Declaration CCP 1033Cal. Super. - 6th Dist.March 17, 2021Electronically Filed by Superior Court of CA, County of Santa Clara, on 7/8/2021 9:59 AM Reviewed By: D Harris Case #21CV379024 Envelope: 6802601 21CV379024 Santa Clara - Civil D Harris OOQON \O 10 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 Derrick Uhri, SBN 321 161 Matthew W. Keim, SBN 33 1 020 Eric Marquez, SBN 33 1023 Karlie D. Schafer, SBN 33 1 884 The Moore Law Group, APC 3710 S. Susan St, Suite 210, Santa Ana, CA 92704 P.O. Box 25145, Santa Ana, CA 92799-5 145 Telephone: (800) 506-2652 I Attorneys for Plaintiff, ' Bank of 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. 21CV3’79024 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. Ihave personal, first-hand knowledge 0f the matters set forth herein and, if called as a Witness, could and would competently testify t0 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 0f the electronic data, computer files and other business recofds which TMLG maintains for accounts it has been retained to collect on for its clients. #0.) \DOONON '10 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 colleét on for its clients. The image is created in such a manner to- capture, in PDF 0r similar format, a picture 0f the docfiment 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. _ Ihave personaliy 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 review 0f 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 2, 2021, TMLG caused to be mailed a letter t0 the defendant advising the defendant of the possibility of the filing of a lawsuit and the incurring of litigation costs in connection herewith, a true and correct copy ofWhich is attached hereto as Exhibit 1. 7. The Small Claims Division 0f 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 of Exhibit 1 attached hereto be accepted in lieu of the original document. I declare under penalty of peljury, under the laws of the State of California, that the foregoing is true and correct and that this declaration was executed on JUL U 7 2021 in _ Santa Ana, California. The Moore Law Gfoup, APC By: W Adam Brumage_ Maria Bradish_ Don Phan-Huy_ Ryota Isozaki_ Derrick Uhri_ Matthew W. KeimL Eric Marquez Karlie D. Schafer_ Attorneys for Plaintiff EXHIBIT l *fllllllllllllllllllllllllllllllllllllllmllllU||=k Arizona Ofice: 2702 N 3rd St. Suite 2010 Phoenix, AZ 85004 Phone 800-506-8652 Fax 71475479568 Nevada Office: 823 Las Vegas Blvd. South Suite 260 Las Vegas, NV 89101 Phone 800-506-2652 Fax 714-754-9568 ~ TrungD Pham 28 13‘ Meadowfaire Dr San Jose CA 951 1 1-2066 Rg: aMoOre Law Group A Professional Corporation Toll Free 1-800-506-2652 Mailing Address: P0 Box 25145 Santa Ana, CA 92799-5145 Dial 711 for Telecommunications Relay Service- March 2, 2021' Creditor: Bank ofAmerica, N.A. Accoum number )OQKXXXXXDQOOCOSN Balancg Owing $2,508.56 California Office: 3710 S. Susan St., Ste 210 Santa Ana, CA 92704 Phone 7 14-43 1 -2000 Fax 714-754-9568 Colorado Ofice: » 1901 W. Littleton' B1vd., Ste 214 Littleton, CO 80120 Phone 303 -566-6561 Fax 720-278-7794 New Mexico Ofice: PO Box 3767 Albuquerque, NM 87190-3767 Phone 505-903-5820 Fax 505-903-5833 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 ajudgment 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 0r 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 Adam Brumage__ Maria Bradish__6 Don Phan-Huy___ Ryota Isozaki_ Derrick Uhri___ Jeremy Kimmelman_ Marquez_KarlieD. Schafer_ Eric This communication is from a debt collector hi an attempt to collect a debt. Any information obtained will be used for that purpose. The Moore Law Group account number 2501 10078