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ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
Christopher D. Mandarich SB 220693 .
AM
5/1/2024 10'50
Teona Pipia SB 343337
Martin Weingarten SB 201906 By: Nuvia Rivera, DEPUTY
Sarkis Karayan SB 316926
MANDARICH LAW GROUP, LLP
P.O. Box 109032 Chicago, IL 60610
877.285.4918
Facsimile: 818.888.1260
Mandarich Law Group, LLP California Debt Collector License Number 10795—99.
\DOOQONUl-PUJNH
Attorneys for Plaintifi‘: LVNV Funding LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN BERNARDINO LIMITED -
LVNV Funding LLC, Case N0. CIVSBZ41 391 1
Plaintiff,
FILE BY FAX COMPLAINT FOR:
vs.
1. BREACH OF CONTRACT
Rhosheil Chavez Uy, an individual; 2. OPEN BOOK ACCOUNT
and DOES 1through 10 inclusive.
Defendant.
DEMAND; $2,481.27
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, WebB ank.
2. Plaintiff is a debt buyer, and is the sole owner 0f the debt at issue. Plaintiffs California
OOQONUl-PUJNHOKOOOQQUI-PUJNr—to
NNNNNNNNNHHHHHHHHHH
Debt Collector License Number 10888-04.
3. The charge-off creditor at the time 0f charge-off is Avant II, LLC, 222 W Merchandise
Mart Plaza Suite 900 Chicago, IL 60654, and the account number associated With this debt is
XXX2313.
4. The subject credit account has been purchased by the following entities after charge—off:
Sherman Originator III LLC P.O. BOX 10466 Greenville, SC 29603. Sherman Originator LLC
P.O. BOX 10466 Greenville, SC 29603. The subject credit account was transferred by Sherman
Originator LLC t0 Plaintiff LVNV Funding LLC, who maintains an address at C/O Resurgent
COMPLAINT—l 0f 5
Capital Services LP P.O. Box 10466, Greenville, SC 29603.
5. Plaintiff is informed and believes that Defendant are individuals Who currently reside
Within the jurisdictional boundaries 0f the above entitled Court. Therefore, this Court is the
proper Court for trial 0f this action.
\OOOQONUI-hUJNH
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 Rhosheil Chavez Uy 2522
,
North Phil Ochs Ave
2522 North Phil Ochs Ave, Rialto, CA 92377.
7. Plaintiff is unaware 0f the true names 0r capacities, Whether individual, corporate,
associate 0r 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 0f them, executed and
delivered a credit application t0 the original creditor, WebB ank 0r made such application over the
NNNNNNNNNr—HHt—tr—r—HHHH
OOQQUIAUJNHOOOOQQUI-RUJNHO
telephone or Internet. Pursuant t0 the aforementioned application, WebBank provided Defendant
With a credit account, and granted use privileges 0n the same, account number XXX2313
(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 comply with the terms governing the use of the Account, as it was
amended from time t0 time, including repaying WebBank and any successors in interest, for any
charges 0n the Account including, but not limited t0, Charges for purchase 0f goods and service
and/or cash advances and balance transfers along with late charges, over limits Charges related
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 . AM 5/1/2024 10'50 Teona Pipia SB 343337 Martin Weingarten SB 201906 By: Nuvia Rivera, DEPUTY Sarkis Karayan SB 316926 MANDARICH LAW GROUP, LLP P.O. Box 109032 Chicago, IL 60610 877.285.4918 Facsimile: 818.888.1260 Mandarich Law Group, LLP California Debt Collector License Number 10795—99. \DOOQONUl-PUJNH Attorneys for Plaintifi‘: LVNV Funding LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO LIMITED - LVNV Funding LLC, Case N0. CIVSBZ41 391 1 Plaintiff, FILE BY FAX COMPLAINT FOR: vs. 1. BREACH OF CONTRACT Rhosheil Chavez Uy, an individual; 2. OPEN BOOK ACCOUNT and DOES 1through 10 inclusive. Defendant. DEMAND; $2,481.27 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, WebB ank. 2. Plaintiff is a debt buyer, and is the sole owner 0f the debt at issue. Plaintiffs California OOQONUl-PUJNHOKOOOQQUI-PUJNr—to NNNNNNNNNHHHHHHHHHH Debt Collector License Number 10888-04. 3. The charge-off creditor at the time 0f charge-off is Avant II, LLC, 222 W Merchandise Mart Plaza Suite 900 Chicago, IL 60654, and the account number associated With this debt is XXX2313. 4. The subject credit account has been purchased by the following entities after charge—off: Sherman Originator III LLC P.O. BOX 10466 Greenville, SC 29603. Sherman Originator LLC P.O. BOX 10466 Greenville, SC 29603. The subject credit account was transferred by Sherman Originator LLC t0 Plaintiff LVNV Funding LLC, who maintains an address at C/O Resurgent COMPLAINT—l 0f 5 Capital Services LP P.O. Box 10466, Greenville, SC 29603. 5. Plaintiff is informed and believes that Defendant are individuals Who currently reside Within the jurisdictional boundaries 0f the above entitled Court. Therefore, this Court is the proper Court for trial 0f this action. \OOOQONUI-hUJNH 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 Rhosheil Chavez Uy 2522 , North Phil Ochs Ave 2522 North Phil Ochs Ave, Rialto, CA 92377. 7. Plaintiff is unaware 0f the true names 0r capacities, Whether individual, corporate, associate 0r 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 0f them, executed and delivered a credit application t0 the original creditor, WebB ank 0r made such application over the NNNNNNNNNr—HHt—tr—r—HHHH OOQQUIAUJNHOOOOQQUI-RUJNHO telephone or Internet. Pursuant t0 the aforementioned application, WebBank provided Defendant With a credit account, and granted use privileges 0n the same, account number XXX2313 (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 comply with the terms governing the use of the Account, as it was amended from time t0 time, including repaying WebBank and any successors in interest, for any charges 0n the Account including, but not limited t0, Charges for purchase 0f goods and service and/or cash advances and balance transfers along with late charges, over limits Charges related COMPLAINT—2 0f 5