Declaration CCP 1033Cal. Super. - 6th Dist.March 17, 2021Electronically Filed by Superior Court of CA, County of Santa Clara, on 7/8/2021 10:08 AM Reviewed By: D Harris Case #21CV379017 Envelope: 6802682 21CV379017 Santa Clara - Civil D Harris 1o 11 12 ~13 14 15 16 17 18 19 .20 21 22 23 24 25 26 27 28 Adam Brumage, SBN 283 1 80 Maria Bradish, SBN 2883 84 Don Phan-Huy, SBN 309853 Ryota Isozaki, SBN 321040 Denick Uhri, SBN 321 161 Matthew W. Keim, SBN 33 1020 Eric Marquez, SBN 331023 Karlie D. Schafer, SBN 331884 The Moore Law Group, APC 3710 S. Susan St, Suite 210, Santa Ana, CA 92704 ' P.O. Box 25145, Santa Ana, CA 92799-5145 Telephone: (800) 506-2652 Attorneys for Plaintiff, Bank 0f America, N.A SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF SANTA CLARA DOWNTOWN SUPERIOR COURT, LIMITED JURISDICTION Bank of America, N.A. CASE NO. 21CV379017 Plaintiff, DECLARATION IN SUPPORT OF ENTRY OF JUDGMENT RE: COMPLIANCE WITH vs. - C.C.P. SECTION 1033 Trung D Pham, Defendant(s). I, the undersigned, declare: 1. I have personal, first-hand knowledge of the mafiers’set forth herein and, if called as a Witness, could and would competently testify to the following: 2. I am an associate attorney With The Moore .LaW Group, APC, (“TMLG”) attorneys for Plaintiff Bank of America, N.A. I am one of the attorneys responsible for the prosecution of this lawsuit. 3. In connection With my employment With TMLG, I have become thoroughly familiar With the mailing practices and the preparation and maintenance of the electronic data, computer files and other business records which TMLG maintains for accounts it has been retained to collect on for its clients. \OOOQON 1o 11 12 13 14 15 16 17 18 19 20 21' 22 23 24 25 26 27 28‘ 4. TMLG images into its computer system each letter mailed on each account it is retained to colléct on for its clients. The image is created in such a manner t0 capture, in PDF or similar format, a picture of the docmfient that was mailed. The image capture is dated to reflect the date not only of When the image was placed in the file but also the date that the letter was in fact mailed. 5. I have personally reviewed TMLG’s records related to this lawsuit and the account related . thereto that TMLG was retained to collect on and I base my testimony on those records, my personal reviéw of those records and my knowledge ofhow those records are created. Further, the document attached hereto as an Exhibit is a true- and accurate copy of the business records maintained by TMLG. 6. On or about March 3, 2021, TMLG caused t0 be mailed a letter to the defendant advising the defendant of the possibility 0f the filing of a lawsuit and the incurring of litigation costs in connection herewith, a true andporrect copy ofWhich is attached hereto as Exhibit 1. 7. The Small Claims Division of this court does not allow cases to be filed in the division if a party is represented by counsel, therefore this case was filed in the Limited Civil Division. 8. Plaintiff requests that the copy 0f Exhibit 1 éfiached hereto be accepted in lieu 0f the original document. ‘ Ideclare under penalty 0f perjury, under the laws of the State of California, that the foregoing is JUL 0 7 2.021 true and correct and that this declaration was executed on in Santa Ana, California. The Moore Law Group, APC By:W Adam Emmage_ Maria Bradish__ Don Phan-Huy_ Ryota Isozaki_ Derrick Uhri_ Matthew W. KeimfiEric Marquez Karlie D. Schafer_ Attorneys for Plaintiff EXHIBIT 1 *HIIIIIUII‘lllll|||||llllllklllflllllllli\IWIII* . 'l o California Ofiice: %°§a3?§53°: :M00re 3710 s. Susan St, Ste 210 Suite 201 0 _ E" ‘ Santa Ana, CA 92704 .. Phone 714-431-2000 gfigffibfioséggg LaW Group Fax 714-754-9568 Fax 714754-9568 A PMGSS‘ODE' C°m°rafl°n Colorado 051cc: ' d _ 1901 w. Littleton Blvd, Ste 214 Neva aOffice- T011 Free 1-800-506-2652 'Limemn, co 80120 235563695 Blvd- South Mailing Addrew Phone 303-566-6561 , ~ ‘ ° . F 720-278-7794 LasVegas,stglo1 P0 Box 25145 .Nax M . 0m - - e 1C0 C: “1°“ 30° 506 2652 - Santa Ana, CA 92799-5145 nggox ’3‘767 ° Fax 714-754-9568 _ . I _ _ Dlal 711 for Telecommumcatlons Relay Serv1ce Albuquerque, NM 87190-3767 Phone 505-903-5820 Fax 505-903-5833 March 3, 2021 Trung D Pham 2813 Meadowfaire. Dr . San Jose CA 95 1 1 1-2066 Re: Creditor: Bank of America; N.A. . Account number XDQQQQOQQCQCXIF: 13 Balance Owing $3,195.63 NOTICE OF INTENTION TO- SUE AND INCUR COURT COSTS Our client has authorized us to file a lawsuit to‘ collect the balance owing on the above referenced account. In addition to seeking a judgment for principal, we will ask the court to award allowable court costs (the actual cost of the filing fee and the actual cost of service of process). You may be able to settle this account for less than the full balance or to arrange to make payments on the account over time. You are encouraged to call us to resolve this matter. Our TOLL FREE NUMBER IS (800) 506-2652. We look forward to hearing from you / The Moore Law Group, APC _ Ryota Eric Adam Brumage_ Maria Bradish_ Don an- Isozaki_ Den‘ick Uhri__ Jeremy Kimelman- Marquez_Karlie D. Schafer_ ,. This communication is from a debt collector in an attempt to collect a debt. Any information obtained will be used for that purpose. The Moore Law Group account number 2501 10080