ComplaintCal. Super. - 3rd Dist.June 10, 2021. _ _ ee . ___PLD-C-001 i ATTORNEY OF PARTY WITHOUT ATTORNEY (Nave Bigte Bar numiner, anct adninens! 7 FOR COUNT USE ONLY | Hunt & Henriques, Attorneys at Law | Donald Sherrill #266038 | | Kevin Brendon Buiza #318691 | 7017 Reaimn Dr | San José CA 95119 | TELEPHONE NO (800) 680-2426 FAX NO. (Optonaiy (408) 362-2299 | | E-MAlL ADDRESS (Optional __ATTOANEY FOR iNamer Plaintiff ae enn | | SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER ~| | STREET ADDRESS FO. Box 619072 | | MAILING ADDRESS ! | CITY AND ZP CODE Roseville CA 98661 [ BRANCH NAME: iil Santucci Justice Center Courthouse nt Tee ee eee eee ee a annensntnntnntnmtnnnptane | PLAINTIFF. Capital One Bank (USA), NA, ! | DEFENDANT. NAVJOT KAUR | (Co) bors rte re A A | _ _. CONTRACT | | [X_] COMPLAINT [_] AMENDED COMPLAINT (Number): | | = CROSS-COMPLAINT [| AMENDED CROSS-COMPLAINT (Number): | | _ Jurisdiction (check ail that apply): nn | LX. ACTION IS A LIMITED CIVIL CASE $4,113.57 | CASE NUMBER Amount demanded Lx] does not exceed $10,000 - (__] exceeds $10,000, but does not exceed $25,000 | | (_.. ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) i | | Co] ACTION IS RECLASSIFIED by this amended complaint or cross-complaint | (__.] from limited to unlimited | ___ [trom unlimited tolimited co 1. Plaintiff (name or names): Capital One Bank (USA), NA. alleges causes ot action against defendant* (name or names): NAVJOT KAUR 2. This pleading, including attachments and exhibits, consists of the following number of pages: 4 3. a. Each plaintiff named above is a competent adult Cx! except plaintiff (name): Capital One Bank (USA), NLA. (1) |] a corporation qualified to do business in California (2) |__| an unincorporated entity (describe): (3) CX] other (specify): A National Banking Association organized and existing under and by virtue of the laws of the _. United States of America b. (___] Plaintiff (name): a. |] has complied with the fictitious business name laws and is doing business under the fictitious name of (specify): b. [_] has complied with all licensing requirements as a licensed (specify): c. [__] information about additional plaintifts who are not competent adults is shown in Attachment 3c. 4. a. Each defendant named above is a natural person -_ except defendant (name): except defendant (name): (1) [_] a business organization, form unknown (1) L__] a business organization, form unknown (2) [] a corporation (2) [__) a corporation (3) [_) an unincorporated entity (describe): (3) ["] an unincorporated entity (deseribey: (4) (la public entity (describe): (4) [_] a public entity (describe): (5) (| other (specify): (5) (_) other (specify): gee nreaceggnnmegnennnannnecenn HAS LOD 38 usted BS 8 cross complaint. plawtil mean cross-tomplainanl and defendant means crossdelandant Page fof 2 | udtal Cours ol aor COMPLAINT-Contract Cade of Cevil Procedure, § 425.12 LDL 4 [Rew January 1, 20077 : Bean 1457251.001 . _. PLD-C-001 [stort TITLE: Capital One Bank (USA), N.A. v. NAVJOT KAUR : CASE NUMBER : 4. (Continued) b. The true names of defendants sued.as Does are unknown to plaintiff. (1) [_] Doe defendants (specify Doe numbers): _..... were the agents or employees of the named _ defendants and acted within the scope of that agency or employment. (2) (| Doe defendants (specify Doe numbers): are persons whose capacities are unknown to plaintiff. c. [__] Information about additional defendants who are natural persons is contained in Attachment 4c. d. [_] Defendants who are joined under Code of Civil Procedure section 382 are (names): 5. (J Plaintiff is required to comply with a claims statute, and a. (J has complied with applicable claims statutes, or b. (__] is excused trom complying because (specify): 6. [__] This action is subjectto [__] Civil Code section 1812.10 [__] Civil Code section 2984.4. 7. This court is the proper court because a. CJ a defendant entered into the contract here. b. |] a defendant lived here when the contract was entered into. c. Cx] a defendant lives here now. d. [|] the contract was to be performed here. e. ["] a defendant is a corporation or unincorporated association and its principal place of business is here. f. ["] real property that is the subject of this action is located here. g. ["] other (specify): 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 CX] Common Counts [_] Other (specify): 9. [] Other allegations: 10. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. LX_] damages of: $4,113.57 b. LX] interest on the damages (1) [-_] according to the proot (2) (XC) at the rate of (specify): 0.0000 percent per year from (date): April 16, 2020 c. [__] attorney's fees () (I of $ (2) [) according to proof. d. [_] other (specify): 11. [CX] The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers): CC-1.a.(1), CC-1.a(2), CC-1.b.44), CC-1.b.(5) Date: May 26, 2021 / a | - ee Ne Kevin Brendon Buiza #318691 Te NN (TYPE OR PRINT NAME} (SIGNATURE OF PLAINTIFF OF ATTORNEY) _(if you wish to verify this pleading, affix a verification.) PLO-C-001 (Rev January 1, 2007] COMPLAINT-Contract Page 2 of 2 1457251.001 oe PLD-C-001(2) | SHORT TITLE: Capital One Bank (USA), N.A. v. NAVJOT KAUR | CASE NUMBER: _..._.._ FIRSTS CAUSE OF ACTION-Common Counts (number) ATTACHMENT TO [X] Complaint [-_] Cross - Complaint (Use a separate cause of action form tor each cause of action.) CC-1. Plaintiff (name): Capital One Bank (USA), N.A. alleges that defendant (name): NAVJOT KAUR became indebted to Ox] plaintiff [I other (name): a. (X] within the last four years (1) Gx) on an open book account for money due. (2) [3X] because an account was stated in writing by and between plaintiff and defendant in which it was agreed that defendant was indebted to plaintiff. b. [X] withinthe last [_] twoyears [X] four years (1) [] for money had and received by defendant for the use and benefit of plaintiff. (2) [_] for work, labor, services and materials rendered at the special instance and request of defendant and for which defendant promised to pay plaintiff. [_] 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) [X) for money lent by plaintiff to defendant at defendant's request (5) [CX] for money paid, laid out, and expended to or for defendant at defendant's special instance and request. (6) [_) other (specify): CC-2. $4,113.57 , which is the reasonable value, is due and unpaid despite plaintiff's demand, plus prejudgment interest [| according to proof CX] atthe rateof 0.0000 __ percent per year from (date): April 16, 2020 CC-3. [| Plaintiff is entitled to attorney fees by an agreement or a statute [_] of $ Cc] according to proof. cc-4, |) Other: Page 3 a . easiness sn enn GE LET Forn Approved for Optional Use CAUSE OF ACTION-Common Counts Code of Crvit Procedure, § 425.12 Judie! Counel of Caltomia wow CouHiNG. ca gay PLO-C-OON2) (Rew. Jaruary 1. 2008! 1457251,001 SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER ROSEVILLE JUDICIAL DISTRICT STATEMENT OF LOCATION/VENUE CASE NAME: Capital One Bank (USA), N.A. v. NAVJOT 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. Td Cause of Action arose in this Judicial District. The address of the cause of action is: Steet ity ip Gode innit ner Property located in this judicial district. The address of this property is: Stet Eliya Goede natn 8. Tort occurred in this judicial district. The address of the tort is: Sweat if known) Gity Zip Code nn (or nearest major intersection) A Contract entered into or to be performed in this judicial district. The address where contract entered into or to be performed is: Street (it known) Gity Zip Goda oct xX. 5. Defendant resides in this judicial district. The address of the defendant is: 860 EQUINOX LOOP , LINCOLN CA 95648-2984 Street City Zip Code | deciare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. é assis DATED: May 26,2021 ot TTA Signature of Plaintiff's Attorney Hunt & Henriques 1457251.001
