On May 24, 2024 a
Complaint,Petition
was filed
involving a dispute between
Unifund Ccr, Llc,
and
Escutia, Alena M,
for Rule 3.740 Collections -Reduced Filing Fee Limited
in the District Court of San Bernardino County.
Preview
ELECTRONICALLY FILED
SUPERIOR COURT OF CALI ORNIA
COUNTY OF SAN BERNAR INO
1601007 SAN BERNARDINO DISTRIC T
5/24/2024 3:22 PM
GURSTEL LAW FIRM P.C. By: Fabiola Moreno, DEPUTY
GurstelLaw Firm P.C.’s California Debt Collection License: 10361-99.
Kimberlee Tsai (SBN # 227426)
Brianna Elmassian (SBN# 329673)
Stella Park (SBN# 3 10445)
A (SBN# 324544)
Spencer Penuela
Anna Karkoon (SBN# 295797)
Ann Doan (SBN# 297543)
9320 East Raintree Drive, Scottsdale, AZ 85260
Telephone: (877) 344-4002
Fax: (877) 750-6335
\OOONONUI
info@gurstel.com
Attorneys for Plaintiff,
Unifund CCR, LLC
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11
SAN BERNARDINO COUNTY - SAN BERNARDINO COURT
12
Unifund CCR, LLC Case N0. CIVSBZ41 6928
13 Plaintiff,
14
COMPLAINT FOR MONEY DUE ON
VS. ACCOUNT STATED; OPEN BOOK
15 ACCOUNT
Alena M Escutia
16
Defendant.
17
18 Unifund CCR, LLC(“Plaintiff”) alleges causes 0f action against Alena M Escutia
19 ("Defendant") as follows:
20
ALLEGATIONS COMMON TO ALL CAUSES OF ACTION
21
1. Plaintiff is a debt buyer.
22
23
24
25
26
27
28
Unifund CCR, LLC vs. Alena M Escutia/ Case No.2
2. Plaintiffbelieves that, 0n 0r about May 2 1 202 1 Citibank, NA. provided Defendant with
, ,
a credit account ("Account"), and granted use privileges 0n the same. Defendant used the
Account t0 make purchases and/or take cash advances and/or make balance transfers, each
A
time reaffirming Defendant's agreement t0 repay Citibank, NA. and its successors in
interest, for the amount 0f the purchase and/or cash advances and/or balance transfers.
\OOONONUI
3. Plaintiff is the sole owner 0f the debt at issue.
4. The debt balance at charge-offwas $2,286.83. $0.00 in post charge-off fees and $0.00 in
post charge-off interest have been imposed since the time 0f charge-off.
10
11
5. The date 0f last payment 0n the Account was 0n November 3, 2021.
12 6. The charge-off creditor at the time 0f charge-off was Citibank, NA. (“Charge-Off
13
Creditor”), whose address at said time was 5800 South Corporate Place, Sioux Falls, SD
14
57108 . Charge-Off Creditor’s account number associated with the debt is
15
************9670_
16
7. Defendant’s name and address as it appeared in the Charge-Off Creditor‘s records prior t0
17
18 the sale 0fthe Account t0 Plaintiffis Alena M Escutia, 5003 WIMMER AVE, BALDWIN
19
PARK, CA 91706-1654.
20
8. Prior t0 the commencement 0f this action, the Account was assigned 0r otherwise
21
transferred t0 Plaintiff. Plaintiff, is the present holder and sole owner 0f the Account.
22
23 Plaintiff‘s address is 10625 Techwoods Circle, Cincinnati, OH 45242-2846. The names
24 and address 0f all persons 0r entities that purchased the debt after charge-off are:
25
(A) Unifund CCR, LLC, 10625 Techwoods Circle Cincinnati, OH
26
45242-2846
27
28
Unifund CCR, LLC vs. Alena M Escutia/ Case No.2
Document Filed Date
May 24, 2024
Case Filing Date
May 24, 2024
Category
Rule 3.740 Collections -Reduced Filing Fee Limited
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Preview
ELECTRONICALLY FILED SUPERIOR COURT OF CALI ORNIA COUNTY OF SAN BERNAR INO 1601007 SAN BERNARDINO DISTRIC T 5/24/2024 3:22 PM GURSTEL LAW FIRM P.C. By: Fabiola Moreno, DEPUTY GurstelLaw Firm P.C.’s California Debt Collection License: 10361-99. Kimberlee Tsai (SBN # 227426) Brianna Elmassian (SBN# 329673) Stella Park (SBN# 3 10445) A (SBN# 324544) Spencer Penuela Anna Karkoon (SBN# 295797) Ann Doan (SBN# 297543) 9320 East Raintree Drive, Scottsdale, AZ 85260 Telephone: (877) 344-4002 Fax: (877) 750-6335 \OOONONUI info@gurstel.com Attorneys for Plaintiff, Unifund CCR, LLC 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 SAN BERNARDINO COUNTY - SAN BERNARDINO COURT 12 Unifund CCR, LLC Case N0. CIVSBZ41 6928 13 Plaintiff, 14 COMPLAINT FOR MONEY DUE ON VS. ACCOUNT STATED; OPEN BOOK 15 ACCOUNT Alena M Escutia 16 Defendant. 17 18 Unifund CCR, LLC(“Plaintiff”) alleges causes 0f action against Alena M Escutia 19 ("Defendant") as follows: 20 ALLEGATIONS COMMON TO ALL CAUSES OF ACTION 21 1. Plaintiff is a debt buyer. 22 23 24 25 26 27 28 Unifund CCR, LLC vs. Alena M Escutia/ Case No.2 2. Plaintiffbelieves that, 0n 0r about May 2 1 202 1 Citibank, NA. provided Defendant with , , a credit account ("Account"), and granted use privileges 0n the same. Defendant used the Account t0 make purchases and/or take cash advances and/or make balance transfers, each A time reaffirming Defendant's agreement t0 repay Citibank, NA. and its successors in interest, for the amount 0f the purchase and/or cash advances and/or balance transfers. \OOONONUI 3. Plaintiff is the sole owner 0f the debt at issue. 4. The debt balance at charge-offwas $2,286.83. $0.00 in post charge-off fees and $0.00 in post charge-off interest have been imposed since the time 0f charge-off. 10 11 5. The date 0f last payment 0n the Account was 0n November 3, 2021. 12 6. The charge-off creditor at the time 0f charge-off was Citibank, NA. (“Charge-Off 13 Creditor”), whose address at said time was 5800 South Corporate Place, Sioux Falls, SD 14 57108 . Charge-Off Creditor’s account number associated with the debt is 15 ************9670_ 16 7. Defendant’s name and address as it appeared in the Charge-Off Creditor‘s records prior t0 17 18 the sale 0fthe Account t0 Plaintiffis Alena M Escutia, 5003 WIMMER AVE, BALDWIN 19 PARK, CA 91706-1654. 20 8. Prior t0 the commencement 0f this action, the Account was assigned 0r otherwise 21 transferred t0 Plaintiff. Plaintiff, is the present holder and sole owner 0f the Account. 22 23 Plaintiff‘s address is 10625 Techwoods Circle, Cincinnati, OH 45242-2846. The names 24 and address 0f all persons 0r entities that purchased the debt after charge-off are: 25 (A) Unifund CCR, LLC, 10625 Techwoods Circle Cincinnati, OH 26 45242-2846 27 28 Unifund CCR, LLC vs. Alena M Escutia/ Case No.2