Complaint

Cal. Super. - 3rd Dist.June 10, 2021

PLD-C-001 FOR COURT USE ONLYATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): TELEPHONE NO: FAX NO. (Optional): E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name): SUPERIOR COURT OF CALIFORNIA, COUNTY OF MAILING ADDRESS: CITY AND ZIP CODE: BRANCH NAME: PLAINTIFF: DEFENDANT: DOES 1 TO CONTRACT COMPLAINT AMENDED COMPLAINT (Number): CROSS-COMPLAINT AMENDED CROSS-COMPLAINT (Number): Jurisdiction (check all that apply): CASE NUMBER: ACTION IS A LIMITED CIVIL CASE Amount demanded does not exceed $10,000 ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) from limited to unlimited 1. Plaintiff* (name or names): alleges causes of action against defendant* (name or names): 2. This pleading, including attachments and exhibits, consists of the following number of pages: except plaintiff (name): a corporation qualified to do business in California an unincorporated entity (describe): other (specify): Plaintiff (name):b. has complied with the fictitious business name laws and is doing business under the fictitious name (specify): has complied with all licensing requirements as a licensed (specify): Information about additional plaintiffs who are not competent adults is shown in Attachment 3c.c. 4. a. Each defendant named above is a natural person except defendant (name):except defendant (name): a business organization, form unknown a business organization, form unknown a corporation a corporation an unincorporated entity (describe):an unincorporated entity (describe): a public entity (describe):a public entity (describe): other (specify):other (specify): Page 1 of 2* If this form is used as a cross-complaint, plaintiff means cross-complainant and defendant means cross-defendant. Code of Civil Procedure, § 425.12 COMPLAINT-ContractForm Approved for Optional UseJudicial Council of California PLD-C-001 [Rev. January 1, 2007] STREET ADDRESS: exceeds $10,000 but does not exceed $25,000 ACTION IS RECLASSIFIED by this amended complaint or cross-complaint from unlimited to limited 3. a. Each plaintiff named above is a competent adult (1) (2) (3) b. a. (1) (2) (3) (1) (2) (3) (4) (5) (4) (5) ✔ (888)277-9071 Amanda Riggs, SBN 285764 / Sherif Fathy, SBN 242937 / Tina Abdolhosseini, SBN 316093 Hon. Howard G. Gibson Courthouse PLAINTIFF 4 Lawgix Lawyers, LLP Placer 10820 Justice Center Drive Roseville CA 95678 U.S. Bank National Association Pittsburgh, PA 15275 1000 Cliff Mine Rd, Suite #330 ✔ ✔ ✔ ✔ A National Association U.S. Bank National Association KASHMIR KAUR; U.S. Bank National Association KASHMIR KAUR; DocuSign Envelope ID: D103D3FF-215B-4972-844B-A32CAF6282F8 SHORT TITLE: CASE NUMBER: (Continued) The true names of defendants sued as Does are unknown to plaintiff. Information about additional defendants who are not natural persons is contained in Attachment 4c.c. Defendants who are joined under Code of Civil Procedure section 382 are (names):d. 5. Plaintiff is required to comply with a claims statute, and a. has complied with applicable claims statutes, or is excused from complying because (specify):b. 6. This action is subject to Civil Code section 1812.10 Civil Code section 2984.4. 7. This court is the proper court because a defendant entered into the contract here. a defendant lived here when the contract was entered into. a defendant lives here now. the contract was to be performed here. a defendant is a corporation or unincorporated association and its principal place of business is here. real property that is the subject of this action is located here. a. b. c. d. e. f. other (specify):g. 8. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): Breach of Contract Common Counts Other (specify): Other allegations:9. 10. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. damages of: $ b. interest on the damages (1) according to proof (2) at the rate of (specify): percent per year from (date): attorney's feesc. (1) of: $ according to proof.(2) other (specify):d. 11. The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers): Date: (TYPE OR PRINT NAME) (If you wish to verify this pleading, affix a verification.) Page 2 of 2COMPLAINT-ContractPLD-C-001 [Rev. January 1, 2007] 4. (SIGNATURE OF PLAINTIFF OR ATTORNEY) b. Doe defendants (specify Doe numbers): _______________________ were the agents or employees of the named defendants and acted within the scope of that agency or employment. (1) Doe defendants (specify Doe numbers): _______________________ are persons whose capacities are unknown to plaintiff. (2) PLD-C-001 DRAFTform_lgx_date_hereform_lgx_name form_lgx_sign_here ✔ ✔ ✔ 15950.28 U.S. Bank National Association v KASHMIR KAUR; DocuSign Envelope ID: D103D3FF-215B-4972-844B-A32CAF6282F8 Tina Abdolhosseini 5/14/2021 CASE NUMBER:SHORT TITLE: CAUSE OF ACTION-Common Counts Page (number) Cross - ComplaintATTACHMENT TO Complaint (Use a separate cause of action form for each cause of action.) CC-1. Plaintiff (name): alleges that defendant (name): other (name):became indebted to plaintiff a. within the last four years on an open book account for money due. because an account was stated in writing by and between plaintiff and defendant in which it was agreed that defendant was indebted to plaintiff. (1) (2) within the last two years four yearsb. (1) for money had and received by defendant for the use and benefit of plaintiff. for work, labor, services and materials rendered at the special instance and request of defendant and for which defendant promised to pay plaintiff. (2) the sum of $ the reasonable value. (3) for goods, wares, and merchandise sold and delivered to defendant and for which defendant promised to pay plaintiff the sum of $ the reasonable value. (4) for money lent by plaintiff to defendant at defendant's request. for money paid, laid out, and expended to or for defendant at defendant's special instance and request. other (specify): (5) (6) CC-2. $ , which is the reasonable value, is due and unpaid despite plaintiff's demand, at the rate of percent per yearplus prejudgment interest according to proof from (date): CC-3. Plaintiff is entitled to attorney fees by an agreement or a statute of $ according to proof. CC-4. Other: Form Approved for Optional Use Judicial Council of California PLD-C-001(2) [Rev. January 1, 2009] CAUSE OF ACTION-Common Counts Code of Civil Procedure, § 425.12www.courtinfo.ca.gov PLD-C-001(2) Page 1 of 1 ✔ U.S. Bank National Association KASHMIR KAUR; ✔ ✔ ✔ 15950.28 ✔ ✔ Defendant(s) applied for and received a credit account from Plaintiff. Defendant(s) used or authorized the use of the Account in accordance with the Customer Agreement governing use of the Account. Defendant(s) breached the Agreement by failing to make periodic payments as required thereby and the Account was subsequently charged-off. Based on Plaintiff's records, there are no unresolved billing disputes related to the Account. ✔ ✔ FIRST 3 U.S. Bank National Association v KASHMIR KAUR; ✔ DocuSign Envelope ID: D103D3FF-215B-4972-844B-A32CAF6282F8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF Placer Hon. Howard G. Gibson Courthouse DECLARATION OF LOCATION/VENUE CASE NAME: U.S. Bank National Association V. KASHMIR KAUR CASE NUMBER: Please check ONE of the following statements to indicate the basis for your filing of the complaint in this Judicial District and fill in the address. ____ 1. Cause of Action arose in this Judicial District. ____ 2. Property located in this Judicial District. ____ 3. Tort occurred in this Judicial District. ____ 4. Contract entered into or to be performed in this Judicial District. __X 5. Defendant resides in this Judicial District. The address of the Defendant(s) is: KASHMIR KAUR 705 MAIN ST APT 2 ROSEVILLE,CA 95678 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Dated: lgx_date_here:_default_identifier lgx_sign_here:_default_identifier _______________________ Plaintiff’s Attorney Amanda Riggs / Sherif Fathy / Tina Abdolhosseini Lawgix Lawyers, LLP DocuSign Envelope ID: D103D3FF-215B-4972-844B-A32CAF6282F8 5/14/2021