On May 08, 2024 a
Complaint,Petition
was filed
involving a dispute between
Synchrony Bank,
and
Does 1 - 15, Inclusive,
Velasco, Abraham,
for Rule 3.740 Collections $10,000 or Less Limited
in the District Court of San Bernardino County.
Preview
PLD-C-001
ATTORNEY OR PARTY WITHOUT ATTORNEY FOR COURT USE ONLY
PATENAUDE & FELIX, A.P.C.
Raymond A. Patenaude (128855) / Laura M. D'Anna (2661 13) ELECTRONICALLY FILED
Nathalia A. Aguirre (337628) / Dinari J. Lee (314542) /Abn'| Saglio-Ruiz (299586)
SUPER|QR COURT 0F CAL|FQRN|A
9619 Chesapeake Drive, Suite 300, San Diego, CA 92123 COUNTY OF SAN BERNARDINO
California DFPI Debt Collector License #10678—99 SAN BERNARD'NO DISTR'CT
TELEPHONE No.: (858) 244-7600 FAX No.: (858) 836-0318
E-MAIL ADDRESS:SD.Legal@Pandf.us
5/8/2024 8'09
_
AM
ATTORNEY FOR (Name): PLAINTIFF By; Ika Schymik’ DEPUTY
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
STREET ADDRESS: 247WEST 3RD STREET
MAILING ADDRESS: 247WEST 3RD STREET
CITY AND ZIP CODE: SAN BERNARDINO CA 92415-0210
BRANCH NAME: SAN BERNARDINO JUSTICE CENTER
PLAINTIFF: SYNCHRONY BANK
DEFENDANT(S): ABRAHAM VELASCO,
g and DOES 1 through 15, inclusive
CONTRACT
g COMPLAINT D AMENDED COMPLAINT(Number):
D CRoss-COMPLAINT D AMENDED CRoss-COMPLAINT (Number):
JuriSdiCtion (CheCk a” that apply): CASE NUMBER;
g ACTION IS A LIMITED CIVIL CASE (does not exceed $35,000)
Amount demanded g does not exceed $10,000
exceeds $10,000 C|VSBZ41 4548
D ACTION IS AN UNLIMITED CIVIL CASE (exceeds $35,000)
D ACTION IS RECLASSIFIED by this amended complaint or cross-complaint
D from limited to unlimited
D from unlimited to limited
1. Plaintiff* (name or names): SYNCHRONY BANK
alleges causes of action against defendant* (name or names): ABRAHAM VELASCO, and DOES 1 through 15, inclusive
2. This pleading, including attachments and exhibits, consists ofthe following number of pages: 3
3. a. Each plaintiff named above is a competent adult
g except plaintiff (name): SYNCHRONY BANK
(1) Da corporation qualified to do business in California
(2) D an unincorporated entity (describe):
(3) g other (specify): a National Banking Association organized and existing under and by Virtue 0f the law
0f the United States 0f America.
b. D Plaintiff (name):
a. D has complied with the fictitious business name laws and is doing business under the fictitious name (specify):
b. D has complied with all licensing requirements as a licensed (specify):
c. D about
Information additional plaintiffs who are not competent adults is shown in Attachment 3c.
4. a. Each defendant(s) named above is a natural person
D except defendant (name): D except defendant (name):
D a business
(1) organization, form unknown (1) D a business organization, form unknown
Da
(2) corporation (2) D a corporation
D an
(3) unincorporated entity (describe): (3) D an unincorporated entity (describe):
Da
(4) public entity (describe): (4) D a public entity (describe):
D
(5) other (specify): (5) D other (specify).-
*|f this form is used as a cross-complaint, plaintiff means cross-complainant and defendant means cross-defendant. Page 1 of2
ForwAppmve‘? f°r Op.ti°“‘i" use COMPLAINT—Contract Code of Civil Procedure, § 425.12.
JudICIaI CounCII of Callfornla
PLD-C-001 [Rev. January 1, 2024] WWW-COUFtS-Ca-QOV
CA_O3 EFile Complaint Contract P&F File N0. 24-15802
PLD-C-001
SHORT TITLE: SYNCHRONY BANK vs. ABRAHAM VELASCO, CASE NUMBER:
4. (Continued)
b. The true names of defendants sued as Does are unknown to plaintiff.
(1) D Doe defendants (specify Doe numbers): were the agents or employees of the named
defendants and acted within the scope of that agency or employment.
(2) g Doe defendants (specify Doe numbers): 1 through 15 are persons whose capacities are unknown to
plaintiff.
c. D Information about additional defendants who are not natural persons is contained in Attachment 4c.
d. D Defendant(s) who are joined under Code of Civil Procedure section 382 are (names):
5. D Plaintiff is required to comply with a claims statute, and
a. D has complied with applicable claims statutes, or
b. D is excused from complying because (specify):
6. D This action is subject to D Civil Code section 1812.10 D Civil Code section 2984.4.
7. This court is the proper court because
a. D a defendant entered into the contract here.
b a defendant lived here when the contract was entered into.
c. a defendant lives here now.
DEED
d the contract was to be performed here.
e a defendant is a corporation or unincorporated association and its principal place of business is here.
f. D real property that is the subject of this action is located here.
g. D other (specify):
8. The following causes of action are attached and the statements above apply to each (each complaint must have one or more
causes of action attached):
D Breach of Contract
g Common Counts
X Other (specify): Refer to Other allegations in number 9
X Other allegations: Before commencement of this action, in those cases where recovery 0f costs is dependent on such
notices, Plaintiff informed the defendant(s) in writing it intended to file this action and that this action could result in
a judgment against defendant(s) that would include court costs and necessary disbursements allowed by CCP Section
1033(b)(2).
10. Plaintiff prays forjudgment for costs of suit; for such relief as is fair, just, and equitable; and for
a. X damages of: $5,693.67
b. D interest on the damages
(1) D according to proof
(2) D at the rate of (specify): percent per year from (date):
c. D attorney's fees
(1) D of:
(2) D according to proof.
d. g other (specify): For such other relief as the Court deems just and fair.
11. D The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers):
Date: April 23, 2024
[ ] NATHALIA A. AGUIRRE [X] DINARI J. LEE
[ ]
ABRIL SAGLIO—RUIZ
(TYPE 0R PRINT NAME)
V g gé (SIGNATURE 0F PLAINTIFF 0R ATTORNEY)
(If you Wish to verify this pleading, affix a verification.)
PLD-C-001 [Rev. January 1, 2024] c0MPLAINT—Contract Page 2 of 2
CA_O3 EFile Complaint Contract P&F File N0. 24-15802
Document Filed Date
May 08, 2024
Case Filing Date
May 08, 2024
Category
Rule 3.740 Collections $10,000 or Less Limited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
PLD-C-001 ATTORNEY OR PARTY WITHOUT ATTORNEY FOR COURT USE ONLY PATENAUDE & FELIX, A.P.C. Raymond A. Patenaude (128855) / Laura M. D'Anna (2661 13) ELECTRONICALLY FILED Nathalia A. Aguirre (337628) / Dinari J. Lee (314542) /Abn'| Saglio-Ruiz (299586) SUPER|QR COURT 0F CAL|FQRN|A 9619 Chesapeake Drive, Suite 300, San Diego, CA 92123 COUNTY OF SAN BERNARDINO California DFPI Debt Collector License #10678—99 SAN BERNARD'NO DISTR'CT TELEPHONE No.: (858) 244-7600 FAX No.: (858) 836-0318 E-MAIL ADDRESS:SD.Legal@Pandf.us 5/8/2024 8'09 _ AM ATTORNEY FOR (Name): PLAINTIFF By; Ika Schymik’ DEPUTY SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO STREET ADDRESS: 247WEST 3RD STREET MAILING ADDRESS: 247WEST 3RD STREET CITY AND ZIP CODE: SAN BERNARDINO CA 92415-0210 BRANCH NAME: SAN BERNARDINO JUSTICE CENTER PLAINTIFF: SYNCHRONY BANK DEFENDANT(S): ABRAHAM VELASCO, g and DOES 1 through 15, inclusive CONTRACT g COMPLAINT D AMENDED COMPLAINT(Number): D CRoss-COMPLAINT D AMENDED CRoss-COMPLAINT (Number): JuriSdiCtion (CheCk a” that apply): CASE NUMBER; g ACTION IS A LIMITED CIVIL CASE (does not exceed $35,000) Amount demanded g does not exceed $10,000 exceeds $10,000 C|VSBZ41 4548 D ACTION IS AN UNLIMITED CIVIL CASE (exceeds $35,000) D ACTION IS RECLASSIFIED by this amended complaint or cross-complaint D from limited to unlimited D from unlimited to limited 1. Plaintiff* (name or names): SYNCHRONY BANK alleges causes of action against defendant* (name or names): ABRAHAM VELASCO, and DOES 1 through 15, inclusive 2. This pleading, including attachments and exhibits, consists ofthe following number of pages: 3 3. a. Each plaintiff named above is a competent adult g except plaintiff (name): SYNCHRONY BANK (1) Da corporation qualified to do business in California (2) D an unincorporated entity (describe): (3) g other (specify): a National Banking Association organized and existing under and by Virtue 0f the law 0f the United States 0f America. b. D Plaintiff (name): a. D has complied with the fictitious business name laws and is doing business under the fictitious name (specify): b. D has complied with all licensing requirements as a licensed (specify): c. D about Information additional plaintiffs who are not competent adults is shown in Attachment 3c. 4. a. Each defendant(s) named above is a natural person D except defendant (name): D except defendant (name): D a business (1) organization, form unknown (1) D a business organization, form unknown Da (2) corporation (2) D a corporation D an (3) unincorporated entity (describe): (3) D an unincorporated entity (describe): Da (4) public entity (describe): (4) D a public entity (describe): D (5) other (specify): (5) D other (specify).- *|f this form is used as a cross-complaint, plaintiff means cross-complainant and defendant means cross-defendant. Page 1 of2 ForwAppmve‘? f°r Op.ti°“‘i" use COMPLAINT—Contract Code of Civil Procedure, § 425.12. JudICIaI CounCII of Callfornla PLD-C-001 [Rev. January 1, 2024] WWW-COUFtS-Ca-QOV CA_O3 EFile Complaint Contract P&F File N0. 24-15802 PLD-C-001 SHORT TITLE: SYNCHRONY BANK vs. ABRAHAM VELASCO, CASE NUMBER: 4. (Continued) b. The true names of defendants sued as Does are unknown to plaintiff. (1) D Doe defendants (specify Doe numbers): were the agents or employees of the named defendants and acted within the scope of that agency or employment. (2) g Doe defendants (specify Doe numbers): 1 through 15 are persons whose capacities are unknown to plaintiff. c. D Information about additional defendants who are not natural persons is contained in Attachment 4c. d. D Defendant(s) who are joined under Code of Civil Procedure section 382 are (names): 5. D Plaintiff is required to comply with a claims statute, and a. D has complied with applicable claims statutes, or b. D is excused from complying because (specify): 6. D This action is subject to D Civil Code section 1812.10 D Civil Code section 2984.4. 7. This court is the proper court because a. D a defendant entered into the contract here. b a defendant lived here when the contract was entered into. c. a defendant lives here now. DEED d the contract was to be performed here. e a defendant is a corporation or unincorporated association and its principal place of business is here. f. D real property that is the subject of this action is located here. g. D other (specify): 8. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): D Breach of Contract g Common Counts X Other (specify): Refer to Other allegations in number 9 X Other allegations: Before commencement of this action, in those cases where recovery 0f costs is dependent on such notices, Plaintiff informed the defendant(s) in writing it intended to file this action and that this action could result in a judgment against defendant(s) that would include court costs and necessary disbursements allowed by CCP Section 1033(b)(2). 10. Plaintiff prays forjudgment for costs of suit; for such relief as is fair, just, and equitable; and for a. X damages of: $5,693.67 b. D interest on the damages (1) D according to proof (2) D at the rate of (specify): percent per year from (date): c. D attorney's fees (1) D of: (2) D according to proof. d. g other (specify): For such other relief as the Court deems just and fair. 11. D The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers): Date: April 23, 2024 [ ] NATHALIA A. AGUIRRE [X] DINARI J. LEE [ ] ABRIL SAGLIO—RUIZ (TYPE 0R PRINT NAME) V g gé (SIGNATURE 0F PLAINTIFF 0R ATTORNEY) (If you Wish to verify this pleading, affix a verification.) PLD-C-001 [Rev. January 1, 2024] c0MPLAINT—Contract Page 2 of 2 CA_O3 EFile Complaint Contract P&F File N0. 24-15802