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Electronically Filed
1 STEVEN A. BOOSKA sbn 107899 4/12/2024 10:10 AM
Attorney at Law
Superior Court of California
Box 2169 File #20240171
County of Stanislaus
2 | P.O.
Clerk of the Court
3 OAKLAND CA 94621
By: Dora Perez, Deputy
Telephone: (415) 397-4345
4. stevenb@booskalaw.com
Debt Collector License 10438-99
5
Attorney for Plaintiff $370 PAID
6
7 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 IN AND FOR THE COUNTY OF STANISLAUS
9 |
CV-24-002851
10 NO.
SHELL MS FUEL CARD LLC
11]
Plaintiff,
COMPLAINT FOR MONEY
12
Vv.
13
KARANJEET SINGH INDIVIDUALLY
14 AND DBA KSK ROADLINES INC; Demand: $29,625.99
DO 1-10
15 BS ’
16 | Defendants. .
174
| Plaintiff alleges as follows:
18|
FIRST CAUSE OF ACTION
19
59 1. Defendants presently reside in the county in which
21 this matter is brought and this Court is the proper court for
22 the trial of this matter.
23 2. The true names and capacities, whether corporate,
24 associate, individual or otherwise, of defendants DOES 1-10
25 inclusive, are unknown to plaintiff who therefore sues said
260 defendants by such fictitious names and plaintiff will ask leave
27 to amend this Complaint to set forth their true names and
28
COMPLAINT FOR MONEY = COMMON COUNTS Sandhu, Sonny S.
Dept. 24
1 capacities when the same are ascertained.
2 | 3. Plaintiff is informed and believes, and on such
3 information and belief, alleges that at all times herein
4 mentioned, each of the defendants was acting as the agent and/or
>| servant of each of the other defendants and all actions alleged
herein were within the course and scope of the defendant’s
3 | agency and/or employment.
9 Ax This cause of action is not subject to the provisions
10 | of Sections 1812.10 or 2984.4 of the Civil Code of the State of
11 | California.
5. Within the last four years defendants, and each of
12 |
13 them, became indebted to plaintiff in the agreed sum of
14 $29,625.99 for goods and/or services to
rendered defendants, and
Is defendants then and there agreed to pay said amount to
16 | plaintiff.
17
6. No part of said sum has been paid, although demand
therefor has been made, and there is now due, owing and unpaid
,
50 the sum of $29,625.99 together with interest thereon at the rate
1 of 10% per annum from January 4, 2024.
224 SECOND CAUSE OF ACTION
23 | 7. Plaintiff realleges and incorporates herein by
24 reference each and every allegation contained in Paragraphs l,
25 2, 3, 4, 5, and 6 of the First Cause of Action.
26 8. Within the last four years defendants, and each of
27 them, became indebted to plaintiff on a book account for a
28 |
COMPLAINT FOR MONEY =~ COMMON COUNTS
| balance due in the amount of $29,625.99.
2 THIRD CAUSE OF ACTION
3 9. Plaintiff realleges and incorporates herein by
*| reference each and every allegation contained in Paragraphs l,
° 2, 3, 4, 5, and 6 of the First Cause of Action.
10. Within the last four years there was a written account
9 stated by and between plaintiff and defendants, and each of
9 them, whereby it was agreed that defendants were indebted to
10 | plaintiff in the sum of $29,625.99.
11 FOURTH CAUSE OF ACTION - MONEY HAD AND RECEIVED
12 11. Defendant became indebted to plaintiff in the sum of
13 | $29,625.99 for money had and received by defendant for the use
14 and benefit of plaintiff.
15 12. No payment has been made by defendant to plaintiff and
16 | there is now due and owing in the sum of $29,625.99, with
“ interest on that amount at the rate of 10 percent per annum from
. and after January 4, 2024.
50 WHEREFORE, plaintiff prays judgment against defendants, and
21 each of them, as follows:
22 1. For damages in the sum of $29,625.99;
234 2. For interest in the sum of 10 percent per annum from
24 |} and after January 4, 2024;
25 3. For costs of suit herein incurred as provided by
26 | C.C.P. Sec. 1033.5 including a reasonable attorney fee to
a be determined by the court authorized by C.C.P. 1717.5, if
28|}
| COMPLAINT FOR MONEY — COMMON COUNTS
1 applicable;
2 4. For other and further relief as the Court may deem
3 proper.
4
5
DATED: April 3, 2024 Ag
7 Attorney for Plaintiff
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10
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12
13]
144
15
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COMPLAINT FOR MONEY - COMMON COUNTS
Preview
Electronically Filed 1 STEVEN A. BOOSKA sbn 107899 4/12/2024 10:10 AM Attorney at Law Superior Court of California Box 2169 File #20240171 County of Stanislaus 2 | P.O. Clerk of the Court 3 OAKLAND CA 94621 By: Dora Perez, Deputy Telephone: (415) 397-4345 4. stevenb@booskalaw.com Debt Collector License 10438-99 5 Attorney for Plaintiff $370 PAID 6 7 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 IN AND FOR THE COUNTY OF STANISLAUS 9 | CV-24-002851 10 NO. SHELL MS FUEL CARD LLC 11] Plaintiff, COMPLAINT FOR MONEY 12 Vv. 13 KARANJEET SINGH INDIVIDUALLY 14 AND DBA KSK ROADLINES INC; Demand: $29,625.99 DO 1-10 15 BS ’ 16 | Defendants. . 174 | Plaintiff alleges as follows: 18| FIRST CAUSE OF ACTION 19 59 1. Defendants presently reside in the county in which 21 this matter is brought and this Court is the proper court for 22 the trial of this matter. 23 2. The true names and capacities, whether corporate, 24 associate, individual or otherwise, of defendants DOES 1-10 25 inclusive, are unknown to plaintiff who therefore sues said 260 defendants by such fictitious names and plaintiff will ask leave 27 to amend this Complaint to set forth their true names and 28 COMPLAINT FOR MONEY = COMMON COUNTS Sandhu, Sonny S. Dept. 24 1 capacities when the same are ascertained. 2 | 3. Plaintiff is informed and believes, and on such 3 information and belief, alleges that at all times herein 4 mentioned, each of the defendants was acting as the agent and/or >| servant of each of the other defendants and all actions alleged herein were within the course and scope of the defendant’s 3 | agency and/or employment. 9 Ax This cause of action is not subject to the provisions 10 | of Sections 1812.10 or 2984.4 of the Civil Code of the State of 11 | California. 5. Within the last four years defendants, and each of 12 | 13 them, became indebted to plaintiff in the agreed sum of 14 $29,625.99 for goods and/or services to rendered defendants, and Is defendants then and there agreed to pay said amount to 16 | plaintiff. 17 6. No part of said sum has been paid, although demand therefor has been made, and there is now due, owing and unpaid , 50 the sum of $29,625.99 together with interest thereon at the rate 1 of 10% per annum from January 4, 2024. 224 SECOND CAUSE OF ACTION 23 | 7. Plaintiff realleges and incorporates herein by 24 reference each and every allegation contained in Paragraphs l, 25 2, 3, 4, 5, and 6 of the First Cause of Action. 26 8. Within the last four years defendants, and each of 27 them, became indebted to plaintiff on a book account for a 28 | COMPLAINT FOR MONEY =~ COMMON COUNTS | balance due in the amount of $29,625.99. 2 THIRD CAUSE OF ACTION 3 9. Plaintiff realleges and incorporates herein by *| reference each and every allegation contained in Paragraphs l, ° 2, 3, 4, 5, and 6 of the First Cause of Action. 10. Within the last four years there was a written account 9 stated by and between plaintiff and defendants, and each of 9 them, whereby it was agreed that defendants were indebted to 10 | plaintiff in the sum of $29,625.99. 11 FOURTH CAUSE OF ACTION - MONEY HAD AND RECEIVED 12 11. Defendant became indebted to plaintiff in the sum of 13 | $29,625.99 for money had and received by defendant for the use 14 and benefit of plaintiff. 15 12. No payment has been made by defendant to plaintiff and 16 | there is now due and owing in the sum of $29,625.99, with “ interest on that amount at the rate of 10 percent per annum from . and after January 4, 2024. 50 WHEREFORE, plaintiff prays judgment against defendants, and 21 each of them, as follows: 22 1. For damages in the sum of $29,625.99; 234 2. For interest in the sum of 10 percent per annum from 24 |} and after January 4, 2024; 25 3. For costs of suit herein incurred as provided by 26 | C.C.P. Sec. 1033.5 including a reasonable attorney fee to a be determined by the court authorized by C.C.P. 1717.5, if 28|} | COMPLAINT FOR MONEY — COMMON COUNTS 1 applicable; 2 4. For other and further relief as the Court may deem 3 proper. 4 5 DATED: April 3, 2024 Ag 7 Attorney for Plaintiff 8 | 9 10 11 12 13] 144 15 16 17 ff 18 | 19 |, 20. 21 22 || 23 24 | 25 26 | 27 28 COMPLAINT FOR MONEY - COMMON COUNTS