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F I L E D m
Lori Williams, Esq. Bar No. 242985 supemoa COURT 0F W833
COUNTY 0F BE
Emily Pierce, Esq. Bar No. 240084 SAN BERNARD'NO D'STRBT
Gregory J. Babcock, Esq. Bar No. 260437
Jordan Cook, Esq. Bar No. 179720 MAY 0 8 202“
Kristen Kohler, Esq. Bar No. 263579 .
IL
PORTFOLIO RECOVERY ASSOCIATES, LLC
10680 Treena Sn, Suite 500
San Diego, CA, 92131
By
(”.m- c,‘
Wu 0'9“”
Tel: 866/428-8102
Fax: 757/518-0860
Attorneys for Plaintiff
File No.1 933889
SUPERIOR COURT OF CALIFORNIA
10
COUNTY OF SAN BERNARDINO
11
PORTFOLIO RECOVERY ASSOCIATES, LLC C'V SB 2 h ‘ l!
Z I 7
12
CASE NO.
l3
Plaintiff, COMPLAINT FOR:
(l) Account Stated
l4 v
15 MARISOL CHAVEZ, PRAYER AMOUNT: $3,302.10
and DOES t0 25. 1
16
LIMITED CIVIL
17 Defendant(s).
l8
Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, ("Plaintiff") alleges:
l9
1. Plaintiff is a limited liability company.
20
2. This court is the proper court because Plaintiff is informed and believes that Defendant, MARISOL
21
22
CHAVEZ ("Defendant"), is a resident of SAN BERNARDINO County, State 0f California.
3. At all times herein mentioned, Defendants, and each ofthem, were the principals, agents, employers,
employees, masters, 0r servants of each of 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
COMPLAINT
_.
4. This suit concerns a credit account that was purchased by Plaintiff on or afier January 1, 2014 and,
therefore, is subject to California Civil Code § 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./ WAYFAIR credit account was issued to Defendant 0n or about November
08, 2020. Defendant used, or authorized the use of, the credit account t0 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 of the credit account at issue, or has authority to assert the rights ofal]
owners of the debt.
8. The balance at charge-offwas $3,302.10. Plaintiff is not seeking to recover any post charge-off
fees 0r interest.
9. The date of last payment on the credit account was September 02, 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 0f charge-off, the charge-off
creditor‘s account number associated with the debt ended in XXXXXXXXXXXXX6280.
l 1. The name and last known address ofthe Defendant as they appeared in the charge-off
creditor's records prior t0 the sale 0fthe debt: MARISOL CHAVEZ, 9562 GRAPEFRUIT AVE,
HESPERIA, CA, 92345-63 l4.
PAGE 2
COM PLAINT
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F I L E D m Lori Williams, Esq. Bar No. 242985 supemoa COURT 0F W833 COUNTY 0F BE Emily Pierce, Esq. Bar No. 240084 SAN BERNARD'NO D'STRBT Gregory J. Babcock, Esq. Bar No. 260437 Jordan Cook, Esq. Bar No. 179720 MAY 0 8 202“ Kristen Kohler, Esq. Bar No. 263579 . IL PORTFOLIO RECOVERY ASSOCIATES, LLC 10680 Treena Sn, Suite 500 San Diego, CA, 92131 By (”.m- c,‘ Wu 0'9“” Tel: 866/428-8102 Fax: 757/518-0860 Attorneys for Plaintiff File No.1 933889 SUPERIOR COURT OF CALIFORNIA 10 COUNTY OF SAN BERNARDINO 11 PORTFOLIO RECOVERY ASSOCIATES, LLC C'V SB 2 h ‘ l! Z I 7 12 CASE NO. l3 Plaintiff, COMPLAINT FOR: (l) Account Stated l4 v 15 MARISOL CHAVEZ, PRAYER AMOUNT: $3,302.10 and DOES t0 25. 1 16 LIMITED CIVIL 17 Defendant(s). l8 Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, ("Plaintiff") alleges: l9 1. Plaintiff is a limited liability company. 20 2. This court is the proper court because Plaintiff is informed and believes that Defendant, MARISOL 21 22 CHAVEZ ("Defendant"), is a resident of SAN BERNARDINO County, State 0f California. 3. At all times herein mentioned, Defendants, and each ofthem, were the principals, agents, employers, employees, masters, 0r servants of each of 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 COMPLAINT _. 4. This suit concerns a credit account that was purchased by Plaintiff on or afier January 1, 2014 and, therefore, is subject to California Civil Code § 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./ WAYFAIR credit account was issued to Defendant 0n or about November 08, 2020. Defendant used, or authorized the use of, the credit account t0 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 of the credit account at issue, or has authority to assert the rights ofal] owners of the debt. 8. The balance at charge-offwas $3,302.10. Plaintiff is not seeking to recover any post charge-off fees 0r interest. 9. The date of last payment on the credit account was September 02, 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 0f charge-off, the charge-off creditor‘s account number associated with the debt ended in XXXXXXXXXXXXX6280. l 1. The name and last known address ofthe Defendant as they appeared in the charge-off creditor's records prior t0 the sale 0fthe debt: MARISOL CHAVEZ, 9562 GRAPEFRUIT AVE, HESPERIA, CA, 92345-63 l4. PAGE 2 COM PLAINT