Preview
F L E D
comm or cm ”an
I
SUPERIOR
COUNTY 0+ SAN RERmrm-n o
Jordan Cook, Esq. Bar No. 179720
Emily Pierce, Esq. Bar No. 240084
Gregory J. Babcock, Esq. Bar N0. 260437
Kristen Kohler, Esq. Bar No. 263579
Lori Williams, Esq. Bar No. 242985
PORTFOLIO RECOVERY ASSOCIATES, LLC
_ I
SAN
”WV”
BERNAR'JNO
"5M O l’;
7f"
m
0:315»,
’
,.
Wfl/flfl
10680 Treena St., Suite 500
San Diego, CA, 92131
Tel: 866/428-8102
Fax: 757/518-0860
Attorneys for Plaintiff
File No.: 915934
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
ll
PORTFOLIO RECOVERY ASSOCIATES, LLC CIVSB
12
CASENO. 24 I 3 1 8 9
l3
Plaintiff, COMPLAINT FOR:
(1) Account Stated
14 V
JOSE DE JESUS ARROYO, PRAYER AMOUNT: $3,551 .61
and DOES 1 t0 25.
LIMITED CIVIL
De fendant(s).
Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, ("Plaintiff") alleges:
l. Plaintiffis a limited liability company.
2. This coun is the proper court because Plaintiff is informed and believes that Defendant, JOSE DE
JESUS ARROYO ("Defendant"), is a resident of SAN BERNARDINO County, State of California.
3. At all times herein mentioned, Defendants, and each of them, were the principals, agents, employers,
employees, masters, or servants of each 0f their co-defendants and ratified, adopted or approved the acts or
omissions alleged herein, and each defendant, in doing the things alleged, were acting in the course and
scope of said authority of such agents, servants,and employees.
PAGE l
COM PLAINT
_
4. This suit concerns a credit account that was purchased by Plaintiff on or afler January 1, 2014 and,
therefore, is subject to California Civil Céde § 1788.50; et seq.
COMPLIANCE WITH CIVIL CODE § 1788.50, et seq.
Pursuant to California Civil Code § 1788.58(a)(l)-(9):
5. Plaintiff is a debt buyer.
6. A CITIBANK, N.A./ THE HOME DEPOT credit account was issued to Defendant on or about
April l6, 2013. Defendant used, or authorized the use of, the credit account to make purchases and/or
transactions. Defendant received periodic billing statements for the credit account.
Defendant
defaulted in making the required payments. Subsequently, Plaintiff was assigned and transferred all
rights, title and interest in the credit account. The account was assigned, transferred and sold to
Plaintiffby CITIBANK, N.A..
7. Plaintiff is the sole owner ofthe credit account at issue, 0r has authority to assert the rights ofall
owners ofthe debt.
8. The balance at charge-offwas $3,55 1 .61. Plaintiff is not seeking to recover any post charge-off
fees or interest.
9. The date of last payment on the credit account was July 04, 2022.
10. The name and an address 0fthe creditor at the time ofcharge-offwas CITIBANK NA 5800
SOUTH CORPORATE PLACE, SIOUX FALLS SD 57108. At the time ofcharge-off, the charge-ofT
creditor's account number associated with the debt ended in XXXXXXXXXXXXX60] 3.
1 1. The name and last known address of the Defendant as they appeared in the charge-off
creditor's records prior t0 the sale ofthe debt: JOSE DE JESUS ARROYO, 2016 W 18TH ST, SN
BERNRDNO, CA, 9241 1-1017.
PAGE 2
COMPLAINT
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F L E D comm or cm ”an I SUPERIOR COUNTY 0+ SAN RERmrm-n o Jordan Cook, Esq. Bar No. 179720 Emily Pierce, Esq. Bar No. 240084 Gregory J. Babcock, Esq. Bar N0. 260437 Kristen Kohler, Esq. Bar No. 263579 Lori Williams, Esq. Bar No. 242985 PORTFOLIO RECOVERY ASSOCIATES, LLC _ I SAN ”WV” BERNAR'JNO "5M O l’; 7f" m 0:315», ’ ,. Wfl/flfl 10680 Treena St., Suite 500 San Diego, CA, 92131 Tel: 866/428-8102 Fax: 757/518-0860 Attorneys for Plaintiff File No.: 915934 SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO ll PORTFOLIO RECOVERY ASSOCIATES, LLC CIVSB 12 CASENO. 24 I 3 1 8 9 l3 Plaintiff, COMPLAINT FOR: (1) Account Stated 14 V JOSE DE JESUS ARROYO, PRAYER AMOUNT: $3,551 .61 and DOES 1 t0 25. LIMITED CIVIL De fendant(s). Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, ("Plaintiff") alleges: l. Plaintiffis a limited liability company. 2. This coun is the proper court because Plaintiff is informed and believes that Defendant, JOSE DE JESUS ARROYO ("Defendant"), is a resident of SAN BERNARDINO County, State of California. 3. At all times herein mentioned, Defendants, and each of them, were the principals, agents, employers, employees, masters, or servants of each 0f their co-defendants and ratified, adopted or approved the acts or omissions alleged herein, and each defendant, in doing the things alleged, were acting in the course and scope of said authority of such agents, servants,and employees. PAGE l COM PLAINT _ 4. This suit concerns a credit account that was purchased by Plaintiff on or afler January 1, 2014 and, therefore, is subject to California Civil Céde § 1788.50; et seq. COMPLIANCE WITH CIVIL CODE § 1788.50, et seq. Pursuant to California Civil Code § 1788.58(a)(l)-(9): 5. Plaintiff is a debt buyer. 6. A CITIBANK, N.A./ THE HOME DEPOT credit account was issued to Defendant on or about April l6, 2013. Defendant used, or authorized the use of, the credit account to make purchases and/or transactions. Defendant received periodic billing statements for the credit account. Defendant defaulted in making the required payments. Subsequently, Plaintiff was assigned and transferred all rights, title and interest in the credit account. The account was assigned, transferred and sold to Plaintiffby CITIBANK, N.A.. 7. Plaintiff is the sole owner ofthe credit account at issue, 0r has authority to assert the rights ofall owners ofthe debt. 8. The balance at charge-offwas $3,55 1 .61. Plaintiff is not seeking to recover any post charge-off fees or interest. 9. The date of last payment on the credit account was July 04, 2022. 10. The name and an address 0fthe creditor at the time ofcharge-offwas CITIBANK NA 5800 SOUTH CORPORATE PLACE, SIOUX FALLS SD 57108. At the time ofcharge-off, the charge-ofT creditor's account number associated with the debt ended in XXXXXXXXXXXXX60] 3. 1 1. The name and last known address of the Defendant as they appeared in the charge-off creditor's records prior t0 the sale ofthe debt: JOSE DE JESUS ARROYO, 2016 W 18TH ST, SN BERNRDNO, CA, 9241 1-1017. PAGE 2 COMPLAINT