BriefCal. Super. - 3rd Dist.July 31, 201710 ta 12 13 14 15 16 17 18 LS 20 241 22 23 24 25 26 211 28 File No. 17-14568-0 Robert Scott Kennard D Joseph Helfrick see RSSURTY OF PLACE OM oe Fes 04709 ; H, Sor Die ra -, Bldg. 250, Bay G See OFFICER 8 CLERK McClellan, CA 95652 Mailing Address: P.O. Box 13807 Sacramento, CA 95853 Telephone: (916) 920-2295 Facsimile: (916) 920-0682 Attorneys for Plaintiff BANK OF AMERICA, N.A. SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER ROSEVILLE BRANCH - LIMITED CIVIL DIVISION BANK OF AMERICA, N.A., CASE NO. MCVv0068135 ‘Plaintif€, PLAINTIFF’S OPENING TRIAL BRIEF vs. DATE: 03/07/2019 COLLEEN FEASTER, et al. TIME: 1:30 P.M. DEPT: 32 Defendants. ~ ~ w o w o w w w w w r w Plaintiff BANK OF AMERICA, N.A. submits the following as and for its opening Trial Brief: PARTIES AND REPRESENTATION Plaintiff BANK OF AMERICA, N.A. is a national banking association and is represented by counsel Robert Scott Kennard and Joseph Helfrick of the law firm of Nelson & Kennard. PLAINTIFF’S OPENING TRIAL BRIEF - 1 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Zo 26 27 28 Defendant COLLEEN FEASTER is an individual residing in the County of Placer and is representing herself in pro per. SUMMARY OF FACTS On or about 2/16/06, Defendant and Plaintiff entered into an agreement by which Defendant was provided a credit account anda corresponding extension of credit. By accepting the account, Defendant: agreed to be bound by the terms and conditions of the credit agreement and disclosure statement. Since establishing the account, Defendant made various purchases and payments in accordance with the terms and conditions of the account agreement. Defendant defaulted under the terms of the account by failing to make the minimum payments due and Plaintiff charged-off the account on or about 2/29/16. The last payment made by Defendant posted to the account on 01/01/19 in the sum of $50.00. The principal, interest and fees due as of the date the account was charged-off was the sum of $6,623.20. Since charge off, Plaintiff has received payments totaling $100.00. Plaintiff also claims its costs incurred to date. /// /// /// PLAINTIFF’S OPENING TRIAL BRIEF - 2 10 ea. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PLAINTIFF’S DEMAND Plaintiff seeks the principal sum of $6,523.20 and court costs of $297.00 for a total judgment of $6,820.20. Dated: {-)2-(4 NELSOD NNARD By: JOSEP ELFRICK Attorpey for Plaintiff BANK OF AMERICA, N.A. PLAINTIFF’S OPENING TRIAL BRIEF - 3 10 Aa 12 13 14 15 16 17 18 19 20 2d 22 23 24 29 26 27 28 PROOF OF SERVICE State of California ) County of Sacramento ) I am a resident of the County aforesaid; I am over the age of eighteen years and not a party to the within action; my business address is 5011 Dudley Blvd., Bldg. 250, Bay G, McClellan, California 55652. On 1 Z01A , L served the within: PLAINTIFF’S OPENING TRIAL BRIEF on the parties in said action by placing a true and correct copy thereof in a sealed envelope and addressed as follows: COLLEEN FEASTER 5570 Sunset Blvd., W. Roseville, CA 95747 I served the documents described hereinabove by placing said documents for collection and processing for mailing following this business's ordinary practice with which I am readily familiar. On the same day correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service. aL dapiaxe under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed on |. 30° (& at Sacramento, California. Li Akh. Kimberley J. flanaka PLAINTIFF’S OPENING TRIAL BRIEF - 4
