Complaint,Petition: Global Lending Services LLC -v- Cabrera Print

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             GURSTEL LAW FIRM P.C.
             GurstelLaw Firm P.C. ’s California Debt Collection License:                               10361-99.
             Kimberlee Tsai (SBN # 227426)
                                                                                               ELECTRONICALLY FILED
             Brianna ElmaSSian (SBN# 329673)                                                   SUPERIOR COURT OF CALIFORNIA
             Stella Park (SBN# 310445)                                                         COUNTY OF SAN BERNARDINO
 J;
             Spencer Penuela (SBN# 324544)                                                     SAN BERNARD'NO DISTRICT
             Anna Karkoon (SBN# 295797)                                                        4/23/2024 7:34          AM
             Ann Doan (SBN# 297543)                                                                           ,    ,
                                                                                                        _

                                                                                               By' Nuv'a Rlvera’         DEPUTY
             9320 East Raintree Drive, Scottsdale,                 AZ 85260
             Telephone: (877) 344-4002
             Fax: (877) 750-6335
 KOOONONUI




             info@gurstel.com
             Attorneys for Plaintiff,
             Global Lending Services             LLC

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                                    SUPERIOR COURT OF THE STATE OF CALIFORNIA

12                           SAN BERNARDINO COUNTY - SAN BERNARDINO COURT
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             Global Lending Services             LLC                               Case N0. CIVSBZ41 3278
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                                           Plaintiff,

15                                                                                 COMPLAINT FOR BREACH OF
             vs.                                                                   CONTRACT DEFICIENCY
16                                                                                 JUDGMENT (MONEY) C.C. §2981;
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             Jessy   A Valle Cabrera aka Jessy Valle Cabrera                       MONEY LENT, PAID OR EXPENDED
18                                         Defendant.                              Prayer Amount: $12,487.04
                                                                                   LIMITED CIVIL MATTER
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                       Plaintiff,   Global Lending Services LLC, by and through undersigned counsel, for its causes
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             0f action against Jessy        A Valle         Cabrera aka Jessy Valle Cabrera hereby                     states   and alleges as
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             follows:
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                                                           GENERAL ALLEGATIONS

25           1.        Global Lending Services             LLC (hereafter "Plaintiff") is qualified t0 d0 business in the State

26                     0f California.

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             Global Lending Services   LLC vs.   Jessy   A Valle Cabrera aka Jessy Valle Cabrera   /   Case No.2
                      Pursuant t0 C.C.P.          §   395(b) and C.C. § 2984.4(a), this Judicial District is the proper venue


                      and jurisdiction 0f this action because the Defendant resides 0r entered                              into the contract


                      within the jurisdictional boundaries 0f this court.


 J;
                      Plaintiff is the     owner 0f the debt            at issue.




                                                            FIRST CAUSE OF ACTION
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                                                            (BREACH OF CONTRACT)

                      Plaintiff refers to        and incorporates paragraphs           1   through       3.




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                      On 0r about October             1,   2022, Defendant entered into a Retail Installment Sale Contract                    -




11                    Simple Finance Charge (with Arbitration Provision) ("Contract") with an Automobile

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                      Dealer ("Dealer") by the terms ofwhich Dealer agreed t0                           sell   and Defendant agreed t0 buy
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                      a 2020     NISSAN ALTIMA VIN#                           1N4BL4BVOLC153521 ("Motor                      Vehicle").   The
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                      Contract    is   attached hereto as Exhibit 1 and incorporated herein                          by reference.
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16                    Defendant agreed           t0   pay monthly payments 0n the outstanding balance pursuant                          t0 the


17                    Contract.

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                      Defendant agreed           t0   pay   interest at the Contract rate      and       is liable   for interest at that rate.

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                      Defendant indicated              their consent t0       be bound by these terms either by authorizing
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                      signature   0n the agreement and/or by taking possession 0f and using the money and Motor
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22                    Vehicle.


23                    Pursuant t0 the Contract, possession 0fthe Motor Vehicle was delivered t0 Defendant and

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                      a lien   was   t0   be given as security for the payment 0f the                   price.

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             10.      Plaintiff   was assigned             all rights   and   interests in the         above described Contract by the
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                      Dealer.
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             Global Lending Services   LLC vs.   Jessy   A Valle Cabrera aka Jessy Valle Cabrera   /   Case No.2