On April 25, 2022 a
Judgment
was filed
involving a dispute between
Creditors Adjustment Bureau, Inc,
and
Does 1 Through 10, Inclusive,
Hospice Care At Home Inc.,
Hospice Care At Home, Inc,
Providence Hospice Inc.,
for Rule 3.740 Collections$10,000.01 - $25,000 Limited
in the District Court of San Bernardino County.
Preview
SUP R
F I a. E D
KENNETH J. FREED, ESQ. [SBN 125349] 25$er 893g; 3253553315?
QAN BERNARD'NO DISTRICT
ERIC J, ESQ [SBN. 263502]
JUN,
LAW OFFICES OF KENNETH J. FREED FEB 4
4340 Fulton Ave., Third Floor 1 2023
Sherman Oaks, California 91423
(818) 990—0888 (818) 990-1047 Facsimile
..
x.
KFREED@KJFESQ.COM / EJUN@KJFESQ.C0M .W Charisse Navarro, Deputy.
Attorneys for Plaintiff
CREDITORS ADJUSTMENT BUREAU, INC.
Our File No. 6078 197
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
SAN BERNARDINO JUSTICE CENTER, LIMITED CIVIL
10 CREDITORS ADJUSTMENT BUREAU, INC, )
CASE NO. CIVSBZZOS629
)
11 P1aintiff(s),
i
12 vs. )
DECLARATION OF ALEXIS INNIS
)
PURSUANT TO C.C.P.
13 )
SECTION 585(d) AND
)
ASSIGNMENT
14 HOSPICE CARE AT HOME, INC. DBA )
HOSPICE CARE AT HOME INC ADBA )
AT HOME; PROVIDENCE Electronic Signature per
15 HOSPICE CARE )
C.R.C. 2.257(a)
HOSPICE INC. DBA PROVIDENCE HOSPICE )
16 INC ADBA PROVIDENCE HOSPICE; and DOES)
1 through 10, Inclusive, )
17 )
Defendant. )
18
19 I, ALEXIS INNIS, d0 hereby declare as follows:
20 1. That 1 am the COLLECTIONS REPRESENTATIVE 0f State Compensation Insurance
if called to the
21 Fund in the action herein pending. I am personally familiar with the following facts and
22 stand to testify, I could and would competently testify with personal knowledge thereto;
files 0f State
23 2. That the documents and records attached hereto were taken from the
24 Compensation Insurance Fund and were prepared in the ordinary course 0f business about the time that
by employees and/or agents of State Compensation
25 the occurrences cited therein actually took place
cited in said documents.
26 Insurance Fund having personal knowledge of the occurrences which are
27 3. As the COLLECTIONS REPRESENTATIVE 0f State Compensation Insurance Fund, I
28 have personal knowledge regarding all issues relating t0 the accounting system and record keeping of
-1-
State Compensation Insurance Fund, including issues relating, but not limited t0, price quoting, invoicing,
delivery, and applying payments to, and collection of, customer accounts. As part 0f my duties as the
COLLECTIONS REPRESENTATIVE, I maintain custody and control of the files with respect to the
account pertaining t0 defendant.
4. That State Compensation Insurance Fund issued a policy of workers compensation
insurance bearing Policy N0. 9280050-20 (covering the period of July 14, 2020 through June 3, 2021), to
defendant at defendant’s instance and request. Defendant became indebted to State Compensation
Insurance Fund in the sum of $13,324.90 for insurance premiums earned pursuant to the terms and
conditions of the policy. A true and correct copy of the outstanding invoice accurately reflecting the
"1" and incorporated herein by
10 obligation owed by defendant is attached hereto and marked as Exhibit
11 this reference as though fully set forth. I have reviewed the invoice and it correctly reflects the status of
12 defendant’s account.
13 5. All amounts indicated 0n the invoice, including, but not limited to, the user assessment
14 fund and fraud assessment fund, are mandated by the Insurance Commissioner 0f the State 0f California;
15 6. That I am authorized by State Compensation Insurance Fund to assign the above-
16 referenced account for collection and thereby assigned the account t0 Creditors Adjustment Bureau, Inc.
17 for collection with full right to file legal action in the name 0f Creditors Adjustment Bureau, Inc.;
18 7. Although demand has been made upon defendant for payment of same, defendant has
19 failed and refiJsed to pay any sum towards the balance. It is therefore respectfully requested that judgment
20 be entered in favor of plaintiff and against defendant in the sum of $13,324.90 principal, cost 0f suit,
21 interest at 10% per annum from the dates of default in the complaint, plus attomey’s fees pursuant to
22 California Civil Code Section 1717.5.
23 I declare under penalty 0f perjury that the foregoing is true and correct.
24 Executed on 9/15/22 ,at Riverside ,Canfomia.
25
26 964w
ALEXIS INNIS, Declarant
27 F#6078l97
28
Preview
SUP R F I a. E D KENNETH J. FREED, ESQ. [SBN 125349] 25$er 893g; 3253553315? QAN BERNARD'NO DISTRICT ERIC J, ESQ [SBN. 263502] JUN, LAW OFFICES OF KENNETH J. FREED FEB 4 4340 Fulton Ave., Third Floor 1 2023 Sherman Oaks, California 91423 (818) 990—0888 (818) 990-1047 Facsimile .. x. KFREED@KJFESQ.COM / EJUN@KJFESQ.C0M .W Charisse Navarro, Deputy. Attorneys for Plaintiff CREDITORS ADJUSTMENT BUREAU, INC. Our File No. 6078 197 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO SAN BERNARDINO JUSTICE CENTER, LIMITED CIVIL 10 CREDITORS ADJUSTMENT BUREAU, INC, ) CASE NO. CIVSBZZOS629 ) 11 P1aintiff(s), i 12 vs. ) DECLARATION OF ALEXIS INNIS ) PURSUANT TO C.C.P. 13 ) SECTION 585(d) AND ) ASSIGNMENT 14 HOSPICE CARE AT HOME, INC. DBA ) HOSPICE CARE AT HOME INC ADBA ) AT HOME; PROVIDENCE Electronic Signature per 15 HOSPICE CARE ) C.R.C. 2.257(a) HOSPICE INC. DBA PROVIDENCE HOSPICE ) 16 INC ADBA PROVIDENCE HOSPICE; and DOES) 1 through 10, Inclusive, ) 17 ) Defendant. ) 18 19 I, ALEXIS INNIS, d0 hereby declare as follows: 20 1. That 1 am the COLLECTIONS REPRESENTATIVE 0f State Compensation Insurance if called to the 21 Fund in the action herein pending. I am personally familiar with the following facts and 22 stand to testify, I could and would competently testify with personal knowledge thereto; files 0f State 23 2. That the documents and records attached hereto were taken from the 24 Compensation Insurance Fund and were prepared in the ordinary course 0f business about the time that by employees and/or agents of State Compensation 25 the occurrences cited therein actually took place cited in said documents. 26 Insurance Fund having personal knowledge of the occurrences which are 27 3. As the COLLECTIONS REPRESENTATIVE 0f State Compensation Insurance Fund, I 28 have personal knowledge regarding all issues relating t0 the accounting system and record keeping of -1- State Compensation Insurance Fund, including issues relating, but not limited t0, price quoting, invoicing, delivery, and applying payments to, and collection of, customer accounts. As part 0f my duties as the COLLECTIONS REPRESENTATIVE, I maintain custody and control of the files with respect to the account pertaining t0 defendant. 4. That State Compensation Insurance Fund issued a policy of workers compensation insurance bearing Policy N0. 9280050-20 (covering the period of July 14, 2020 through June 3, 2021), to defendant at defendant’s instance and request. Defendant became indebted to State Compensation Insurance Fund in the sum of $13,324.90 for insurance premiums earned pursuant to the terms and conditions of the policy. A true and correct copy of the outstanding invoice accurately reflecting the "1" and incorporated herein by 10 obligation owed by defendant is attached hereto and marked as Exhibit 11 this reference as though fully set forth. I have reviewed the invoice and it correctly reflects the status of 12 defendant’s account. 13 5. All amounts indicated 0n the invoice, including, but not limited to, the user assessment 14 fund and fraud assessment fund, are mandated by the Insurance Commissioner 0f the State 0f California; 15 6. That I am authorized by State Compensation Insurance Fund to assign the above- 16 referenced account for collection and thereby assigned the account t0 Creditors Adjustment Bureau, Inc. 17 for collection with full right to file legal action in the name 0f Creditors Adjustment Bureau, Inc.; 18 7. Although demand has been made upon defendant for payment of same, defendant has 19 failed and refiJsed to pay any sum towards the balance. It is therefore respectfully requested that judgment 20 be entered in favor of plaintiff and against defendant in the sum of $13,324.90 principal, cost 0f suit, 21 interest at 10% per annum from the dates of default in the complaint, plus attomey’s fees pursuant to 22 California Civil Code Section 1717.5. 23 I declare under penalty 0f perjury that the foregoing is true and correct. 24 Executed on 9/15/22 ,at Riverside ,Canfomia. 25 26 964w ALEXIS INNIS, Declarant 27 F#6078l97 28