On May 24, 2024 a
Complaint,Petition
was filed
involving a dispute between
Jpmorgan Chase Bank, N.A.,
and
Exiga, Crystal,
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 (Name, State Bar number, and address): FOR COURT USE ONLY
Hunt & Henriques, LLP
Donald Sherrill #266038 | |
Anthony DiPiero #268246
7017 Realm Drive
San José CA 951 19
CA Debt Collection License No. 101 36-99 ELECTRONICALLY FILED
I
TELEPHONE No: (800) 680-2426 FAX No. (Optional); (408) 362-2299 SUPERIOR COURT OF CALIFORNIA
EMAIL ADDRESS (OptionaI); COUNTY OF SAN BERNARDINO
ATTORNEY FOR (Name): Plaintiff SAN BERNARDINO DISTRICT
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO 5/24/2024 2:37 PM
STREET ADDRESS: 247 West Third Street
MAILING ADDRESS: By: Isabel Torres, DEPUTY
cm! AND z|P cone; San Bernardino CA 92415-0210
BRANCH NAME: San Bernardino Districl-Civil Division
PLAINTIFF: JPMorgan Chase Bank, N.A.
DEFENDANT: CRYSTAL EXIGA
D DOES 1 To
CONTRACT
m COMPLAINT E AMENDED COMPLAINT (Number):
E CROSS-COMPLAINT E AMENDED CROSS-COMPLAiNT (Number):
m
Jurisdiction (check all that apply):
ACTION IS A LIMITED CIVIL CASE (does not exceed
Amount demanded does not exceed $10,000
$35,000)
CASE NUMBER:
E ACTION
ACTION
Is
exceeds $1 0,000
AN UNLIMITED
CIVIL CASE (exceeds $35,000)
IS RECLASSIFIED by this amended complaint or cross-complaint
CIVSB2416842
E
E from limited to unlimited
from unlimited to limited
1. Plaintiff* (name or names): JPMorgan Chase Bank, N.A.
alleges causes of action against defendant" (name or names): CRYSTAL EXIGA
2. This pleading, including attachments and exhibits, consists ofthe following number of pages: 4
3. a. Each plaintiff named above is a competent adult
except (name): JPMorgan Chase Bank, N.A.
(1) E
E
plaintiff
a corporation qualified to do business in California
(2)
(3) m an unincorporated
other (specify): A
entity (describe):
National Banking Association organized and existing under and by virtue 0fthe laws of the
b. EE
a.
Plaintiff (name).-
has complied with the
United States of America
fictitious business name laws and is doing business under the fictitious name of (specify):
1::
4.
c.
a.
E
b. has complied with
Information about additional plaintiffs
Each defendant named above is a
all licensing requirements as a licensed (specify):
who
natural person
are not competent adults is shown in Attachment 3c.
l: except defendant (name):
(1) Cl
E a business organization, form unknown (1) E
except defendant (name):
E a business organization, form unknown
(2)
(3) E a corporation
an unincorporated entity (describe):
(2)
(3) E a corporation
an unincorporated entity (describe):
(4) D a public entity (describe): (4) E a public entity (describe):
(5) E other (specify): (5) E other (specify):
‘If thws form is used as a cross-oomplaim, plaintiff means cross»complainant and defendam means cross-defendant. Page 1 of 2
F05TaiAc’ijglrgfiigro?lglagirf‘grlnlfase COMPLAINT—ContraCt Code of Civn Procedure, § 425,12
‘mmHllmmulmuumummmmummumm
PLD-C-001
SHORT TITLE: JPMorgan Chase Bank, N.A. v. CRYSTAL EXIGA CASE NUMBER:
4. (Continued)
b. The true names of defendants sued as Does are unknown to plaintiff.
E
(1) Doe defendants (specify Doe numbers):
defendants and acted within the scope of that agency or employment.
were the agents or employees of the named
E
(2) Doe defendants
plaintiff.
(specify Doe numbers): are persons whose capacities are unknown to
Cl Information about additional defendants who are natural persons contained Attachment 4c.
c.
d. E Defendants who are joined under Code of Civil Procedure section
is
382 are (names):
in
5. E] Plaintiff is required to comply with a claims statute, and
a.
b.
E
E
has complied with applicable claims statutes, or
is excused from complying because (specify):
6. E This action is subject to E Civil Code section 1812.10 E Civil Code section 2984.4.
7. This court is the proper court because
a defendant entered into the contract here.
a defendant lived here when the contract was entered into.
a defendant lives here now.
Efiiiéii the contract was to be performed here.
a defendant is a corporation or unincorporated association and its principal place of business is here.
real property that is the subject ofthis action is located here.
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
Common Counts
D Other (specify):
9. E Otherallegations:
10. Plaintiff prays forjudgment for costs of suit; for such relief as is fair, just, and equitable; and for
a. damages of: $7,064.75
on the damages
b.
E interest
(1) according to the proof
c. E E (2)
attorney’s fees
at the rate of (specify): 0.0000 percent per year from (date): October 31, 2023
E E
(1) 0f: $
(2) according to proof.
d. other (specify):
11. D The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers):
Date: May 2, 2024
Anthony DiPiero #268246 >
(TYPE 0R PRINT NAME) /6IGNATURE 0F PLAINTIFF 0R AWORMIW
(If you wish t0 ven'fy this pleadigg, affix a verification.)
PLD»c-oo1 [Rev January 1, 2024] COMPLAINT—Contract Page 2 of 2
1571492001
Document Filed Date
May 24, 2024
Case Filing Date
May 24, 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 (Name, State Bar number, and address): FOR COURT USE ONLY Hunt & Henriques, LLP Donald Sherrill #266038 | | Anthony DiPiero #268246 7017 Realm Drive San José CA 951 19 CA Debt Collection License No. 101 36-99 ELECTRONICALLY FILED I TELEPHONE No: (800) 680-2426 FAX No. (Optional); (408) 362-2299 SUPERIOR COURT OF CALIFORNIA EMAIL ADDRESS (OptionaI); COUNTY OF SAN BERNARDINO ATTORNEY FOR (Name): Plaintiff SAN BERNARDINO DISTRICT SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO 5/24/2024 2:37 PM STREET ADDRESS: 247 West Third Street MAILING ADDRESS: By: Isabel Torres, DEPUTY cm! AND z|P cone; San Bernardino CA 92415-0210 BRANCH NAME: San Bernardino Districl-Civil Division PLAINTIFF: JPMorgan Chase Bank, N.A. DEFENDANT: CRYSTAL EXIGA D DOES 1 To CONTRACT m COMPLAINT E AMENDED COMPLAINT (Number): E CROSS-COMPLAINT E AMENDED CROSS-COMPLAiNT (Number): m Jurisdiction (check all that apply): ACTION IS A LIMITED CIVIL CASE (does not exceed Amount demanded does not exceed $10,000 $35,000) CASE NUMBER: E ACTION ACTION Is exceeds $1 0,000 AN UNLIMITED CIVIL CASE (exceeds $35,000) IS RECLASSIFIED by this amended complaint or cross-complaint CIVSB2416842 E E from limited to unlimited from unlimited to limited 1. Plaintiff* (name or names): JPMorgan Chase Bank, N.A. alleges causes of action against defendant" (name or names): CRYSTAL EXIGA 2. This pleading, including attachments and exhibits, consists ofthe following number of pages: 4 3. a. Each plaintiff named above is a competent adult except (name): JPMorgan Chase Bank, N.A. (1) E E plaintiff a corporation qualified to do business in California (2) (3) m an unincorporated other (specify): A entity (describe): National Banking Association organized and existing under and by virtue 0fthe laws of the b. EE a. Plaintiff (name).- has complied with the United States of America fictitious business name laws and is doing business under the fictitious name of (specify): 1:: 4. c. a. E b. has complied with Information about additional plaintiffs Each defendant named above is a all licensing requirements as a licensed (specify): who natural person are not competent adults is shown in Attachment 3c. l: except defendant (name): (1) Cl E a business organization, form unknown (1) E except defendant (name): E a business organization, form unknown (2) (3) E a corporation an unincorporated entity (describe): (2) (3) E a corporation an unincorporated entity (describe): (4) D a public entity (describe): (4) E a public entity (describe): (5) E other (specify): (5) E other (specify): ‘If thws form is used as a cross-oomplaim, plaintiff means cross»complainant and defendam means cross-defendant. Page 1 of 2 F05TaiAc’ijglrgfiigro?lglagirf‘grlnlfase COMPLAINT—ContraCt Code of Civn Procedure, § 425,12 ‘mmHllmmulmuumummmmummumm PLD-C-001 SHORT TITLE: JPMorgan Chase Bank, N.A. v. CRYSTAL EXIGA CASE NUMBER: 4. (Continued) b. The true names of defendants sued as Does are unknown to plaintiff. E (1) Doe defendants (specify Doe numbers): defendants and acted within the scope of that agency or employment. were the agents or employees of the named E (2) Doe defendants plaintiff. (specify Doe numbers): are persons whose capacities are unknown to Cl Information about additional defendants who are natural persons contained Attachment 4c. c. d. E Defendants who are joined under Code of Civil Procedure section is 382 are (names): in 5. E] Plaintiff is required to comply with a claims statute, and a. b. E E has complied with applicable claims statutes, or is excused from complying because (specify): 6. E This action is subject to E Civil Code section 1812.10 E Civil Code section 2984.4. 7. This court is the proper court because a defendant entered into the contract here. a defendant lived here when the contract was entered into. a defendant lives here now. Efiiiéii the contract was to be performed here. a defendant is a corporation or unincorporated association and its principal place of business is here. real property that is the subject ofthis action is located here. 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 Common Counts D Other (specify): 9. E Otherallegations: 10. Plaintiff prays forjudgment for costs of suit; for such relief as is fair, just, and equitable; and for a. damages of: $7,064.75 on the damages b. E interest (1) according to the proof c. E E (2) attorney’s fees at the rate of (specify): 0.0000 percent per year from (date): October 31, 2023 E E (1) 0f: $ (2) according to proof. d. other (specify): 11. D The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers): Date: May 2, 2024 Anthony DiPiero #268246 > (TYPE 0R PRINT NAME) /6IGNATURE 0F PLAINTIFF 0R AWORMIW (If you wish t0 ven'fy this pleadigg, affix a verification.) PLD»c-oo1 [Rev January 1, 2024] COMPLAINT—Contract Page 2 of 2 1571492001