On March 04, 2024 a
Complaint,Petition
was filed
involving a dispute between
Portfolio Recovery Associates Llc,
and
Holden, Dequanna L,
for Rule 3.740 Collections -Reduced Filing Fee Limited
in the District Court of San Bernardino County.
Preview
Donald Sherrill #266038
William Bliss #341046
ELECTRONICALLY FILED
HUNT & HENRIQUES, LLP SUPERIOR COURT OF CALIFORNIA
7017 Realm Dr., San José CA 95119 COUNTY OF SAN BERNARDINO
Telephone: (800) 680-2426 SAN BERNARDINO DISTRICT
Facsimile: (408) 362-2299
Attorneys for Plaintiff 3/4/2024 12:00 AM
File no. 1546959001 By: Sabrina Jamison, DEPUTY
CA Debt Collection License No. 10136-99
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
' San Bernardino District-Civil Division
10
CIVSB2407163
Portfolio Recovery Associates, LLC Case NO.
ll ~ Plaintiff, ~ ~ -»
‘ ‘ COMPLAINT FOR:
12
vs. (1) Account Stated
(2) Open Book Account
HUNT x: HENRIQUES, LLP
SAN JOSE CALIFORNIA 9511 9
TELEPHONE: (800) 680-2426
PRAYER AMOUNT $1,266.50
FAC‘SIMILE: (408) 362-2299
3.1
J;
f 7017 REALM DR.
LIMITED CIVIL
,_.
(J!
DEQUANNA L HOLDEN Amount demanded does not exceed $10,000
16 .. T'T‘ .LL... . . .
Defendant_(s).
17
18
- Plaintiff, Portfolio Recovery Associates, LLC, (“Plaintiff"), alleges:
19
1. Plaintiff is a limited liability company.
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2. This court is the proper court because Plaintiff is informed and believes that
21
Defendant, DEQUANNA L HOLDEN (“Defendant”), is a resident of SAN BERNARDINO
22
County, State of California.
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3. At all times herein mentioned, Defendants, and each of them, were the principals,
24
agents, employers, employees, masters, or servants of each of their co-defendants and ratified,
25
adopted or approved the acts or omissions alleged herein, and each defendant, in doing the things
26
alleged, were acting in the course and scope of said authority of such agents, servants, and
27
employees.
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COMPLAINT
Page 1 ' -
A 1 154695900]
4. This suit concerns a credit account that was purchased by Plaintiff after January 1,
2014 and, therefore, is subject to California Civil Code § 1788.50, et 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. SYNCHRONY BANK issued a credit account to Defendant. 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 right, title and .
10 interest in the credit account.
11 - --- 7 -- . Plaintiff is the sole oWner of the 'credit account at issue; or has authority to assert
12 the rights of all owners of the debt.
13 8. The balance at charge-off was $1,307.50. Plaintiff is not seeking to recover any
HUNT 82: HENRIQUES, LLP
SAN JOSE CALIFORNIA 95119
TELEPHONE: (800) 680-2426
FACSIMILE: (408) 362-2299
14 post charge—off fees or interest. i
7017 REALM DR.
15 9. , The date of last payment on the credit account was on August 13, 2022.
. .522.” 2g . ..=
1-6' .. .7 10? 4' Thename of the charge—off—creditor is SYNCHRON¥BA~NI§ ‘éfiéf'the account
17 number of the charge-off creditor ended in 8663. An address SYNCHRONY BANK maintained
18 at. the time of charge—off was:
19 4500 MUNSON STREET
20 CANTON OH 44718.
21 11. The name and last known address that the charge—off creditor had for Defendant
22 is:
DEQUANNA L HOLDEN
23
16980 NISQUALLI RD APT G204
24
VICTORVILLE CA 92395—9634.
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12. The subject credit account has been purchased by the following entity after
26
charge-off: Portfolio Recovery Associates, LLC who maintains an address at 120 Corporate
27
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COMPLAINT
Page 2
A 1 1546959001
Preview
Donald Sherrill #266038 William Bliss #341046 ELECTRONICALLY FILED HUNT & HENRIQUES, LLP SUPERIOR COURT OF CALIFORNIA 7017 Realm Dr., San José CA 95119 COUNTY OF SAN BERNARDINO Telephone: (800) 680-2426 SAN BERNARDINO DISTRICT Facsimile: (408) 362-2299 Attorneys for Plaintiff 3/4/2024 12:00 AM File no. 1546959001 By: Sabrina Jamison, DEPUTY CA Debt Collection License No. 10136-99 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO ' San Bernardino District-Civil Division 10 CIVSB2407163 Portfolio Recovery Associates, LLC Case NO. ll ~ Plaintiff, ~ ~ -» ‘ ‘ COMPLAINT FOR: 12 vs. (1) Account Stated (2) Open Book Account HUNT x: HENRIQUES, LLP SAN JOSE CALIFORNIA 9511 9 TELEPHONE: (800) 680-2426 PRAYER AMOUNT $1,266.50 FAC‘SIMILE: (408) 362-2299 3.1 J; f 7017 REALM DR. LIMITED CIVIL ,_. (J! DEQUANNA L HOLDEN Amount demanded does not exceed $10,000 16 .. T'T‘ .LL... . . . Defendant_(s). 17 18 - Plaintiff, Portfolio Recovery Associates, LLC, (“Plaintiff"), alleges: 19 1. Plaintiff is a limited liability company. 20 2. This court is the proper court because Plaintiff is informed and believes that 21 Defendant, DEQUANNA L HOLDEN (“Defendant”), is a resident of SAN BERNARDINO 22 County, State of California. 23 3. At all times herein mentioned, Defendants, and each of them, were the principals, 24 agents, employers, employees, masters, or servants of each of their co-defendants and ratified, 25 adopted or approved the acts or omissions alleged herein, and each defendant, in doing the things 26 alleged, were acting in the course and scope of said authority of such agents, servants, and 27 employees. 28 COMPLAINT Page 1 ' - A 1 154695900] 4. This suit concerns a credit account that was purchased by Plaintiff after January 1, 2014 and, therefore, is subject to California Civil Code § 1788.50, et 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. SYNCHRONY BANK issued a credit account to Defendant. 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 right, title and . 10 interest in the credit account. 11 - --- 7 -- . Plaintiff is the sole oWner of the 'credit account at issue; or has authority to assert 12 the rights of all owners of the debt. 13 8. The balance at charge-off was $1,307.50. Plaintiff is not seeking to recover any HUNT 82: HENRIQUES, LLP SAN JOSE CALIFORNIA 95119 TELEPHONE: (800) 680-2426 FACSIMILE: (408) 362-2299 14 post charge—off fees or interest. i 7017 REALM DR. 15 9. , The date of last payment on the credit account was on August 13, 2022. . .522.” 2g . ..= 1-6' .. .7 10? 4' Thename of the charge—off—creditor is SYNCHRON¥BA~NI§ ‘éfiéf'the account 17 number of the charge-off creditor ended in 8663. An address SYNCHRONY BANK maintained 18 at. the time of charge—off was: 19 4500 MUNSON STREET 20 CANTON OH 44718. 21 11. The name and last known address that the charge—off creditor had for Defendant 22 is: DEQUANNA L HOLDEN 23 16980 NISQUALLI RD APT G204 24 VICTORVILLE CA 92395—9634. 25 12. The subject credit account has been purchased by the following entity after 26 charge-off: Portfolio Recovery Associates, LLC who maintains an address at 120 Corporate 27 28 COMPLAINT Page 2 A 1 1546959001