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Donald Sherrill #266038
Brian Langedyk #337250 ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
HUNT & HENRIQUES, LLP COUNTY OF SAN BERNARDINO
7017 Realm Dr., San José CA 951 19 SAN BERNARDINO DISTRICT
Telephone: (800) 680—2426
Facsimile: (408) 362-2299 5/24/2024 2:46 PM
Attorneys for Plaintiff
By: Isabel Torres, DEPUTY
File no. 1559278001
CA Debt Collection License No. 10136—99
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
San Bernardino District-Civil Division
10
CIVSB2416907
Portfolio Recovery Associates, LLC Case N0.
11 Plaintiff,
COMPLAINT FOR:
12
vs. (1) Account Stated
13 (2) Open Book Account
LLP
95119
680-2426
362-2299
14 PRAYER AMOUNT: $1,3 14.18
DR.
HENRIQUES,
CALIFORNIA (800)
15
DANNY J SEVILLA LIMITED CIVIL
(408)
REALM
Amount demanded does not exceed $1 0,000
l6
7017
Defendant(s).
8: JOSE TELEPHONE:
FACSIMILE:
l7
HUNT SAN
18
Plaintiff, Portfolio Recovery Associates, LLC, (“Plaintiff”), alleges:
l9
1. Plaintiff is a limited liability company.
20
2. This court is the proper court because Plaintiff is informed and believes that
21
Defendant, DANNY J SEVILLA (“Defendant”), is a resident of SAN BERNARDINO County,
22
State 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 l 1559278001
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, el 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.A. issued a credit account t0 Defendant. Defendant used, or
authorized the use of, the credit account to make purchases and/or transactions. Defendant
received periodic billing statements for the credit account. Defendant defaulted in niaking the
required payments. Subsequently, Plaintiff was assigned and transferred all right, title and
10 interest in the credit account.
11 7. Plaintiff is the sole owner of the credit account at issue, or has authority to assert
12 the rights 0f all owners 0f the debt.
13 8. The balance at charge-off was $1,314.18. Plaintiff is not seeking t0 recover any
LLP
95119
680—2426
362—2299
14 post charge-off fees or interest.
DR. I
HENRIQUES,
CALIFORNIA (800)
15 9. The date of last payment on the credit account was on October 25, 2022.
(408)
REALM
7017
16 10. The name 0f the charge-off creditor is CITIBANK, N.A. and the account number
8: JOSE TELEPHONE:
FACSIMILE:
SAN
17 0f the charge-off creditor ended in 8455. An address CITIBANK, N.A. maintained at the time 0f
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: ,
DANNY J SEVILLA
23
1710 W ARROW RTE APT 5
24
UPLAND CA 91786-7636.
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
A 1 155927800]
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Donald Sherrill #266038 Brian Langedyk #337250 ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA HUNT & HENRIQUES, LLP COUNTY OF SAN BERNARDINO 7017 Realm Dr., San José CA 951 19 SAN BERNARDINO DISTRICT Telephone: (800) 680—2426 Facsimile: (408) 362-2299 5/24/2024 2:46 PM Attorneys for Plaintiff By: Isabel Torres, DEPUTY File no. 1559278001 CA Debt Collection License No. 10136—99 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO San Bernardino District-Civil Division 10 CIVSB2416907 Portfolio Recovery Associates, LLC Case N0. 11 Plaintiff, COMPLAINT FOR: 12 vs. (1) Account Stated 13 (2) Open Book Account LLP 95119 680-2426 362-2299 14 PRAYER AMOUNT: $1,3 14.18 DR. HENRIQUES, CALIFORNIA (800) 15 DANNY J SEVILLA LIMITED CIVIL (408) REALM Amount demanded does not exceed $1 0,000 l6 7017 Defendant(s). 8: JOSE TELEPHONE: FACSIMILE: l7 HUNT SAN 18 Plaintiff, Portfolio Recovery Associates, LLC, (“Plaintiff”), alleges: l9 1. Plaintiff is a limited liability company. 20 2. This court is the proper court because Plaintiff is informed and believes that 21 Defendant, DANNY J SEVILLA (“Defendant”), is a resident of SAN BERNARDINO County, 22 State 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 l 1559278001 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, el 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.A. issued a credit account t0 Defendant. Defendant used, or authorized the use of, the credit account to make purchases and/or transactions. Defendant received periodic billing statements for the credit account. Defendant defaulted in niaking the required payments. Subsequently, Plaintiff was assigned and transferred all right, title and 10 interest in the credit account. 11 7. Plaintiff is the sole owner of the credit account at issue, or has authority to assert 12 the rights 0f all owners 0f the debt. 13 8. The balance at charge-off was $1,314.18. Plaintiff is not seeking t0 recover any LLP 95119 680—2426 362—2299 14 post charge-off fees or interest. DR. I HENRIQUES, CALIFORNIA (800) 15 9. The date of last payment on the credit account was on October 25, 2022. (408) REALM 7017 16 10. The name 0f the charge-off creditor is CITIBANK, N.A. and the account number 8: JOSE TELEPHONE: FACSIMILE: SAN 17 0f the charge-off creditor ended in 8455. An address CITIBANK, N.A. maintained at the time 0f 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: , DANNY J SEVILLA 23 1710 W ARROW RTE APT 5 24 UPLAND CA 91786-7636. 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 A 1 155927800]