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PATENAUDE & FELIX, A.P.C.
Raymond A'. Patenaude, Esq. (#128855) ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
Laura M. D Anna, Esq. (#2661 13) COUNTY 0F SAN BERNARDINO
Nathalia A. Aguirre, Esq. (#337628) SAN BERNARDINO DISTRICT
Dlngn J. L-ee, Es.q. (#314542) 5/24/2024 12:26 PM
Abrll Sagllo—Rulz, Esq. (#299586)
9619 Chesapeake Drive, Suite 300 By= Isabel Torres, DEPUTY
San Diego, California 92123
California DFPI Debt Collector License # 10678-99
Tele: (858) 244—7600 Fax: (858) 836—0318
Attorneys for Plaintiff
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO, SAN BERNARDINO JUSTICE CENTER
10
CREDIT CORP SOLUTIONS, INC., Case No. CIVSBZ41 6923
ASSIGNEE OF SYNCHRONY BANIIEi
11 u COMPLAINT FOR
am tuff
1 ’
(1) Account Stated
12
3m
33541313
V. (2) Open Book Account
APE
SUITE
13 JAIME ZARATE,
LAW 92123
(353::
and DOES 1 through 15 inclusive
PRAYER AMOUNT: $3’644°53
FELIX, ’ ’
AT 14 LIMITED CIVIL
BREE
CA FA}:
Defendant.
& Amount demanded does not exceed $35,000
DECK}.
15
ATICIRNEYS
Plaintiff, CREDIT CORP SOLUTIONS, INC., ASSIGNEE OF SYNCHRONY BANK,
(3533244-?500
[fl-ESAPEAKE
PATENAIME SAN 16
("Plaintif "), alleges:
17
9519 TELE:
1. Plaintiff is a corporation qualified t0 do business in California.
18
2. This court is the proper court because Plaintiff is informed and believes that
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20 Defendant, JAIME ZARATE ("Defendant"), is a resident 0f SAN BERNARDINO County, State
21 0f California.
22
3. At all times herein mentioned, Defendants, and each 0f them, were the principals,
23
agents, employers, employees, masters, 0r servants 0f each 0f their co—defendants and ratified,
24
adopted 0r approved the acts 0r omissions alleged herein, and each defendant, in doing the things
25
alleged, were acting in the course and scope 0f said authority 0f such agents, servants, and
26
27 employees.
28
COMPLAINT
CA_1808 Complaint_Dbuyer P&F File N0. 24-1273
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.
5. Plaintiff is a debt buyer.
6. Synchrony Bank FKA GE Capital Retail Bank issued a credit account t0 Defendant.
Defendant used, 0r authorized the use 0f, 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
10 all right, title and interest in the credit account. See Exhibit D.
11
7. Plaintiff is the sole owner of the credit account at issue, 0r has authority t0 assert the
12
a E rights 0f all owners 0f the debt.
EBM
Efimfifi
13
8. The balance at charge—off was $3,684.53. Plaintiff is not seeking t0 recover any post
14
Eiggfi
charge—off fees or interest.
3% 3% 15
gig; 16 9. Defendant never made a payment 0n the account. The last transaction 0n the
EEEEEa
[-u
..
E m 17 account was 0n June 04, 2021.
E E
18
10. The name 0f the charge—off creditor is Synchrony Bank FKA GE Capital Retail
19
Bank and the account number 0f the Charge-off creditor ended in XXXXXXXXXXXX2453. An
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address Synchrony Bank FKA GE Capital Retail Bank maintained at the time 0f charge—off was:
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PO BOX 960061 ORLANDO, FL 32896—0061
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11. The last known address that the charge—Off creditor had for Defendant is:
24 JAIME ZARATE
3074 LINCOLN DR SAN BERNARDINO CA 92405
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12. The subject credit account has been purchased by the following entity after
26
27 charge—off: CREDIT CORP SOLUTIONS INC. Who maintains an address at 121 WEST
28 ELECTION ROAD, SUITE 200, DRAPER, UT 84020.
2
COMPLAINT
CA_1808 Complaint_Dbuyer P&F File N0. 24-1273
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PATENAUDE & FELIX, A.P.C. Raymond A'. Patenaude, Esq. (#128855) ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA Laura M. D Anna, Esq. (#2661 13) COUNTY 0F SAN BERNARDINO Nathalia A. Aguirre, Esq. (#337628) SAN BERNARDINO DISTRICT Dlngn J. L-ee, Es.q. (#314542) 5/24/2024 12:26 PM Abrll Sagllo—Rulz, Esq. (#299586) 9619 Chesapeake Drive, Suite 300 By= Isabel Torres, DEPUTY San Diego, California 92123 California DFPI Debt Collector License # 10678-99 Tele: (858) 244—7600 Fax: (858) 836—0318 Attorneys for Plaintiff SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO, SAN BERNARDINO JUSTICE CENTER 10 CREDIT CORP SOLUTIONS, INC., Case No. CIVSBZ41 6923 ASSIGNEE OF SYNCHRONY BANIIEi 11 u COMPLAINT FOR am tuff 1 ’ (1) Account Stated 12 3m 33541313 V. (2) Open Book Account APE SUITE 13 JAIME ZARATE, LAW 92123 (353:: and DOES 1 through 15 inclusive PRAYER AMOUNT: $3’644°53 FELIX, ’ ’ AT 14 LIMITED CIVIL BREE CA FA}: Defendant. & Amount demanded does not exceed $35,000 DECK}. 15 ATICIRNEYS Plaintiff, CREDIT CORP SOLUTIONS, INC., ASSIGNEE OF SYNCHRONY BANK, (3533244-?500 [fl-ESAPEAKE PATENAIME SAN 16 ("Plaintif "), alleges: 17 9519 TELE: 1. Plaintiff is a corporation qualified t0 do business in California. 18 2. This court is the proper court because Plaintiff is informed and believes that 19 20 Defendant, JAIME ZARATE ("Defendant"), is a resident 0f SAN BERNARDINO County, State 21 0f California. 22 3. At all times herein mentioned, Defendants, and each 0f them, were the principals, 23 agents, employers, employees, masters, 0r servants 0f each 0f their co—defendants and ratified, 24 adopted 0r approved the acts 0r omissions alleged herein, and each defendant, in doing the things 25 alleged, were acting in the course and scope 0f said authority 0f such agents, servants, and 26 27 employees. 28 COMPLAINT CA_1808 Complaint_Dbuyer P&F File N0. 24-1273 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. 5. Plaintiff is a debt buyer. 6. Synchrony Bank FKA GE Capital Retail Bank issued a credit account t0 Defendant. Defendant used, 0r authorized the use 0f, 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 10 all right, title and interest in the credit account. See Exhibit D. 11 7. Plaintiff is the sole owner of the credit account at issue, 0r has authority t0 assert the 12 a E rights 0f all owners 0f the debt. EBM Efimfifi 13 8. The balance at charge—off was $3,684.53. Plaintiff is not seeking t0 recover any post 14 Eiggfi charge—off fees or interest. 3% 3% 15 gig; 16 9. Defendant never made a payment 0n the account. The last transaction 0n the EEEEEa [-u .. E m 17 account was 0n June 04, 2021. E E 18 10. The name 0f the charge—off creditor is Synchrony Bank FKA GE Capital Retail 19 Bank and the account number 0f the Charge-off creditor ended in XXXXXXXXXXXX2453. An 20 address Synchrony Bank FKA GE Capital Retail Bank maintained at the time 0f charge—off was: 21 PO BOX 960061 ORLANDO, FL 32896—0061 22 23 11. The last known address that the charge—Off creditor had for Defendant is: 24 JAIME ZARATE 3074 LINCOLN DR SAN BERNARDINO CA 92405 25 12. The subject credit account has been purchased by the following entity after 26 27 charge—off: CREDIT CORP SOLUTIONS INC. Who maintains an address at 121 WEST 28 ELECTION ROAD, SUITE 200, DRAPER, UT 84020. 2 COMPLAINT CA_1808 Complaint_Dbuyer P&F File N0. 24-1273