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ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
4/8/2024 9:16 AM
Christopher D. Mandarich SB 220693
Teona Pipia SB 343337 By: Nuvia Rivera, DEPUTY
Martin Weingarten SB 201906
Ioana R. Neacsu SB 324660
MANDARICH LAW GROUP, LLP
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.
CAVALRY SPVI, LLC, AS ASSIGNEE OF CITIBANK, N.A.
\DOOQOUIAUJNH
Attorneysfor Plaintifl:
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN BERNARDINO LIMITED -
N0.CIVSBZ41 161 2
CAVALRY SPV I, LLC, AS ASSIGNEE OF Case
CITIBANK, N.A.,
Plaintiff, COMPLAINT FOR:
VS. 1. ACCOUNT STATED
2. OPEN BOOK ACCOUNT
JATINDER SINGH, an individual;
and DOES 1 through 10 inclusive.
Defendant.
DEMAND: $6,405 .22
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 CITIBANK, N.A., and successor in interest t0 original creditor, CITIBANK, N.A..
NNNNNNNNNHHr—r—r—HHHHH
2.Plaintiff is the only entity that purchased the debt after charge-off and its name and
CAVALRY SPV LLC, AS ASSIGNEE OF CITIBANK, N.A.
OOQONUl-RUJNHOGOOQQUIAUJNHO
address is as follows: I, 1 American
Lane Suite 220 Greenwich, CT 06831.
3.Plaintiff is a debt buyer, and is the sole owner 0f the debt at issue. Plaintiffs California
Debt Collector License Number 10630—99.
4.The Charge—off creditor at the time 0f Charge—off is CITIBANK N.A., PO BOX 78045
Phoenix, AZ 85062—8045, and the account number associated with this debt is
XXXXXXXXXXXX3 1 1 1.
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 JATINDER SINGH, 14402 WILLAMETTE AVE
OOOQOUI-PUJNH
, CHINO, CA 91710-1390.
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 0f 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, CITIBANK, N.A. or made such
application over the telephone 0r Internet. Pursuant t0 the aforementioned application,
CITIBANK, N.A. provided Defendant With a credit account, and granted use privileges 0n the
OOQONUl-PUJNHOOOOQGUI-PUJNHO
same, account number XXXXXXXXXXXX31 11 (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 CITIBANK, N.A. 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 4/8/2024 9:16 AM Christopher D. Mandarich SB 220693 Teona Pipia SB 343337 By: Nuvia Rivera, DEPUTY Martin Weingarten SB 201906 Ioana R. Neacsu SB 324660 MANDARICH LAW GROUP, LLP 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. CAVALRY SPVI, LLC, AS ASSIGNEE OF CITIBANK, N.A. \DOOQOUIAUJNH Attorneysfor Plaintifl: SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO LIMITED - N0.CIVSBZ41 161 2 CAVALRY SPV I, LLC, AS ASSIGNEE OF Case CITIBANK, N.A., Plaintiff, COMPLAINT FOR: VS. 1. ACCOUNT STATED 2. OPEN BOOK ACCOUNT JATINDER SINGH, an individual; and DOES 1 through 10 inclusive. Defendant. DEMAND: $6,405 .22 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 CITIBANK, N.A., and successor in interest t0 original creditor, CITIBANK, N.A.. NNNNNNNNNHHr—r—r—HHHHH 2.Plaintiff is the only entity that purchased the debt after charge-off and its name and CAVALRY SPV LLC, AS ASSIGNEE OF CITIBANK, N.A. OOQONUl-RUJNHOGOOQQUIAUJNHO address is as follows: I, 1 American Lane Suite 220 Greenwich, CT 06831. 3.Plaintiff is a debt buyer, and is the sole owner 0f the debt at issue. Plaintiffs California Debt Collector License Number 10630—99. 4.The Charge—off creditor at the time 0f Charge—off is CITIBANK N.A., PO BOX 78045 Phoenix, AZ 85062—8045, and the account number associated with this debt is XXXXXXXXXXXX3 1 1 1. 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 JATINDER SINGH, 14402 WILLAMETTE AVE OOOQOUI-PUJNH , CHINO, CA 91710-1390. 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 0f 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, CITIBANK, N.A. or made such application over the telephone 0r Internet. Pursuant t0 the aforementioned application, CITIBANK, N.A. provided Defendant With a credit account, and granted use privileges 0n the OOQONUl-PUJNHOOOOQGUI-PUJNHO same, account number XXXXXXXXXXXX31 11 (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 CITIBANK, N.A. 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