Preview
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Supertor Court of Calttorntd,
Nathan A. Melendrez, SBN 332016 Sacramento
Ralph L. Sims, SBN 083880
Melendrez & Sims, A P.C. 40/24/2023
CA DFPI Debt Collector License Number 10427-99 russeit
7700 Irvine Center Drive Suite 820, Irvine, CA 92618-3060
PO Box 54148, Irvine, CA 92619 By , Deputy
Telephone: (877) 958-2350
Facsimile: (888) 847-1732
Z23CV011619
File Number: 10102365
Attorney for Plaintiff
SUPERIOR COURT, STATE OF CALIFORNIA
SACRAMENTO COUNTY, CENTRAL DISTRICT
10
11
12
13 CASE NO.:
PLAINTIFF(S): TWO JINN, INC. DBA
14 ALADDIN BAIL BONDS LIMITED JURISDICTION
15 VS COMPLAINT FOR BREACH
OF CONTRACT
16 DEFENDANT(S):
TERESA WATSON; DEMAND AMOUNT: $3,515.00,
17 RAYMOND WILLIAM DAVISON; plus interest, attorney fees and
DOES 1 TO 10, INCLUSIVE costs
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20
21
PLAINTIFF, TWO JINN, INC. DBA ALADDIN BAIL BONDS, complain of
22
“a DEFENDANTS as follows:
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PLAINTIFF'S IDENTITY
24
l. PLAINTIFF is a corporation, TWO JINN, INC., duly organized and
25
existing under the laws of the state of California; at all times alleged in this
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complaint, PLAINTIFF was an active corporation in good standing, doing
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business under the fictitious business name of ALADDIN BAIL BONDS;
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Page |
COMPLAINT FOR BREACH OF CONTRACT
PLAINTIFF has executed, filed, and published the statement required by Chapter
5, Part 3, Division 7 of the California Business and Professions Code, the
provisions of which are incorporated in this PARAGRAPH by this reference
thereto.
DEFINITIONS AND DESIGNATIONS
2. Unless otherwise indicated,
a. Words denoting a gender include the masculine, feminine,
and neuter forms of those words.
b. Words denoting a number include the plural and singular
10 forms of those words.
ll c, "AND/OR" means one "thing or another" or "both things,"
12 depending on the context;
13 d. “PERSON” includes (without limitation) an individual, a
14 corporation, a partnership, a limited liability company, a joint venture, an
15 association, a joint stock company, a trust, an unincorporated organization, a
16 government, and a political subdivision of a government;
17 e. “CONDUCT” means the behavior of a PERSON and includes
18 both acts and omissions;
19 f. "PLAINTIFF" means the plaintiff in this action, TWO JINN, INC.
20 DBA ALADDIN BAIL BONDS;
21 g. "DEFENDANTS" means all of the defendants in this action,
22 TERESA WATSON; RAYMOND WILLIAM DAVISON; DOES 1 TO 10, INCLUSIVE;
23 h. “DOE DEFENDANTS” means the following defendants in this
24 action: DOE 1 to and including DOE 10;
25 I. "PARAGRAPH" means a paragraph in this complaint;
26 js "REPLEAD" means to replicate the allegations made in a prior
27 PARAGRAPH and incorporate them by reference in another PARAGRAPH;
28 JURISDICTION AND NATURE OF ACTION
Page 2
COMPLAINT FOR BREACH OF CONTRACT
3. This is an action for breach of contract for which the Superior Court
has original jurisdiction under Article 6 § 10 of the California Constitution; the
amount in controversy is $3,515.00; therefore, under Section 85 of the California
Code of Civil Procedure, it is a limited civil case.
VENUE
4. This is an action that arises from a transaction in which the subject of
the transaction is primarily for personal, family, or household purposes; it is not
an action on an obligation described in section 1812.10 or section 2984.4 of the
California Civil Code or an obligation arising from an unsolicited telephone call
or arising from a telephone call or electronic transmission made in response to a
solicitation by a seller.
5. On information AND/OR belief, plaintiff alleges that, the above-
entitled court is located in the judicial district of the county where the contract
was in fact signed by one of the DEFENDANTS or where one of the DEFENDANTS
resides at the commencement of this action; therefore, under section 395 of the
California Code of Civil Procedure and section 1692i of Title 15 of the United
State Codes, the provisions of each of which are incorporated in this
PARAGRAPH by this reference thereto, this is the proper court for the
commencement and trial of this action.
THE DOE DEFENDANTS
6. PLAINTIFF is not aware of the true names of the DOE DEFENDANTS;
therefore, pursuant to and in accordance with the provisions of Section 474 of the
California Code of Civil Procedure, PLAINTIFF is suing the DOE DEFENDANTS
by the fictitious names of DOE 1 to and including DOE 10; and PLAINTIFF will ask
this court for leave to amend this complaint to state the true names of the DOE
DEFENDANTS after they are discovered.
Page 3
COMPLAINT FOR BREACH OF CONTRACT
ORGANIZATION OF THE DOE DEFENDANTS
tT PLAINTIFF is not aware of the nature of or the basis for the
organization (if any) of the DOE DEFENDANTS; therefore, PLAINTIFF will ask this
court for leave to amend this complaint to state the facts in this regard after they
are discovered.
RELATIONSHIP BETWEEN THE DEFENDANTS
8. On information AND/OR belief, PLAINTIFF alleges that,
at all times alleged in this complaint, the relationships between the
10 DEFENDANTS were such that each of them is liable for the CONDUCT of the
1 others (e.g., as principal, agent, servant, employee, partner, joint venturer,
12 associate, alter ego, etc.); PLAINTIFF is not aware of the specific facts in this
13 regard; therefore, PLAINTIFF will ask this court for leave to amend this complaint
14 to state those fact after they are discovered.
15
16 FIRST CAUSE OF ACTION
17 AGAINST ALL DEFENDANTS
18 FOR BREACH OF CONTRACT
19 ACCOUNT NUMBER XXXXX-XXX2761
20 9. PLAINTIFF herein REPLEADS all of the allegations made in
21 PARAGRAPHS 1-8.
22 10. Onor about OCTOBER 22, 2021, DEFENDANTS entered into a
23 written contract ("the CONTRACT"), pursuant to which PLAINTIFF arranged for
24 the issuance of a bail bond ("the BAIL BOND") to TERESA WATSON ("the
25 PRINCIPAL"). The CONTRACT contained a Notice to Cosigner. The CONTRACT
26 is in writing, a copy of which is marked for identification as Exhibit "A", attached
27 hereto, and incorporated herein by this reference thereto.
28 11. The CONTRACT provides that DEFENDANTS promise to:
Page 4
COMPLAINT FOR BREACH OF CONTRACT
a. pay PLAINTIFF for the cost of the BAIL BOND AND/OR any
renewal or court-ordered increase thereof;
b reimburse PLAINTIFF for actual expenses incurred by
PLAINTIFF in connection with the arranging AND/OR the execution of the BAIL
BOND AND/OR any renewal or substitution thereof;
e. reimburse PLAINTIFF for actual expenses incurred by
PLAINTIFF as a result of a breach by the PRINCIPAL of any of the terms for which
the BAIL BOND AND/OR the application for the BAIL BOND was written,
including (without limitation) any expense AND/OR liability incurred by
10 PLAINTIFF as a result of searching for, apprehending. attempting to apprehend
11 recapturing, attempting to recapture, AND/OR returning the PRINCIPAL to
12 custody AND/OR any expense incurred by PLAINTIFF in securing the release of
13 PLAINTIFF or the surety from all liability under the BAIL BOND ; as used in this
14 PARAGRAPH, "expenses," includes (without limitation) any legal fees incurred
15 by PLAINTIFF in applying for a court order to vacate or set aside an order of
16 forfeiture or a judgment entered thereon;
17 d. pay to PLAINTIFF on demand the penal amount of the BAIL
18 BOND if PLAINTIFF deems such payment necessary to protect itself for any
19 reasonable cause, including (without limitation) the misrepresentation AND/OR
20 concealment of any information that is material to the hazard assumed by
21 PLAINTIFF;
22 12. DEFENDANTS breached the CONTRACT by:
23 a. failing to pay PLAINTIFF for the cost of the BAIL BOND AND/OR
24 a renewal or court-ordered increase thereof;
25 b failing to reimburse PLAINTIFF for actual expenses incurred
26 by PLAINTIFF in connection with the arranging AND/OR the execution of the
27 BAIL BOND AND/OR a renewal or substitution thereof;
28
Page 5
COMPLAINT FOR BREACH OF CONTRACT
Cc. failing to reimburse PLAINTIFF for actual expenses incurred
by PLAINTIFF as a result of a breach by the PRINCIPAL of any of the terms for
which the BAIL BOND AND/OR the application for the BAIL BOND was written;
(Collectively, these events are hereinafter called "the BREACH.").
13. The BREACH occurred on or about NOVEMBER 13, 2021.
14. Thereafter, PLAINTIFF made demand on DEFENDANTS to cure the
BREACH ("the DEMAND"), but DEFENDANTS have failed and now refused to
comply with the DEMAND.
15. Asadirect and proximate result of DEFENDANTS' CONDUCT as
10 alleged in this cause of action, PLAINTIFF has sustained monetary damages in
11 the amount of $3,515.00 plus interest on that amount from NOVEMBER 13, 2021 at
12 the rate of ten (10) percent per annum pursuant to section 3289 of the California
13 Civil Code or as otherwise allowed by law.
14 16. The CONTRACT provides that DEFENDANTS will pay reasonable
15 attorney fees incurred by PLAINTIFF in any action or proceeding arising from
16 the CONTRACT; therefore, in addition to compensatory damages, PLAINTIFF is
17 entitled to recover an award of reasonable attorney fees from DEFENDANTS
18 pursuant to the CONTRACT AND/OR section 1717 of the California Civil Code,
19 the provisions of which are incorporated in this PARAGRAPH by this reference
20 thereto.
21 17. All conditions precedent to performance of the CONTRACT by
22 DEFENDANTS have been performed, waived, excused, discharged, or otherwise
23 extinguished, including (without limitation) performance of the CONTRACT by
24 PLAINTIFF.
25 \\\
26 WHEREFORE, PLAINTIFF prays for judgment against DEFENDANTS
27 as set forth below.
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Page 6
COMPLAINT FOR BREACH OF CONTRACT
PRAYER
PLAINTIFF prays for judgment against DEFENDANTS, and each of them,
jointly and severally, as follows:
l. On the First Cause of Action for:
a. $3,515.00 compensatory damages;
b. interest on that sum from NOVEMBER 13, 2021 to be calculated
at the rate of ten (10) percent per annum pursuant to section 3289 of the
California Civil Code or as otherwise allowed by law;
é. reasonable attorney fees;
10 d. all costs of suit; and
1] e. such other relief as the court deems appropriate;
12
13 Dated: October 18, 2023 Melendrez & Sims, A P.C.
Attorney for P
14
15 By
[ ] Ralph L. Sims
16 [xx] Nathan A. Melendrez
17
18
19
20
2]
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23
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25
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Page 7
COMPLAINT FOR BREACH OF CONTRACT
EXHIBIT "A"
(CONTRACT)
EXHIBIT "A"
(CONTRACT)
EXHIBIT "A"
(CONTRACT)
Aladdin Bail Bonds
715 9TH STREET, #105
Sacramento, CA 95814 Retail Installment Contract
(916) 444-2700
SEAVIEW INSURANCE COMPANY
INDEMNITY AGREEMENT
FOR
SURETY BAIL BOND
RECITAL
The following is a bail bond contract/indemnity agreement between you (as the defendant or indemnitor(s)), Two Jinn, Inc. dba
Aladdin Bail Bonds ("Aladdin"), and SEAVIEW INSURANCE COMPANY ("SEAVIEW")(collectively "we" and/or "us"). It
provides for, among other things, the consequences to you as a result of failing to pay the bail bond premium and/or the defendant's
failure to appear in court as ordered.
In order to keep the bail bond in force and the defendant out of jail, you must (1) pay the bail bond premium, and (2) ensure that the
defendant appears in court on the required dates. If a bail bond premium is not fully paid and/or the defendant does not appear in
court as ordered, we may surrender the defendant back to the custody of the court and charge you for all expenses incurred in
locating, capturing, and returning the defendant to court. Additionally, IN THE EVENT WE ARE UNABLE TO RETURN THE
DEFENDANT TO COURT WITHIN THE TIME PRESCRIBED BY LAW AND MUST PAY THE FULL PENAL AMOUNT
OF THE BAIL BOND, YOU ARE RESPONSIBLE TO REIMBURSE US FOR ALL AMOUNTS WE MUST PAY,
INCLUDING THE PENAL SUM OF THE BOND, INVESTIGATION COSTS, COURT COSTS, AND ATTORNEYS' FEES
(INCLUDING ATTORNEYS’ FEES INCURRED RECOVERING THESE AMOUNTS FROM YOU). In such an event, any
premium amounts paid by you will not offset your obligation for the full penal amount of the bond.
Please carefully review each of the terms and conditions of this bail bond contract/indemnity agreement.
SV-0100-02 I 10/22/2021
SEAVIEW INSURANCE COMPANY
INDEMNITY AGREEMENT FOR SURETY BAIL BOND
This Indemnity Agreement ("Agreement") is effective as of October 22, 2021. In consideration for the executing, arranging, and continuance of
the undertaking of bail for Watson, Teresa _A (the "Principal" or "Defendant") in the penal amount of $50,000.00
("Bail Bond"), the undersigned
Indemnitor(s) agrees to pay the Bail Bond premium(s) and to indemnify Aladdin Bail Bonds ("Aladdin") and SEAVIEW
INSURANCE COMPANY
("Surety") as follows:
1. General Conditions of Bail. As a further condition to Aladdin and/or Surety maintaining the Bail Bond, Indemnitor(s) and
Principal/Defendant agree that their failure to satisfy any of the following conditions constitutes a breach
of this Agreement and may result in
Defendant's surrender to custody without return of premium:
(a2) THE DEFENDANT MUST RETURN TO ALADDIN'S OFFICE IMMEDIATELY UPON RELEASE FROM JAIL. Failure to do so may
result in the
Defendant being surrendered back to custody in accordance with paragraph 6 below ("Surrender"), and additional fees may be
owed pursuant to paragraph 5 below ("Indemnification").
(b) The Defendant must APPEAR AT ALL COURT DATES in person as ordered by the court.
(c) If the Defendant fails to appear in court, he/she must contact Aladdin immediately for possible bail bond reinstatement.
If reinstatement
is approved by Aladdin, the Defendant must submit the reinstatement document provided by Aladdin to the clerk of
the court immediately or it
will otherwise be void. Please be advised that under these circumstances the Defendant's warrant is still active until he/she has appeared
in
court and the judge has recalled the warrant.
(d) As more fully set out in paragraph 5 below, the Defendant and Indemnitor(s) are responsible for any and all expenses incurred by
Aladdin or its Surety as a result of the Defendant's failure to appear for scheduled court dates.
* (ec) The Defendant and Indemnitor(s) must notify Aladdin if they (or any of them) change their residence address, business address,
telephone numbers, or employment.
(f) The Defendant and Indemnitors(s) shall remain liable hereunder until such time as the Bail Bond is exonerated and Aladdin and/or Surety
are fully indemnified for any losses pursuant to paragraph 5 below ("Indemnification").
(g) Supervised Bail. The Defendant may be placed on supervised bail at any time in Aladdin's
sole discretion. If placed on supervised bail,
Defendant must check in with Aladdin or its designee as requested by Aladdin.
2. Premium. Indemmnitor(s) shall pay Aladdin $5,000.00 for continuance of the Bail Bond (the "Premium"). The Premium is fully eamed upon the
release of the Principal. The fact that the Principal may have been improperly arrested, or his bail reduced, or his case dismissed,
shall not
obligate the return of any portion of said Premium. In the event any Premium due is not paid upon demand, Aladdin and/or Surety maintain the
right to surrender the Principal as provided by law, in addition to exercising any other available
legal remedies arising from this Agreement. Any
delinquent amounts due hereunder shall bear interest at the maximum rate allowed by law. Time is of the
essence as to all payments.
SV-0100-02
10/22/2021
N
INDEMNITY AGREEMENT FOR SURETY Bait BOND
3. Premium Payment
Schedule _& Promissory Note. The Principal and/or Indemmnitor(s) promises to pay to the order of
Aladdin Bail Bonds, the Premium described in paragraph 2 as follows:
Total Down Payment: $1,200.00
Current Balance: $3,815.00
1 Down Payment payment(s) of $1,200.00 on 10/22/2021.
1 Additional Down Payment payment(s) of $500.00 on 11/1/2021.
13 Monthly payment(s) of $250.00, starting on 12/1/2021.
and / or in the following manner:
If Principal and/or Indemnitor(s) fails to make a payment hereunder, the entire Premium balance shall be due and payable to
- Aladdin immediately. In the event legal action is commenced to collect the Premium balance or any portion thereof, Principal
and/or Indemnitor(s) promises to pay such additional sums as the court may adjudge reasonable as attorneys fees and costs.
Principal and/or Indmenitor(s) understands this Agreement is a credit transaction, and as such, authorizes Aladdin to review
Principal and/or Indemnitor(s)’ credit history via credit reporting agency inquiries.
4.__Collateral. Aladdin and/or Surety may require Indemnitor(s) to deposit money or other property as collateral in an amount or
value which
Aladdin and/or Surety determines, in their sole and absolute discretion, sufficient to protect against the risk of
Bail Bond forfeiture and/or
summary judgment ("Collateral"). If as a result of judicial action bail is increased, Aladdin and/or Surety may demand such additional Collateral
as they determine necessary to protect against the increased risk. In the event Indemnitor(s) or Principal misrepresents or conceals information
which would have been material to Aladdin and/or Surety’s decision to execute the Bail Bond, or otherwise
takes any action which creates an
increase in the risk of Bail Bond forfeiture, Indemnitor(s) shall, upon demand, deposit Collateral in an amount or value equivalent
to the full penal
amount of the Bail Bond. Indemnitor(s) authorizes Aladdin and/or Surety to levy upon Collateral in any lawful manner to recover sums
due under
this Agreement for unpaid Premium, indemnity obligations, fees, costs, expenses and/or other liabilities
for which the Indemnitor(s) has agreed to
indemnify Aladdin and/or Surety hereunder. Following exoneration or other final disposition of the Bail Bond and following the application of
Collateral to satisfy Indemnitor(s) obligations, any excess Collateral shall be immediately retumed to the depositor.
:
SV-0100-02 3 10/22/2021
INDEMNITY AGREEMENT FOR SURETY BAn. BOND
5. Indemnification. To the fullest extent permitted by law, Indemnitor(s) agrees to indemnify and reimburse Aladdin and/or Surety for any and all
losses, damages, judgments, attorneys’ fees (including the reasonable value of services performed by Aladdin and/or Surety’s in-house legal
staff, claims staff and/or investigative staff), costs, expenses, or liability of any kind whatsoever arising out of or relating to the following:
(1) the Principal and/or Indemnitor(s)'s breach of any of the terms and conditions of this Agreement;
(2) false or misleading information provided by Principal/Indemnitor(s) in the Bail Bond Application (the contents of which are
incorporated herein by reference);
(3) searching for, recapturing, and/or returning the Principal to custody prior to the entry of summary judgment on the Bail Bond;
(4) making application to a court for an order to vacate or set aside the order of Bail Bond forfeiture or summary judgment entered thereon;
(5) payment of a judgment on the forfeiture of the Bail Bond;
(6) any action or proceeding commenced by Aladdin and/or Surety to enforce this Agreement; and
(7) any expenses incurred by Aladdin and/or Surety as a result of the Principal's refusal to cooperate with the arrangment and/or
execution of the Bail Bond (or any renewal or substitution thereof) once Aladdin and/or Surety have initiated arrangments with the
court and/or detention facility.
Principal and Indemnitor(s) understand and agree that Aladdin or Surety's own active or passive negligence in connection with investigation and
handling of claims forfeitures shall not in any way cancel or limit Principal and Indemnitor(s) indemnity obligations. Defendant and
Indemnitor(s) fully assume the risk of the Defendant's non-appearance. Indemmitor(s) futher agrees to fully cooperate and assist Aladdin and/or
Surety in securing the release and exoneration of the Bail Bond, including the surrender of the Principal to court should Aladdin and/or Surety
deem such action advisable.
6. Surrender. In the event of Bail Bond forfeiture, or the Principal and/or Indemmnitor(s)'s failure to abide by the terms of this Agreement,
Aladdin and/or Surety maintain the right to surrender the Principal as provided by law. Aladdin and/or Surety shall not surrender the Principal to
custody prior to the time specified in the Bail Bond for the appearance of the Principal, or prior to any occasion when the presence of the
Principal in court is lawfully required, without first returning all Premium paid, unless as a result of judicial action, information concealed or
misrepresented by the Principal and/or Indemnitor(s), or other reasonable cause, any one of which was material to the risk to be assumed by
Aladdin and/or Surety, the risk was substantially mcreased.
7.__Indemnitor Representations & Warranties. Indemmitor(s) represents and warrants that (1) all statements and/or information provided on or
in connection with the Bail Bond Application are true and accurate; (2) Indemnitor(s) will advise Aladdin and/or Surety of any change in such
information within 48 hours of learning of the change (including but not limited to (i) changes of address or employment of either the Principal or
Indemnitor(s), or (ii) any other material change in circumstances), and that Indemnitor's failure to so advise shall be reasonable cause for the
immediate surrender of the Principal; (3) Indemnitor(s) has read and knows the contents of the Bail Bond Agreement and this Agreement, and has
received copies of each document included therein; (4) Indemnitor(s) is the true and lawful owner of all Collateral or other property set forth in
the Bail Bond Application, and Indemnitor(s) shall not transfer or otherwise encumber said property without first satisfying all outstanding
liability for the Bail Bond.
8 Additional Bail Bonds. In the event additional Aladdin bail bonds are executed for the same charge for which the above mentioned Bail Bond
was executed, or any other charge arising out of the same criminal matter, this Agreement shall apply equally to those bonds.
9. Joint _& Several Obligations. The obligations hereunder are joint and several. Indemnitor(s) expressly waives the benefits of any law
requiring Aladdin and/or Surety to seek available remedies from the Principal prior to proceeding against Indemnitor(s) hereunder.
10. Governing Law. This Agreement shall be governed, construed, and interpreted in accordance with the laws of the State of California.
SV-0100-02 4 10/22/2021
INDEMNITY AGREEMENT FOR SURETY BAi~ BOND
li. Yntegrated Agreement. Indemnitor(s) acknowledges and agrees that no promises or representations were made to Principal
or Indemnitor(s)
which do not appear written herein and that this Agreement contains the entire agreement between
Principal/Indemnitor(s) and Aladdin on the
subject matter hereof. Principal/Indemnitor(s) further acknowledges and agrees that all prior statements, agreements, understandings or
promises, written or oral, are superceded by this Agreement. This Agreement may only be modified by a writing signed by authorized
Tepresentatives of the parties.
IN WITNESS THEREOF, Principal/Indemnitor(s) acknowledges that in executing and continuing the Bail
Bond, Aladdin and/or Surety is relying
on this Agreement and the statements made by Principal/Indemnitor(s) in connection herewith, and as such, the undersigned
Principal/Indemnitor(s) enters into this Agreement by signing below.
NOTICE TO COSIGNER (Traduccion en Ingles Se Requiere Por La Ley)
You are being asked to guarantee this debt. Think carefully before you do. If the borrower doesn't pay the debt, you will have to.
Be sure you can afford to pay if you have to, and that you want to accept this responsibility.
You may have to pay up to the full amount of the debt if the borrower does not pay. You may also have to pay late fees or
collection costs, which increases this amount.
The creditor can ‘collect this debt from you without first trying to collect from the borrower. The creditor can use the same collection
methods against you that can be used against the borrower, such as suing you, gamishing your wages, etc. If this debt is ever in
default, that fact may become part of your credit record.
This notice is not the contract that makes you liable for the debt.
AVISO PARA EL FIADOR (Spanish Translation Required By Law)
Se le esta pidiendo que garantice esta deuda. Piénselo con cuidado antes de ponerse de acuerdo. Si
la persona que ha pedido este préstamo
no paga la deuda, usted tendrd que pagarla. Esté seguro de que usted podra pagar si sea obligado a
pagarla y de que usted desea aceptar la
" responsabilidad.
Si la persona que ha pedido el préstamo no paga la deuda, es posible que usted tenga que pagar Ja suma total de la deuda,
mas los cargos
Por tardarse en el pago 0 el costo de cobranza, lo cual aumenta el total de esta suma.
El acreedor (financiero) puede cobrarle a usted sin, primeramente, tratar de cobrarle el deudor. Los mismos metodos
de cobranza que
pueden usarse contra el deudor, podran usarse contra usted, tales como presenter una demanda en corte,
quitar parte de su sueldo, etc. Si
alguna vez no se cumpla con la obligacién de pagar esta deuda, se puede incluir esa informacién en Ia historia de
credito de usted.
Este aviso no es el contrato mismo en que se le echa a usted la responsabilidad de la deuda.
“wy f _
indemnitor hg P / | 3
SIGNATURE A all 8 y —“, NAME Davison, Raymond William
Lf
Defendant
SIGNATURE
“ SEE ATTACHED
E DATE 10/22/2021
NAME Watson, Teresa A
SV-0100-02 5 10/22/2021
Aladdin Bail Bonds
715 9TH STREET, #105
Sacramento, CA 95814 Retail Installment Contract
(916) 444-2700
SEAVIEW INSURANCE COMPANY
INDEMNITY AGREEMENT
FOR
SURETY BAIL BOND
RECITAL
The following is a bail bond contract/indemnity agreement between you (as the defendant or indemnitor(s)), Two Jinn, Inc. dba
Aladdin Bail Bonds ("Aladdin"), and SEAVIEW INSURANCE COMPANY ("SEAVIEW")(collectively "we" and/or “us"). It
provides for, among other things, the consequences to you as a result of failing to pay the bail bond premium and/or the defendant's
failure to appear in court as ordered.
In order to keep the bail bond in force and the defendant out of jail, you must (1) pay the bail bond premium, and (2) ensure that the
defendant appears in court on the required dates. If a bail bond premium is not fully paid and/or the defendant does not appear in
court as ordered, we may surrender the defendant back to the custody of the court and charge you for all expenses incurred in
locating, capturing, and returning the defendant to court. Additionally, IN THE EVENT WE ARE UNABLE TO RETURN THE
DEFENDANT TO COURT WITHIN THE TIME PRESCRIBED BY LAW AND MUST PAY THE FULL PENAL AMOUNT
OF THE BAIL BOND, YOU ARE RESPONSIBLE TO REIMBURSE US FOR ALL AMOUNTS WE MUST PAY,
INCLUDING THE PENAL SUM OF THE BOND, INVESTIGATION COSTS, COURT COSTS, AND ATTORNEYS’ FEES
(INCLUDING ATTORNEYS' FEES INCURRED RECOVERING THESE AMOUNTS FROM YOU). In such an event, any
premium amounts paid by you will not offset your obligation for the full penal amount of the bond.
Please carefully review each of the terms and conditions of this bail bond contract/indemnity agreement.
SV-0100-02 1 10/22/2021
sEAVIEW INSURANCE COMPANY
INDEMNITY AGREEMENT FOR SURETY BAIL BOND
This Indemnity Agreement ("Agreement") is effective as of October 22, 2021. In consideration for the executing, arranging, and continuance of
the undertaking of bail for Watson, Teresa A (the "Principal" or "Defendant") in the penal amount of $50,000.00 ("Bail Bond"), the undersigned
Indemnitor(s) agrees to pay the Bail Bond premium(s) and to indemnify Aladdin Bail Bonds ("Aladdin") and SEAVIEW JNSURANCE COMPANY
("Surety") as follows:
1. General Conditions of Bail. As a further condition to Aladdin and/or Surety maintaining the Bail Bond, Indemmnitor(s) and
Principal/Defendant agree that their failure to satisfy any of the following conditions constitutes a breach of this Agreement and may result in
Defendant's surrender to custody without return of premium:
(a) THE DEFENDANT MUST RETURN TO ALADDIN'S OFFICE IMMEDIATELY UPON RELEASE FROM JAIL. Failure to do so may
result in the Defendant being surrendered back to custody in accordance with paragraph 6 below ("Surrender"), and additional fees may be
owed pursuant to paragraph 5 below ("Indemnification").
(b) The Defendant must APPEAR AT ALL COURT DATES in person as ordered by the court.
(c) If the Defendant fails to appear in court, he/she must contact Aladdin immediately for possible bail bond reinstatement. If reinstatement
is approved by Aladdin, the Defendant must submit the reinstatement document provided by Aladdin to the clerk of the court immediately or it
will otherwise be void. Please be advised that under these circumstances the Defendant's warrant is still active until he/she bas appeared in
court and the judge has recalled the warrant.
(4) As more fully set out in paragraph 5 below, the Defendant and Indemnitor(s) are responsible for any and all expenses incurred by
Aladdin or its Surety as a result of the Defendant's failure to appear for scheduled court dates.
(e) The Defendant and Indemnitor(s) must notify Aladdin if they (or any of them) change their residence address, business address,
telephone numbers, or employment.
(f) The Defendant and Indemnitors(s) shall remain liable hereunder until such time as the Bail Bond is exonerated and Aladdin and/or Surety
are fully indemnified for any losses pursuant to paragraph 5 below ("Indemnification").
(g) Supervised Bail. The Defendant may be placed on supervised bail at any time in Aladdin's sole discretion. If placed on supervised bail,
Defendant must check in with Aladdin or its designee as requested by Aladdin.
2. Premium. Indemnitor(s) shall pay Aladdin $5.000.00 for continuance of the Bail Bond (the "Premium"). The Premium is fully eared upon the
release of the Principal. The fact that the Principal may have been improperly arrested, or his bail reduced, or his case dismissed, shall not
obligate the return of any portion of said Premium. In the event any Premium due is not paid upon demand, Aladdin and/or Surety maintain the
right to surrender the Principal as provided by law, in addition to exercising any other available legal remedies arising from this Agreement. Any
delinquent amounts due hereunder shall bear interest at the maximum rate allowed by law. Time is of the essence as to all payments.
SV-0100-02 2 10/22/2021
‘ INDE¥ Y AGREEMENT FOR SURETY B BOND
3. Premium Payment Schedule & Promissory Note. The Principal and/or Indemnitor(s) promises to pay to the order of
Aladdin Bail Bonds, the Premium described in paragraph 2 as follows:
Total Down Payment: $1,200.00
Current Balance: $3,815.00
1 Down Payment payment(s) of $1,200.00 on 10/22/2021.
1 Additional Down Payment payment(s) of $500.00 on 11/1/2021.
13 Monthly payment(s) of $250.00, starting on 12/1/2021.
and / or in the following manner:
If Principal and/or Indemnitor(s) fails to make a payment hereunder, the entire Premium balance shall
be due and payable to
Aladdin immediately. In the event legal action is commenced to collect the Premium balance or
any portion thereof, Principal
,and/or Indemnitor(s) promises to pay such additional sums as the court may adjudge reasonable as
attorneys fees and costs.
Principal and/or Indmenitor(s) understands this Agreement is a credit transaction, and as such, authorizes
Aladdin to review
Principal and/or Indemnitor(s)’ credit history via credit reporting agency inquiries.
4. Collateral. Aladdin and/or Surety may require Indemnitor(s) to deposit money or other property
as collateral in an amount or value which
Aladdin and/or Surety determines, in their sole and absolute discretion, sufficient
to protect against the risk of Bail Bond forfeiture and/or
summary judgment ("Collateral"). If as a result of Judicial action bail is increased, Aladdin and/or Surety may demand
such additional Collateral
as they determine necessary to protect against the increased risk. In the event Indemnitor(s) or Principal misrepresents or conceals information
which would have been material to Aladdin and/or Surety's decision to execute the Bail Bond, or otherwise takes any action which creates an
increase in the risk of Bail Bond forfeiture, Indemnitor(s) shall, upon demand,
deposit Collateral in an amount or value equivalent to the full penal
amount of the Bail Bond. Indemnitor(s) authorizes Aladdin and/or Surety to levy upon Collateral in any lawful
manner to recover sums due under
this Agreement for unpaid Premium, indemnity obligations, fees, costs, expenses
and/or other liabilities for which the Indemnitor(s) has agreed to
indemnify Aladdin and/or Surety hereunder. Following exoneration or other final disposition of the Bail Bond and following
the application of
Collateral to satisfy Indemnitor(s) obligations, any excess Collateral shall be immediately
returned to the depositor.
SV-0100-02
3 10/22/2021
. . INDEM* ‘AGREEMENT FOR SURETY B/ 30ND
5. Indemnification. To the fullest extent permitted by law, Indemnitor(s) agrees to indemnify and reimburse Aladdin and/or Surety for any and all
losses, damages, judgments, attomeys' fees (including the reasonable value of services performed by Aladdin and/or Surety's in-house legal
staff, claims staff and/or investigative staff), costs, expenses, or liability of any kind whatsoever arising out of or relating to the following:
(1) the Principal and/or Indemnitor(s)'s breach of any of the terms and conditions of this Agreement;
(2) false or misleading information provided by Principal/Indemnitor(s) in the Bail Bond Application (the contents of which are
incorporated herein by reference);
(3) searching for, recapturing, and/or returning the Principal to custody prior to the entry of summary judgment on the Bail Bond;
(4) making application to a court for an order to vacate or set aside the order of Bail Bond forfeiture or summary judgment entered thereon;
(5) payment of a judgment on the forfeiture of the Bail Bond;
(6) any action or proceeding commenced by Aladdin and/or Surety to enforce this Agreement; and
(7) any expenses incurred by Aladdin and/or Surety as a result of the Principal's refusal to cooperate with the arrangment and/or
execution of the Bail Bond (or any renewal or substitution thereof) once Aladdin and/or Surety have initiated arrangments with the
court and/or detention facility.
Principal and Indemnitor(s) understand and agree that Aladdin or Surety's own active or passive negligence in connection with imvestigation and
handling of claims forfeitures shall not in any way cancel or limit Principal and Indemnitor(s) indemnity obligations. Defendant and
Indemnitor(s) fully assume the risk of the Defendant's non-appearance. Indemmitor(s) futher agrees to fully cooperate and assist Aladdin and/or
Surety im securing the release and exoneration of the Bail Bond, including the surrender of the Principal to court should Aladdin and/or Surety
deem such action advisable.
6. Surrender. In the event of Bail Bond forfeiture, or the Principal and/or Indemnitor(s)'s failure to abide by the terms of this Agreement,
Aladdin and/or Surety maintain the right to surrender the Principal as provided by law. Aladdin and/or Surety shall not surrender the Principal to
custody prior to the time specified in the Bail Bond for the appearance of the Principal, or prior to any occasion when the presence of the
Principal in court is lawfully required, without first returning all Premium paid, unless as a result of judicial action, information conceale
Preview
ed Supertor Court of Calttorntd, Nathan A. Melendrez, SBN 332016 Sacramento Ralph L. Sims, SBN 083880 Melendrez & Sims, A P.C. 40/24/2023 CA DFPI Debt Collector License Number 10427-99 russeit 7700 Irvine Center Drive Suite 820, Irvine, CA 92618-3060 PO Box 54148, Irvine, CA 92619 By , Deputy Telephone: (877) 958-2350 Facsimile: (888) 847-1732 Z23CV011619 File Number: 10102365 Attorney for Plaintiff SUPERIOR COURT, STATE OF CALIFORNIA SACRAMENTO COUNTY, CENTRAL DISTRICT 10 11 12 13 CASE NO.: PLAINTIFF(S): TWO JINN, INC. DBA 14 ALADDIN BAIL BONDS LIMITED JURISDICTION 15 VS COMPLAINT FOR BREACH OF CONTRACT 16 DEFENDANT(S): TERESA WATSON; DEMAND AMOUNT: $3,515.00, 17 RAYMOND WILLIAM DAVISON; plus interest, attorney fees and DOES 1 TO 10, INCLUSIVE costs 18 20 21 PLAINTIFF, TWO JINN, INC. DBA ALADDIN BAIL BONDS, complain of 22 “a DEFENDANTS as follows: 23 PLAINTIFF'S IDENTITY 24 l. PLAINTIFF is a corporation, TWO JINN, INC., duly organized and 25 existing under the laws of the state of California; at all times alleged in this 26 complaint, PLAINTIFF was an active corporation in good standing, doing 27 business under the fictitious business name of ALADDIN BAIL BONDS; 28 Page | COMPLAINT FOR BREACH OF CONTRACT PLAINTIFF has executed, filed, and published the statement required by Chapter 5, Part 3, Division 7 of the California Business and Professions Code, the provisions of which are incorporated in this PARAGRAPH by this reference thereto. DEFINITIONS AND DESIGNATIONS 2. Unless otherwise indicated, a. Words denoting a gender include the masculine, feminine, and neuter forms of those words. b. Words denoting a number include the plural and singular 10 forms of those words. ll c, "AND/OR" means one "thing or another" or "both things," 12 depending on the context; 13 d. “PERSON” includes (without limitation) an individual, a 14 corporation, a partnership, a limited liability company, a joint venture, an 15 association, a joint stock company, a trust, an unincorporated organization, a 16 government, and a political subdivision of a government; 17 e. “CONDUCT” means the behavior of a PERSON and includes 18 both acts and omissions; 19 f. "PLAINTIFF" means the plaintiff in this action, TWO JINN, INC. 20 DBA ALADDIN BAIL BONDS; 21 g. "DEFENDANTS" means all of the defendants in this action, 22 TERESA WATSON; RAYMOND WILLIAM DAVISON; DOES 1 TO 10, INCLUSIVE; 23 h. “DOE DEFENDANTS” means the following defendants in this 24 action: DOE 1 to and including DOE 10; 25 I. "PARAGRAPH" means a paragraph in this complaint; 26 js "REPLEAD" means to replicate the allegations made in a prior 27 PARAGRAPH and incorporate them by reference in another PARAGRAPH; 28 JURISDICTION AND NATURE OF ACTION Page 2 COMPLAINT FOR BREACH OF CONTRACT 3. This is an action for breach of contract for which the Superior Court has original jurisdiction under Article 6 § 10 of the California Constitution; the amount in controversy is $3,515.00; therefore, under Section 85 of the California Code of Civil Procedure, it is a limited civil case. VENUE 4. This is an action that arises from a transaction in which the subject of the transaction is primarily for personal, family, or household purposes; it is not an action on an obligation described in section 1812.10 or section 2984.4 of the California Civil Code or an obligation arising from an unsolicited telephone call or arising from a telephone call or electronic transmission made in response to a solicitation by a seller. 5. On information AND/OR belief, plaintiff alleges that, the above- entitled court is located in the judicial district of the county where the contract was in fact signed by one of the DEFENDANTS or where one of the DEFENDANTS resides at the commencement of this action; therefore, under section 395 of the California Code of Civil Procedure and section 1692i of Title 15 of the United State Codes, the provisions of each of which are incorporated in this PARAGRAPH by this reference thereto, this is the proper court for the commencement and trial of this action. THE DOE DEFENDANTS 6. PLAINTIFF is not aware of the true names of the DOE DEFENDANTS; therefore, pursuant to and in accordance with the provisions of Section 474 of the California Code of Civil Procedure, PLAINTIFF is suing the DOE DEFENDANTS by the fictitious names of DOE 1 to and including DOE 10; and PLAINTIFF will ask this court for leave to amend this complaint to state the true names of the DOE DEFENDANTS after they are discovered. Page 3 COMPLAINT FOR BREACH OF CONTRACT ORGANIZATION OF THE DOE DEFENDANTS tT PLAINTIFF is not aware of the nature of or the basis for the organization (if any) of the DOE DEFENDANTS; therefore, PLAINTIFF will ask this court for leave to amend this complaint to state the facts in this regard after they are discovered. RELATIONSHIP BETWEEN THE DEFENDANTS 8. On information AND/OR belief, PLAINTIFF alleges that, at all times alleged in this complaint, the relationships between the 10 DEFENDANTS were such that each of them is liable for the CONDUCT of the 1 others (e.g., as principal, agent, servant, employee, partner, joint venturer, 12 associate, alter ego, etc.); PLAINTIFF is not aware of the specific facts in this 13 regard; therefore, PLAINTIFF will ask this court for leave to amend this complaint 14 to state those fact after they are discovered. 15 16 FIRST CAUSE OF ACTION 17 AGAINST ALL DEFENDANTS 18 FOR BREACH OF CONTRACT 19 ACCOUNT NUMBER XXXXX-XXX2761 20 9. PLAINTIFF herein REPLEADS all of the allegations made in 21 PARAGRAPHS 1-8. 22 10. Onor about OCTOBER 22, 2021, DEFENDANTS entered into a 23 written contract ("the CONTRACT"), pursuant to which PLAINTIFF arranged for 24 the issuance of a bail bond ("the BAIL BOND") to TERESA WATSON ("the 25 PRINCIPAL"). The CONTRACT contained a Notice to Cosigner. The CONTRACT 26 is in writing, a copy of which is marked for identification as Exhibit "A", attached 27 hereto, and incorporated herein by this reference thereto. 28 11. The CONTRACT provides that DEFENDANTS promise to: Page 4 COMPLAINT FOR BREACH OF CONTRACT a. pay PLAINTIFF for the cost of the BAIL BOND AND/OR any renewal or court-ordered increase thereof; b reimburse PLAINTIFF for actual expenses incurred by PLAINTIFF in connection with the arranging AND/OR the execution of the BAIL BOND AND/OR any renewal or substitution thereof; e. reimburse PLAINTIFF for actual expenses incurred by PLAINTIFF as a result of a breach by the PRINCIPAL of any of the terms for which the BAIL BOND AND/OR the application for the BAIL BOND was written, including (without limitation) any expense AND/OR liability incurred by 10 PLAINTIFF as a result of searching for, apprehending. attempting to apprehend 11 recapturing, attempting to recapture, AND/OR returning the PRINCIPAL to 12 custody AND/OR any expense incurred by PLAINTIFF in securing the release of 13 PLAINTIFF or the surety from all liability under the BAIL BOND ; as used in this 14 PARAGRAPH, "expenses," includes (without limitation) any legal fees incurred 15 by PLAINTIFF in applying for a court order to vacate or set aside an order of 16 forfeiture or a judgment entered thereon; 17 d. pay to PLAINTIFF on demand the penal amount of the BAIL 18 BOND if PLAINTIFF deems such payment necessary to protect itself for any 19 reasonable cause, including (without limitation) the misrepresentation AND/OR 20 concealment of any information that is material to the hazard assumed by 21 PLAINTIFF; 22 12. DEFENDANTS breached the CONTRACT by: 23 a. failing to pay PLAINTIFF for the cost of the BAIL BOND AND/OR 24 a renewal or court-ordered increase thereof; 25 b failing to reimburse PLAINTIFF for actual expenses incurred 26 by PLAINTIFF in connection with the arranging AND/OR the execution of the 27 BAIL BOND AND/OR a renewal or substitution thereof; 28 Page 5 COMPLAINT FOR BREACH OF CONTRACT Cc. failing to reimburse PLAINTIFF for actual expenses incurred by PLAINTIFF as a result of a breach by the PRINCIPAL of any of the terms for which the BAIL BOND AND/OR the application for the BAIL BOND was written; (Collectively, these events are hereinafter called "the BREACH."). 13. The BREACH occurred on or about NOVEMBER 13, 2021. 14. Thereafter, PLAINTIFF made demand on DEFENDANTS to cure the BREACH ("the DEMAND"), but DEFENDANTS have failed and now refused to comply with the DEMAND. 15. Asadirect and proximate result of DEFENDANTS' CONDUCT as 10 alleged in this cause of action, PLAINTIFF has sustained monetary damages in 11 the amount of $3,515.00 plus interest on that amount from NOVEMBER 13, 2021 at 12 the rate of ten (10) percent per annum pursuant to section 3289 of the California 13 Civil Code or as otherwise allowed by law. 14 16. The CONTRACT provides that DEFENDANTS will pay reasonable 15 attorney fees incurred by PLAINTIFF in any action or proceeding arising from 16 the CONTRACT; therefore, in addition to compensatory damages, PLAINTIFF is 17 entitled to recover an award of reasonable attorney fees from DEFENDANTS 18 pursuant to the CONTRACT AND/OR section 1717 of the California Civil Code, 19 the provisions of which are incorporated in this PARAGRAPH by this reference 20 thereto. 21 17. All conditions precedent to performance of the CONTRACT by 22 DEFENDANTS have been performed, waived, excused, discharged, or otherwise 23 extinguished, including (without limitation) performance of the CONTRACT by 24 PLAINTIFF. 25 \\\ 26 WHEREFORE, PLAINTIFF prays for judgment against DEFENDANTS 27 as set forth below. 28 Page 6 COMPLAINT FOR BREACH OF CONTRACT PRAYER PLAINTIFF prays for judgment against DEFENDANTS, and each of them, jointly and severally, as follows: l. On the First Cause of Action for: a. $3,515.00 compensatory damages; b. interest on that sum from NOVEMBER 13, 2021 to be calculated at the rate of ten (10) percent per annum pursuant to section 3289 of the California Civil Code or as otherwise allowed by law; é. reasonable attorney fees; 10 d. all costs of suit; and 1] e. such other relief as the court deems appropriate; 12 13 Dated: October 18, 2023 Melendrez & Sims, A P.C. Attorney for P 14 15 By [ ] Ralph L. Sims 16 [xx] Nathan A. Melendrez 17 18 19 20 2] 22 23 24 25 26 27 28 Page 7 COMPLAINT FOR BREACH OF CONTRACT EXHIBIT "A" (CONTRACT) EXHIBIT "A" (CONTRACT) EXHIBIT "A" (CONTRACT) Aladdin Bail Bonds 715 9TH STREET, #105 Sacramento, CA 95814 Retail Installment Contract (916) 444-2700 SEAVIEW INSURANCE COMPANY INDEMNITY AGREEMENT FOR SURETY BAIL BOND RECITAL The following is a bail bond contract/indemnity agreement between you (as the defendant or indemnitor(s)), Two Jinn, Inc. dba Aladdin Bail Bonds ("Aladdin"), and SEAVIEW INSURANCE COMPANY ("SEAVIEW")(collectively "we" and/or "us"). It provides for, among other things, the consequences to you as a result of failing to pay the bail bond premium and/or the defendant's failure to appear in court as ordered. In order to keep the bail bond in force and the defendant out of jail, you must (1) pay the bail bond premium, and (2) ensure that the defendant appears in court on the required dates. If a bail bond premium is not fully paid and/or the defendant does not appear in court as ordered, we may surrender the defendant back to the custody of the court and charge you for all expenses incurred in locating, capturing, and returning the defendant to court. Additionally, IN THE EVENT WE ARE UNABLE TO RETURN THE DEFENDANT TO COURT WITHIN THE TIME PRESCRIBED BY LAW AND MUST PAY THE FULL PENAL AMOUNT OF THE BAIL BOND, YOU ARE RESPONSIBLE TO REIMBURSE US FOR ALL AMOUNTS WE MUST PAY, INCLUDING THE PENAL SUM OF THE BOND, INVESTIGATION COSTS, COURT COSTS, AND ATTORNEYS' FEES (INCLUDING ATTORNEYS’ FEES INCURRED RECOVERING THESE AMOUNTS FROM YOU). In such an event, any premium amounts paid by you will not offset your obligation for the full penal amount of the bond. Please carefully review each of the terms and conditions of this bail bond contract/indemnity agreement. SV-0100-02 I 10/22/2021 SEAVIEW INSURANCE COMPANY INDEMNITY AGREEMENT FOR SURETY BAIL BOND This Indemnity Agreement ("Agreement") is effective as of October 22, 2021. In consideration for the executing, arranging, and continuance of the undertaking of bail for Watson, Teresa _A (the "Principal" or "Defendant") in the penal amount of $50,000.00 ("Bail Bond"), the undersigned Indemnitor(s) agrees to pay the Bail Bond premium(s) and to indemnify Aladdin Bail Bonds ("Aladdin") and SEAVIEW INSURANCE COMPANY ("Surety") as follows: 1. General Conditions of Bail. As a further condition to Aladdin and/or Surety maintaining the Bail Bond, Indemnitor(s) and Principal/Defendant agree that their failure to satisfy any of the following conditions constitutes a breach of this Agreement and may result in Defendant's surrender to custody without return of premium: (a2) THE DEFENDANT MUST RETURN TO ALADDIN'S OFFICE IMMEDIATELY UPON RELEASE FROM JAIL. Failure to do so may result in the Defendant being surrendered back to custody in accordance with paragraph 6 below ("Surrender"), and additional fees may be owed pursuant to paragraph 5 below ("Indemnification"). (b) The Defendant must APPEAR AT ALL COURT DATES in person as ordered by the court. (c) If the Defendant fails to appear in court, he/she must contact Aladdin immediately for possible bail bond reinstatement. If reinstatement is approved by Aladdin, the Defendant must submit the reinstatement document provided by Aladdin to the clerk of the court immediately or it will otherwise be void. Please be advised that under these circumstances the Defendant's warrant is still active until he/she has appeared in court and the judge has recalled the warrant. (d) As more fully set out in paragraph 5 below, the Defendant and Indemnitor(s) are responsible for any and all expenses incurred by Aladdin or its Surety as a result of the Defendant's failure to appear for scheduled court dates. * (ec) The Defendant and Indemnitor(s) must notify Aladdin if they (or any of them) change their residence address, business address, telephone numbers, or employment. (f) The Defendant and Indemnitors(s) shall remain liable hereunder until such time as the Bail Bond is exonerated and Aladdin and/or Surety are fully indemnified for any losses pursuant to paragraph 5 below ("Indemnification"). (g) Supervised Bail. The Defendant may be placed on supervised bail at any time in Aladdin's sole discretion. If placed on supervised bail, Defendant must check in with Aladdin or its designee as requested by Aladdin. 2. Premium. Indemmnitor(s) shall pay Aladdin $5,000.00 for continuance of the Bail Bond (the "Premium"). The Premium is fully eamed upon the release of the Principal. The fact that the Principal may have been improperly arrested, or his bail reduced, or his case dismissed, shall not obligate the return of any portion of said Premium. In the event any Premium due is not paid upon demand, Aladdin and/or Surety maintain the right to surrender the Principal as provided by law, in addition to exercising any other available legal remedies arising from this Agreement. Any delinquent amounts due hereunder shall bear interest at the maximum rate allowed by law. Time is of the essence as to all payments. SV-0100-02 10/22/2021 N INDEMNITY AGREEMENT FOR SURETY Bait BOND 3. Premium Payment Schedule _& Promissory Note. The Principal and/or Indemmnitor(s) promises to pay to the order of Aladdin Bail Bonds, the Premium described in paragraph 2 as follows: Total Down Payment: $1,200.00 Current Balance: $3,815.00 1 Down Payment payment(s) of $1,200.00 on 10/22/2021. 1 Additional Down Payment payment(s) of $500.00 on 11/1/2021. 13 Monthly payment(s) of $250.00, starting on 12/1/2021. and / or in the following manner: If Principal and/or Indemnitor(s) fails to make a payment hereunder, the entire Premium balance shall be due and payable to - Aladdin immediately. In the event legal action is commenced to collect the Premium balance or any portion thereof, Principal and/or Indemnitor(s) promises to pay such additional sums as the court may adjudge reasonable as attorneys fees and costs. Principal and/or Indmenitor(s) understands this Agreement is a credit transaction, and as such, authorizes Aladdin to review Principal and/or Indemnitor(s)’ credit history via credit reporting agency inquiries. 4.__Collateral. Aladdin and/or Surety may require Indemnitor(s) to deposit money or other property as collateral in an amount or value which Aladdin and/or Surety determines, in their sole and absolute discretion, sufficient to protect against the risk of Bail Bond forfeiture and/or summary judgment ("Collateral"). If as a result of judicial action bail is increased, Aladdin and/or Surety may demand such additional Collateral as they determine necessary to protect against the increased risk. In the event Indemnitor(s) or Principal misrepresents or conceals information which would have been material to Aladdin and/or Surety’s decision to execute the Bail Bond, or otherwise takes any action which creates an increase in the risk of Bail Bond forfeiture, Indemnitor(s) shall, upon demand, deposit Collateral in an amount or value equivalent to the full penal amount of the Bail Bond. Indemnitor(s) authorizes Aladdin and/or Surety to levy upon Collateral in any lawful manner to recover sums due under this Agreement for unpaid Premium, indemnity obligations, fees, costs, expenses and/or other liabilities for which the Indemnitor(s) has agreed to indemnify Aladdin and/or Surety hereunder. Following exoneration or other final disposition of the Bail Bond and following the application of Collateral to satisfy Indemnitor(s) obligations, any excess Collateral shall be immediately retumed to the depositor. : SV-0100-02 3 10/22/2021 INDEMNITY AGREEMENT FOR SURETY BAn. BOND 5. Indemnification. To the fullest extent permitted by law, Indemnitor(s) agrees to indemnify and reimburse Aladdin and/or Surety for any and all losses, damages, judgments, attorneys’ fees (including the reasonable value of services performed by Aladdin and/or Surety’s in-house legal staff, claims staff and/or investigative staff), costs, expenses, or liability of any kind whatsoever arising out of or relating to the following: (1) the Principal and/or Indemnitor(s)'s breach of any of the terms and conditions of this Agreement; (2) false or misleading information provided by Principal/Indemnitor(s) in the Bail Bond Application (the contents of which are incorporated herein by reference); (3) searching for, recapturing, and/or returning the Principal to custody prior to the entry of summary judgment on the Bail Bond; (4) making application to a court for an order to vacate or set aside the order of Bail Bond forfeiture or summary judgment entered thereon; (5) payment of a judgment on the forfeiture of the Bail Bond; (6) any action or proceeding commenced by Aladdin and/or Surety to enforce this Agreement; and (7) any expenses incurred by Aladdin and/or Surety as a result of the Principal's refusal to cooperate with the arrangment and/or execution of the Bail Bond (or any renewal or substitution thereof) once Aladdin and/or Surety have initiated arrangments with the court and/or detention facility. Principal and Indemnitor(s) understand and agree that Aladdin or Surety's own active or passive negligence in connection with investigation and handling of claims forfeitures shall not in any way cancel or limit Principal and Indemnitor(s) indemnity obligations. Defendant and Indemnitor(s) fully assume the risk of the Defendant's non-appearance. Indemmitor(s) futher agrees to fully cooperate and assist Aladdin and/or Surety in securing the release and exoneration of the Bail Bond, including the surrender of the Principal to court should Aladdin and/or Surety deem such action advisable. 6. Surrender. In the event of Bail Bond forfeiture, or the Principal and/or Indemmnitor(s)'s failure to abide by the terms of this Agreement, Aladdin and/or Surety maintain the right to surrender the Principal as provided by law. Aladdin and/or Surety shall not surrender the Principal to custody prior to the time specified in the Bail Bond for the appearance of the Principal, or prior to any occasion when the presence of the Principal in court is lawfully required, without first returning all Premium paid, unless as a result of judicial action, information concealed or misrepresented by the Principal and/or Indemnitor(s), or other reasonable cause, any one of which was material to the risk to be assumed by Aladdin and/or Surety, the risk was substantially mcreased. 7.__Indemnitor Representations & Warranties. Indemmitor(s) represents and warrants that (1) all statements and/or information provided on or in connection with the Bail Bond Application are true and accurate; (2) Indemnitor(s) will advise Aladdin and/or Surety of any change in such information within 48 hours of learning of the change (including but not limited to (i) changes of address or employment of either the Principal or Indemnitor(s), or (ii) any other material change in circumstances), and that Indemnitor's failure to so advise shall be reasonable cause for the immediate surrender of the Principal; (3) Indemnitor(s) has read and knows the contents of the Bail Bond Agreement and this Agreement, and has received copies of each document included therein; (4) Indemnitor(s) is the true and lawful owner of all Collateral or other property set forth in the Bail Bond Application, and Indemnitor(s) shall not transfer or otherwise encumber said property without first satisfying all outstanding liability for the Bail Bond. 8 Additional Bail Bonds. In the event additional Aladdin bail bonds are executed for the same charge for which the above mentioned Bail Bond was executed, or any other charge arising out of the same criminal matter, this Agreement shall apply equally to those bonds. 9. Joint _& Several Obligations. The obligations hereunder are joint and several. Indemnitor(s) expressly waives the benefits of any law requiring Aladdin and/or Surety to seek available remedies from the Principal prior to proceeding against Indemnitor(s) hereunder. 10. Governing Law. This Agreement shall be governed, construed, and interpreted in accordance with the laws of the State of California. SV-0100-02 4 10/22/2021 INDEMNITY AGREEMENT FOR SURETY BAi~ BOND li. Yntegrated Agreement. Indemnitor(s) acknowledges and agrees that no promises or representations were made to Principal or Indemnitor(s) which do not appear written herein and that this Agreement contains the entire agreement between Principal/Indemnitor(s) and Aladdin on the subject matter hereof. Principal/Indemnitor(s) further acknowledges and agrees that all prior statements, agreements, understandings or promises, written or oral, are superceded by this Agreement. This Agreement may only be modified by a writing signed by authorized Tepresentatives of the parties. IN WITNESS THEREOF, Principal/Indemnitor(s) acknowledges that in executing and continuing the Bail Bond, Aladdin and/or Surety is relying on this Agreement and the statements made by Principal/Indemnitor(s) in connection herewith, and as such, the undersigned Principal/Indemnitor(s) enters into this Agreement by signing below. NOTICE TO COSIGNER (Traduccion en Ingles Se Requiere Por La Ley) You are being asked to guarantee this debt. Think carefully before you do. If the borrower doesn't pay the debt, you will have to. Be sure you can afford to pay if you have to, and that you want to accept this responsibility. You may have to pay up to the full amount of the debt if the borrower does not pay. You may also have to pay late fees or collection costs, which increases this amount. The creditor can ‘collect this debt from you without first trying to collect from the borrower. The creditor can use the same collection methods against you that can be used against the borrower, such as suing you, gamishing your wages, etc. If this debt is ever in default, that fact may become part of your credit record. This notice is not the contract that makes you liable for the debt. AVISO PARA EL FIADOR (Spanish Translation Required By Law) Se le esta pidiendo que garantice esta deuda. Piénselo con cuidado antes de ponerse de acuerdo. Si la persona que ha pedido este préstamo no paga la deuda, usted tendrd que pagarla. Esté seguro de que usted podra pagar si sea obligado a pagarla y de que usted desea aceptar la " responsabilidad. Si la persona que ha pedido el préstamo no paga la deuda, es posible que usted tenga que pagar Ja suma total de la deuda, mas los cargos Por tardarse en el pago 0 el costo de cobranza, lo cual aumenta el total de esta suma. El acreedor (financiero) puede cobrarle a usted sin, primeramente, tratar de cobrarle el deudor. Los mismos metodos de cobranza que pueden usarse contra el deudor, podran usarse contra usted, tales como presenter una demanda en corte, quitar parte de su sueldo, etc. Si alguna vez no se cumpla con la obligacién de pagar esta deuda, se puede incluir esa informacién en Ia historia de credito de usted. Este aviso no es el contrato mismo en que se le echa a usted la responsabilidad de la deuda. “wy f _ indemnitor hg P / | 3 SIGNATURE A all 8 y —“, NAME Davison, Raymond William Lf Defendant SIGNATURE “ SEE ATTACHED E DATE 10/22/2021 NAME Watson, Teresa A SV-0100-02 5 10/22/2021 Aladdin Bail Bonds 715 9TH STREET, #105 Sacramento, CA 95814 Retail Installment Contract (916) 444-2700 SEAVIEW INSURANCE COMPANY INDEMNITY AGREEMENT FOR SURETY BAIL BOND RECITAL The following is a bail bond contract/indemnity agreement between you (as the defendant or indemnitor(s)), Two Jinn, Inc. dba Aladdin Bail Bonds ("Aladdin"), and SEAVIEW INSURANCE COMPANY ("SEAVIEW")(collectively "we" and/or “us"). It provides for, among other things, the consequences to you as a result of failing to pay the bail bond premium and/or the defendant's failure to appear in court as ordered. In order to keep the bail bond in force and the defendant out of jail, you must (1) pay the bail bond premium, and (2) ensure that the defendant appears in court on the required dates. If a bail bond premium is not fully paid and/or the defendant does not appear in court as ordered, we may surrender the defendant back to the custody of the court and charge you for all expenses incurred in locating, capturing, and returning the defendant to court. Additionally, IN THE EVENT WE ARE UNABLE TO RETURN THE DEFENDANT TO COURT WITHIN THE TIME PRESCRIBED BY LAW AND MUST PAY THE FULL PENAL AMOUNT OF THE BAIL BOND, YOU ARE RESPONSIBLE TO REIMBURSE US FOR ALL AMOUNTS WE MUST PAY, INCLUDING THE PENAL SUM OF THE BOND, INVESTIGATION COSTS, COURT COSTS, AND ATTORNEYS’ FEES (INCLUDING ATTORNEYS' FEES INCURRED RECOVERING THESE AMOUNTS FROM YOU). In such an event, any premium amounts paid by you will not offset your obligation for the full penal amount of the bond. Please carefully review each of the terms and conditions of this bail bond contract/indemnity agreement. SV-0100-02 1 10/22/2021 sEAVIEW INSURANCE COMPANY INDEMNITY AGREEMENT FOR SURETY BAIL BOND This Indemnity Agreement ("Agreement") is effective as of October 22, 2021. In consideration for the executing, arranging, and continuance of the undertaking of bail for Watson, Teresa A (the "Principal" or "Defendant") in the penal amount of $50,000.00 ("Bail Bond"), the undersigned Indemnitor(s) agrees to pay the Bail Bond premium(s) and to indemnify Aladdin Bail Bonds ("Aladdin") and SEAVIEW JNSURANCE COMPANY ("Surety") as follows: 1. General Conditions of Bail. As a further condition to Aladdin and/or Surety maintaining the Bail Bond, Indemmnitor(s) and Principal/Defendant agree that their failure to satisfy any of the following conditions constitutes a breach of this Agreement and may result in Defendant's surrender to custody without return of premium: (a) THE DEFENDANT MUST RETURN TO ALADDIN'S OFFICE IMMEDIATELY UPON RELEASE FROM JAIL. Failure to do so may result in the Defendant being surrendered back to custody in accordance with paragraph 6 below ("Surrender"), and additional fees may be owed pursuant to paragraph 5 below ("Indemnification"). (b) The Defendant must APPEAR AT ALL COURT DATES in person as ordered by the court. (c) If the Defendant fails to appear in court, he/she must contact Aladdin immediately for possible bail bond reinstatement. If reinstatement is approved by Aladdin, the Defendant must submit the reinstatement document provided by Aladdin to the clerk of the court immediately or it will otherwise be void. Please be advised that under these circumstances the Defendant's warrant is still active until he/she bas appeared in court and the judge has recalled the warrant. (4) As more fully set out in paragraph 5 below, the Defendant and Indemnitor(s) are responsible for any and all expenses incurred by Aladdin or its Surety as a result of the Defendant's failure to appear for scheduled court dates. (e) The Defendant and Indemnitor(s) must notify Aladdin if they (or any of them) change their residence address, business address, telephone numbers, or employment. (f) The Defendant and Indemnitors(s) shall remain liable hereunder until such time as the Bail Bond is exonerated and Aladdin and/or Surety are fully indemnified for any losses pursuant to paragraph 5 below ("Indemnification"). (g) Supervised Bail. The Defendant may be placed on supervised bail at any time in Aladdin's sole discretion. If placed on supervised bail, Defendant must check in with Aladdin or its designee as requested by Aladdin. 2. Premium. Indemnitor(s) shall pay Aladdin $5.000.00 for continuance of the Bail Bond (the "Premium"). The Premium is fully eared upon the release of the Principal. The fact that the Principal may have been improperly arrested, or his bail reduced, or his case dismissed, shall not obligate the return of any portion of said Premium. In the event any Premium due is not paid upon demand, Aladdin and/or Surety maintain the right to surrender the Principal as provided by law, in addition to exercising any other available legal remedies arising from this Agreement. Any delinquent amounts due hereunder shall bear interest at the maximum rate allowed by law. Time is of the essence as to all payments. SV-0100-02 2 10/22/2021 ‘ INDE¥ Y AGREEMENT FOR SURETY B BOND 3. Premium Payment Schedule & Promissory Note. The Principal and/or Indemnitor(s) promises to pay to the order of Aladdin Bail Bonds, the Premium described in paragraph 2 as follows: Total Down Payment: $1,200.00 Current Balance: $3,815.00 1 Down Payment payment(s) of $1,200.00 on 10/22/2021. 1 Additional Down Payment payment(s) of $500.00 on 11/1/2021. 13 Monthly payment(s) of $250.00, starting on 12/1/2021. and / or in the following manner: If Principal and/or Indemnitor(s) fails to make a payment hereunder, the entire Premium balance shall be due and payable to Aladdin immediately. In the event legal action is commenced to collect the Premium balance or any portion thereof, Principal ,and/or Indemnitor(s) promises to pay such additional sums as the court may adjudge reasonable as attorneys fees and costs. Principal and/or Indmenitor(s) understands this Agreement is a credit transaction, and as such, authorizes Aladdin to review Principal and/or Indemnitor(s)’ credit history via credit reporting agency inquiries. 4. Collateral. Aladdin and/or Surety may require Indemnitor(s) to deposit money or other property as collateral in an amount or value which Aladdin and/or Surety determines, in their sole and absolute discretion, sufficient to protect against the risk of Bail Bond forfeiture and/or summary judgment ("Collateral"). If as a result of Judicial action bail is increased, Aladdin and/or Surety may demand such additional Collateral as they determine necessary to protect against the increased risk. In the event Indemnitor(s) or Principal misrepresents or conceals information which would have been material to Aladdin and/or Surety's decision to execute the Bail Bond, or otherwise takes any action which creates an increase in the risk of Bail Bond forfeiture, Indemnitor(s) shall, upon demand, deposit Collateral in an amount or value equivalent to the full penal amount of the Bail Bond. Indemnitor(s) authorizes Aladdin and/or Surety to levy upon Collateral in any lawful manner to recover sums due under this Agreement for unpaid Premium, indemnity obligations, fees, costs, expenses and/or other liabilities for which the Indemnitor(s) has agreed to indemnify Aladdin and/or Surety hereunder. Following exoneration or other final disposition of the Bail Bond and following the application of Collateral to satisfy Indemnitor(s) obligations, any excess Collateral shall be immediately returned to the depositor. SV-0100-02 3 10/22/2021 . . INDEM* ‘AGREEMENT FOR SURETY B/ 30ND 5. Indemnification. To the fullest extent permitted by law, Indemnitor(s) agrees to indemnify and reimburse Aladdin and/or Surety for any and all losses, damages, judgments, attomeys' fees (including the reasonable value of services performed by Aladdin and/or Surety's in-house legal staff, claims staff and/or investigative staff), costs, expenses, or liability of any kind whatsoever arising out of or relating to the following: (1) the Principal and/or Indemnitor(s)'s breach of any of the terms and conditions of this Agreement; (2) false or misleading information provided by Principal/Indemnitor(s) in the Bail Bond Application (the contents of which are incorporated herein by reference); (3) searching for, recapturing, and/or returning the Principal to custody prior to the entry of summary judgment on the Bail Bond; (4) making application to a court for an order to vacate or set aside the order of Bail Bond forfeiture or summary judgment entered thereon; (5) payment of a judgment on the forfeiture of the Bail Bond; (6) any action or proceeding commenced by Aladdin and/or Surety to enforce this Agreement; and (7) any expenses incurred by Aladdin and/or Surety as a result of the Principal's refusal to cooperate with the arrangment and/or execution of the Bail Bond (or any renewal or substitution thereof) once Aladdin and/or Surety have initiated arrangments with the court and/or detention facility. Principal and Indemnitor(s) understand and agree that Aladdin or Surety's own active or passive negligence in connection with imvestigation and handling of claims forfeitures shall not in any way cancel or limit Principal and Indemnitor(s) indemnity obligations. Defendant and Indemnitor(s) fully assume the risk of the Defendant's non-appearance. Indemmitor(s) futher agrees to fully cooperate and assist Aladdin and/or Surety im securing the release and exoneration of the Bail Bond, including the surrender of the Principal to court should Aladdin and/or Surety deem such action advisable. 6. Surrender. In the event of Bail Bond forfeiture, or the Principal and/or Indemnitor(s)'s failure to abide by the terms of this Agreement, Aladdin and/or Surety maintain the right to surrender the Principal as provided by law. Aladdin and/or Surety shall not surrender the Principal to custody prior to the time specified in the Bail Bond for the appearance of the Principal, or prior to any occasion when the presence of the Principal in court is lawfully required, without first returning all Premium paid, unless as a result of judicial action, information conceale