DeclarationCal. Super. - 3rd Dist.January 15, 2014Sa 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BRYANT BURNSTAD, SBN 297286 T OF CALIFORNIA RESURGENCE LEGAL GROUP, PC SUPER OR OOF PLACER 10805 Holder Street, Suite 205 Cypress, CA 90630 NOV 29 2018 (T) 877/440-0860 (F) 714/226-0024 TERS EMAIL: CAAttorney@ResurgenceLegal.com EXECUTIVE OI y & CLERK By: E.C s, Deputy Refer to File Number: CA034719 Attorney for Plaintiff SUPERIOR COURT OF CALIFORNIA COUNTY OF PLACER, PLACER JUDICIAL DISTRICT BILL SANTUCCI JUSTICE CENTER RESURGENCE CAPITAL, LLC, CASE NO.: MCV0060300 DECLARATION IN SUPPORT OF DEFAULT JUDGMENT PURSUANT TO CCP §585 Plaintiff V. ENCHANTED E DOUTHERD A/K/A ENCHANTED E DOUTHERD BODINE A/K/A ENCHANTED DOUTHEREDBODIN, and DOES | through 15 inclusive Defendant(s). w e e e e e e O O S S a I, STEPHEN LUBELFELD, declare as follows: 1. Iam an Chief Financial Officer/Managing Member of Plaintiff. I have access to and have reviewed the computer business records of Plaintiff as they relate to the obligation of Defendant(s), ENCHANTED E DOUTHERD A/K/A ENCHANTED E DOUTHERD BODINE A/K/A ENCHANTED DOUTHEREDBODIN, (hereinafter "Defendant(s)") sued upon in Plaintiff's Complaint herein, andl am very familiar with the manner in which those records are compiled. 2. All matters contained herein are based upon my personal knowledge and/or personal review of the computer business records of Plaintiff. If called as a witness, I could and would competently testify thereto. 3. Such business records were made in Plaintiff's regular course of business and at or near the time of the occurrence of the matter set forth therein by, or from information transmitted by a person with 1 DECLARATION IN SUPPORT OF DEFAULT JUDGMENT PURSUANT TO CCP §585 I A M A A 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 knowledge of these matters. 4. Defendant(s), and each of them, requested a credit card (the "Account") from the original credit issuer. Thereafter, said request was accepted. A credit card was issued to Defendant(s) and credit was extended. 5. Defendant(s), and each of them, accepted and used the credit privileges . 6. Thereafter, all rights, title and interest in the Account were transferred to Plaintiff. Attached hereto collectively as Exhibit "A" are true and correct copies of said transfers and are incorporated herein by reference. 7. Defendant(s), and each of them, defaulted on the account by failing to make payments since on or about March 25, 2012, causing damages as set forth herein. Attached hereto collectively as Exhibit "B" are true and correct copies of the raw account data and are incorporated herein by reference. 8. | Demand has been made on Defendant(s), and each of them, for the payment of said sum owed of $1,860.00. 9. Within the last four years, an account was stated by and between the charge-off creditor and Defendant(s), and each of them, wherein it was agreed that said Defendant(s), and each of them, were indebted to the charge-off creditor in the sum of $1,860.00. Plaintiff is the current holder and assignee of the Account. 10. Within the last four years, Defendant(s), and each of them, became indebted to the charge-off creditor on an open book account for $1,860.00. The open book account reflected all the credits and debits involved in the financial transaction(s) between charge-off creditor and Defendant(s) in the Account. Plaintiff is the current holder and assignee of the Account. 2 DECLARATION IN SUPPORT OF DEFAULT JUDGMENT PURSUANT TO CCP §585 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff therefore requests a money judgment against Defendant, ENCHANTED E DOUTHERD, as follows: Account Balance Sued Upon.............. $1,860.00 Court Costs Incurred. ................... $405.50 Less Post-Suit Payment Credits............ $0.00 TOTAL. ........ 0.0.0... eee eee $2,265.50 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on /0 | 7 / % at 3000 LAKESID¥ DRIVE, SUIT 309-S, BANNOCKBURN, IL 60015. By: STEPHEN LUBELFELD 3 DECLARATION IN SUPPORT OF DEFAULT JUDGMENT PURSUANT TO CCP §585 EXHIBIT “A” Exhibit 1 BILL OF SALE This Bill of Sale is entered into this 24th day of December, 2012 pursuant to that certain Flow Purchase Agreement (“Agreement”) effective as of January 24, 2012 by and among Absolute Resolution Corp.. as Buyer, and Wells Fargo Bank. N.A.. as Seller. For good and valuable consideration as more particularly set for in the Agreement, Seller hereby assigns, Selis, transfers and conveys to Buyer, and Buyer hereby accepts from Seller, without recourse except as specifically provided in the Agreement, the Accounts described in the Accounts Schedule attached hereto as Exhibit A. Seller: Wells Fargo Bank, N.A., Buyer: Absolute Resolution Corp. Number of Accounts: List of Accounts: Attached hereto as Schedule ] Unpaid Balance of Accounts: Cut-Off Date: December 17, 2012 Closing Date: December 24, 2012 SOLUTION CORP. WELLS FARGO BANK. N.A. pi fe 7 av WARES » Name: Naiman Nam? Fhomas B. LaCe nteoan Title: Cé¢) Tile: EYEo Operar ions Date: s2/zy fae, LE Date: (2/24/12 . Wel vse LAN) L504 Exhibit 1 BILL OF SALE This Bill of Sale ig entered into this 27th day of December, 2012 pursuant to that certain Flow Purchase Agreement (“Agreement”) effective as of January 24, 2012 by and among Security Credit Services LLC, as Buyer, and Absolute Resolutions Corp., as Seller. For good and valuable consideration as more particularly set for in the Agreement, Seller hereby assigns, sells, transfers and conveys to Buyer, and Buyer hereby accepts from Seller, without recourse except as specifically provided in the Agreement, the Accounts described in the Accounts Schedule attached hereto as Exhibit A. Seller: Absolute Resolutions Corp., Buyer: Security Credit Services, LLC Number of Accounts: Qi List of Accounts: Attached hereto as Schedule 1 Unpaid Balance of Accounts: Cut-Off Date: December 27, 2012 Closing Date: December 27, 2012 ABSO OLUTION CORP. SECURITY CREDIT SERVICES, LLC B ZZ By: K Name: Mavk Noman Name: Title: Chief Operating Officer” Title: Exhibit A ASSIGNMENT AND BILL OF SALE Security Credit Services, LLC (“Seller”) has entered into a Credit Card Purchase Agreement, dated November 26, 2012 ( “Agreement”) for the sale of Accounts described in Agreement thereof to Resurgence Capital, LLC.(“Purchaser”), upon terms and conditions set forth in that Agreement. NOW, THEREFORE, for good and valuable consideration, Seller hereby sells, assigns, and transfers to Purchaser all of Seller’s rights, title, and interest in each and every one of the Accounts described in the Agreement, and identified herein as February CA, WI, MN, IL 2013 accounts, provided however such transfer is made without any representations, warranties, or recourse. IN WITNESS WHEREOF, Seller has signed and delivered this instrument on the 28" day of February, 2013. Security Credit Services, LLC » KO Kaye Dreififert Executive President EXHIBIT “B” es S$ 6018-102670403 2017102614:73 Page & Account Number 900 Remaining Balance $1,860.00 Date Opened 12/14/2009 Charge Off Date 4/30/2012 Last Activity Date 3/25/2012 Charge-off Creditor WELLS FARGO BANK NA Last Name DOUTHERD First Name ENCHANTED Middle Initial E Address 1337 HIDALGO CIR City ROSEVILLE State CA Zip 95747 County PLACER Home Phone 916/856-6485 SSN am, e e@ 6018-102670403 2017102614:73 rage ACCOUNT SUMMARY as of October 4, 2017 Seller: WELLS FARGO BANK NA Original Account Number Date Account Last Payment Date Charge-Off Date Opened | XXKX-HOHOKK-XKKK-7900 April 30, 2012 Amount: $1,860.00 RESURGENCE LEGAL GROUP, PC Account Purchase Date Account Number CA034719 February 28, 2013 ENCHANTED E DOUTHERD
