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ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
Christopher D. Mandarich SB 220693
Teona Pipia SB 343337 4/5/2024 5:24 AM
Martin Weingarten SB 201906
MANDARICH LAW GROUP, LLP By: Jacob Sobredo, DEPUTY
P.O. Box 109032 Chicago, IL 60610
Phone: 877.285.4918
Facsimile: 818.888.1260
Mandarich Law Group, LLP California Debt Collector License Number 10795—99.
\DOOQOUIAUJNH
Attorneys for Plaintifi”: LVNV Funding LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN BERNARDINO LIMITED -
CIVSBZ41 1 198
LVNV Funding LLC, Case N0.
Plaintiff,
COMPLAINT FOR:
VS. FILE BY FAX
1. ACCOUNT STATED
Brian Reynolds, an individual; 2. OPEN BOOK ACCOUNT
and DOES 1 through 10 inclusive.
Defendant“
DEMAND: $1,727.58
Plaintiff alleges:
FACTS COMMON TO ALL CAUSES OF ACTION
1.Plaintiff is and at all times herein mentioned, LVNV Funding LLC, and successor in
interest t0 original creditor, Sterling Jewelers, Inc..
2.Plaintiff is a debt buyer, and is the sole owner 0f the debt at issue. Plaintiffs California
NNNNNNNNNHHr—r—r—HHHHH
Debt Collector License Number 10888—04.
OOQONUl-RUJNHOGOOQQUIAUJNHO
3.The Charge—off creditor at the time 0f charge—off is Sterling Jewelers, Inc., 375 Ghent
Road Akron, OH 44333, and the account number associated with this debt is
XXXXXXXXXXXXI 83 3 .
4.The subject credit account has been purchased by the following entities after charge-off:
WSFS, FSB, as Trustee for CVI SGP Acquis. Trust P.O. BOX 10466 Greenville, SC 29603.
Resurgent Acquisitions LLC P.O. BOX 10466 Greenville, SC 29603. The subject credit account
was transferred by Resurgent Acquisitions LLC t0 Plaintiff LVNV Funding LLC, who maintains
an address at C/O Resurgent Capital Services LP P.O. BOX 10466, Greenville, SC 29603.
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 Brian Reynolds, 18754 WILLOW ST ,
OOOQOUI-PUJNH
HESPERIA, CA 92345-5540.
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, Sterling Jewelers, Inc. or made such
application over the telephone 0r Internet. Pursuant t0 the aforementioned application, Sterling
Jewelers, Inc. provided Defendant with a credit account, and granted use privileges 0n the same,
OOQONUl-PUJNHOOOOQGUI-PUJNHO
account number XXXXXXXXXXXX1833 (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 Sterling Jewelers, Inc. and any successors in interest, for any
charges 0n the Account including, but not limited t0, Charges for purchase of 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
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ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT Christopher D. Mandarich SB 220693 Teona Pipia SB 343337 4/5/2024 5:24 AM Martin Weingarten SB 201906 MANDARICH LAW GROUP, LLP By: Jacob Sobredo, DEPUTY P.O. Box 109032 Chicago, IL 60610 Phone: 877.285.4918 Facsimile: 818.888.1260 Mandarich Law Group, LLP California Debt Collector License Number 10795—99. \DOOQOUIAUJNH Attorneys for Plaintifi”: LVNV Funding LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO LIMITED - CIVSBZ41 1 198 LVNV Funding LLC, Case N0. Plaintiff, COMPLAINT FOR: VS. FILE BY FAX 1. ACCOUNT STATED Brian Reynolds, an individual; 2. OPEN BOOK ACCOUNT and DOES 1 through 10 inclusive. Defendant“ DEMAND: $1,727.58 Plaintiff alleges: FACTS COMMON TO ALL CAUSES OF ACTION 1.Plaintiff is and at all times herein mentioned, LVNV Funding LLC, and successor in interest t0 original creditor, Sterling Jewelers, Inc.. 2.Plaintiff is a debt buyer, and is the sole owner 0f the debt at issue. Plaintiffs California NNNNNNNNNHHr—r—r—HHHHH Debt Collector License Number 10888—04. OOQONUl-RUJNHOGOOQQUIAUJNHO 3.The Charge—off creditor at the time 0f charge—off is Sterling Jewelers, Inc., 375 Ghent Road Akron, OH 44333, and the account number associated with this debt is XXXXXXXXXXXXI 83 3 . 4.The subject credit account has been purchased by the following entities after charge-off: WSFS, FSB, as Trustee for CVI SGP Acquis. Trust P.O. BOX 10466 Greenville, SC 29603. Resurgent Acquisitions LLC P.O. BOX 10466 Greenville, SC 29603. The subject credit account was transferred by Resurgent Acquisitions LLC t0 Plaintiff LVNV Funding LLC, who maintains an address at C/O Resurgent Capital Services LP P.O. BOX 10466, Greenville, SC 29603. 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 Brian Reynolds, 18754 WILLOW ST , OOOQOUI-PUJNH HESPERIA, CA 92345-5540. 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, Sterling Jewelers, Inc. or made such application over the telephone 0r Internet. Pursuant t0 the aforementioned application, Sterling Jewelers, Inc. provided Defendant with a credit account, and granted use privileges 0n the same, OOQONUl-PUJNHOOOOQGUI-PUJNHO account number XXXXXXXXXXXX1833 (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 Sterling Jewelers, Inc. and any successors in interest, for any charges 0n the Account including, but not limited t0, Charges for purchase of 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