On May 24, 2024 a
Complaint,Petition
was filed
involving a dispute between
Jpmorgan Chase Bank, N.A.,
and
Exiga, Cyrstal,
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, spare Bar number, and address); FOR COURT uss ONLY
Hunt & Henriques, LLP \
Donald Sherrill #266038 | |
Anthony DiPiero #268246
7017 Realm Drive
San José CA 951 19
CA Debt Collection License No. 10136-99
TELEPHONE No; (800) 680-2426 FAX No. (apnonal); (408) 362—2299
E—MAIL ADDRESS (Optional).- v
ELECTRONICALLY FILED
ATTORNEY FOR (Name): Plaintiff SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT
STREET ADDRESS 247 West Third Street
MAILING ADDRESS 5/24/2024 2:32 PM
CITY AND ZIP cone; San Bernardino CA 92415-0210
BRANCH NAME: San Bernardino District—Civil Division By: Isabel Torres, DEPUTY
PLAINTIFF: JPMorgan Chase Bank, N.A.
DEFENDANT: CRYSTAL EXIGA
l:| DOES 1 To
CONTRACT
COMPLAINT E AMENDED COMPLAINT (Number):
D CRoss-COMPLAINT E AMENDED CRoss-COMPLAINT (Number):
m
Jurisdiction (check
ACTION Is A LIMITED
all that apply):
m
(does not exceed $35,000)
CIVIL CASE CASE NUMBER:
l:
Amount demanded
ACTION IS
E
does not exceed $10,000
exceeds $10,000
AN UNLIMITED CIVIL CASE (exceeds $35,000) CIVSB2416897
ACTION RECLASSIFIED by this amended complaint or cross-complaint
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): CRYSTAL EXIGA
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 to do business in California
(2)
(3) m an unincorporated
other (specify): A
entity (describe):
National Banking Association organized and existing under and by virtue ofthe 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.
E
b. has complied with
Information about additional plaintiffs
all licensing requirements as a licensed (specify):
who are not competent adults is shown in Attachment 3c.
4. a. Each defendant named above is a natural person
except defendant (name):
(1) Cl
Cl
a business organization, form unknown (1) D
except defendant (name):
D a business organization, form unknown
(2)
(3) E a corporation
an unincorporated entity (describe):
(2)
(3) E a corporation
an unincorporated entity (describe):
(4) :I a public entity (describe): (4) E3 a public entity (describe):
(5) E other (specify): (5) E other (specify):
[1
Fodeémaflfcfiro?glaonrf1§rlnLiJase
‘If [his form is used as a cross-complaint, plaintiff means cross-complainant and defendam means
COMPLAINT*C°ntra°t
lIIHIIHIIIIHHlllllHlllNWIIHIIVIIHIHIHIWIIWIHHIll!
cruss-defendant.
Code
Page
of Civil Procedure, §
1571504001
1 of 2
425.12
PLD-C-001
SHORT TlTLEi JPMorgan Chase Bank, N‘A. v‘ CRYSTAL EXIGA CASE NUMBER:
4. (Continued)
b. The true names of defendants sued as Does are unknown to plaintiff.
E
(1) Doe defendants (specify Doe numbers):
defendants and acted within the scope of that
were the agents
agency or employment.
or employees of the named
E
(2) Doe defendants
plaintiff.
(specify Doe numbers): 7 are persons whose capacities are unknown to
c.
d.
E
D Information about additional defendants
Defendants who are joined under Code of
who
Civil
are natural persons is
Procedure section 382 are (names):
contained in Attachment 4c.
5. E E Plaintiff is
a.
required to comply with a claims statute, and
has complied with applicable claims statutes, or
E b. is excused from complying because (specify):
6. D 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 defendant entered into the contract here.
a defendant lived here when the contract was entered into.
a defendant lives here now.
Eiiiiifi 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 (special):
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
Common Counts
E Other (specify).-
9. E Other allegations:
10. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for
a. E] damages of: $4,642.72
b. interest on the damages
(1) [j according to the proof
0.0000 percent peryearfrom (date):October31, 2023
E I:
c.
(2)
attorney’s fees
at the rate of (specify):
E E
1) of: $
(2) according to proof.
d. other (specify):
11. D The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers):
Date: May 2,
Anthony DiPiero #268246
2024
’n/ -----
(TYPE OR PRINT NAME)
(Ifyou wish to venfy this pleading,
’// xa
/§JG‘N’TURE OF
verification )
PLAINTIFF OR ATTORNEY)
PLD—c—om [Rev January 1, 2024] COMPLAINT—Contract Page 2 of 2
1571504001
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 WITHOUT ATTORNEY (Name, spare Bar number, and address); FOR COURT uss ONLY Hunt & Henriques, LLP \ Donald Sherrill #266038 | | Anthony DiPiero #268246 7017 Realm Drive San José CA 951 19 CA Debt Collection License No. 10136-99 TELEPHONE No; (800) 680-2426 FAX No. (apnonal); (408) 362—2299 E—MAIL ADDRESS (Optional).- v ELECTRONICALLY FILED ATTORNEY FOR (Name): Plaintiff SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT STREET ADDRESS 247 West Third Street MAILING ADDRESS 5/24/2024 2:32 PM CITY AND ZIP cone; San Bernardino CA 92415-0210 BRANCH NAME: San Bernardino District—Civil Division By: Isabel Torres, DEPUTY PLAINTIFF: JPMorgan Chase Bank, N.A. DEFENDANT: CRYSTAL EXIGA l:| DOES 1 To CONTRACT COMPLAINT E AMENDED COMPLAINT (Number): D CRoss-COMPLAINT E AMENDED CRoss-COMPLAINT (Number): m Jurisdiction (check ACTION Is A LIMITED all that apply): m (does not exceed $35,000) CIVIL CASE CASE NUMBER: l: Amount demanded ACTION IS E does not exceed $10,000 exceeds $10,000 AN UNLIMITED CIVIL CASE (exceeds $35,000) CIVSB2416897 ACTION RECLASSIFIED by this amended complaint or cross-complaint 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): CRYSTAL EXIGA 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 to do business in California (2) (3) m an unincorporated other (specify): A entity (describe): National Banking Association organized and existing under and by virtue ofthe 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. E b. has complied with Information about additional plaintiffs all licensing requirements as a licensed (specify): who are not competent adults is shown in Attachment 3c. 4. a. Each defendant named above is a natural person except defendant (name): (1) Cl Cl a business organization, form unknown (1) D except defendant (name): D a business organization, form unknown (2) (3) E a corporation an unincorporated entity (describe): (2) (3) E a corporation an unincorporated entity (describe): (4) :I a public entity (describe): (4) E3 a public entity (describe): (5) E other (specify): (5) E other (specify): [1 Fodeémaflfcfiro?glaonrf1§rlnLiJase ‘If [his form is used as a cross-complaint, plaintiff means cross-complainant and defendam means COMPLAINT*C°ntra°t lIIHIIHIIIIHHlllllHlllNWIIHIIVIIHIHIHIWIIWIHHIll! cruss-defendant. Code Page of Civil Procedure, § 1571504001 1 of 2 425.12 PLD-C-001 SHORT TlTLEi JPMorgan Chase Bank, N‘A. v‘ CRYSTAL EXIGA CASE NUMBER: 4. (Continued) b. The true names of defendants sued as Does are unknown to plaintiff. E (1) Doe defendants (specify Doe numbers): defendants and acted within the scope of that were the agents agency or employment. or employees of the named E (2) Doe defendants plaintiff. (specify Doe numbers): 7 are persons whose capacities are unknown to c. d. E D Information about additional defendants Defendants who are joined under Code of who Civil are natural persons is Procedure section 382 are (names): contained in Attachment 4c. 5. E E Plaintiff is a. required to comply with a claims statute, and has complied with applicable claims statutes, or E b. is excused from complying because (specify): 6. D 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 defendant entered into the contract here. a defendant lived here when the contract was entered into. a defendant lives here now. Eiiiiifi 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 (special): 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 Common Counts E Other (specify).- 9. E Other allegations: 10. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. E] damages of: $4,642.72 b. interest on the damages (1) [j according to the proof 0.0000 percent peryearfrom (date):October31, 2023 E I: c. (2) attorney’s fees at the rate of (specify): E E 1) of: $ (2) according to proof. d. other (specify): 11. D The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers): Date: May 2, Anthony DiPiero #268246 2024 ’n/ ----- (TYPE OR PRINT NAME) (Ifyou wish to venfy this pleading, ’// xa /§JG‘N’TURE OF verification ) PLAINTIFF OR ATTORNEY) PLD—c—om [Rev January 1, 2024] COMPLAINT—Contract Page 2 of 2 1571504001