On May 24, 2024 a
Complaint,Petition
was filed
involving a dispute between
Jpmorgan Chase Bank, N.A.,
and
Ruiz, Leticia,
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 MTHOUT ATTORNEY (Name, Stare Barnumber, 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 N0. 101 36-99
ELECTRONICALLY FILED
TELEPHONE No: (800) 680-2426 FAX No. (408) 362-2299
E—MAIL ADDRESS (Optimal).-
(Optional):
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
ATrORNEY FOR Plaintiff
(Name):
SAN BERNARDINO DISTRICT
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
STREET ADDRESS: 247 West Third Street
5/24/2024 2:39 PM
MAILING ADDRESS:
CITY AND ZIP CODE: San Bernardino CA 92415-0210
By: Isabel Torres, DEPUTY
BRANCH NAME? San Bernardino District-Civil Division
PLAINTIFF: JPMorgan Chase Bank, N,A.
DEFENDANT: LETICIA RUIZ
E Does 1 To
CONTRACT
m COMPLAINT E AMENDED COMPLAINT (Number):
E CRoss-COMPLAINT D AMENDED CRoss-COMPLAINT (Number):
E
Jurisdiction (check
ACTION Is A LIMITED
Amount demanded
all that apply):
CIVIL CASE (does not exceed $35,000)
does not exceed $10,000
CASE NUMBER:
E ACTION
ACTION
IS AN UNLIMITED
exceeds $1 0,000
CIVIL CASE (exceeds $35,000)
RECLASSIFIED by this amended complaint or cross-complaint
CIVSB2416898
E
E
IS
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): LETICIA RUIZ
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 t0 do business in California
(2)
(3) m an unincorporated
other (specify): A
entity (describe):
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 0f America
fictitious business name laws and is doing business under the fictitious name of (specify):
c. EE
b. has complied with
Information about additional plaintiffs
all licensing requirements as a licensed (specify):
who are not competent adults is shown in Attachment 30.
4. a.
E E
Each defendant named above is a
except defendant (name):
natural person
unknown E
except defendant (name):
a business organization, form unknown
E (1)
(2)
(3)
a business organization, form
a corporation
an unincorporated entity (describe):
(1)
(2)
(3)
E
D a corporation
an unincorporated entity (describe):
D (4) a public entity (describe): (4) E a public entity (describe):
E (5) other (specify): (5) E other (specify):
43]
‘If this form is used as a cross-complaint, plaintiff means cross—complainant and defendant means cross—defendant. Page 1 of 2
FDSTdQEaplrgéeudn2%r0?%uaolirf1§rlnLilase C0MPLAINT—ContraCt Code of Civil Procedure, § 425.12
||||I||HlllIHIHIIIINIIIHHI||?||WIHIHIIIHIIHIHIIHIH
1571393001
PLD-C-001
SHORT TlTLEi JPMorgan Chase Bank, N.A. v. LETICIA RUIZ CASE NUMBER
4. (Continued)
b. The true names of defendants sued as Does are unknown to plaintiff.
(1) D 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) El Doe defendants (specify Doe numbers): are persons whose capacities are unknown to
plaintiff.
c.
d.
D
D 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. D Plaintiff is
a. |:| has comp|ied
required to comply with a claims statute,
with applicable claims statutes, or
and
b. D 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.T his 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.
Eifiiiia 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):
E Breach of Contract
‘\.
m Common Counts
:I Other (specify):
9. Cl Otherallegations:
10.
a. E
Plaintiff prays forjudgment
damages 0f:
for
$8,1 18.77
on the damages
costs of suit; for such relief as is fair, just, and equitable; and for
b.
E interest
(1) according to the proof
0.0000 percent per year from (date): December 31, 2023
c, E E (2)
attorney’s fees
at the rate of (specify):
D D
(1) of: $
(2) according to proof.
d. other (specify):
11. E The paragraphs ofthis pleading alleged on information and belief are as follows (specify paragraph numbers):
Date: May 2, 2024
Anthony DiPiero #268246 b
(TYPE 0R PRINT NAME) (SIGNATURE 0F PLAINTIFF 0R AWORNEY)
(If you Wish to ven'fy this pleading, affix a verification.)
PLoic-om [Rev January 1, 2024] COMPLAINT—Contract Page 2 or 2
1571393001
Document Filed Date
May 24, 2024
Case Filing Date
May 24, 2024
Category
Rule 3.740 Collections $10,000 or Less Limited
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Preview
‘ PLD-C-001 ATTORNEY 0R PARTY MTHOUT ATTORNEY (Name, Stare Barnumber, 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 N0. 101 36-99 ELECTRONICALLY FILED TELEPHONE No: (800) 680-2426 FAX No. (408) 362-2299 E—MAIL ADDRESS (Optimal).- (Optional): SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO ATrORNEY FOR Plaintiff (Name): SAN BERNARDINO DISTRICT SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO STREET ADDRESS: 247 West Third Street 5/24/2024 2:39 PM MAILING ADDRESS: CITY AND ZIP CODE: San Bernardino CA 92415-0210 By: Isabel Torres, DEPUTY BRANCH NAME? San Bernardino District-Civil Division PLAINTIFF: JPMorgan Chase Bank, N,A. DEFENDANT: LETICIA RUIZ E Does 1 To CONTRACT m COMPLAINT E AMENDED COMPLAINT (Number): E CRoss-COMPLAINT D AMENDED CRoss-COMPLAINT (Number): E Jurisdiction (check ACTION Is A LIMITED Amount demanded all that apply): CIVIL CASE (does not exceed $35,000) does not exceed $10,000 CASE NUMBER: E ACTION ACTION IS AN UNLIMITED exceeds $1 0,000 CIVIL CASE (exceeds $35,000) RECLASSIFIED by this amended complaint or cross-complaint CIVSB2416898 E E IS 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): LETICIA RUIZ 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 t0 do business in California (2) (3) m an unincorporated other (specify): A entity (describe): 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 0f America fictitious business name laws and is doing business under the fictitious name of (specify): c. EE b. has complied with Information about additional plaintiffs all licensing requirements as a licensed (specify): who are not competent adults is shown in Attachment 30. 4. a. E E Each defendant named above is a except defendant (name): natural person unknown E except defendant (name): a business organization, form unknown E (1) (2) (3) a business organization, form a corporation an unincorporated entity (describe): (1) (2) (3) E D a corporation an unincorporated entity (describe): D (4) a public entity (describe): (4) E a public entity (describe): E (5) other (specify): (5) E other (specify): 43] ‘If this form is used as a cross-complaint, plaintiff means cross—complainant and defendant means cross—defendant. Page 1 of 2 FDSTdQEaplrgéeudn2%r0?%uaolirf1§rlnLilase C0MPLAINT—ContraCt Code of Civil Procedure, § 425.12 ||||I||HlllIHIHIIIINIIIHHI||?||WIHIHIIIHIIHIHIIHIH 1571393001 PLD-C-001 SHORT TlTLEi JPMorgan Chase Bank, N.A. v. LETICIA RUIZ CASE NUMBER 4. (Continued) b. The true names of defendants sued as Does are unknown to plaintiff. (1) D 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) El Doe defendants (specify Doe numbers): are persons whose capacities are unknown to plaintiff. c. d. D D 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. D Plaintiff is a. |:| has comp|ied required to comply with a claims statute, with applicable claims statutes, or and b. D 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.T his 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. Eifiiiia 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): E Breach of Contract ‘\. m Common Counts :I Other (specify): 9. Cl Otherallegations: 10. a. E Plaintiff prays forjudgment damages 0f: for $8,1 18.77 on the damages costs of suit; for such relief as is fair, just, and equitable; and for b. E interest (1) according to the proof 0.0000 percent per year from (date): December 31, 2023 c, E E (2) attorney’s fees at the rate of (specify): D D (1) of: $ (2) according to proof. d. other (specify): 11. E The paragraphs ofthis pleading alleged on information and belief are as follows (specify paragraph numbers): Date: May 2, 2024 Anthony DiPiero #268246 b (TYPE 0R PRINT NAME) (SIGNATURE 0F PLAINTIFF 0R AWORNEY) (If you Wish to ven'fy this pleading, affix a verification.) PLoic-om [Rev January 1, 2024] COMPLAINT—Contract Page 2 or 2 1571393001