On April 18, 2024 a
Complaint,Petition
was filed
involving a dispute between
Jpmorgan Chase Bank, N.A.,
and
Roy Egbokhan,
for (Collections Case)
in the District Court of Sacramento County.
Preview
PLD-C-001
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER FOR COURT USE ONLY
Harvey Moore(101128) Adam Brumage(283180) Chinyere A. Abuka(303286) Matthew Keim(331020) Jason Burrows(309882) Chan Hsu(334555)
NAME:Nicholas Morello(337656) John Phan(338677) Linda Doan(343453) Angela Dawson(209860) Christine Siduguen(240380) Jeremy LaForge(350818)
FIRM NAME: The Moore Law Group, A Professional Corporation*
STREET ADDRESS: 3710 S. Susan Street, Ste 210
CITY: Santa Ana STATE: CA ZIP CODE: 92704
TELEPHONE NO.: 800-506-2652
800-506-2652 FAX NO.:
EMAIL ADDRESS: CALit@collectmoore.com
ATTORNEY FOR (name): Plaintiff
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sacramento
STREET ADDRESS: 720 Ninth Street Room 102
MAILING ADDRESS:
CITY AND ZIP CODE: Sacramento CA 95814
BRANCH NAME: Sacramento County - Downtown Courthouse
PLAINTIFF: JPMorgan Chase Bank, N.A.
DEFENDANT: ROY EGBOKHAN
D DOES 1 TO
• •
CONTRACT
X COMPLAINT AMENDED COMPLAINT (Number):
• CROSS-COMPLAINT
Jurisdiction (check all that apply):
• AMENDED CROSS-COMPLAINT (Number):
CJ
X ACTION IS A LIMITED CIVIL CASE (does not exceed $35,000)
CASE NUMBER:
Amount demanded CJ does not exceed $10,000
[_l
X exceeds $10,000
CJ ACTION IS AN UNLIMITED CIVIL CASE (exceeds $35,000)
CJ ACTION IS RECLASSIFIED by this amended complaint or cross-complaint
CJ from limited to unlimited
CJ from unlimited to limited
1. Plaintiff (name or names): JPMorgan Chase Bank, N.A.
alleges causes of action against defendant' (name or names): ROY EGBOKHAN
2. This pleading, including attachments and exhibits, consists of the following number of pages: 3
3. a. Each plaintiff named above is a competent adult
CJ
X except plaintiff (name): JPMorgan Chase Bank, N.A.
(1) CJ a corporation qualified to do business in California.
L an unincorporated entity (describe):
X other (specify): National Bank organized
(3) [] under Federal Law
b. [] Paintf (name):
(1) CJ has complied with the fictitious business name laws and is doing business under the fictitious name (specify):
(2) CJ has complied with all licensing requirements as a licensed (specify):
c. CJ Information about additional plaintiffs who are not competent adults is shown in Attachment 3c.
4. a. Each defendant named above is a natural person
[]except defendant (name): [ except defendant (name):
(1) CJ a business organization, form unknown. (1) CJ a business organization, form unknown.
) La corporation. (2) [] a corporation.
(3) CJ an unincorporated entity (describe): (3) [ an unincorporated entity (describe):
(4) CJ a public entity (describe): (4) CJ a public entity (describe):
(5) [] other (specify): (5) [] other (specify):
If this form is used as a cross-complaint, plaintiff means cross-complainant and defendant means cross-defendant. Page 1 of 2
Form Approved for Optional Use
Judicial Council of California
COMPLAINT-Contract Code of Civil Procedure, $ 425.12
www.courts.ca.gov
PLD-C-001 [Rev. January 1, 2024]
*CA DFPI Debt Collector License Number 10223-99
PLD-C-001
I SHORT TITLE: I CASE NUMBER
JPMorgan Chase Bank, N.A. v. ROY EGBOKHAN
4. b. The true names of defendants sued as Does are unknown to plaintiff.
(1) � Doe defendants (specify Doe numbers): were the agents or employees of the named
defendants and acted within the scope of that agency or employment.
(2) � Doe defendants (specify Doe numbers): are persons whose capacities are unknown to
plaintiff.
c. � Information about additional defendants who are not natural persons is contained in Attachment 4c.
d. [l Defendants who are joined under Code of Civil Procedure section 382 are (names):
5. � Plaintiff is required to comply with a claims statute, and
a. [ has complied with applicable claims statutes, or
b. [ is excused from complying because (specify):
6. [_l This action is subject to [l Civil Code section 1812.10 [_l Civil Code section 2984.4.
7. This court is the proper court because
a. [ a defendant entered into the contract here.
b. � a defendant lived here when the contract was entered into.
c. [X adefendant lives here now.
d. [ the contract was to be performed here.
Lla defendant is a corporation or unincorporated association and its principal place of business is here.
f. � real property that is the subject of this action is located here.
g. [_] other (specify):
8. The following causes of action are attached and the statements above apply to each (each complaint must have one or
more causes of action attached):
[_l Breach of Contract
[l
X common Counts
[] other (specify):
9. [_] other allegations:
10. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for
a. [lX damages of. $ 11,850.79
b. [ interest on the damages *Plaintiff waives post charge-off prejudgment interest
(1) [l according to proof
(2) � at the rate of (specify): percent per year from (date):
c. [_] attorney's fees *Plaintiff waives attorney fees
( L] of s
[l according to proof.
(2)
d. [l other (specify):
11. � The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers):
4/8/2024
Date:
)
Harvey Moore___ Adam Brumage___ Matthew Keim___ Angela Dawson___ Christine Siduguen___ Jason Burrows___ Chan Hsu___
X
Nicholas Morello___ John Phan___ Linda Doan___ Chinyere A. Abuka___ Jeremy LaForge___
(TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY)
(If you wish to verify this pleading, affix a verification.)
PLD-C-001 [Rev. January 1, 2024] COMPLAINT-Contract Page 2 of2
PLD-C-001(2)
SHORT TITLE: I CASE NUMBER:
JPMorgan Chase Bank, N.A. v. ROY EGBOKHAN
FIRST CAUSE OF ACTION-Common Counts
(number)
ATTACHMENT TO O
X Complaint [_] Cross - Complaint
(Use a separate cause of action form for each cause of action.)
CC-1. Plaintiff (name): JPMorgan Chase Bank, N.A.
alleges that defendant (name): ROY EGBOKHAN
became indebted to []
X plaintiff D other (name):
a. [_]
X within the last four years
(1) X D on an open book account for money due.
(2) [lX because an account was stated in writing by and between plaintiff and defendant in which it
was agreed that defendant was indebted to plaintiff.
b. []
X within the last [] two years [_l X tour years
(1) D for money had and received by defendant for the use and benefit of plaintiff.
(2) D for work, labor, services and materials rendered at the special instance and request of defendant
and for which defendant promised to pay plaintiff.
D the sum of$
L]me reasonable value.
(3) D for goods, wares, and merchandise sold and delivered to defendant and for which defendant
promised to pay plaintiff
D the sum of$
D the reasonable value.
(4) D
X for money lent by plaintiff to defendant at defendant's request.
(5) D
X for money paid, laid out, and expended to or for defendant at defendant's special instance and
request.
(6) []
X other (specify): This cause of action relates to the credit card issued by Plaintiff
having account number XXXXXXXXXXXX8612.
CC-2.$ 11,850.79 , which is the reasonable value, is due and unpaid despite plaintiffs demand,
plus prejudgment interest [l according to proof D at the rate of percent per year
from (date): *Plaintiff waives post charge-off prejudgment interest
CC-3. D Plaintiff is entitled to attorney fees by an agreement or a statute
D of$ *Plaintiff waives attorney fees
[l according to proof.
CC-4. D Other:
Page 3
Pae1off
Form Approved for Optional Use
Judicial Council of California
CAUSE OF ACTION-Common Counts Code of Civil Procedure,§ 425.12
www.courtinfo.ca.gov
PLD-C-001(2) [Rev. January 1, 2009]
Document Filed Date
April 18, 2024
Case Filing Date
April 18, 2024
Category
(Collections Case)
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Preview
PLD-C-001 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER FOR COURT USE ONLY Harvey Moore(101128) Adam Brumage(283180) Chinyere A. Abuka(303286) Matthew Keim(331020) Jason Burrows(309882) Chan Hsu(334555) NAME:Nicholas Morello(337656) John Phan(338677) Linda Doan(343453) Angela Dawson(209860) Christine Siduguen(240380) Jeremy LaForge(350818) FIRM NAME: The Moore Law Group, A Professional Corporation* STREET ADDRESS: 3710 S. Susan Street, Ste 210 CITY: Santa Ana STATE: CA ZIP CODE: 92704 TELEPHONE NO.: 800-506-2652 800-506-2652 FAX NO.: EMAIL ADDRESS: CALit@collectmoore.com ATTORNEY FOR (name): Plaintiff SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sacramento STREET ADDRESS: 720 Ninth Street Room 102 MAILING ADDRESS: CITY AND ZIP CODE: Sacramento CA 95814 BRANCH NAME: Sacramento County - Downtown Courthouse PLAINTIFF: JPMorgan Chase Bank, N.A. DEFENDANT: ROY EGBOKHAN D DOES 1 TO • • CONTRACT X COMPLAINT AMENDED COMPLAINT (Number): • CROSS-COMPLAINT Jurisdiction (check all that apply): • AMENDED CROSS-COMPLAINT (Number): CJ X ACTION IS A LIMITED CIVIL CASE (does not exceed $35,000) CASE NUMBER: Amount demanded CJ does not exceed $10,000 [_l X exceeds $10,000 CJ ACTION IS AN UNLIMITED CIVIL CASE (exceeds $35,000) CJ ACTION IS RECLASSIFIED by this amended complaint or cross-complaint CJ from limited to unlimited CJ from unlimited to limited 1. Plaintiff (name or names): JPMorgan Chase Bank, N.A. alleges causes of action against defendant' (name or names): ROY EGBOKHAN 2. This pleading, including attachments and exhibits, consists of the following number of pages: 3 3. a. Each plaintiff named above is a competent adult CJ X except plaintiff (name): JPMorgan Chase Bank, N.A. (1) CJ a corporation qualified to do business in California. L an unincorporated entity (describe): X other (specify): National Bank organized (3) [] under Federal Law b. [] Paintf (name): (1) CJ has complied with the fictitious business name laws and is doing business under the fictitious name (specify): (2) CJ has complied with all licensing requirements as a licensed (specify): c. CJ Information about additional plaintiffs who are not competent adults is shown in Attachment 3c. 4. a. Each defendant named above is a natural person []except defendant (name): [ except defendant (name): (1) CJ a business organization, form unknown. (1) CJ a business organization, form unknown. ) La corporation. (2) [] a corporation. (3) CJ an unincorporated entity (describe): (3) [ an unincorporated entity (describe): (4) CJ a public entity (describe): (4) CJ a public entity (describe): (5) [] other (specify): (5) [] other (specify): If this form is used as a cross-complaint, plaintiff means cross-complainant and defendant means cross-defendant. Page 1 of 2 Form Approved for Optional Use Judicial Council of California COMPLAINT-Contract Code of Civil Procedure, $ 425.12 www.courts.ca.gov PLD-C-001 [Rev. January 1, 2024] *CA DFPI Debt Collector License Number 10223-99 PLD-C-001 I SHORT TITLE: I CASE NUMBER JPMorgan Chase Bank, N.A. v. ROY EGBOKHAN 4. b. The true names of defendants sued as Does are unknown to plaintiff. (1) � Doe defendants (specify Doe numbers): were the agents or employees of the named defendants and acted within the scope of that agency or employment. (2) � Doe defendants (specify Doe numbers): are persons whose capacities are unknown to plaintiff. c. � Information about additional defendants who are not natural persons is contained in Attachment 4c. d. [l Defendants who are joined under Code of Civil Procedure section 382 are (names): 5. � Plaintiff is required to comply with a claims statute, and a. [ has complied with applicable claims statutes, or b. [ is excused from complying because (specify): 6. [_l This action is subject to [l Civil Code section 1812.10 [_l Civil Code section 2984.4. 7. This court is the proper court because a. [ a defendant entered into the contract here. b. � a defendant lived here when the contract was entered into. c. [X adefendant lives here now. d. [ the contract was to be performed here. Lla defendant is a corporation or unincorporated association and its principal place of business is here. f. � real property that is the subject of this action is located here. g. [_] other (specify): 8. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): [_l Breach of Contract [l X common Counts [] other (specify): 9. [_] other allegations: 10. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. [lX damages of. $ 11,850.79 b. [ interest on the damages *Plaintiff waives post charge-off prejudgment interest (1) [l according to proof (2) � at the rate of (specify): percent per year from (date): c. [_] attorney's fees *Plaintiff waives attorney fees ( L] of s [l according to proof. (2) d. [l other (specify): 11. � The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers): 4/8/2024 Date: ) Harvey Moore___ Adam Brumage___ Matthew Keim___ Angela Dawson___ Christine Siduguen___ Jason Burrows___ Chan Hsu___ X Nicholas Morello___ John Phan___ Linda Doan___ Chinyere A. Abuka___ Jeremy LaForge___ (TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY) (If you wish to verify this pleading, affix a verification.) PLD-C-001 [Rev. January 1, 2024] COMPLAINT-Contract Page 2 of2 PLD-C-001(2) SHORT TITLE: I CASE NUMBER: JPMorgan Chase Bank, N.A. v. ROY EGBOKHAN FIRST CAUSE OF ACTION-Common Counts (number) ATTACHMENT TO O X Complaint [_] Cross - Complaint (Use a separate cause of action form for each cause of action.) CC-1. Plaintiff (name): JPMorgan Chase Bank, N.A. alleges that defendant (name): ROY EGBOKHAN became indebted to [] X plaintiff D other (name): a. [_] X within the last four years (1) X D on an open book account for money due. (2) [lX because an account was stated in writing by and between plaintiff and defendant in which it was agreed that defendant was indebted to plaintiff. b. [] X within the last [] two years [_l X tour years (1) D for money had and received by defendant for the use and benefit of plaintiff. (2) D for work, labor, services and materials rendered at the special instance and request of defendant and for which defendant promised to pay plaintiff. D the sum of$ L]me reasonable value. (3) D for goods, wares, and merchandise sold and delivered to defendant and for which defendant promised to pay plaintiff D the sum of$ D the reasonable value. (4) D X for money lent by plaintiff to defendant at defendant's request. (5) D X for money paid, laid out, and expended to or for defendant at defendant's special instance and request. (6) [] X other (specify): This cause of action relates to the credit card issued by Plaintiff having account number XXXXXXXXXXXX8612. CC-2.$ 11,850.79 , which is the reasonable value, is due and unpaid despite plaintiffs demand, plus prejudgment interest [l according to proof D at the rate of percent per year from (date): *Plaintiff waives post charge-off prejudgment interest CC-3. D Plaintiff is entitled to attorney fees by an agreement or a statute D of$ *Plaintiff waives attorney fees [l according to proof. CC-4. D Other: Page 3 Pae1off Form Approved for Optional Use Judicial Council of California CAUSE OF ACTION-Common Counts Code of Civil Procedure,§ 425.12 www.courtinfo.ca.gov PLD-C-001(2) [Rev. January 1, 2009]