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ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
Christopher D. Mandarich SB 220693 6/6/2024 7:22 PM
Teona Pipia SB 343337
Martin Weingarten SB 201906 By: Breanna Guerra, DEPUTY
Sarkis Karayan SB 316926
MANDARICH LAW GROUP, LLP
P.O. Box 109032 Chicago, IL 60610
877.285.4918
Facsimile: 818.888.1260
Mandarich Law Group, LLP California Debt Collector License Number 10795—99.
\DOOQONUl-PUJNH
Attorneysfor Plaintifi‘: Velocity Investments, LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN BERNARDINO LIMITED -
Velocity Investments, LLC, Case N0. CIVSBZ41 8482
Plaintiff,
FILE BY FAX COMPLAINT FOR:
VS.
1. BREACH OF CONTRACT
Ashley Lindbeck, an individual; 2. OPEN BOOK ACCOUNT
and DOES through 10 inclusive.
1
Defendant.
DEMAND; $3,047.74
Plaintiff alleges:
FACTS COMMON TO ALL CAUSES OF ACTION
1. Plaintiff is and at all times herein mentioned, Velocity Investments, LLC, and successor
in interest to original creditor, CROSS RIVER BANK.
2. Plaintiff is the only entity that purchased the debt after charge-off and its name and
OOQONUl-PUJNHOKOOOQQUI-PUJNr—to
NNNNNNNNNHHHHHHHHHH
address is as follows: Velocity Investments, LLC; 1800 Route 34N Suite 404A Wall NJ 07719.
,
3. Plaintiff is a debt buyer, and is the sole owner of the debt at issue. Plaintiffs California
Debt Collector License Number 10229—99.
4. The charge-off creditor at the time 0f charge-off is UPSTART PASS-THROUGH
TRUST SERIES 2022-PT1, P.O. BOX 1503, SAN CARLOS, CA 94070-1, and the account
number associated With this debt is XXXX5631.
5. Plaintiff is informed and believes that Defendant are individuals who currently reside
Within the jurisdictional boundaries 0f the above entitled Court. Therefore, this Court is the
COMPLAINT—l 0f 5
proper Court for trial 0f this action.
6. The name and last known address 0f the debtor as they appeared in the charge—off
creditor’s records prior to the sale 0f the debt is Ashley Lindbeck ,
15996 MUNI RD APPLE
,
VALLEY, CA 92307.
\DOOQOUI-PUJNr—t
7. Plaintiff is unaware of the true names 0r capacities, whether individual, corporate,
associate 01‘ otherwise 0f the Defendant sued herein as DOES 1 through 10 inclusive, and therefore,
sued the Defendant by such fictitious names. Plaintiff Will amend this Complaint t0 show their true
names and capacities once ascertained.
8. Plaintiff believes and at all times mentioned herein, each 0f the Defendant was, and is,
the agent, servant and employee, employer 0f each 0f the other Defendant, and also acted in the
capacity 0f and as agent 0f the other Defendant. Plaintiff also believes that the individual
Defendant, and each 0f them, are jointly and severally liable that the actions described herein
were taken as actions for the benefit 0f the Defendant's separate and/or community property.
9. Plaintiff believes that, for value received, Defendant and each of them, executed and
delivered a credit application t0 the original creditor, CROSS RIVER BANK or made such
application over the telephone 0r Internet. Pursuant t0 the aforementioned application, CROSS
RIVER BANK provided Defendant with a credit account, and granted use privileges 0n the same,
account number XXXX5631 (hereinafter “Account”).
NNNNNNNNNHHHHHHHHHH
OOQONUl-PUJNHOKOOOQQUI-PUJNr—to
10. Prior t0 the commencement 0f this action, the Account was assigned for value t0 the
Plaintiff and Plaintiff is its current holder.
11. Defendant agreed t0 comply with the terms governing the use of the Account, as it was
amended from time to time, including repaying CROSS RIVER BANK and any successors in
interest, for any charges 0n the Account including, but not limited to, charges for purchase 0f goods
and service and/or cash advances and balance transfers along with late charges, over limits charges
related thereto.
12. Defendant used the Account to make purchases and/or t0 take cash advances and/or t0
make balance transfers. Each time the Defendant used the Account t0 purchase goods and services
COMPLAINT—2 0f 5
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ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT Christopher D. Mandarich SB 220693 6/6/2024 7:22 PM Teona Pipia SB 343337 Martin Weingarten SB 201906 By: Breanna Guerra, DEPUTY Sarkis Karayan SB 316926 MANDARICH LAW GROUP, LLP P.O. Box 109032 Chicago, IL 60610 877.285.4918 Facsimile: 818.888.1260 Mandarich Law Group, LLP California Debt Collector License Number 10795—99. \DOOQONUl-PUJNH Attorneysfor Plaintifi‘: Velocity Investments, LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO LIMITED - Velocity Investments, LLC, Case N0. CIVSBZ41 8482 Plaintiff, FILE BY FAX COMPLAINT FOR: VS. 1. BREACH OF CONTRACT Ashley Lindbeck, an individual; 2. OPEN BOOK ACCOUNT and DOES through 10 inclusive. 1 Defendant. DEMAND; $3,047.74 Plaintiff alleges: FACTS COMMON TO ALL CAUSES OF ACTION 1. Plaintiff is and at all times herein mentioned, Velocity Investments, LLC, and successor in interest to original creditor, CROSS RIVER BANK. 2. Plaintiff is the only entity that purchased the debt after charge-off and its name and OOQONUl-PUJNHOKOOOQQUI-PUJNr—to NNNNNNNNNHHHHHHHHHH address is as follows: Velocity Investments, LLC; 1800 Route 34N Suite 404A Wall NJ 07719. , 3. Plaintiff is a debt buyer, and is the sole owner of the debt at issue. Plaintiffs California Debt Collector License Number 10229—99. 4. The charge-off creditor at the time 0f charge-off is UPSTART PASS-THROUGH TRUST SERIES 2022-PT1, P.O. BOX 1503, SAN CARLOS, CA 94070-1, and the account number associated With this debt is XXXX5631. 5. Plaintiff is informed and believes that Defendant are individuals who currently reside Within the jurisdictional boundaries 0f the above entitled Court. Therefore, this Court is the COMPLAINT—l 0f 5 proper Court for trial 0f this action. 6. The name and last known address 0f the debtor as they appeared in the charge—off creditor’s records prior to the sale 0f the debt is Ashley Lindbeck , 15996 MUNI RD APPLE , VALLEY, CA 92307. \DOOQOUI-PUJNr—t 7. Plaintiff is unaware of the true names 0r capacities, whether individual, corporate, associate 01‘ otherwise 0f the Defendant sued herein as DOES 1 through 10 inclusive, and therefore, sued the Defendant by such fictitious names. Plaintiff Will amend this Complaint t0 show their true names and capacities once ascertained. 8. Plaintiff believes and at all times mentioned herein, each 0f the Defendant was, and is, the agent, servant and employee, employer 0f each 0f the other Defendant, and also acted in the capacity 0f and as agent 0f the other Defendant. Plaintiff also believes that the individual Defendant, and each 0f them, are jointly and severally liable that the actions described herein were taken as actions for the benefit 0f the Defendant's separate and/or community property. 9. Plaintiff believes that, for value received, Defendant and each of them, executed and delivered a credit application t0 the original creditor, CROSS RIVER BANK or made such application over the telephone 0r Internet. Pursuant t0 the aforementioned application, CROSS RIVER BANK provided Defendant with a credit account, and granted use privileges 0n the same, account number XXXX5631 (hereinafter “Account”). NNNNNNNNNHHHHHHHHHH OOQONUl-PUJNHOKOOOQQUI-PUJNr—to 10. Prior t0 the commencement 0f this action, the Account was assigned for value t0 the Plaintiff and Plaintiff is its current holder. 11. Defendant agreed t0 comply with the terms governing the use of the Account, as it was amended from time to time, including repaying CROSS RIVER BANK and any successors in interest, for any charges 0n the Account including, but not limited to, charges for purchase 0f goods and service and/or cash advances and balance transfers along with late charges, over limits charges related thereto. 12. Defendant used the Account to make purchases and/or t0 take cash advances and/or t0 make balance transfers. Each time the Defendant used the Account t0 purchase goods and services COMPLAINT—2 0f 5