Complaint,Petition: THE GOLDEN 1 CREDIT UNION, A CALIFORNIA CORPORATION VS NATEANA NICOLE BROWN

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                                Electronically FILED by
                                                                                Superior Court of California,
      PRENOVOST, NORMANDIN, DAWE & ROCHA                                        County of Los Angeles
     A Professional Corporation                                                 4/08/2024 12:22 PM
                                                                                David W. Slayton,
     KAREL ROCHA, SBN 212413                                                    Executive Officer/Clerk of Court,
     krocha@pnbd.com                                                            By E. Galicia, Deputy Clerk
     JASON MEYER, SBN 299032
     jmeyer@pnbd.com
     2122 North Broadway, Suite 200
     Santa Ana, California 92706-2614
     Phone No.:    (714) 547-2444
     Fax No.:      (714) 835-2889
     PNDR: 9512.0582

     Attorneys for THE GOLDEN            1 CREDIT UNION, a
     California corporation


                               SUPERIOR COURT OF THE STATE OF CALIFORNIA

10                     COUNTY OF LOS ANGELES, STANLEY MOSK COURTHOUSE

11

12   THE GOLDEN               1 CREDIT UNION, a               CaseNo,     245     T CYOS?744
     California corporation,
13                                                            COMPLAINT FOR:
                          Plaintiff,
14                                                            1         BREACH OF AGREEMENT;
               Vv.
15
     NATEANA NICOLE BROWN                 aka
16   NATEANA BROWN aka NATEANA N.                             DEMAND:           $65,548.00
     BROWN, an individual,
17
                          Defendants.
18

19             Plaintiff alleges:

20                                         GENERAL ALLEGATIONS

21              1         Plaintiff, THE GOLDEN   1 CREDIT UNION, a California corporation, (“Plaintiff”)

22   is, and at all times herein mentioned was a corporation duly authorized to conduct business in the

23   State of California.

24   a

25   M1

26   M1

27   M1

28   11

     9512.0583 / 02690255.1                               1
                                                    COMPLAINT
2,         Plaintiff is informed and believes that Defendant NATEANA NICOLE BROWN aka

                NATEANA BROWN aka NATEANA N. BROWN, an individual (“Defendant”), is and at all times

                herein mentioned was, residing in the City of Los Angeles, County of Los Angeles, California,

                which is within this court’s judicial boundaries.

                          3          The     true names   and    capacities,       whether   individual,   corporation,   associate   or

                otherwise, of Defendants sued herein as DOES 1 through 20, inclusive, are unknown to Plaintiff
                who therefore            sues said Defendants    by such fictitious names          under California Code       of Civil

                Procedure section 474.           Plaintiff will amend its Complaint to show the true names and capacities

                when it has ascertained the same.          Plaintiff is informed and believes and thereon alleges that each

           10   of the fictitiously named Defendants are responsible in some manner for the occurrences and

           11   damages as herein alleged, and Plaintiff's injuries as herein alleged were proximately caused by
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           13                        Plaintiff is informed and believes and thereon alleges that at all times herein
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    Zak    14   mentioned, Defendants, and each of them, were the agents and employees of each of the remaining
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