On May 24, 2024 a
Complaint,Petition
was filed
involving a dispute between
Jpmorgan Chase Bank N.A.,
and
Williams-Edwards, Sherme,
for Rule 3.740 Collections $10,000 or Less Limited
in the District Court of San Bernardino County.
Preview
PLD-C-001
ATTORNEY 0R PARTY WITHOUT ATTORNEY (Name, Stare Bar number, and address): FOR COURT USE ONLY
Hunt 8. Henriques. LLP
Donald Sherrill #266038 | |
VWliam Bliss #341046
7017 Realm Drive
San José CA 951 19
CA Debt Collection License No. 10136-99
TELEPHONE N0: (800) 680-2426 FAX N0. (Optional): (408) 362-2299
E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Name): Plaintiff ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO COUNTY OF SAN BERNARDINO
STREET ADDRESS: 247 West Third Street SAN BERNARDINO DISTRICT
MAILING ADDRESS:
CITY AND ZIP CODE; San Bernardino CA 92415-0210 5/24/2024 2:24 PM
BRANCH NAME: San Bernardino Distfict-Civil Division
By: Maryann White-Penright, DEPUTY
PLAINTIFF: JPMorgan Chase Bank, N.A.
DEFENDANT: SHERME WlLLlAMS-EDWARDS
E Does 1 To___
CONTRACT
m COMPLAINT E AMENDED COMPLAINT (Number):
E CRoss-COMPLAINT D AMENDED CRoss-COMPLAINT (Number):
m
Jurisdiction (check aII that apply):
m
ACTION Is A LIMITED CIVIL CASE (does not exceed
Amount demanded does not exceed $10,000
$35,000)
CASE NUMBER:
E
E ACTION
ACTION
Is AN UNLIMITED
exceeds $10,000
CIVIL
(exceeds $35,000) CASE
ls RECLASSIFIED by this amended complaint or cross-complaint
CIVSB2416887
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): SHERME WILLIAMS-EDWARDS
2. This pleading, including attachments and exhibits, consists of the following number of pages: 4
Each named above
3. a.
m E plaintiff
except plaintiff
is a competent adult
(name): JPMorgan Chase Bank. N.A.
a corporation qualified to do business
E
m
(1)
(2)
(3)
an unincorporated
other (specify): A
entity (describe):
in California
National Banking Association organized and existing under and by virtue of the 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):
c.
b.
[j
E has complied with
Information about additional plaintiffs
all licensing requirements as a licensed (specify):
who are not competent adults is shown in Attachment 3c.
Each defendant named above is a
4. a.
E D except defendant (name):
natural person
unknown E
except defendant (name):
a business organization, form unknown
E
E
(1)
(2)
(3)
a business organization, form
a corporation
an unincorporated entity (describe):
(1)
(2)
(3)
[j
E a corporation
an unincorporated entity (describe):
E (4) a public entity (describe): (4) E a public entity (describe):
E (5) other (specify): (5) D other (specify):
'lf this form is used as a cross-complaint. plaintiff means cross-complainant and defendant means cross-defendant. Page 1 of 2
FOSTdéeaplrgfiigro?pcnafiggr'ntiJase COMPLAINT—Contra“ Code or cavn Procedure. § 425.12
ImmmuumImlmmmmmmmnmnmlmuu
PLD-C-001
SHORT TITLE: JPMorgan Chase Bank, N.A. v. SHERME WILLIAMS-EDWARDS CASE NUMBER:
4. (Continued)
b. The true names of defendants sued as Does are unknown to plaintiff.
(1) E Doe defendants (specify Doe numbers):
defendants and acted within the scope of that agency or employment.
were the agents or employees of the named
(2) E] Doe defendants (specify Doe numbers): are persons whose capacities are unknown to
plaintiff.
c.
d.
E
E Information about additional defendants
Defendants who are joined under Code
who are natural persons
of Civil
is
Procedure section 382 are (names):
contained in Attachment 4c.
5. E Plaintiff is
a. E]
required to comply with a claims statute, and
has complied with applicable claims statutes, or
b. E] 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. a defendant entered into the contract here.
a defendant lived here when the contract was entered into.
a defendant lives here now.
Eifiiéim 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 of this 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
E] Common Counts
E Other (specify):
9. E Otherallegations:
10.
a. m
Plaintiff
m
prays forjudgment
damages of: $7,824.77
on the damages
for costs of suit; for such relief as is fair, just, and equitable; and for
b. interest
(1) E
m according to the proof
c. D (2)
E
attorney’s fees
at the rate of (specify): 0.0000 percent per year from (date): October 31, 2023
d. E
(1)
(2) E
other (specify):
of: $
according to proof.
11. E The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers):
Date: April 23, 2024
William Bliss #341046
(TYPE 0R PRINT NAME)
> /
(SIGNATURE 0F PLAINTIFFOR ATrORNEY)
(If you wish to ven'fy this pleading, affix a verification.)
PLD-c—om [Rev January 1. 2024] COMPLAINT—Contract Page 2 or 2
1569191001
Category
Rule 3.740 Collections $10,000 or Less Limited
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PLD-C-001 ATTORNEY 0R PARTY WITHOUT ATTORNEY (Name, Stare Bar number, and address): FOR COURT USE ONLY Hunt 8. Henriques. LLP Donald Sherrill #266038 | | VWliam Bliss #341046 7017 Realm Drive San José CA 951 19 CA Debt Collection License No. 10136-99 TELEPHONE N0: (800) 680-2426 FAX N0. (Optional): (408) 362-2299 E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name): Plaintiff ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO COUNTY OF SAN BERNARDINO STREET ADDRESS: 247 West Third Street SAN BERNARDINO DISTRICT MAILING ADDRESS: CITY AND ZIP CODE; San Bernardino CA 92415-0210 5/24/2024 2:24 PM BRANCH NAME: San Bernardino Distfict-Civil Division By: Maryann White-Penright, DEPUTY PLAINTIFF: JPMorgan Chase Bank, N.A. DEFENDANT: SHERME WlLLlAMS-EDWARDS E Does 1 To___ CONTRACT m COMPLAINT E AMENDED COMPLAINT (Number): E CRoss-COMPLAINT D AMENDED CRoss-COMPLAINT (Number): m Jurisdiction (check aII that apply): m ACTION Is A LIMITED CIVIL CASE (does not exceed Amount demanded does not exceed $10,000 $35,000) CASE NUMBER: E E ACTION ACTION Is AN UNLIMITED exceeds $10,000 CIVIL (exceeds $35,000) CASE ls RECLASSIFIED by this amended complaint or cross-complaint CIVSB2416887 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): SHERME WILLIAMS-EDWARDS 2. This pleading, including attachments and exhibits, consists of the following number of pages: 4 Each named above 3. a. m E plaintiff except plaintiff is a competent adult (name): JPMorgan Chase Bank. N.A. a corporation qualified to do business E m (1) (2) (3) an unincorporated other (specify): A entity (describe): in California National Banking Association organized and existing under and by virtue of the 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): c. b. [j E has complied with Information about additional plaintiffs all licensing requirements as a licensed (specify): who are not competent adults is shown in Attachment 3c. Each defendant named above is a 4. a. E D except defendant (name): natural person unknown E except defendant (name): a business organization, form unknown E E (1) (2) (3) a business organization, form a corporation an unincorporated entity (describe): (1) (2) (3) [j E a corporation an unincorporated entity (describe): E (4) a public entity (describe): (4) E a public entity (describe): E (5) other (specify): (5) D other (specify): 'lf this form is used as a cross-complaint. plaintiff means cross-complainant and defendant means cross-defendant. Page 1 of 2 FOSTdéeaplrgfiigro?pcnafiggr'ntiJase COMPLAINT—Contra“ Code or cavn Procedure. § 425.12 ImmmuumImlmmmmmmmnmnmlmuu PLD-C-001 SHORT TITLE: JPMorgan Chase Bank, N.A. v. SHERME WILLIAMS-EDWARDS CASE NUMBER: 4. (Continued) b. The true names of defendants sued as Does are unknown to plaintiff. (1) E Doe defendants (specify Doe numbers): defendants and acted within the scope of that agency or employment. were the agents or employees of the named (2) E] Doe defendants (specify Doe numbers): are persons whose capacities are unknown to plaintiff. c. d. E E Information about additional defendants Defendants who are joined under Code who are natural persons of Civil is Procedure section 382 are (names): contained in Attachment 4c. 5. E Plaintiff is a. E] required to comply with a claims statute, and has complied with applicable claims statutes, or b. E] 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. a defendant entered into the contract here. a defendant lived here when the contract was entered into. a defendant lives here now. Eifiiéim 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 of this 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 E] Common Counts E Other (specify): 9. E Otherallegations: 10. a. m Plaintiff m prays forjudgment damages of: $7,824.77 on the damages for costs of suit; for such relief as is fair, just, and equitable; and for b. interest (1) E m according to the proof c. D (2) E attorney’s fees at the rate of (specify): 0.0000 percent per year from (date): October 31, 2023 d. E (1) (2) E other (specify): of: $ according to proof. 11. E The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers): Date: April 23, 2024 William Bliss #341046 (TYPE 0R PRINT NAME) > / (SIGNATURE 0F PLAINTIFFOR ATrORNEY) (If you wish to ven'fy this pleading, affix a verification.) PLD-c—om [Rev January 1. 2024] COMPLAINT—Contract Page 2 or 2 1569191001