Preview
ELECTRONICALLY FILED
' '
SB 220693 SUPERIOR COURT OF CALIFORNIA
gggfigolg’ifig ?Bhgfiggggm COUNTY 0F SAN BERNARDINO
SAN BERNARDINO DISTRICT
Martin Weingarten SB 201906
MANDARICH LAW GROUP, LLP 3/22/2024 5:25 pM
P.O. Box 109032 Chlcago, IL 60610
Phone: 877.285.4918 By: Makeda Joyeux, DEPUTY
Facsimile: 818.888.1260
Mandarich Law Group, LLP California Debt Collector License Number 10795—99.
\DOOQOUIAUJNH
Attorneysfor Plaintifi”: CAVALRY SPVI, LLC, AS ASSIGNEE 0F SYNCHRONY BANK
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN BERNARDINO LIMITED -
CAVALRY SPV LLC, As ASSIGNEE 0F
1, Case No.0lVSBZ409696
SYNCHRONY BANK,
Plaintiff, COMPLAINT FOR:
vs. 1. ACCOUNT STATED
2. OPEN BOOK ACCOUNT
SARA C LUSTIG, an individual;
and DOES 1 through 10 inclusive.
Defendant.
DEMAND: $2,647.73
Plaintiff alleges:
FACTS COMMON TO ALL CAUSES OF ACTION
1.Plaintiff is and at all times herein mentioned, CAVALRY SPV I, LLC, AS ASSIGNEE
OF SYNCHRONY BANK, and successor in interest t0 original creditor, SYNCHRONY BANK.
NNNNNNNNNHHr—r—r—HHHHH
2.Plaintiff is the only entity that purchased the debt after Charge—off and its name and
OOQONUl-RUJNHOGOOQQUIAUJNHO
address is as follows: CAVALRY SPV I, LLC, AS ASSIGNEE OF SYNCHRONY BANK 1
American Lane Suite 220 Greenwich, CT 06831.
3.Plaintiff is a debt buyer, and is the sole owner of the debt at issue. Plaintiffs California
Debt Collector License Number 10630-99.
4.The charge-off creditor at the time 0f charge-off is SYNCHRONY BANK, PO BOX
960061 ORLANDO, FL 32896-0061, and the account number associated With this debt is
XXXXXXXXXXXX99 1 2.
5.Plaintiff is informed and believes that Defendant are individuals who currently reside
COMPLAINT-l 0f 5
within the jurisdictional boundaries 0f the above entitled Court. Therefore, this Court is the proper
Court for trial 0f this action.
6.The name and last known address 0f the debtor as they appeared in the charge—off
creditor’s records prior t0 the sale 0f the debt is SARA C LUSTIG, 16558 PAINE ST UNIT 1 ,
OOOQOUI-PUJNH
FONTANA, CA 92336-2778.
7.P1aintiff is unaware 0f the true names or capacities, Whether individual, corporate,
associate 01‘ otherwise 0f the Defendant sued herein as DOES 1 through 10 inclusive, and therefore,
sued the Defendant by such fictitious names. Plaintiff Will amend this Complaint t0 show their true
names and capacities once ascertained.
8.Plaintiff believes and at all times mentioned herein, each 0f the Defendant was, and is,
the agent, servant and employee, employer 0f each 0f the other Defendant, and also acted in the
capacity 0f and as agent 0f the other Defendant. Plaintiff also believes that the individual
Defendant, and each of them, are jointly and severally liable that the actions described herein
were taken as actions for the benefit 0f the Defendant's separate and/or community property.
9.Plaintiff believes that, for value received, Defendant and each of them, executed and
NNNNNNNNNHHr—tr—tr—KHr—tr—tt—tt—t
delivered a credit card application t0 the original creditor, SYNCHRONY BANK 0r made such
application over the telephone 0r Internet. Pursuant t0 the aforementioned application,
SYNCHRONY BANK provided Defendant with a credit account, and granted use privileges 0n
OOQONUl-PUJNHOOOOQGUI-PUJNHO
the same, account number XXXXXXXXXXXX9912 (hereinafter “Account”).
10.Prior t0 the commencement 0f this action, the Account was assigned for value t0 the
Plaintiff and Plaintiff is its current holder.
11.Defendant agreed t0 repay SYNCHRONY BANK and any successors in interest, for
any charges on the Account including, but not limited to, charges for purchase 0f goods and service
and/or cash advances and balance.
12.Defendant used the Account t0 make purchases and/or t0 take cash advances and/or t0
make balance transfers. Each time the Defendant used the Account t0 purchase goods and services
COMPLAINT-2 0f 5
Preview
ELECTRONICALLY FILED ' ' SB 220693 SUPERIOR COURT OF CALIFORNIA gggfigolg’ifig ?Bhgfiggggm COUNTY 0F SAN BERNARDINO SAN BERNARDINO DISTRICT Martin Weingarten SB 201906 MANDARICH LAW GROUP, LLP 3/22/2024 5:25 pM P.O. Box 109032 Chlcago, IL 60610 Phone: 877.285.4918 By: Makeda Joyeux, DEPUTY Facsimile: 818.888.1260 Mandarich Law Group, LLP California Debt Collector License Number 10795—99. \DOOQOUIAUJNH Attorneysfor Plaintifi”: CAVALRY SPVI, LLC, AS ASSIGNEE 0F SYNCHRONY BANK SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO LIMITED - CAVALRY SPV LLC, As ASSIGNEE 0F 1, Case No.0lVSBZ409696 SYNCHRONY BANK, Plaintiff, COMPLAINT FOR: vs. 1. ACCOUNT STATED 2. OPEN BOOK ACCOUNT SARA C LUSTIG, an individual; and DOES 1 through 10 inclusive. Defendant. DEMAND: $2,647.73 Plaintiff alleges: FACTS COMMON TO ALL CAUSES OF ACTION 1.Plaintiff is and at all times herein mentioned, CAVALRY SPV I, LLC, AS ASSIGNEE OF SYNCHRONY BANK, and successor in interest t0 original creditor, SYNCHRONY BANK. NNNNNNNNNHHr—r—r—HHHHH 2.Plaintiff is the only entity that purchased the debt after Charge—off and its name and OOQONUl-RUJNHOGOOQQUIAUJNHO address is as follows: CAVALRY SPV I, LLC, AS ASSIGNEE OF SYNCHRONY BANK 1 American Lane Suite 220 Greenwich, CT 06831. 3.Plaintiff is a debt buyer, and is the sole owner of the debt at issue. Plaintiffs California Debt Collector License Number 10630-99. 4.The charge-off creditor at the time 0f charge-off is SYNCHRONY BANK, PO BOX 960061 ORLANDO, FL 32896-0061, and the account number associated With this debt is XXXXXXXXXXXX99 1 2. 5.Plaintiff is informed and believes that Defendant are individuals who currently reside COMPLAINT-l 0f 5 within the jurisdictional boundaries 0f the above entitled Court. Therefore, this Court is the proper Court for trial 0f this action. 6.The name and last known address 0f the debtor as they appeared in the charge—off creditor’s records prior t0 the sale 0f the debt is SARA C LUSTIG, 16558 PAINE ST UNIT 1 , OOOQOUI-PUJNH FONTANA, CA 92336-2778. 7.P1aintiff is unaware 0f the true names or capacities, Whether individual, corporate, associate 01‘ otherwise 0f the Defendant sued herein as DOES 1 through 10 inclusive, and therefore, sued the Defendant by such fictitious names. Plaintiff Will amend this Complaint t0 show their true names and capacities once ascertained. 8.Plaintiff believes and at all times mentioned herein, each 0f the Defendant was, and is, the agent, servant and employee, employer 0f each 0f the other Defendant, and also acted in the capacity 0f and as agent 0f the other Defendant. Plaintiff also believes that the individual Defendant, and each of them, are jointly and severally liable that the actions described herein were taken as actions for the benefit 0f the Defendant's separate and/or community property. 9.Plaintiff believes that, for value received, Defendant and each of them, executed and NNNNNNNNNHHr—tr—tr—KHr—tr—tt—tt—t delivered a credit card application t0 the original creditor, SYNCHRONY BANK 0r made such application over the telephone 0r Internet. Pursuant t0 the aforementioned application, SYNCHRONY BANK provided Defendant with a credit account, and granted use privileges 0n OOQONUl-PUJNHOOOOQGUI-PUJNHO the same, account number XXXXXXXXXXXX9912 (hereinafter “Account”). 10.Prior t0 the commencement 0f this action, the Account was assigned for value t0 the Plaintiff and Plaintiff is its current holder. 11.Defendant agreed t0 repay SYNCHRONY BANK and any successors in interest, for any charges on the Account including, but not limited to, charges for purchase 0f goods and service and/or cash advances and balance. 12.Defendant used the Account t0 make purchases and/or t0 take cash advances and/or t0 make balance transfers. Each time the Defendant used the Account t0 purchase goods and services COMPLAINT-2 0f 5