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ROBERT K. HANNA, Bar No.: 341970
State
JUNQIAO XIAO, Bar No.: 341670
State
HYO JIN IULIA IUNG, State Bar No.: 316090 ELECTRONICALLY FILED
MICHAEL D. KAHN, State Bar No.: 236898 SUPERIOR COURT OF CALIFORNIA
LAMONT FREEMAN, State Bar No.: 349862 COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
Midland Credit Management, Inc.
350 CAMINO DE LA REINA, SUITE 100 4/8/2024 8:18 AM
SAN DIEGO, CA 92108
Telephone: (866) 300-8750 By: Deborah Nugent, DEPUTY
Facsimile: (858) 309-1588
CalifomiaLegal@mcmcg.com
CA Debt Collector License Number Pending
Attorneys for Plaintiff
\OOONQ
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT CIVIL DIVISION
10 IVSBZ41 1474
MIDLAND CREDIT MANAGEMENT, INC. Case No.0
11
Plaintiff, COMPLAINT FOR:
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VS. (1) Account Stated
13
14
DAVE KING; PRAYER AMT: $2,827.92
and DOES 1 through 10, inclusive LIMITED
15 Defendant.
16
MIDLAND CREDIT MANAGEMENT, INC, ("Plaintiff'), by counsel, sues DAVE KING,
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(“Defendant”) under Account Stated and in support thereof states:
18 1. Plaintiff is authorized t0 d0 business in CALIFORNIA, with its principal place of
19 business at 350 CAMINO DE LA REINA SUITE 100 SAN DIEGO CA 92108. Plaintiff
20 owns portfolios of consumer receivables, which it attempts to collect. Plaintiff strives to
treat its consumers, such as Defendant, with respect, compassion and integrity, hoping to
21
provide mutually—beneficial opportunities for consumers to repay their debts and attain
22
financial recovery.
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Defendant is a resident 0f SAN BERNARDINO County, State of California and is
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subject to this Court’s jurisdiction.
25 unaware 0f the names and capacities 0f Defendants sued
Plaintiff is true by the fictitious
26 names DOES 1 through 10. Plaintiff Will ask leave 0f court t0 amend this complaint as
27 and when the true names and capacities of Defendants named herein as DOES 1 through
10 have been ascertained.
28
Pursuant t0 California Civil Code (“CA CIVIL”) §1788.58(a)(1)—(9), Plaintiff alleges:
Plaintiff is a debt buyer as defined by CA CIVIL §1788.50(a).
1
COMPLAINT
CA_0132G File No.: 24-3 1433 SCP
Defendant established an account (the “Account”) with CREDIT ONE BANK, N.A..
The amount due is the result 0f transactions that occurred on the Account. Defendant was
provided statements evidencing Defendant’s use 0f the Account and the balance due.
AWN
Defendant failed to make the required payments and subsequently defaulted on the
Account on July 21, 2021. Thereafter, Plaintiff was assigned all rights, title, and interest
in the Account.
Plaintiff is the sole owner 0f the debt. Attached as Exhibit A is a true and correct copy of
the Bill 0f Sale from CREDIT ONE BANK, N.A., t0 Plaintiff. The Account was
KOOONQ
purchased by Plaintiff on February 25, 2022.
The Account balance at the time of charge-off was $2,827.92. Plaintiff alleges that the
date 0f default is July 21, 2021 and the date 0f the last payment was May 24, 2021.
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The name of the charge-off creditor at the time of charge-off is CREDIT ONE BANK,
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N.A.. The address utilized by CREDIT ONE BANK, N.A. at the time of charge-off was
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P.O. BOX 98873 LAS VEGAS,NV 89193. At the time 0f charge off, the account
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number associated With the debt was XXXXXXXX-XX-681 1.
14 The name of the debtor as it appeared in the records of CREDIT ONE BANK, N.A. is
15 DAVE KING and the last known address as it appeared in the records 0f CREDIT ONE
16 BANK, N.A. is 38491 PATRICK DR INDIO CA 92203.
10. The name and address 0f all post charge-off purchasers of the debt are as follows:
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Name Address
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MHC RECEIVABLES, LLC 6807 S. CIMARRON RD LAS VEGAS NV
891 13
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CREDIT ASSET SALES LLC 200 MEETING STREET SUITE 206
20 CHARLESTON SC 29401
MIDLAND CREDIT MANAGEMENT, 350 CAMINO DE LA REINA SUITE 100 SAN
21 INC. DIEGO CA 92108
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11. Plaintiff has complied With the provisions of CA CIVIL §1788.52. Plaintiff informed
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Defendant of the assignment of the Account.
24 12 Pursuant t0 CA CIVIL §1788.58(b), attached as Exhibit B is a true and correct copy 0f a
25 monthly statement recording a purchase transaction, payment, 0r balance transfer While
26 the Account was active as required by CA CIVIL §1788.52(b).
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13. Attached as Exhibit C is a true and correct copy of a billing statement that was mailed to
Defendant stating the balance due on the Account at or around the time of charge-off.
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14. Plaintiff acquired all right, title, and interest t0 the Account. T0 the extent that Plaintiff
acts in its capacity as successor—in-interest t0 the original creditor or its assigns,
references herein to Plaintiff may include Plaintiff” s predecessor-in-interest.
2
COMPLAINT
CA_0132G File N0.: 24-3 1433 SCP
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ROBERT K. HANNA, Bar No.: 341970 State JUNQIAO XIAO, Bar No.: 341670 State HYO JIN IULIA IUNG, State Bar No.: 316090 ELECTRONICALLY FILED MICHAEL D. KAHN, State Bar No.: 236898 SUPERIOR COURT OF CALIFORNIA LAMONT FREEMAN, State Bar No.: 349862 COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT Midland Credit Management, Inc. 350 CAMINO DE LA REINA, SUITE 100 4/8/2024 8:18 AM SAN DIEGO, CA 92108 Telephone: (866) 300-8750 By: Deborah Nugent, DEPUTY Facsimile: (858) 309-1588 CalifomiaLegal@mcmcg.com CA Debt Collector License Number Pending Attorneys for Plaintiff \OOONQ SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT CIVIL DIVISION 10 IVSBZ41 1474 MIDLAND CREDIT MANAGEMENT, INC. Case No.0 11 Plaintiff, COMPLAINT FOR: 12 VS. (1) Account Stated 13 14 DAVE KING; PRAYER AMT: $2,827.92 and DOES 1 through 10, inclusive LIMITED 15 Defendant. 16 MIDLAND CREDIT MANAGEMENT, INC, ("Plaintiff'), by counsel, sues DAVE KING, 17 (“Defendant”) under Account Stated and in support thereof states: 18 1. Plaintiff is authorized t0 d0 business in CALIFORNIA, with its principal place of 19 business at 350 CAMINO DE LA REINA SUITE 100 SAN DIEGO CA 92108. Plaintiff 20 owns portfolios of consumer receivables, which it attempts to collect. Plaintiff strives to treat its consumers, such as Defendant, with respect, compassion and integrity, hoping to 21 provide mutually—beneficial opportunities for consumers to repay their debts and attain 22 financial recovery. 23 Defendant is a resident 0f SAN BERNARDINO County, State of California and is 24 subject to this Court’s jurisdiction. 25 unaware 0f the names and capacities 0f Defendants sued Plaintiff is true by the fictitious 26 names DOES 1 through 10. Plaintiff Will ask leave 0f court t0 amend this complaint as 27 and when the true names and capacities of Defendants named herein as DOES 1 through 10 have been ascertained. 28 Pursuant t0 California Civil Code (“CA CIVIL”) §1788.58(a)(1)—(9), Plaintiff alleges: Plaintiff is a debt buyer as defined by CA CIVIL §1788.50(a). 1 COMPLAINT CA_0132G File No.: 24-3 1433 SCP Defendant established an account (the “Account”) with CREDIT ONE BANK, N.A.. The amount due is the result 0f transactions that occurred on the Account. Defendant was provided statements evidencing Defendant’s use 0f the Account and the balance due. AWN Defendant failed to make the required payments and subsequently defaulted on the Account on July 21, 2021. Thereafter, Plaintiff was assigned all rights, title, and interest in the Account. Plaintiff is the sole owner 0f the debt. Attached as Exhibit A is a true and correct copy of the Bill 0f Sale from CREDIT ONE BANK, N.A., t0 Plaintiff. The Account was KOOONQ purchased by Plaintiff on February 25, 2022. The Account balance at the time of charge-off was $2,827.92. Plaintiff alleges that the date 0f default is July 21, 2021 and the date 0f the last payment was May 24, 2021. 10 The name of the charge-off creditor at the time of charge-off is CREDIT ONE BANK, 11 N.A.. The address utilized by CREDIT ONE BANK, N.A. at the time of charge-off was 12 P.O. BOX 98873 LAS VEGAS,NV 89193. At the time 0f charge off, the account 13 number associated With the debt was XXXXXXXX-XX-681 1. 14 The name of the debtor as it appeared in the records of CREDIT ONE BANK, N.A. is 15 DAVE KING and the last known address as it appeared in the records 0f CREDIT ONE 16 BANK, N.A. is 38491 PATRICK DR INDIO CA 92203. 10. The name and address 0f all post charge-off purchasers of the debt are as follows: 17 Name Address 18 MHC RECEIVABLES, LLC 6807 S. CIMARRON RD LAS VEGAS NV 891 13 19 CREDIT ASSET SALES LLC 200 MEETING STREET SUITE 206 20 CHARLESTON SC 29401 MIDLAND CREDIT MANAGEMENT, 350 CAMINO DE LA REINA SUITE 100 SAN 21 INC. DIEGO CA 92108 22 11. Plaintiff has complied With the provisions of CA CIVIL §1788.52. Plaintiff informed 23 Defendant of the assignment of the Account. 24 12 Pursuant t0 CA CIVIL §1788.58(b), attached as Exhibit B is a true and correct copy 0f a 25 monthly statement recording a purchase transaction, payment, 0r balance transfer While 26 the Account was active as required by CA CIVIL §1788.52(b). 27 13. Attached as Exhibit C is a true and correct copy of a billing statement that was mailed to Defendant stating the balance due on the Account at or around the time of charge-off. 28 14. Plaintiff acquired all right, title, and interest t0 the Account. T0 the extent that Plaintiff acts in its capacity as successor—in-interest t0 the original creditor or its assigns, references herein to Plaintiff may include Plaintiff” s predecessor-in-interest. 2 COMPLAINT CA_0132G File N0.: 24-3 1433 SCP