On March 22, 2023 a
Dec in Support of Appl for Default Judg under CC 1788.60(a)
was filed
involving a dispute between
Velocity Investments Llc,
and
Does 1 Through 15 Inclusive,
Solis, Joshua,
for Rule 3.740 Collections -Reduced Filing Fee Limited
in the District Court of San Bernardino County.
Preview
\a \y
F L
SUPERIOR COURT 5F
l
CDALIFORNIA
COUNTY OF SAN BEHNAHDINO
1
BRYANT BURNSTAD, SBN 297286
2
RESURGENCE LEGAL GROUP,
PC
>
AUG 1 7 2023
—
10805 Holder
3 Cypress, CA
Street, suite
90630
167
g
4
(T) 877/440-0860
EMAIL: CA
(F) 714/226~0024
m ' ‘
u
g
E
Attorney@Rcsurgencechal.com '
'y
5 Refer
E
a
6
to File Number: TPI 18505
Attorney for Plaintiff a
a
7 SUPERIOR COURT OF
CALIFORNIA
8 COUNTY 0F SAN BERNARDINO,
JUDICIAL DISTRICT
9
SAN BERNARDINO COUNTY
VELOCITY INVESTMENTS JUSTICE CENTER
10 LLC,
)
Plaintiff ) CASE NO.: CIVSB2301557
11
)
v. ) DECLARATION IN SUPPORT 0F
12 ) APPLICATION FOR ENTRY OF
JOSHUA SOLIS, ) DEFAULT JUDGMENT PURSUANT
13 and DOES through
l
15 inclusive ) T0 CIVIL CODE §1788.60
)
1 4 Defendant(s). )
1 5 g
)
I6 )
)
l7 I,
W671! ”Q (Z mal Mm“, 'g
declare as follows:
18 1 1 am an Compliance Associate 0f Plaintiff
I have access to and have revxcwcd
19 business records of the computer
Plamnft as they relate
to the
20 obligatwn—eF—DcfcndeTO‘SHUA
(hereinafter "Defcndant(s)") SOLIS
sucd upon in Plaintiff‘s
Complaint herein, and I am
21 very familiar with the
manner in which those records arc
compiled.
22 2. AJI matters contained
herein arc based upon
my personal knowledge and/or
23 tho computer busmcss records
personal review of
ofPlamuff If called as a Witness,
Icould and would competently
24 thereto. tcetxty
25 3 Plamtlfl" purchases
portfolios of delmqucnt
accounts from either
26 the ongma] cxedxtor
subsequent purchaser ofthe ora
account As part oflts
operatlons, PIamtnffopcrates
7-7 and maintains computer
systems, mto winch l’JamtxfT
mtcgrates electromc
records and Information
28 recexvcd from the seller
m
DECLARATION IN SUPPORT OF APPLICATION ....,4.,_u
FOR ENTRY OF DEFAULT
JUDGMENT PURSUANT 1D CIVIL CODE §l788.60
u...
U.)
OmeO‘xMA
entries made at or near the time of
any such occurrence.
5. Plaintiff acquired the
account sued upon (the "Account").
Plaintiff acquired
and incorporated
Il
I2 collecting this Account.
These records arc
trustworthy because the
13 charge-off creditor
keep accurate records is required to
of the Account.
l4 6. Plaintiffs
predecessor-in-intercst, issued
a loan to Defendant
and Defendant agreed
amounts due and owing to pay all
pursuant to the Agreement
attached hereto as
16 Exhibit " ".
7. Pursuant t0 the
Agreement, Defendant(s), and each of
I7 them, agreed to make
Ioan.On or about June payments on the
21, 2021, Defendant(s),
and each ofthcm,
l8 defaulted on the
t0 make pay the Contract by failing
agrccd-upon payments.
As a result, Plaintiffhas
19 suffered damages as a
of Defendant(s)' breach proximate result
in the principal
sum of$1.370 70
10
21 Section 1788.60.
22 9. In accordance
with California Civil
Code section l788.58(a)(3-8),
23 following relevant
Plaintiffs records
show thc
information concerning
the Account.
24 a. Plaintiff is the sole
owner of the Account.
25
b. The account was opened
on March 15, 2021 and charged off
26 on November l3, 202! with a
28
m..-‘
Document Filed Date
August 17, 2023
Case Filing Date
March 22, 2023
Category
Rule 3.740 Collections -Reduced Filing Fee Limited
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\a \y F L SUPERIOR COURT 5F l CDALIFORNIA COUNTY OF SAN BEHNAHDINO 1 BRYANT BURNSTAD, SBN 297286 2 RESURGENCE LEGAL GROUP, PC > AUG 1 7 2023 — 10805 Holder 3 Cypress, CA Street, suite 90630 167 g 4 (T) 877/440-0860 EMAIL: CA (F) 714/226~0024 m ' ‘ u g E Attorney@Rcsurgencechal.com ' 'y 5 Refer E a 6 to File Number: TPI 18505 Attorney for Plaintiff a a 7 SUPERIOR COURT OF CALIFORNIA 8 COUNTY 0F SAN BERNARDINO, JUDICIAL DISTRICT 9 SAN BERNARDINO COUNTY VELOCITY INVESTMENTS JUSTICE CENTER 10 LLC, ) Plaintiff ) CASE NO.: CIVSB2301557 11 ) v. ) DECLARATION IN SUPPORT 0F 12 ) APPLICATION FOR ENTRY OF JOSHUA SOLIS, ) DEFAULT JUDGMENT PURSUANT 13 and DOES through l 15 inclusive ) T0 CIVIL CODE §1788.60 ) 1 4 Defendant(s). ) 1 5 g ) I6 ) ) l7 I, W671! ”Q (Z mal Mm“, 'g declare as follows: 18 1 1 am an Compliance Associate 0f Plaintiff I have access to and have revxcwcd 19 business records of the computer Plamnft as they relate to the 20 obligatwn—eF—DcfcndeTO‘SHUA (hereinafter "Defcndant(s)") SOLIS sucd upon in Plaintiff‘s Complaint herein, and I am 21 very familiar with the manner in which those records arc compiled. 22 2. AJI matters contained herein arc based upon my personal knowledge and/or 23 tho computer busmcss records personal review of ofPlamuff If called as a Witness, Icould and would competently 24 thereto. tcetxty 25 3 Plamtlfl" purchases portfolios of delmqucnt accounts from either 26 the ongma] cxedxtor subsequent purchaser ofthe ora account As part oflts operatlons, PIamtnffopcrates 7-7 and maintains computer systems, mto winch l’JamtxfT mtcgrates electromc records and Information 28 recexvcd from the seller m DECLARATION IN SUPPORT OF APPLICATION ....,4.,_u FOR ENTRY OF DEFAULT JUDGMENT PURSUANT 1D CIVIL CODE §l788.60 u... U.) OmeO‘xMA entries made at or near the time of any such occurrence. 5. Plaintiff acquired the account sued upon (the "Account"). Plaintiff acquired and incorporated Il I2 collecting this Account. These records arc trustworthy because the 13 charge-off creditor keep accurate records is required to of the Account. l4 6. Plaintiffs predecessor-in-intercst, issued a loan to Defendant and Defendant agreed amounts due and owing to pay all pursuant to the Agreement attached hereto as 16 Exhibit " ". 7. Pursuant t0 the Agreement, Defendant(s), and each of I7 them, agreed to make Ioan.On or about June payments on the 21, 2021, Defendant(s), and each ofthcm, l8 defaulted on the t0 make pay the Contract by failing agrccd-upon payments. As a result, Plaintiffhas 19 suffered damages as a of Defendant(s)' breach proximate result in the principal sum of$1.370 70 10 21 Section 1788.60. 22 9. In accordance with California Civil Code section l788.58(a)(3-8), 23 following relevant Plaintiffs records show thc information concerning the Account. 24 a. Plaintiff is the sole owner of the Account. 25 b. The account was opened on March 15, 2021 and charged off 26 on November l3, 202! with a 28 m..-‘