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Donald Sherrill #266038 ELECTRONICALLY FILED
Brian Langedyk #337250 SUPERIOR COURT OF CALIFORNIA
HUNT & HENRIQUES, LLP COUNTY OF SAN BERNARDINO
7017 Realm Dr., San Jose’ CA 951 19 SAN BERNARDINO DISTRICT
Telephone: (800) 680-2426 5/24/2024 3:05 PM
Facsimile: (408) 362-2299
Attorneys for Plaintiff By: Isabel Torres, DEPUTY
File no. 1563668001
CA Debt Collection License No. 10136-99
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
San Bernardino District—Civil Division
10
Portfolio Recovery Associates, LLC Case N0.CIVSB2416917
11 Plaintiff,
COMPLAINT FOR:
12
vs. (1) Account Stated
13 (2) Open Book Account
LLP
95119
680-2426
362-2299
14 PRAYER AMOUNT: $4,761 .96
DR.
HENRIQUES,
CALIFORNIA (800)
15
DAVID JONES LIMITED CIVIL
(408)
REALM
Amount demanded does not exceed $10,000
l6
Defendant(s).
& 7017
JOSE TELEPHONE:
FACSIMILE:
17
HUNT SAN
18
Plaintiff, Portfolio Recovery Associates, LLC, (“Plaintiff”), alleges:
19
1. Plaintiff is a limited liability company.
20
2. This'court is the proper coun because Plaintiff is informed and believes that
21
Defendant, DAVID JONES (“Defendant”), is a resident of SAN BERNARDINO County, State
22
of California.
23
3. At all times herein mentioned, Defendants, and each of them, were the principals,
24
agents, employers, employees, masters, or servants of each of their co—defendants and ratified,
25
adopted or approved the acts or omissions alleged herein, and each defendant, in doing the things
26
alleged, were acting in the course and scope of said authority of such agents, servants, and
27
employees.
28
COMPLAINT
Page l
A 1 1563668001
4. This suit concerns a credit account that was purchased by Plaintiff after 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)(1)-(9):
5. Plaintiff is a debt buyer.
6. CITIBANK, N.A. issued a credit account to Defendant. Defendant used, or
authorized the use of, the credit account to 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 right, title and
10 interest in the credit account.
11 7. Plaintiff is the sole owner of the credit account at issue, or has authority to assert
12 the rights of all owners of the debt.
13 8. The balance at charge-off was $4,761.96. Plaintiff is not seeking to recover any
LLP
95119
680-2426
362—2299
14 post charge-off fees or interest.
DR.
HENRIQUES,
CALIFORNIA (800)
15 9. The date of last payment on the credit account was on December 9, 2022.
(408)
REALM
16 10. The name 0f the charge-off creditor is CITIBANK, N.A. and the account number
7017
& JOSE TELEPHONE: FAcsnmLs:
HUNT SAN
17 of the charge-off creditor ended in 2129. An address CITIBANK, N.A. maintained at the time of
18 charge-off was:
19 5800 SOUTH CORPORATE PLACE
20 SIOUX FALLS SD 57108.
21 11. The name and last known address that the charge-off creditor had for Defendant
22 is:
DAVID JONES
23
16092 VILLAGE DR
24
VICTORVILLE CA 92394-1560.
25
12. The subject credit account has been purchased by the following entity after
26
charge-off: Portfolio Recovery Associates, LLC who maintains an address at 120 Corporate
27
28
COMPLAINT
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A 1 1563668001
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Donald Sherrill #266038 ELECTRONICALLY FILED Brian Langedyk #337250 SUPERIOR COURT OF CALIFORNIA HUNT & HENRIQUES, LLP COUNTY OF SAN BERNARDINO 7017 Realm Dr., San Jose’ CA 951 19 SAN BERNARDINO DISTRICT Telephone: (800) 680-2426 5/24/2024 3:05 PM Facsimile: (408) 362-2299 Attorneys for Plaintiff By: Isabel Torres, DEPUTY File no. 1563668001 CA Debt Collection License No. 10136-99 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO San Bernardino District—Civil Division 10 Portfolio Recovery Associates, LLC Case N0.CIVSB2416917 11 Plaintiff, COMPLAINT FOR: 12 vs. (1) Account Stated 13 (2) Open Book Account LLP 95119 680-2426 362-2299 14 PRAYER AMOUNT: $4,761 .96 DR. HENRIQUES, CALIFORNIA (800) 15 DAVID JONES LIMITED CIVIL (408) REALM Amount demanded does not exceed $10,000 l6 Defendant(s). & 7017 JOSE TELEPHONE: FACSIMILE: 17 HUNT SAN 18 Plaintiff, Portfolio Recovery Associates, LLC, (“Plaintiff”), alleges: 19 1. Plaintiff is a limited liability company. 20 2. This'court is the proper coun because Plaintiff is informed and believes that 21 Defendant, DAVID JONES (“Defendant”), is a resident of SAN BERNARDINO County, State 22 of California. 23 3. At all times herein mentioned, Defendants, and each of them, were the principals, 24 agents, employers, employees, masters, or servants of each of their co—defendants and ratified, 25 adopted or approved the acts or omissions alleged herein, and each defendant, in doing the things 26 alleged, were acting in the course and scope of said authority of such agents, servants, and 27 employees. 28 COMPLAINT Page l A 1 1563668001 4. This suit concerns a credit account that was purchased by Plaintiff after 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)(1)-(9): 5. Plaintiff is a debt buyer. 6. CITIBANK, N.A. issued a credit account to Defendant. Defendant used, or authorized the use of, the credit account to 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 right, title and 10 interest in the credit account. 11 7. Plaintiff is the sole owner of the credit account at issue, or has authority to assert 12 the rights of all owners of the debt. 13 8. The balance at charge-off was $4,761.96. Plaintiff is not seeking to recover any LLP 95119 680-2426 362—2299 14 post charge-off fees or interest. DR. HENRIQUES, CALIFORNIA (800) 15 9. The date of last payment on the credit account was on December 9, 2022. (408) REALM 16 10. The name 0f the charge-off creditor is CITIBANK, N.A. and the account number 7017 & JOSE TELEPHONE: FAcsnmLs: HUNT SAN 17 of the charge-off creditor ended in 2129. An address CITIBANK, N.A. maintained at the time of 18 charge-off was: 19 5800 SOUTH CORPORATE PLACE 20 SIOUX FALLS SD 57108. 21 11. The name and last known address that the charge-off creditor had for Defendant 22 is: DAVID JONES 23 16092 VILLAGE DR 24 VICTORVILLE CA 92394-1560. 25 12. The subject credit account has been purchased by the following entity after 26 charge-off: Portfolio Recovery Associates, LLC who maintains an address at 120 Corporate 27 28 COMPLAINT Page 2 A 1 1563668001