On March 15, 2024 a
Complaint,Petition
was filed
involving a dispute between
Cavalry Spv I, Llc,
and
Does 1 To 10, Inclusive,
Lizama, Cindy C,
for Rule 3.740 Collections -Reduced Filing Fee Limited
in the District Court of San Bernardino County.
Preview
File No. 23—45660—0
Robert Scott Kennard
State Bar No. 117017
Gloria zarco ELECTRONICALLY FILED
State Bar No. 199702 SUPERKNQCOURTOFCAUFORNM
NEHLSODJ & I§ENKUURD CCNJNTYKDFSSANIBERbUURDHQO
5011 Dudley Blvd., Bldg. 25o, Bay G SANBERNARDWKHmSTmCT
McClellan, CA 95652—1020 3M5QOZ4¢29PM
P.O. Box 13807
By: Sabrina Jamison, DEPUTY
Sacramento, CA 95853
Telephone: (916) 920—2295
Facsimile: (916) 920—0682
Attorneys for Plaintiff
CAVALRY SPV I, LLC as assignee of Synchrony Bank
10 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT — LIMITED CIVIL CASE
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CAVALRY SPV I, LLC as assignee of CASE NO.CWVSBZ408703
Synchrony Bank
13 COMPLAINT FOR ACCOUNT STATED;
Plaintiff, MONEY LENT
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VS.
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(DEMAND AMOUNT: $2,626.39)
CINDY c LIZAMA
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and DOES 1 to lO, Inclusive,
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18 Defendants.
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Plaintiff alleges and complains as follows:
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PRELIMINARY ALLEGATIONS
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22 Plaintiff, CAVALRY SPV I, LLC, as assignee of Synchrony Bank,
23 as issuer of the Ashley credit card account, complains of
24 Defendants, and each of them, singularly and collectively, that:
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l. The true names and capacities of Defendants herein sued by
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the fictitious names as DOES l to 10, Inclusive, are unknown to
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Plaintiff, who therefore sues those Defendants under, pursuant to,
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l
Complaint
and in accordance with the provisions of Section 474 of the Code of
Civil Procedure. Plaintiff will ask leave of court to amend this
complaint as and when the true names and capacities of Defendants
named herein as DOES l to 10 have been ascertained.
2. At all times herein mentioned, Defendants, and each of
them, were the agents, servants and employees of each other and
every remaining Defendant, and in doing the things alleged, were
acting in the course and scope of said authority of such agents,
10 servants, and employees.
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3. Plaintiff is now and was at all times herein mentioned a
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limited liability company, authorized to do business in the State of
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California.
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4. Plaintiff is a debt buyer as defined by Section 1788.50 of
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the CA Civil Code. Plaintiff and Plaintiff’s counsel’s application
17 for license pursuant to Financial Code Section lOOOOO et. seq. are
18 pending issuance with the Nationwide Multistate Licensing and
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Registry and/or the California Department of Financial Protection
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and Innovation.
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5. Section 1788.50 of the CA Civil Code is applicable to this
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action as the debt subject to this lawsuit was purchased by
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Plaintiff after January 1, 2014. Plaintiff is the sole owner of the
25 debt at issue.
26 6. Plaintiff is in compliance with Section 1788.52 of the CA
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Civil Code. Attached hereto as Exhibit A is a true and correct copy
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2
Complaint
Document Filed Date
March 15, 2024
Case Filing Date
March 15, 2024
Category
Rule 3.740 Collections -Reduced Filing Fee Limited
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