Declaration

Cal. Super. - 6th Dist.April 30, 2021

Electronically Filed by Superior Court of CA, County of Santa Clara, on 7/15/2021 10:11 AM Reviewed By: D Harris Case #21CV381155 Envelope: 6853054 21CV381155 Santa Clara - Civil D Harris 10 ll 12 l3 l4 l5 16 l7 18 19 20 21 22 23 24 25 26 27 28 Christopher D. Mandarich SB 220693 MANDARICH LAW GROUP, LLP P.O. Box 109032 Chicago, IL 60610 Phone: 877.285.4918 Facsimile: 818.888.1260 Attorneysfor Plaintiff Midland Credit Management, Inc SUPERIOR COURT OF CALIFORNIA COUNTY 0F SANTA CLARA _ , Case No.2 21CV381155 Mldland Credlt Management, Inc, Plaintiff, vs. OF CIVIL PROCEDURE §1033 MERCEDES A KINNER, Defendant. ) ) § g DECLARATION PURSUANT T0 CODE ) ) ) ) I declare as follows: 1. I am the attorney 0f record for the Plaintiff. Ihave personal knowledge of the facts set forth herein, and if called as a witness Iwould and could so testify competently. 2. Attached as Exhibit “A” is a true and correct copy of the letter which was mailed to the Defendant advising 0f Plaintiff‘s intent t0 file suit in the Superior Court pursuant to CCP § 1033. I declare under penalty of perjury that the forgoing is true and correct under the laws 0f the State 0f California. Executed at Chicago, Illinois on July 6, 2021 MANDARICH LAW GROUP, LLP 0OMM [X] Christopher D. Mandarich Attorneysfor Plaintiff Midland Credit Management, Inc DECLARATION PURSUANT TO CCP 1033 EXHIBIT A Please Regly To: P.O. Box 109032 Chicago, IL 60610 P: 877.285.4918 F: 818.888.1260 www.mandarichlaw.com You may also contact us via email at INFO@MANDARICHLAW.COM March 21, 2021 Sent Via US Mail MERCEDES A KINNER 4750 ALMADEN EXPY STE I24 SAN JOSE CA 951 18-2052 Current Creditor: Our File N0.: Original Creditor: Original Creditor Account N0.: Current Balance Due: Charge Off Date MANDARICH LAW GROUP, LLP Attorneys at Law Midland Credit Management, Inc 43 82545 CITIBANK, NA. XXXXXXXXXXXXI 807 $1,446.02 03/1 5/2020 THIS LAW FIRM EMPLOYS ONE OR MORE ATTORNEYS ADMI'lTED TO PRACTICE IN THE FOLLOWING STATES: Alaska, California, District of Columbia, Florida, Georgia, Idaho, Illinois, Iowa, Kansas, Michigan, Missouri, Nebraska, Nevada, New York, North Carolina, Ohio, Oregon, South Carolina, Virginia, Washington OF COUNSEL Thomas M. McGreal (CA, HI) Crystal Flynn (UT) NOTICE OF INTENTION TO SUE AND INCUR COSTS Dear MERCEDES A KINNER, We represent Midland Credit Management, Inc. If we are unable t0 resolve this matter within ten (10) days of the date 0f this letter, our client has authorized us t0 file a lawsuit t0 collect the balance owing on the above-referenced account. You are hereby notified that pursuant t0 California Code of Civil Procedure Section 1033, should legal action result in ajudgment against you, you may also be found liable for various court costs, including, but not limited t0, filing fees and service 0f process fees. Please give this matter your prompt attention and contact our office toll-free at 877285.491 8. Sincerely, Mandarich Law Group, LLP THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. SEE REVERSE SIDE OR ATTACHED FOR AN IMPORTANT STATEMENT OF YOUR RIGHTS. 1lllllll“llIIIIHIWIIHIIIIHlllllIHIIWIUIIIIWIIIIIIIU{IN IMPORTANT NOTICE OF RIGHTS We are required under state and/or federal law(s) to notify consumers of certain rights. This list does not include a complete list 0f rights you may have under state 0r federal laws 0r regulations. Federal Law 0r other state laws may also provide you with similar or even greater rights. In California: The state Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt Collection Practices Act require that, except under unusual circumstances, collectors may not contact you before 8 am. 01‘ after 9 p.m. They may not harass you by using threats of violence 01‘ arrest 0r by using obscene language. Collectors may not use false 0r misleading statements 0r call you at work if they know 0r have reason t0 know that you may not receive personal calls at work. For the most pan, collectors may not tell another person, Other than your attorney 0r spouse, about your debt. Collectors may contact another person t0 confirm your location 01‘ enforce a judgment. For more information about debt collection activities, you may contact The Federal Trade Commission at 1-877-FTC-HELP 0r www.fiogov. As required by law, you are hereby notified that a negative credit report reflecting 0n your credit record may be submitted by the creditor to a credit reporting agency ifyou fail to fulfill the terms 0f your credit obligations. Mandarich Law Group, LLP I P.O. Box 109032 Chicago, IL 60610, 877.285.4918