Preview
ELECTRONICALLY FILED
Donald #266038
Sherrill SUPERIOR COURT OF CALIFORNIA
Alexander Balzer Carr #338024 COUNTY OF SAN BERNARDINO
HUNT & HENRIQUES, LLP SAN BERNARDINO DISTRICT
7017 Realm Dr., San Jose’ CA 951 19 5/24/2024 2:41 PM
Telephone: (800) 680-2426
Facsimile: (408) 362-2299 By: Isabel Torres, DEPUTY
Attorneys for Plaintiff
File no. 1554392001
CA Debt Collection License No. 101 36-99
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
San Bernardino District-Civil Division
10
Portfolio Recovery Associates, LLC Case N0. CIVSB2416850
11 Plaintiff,
COMPLAINT FOR:
12
vs. (1) Account Stated
13 (2) Open Book Account
LLP
95119
680-2426
362-2299
PRAYER AMOUNT: $3,590.01
DR.
HENRIQUEs,
CALIFORNIA (800)
15
DEANA JOVEN LIMITED CIVIL
(408)
REALM
Amount demanded does not exceed $10,000
16
7017
Defendant(s).
& 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 court because Plaintiff is informed and believes that
21
Defendant, DEANA JOVEN (“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 1
A 1 1554392001
4. This suit concerns a credit account that was purchased by Plaintiff after January 1,
2014 and, therefore, is subject t0 California Civil Code § 1788.50, et seq.
COMPLIANCE WITH CIVIL CODE § 1788.50, et seq.
Pursuant t0 California Civil Code § 1788.58(a)(1)—(9):
5. Plaintiff is a debt buyer.
6. CITIBANK, N.A4 issued a credit account to Defendant. Defendant used, 0r
authorized the use 0f, 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 right, title and
10 interest in the credit account.
H 7. Plaintiff is the sole owner of the credit account at issue, 0r has authority to assert
the rights of all owners 0f the debt.
8. The balance at charge-off was $3,590.01. Plaintiff is not seeking to recover any
LLP
95119
680—2426
362—2299
post charge-off fees or interest.
DR.
HENRIQUES,
CALIFORNIA (800)
15 9. The date 0f last payment 0n the credit account was on June 6, 2022.
(408)
REALM
16 10. The name of the charge-off creditor is CITIBANK, N.A. and the account number
7017
&; JOSE TELEPHONE:
FACSIMILE:
SAN
17 of the charge-off creditor ended in 2632. An address CITIBANK, N.A. maintained at the time of
HUNT
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:
DEANA JOVEN
23
3077 CANYON VISTA DR
24
COLTON CA 92324-9791.
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
A1 1554392001
Preview
ELECTRONICALLY FILED Donald #266038 Sherrill SUPERIOR COURT OF CALIFORNIA Alexander Balzer Carr #338024 COUNTY OF SAN BERNARDINO HUNT & HENRIQUES, LLP SAN BERNARDINO DISTRICT 7017 Realm Dr., San Jose’ CA 951 19 5/24/2024 2:41 PM Telephone: (800) 680-2426 Facsimile: (408) 362-2299 By: Isabel Torres, DEPUTY Attorneys for Plaintiff File no. 1554392001 CA Debt Collection License No. 101 36-99 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO San Bernardino District-Civil Division 10 Portfolio Recovery Associates, LLC Case N0. CIVSB2416850 11 Plaintiff, COMPLAINT FOR: 12 vs. (1) Account Stated 13 (2) Open Book Account LLP 95119 680-2426 362-2299 PRAYER AMOUNT: $3,590.01 DR. HENRIQUEs, CALIFORNIA (800) 15 DEANA JOVEN LIMITED CIVIL (408) REALM Amount demanded does not exceed $10,000 16 7017 Defendant(s). & 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 court because Plaintiff is informed and believes that 21 Defendant, DEANA JOVEN (“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 1 A 1 1554392001 4. This suit concerns a credit account that was purchased by Plaintiff after January 1, 2014 and, therefore, is subject t0 California Civil Code § 1788.50, et seq. COMPLIANCE WITH CIVIL CODE § 1788.50, et seq. Pursuant t0 California Civil Code § 1788.58(a)(1)—(9): 5. Plaintiff is a debt buyer. 6. CITIBANK, N.A4 issued a credit account to Defendant. Defendant used, 0r authorized the use 0f, 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 right, title and 10 interest in the credit account. H 7. Plaintiff is the sole owner of the credit account at issue, 0r has authority to assert the rights of all owners 0f the debt. 8. The balance at charge-off was $3,590.01. Plaintiff is not seeking to recover any LLP 95119 680—2426 362—2299 post charge-off fees or interest. DR. HENRIQUES, CALIFORNIA (800) 15 9. The date 0f last payment 0n the credit account was on June 6, 2022. (408) REALM 16 10. The name of the charge-off creditor is CITIBANK, N.A. and the account number 7017 &; JOSE TELEPHONE: FACSIMILE: SAN 17 of the charge-off creditor ended in 2632. An address CITIBANK, N.A. maintained at the time of HUNT 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: DEANA JOVEN 23 3077 CANYON VISTA DR 24 COLTON CA 92324-9791. 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 A1 1554392001