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ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
Vanessa Thomas, State Bar #323167
RAUSCH STURM LLP 3/1 5/2024 4:31 PM
250 N. Sunnyslope Road, Suite 300 -
By.
.
Taml Camarena, DEPUTY
Brookfield WI 53005
Telephone: (877) 215—2552
Facsimile: (877) 396-4464
E-mail Address: LawfirmCA@rauschsturm.com
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Attorneysfor Plaintlfi
California License N0. 10685—99
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO, SAN BERNARDINO JUSTICE CENTER
CIVSBZ4O8751
GALAXY INTERNATIONAL PURCHASING, LLC, ) Case No.2
)
Plaintiff, ) COMPLAINT FOR:
) 1. BREACH OF CONTRACT
vs. ) (Rule 3.740 Collections)
) 2. ACCOUNT STATED
ALEC KALLAL; )
and DOES 1 through 10, inclusive, )
) PRAYER AMOUNT: $4,814.81
Defendants. )
) LIMITED CIVIL CASE
)
Plaintiff GALAXY INTERNATIONAL PURCHASING, LLC (“Plaintiff”) alleges the following facts as t0 all
causes 0f action as follows:
NNNNNNNNNHHHHHHHHr—tt—t
1. Plaintiff is qualified t0 d0 business in California.
2. This Court is proper for this action because Plaintiff is informed and believes that Defendant ALEC
OOQQUl-PUJNHOOOOQONUI-PWNHO
KALLAL is a resident Within the jurisdictional boundaries 0f this Court.
3. Plaintiff is informed and believes that Defendant ALEC KALLAL and Defendants sued by the fictitious
names DOES 1 through 10 (“Defendants”) are responsible for the alleged debt; however, Plaintiff is unaware 0f the
true names and capacities 0f DOES 1 through 10 and Will seek leave 0f this Court t0 amend this Complaint When the
true names and capacities have been ascertained.
4. Plaintiff believes that at all times mentioned herein, Defendants, and each 0f them, were the agent, servant,
employee, 0r employer, and acted in the capacity and as agent, 0f each and 0f the other Defendants. Plaintiff also
believes that each 0f the Defendants is jointly and severally liable in the actions were taken for the benefit 0f the
1
COMPLAINT 4846607
Defendants’ separate and/or community property. Plaintiff also believes that each 0f the Defendants is jointly and
severally liable in that the actions were taken for the benefit 0f the Defendants' separate and/or community property.
5. Pursuant to California Civil Code, section 1788.58, subsection (a)(l), Plaintiff is a debt buyer as defined by
California Civil Code, section 1788.50, subsection (a).
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6. Pursuant to California Civil Code, section 1788.58, subsection (a)(2), Plaintiff is seeking to recover the
amount 0f $4,814.81 from Defendants. This is the past-due balance 0n a loan 0r borrower agreement, Which was
obtained and used by Defendants in exchange for value received from the original creditor, WebBank, with the
original account number ending in ***** 1239 (the "Account"). The amount due is the result 0f loan proceeds and/or
goods accepted by Defendants that have not been repaid as agreed and, upon information and belief, were for
personal, family, 0r household purposes.
7. Pursuant t0 California Civil Code, section 1788.58, subsection (a)(3), Plaintiff is the sole owner 0f the
obligation sued upon. Attached hereto and incorporated herein by reference as Exhibit 1 is a true and correct copy
0f the Bill 0f Sale(s). The account was purchased by the Plaintiff 0n 0r around November 30, 2022.
8. Pursuant t0 California Civil Code, section 1788.58, subsection (a)(4), the Account balance at the time of
charge-off was $4,8 14.8 1.
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9. Pursuant to California Civil Code, section 1788.58, subsection (a)(S), Plaintiff alleges that the date of the
last payment was September 15, 2022. Attached hereto and incorporated herein by reference as Exhibit 2 is a true
OOQQUl-PUJNHOOOOQONUI-PWNHO
and correct copy 0f a transaction history for Defendants' Account.
10. Pursuant t0 California Civil Code, section 1788.58, subsection (a)(6), Plaintiff alleges that the name 0f
the creditor at the time 0f charge-Off was THEOREMPRIME+ FUND TRUST II (serviced by LendingClub). On
information and belief, Plaintiff further alleges that an address used by THEOREMPRIME+ FUND TRUST II
(serviced by LendingClub) at the time 0f charge-Off was 71 STEVENSON STREET SUITE 300, SAN FRANCISCO
CA 94105. At the time 0f charge-off, the redacted account number associated With this debt was ***** 1239.
11. Pursuant t0 California Civil Code, section 1788.58, subsection (a)(7), Plaintiff alleges that the name 0f
the debt0r(s) as it appears in the records 0f THEOREMPRIME+ FUND TRUST II (serviced by LendingClub) is
2
COMPLAINT 4846607
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ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT Vanessa Thomas, State Bar #323167 RAUSCH STURM LLP 3/1 5/2024 4:31 PM 250 N. Sunnyslope Road, Suite 300 - By. . Taml Camarena, DEPUTY Brookfield WI 53005 Telephone: (877) 215—2552 Facsimile: (877) 396-4464 E-mail Address: LawfirmCA@rauschsturm.com ©OOQO\Ul-I>UJN>—t Attorneysfor Plaintlfi California License N0. 10685—99 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, SAN BERNARDINO JUSTICE CENTER CIVSBZ4O8751 GALAXY INTERNATIONAL PURCHASING, LLC, ) Case No.2 ) Plaintiff, ) COMPLAINT FOR: ) 1. BREACH OF CONTRACT vs. ) (Rule 3.740 Collections) ) 2. ACCOUNT STATED ALEC KALLAL; ) and DOES 1 through 10, inclusive, ) ) PRAYER AMOUNT: $4,814.81 Defendants. ) ) LIMITED CIVIL CASE ) Plaintiff GALAXY INTERNATIONAL PURCHASING, LLC (“Plaintiff”) alleges the following facts as t0 all causes 0f action as follows: NNNNNNNNNHHHHHHHHr—tt—t 1. Plaintiff is qualified t0 d0 business in California. 2. This Court is proper for this action because Plaintiff is informed and believes that Defendant ALEC OOQQUl-PUJNHOOOOQONUI-PWNHO KALLAL is a resident Within the jurisdictional boundaries 0f this Court. 3. Plaintiff is informed and believes that Defendant ALEC KALLAL and Defendants sued by the fictitious names DOES 1 through 10 (“Defendants”) are responsible for the alleged debt; however, Plaintiff is unaware 0f the true names and capacities 0f DOES 1 through 10 and Will seek leave 0f this Court t0 amend this Complaint When the true names and capacities have been ascertained. 4. Plaintiff believes that at all times mentioned herein, Defendants, and each 0f them, were the agent, servant, employee, 0r employer, and acted in the capacity and as agent, 0f each and 0f the other Defendants. Plaintiff also believes that each 0f the Defendants is jointly and severally liable in the actions were taken for the benefit 0f the 1 COMPLAINT 4846607 Defendants’ separate and/or community property. Plaintiff also believes that each 0f the Defendants is jointly and severally liable in that the actions were taken for the benefit 0f the Defendants' separate and/or community property. 5. Pursuant to California Civil Code, section 1788.58, subsection (a)(l), Plaintiff is a debt buyer as defined by California Civil Code, section 1788.50, subsection (a). ©OOQO\Ul-I>UJN>—t 6. Pursuant to California Civil Code, section 1788.58, subsection (a)(2), Plaintiff is seeking to recover the amount 0f $4,814.81 from Defendants. This is the past-due balance 0n a loan 0r borrower agreement, Which was obtained and used by Defendants in exchange for value received from the original creditor, WebBank, with the original account number ending in ***** 1239 (the "Account"). The amount due is the result 0f loan proceeds and/or goods accepted by Defendants that have not been repaid as agreed and, upon information and belief, were for personal, family, 0r household purposes. 7. Pursuant t0 California Civil Code, section 1788.58, subsection (a)(3), Plaintiff is the sole owner 0f the obligation sued upon. Attached hereto and incorporated herein by reference as Exhibit 1 is a true and correct copy 0f the Bill 0f Sale(s). The account was purchased by the Plaintiff 0n 0r around November 30, 2022. 8. Pursuant t0 California Civil Code, section 1788.58, subsection (a)(4), the Account balance at the time of charge-off was $4,8 14.8 1. NNNNNNNNNHHHHHHHHr—tt—t 9. Pursuant to California Civil Code, section 1788.58, subsection (a)(S), Plaintiff alleges that the date of the last payment was September 15, 2022. Attached hereto and incorporated herein by reference as Exhibit 2 is a true OOQQUl-PUJNHOOOOQONUI-PWNHO and correct copy 0f a transaction history for Defendants' Account. 10. Pursuant t0 California Civil Code, section 1788.58, subsection (a)(6), Plaintiff alleges that the name 0f the creditor at the time 0f charge-Off was THEOREMPRIME+ FUND TRUST II (serviced by LendingClub). On information and belief, Plaintiff further alleges that an address used by THEOREMPRIME+ FUND TRUST II (serviced by LendingClub) at the time 0f charge-Off was 71 STEVENSON STREET SUITE 300, SAN FRANCISCO CA 94105. At the time 0f charge-off, the redacted account number associated With this debt was ***** 1239. 11. Pursuant t0 California Civil Code, section 1788.58, subsection (a)(7), Plaintiff alleges that the name 0f the debt0r(s) as it appears in the records 0f THEOREMPRIME+ FUND TRUST II (serviced by LendingClub) is 2 COMPLAINT 4846607