 Ship/Handling $8.70 Tax Total (%) $0.00 Total $443.70 Total Due $443.70 00007 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 Apehi re oducts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT rh [CATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the bi er, whether in a purchase order, online, or otherwise, which varies or differs from, contradicts, or conflicts with the DEALER AGREEMENT and REDIT 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 Invoice No.. 784953 aa s Distributing, Inc. gy We RIGGS SHOWROOM DISTRIBUTING + Mitten Rd, Ste 200 Burlingame CA 94010 United States Invoice Date. 2023-08-16 Phone: 650-240-3000 Order Date. 2022-11-16 Invoice Bill To Ship To ASIEN'S APPLIANCE, INC. ASIENS APPLIANCE, INC. Santa Rosa CA 1801 Piner Road United States Santa Rosa CA 3 United States Customer P/O No Ship Via Terms Shipped Territory Manager 16363 Pilot Freight Net 30 Nikki Cunningham System Ord Qty Ship Qty Item Serial Number Description Price U/M Amount 2 2 CIBES0UFDID/ 4g0ge4s 36" Classic French Door $10,965.00 EA $21,930.00 Refrigerator/Freezer with Internal Dispenser Subtotal $21,930.00 Discount $0.00 Ship/Handling $438.60 Tax Total (%) $0.00 Total $22,368.60 Total Due $22,368.60 00008 Dear Customer: ti a We are invoicing ou for the products and services as listed in the attached invoices. The terms of the conditions of the sale of the re ‘oducts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT APP| [CATION 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 Ri igs Distributing, Inc. Invoice No... 785595 ey RIGGS Mitten Rd, Ste 200 Burlingame CA 94010 2023-08-18 Ase SHOWROOM + Invoice Date. DISTRIBUTING Unite States Phone: 650-240-3000 Order Date. 2022-01-04 Invoice Bill To Ship To ASIEN'S APPLIANCE, INC. ASiEN'S APPLIANCE, INC. Santa Rosa CA 95403 1801 Piner Roa United States Santa Rosa CA 95403 United States Customer P/O No Ship Via Terms Shipped Territory Manager 14455 Pilot Freight Net 30 Nikki Cunningham System Ord Qty — Ship Qty Item Serial Number Description Price U/M Amount 1 1 DET30S50RID/R 24390682 30" Designer Over-and- $7,970.00