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Kristen Kohler, Esq. Bar No. 263579 "gang ??figmgsg“
Emily Pierce, Esq. Bar No. 240084 SAN BERNARDINO DISTRICT
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Jordan Cook, Esq. Bar No. 179720 ' -
Lori Williams, Esq. Bar No. 242985 FEB 2 7 202‘}
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Michelle Mitchell, Esq. Bar No. 221841 UV!
PORTFOLIO RECOVERY ASSOCIATES, LLC a
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10680 Treena St., Suite 500 ,
99W
San Diego, CA, 92131 Mlma Moreno
Tel: 866/428-8102
Fax: 757/518-0860
Attorneys for Plaintifi
File No.1 879396
SUPERIOR COURT 0F CALIFORNIA
COUNTY 0F SAN BERNARDINO
ll
PORTFOLIO RECOVERY ASSOCIATES, LLC CASE NO CIV SB 2 5 0 I 6 1 5
12
Plaintifi‘, COMPLAINT FOR:
l3
(1) Account Stated
l4 V
IUAN E PAHUA, PRAYER AMOUNT: $4,273.77
and DOES to 25. 1
l6
LIMITED CIVIL
17 Defendant(s).
18
Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, ("Plaintiff“) alleges:
l. Plaintiff is a limited liability company.
20
Z This court is the proper court because Plaintiff is informed and believes that Defendant, JUAN E
21
22
PAHUA ("Defendant"), is a resident of SAN BERNARDINO County, State of California.
23 3. At all times herein mentioned, Defendants, and each of them, were the principals, agents, employers,
24
employees, masters, or servants of each of their co—defendants and ratified, adopted or approved the acts or
2S
omissions alleged herein, and each defendant, in doing the things alleged, were acting in the course and
26
scope of said authority 0f such agents, servants,and employees.
27
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PAGE 1
COMPLAINT
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4. This suit concerns a credit account that was purchased by Plaintiff 0n or afier January 1, 2014 and,
therefore, is subject to California Civil Code § 1788.50; er seq.
COMPLIANCE WITH CIVIL CODE § 1788.50, et seq.
Pursuant to California Civil Code § l788.58(a)(1)-(9):
5. Plaintiff is a debt buyer.
6. A CAPITAL ONE, N.A. credit account was issued to Defendant on or about October 16, 2020.
Defendant used, or authorized the use of, the credit account to make purchases and/or transactions.
Defendant received periodic billing statements for the credit account. Defendant defaulted in making
the required payments. Subsequently, Plaintiff was assigned and transferred all rights, title and interest
in the credit account. The account was assigned, transferred and sold to Plaintiff by CAPITAL ONE,
N.A..
7. Plaintiff is the sole owner ofthe credit account at issue, or has authority to assert the rights of all
owners 0fthe debt.
8. The balance at charge-offwas $4,273.77. Plaintiff is not seeking to recover any post charge-off
fees 0r interest.
9. The date 0f last payment 0n the credit account was December 29, 2022.
10. The name and an address ofthe creditor at the time ofcharge-ofTwas CAPITAL ONE NA
1680 CAPITAL ONE DRIVE, MCLEAN VA 22102. At the time ofcharge-off, the charge—of‘f
creditor's account number associated with the debt ended in XXXXXXXXXXXXX0540.
1 1. The name and last known address of the Defendant as they appeared in the charge-ofi“
creditor's records prior to the sale ofthe debt: JUAN E PAHUA, 7555 CHERIMOYA CT,
FONTANA, CA, 92336- 835.1
PAGE 2
COMPLAINT
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V u _._. a u M , , F LE D l Kristen Kohler, Esq. Bar No. 263579 "gang ??figmgsg“ Emily Pierce, Esq. Bar No. 240084 SAN BERNARDINO DISTRICT “m Jordan Cook, Esq. Bar No. 179720 ' - Lori Williams, Esq. Bar No. 242985 FEB 2 7 202‘} ‘ Michelle Mitchell, Esq. Bar No. 221841 UV! PORTFOLIO RECOVERY ASSOCIATES, LLC a y,' 10680 Treena St., Suite 500 , 99W San Diego, CA, 92131 Mlma Moreno Tel: 866/428-8102 Fax: 757/518-0860 Attorneys for Plaintifi File No.1 879396 SUPERIOR COURT 0F CALIFORNIA COUNTY 0F SAN BERNARDINO ll PORTFOLIO RECOVERY ASSOCIATES, LLC CASE NO CIV SB 2 5 0 I 6 1 5 12 Plaintifi‘, COMPLAINT FOR: l3 (1) Account Stated l4 V IUAN E PAHUA, PRAYER AMOUNT: $4,273.77 and DOES to 25. 1 l6 LIMITED CIVIL 17 Defendant(s). 18 Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, ("Plaintiff“) alleges: l. Plaintiff is a limited liability company. 20 Z This court is the proper court because Plaintiff is informed and believes that Defendant, JUAN E 21 22 PAHUA ("Defendant"), is a resident of SAN BERNARDINO County, State of California. 23 3. At all times herein mentioned, Defendants, and each of them, were the principals, agents, employers, 24 employees, masters, or servants of each of their co—defendants and ratified, adopted or approved the acts or 2S omissions alleged herein, and each defendant, in doing the things alleged, were acting in the course and 26 scope of said authority 0f such agents, servants,and employees. 27 28 PAGE 1 COMPLAINT ._. 4. This suit concerns a credit account that was purchased by Plaintiff 0n or afier January 1, 2014 and, therefore, is subject to California Civil Code § 1788.50; er seq. COMPLIANCE WITH CIVIL CODE § 1788.50, et seq. Pursuant to California Civil Code § l788.58(a)(1)-(9): 5. Plaintiff is a debt buyer. 6. A CAPITAL ONE, N.A. credit account was issued to Defendant on or about October 16, 2020. Defendant used, or authorized the use of, the credit account to make purchases and/or transactions. Defendant received periodic billing statements for the credit account. Defendant defaulted in making the required payments. Subsequently, Plaintiff was assigned and transferred all rights, title and interest in the credit account. The account was assigned, transferred and sold to Plaintiff by CAPITAL ONE, N.A.. 7. Plaintiff is the sole owner ofthe credit account at issue, or has authority to assert the rights of all owners 0fthe debt. 8. The balance at charge-offwas $4,273.77. Plaintiff is not seeking to recover any post charge-off fees 0r interest. 9. The date 0f last payment 0n the credit account was December 29, 2022. 10. The name and an address ofthe creditor at the time ofcharge-ofTwas CAPITAL ONE NA 1680 CAPITAL ONE DRIVE, MCLEAN VA 22102. At the time ofcharge-off, the charge—of‘f creditor's account number associated with the debt ended in XXXXXXXXXXXXX0540. 1 1. The name and last known address of the Defendant as they appeared in the charge-ofi“ creditor's records prior to the sale ofthe debt: JUAN E PAHUA, 7555 CHERIMOYA CT, FONTANA, CA, 92336- 835.1 PAGE 2 COMPLAINT