Preview
Electronically
bys Fe ip eres" of San Mate
DAVID J. COOK, ESQ. (State Bar # 060859)
COOK COLLECTION A’ By. /s/ Anthony Berini
A PROFESSIONAL LAW CORPORATION Deputy Cle
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
Attorneys for Plaintiff RIGGS DISTRIBUTING, INC., a corporation
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
UNLIMITED CIVIL JURISDICTION
23-CIV-05051
10 RIGGS DISTRIBUTING, INC., a CASE NO.
corporation
Ml 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
iF 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. 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 I
THROUGH X, AND EACH OF THEM, praying leave to amend this Complaint when their true
names and capacities are ascertained.
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
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-34" 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-34” 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. Atall 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
21 as described herein in the course and scope of their agency, employment and serving hereunder.
s D OF
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, 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-34” which is attached hereto and incorporated by reference as though fully set forth herein.
USE OF
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. Atall 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-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 1, For damages in the principal amount of $306,149.12 as set forth in Exhibit “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 Exhibit “A”
23 and Exhibits “B-1" to “B-34” which is attached hereto and incorporated by reference as though
24
fully set forth herein.
25
3. For reasonable attomeys fees and costs of suit herein.
26
27 4. For other and further relief as the Court deems just and proper.
28 HW
4
COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED
DATED: October 24, 2023 COOK COLLECTIO! ‘ORNEYS PLC
f
By:
DAVID J{COOK7E Si
Attorneys for Plaintiff IGGS
“DISTRIBUTING, IN ., 4 corporation
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
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5
COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED
EXHIBIT “A”
&2 RIGGS Statement
Br}(c)
[zzs1020 |
Page
1 of 2
Distributing, Inc.
sauna itten Rd, Ste 200
Burtin: me CA 94010
United States
Phone: 650-240-3000
ASIEN’S APPLIANCE, INC.
1801 PinerR
Santa Rosa CA 95403
United States
Paveliia Le) raaselslea =nlele SST] ekifel tla
Pe $206,149.12] | RIGGS Distributing, |
BEN} 1By-ssterg]e)
te) al Oar Iee(-) ete \AEALanl Sr-lFlale
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,
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 #792051 11,622.90 223,884.32
2023-09- Invoice #792566 7,665.30 231,549.62
2023. Invoice #792567 8,843.40 240,393.02
2023. 1 Invoice #793538 5,936.40 246,329.42
2023- 1 Invoice #793540 249,996.32
2023-09-13 Invoice #794978 11,367.90 261,364.22
2023-09-13 Invoice #794979 263,093.12
2023-09-13 Invoice #794977 1,162.80 264,255.92
2023-09-14 Invoice #795188 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
«3 RIGGS Statement
Biowes MISCe DUD
sl
Page
2 of 2
OM Distributing, Inc.
itten Rd, Ste 200
Burlin: me CA
Unite
Phone: 650-240-3000
Or ic-n) WEciem Br" CME ol0M BI-Nc) ou cl OM BTA (ON lOMBY-\73 PNisleleia ja B10 Ic)
2,323.56 255,870.26 47,955.30 0.00 0.00 $306,149.12
EXHIBIT “B-1” TO “B-34”
sy RIGGS éBurlingame
iggs Distributing, Inc.
Mitten Rd, Ste 200
CA 94010
Invoice No...
Invoice Date..
796283
2023-09-18
ts
SHOWROOM +
DISTRIBUTING Unites States
CALE OMNIA 8 wawair Phone: 650-240-3000 Order Date.. 2022-06-08
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/t ‘Terms ed
15365 Displ. Frei Net 30
System
‘Ord Qty. Shipaty Serial. Numbi P! ‘Price: ‘Amount:
a Le
CL36SOUIDIS/P/ 4815475, LASSIC OVER-AND-
UNDER REFRIGERATOR/
“$895475 EA "895475
FREEZER WITH INTERNAL
DISPENS!
DEC18S0FI/L 24444716 18" DESIGNER COLUMN $5,376.25 EA $5,376.25
FREEZER WITH ICE MAKER -
PANEL READY
DEC30SORID/R 24386302 30" DESIGNER COLUMN $6,387.75 EA $6,387.75
REFRIGERATOR WI
INTERNAL DISPENSER -
PANEL READY
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
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
f
the oducts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT
APP ICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms o' 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
1
“|
RIGGS aBurlingame
s Distributing, Inc.
Mitten Rd, Ste 200
CA 94010
Invoice No.. 796721
SHOWROOM + Invoice Date. 2023-09-19
ig? DISTRIBUTING
CALIFORUIA Rawat
Unite States
Phone: 650-240-3000 Order Date. 2022-09-09
Invoice
BI To Ship To
ASIEN'S APPLIANCE, INC.
ASTEN'S APPLIANCE, INC. Santa Rosa CA
1801 Piner Roa United States
Santa Rosa CA 95403
United States
CustomerP/0\No ‘Shipmt 2 Teritis, Sa ee ‘Ship aS Manager
eeneg
15917 Pilot Fre’ ight Net 30 ‘unningham
System
‘Ord: Ip'Qty, Ite lan Fic ~ Amount
1 ” cuaasosis/e 4820435 LASSIC SIDE-BY-SIDE
REFRIGERATOR/FREEZER
$10,560.00 EA “$10,560.00
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:
meer
We are invoicing you for the products and services as listed in the attached invoices, The terms of the conditions of the sale of
ts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or
IN OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the b r, 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
Crv
RIGGS aa s Distributing, Inc.
Mitten Rd, Ste 200
Burlingame CA 94010
Invoice No. 786390
Invoice Date. 2023-08-22
bse
SHOWROOM +
DISTRIBUTING Unite States
CALIFoRurA
| amas Phone: 650-240-3000 Order Date. 2023-06-14
Invoice
BIN To Ship To
ASIEN'S APPLIANCE, INC.
ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403
1801 Piner Road United States
panta Rosa cA 95403
-
foiNo: ‘stil ae jad" he
‘ight Ne ‘unning|
gystern
Ord }Num
Dererly a mt * Amount
aa :
1 DF48650C/S/P 18783011 48” DUAL FUEL RANGE - 6 $12,970.00 EA $12,970.00
BURNERS AND INFRARED
CHARBROILER - NG
—- ees a
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 u for the products and services as listed in the attached invoices. The terms of the conditions of the sale of
the roducts an r services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT
PPLICATI ISTRIBUTING 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 DEALER JREEMENT 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.
¢-3
Page 1 of 1
gry RIGGS aBurlingame
‘iggs Distributing, Inc.
Mitten Rd, Ste 200
CA 94010
Invoice No...
Invoice Date.
786391
2023-08-22
Rae
SHOWROOM +
DISTRIBUTING Unite States
CALIFORNIA & HAWAtE 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
Custom No shi _ Stlpped
17050 Pllot ht kk ghai
System
-
Ord Qty ship any Item: Serlak.Nuiml ptio
er Amount
- ane
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 and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CRED!
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 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.
e
Page 1 of 1
Riggs Distributing, Inc. Invoice No... 795188
RIGGS 8: Mitten Rd, Ste 200
Burlingame CA 94010 Invoice Date.. 2023-09-14
Ue
SHOWROOM +
DISTRIBUTING United States
CALIFORNIA A waWare 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 9540:
1801 Piner Road United States
Santa Rosa CA 95403
United States
~T
Custom hi Shipped:
ee
15948 Pilot Freig| Net 30 Nikki Cunningham
System
~
Ord Qty, Ship Qty: Item, ‘Serial. Nuva ription “Amount
a te ate aa lie
EC3OSORIOIR 24431873 30” DESIGNER COL
IN $7, 00 EA $7,515.00
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 ducts 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 bu r, whether in a purchase order, online, or otherwise,
which varies or differs from, contradicts, or conflicts with the DEALER 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,
g
0
Page 1 of 1
S
RIGGS aa s Distributing, Inc.
Mitten Rd, Ste 200
Burlingame CA 94010
Invoice No... 787614
Invoice Date. 2023-08-24
Rs
SHOWROOM +
DISTRIBUTING Unite States
AHORA
A ama Phone: 650-240-3000 Order Date. 2022-06-14
Invoice
BIN 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
Cus!
154 ki
system
es
ortay spay ” DET36SOCUD/L
-:
‘Seflal’ Number: ma {Amount
1 1 24413481 36" Designer Over-and- "$8,670.00 ia , ~ $8,670.00
Under Refrigerator/Freezer
with Ice Maker and Internal
Dispenser - Panel Ready
a _
Subtotal $8,670.00
Discount $0.00
Ship/Handling $173.40
Tax Total (%) $0.00
Total $8,843.40
Total Due $8,843.40
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 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
€-G
Ri igs Distributing, Inc. Invoice No... 783801
RIGGS Mitten Rd, Ste 200
SHOWROOM + Burlingame CA 94010 Invoice Date. 2023-08-14
Re? DISTRIBUTING
CALIFORNIA A aware
Unites States
Phone: 650-240-3000 Order Date. 2023-08-09
Invoice
Bill To Ship To
ASIEN'S APPLIANCE, INC.
ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403
1801 Piner Road United States
Santa Rosa CA 95403
United States
Custo ‘shipvia Tei
17512-C Pilot Freig) Cui igham
System
Ord Qty
ae
stip ay Item Seriat Number Description “ priee U/M ‘Amount
2 7025228 ‘SS Tubular Handle 33 1/4" $145.00 EA $290.00
(3/4” Diameter) - Sq
itandot
1 1 7025229 $S 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
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
ApPI f CATION
the roducts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT
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.
g
Page 1 of 1
RIGGS 3% gsMitten
aBurlingame
Distributing, Inc.
Rd, Ste 200
CA 94010
Invoice No... 784953
Ase
SHOWROOM + Invoice Date.. 2023-08-16
DISTRIBUTING Unite: States
CALIFORNIA
A Haw A Phone: 650-240-3000 Order Date.. 2022-11-16
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! hip:via: eke ‘Ternis'
is o ger
16363 — jot Freight Net 30 nl ham
System
’ ber’
Ord ‘Ship:Qty,, Item Seri ription: ice. ‘Amount
+ i abe,be
C136s0UFOIY :
‘
2 “4808645 Classic French Door $10,965. 00 EA ~~ $21,930.00
647 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
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
APPLICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the bt 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
e
Preview
Electronically bys Fe ip eres" of San Mate DAVID J. COOK, ESQ. (State Bar # 060859) COOK COLLECTION A’ By. /s/ Anthony Berini A PROFESSIONAL LAW CORPORATION Deputy Cle 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 Attorneys for Plaintiff RIGGS DISTRIBUTING, INC., a corporation SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF SAN MATEO UNLIMITED CIVIL JURISDICTION 23-CIV-05051 10 RIGGS DISTRIBUTING, INC., a CASE NO. corporation Ml 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 iF 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. 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 I THROUGH X, AND EACH OF THEM, praying leave to amend this Complaint when their true names and capacities are ascertained. 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 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-34" 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-34” 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. Atall 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 21 as described herein in the course and scope of their agency, employment and serving hereunder. s D OF 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, 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-34” which is attached hereto and incorporated by reference as though fully set forth herein. USE OF 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. Atall 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-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 1, For damages in the principal amount of $306,149.12 as set forth in Exhibit “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 Exhibit “A” 23 and Exhibits “B-1" to “B-34” which is attached hereto and incorporated by reference as though 24 fully set forth herein. 25 3. For reasonable attomeys fees and costs of suit herein. 26 27 4. For other and further relief as the Court deems just and proper. 28 HW 4 COMPLAINT FOR GOODS AND SERVICES FURNISHED AND RENDERED DATED: October 24, 2023 COOK COLLECTIO! ‘ORNEYS PLC f By: DAVID J{COOK7E Si Attorneys for Plaintiff IGGS “DISTRIBUTING, IN ., 4 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” &2 RIGGS Statement Br}(c) [zzs1020 | Page 1 of 2 Distributing, Inc. sauna itten Rd, Ste 200 Burtin: me CA 94010 United States Phone: 650-240-3000 ASIEN’S APPLIANCE, INC. 1801 PinerR Santa Rosa CA 95403 United States Paveliia Le) raaselslea =nlele SST] ekifel tla Pe $206,149.12] | RIGGS Distributing, | BEN} 1By-ssterg]e) te) al Oar Iee(-) ete \AEALanl Sr-lFlale 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, 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 #792051 11,622.90 223,884.32 2023-09- Invoice #792566 7,665.30 231,549.62 2023. Invoice #792567 8,843.40 240,393.02 2023. 1 Invoice #793538 5,936.40 246,329.42 2023- 1 Invoice #793540 249,996.32 2023-09-13 Invoice #794978 11,367.90 261,364.22 2023-09-13 Invoice #794979 263,093.12 2023-09-13 Invoice #794977 1,162.80 264,255.92 2023-09-14 Invoice #795188 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 «3 RIGGS Statement Biowes MISCe DUD sl Page 2 of 2 OM Distributing, Inc. itten Rd, Ste 200 Burlin: me CA Unite Phone: 650-240-3000 Or ic-n) WEciem Br" CME ol0M BI-Nc) ou cl OM BTA (ON lOMBY-\73 PNisleleia ja B10 Ic) 2,323.56 255,870.26 47,955.30 0.00 0.00 $306,149.12 EXHIBIT “B-1” TO “B-34” sy RIGGS éBurlingame iggs Distributing, Inc. Mitten Rd, Ste 200 CA 94010 Invoice No... Invoice Date.. 796283 2023-09-18 ts SHOWROOM + DISTRIBUTING Unites States CALE OMNIA 8 wawair Phone: 650-240-3000 Order Date.. 2022-06-08 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/t ‘Terms ed 15365 Displ. Frei Net 30 System ‘Ord Qty. Shipaty Serial. Numbi P! ‘Price: ‘Amount: a Le CL36SOUIDIS/P/ 4815475, LASSIC OVER-AND- UNDER REFRIGERATOR/ “$895475 EA "895475 FREEZER WITH INTERNAL DISPENS! DEC18S0FI/L 24444716 18" DESIGNER COLUMN $5,376.25 EA $5,376.25 FREEZER WITH ICE MAKER - PANEL READY DEC30SORID/R 24386302 30" DESIGNER COLUMN $6,387.75 EA $6,387.75 REFRIGERATOR WI INTERNAL DISPENSER - PANEL READY 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 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 f the oducts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT APP ICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms o' 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 1 “| RIGGS aBurlingame s Distributing, Inc. Mitten Rd, Ste 200 CA 94010 Invoice No.. 796721 SHOWROOM + Invoice Date. 2023-09-19 ig? DISTRIBUTING CALIFORUIA Rawat Unite States Phone: 650-240-3000 Order Date. 2022-09-09 Invoice BI To Ship To ASIEN'S APPLIANCE, INC. ASTEN'S APPLIANCE, INC. Santa Rosa CA 1801 Piner Roa United States Santa Rosa CA 95403 United States CustomerP/0\No ‘Shipmt 2 Teritis, Sa ee ‘Ship aS Manager eeneg 15917 Pilot Fre’ ight Net 30 ‘unningham System ‘Ord: Ip'Qty, Ite lan Fic ~ Amount 1 ” cuaasosis/e 4820435 LASSIC SIDE-BY-SIDE REFRIGERATOR/FREEZER $10,560.00 EA “$10,560.00 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: meer We are invoicing you for the products and services as listed in the attached invoices, The terms of the conditions of the sale of ts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or IN OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the b r, 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 Crv RIGGS aa s Distributing, Inc. Mitten Rd, Ste 200 Burlingame CA 94010 Invoice No. 786390 Invoice Date. 2023-08-22 bse SHOWROOM + DISTRIBUTING Unite States CALIFoRurA | amas Phone: 650-240-3000 Order Date. 2023-06-14 Invoice BIN To Ship To ASIEN'S APPLIANCE, INC. ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403 1801 Piner Road United States panta Rosa cA 95403 - foiNo: ‘stil ae jad" he ‘ight Ne ‘unning| gystern Ord }Num Dererly a mt * Amount aa : 1 DF48650C/S/P 18783011 48” DUAL FUEL RANGE - 6 $12,970.00 EA $12,970.00 BURNERS AND INFRARED CHARBROILER - NG —- ees a 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 u for the products and services as listed in the attached invoices. The terms of the conditions of the sale of the roducts an r services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT PPLICATI ISTRIBUTING 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 DEALER JREEMENT 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. ¢-3 Page 1 of 1 gry RIGGS aBurlingame ‘iggs Distributing, Inc. Mitten Rd, Ste 200 CA 94010 Invoice No... Invoice Date. 786391 2023-08-22 Rae SHOWROOM + DISTRIBUTING Unite States CALIFORNIA & HAWAtE 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 Custom No shi _ Stlpped 17050 Pllot ht kk ghai System - Ord Qty ship any Item: Serlak.Nuiml ptio er Amount - ane 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 and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CRED! 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 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. e Page 1 of 1 Riggs Distributing, Inc. Invoice No... 795188 RIGGS 8: Mitten Rd, Ste 200 Burlingame CA 94010 Invoice Date.. 2023-09-14 Ue SHOWROOM + DISTRIBUTING United States CALIFORNIA A waWare 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 9540: 1801 Piner Road United States Santa Rosa CA 95403 United States ~T Custom hi Shipped: ee 15948 Pilot Freig| Net 30 Nikki Cunningham System ~ Ord Qty, Ship Qty: Item, ‘Serial. Nuva ription “Amount a te ate aa lie EC3OSORIOIR 24431873 30” DESIGNER COL IN $7, 00 EA $7,515.00 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 ducts 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 bu r, whether in a purchase order, online, or otherwise, which varies or differs from, contradicts, or conflicts with the DEALER 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, g 0 Page 1 of 1 S RIGGS aa s Distributing, Inc. Mitten Rd, Ste 200 Burlingame CA 94010 Invoice No... 787614 Invoice Date. 2023-08-24 Rs SHOWROOM + DISTRIBUTING Unite States AHORA A ama Phone: 650-240-3000 Order Date. 2022-06-14 Invoice BIN 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 Cus! 154 ki system es ortay spay ” DET36SOCUD/L -: ‘Seflal’ Number: ma {Amount 1 1 24413481 36" Designer Over-and- "$8,670.00 ia , ~ $8,670.00 Under Refrigerator/Freezer with Ice Maker and Internal Dispenser - Panel Ready a _ Subtotal $8,670.00 Discount $0.00 Ship/Handling $173.40 Tax Total (%) $0.00 Total $8,843.40 Total Due $8,843.40 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 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 €-G Ri igs Distributing, Inc. Invoice No... 783801 RIGGS Mitten Rd, Ste 200 SHOWROOM + Burlingame CA 94010 Invoice Date. 2023-08-14 Re? DISTRIBUTING CALIFORNIA A aware Unites States Phone: 650-240-3000 Order Date. 2023-08-09 Invoice Bill To Ship To ASIEN'S APPLIANCE, INC. ASIEN'S APPLIANCE, INC. Santa Rosa CA 95403 1801 Piner Road United States Santa Rosa CA 95403 United States Custo ‘shipvia Tei 17512-C Pilot Freig) Cui igham System Ord Qty ae stip ay Item Seriat Number Description “ priee U/M ‘Amount 2 7025228 ‘SS Tubular Handle 33 1/4" $145.00 EA $290.00 (3/4” Diameter) - Sq itandot 1 1 7025229 $S 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 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 ApPI f CATION the roducts and/or services which are described in these invoices are subject to the DEALER AGREEMENT and/or CREDIT 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. g Page 1 of 1 RIGGS 3% gsMitten aBurlingame Distributing, Inc. Rd, Ste 200 CA 94010 Invoice No... 784953 Ase SHOWROOM + Invoice Date.. 2023-08-16 DISTRIBUTING Unite: States CALIFORNIA A Haw A Phone: 650-240-3000 Order Date.. 2022-11-16 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! hip:via: eke ‘Ternis' is o ger 16363 — jot Freight Net 30 nl ham System ’ ber’ Ord ‘Ship:Qty,, Item Seri ription: ice. ‘Amount + i abe,be C136s0UFOIY : ‘ 2 “4808645 Classic French Door $10,965. 00 EA ~~ $21,930.00 647 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 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 APPLICATION OF RIGGS DISTRIBUTING INC. (RDI). Any terms of the bt 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 e