On May 24, 2024 a
Complaint,Petition
was filed
involving a dispute between
Portfolio Recovery Associates Llc,
and
Long, Seth,
for Rule 3.740 Collections $10,000 or Less Limited
in the District Court of San Bernardino County.
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ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
Donald Sherrill #266038
Alexander Balzer Carr #338024 5/24/2024 2:42 PM
HUNT & HENRIQUES, LLP
7017 Realm Dr., San José CA 951 19 By: Ilisha Siggers, DEPUTY
Telephone: (800) 680—2426
Facsimile: (408) 362—2299
Attorneys for Plaintiff
File no. 1553993001
CA Debt Collection License N0. 10136-99
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
San Bernardino District-Civil Division
10 CIVSB2416911
Portfolio Recovery Associates, LLC Case N0.
11 Plaintiff,
COMPLAINT FOR:
12
vs. (l) Account Stated
13 (2) Open Book Account
LLP
95119
680-2426
362-2299
PRAYER AMOUNT: $6,051.28
DR.
HENRIQUES,
CALIFORNIA (800)
15
SETH LONG LIMITED CIVIL
(408)
REALM
Amount demanded does not exceed $10,000
16
7017
Defendant(s).
& JOSE TELEPHONE:
FACSIMILE:
HUNT SAN
18
Plaintiff, Portfolio Recovery Associates, LLC, (“Plaintiff”), alleges:
19
1. Plaintiff is a limited liability company.
20
2. This court is the proper court because Plaintiff is informed and believes that
21
Defendant, SETH LONG (“Defendant”), is a resident of SAN BERNARDINO County, State of
22
California.
23
3. At all times herein mentioned, Defendants, and each of them, were the principals,
24
agents, employers, employees, masters, or servants 0f 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 1 1553993001
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, et 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. SYNCHRONY BANK issued a credit account t0 Defendant. Defendant used, or
authorized the use of, the credit account t0 make purchases and/or transactions. Defendant
received periodic billing statements for the credit account. Defendant defaulted in making 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 t0 assert
12 the rights of all owners of the debt.
13 8. The balance at charge-off was $6,091.28. Plaintiff is not seeking to recover any
LLP
95119
680-2426
362-2299
14 post charge-off fees or interest.
DR.
HENRIQUES,
CALIFORNIA (800)
15 9. The date of last payment on the credit account was on July 5, 2022.
(408)
REALM
7017
16 10. The name 0f the charge-off creditor is SYNCHRONY BANK and the account
8: JOSE TELEPHONE:
FACSIMILE:
HUNT SAN
l7 number of the charge-off creditor ended in 8010. An address SYNCHRONY BANK maintained
18 at the time of charge-off was:
19 4500 MUNSON STREET
20 CANTON OH 4471 8.
21 11. The name and last known address that the charge-off creditor had for Defendant
22 is:
SETH LONG
23
11573 SPRINGOAK CT
24
FONTANA CA 92337-1235.
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 1553993001
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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ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT Donald Sherrill #266038 Alexander Balzer Carr #338024 5/24/2024 2:42 PM HUNT & HENRIQUES, LLP 7017 Realm Dr., San José CA 951 19 By: Ilisha Siggers, DEPUTY Telephone: (800) 680—2426 Facsimile: (408) 362—2299 Attorneys for Plaintiff File no. 1553993001 CA Debt Collection License N0. 10136-99 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO San Bernardino District-Civil Division 10 CIVSB2416911 Portfolio Recovery Associates, LLC Case N0. 11 Plaintiff, COMPLAINT FOR: 12 vs. (l) Account Stated 13 (2) Open Book Account LLP 95119 680-2426 362-2299 PRAYER AMOUNT: $6,051.28 DR. HENRIQUES, CALIFORNIA (800) 15 SETH LONG LIMITED CIVIL (408) REALM Amount demanded does not exceed $10,000 16 7017 Defendant(s). & JOSE TELEPHONE: FACSIMILE: HUNT SAN 18 Plaintiff, Portfolio Recovery Associates, LLC, (“Plaintiff”), alleges: 19 1. Plaintiff is a limited liability company. 20 2. This court is the proper court because Plaintiff is informed and believes that 21 Defendant, SETH LONG (“Defendant”), is a resident of SAN BERNARDINO County, State of 22 California. 23 3. At all times herein mentioned, Defendants, and each of them, were the principals, 24 agents, employers, employees, masters, or servants 0f 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 1 1553993001 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, et 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. SYNCHRONY BANK issued a credit account t0 Defendant. Defendant used, or authorized the use of, the credit account t0 make purchases and/or transactions. Defendant received periodic billing statements for the credit account. Defendant defaulted in making 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 t0 assert 12 the rights of all owners of the debt. 13 8. The balance at charge-off was $6,091.28. Plaintiff is not seeking to recover any LLP 95119 680-2426 362-2299 14 post charge-off fees or interest. DR. HENRIQUES, CALIFORNIA (800) 15 9. The date of last payment on the credit account was on July 5, 2022. (408) REALM 7017 16 10. The name 0f the charge-off creditor is SYNCHRONY BANK and the account 8: JOSE TELEPHONE: FACSIMILE: HUNT SAN l7 number of the charge-off creditor ended in 8010. An address SYNCHRONY BANK maintained 18 at the time of charge-off was: 19 4500 MUNSON STREET 20 CANTON OH 4471 8. 21 11. The name and last known address that the charge-off creditor had for Defendant 22 is: SETH LONG 23 11573 SPRINGOAK CT 24 FONTANA CA 92337-1235. 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 1553993001