On May 24, 2024 a
Complaint,Petition
was filed
involving a dispute between
Discover Bank,
and
Crist, Gordonna M,
for Rule 3.740 Collections $10,000 or Less Limited
in the District Court of San Bernardino County.
Preview
PLD-C-001
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER;
Harvey Mooreflol 128) Chinyere A. Abuka(303286) Matthew Keim(33 1020) Jason Burrows(309882) Chan Hsu(334555) Nicholas Morello(337656)
FOR COURT USE ONLY
NAMEJOhn Phan(338677) Linda Doan(343453) Angela Dawsun(209860) Christine Siduguen(240380) Jeremy LaForge(350818)
FIRM NAME: The Moore Law Group, A Professional Corporati0n*
STREET ADDRESS; 3710 SA Susan Street, Ste 210
CITY: Santa Ana STATE; CA ZIP CODE: 92704
TELEPHONE NOA: (800)-506-2652 FAX NO.:
EMAIL ADDRESS: CALit@collectmoore.com
ATTORNEY FOR (name): Plaintiff
ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Bernardino SUPERIOR COURT OF CALIFORN IA
STREET ADDRESS: 247 West Third Street COUNTY OF SAN BERNARDINO
MAILING ADDRESS: SAN BERNARDINO DISTRICT
CITY AND Z'P CODE: San Bernardino CA 92415-02 1 0
BRANCH "AME: San Bernardino County — Central 5/24/2024 1:13 PM
PLAINTIFF: Discover Bank DEPUTY
By: Ilisha Siggers,
DEFENDANT: Gordonna M
E DOES 1 To
Crist
CONTRACT
m COMPLAINT E AMENDED COMPLAINT (Number):
E CROSS-COMPLAINT E AMENDED CROSS-COMPLAINT (Numbed:
Jurisdiction (check afl that appiy):
CASE NUMBER:
ACTION IS A LIMITED CASE
Amount demanded m
E
CIVIL (does not exceed $35,000)
does not excead $1 0,000
exceeds $10,000
E
E ACTION
ACTION
IS AN UNLIMITED (exceeds $35,000)
CIVIL CASE
IS RECLASSIFIED by this amended complaint or cross-complaint
CIVSBZ41 6875
from limited to unlimited
from unlimited to limited
1. PlaintifP (name or names): Discover Bank
alleges causes of action against defendant" (name or names):G0rdonna M Crist
2. This pleading, including attachments and exhibits, consists of the following number of pages: 3
3. a. Each named above a competent adult
EE
plaintiff is
except plaintiff (name): Discover Bank
E
E
(1)
(2)
(3)
a corporation qualified to do business
an unincorporated entity (describe):
Other (SPGCW)! Corporation
in California.
EE
b.
(1)
Plaintiff (name):
has complied with the fictitious business name laws and is doing business under the fictitious name (specifil):
4.
DE
c.
a.
(2) has complied with
Information about additional plaintiffs
Each defendant named above
aII
is
ticensing requirements
a
who
natural person
as a licensed
are not competent adults
(specify):
is shown in Attachment 3c.
D E except defendant (name): E D except defendant(name):
a business organization, form unknown.
E
E
(1)
(2)
(3)
a business organization, form unknown.
a corporation.
an unincorporated entity(descnfbe):
E
E
(1)
(2)
(3)
a corporation.
an unincorporated entity(describe):
E (4) a public entity (describe): E (4) a public entity (describe):
E
E (5)
Form AspmvedforomionaIUse
Judicial Council of Califomia
PLD—C—001 [Rev. January
otherfspeciflr):
1, 2024]
*CA DFPI Debt Collector License Number
“
lfihis form is used as a cmss-complaint,
10223-99
plaintiff
COMPLAINT—Contract
(5) other (specifil):
means cross-oomplainant and defendant means cmss-defendant.
Code
W Page 1 of2
of Civil Procedure, § 425.12
PLD-C-OO‘I
SHORT TITLE: CASE NUMBER:
Discover Bank V. Gordonna M Crist
4_ b. The true names of defendants sued as Does are unknown to plaintiff.
E (1) Doe defendants (specify Doe numbers): were the agents or employees of the named
defendants and acted within the scope of that agency or employment.
E (2) Doe defendants (specify Doe numbers): are persons whose capacities are unknown to
E
E
c.
d.
plaintiff.
Information about additional defendants who are not natural persons
Defendants who are joined under Code of Civil Procedure section 382 are (names):
is contained in Attachment 4c.
5. EE required to comply with a claims statute, and
Plaintiff is
E
a.
b.
has complied with applicable claims statutes, or
is excused from complying because (specfffl:
6.
7.
E
This court
This action
is
is subject to
the proper court because
E Civil Code section 1812.10 E Civil Code section 2984.4.
a defendant entered into the contract here.
a defendant lived here when the contract was entered into.
a defendant lives here now.
Eifiiéii 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):
E
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 and equitable; and for
m
is fair, just,
E
a.
b.
E
damages
interest
$5,066.60
of:
on the damages
EE
(1) according to proof
(2) at the rate of (specify): percent per year from (date):
C'
E attorney's fees
*Plaintiff waives attorney fees
mE
(1) of: $
(2) according to proof.
d- Other (3p901m5 Costs 0f suit and post judgment interest according to statute.
11. E The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers):
Date: 05/15/2024
Christine Siduguen. Esq. ’
(TYPE 0R PRINT NAME) (SIGNATURE OFVINTIFF 0R ATTORNEY)
(If you wish to verify this pleading, affix a verification.)
PLD-oom [Rem January 1. 2024] comp LAI NT_contract Page 2 of 2
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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PLD-C-001 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER; Harvey Mooreflol 128) Chinyere A. Abuka(303286) Matthew Keim(33 1020) Jason Burrows(309882) Chan Hsu(334555) Nicholas Morello(337656) FOR COURT USE ONLY NAMEJOhn Phan(338677) Linda Doan(343453) Angela Dawsun(209860) Christine Siduguen(240380) Jeremy LaForge(350818) FIRM NAME: The Moore Law Group, A Professional Corporati0n* STREET ADDRESS; 3710 SA Susan Street, Ste 210 CITY: Santa Ana STATE; CA ZIP CODE: 92704 TELEPHONE NOA: (800)-506-2652 FAX NO.: EMAIL ADDRESS: CALit@collectmoore.com ATTORNEY FOR (name): Plaintiff ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Bernardino SUPERIOR COURT OF CALIFORN IA STREET ADDRESS: 247 West Third Street COUNTY OF SAN BERNARDINO MAILING ADDRESS: SAN BERNARDINO DISTRICT CITY AND Z'P CODE: San Bernardino CA 92415-02 1 0 BRANCH "AME: San Bernardino County — Central 5/24/2024 1:13 PM PLAINTIFF: Discover Bank DEPUTY By: Ilisha Siggers, DEFENDANT: Gordonna M E DOES 1 To Crist CONTRACT m COMPLAINT E AMENDED COMPLAINT (Number): E CROSS-COMPLAINT E AMENDED CROSS-COMPLAINT (Numbed: Jurisdiction (check afl that appiy): CASE NUMBER: ACTION IS A LIMITED CASE Amount demanded m E CIVIL (does not exceed $35,000) does not excead $1 0,000 exceeds $10,000 E E ACTION ACTION IS AN UNLIMITED (exceeds $35,000) CIVIL CASE IS RECLASSIFIED by this amended complaint or cross-complaint CIVSBZ41 6875 from limited to unlimited from unlimited to limited 1. PlaintifP (name or names): Discover Bank alleges causes of action against defendant" (name or names):G0rdonna M Crist 2. This pleading, including attachments and exhibits, consists of the following number of pages: 3 3. a. Each named above a competent adult EE plaintiff is except plaintiff (name): Discover Bank E E (1) (2) (3) a corporation qualified to do business an unincorporated entity (describe): Other (SPGCW)! Corporation in California. EE b. (1) Plaintiff (name): has complied with the fictitious business name laws and is doing business under the fictitious name (specifil): 4. DE c. a. (2) has complied with Information about additional plaintiffs Each defendant named above aII is ticensing requirements a who natural person as a licensed are not competent adults (specify): is shown in Attachment 3c. D E except defendant (name): E D except defendant(name): a business organization, form unknown. E E (1) (2) (3) a business organization, form unknown. a corporation. an unincorporated entity(descnfbe): E E (1) (2) (3) a corporation. an unincorporated entity(describe): E (4) a public entity (describe): E (4) a public entity (describe): E E (5) Form AspmvedforomionaIUse Judicial Council of Califomia PLD—C—001 [Rev. January otherfspeciflr): 1, 2024] *CA DFPI Debt Collector License Number “ lfihis form is used as a cmss-complaint, 10223-99 plaintiff COMPLAINT—Contract (5) other (specifil): means cross-oomplainant and defendant means cmss-defendant. Code W Page 1 of2 of Civil Procedure, § 425.12 PLD-C-OO‘I SHORT TITLE: CASE NUMBER: Discover Bank V. Gordonna M Crist 4_ b. The true names of defendants sued as Does are unknown to plaintiff. E (1) Doe defendants (specify Doe numbers): were the agents or employees of the named defendants and acted within the scope of that agency or employment. E (2) Doe defendants (specify Doe numbers): are persons whose capacities are unknown to E E c. d. plaintiff. Information about additional defendants who are not natural persons Defendants who are joined under Code of Civil Procedure section 382 are (names): is contained in Attachment 4c. 5. EE required to comply with a claims statute, and Plaintiff is E a. b. has complied with applicable claims statutes, or is excused from complying because (specfffl: 6. 7. E This court This action is is subject to the proper court because E Civil Code section 1812.10 E Civil Code section 2984.4. a defendant entered into the contract here. a defendant lived here when the contract was entered into. a defendant lives here now. Eifiiéii 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): E 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 and equitable; and for m is fair, just, E a. b. E damages interest $5,066.60 of: on the damages EE (1) according to proof (2) at the rate of (specify): percent per year from (date): C' E attorney's fees *Plaintiff waives attorney fees mE (1) of: $ (2) according to proof. d- Other (3p901m5 Costs 0f suit and post judgment interest according to statute. 11. E The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers): Date: 05/15/2024 Christine Siduguen. Esq. ’ (TYPE 0R PRINT NAME) (SIGNATURE OFVINTIFF 0R ATTORNEY) (If you wish to verify this pleading, affix a verification.) PLD-oom [Rem January 1. 2024] comp LAI NT_contract Page 2 of 2