On May 01, 2024 a
Complaint,Petition
was filed
involving a dispute between
Wells Fargo Bank, N.A.,
and
Vargas, Julio C,
for Rule 3.740 Collections $10,000.01 - $35,000 Limited
in the District Court of San Bernardino County.
Preview
PLD-C-001
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 1 1 8226 FOR COURT USE ONLY
NAME: Harlan M. Reese, Esq.
FIRM NAME: REESE LAW GROUP (CA Debt Collection Lic. No.: 10303-99)
STREET ADDRESS: 31 68 Lionshead Avenue 574051 ELECTRONICALLY FILED
CITY, STATE, ZIP CODE: Carlsbad, CA 92010 SUPERIOR COURT OF CALIFORNIA
TELEPHONE No.: 760/842-5850 FAX NO.: 760/842-5865 COUNTY OF SAN BERNARDINO
CourtDocs@reeselawgroup.com
E-MAILADDRESS(OptionaI):
SAN BERNARDINO DISTRICT
ATTORNEY FOR(Name): WELLS FARGO BANK, N.A.
5/1/2024 7:25 AM
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
STREETADDRESSr 247 West Third Street By: Nuvia Rivera, DEPUTY
MAILING ADDRESS: 247 West Third Street
CITY AND ZIPCODE: San Bernardino CA 92415-021 0
BRANCH NAME: SAN BERNARDINO JUSTICE CENTER
PLAINTIFF: WELLS FARGO BANK, N.A.
DEFENDANT: JULIO C VARGAS ,
E DOES 1 To
E COMPLAINT E CONTRACT
AMENDED COMPLAINT (Number):
E CRoss-COMPLAINT E AMENDED CRoss-COMPLAINT (Number):
Jurisdiction (check all that apply):
ACTION Is A LIMITED
Amount demanded E CIVIL CASE
(does not exceed $35,000)
does not exceed $10,000
CASE NUMBER:
E
EE ACTION
ACTION
IS
IS
AN UNLIMITED
RECLASSIFIED by
exceeds $10,000
CIVIL CASE (exceeds $35,000)
this amended complaint or cross-complaint
CIVSBZ41 3889
1.
E Plaintiff*
from limited to unlimited
from unlimited to limited
(name or names):
WELLS FARGO BANK, N.A.
alleges causes of action against defendant* (name or names):
JULIO C VARGAS ,
2. This pleading, including attachments and exhibits, consists ofthe following number of pages:
3. a. Each plaintiff named above is a competent adult
E
E (1)
Except plaintiff (name):
a corporation qualified to do business
Same as paragraph
in
“1”
above.
California.
E (2)
(3)
an unincorporated entity (describe):
other (specify): Plaintiff is a National Banking Association organized under the National Banking Act, Title 12 of
ES
b.
(1)
The United States Code.
Plaintiff (name):
has complied with the fictitious business name laws and is doing business under the fictitious name (specify):
c. ES (2) has complied with
Information about additional plaintiffs
all licensing requirements as a licensed (specify):
who are not competent adults is shown in Attachment 30.
4. a.
E E Each defendant named above
except defendant
is a natural person
E E except defendant (name):
E
E
(1)
(2)
(3)
a business organization, form unknown.
a corporation.
an unincorporated entity (descn'be):
S
E
(1)
(2)
(3)
a business organization, form unknown.
a corporation.
an unincorporated entity (describe):
E (4) a public entity (describe): S (4) a public entity (describe):
E (5) other (specify):
*
If this form is used as a cross—complaint, plaintiff
S (5) other (specify):
means cross-complainant and defendant means cross-defendant. Page 1 of 2
Form Approved for Optional Use COMPLAINT_ContI-act Code of Civil Procedure, § 425.12
Judicial Council of California
PLD-C—001 [Rev. January 1, 2024]
PLD-C-001
SHORT TITLE: CASE NUMBER:
WELLS FARGO BANK, N.A. v. CIVSBZ41 3889
JULIO C VARGAS ,
4. b.
E The
(1)
true names of defendants
Doe defendants
sued as Does are unknown
(specify Doe numbers):
to plaintiff.
were the agents or employees of the named
E (2)
defendants and acted within the scope ofthat agency or employment.
Doe defendants (specify Doe numbers): are persons whose capacities are unknown to
E
E
c.
d.
plaintiff.
Information about additional defendants
Defendants who are joined under Code
who are not natural persons
of Civil Procedure section
is contained
382 are (names):
in Attachment 4c.
EE Plaintiff is required to comply with a claims statute, and
E
a.
b.
has complied with applicable claims
is excused from complying because
statutes, or
(specify):
This action is subjectto Civil Code section 1812.10 E Civil Code section 2984.4.
a.
b.
E
This court
E
is the proper court because
a defendant entered
a defendant lived here
into the contract here.
when the contract was entered into.
c.
d. E
E
a defendant lives here now.
the contract was to be performed here.
e.
f.
g.
E
E
a defendant
real property that
other (specify):
is a corporation or unincorporated association and
is the subject ofthis action is located here.
its principal place of business is here.
The following causes of action are attached and the statements above apply to each (each complaintmust have one or
more causes of action attached):
Breach of Contract
E Common
Other (specify):
Counts
E Other allegations:
10. Plaintiff prays forjudgment for costs of suit; for such relief as is fair, just, and equitable; and for
E E
a.
b.
damages
interest
of: $16,573.40
on the damages
E (1)
(2)
according to proof
at the rate of (specify): percent per year from (date):
c.
E attorney's fees
(1)
(2)
of: $
accordingto proof
d. Other(specify):
11. E Plus costs of
The paragraphs
suit. Minus any payments made that have not yet been
of this pleading alleged on information and belief are
credited.
as follows (specify paragraph numbers):
Date: April 26, 2024
Harlan M. Reese, Esq.
(TYPE 0R PRINT NAME)
V
WW Rm
(SIGNATURE 0F PLAINTIFF 0R ATTORNEY)
(lfyou wish to verify this pleading, affix a verification.)
PLD-C-OO1 [Rev. January Page 2 of 2
1, 2024]
COMPLAINT_Contract
Category
Rule 3.740 Collections $10,000.01 - $35,000 Limited
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Preview
PLD-C-001 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 1 1 8226 FOR COURT USE ONLY NAME: Harlan M. Reese, Esq. FIRM NAME: REESE LAW GROUP (CA Debt Collection Lic. No.: 10303-99) STREET ADDRESS: 31 68 Lionshead Avenue 574051 ELECTRONICALLY FILED CITY, STATE, ZIP CODE: Carlsbad, CA 92010 SUPERIOR COURT OF CALIFORNIA TELEPHONE No.: 760/842-5850 FAX NO.: 760/842-5865 COUNTY OF SAN BERNARDINO CourtDocs@reeselawgroup.com E-MAILADDRESS(OptionaI): SAN BERNARDINO DISTRICT ATTORNEY FOR(Name): WELLS FARGO BANK, N.A. 5/1/2024 7:25 AM SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO STREETADDRESSr 247 West Third Street By: Nuvia Rivera, DEPUTY MAILING ADDRESS: 247 West Third Street CITY AND ZIPCODE: San Bernardino CA 92415-021 0 BRANCH NAME: SAN BERNARDINO JUSTICE CENTER PLAINTIFF: WELLS FARGO BANK, N.A. DEFENDANT: JULIO C VARGAS , E DOES 1 To E COMPLAINT E CONTRACT AMENDED COMPLAINT (Number): E CRoss-COMPLAINT E AMENDED CRoss-COMPLAINT (Number): Jurisdiction (check all that apply): ACTION Is A LIMITED Amount demanded E CIVIL CASE (does not exceed $35,000) does not exceed $10,000 CASE NUMBER: E EE ACTION ACTION IS IS AN UNLIMITED RECLASSIFIED by exceeds $10,000 CIVIL CASE (exceeds $35,000) this amended complaint or cross-complaint CIVSBZ41 3889 1. E Plaintiff* from limited to unlimited from unlimited to limited (name or names): WELLS FARGO BANK, N.A. alleges causes of action against defendant* (name or names): JULIO C VARGAS , 2. This pleading, including attachments and exhibits, consists ofthe following number of pages: 3. a. Each plaintiff named above is a competent adult E E (1) Except plaintiff (name): a corporation qualified to do business Same as paragraph in “1” above. California. E (2) (3) an unincorporated entity (describe): other (specify): Plaintiff is a National Banking Association organized under the National Banking Act, Title 12 of ES b. (1) The United States Code. Plaintiff (name): has complied with the fictitious business name laws and is doing business under the fictitious name (specify): c. ES (2) has complied with Information about additional plaintiffs all licensing requirements as a licensed (specify): who are not competent adults is shown in Attachment 30. 4. a. E E Each defendant named above except defendant is a natural person E E except defendant (name): E E (1) (2) (3) a business organization, form unknown. a corporation. an unincorporated entity (descn'be): S E (1) (2) (3) a business organization, form unknown. a corporation. an unincorporated entity (describe): E (4) a public entity (describe): S (4) a public entity (describe): E (5) other (specify): * If this form is used as a cross—complaint, plaintiff S (5) other (specify): means cross-complainant and defendant means cross-defendant. Page 1 of 2 Form Approved for Optional Use COMPLAINT_ContI-act Code of Civil Procedure, § 425.12 Judicial Council of California PLD-C—001 [Rev. January 1, 2024] PLD-C-001 SHORT TITLE: CASE NUMBER: WELLS FARGO BANK, N.A. v. CIVSBZ41 3889 JULIO C VARGAS , 4. b. E The (1) true names of defendants Doe defendants sued as Does are unknown (specify Doe numbers): to plaintiff. were the agents or employees of the named E (2) defendants and acted within the scope ofthat agency or employment. Doe defendants (specify Doe numbers): are persons whose capacities are unknown to E E c. d. plaintiff. Information about additional defendants Defendants who are joined under Code who are not natural persons of Civil Procedure section is contained 382 are (names): in Attachment 4c. EE Plaintiff is required to comply with a claims statute, and E a. b. has complied with applicable claims is excused from complying because statutes, or (specify): This action is subjectto Civil Code section 1812.10 E Civil Code section 2984.4. a. b. E This court E is the proper court because a defendant entered a defendant lived here into the contract here. when the contract was entered into. c. d. E E a defendant lives here now. the contract was to be performed here. e. f. g. E E a defendant real property that other (specify): is a corporation or unincorporated association and is the subject ofthis action is located here. its principal place of business is here. The following causes of action are attached and the statements above apply to each (each complaintmust have one or more causes of action attached): Breach of Contract E Common Other (specify): Counts E Other allegations: 10. Plaintiff prays forjudgment for costs of suit; for such relief as is fair, just, and equitable; and for E E a. b. damages interest of: $16,573.40 on the damages E (1) (2) according to proof at the rate of (specify): percent per year from (date): c. E attorney's fees (1) (2) of: $ accordingto proof d. Other(specify): 11. E Plus costs of The paragraphs suit. Minus any payments made that have not yet been of this pleading alleged on information and belief are credited. as follows (specify paragraph numbers): Date: April 26, 2024 Harlan M. Reese, Esq. (TYPE 0R PRINT NAME) V WW Rm (SIGNATURE 0F PLAINTIFF 0R ATTORNEY) (lfyou wish to verify this pleading, affix a verification.) PLD-C-OO1 [Rev. January Page 2 of 2 1, 2024] COMPLAINT_Contract