DeclarationCal. Super. - 3rd Dist.November 25, 2019S o © O A N OD O oO K R WH } P O xX a 2 N O A . D N H N A A HN &@ &@ @ oh O l U l lC Ul U C C o N O o K R W O NY F| - F D o O W O N D O TG H R W O PS = ~ a~ REESE LAW GROUP Harlan M. Reese, Esq., Bar #118226 3168 Lionshead Avenue F I L E D Carlsbad, CA 92010 supers Court of California 760/842-5850 ounty of Placer Attorneys for Plaintiff, FEB 26 2020 Wells Fargo Bank, N.A. Jake Chatters Executive Officer & Clerk By: K. Pearson, Deputy SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER ROSEVILLE BRANCH Wells Fargo Bank, N.A. Case No. MCV0075321 Plaintiff, DECLARATION PURSUANT TO 1033(b) V. ANAHJEA S YOSHIDA Defendants. |, Harlan M. Reese, Esq., declare as follows: 1. |am an attorney licensed to practice before all of the Courts of the State of California. | am an attorney with the law firm of Reese Law Group, A Professional Law Corporation, the attorneys of record for the Plaintiff herein. | have been primarily responsible for monitoring and prosecuting this action on behalf of the Plaintiff. This Declaration is offered in support of Plaintiff's request for Court Judgment to include Plaintiff's costs pursuant to C.C.P. §1033. All of the facts set-forth below are known to me personally. If called upon to testify to the truth thereof, | could and would be willing to do so. MI Declaration Pursuant to 1033(b) 1 o O O o N n D O oO F R WD ) PP O & P O RP PR PR PN B DY MO NO ND P NY O | | HS o e e s as as e e r Se a o N O O K R W O NY | - F D O o Wo O N DO DO O T K R W O YB | ~ CO o~ -_ 2. Plaintiff could not have brought the action within small claims court because it is a corporate entity, represented by counsel. Pursuant to C.C.P. §1033(b)(2), Plaintiff is limited to the actual cost of the filing fee, the actual cost of service of process, and when allowed by law, reasonable attorney fees. 3. On October 12, 2019, pursuant to C.C.P. §1033(b)(2), a demand letter was mailed to defendant. This letter informed the defendant of the intended legal action and the potential liability for plaintiff's costs. A true and accurate copy of this demand letter is attached hereto and labeled as Exhibit "A". | declare under penalty of perjury under the laws of the State of California that the L-/F-2eO ZA rlan M. Reese, Esq. Attorney for Plaintiff foregoing is true and correct. Executed on this , at Carlsbad, California. Declaration Pursuant to 1033(b) 2 | : ~ : : t > oy . . . . EXHIBIT A REESE LAW GROUP, APLC A Professional Law Corporation 3168 Lionshead Ave Carlsbad CA 92010 Telephone: (760) 842-5850 Facsimile: (760) 842-5865 October 12, 2019 ANAHJEA S YOSHIDA Re: Wells Fargo Bank, NA 201 MCRAE CT Our File Number: 562536 ROSEVILLE CA 95678-9538 Claim: $7,594.69 Account Number Ending: 6104 Dear ANAHJEA S YOSHIDA: This law firm represents Wells Fargo Bank, N.A. . Your file was forwarded to us for collection. The amount of your debt you owe to Wells Fargo Bank, N.A. is $7,594.69. Please note that if a lawsuit is initiated to collect the claim amount, and if our client prevails, a judgment may be entered against you which may include not only the principal amount but also the cost of filing the lawsuit, the cost of serving the lawsuit and, when allowed by law, reasonable attorney's fees. We urge you to contact Michael Campbell, Ext. 256, a non-attorney collection assistant. Sincerely, L-+ [hy Jennifer Myers, Esq. This Communication is from a Debt Collector IMPORTANT LEGAL NOTICE FEDERAL NOTICE Unless you notify us, within 30 days after receipt of this notice, that you dispute the validity of this debt or any portion thereof, the debt will be assumed to be valid. If you notify us, in writing, within the 30 day period, that the debt or portion thereof, is disputed, we will obtain verification of the debt or obtain a copy of the judgment against you and a copy of such verification of the debt or judgment will be mailed to you. If you notify us, in writing, within 30 days following receipt of this notice, we will also provide you with the name and address of the original creditor, if different from the current creditor. This letter is an attempt to collect a debt and any information obtained will be used for that purpose. CALIFORNIA NOTICE 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 a.m. or after 9 p.m. They may not harass you by using threats of violence or arrest or by using obscene language. Collectors may not use false or misleading statements or call you at work if they know or have reason to know that you may not receive personal calls at work. For the most part, collectors may not tell another person, other than your attorney or spouse, about your debt. Collectors may contact another person to confirm your location or enforce a judgment. For more information about debt collection activities, you may contact the Federal Trade Commission at 1-877-FTC-HELP or www. ftc.gov. DWF100A
