This case was last updated from Santa Clara County Superior Courts on 03/10/2020 at 11:03:30 (UTC).

Chambers v. Crown Asset Management, LLC

Case Summary

On 12/04/2018 Chambers filed an Other lawsuit against Crown Asset Management, LLC. This case was filed in Santa Clara County Superior Courts, Downtown Superior Court located in Santa Clara, California. The Judges overseeing this case are Walsh, Brian C and Kuhnle, Thomas. The case status is Pending - Other Pending.

Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    ******8800

  • Filing Date:

    12/04/2018

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Other

  • Court:

    Santa Clara County Superior Courts

  • Courthouse:

    Downtown Superior Court

  • County, State:

    Santa Clara, California

Judge Details

Judges

Walsh, Brian C

Kuhnle, Thomas

 

Party Details

Plaintiff

Chambers, Pamela Sheree

Defendant

Crown Asset Management, LLC

Not Classified By Court

Superior Court of California

Attorney/Law Firm Details

Plaintiff Attorneys

Schwinn, Fred W.

Salmonsen, Matthew C

Roulston, Raeon Rodrigo

Defendant Attorneys

Kaminski, David J.

Lavigne, Michael Paul

Johnson, Timothy P

Watkins, Stephen Albert

Not Classified By Court Attorney

Superior Court of CA, County of Santa Clara

 

Court Documents

Substitution: Attorney

Substitution of Attorneys: Comment: Substitution of Attorney

Notice

Notice Appearance Counsel: Comment: Notice of Appearance

Notice: Appearance

Notice of Appearance Deft Crown Asset Management LLC:

Proof of Service: Summons DLR (Civil)

Proof of Service of Summons Complaint:

Order: Deeming Case Complex

Order Deeming Case Complex and Staying Discovery and Responsive Pleading Deadline: Comment: Order Deeming Case Complex and Staying Discovery and Responsive Pleading Deadline signed/TEK

Civil Lawsuit Notice

Civil Lawsuit Notice: Comment: 1st CMC set for 3/22/19 at 10am in D5; assigned to Hon. Thomas E. Kuhnle

Summons: Issued/Filed

Summons Issued Filed: Comment: Summons

Civil Case Cover Sheet

Civil Case Cover Sheet: Comment: Civil Case Cover Sheet COMPLEX

Complaint (Unlimited) (Fee Applies)

Complaint (Unlimited) (Fee Applies): Comment: Class Action Complaint for Statutory Damages

Notice

Notice CMC 12-13-19 off calendar due to pending appeal: Comment: CMC on 12/13/19 is off calendar due to pending appeal.

Notice

Notice: Comment: RE: Consent to Electronic Service

Answer (Unlimited) (Fee Applies)

Answer to Complaint: Comment: To Complaint atty: Kaminski

Minute Order

Minutes Non-Criminal:

Notice

Notice CMC 12-13-19 at 10am in D5: Comment: CMC set for 12/13/19 at 10am in D5

Notice

Notice CMC 9-13-19 at 10am in D5: Comment: CMC set for 9/13/19 at 10am in D5

Order: Submitted Matter

Order Submitted Matter HRG 8-16-19: Judicial Officer: Kuhnle, Thomas; Comment: Order re Motion to Stay Case and Compel Arbitration; Motion to Seal HRG 8/16/19 - signed/TEK

Minute Order

Minutes Non-Criminal:

Minute Order

Minutes Non-Criminal:

36 More Documents Available

 

Docket Entries

  • 12/13/2019
  • DocketConference: Case Management - Judicial Officer: Kuhnle, Thomas; Hearing Time: 10:00 AM; Cancel Reason: Vacated; Comment: (4th CMC) Proposed Class Action. Discovery and responsive pleading deadline stayed, as of 12/5/18, when the case was deemed complex; discovery was partially lifted on 3/22/19 for the purpose of class certification and discovery related to the individual plaintiff. Responsive pleadings are due by 9/30/19 (Answer to Complaint filed 9/30/19).

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  • 12/06/2019
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  • DocketNotice - Notice CMC 12-13-19 off calendar due to pending appeal: Comment: CMC on 12/13/19 is off calendar due to pending appeal.

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  • 11/14/2019
  • DocketAppeal: Notice of Completion - Comment: H047422

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  • 10/22/2019
  • DocketDesignation

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  • 10/17/2019
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  • DocketNotice - Notice: Comment: RE: Consent to Electronic Service

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  • 10/17/2019
  • DocketAppeal: Clerk's Notice of Appeal

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  • 10/16/2019
  • DocketDeposit: Clerk's Transcript - Comment: $100 check deposited, taken on notice of undocumented action

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  • 10/15/2019
  • DocketNotice of Appeal - Court of Appeal

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  • 10/02/2019
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  • DocketHearing: Other - Order Submitted Matter HRG 8-16-19: Judicial Officer: Kuhnle, Thomas; Hearing Time: 9:30 AM; Cancel Reason: Vacated; Comment: CONFERENCE CALL re clarification of whether the Court's 8/16/19 order denying Crown's motion to compel arbitration was with or without prejudice

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  • 09/30/2019
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  • DocketAnswer (Unlimited) (Fee Applies) - Answer to Complaint: Comment: To Complaint atty: Kaminski

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46 More Docket Entries
  • 02/05/2019
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  • DocketNotice - Notice Appearance Counsel: Comment: Notice of Appearance

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  • 01/15/2019
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  • DocketNotice: Appearance - Notice of Appearance Deft Crown Asset Management LLC:

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  • 12/27/2018
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  • DocketProof of Service: Summons DLR (Civil) - Proof of Service of Summons Complaint:

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  • 12/05/2018
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  • DocketOrder: Deeming Case Complex - Order Deeming Case Complex and Staying Discovery and Responsive Pleading Deadline: Comment: Order Deeming Case Complex and Staying Discovery and Responsive Pleading Deadline signed/TEK

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  • 12/05/2018
  • DocketFee Waiver Order-Grant - Comment: signed/TEK

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  • 12/04/2018
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  • DocketCivil Lawsuit Notice - Civil Lawsuit Notice: Comment: 1st CMC set for 3/22/19 at 10am in D5; assigned to Hon. Thomas E. Kuhnle

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  • 12/04/2018
  • DocketFee Waiver Application - Comment: Request to Waive Court Fees

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  • 12/04/2018
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  • DocketSummons: Issued/Filed - Summons Issued Filed: Comment: Summons

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  • 12/04/2018
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  • DocketCivil Case Cover Sheet - Civil Case Cover Sheet: Comment: Civil Case Cover Sheet COMPLEX

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  • 12/04/2018
  • View Court Documents
  • DocketComplaint (Unlimited) (Fee Applies) - Complaint (Unlimited) (Fee Applies): Comment: Class Action Complaint for Statutory Damages

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Complaint Information

E-FILED

12/4/2018 11:29 AM

Fred W. Schwinn (SBN 225575) Clerk of Court

Raeon R. Roulston (SBN 255622) Superior Court of CA, Matthew C. Salmonsen (SBN 302854) County of Santa Clara CONSUMER LAW CENTER, INC. 18CV338800

1435 Koll Circle, Suite 104 Reviewed By: R. Walker

San Jose, California 95112-4610

Telephone Number: (408) 294-6100

Facsimile Number: (408) 294-6190

Email Address: fred.schwinn@sjconsumerlaw.com

Attorneys for Plaintiff

PAMELA SHEREE CHAMBERS SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA

PAMELA SHEREE CHAMBERS, Case No. 18CV338800 individually and on behalf of all others (Unlimited Civil Case)

similarly situated,

CLASS ACTION COMPLAINT

Plaintiff, FOR STATUTORY DAMAGES

V.

CROWN ASSET MANAGEMENT, LLC, a California Civil Code §§ 1788.50-1788.64 Georgia limited liability company; and DOES 1 through 10, inclusive,

Defendants.

Plaintiff, PAMELA SHEREE CHAMBERS, on behalf of herself and all others similarly situated, based on information and belief and investigation of counsel, except for those allegations which pertain to the named Plaintiff or her attorneys (which are alleged on personal knowledge), hereby makes the following allegations:

INTRODUCTION

1. This is a consumer class action brought pursuant to the California Fair Debt Buying Practices Act, California Civil Code §§ 1788.50-1788.64 (hereinafter “CFDBPA”’) which prohibits debt buyers from engaging in abusive, deceptive, and unfair practices. Plaintiff, PAMELA SHEREE CHAMBERS, on behalf of herself and all persons similarly situated, seeks statutory damages against sent to Plaintiff, which provide the notice required by the CFDBPA, California Civil Code § 1788.52(d) (1), in smaller than 12-point type. As a result, Defendants have engaged in unlawful acts in connection with their attempt to collect charged-off consumer debts from Plaintiff and the Class.

JURISDICTION AND VENUE

2. The California Superior Court has jurisdiction over this action pursuant to California Code of Civil Procedure § 410.10 and California Constitution Article VI, § 10, which grants the Superior Court “original jurisdiction in all cases except those given by statute to other trial courts.” The statute under which this action is brought does not grant jurisdiction to any other trial court in California.

3. This Court has jurisdiction over each Defendant named herein because, based on information and belief, each Defendant is a corporation or association authorized to do business in California and registered with the California Secretary of State, or does sufficient business, has sufficient minimum contacts in California, is a citizen of California, or otherwise intentionally avails itself of the California market through the promotion, sale, marketing and/or distribution of goods and services in California and thereby having such other contacts with California so as to render the exercise of jurisdiction over it by the California courts consistent with traditional notions of fair play and substantial justice.

4. Venue is proper 1n the Santa Clara Superior Court, pursuant to California Code of Civil Procedure §§ 393 and 395.5, because one or more of the violations alleged in this Complaint arise in the County of Santa Clara. Venue is also proper in the Santa Clara Superior Court, pursuant to California Code of Civil Procedure § 395(b), because this action arises from an extension of credit intended primarily for personal, family or household use and Plaintiff (the alleged borrower) resided in

the County of Santa Clara at the commencement of this action. 5. The total amount in controversy as to Plaintiff and each member of the proposed Class does not exceed seventy-four thousand, nine hundred and ninety-nine dollars ($74,999) each, exclusive of interest and costs. Plaintiff disclaims any compensatory damages, punitive damages, declaratory, injunctive, or equitable relief greater than ($74,999) per individual Class member. Plaintiff and the proposed Class limit their total class wide claims to less than four million, nine hundred and ninety-nine thousand, nine hundred and ninety-nine dollars ($4,999,999.00).

6. Plamntiff and the proposed Class seek only statutory damages in this action and do not allege in this Class Action Complaint for Statutory Damages that they, or any of them, have suffered a concrete injury within the meaning of Article III of the United States Constitution and the Supreme Court’s related interpretation.’

PARTIES

7. Plaintiff, PAMELA SHEREE CHAMBERS (hereinafter “Plaintiff”), is a natural person residing in Santa Clara County, California. Plaintiff i1s a “debtor” as that term 1s defined by California Civil Code § 1788.2(h), as incorporated by California Civil Code § 1788.50(c), and a “disabled person” within the meaning of California Civil Code § 1761(g).

8. Defendant, CROWN ASSET MANAGEMENT, LLC (hereinafter “CROWN”), is a Georgia limited liability company engaged in the business of purchasing and collecting charged-off consumer debts in this state with its principal place of business located at: 3100 Breckinridge Boulevard, Suite 725, Duluth, Georgia 30096-7605. CROWN may be served as follows: Crown Asset Management, LLC, c/o CT Corporation System, 1201 Peachtree Street NE, Atlanta, Georgia 30361- 3503. CROWN is regularly engaged in the business of purchasing charged-off consumer debts for collection purposes. CROWN is a “debt collector” as that term is defined by California Civil Code § 1788.2(c), as incorporated by California Civil Code § 1788.50(c), and a “debt buyer” as that term is defined by California Civil Code § 1788.50(a)(1).

9. The true names and capacities, whether individual, corporate, associate, governmental, or otherwise, of Defendants, DOES 1 through 10, are unknown to Plaintiff at this time, who therefore sues said Defendants by such fictitious names. When the true names and capacities of said Defendants have been ascertained, Plaintiff will amend this Complaint accordingly. Plaintiff is informed and believes, and thereon alleges, that each Defendant designated herein as a DOE is responsible, negligently or in some other actionable manner, for the events and happenings hereinafter referred to, and caused damages thereby to the Plaintiff, as hereinafter alleged. Defendant, DOES 1-10, are, and each of them 1s, a “debt collector” as that term is defined by California Civil Code § 1788.2(c), as incorporated by California Civil Code § 1788.50(¢c), and a “debt buyer” as that term is defined by California Civil Code § 1788.50(a)(1).

FACTUAL ALLEGATIONS

12. On a date or dates unknown to Plaintiff, Plaintiff is alleged to have incurred a financial obligation in the form of a consumer credit account issued by SYNCHRONY BANK (hereinafter the “alleged debt”). Plaintiff generally denies that any debt is owed. The alleged debt to SYNCHRONY BANK, was primarily for personal, family, or household purposes and is therefore a “consumer debt” as that term 1s defined by California Civil Code § 1788.2(f), as incorporated by California Civil Code § 1788.50(c).

13. Thereafter, on a date after January 1, 2014, SYNCHRONY BANK, removed the alleged debt from its books as an asset and treated the alleged debt as a loss or expense. As a result, the alleged debt was thereafter a “charged-off consumer debt” as that term is defined by California Civil Code § 1788.50(a)(2).

14, Thereafter, on or about March 20, 2018, the alleged debt was sold by SYNCHRONY BANK to CROWN for collection purposes.

15. Because the alleged debt was sold or resold after January 1, 2014, CROWN’s collection of the alleged debt is subject to the California Fair Debt Buying Practices Act, California Civil Code §§ 1788.50-1788.64 (“CFDBPA”), pursuant to California Civil Code § 1788.50(d).

16. Plaintiff 1s informed and believes, and thereon alleges that, on a date unknown to Plaintiff, CROWN hired, contracted, or otherwise engaged MCCARTHY, BURGESS & WOLFF, INC., to collect the alleged debt from Plaintiff and the Class on CROWN’s behallf.

17. Thereafter, MCCARTHY, BURGESS & WOLFF, INC., was, and acted as, CROWN’s authorized agent with the actual or ostensible authority to act on CROWN’s behalf.

18. On or about November 7, 2018, MCCARTHY, BURGESS & WOLFF, INC., sent,

or caused to be sent, a written communication to Plaintiff at CROWN’s request and on CROWN’s behalf. This was the first written communication from CROWN to Plaintiff with regard to the alleged debt.

19. A true and accurate copy of CROWN’s first written communication to Plaintiff is attached hereto, marked Exhibit “1,” and by this reference is incorporated herein.

20. CROWN?’s first written communication provided the notice required by the CFDBPA, California Civil Code § 1788.52(d)(1), in smaller than 12-point type.

21. CROWN is strictly liable to Plaintiff and the Class for MCCARTHY, BURGESS & WOLFF, INC.’s, failure to provide the notice required by the CFDBPA, California Civil Code § 1788.52(d)(1).?

22. CROWN owed Plaintiff and the Class a nondelegable duty to ensure that MCCARTHY, BURGESS & WOLFF, INC., complied with the CFDBPA in all respects, including California Civil Code § 1788.52(d)(1).” Therefore, CROWN is vicariously liable to Plaintiff and the Class for MCCARTHY, BURGESS & WOLFF, INC.’s, failure to provide the notice required by the CFDBPA, California Civil Code § 1788.52(d)(1).*

23. As a disabled person subjected to CROWN’s abusive, deceptive, and unfair collection practices, Plaintiff is entitled to treble damages, pursuant to California Civil Code § 3345. /]

* Brodsky v. California State Board of Pharmacy, 173 Cal. App. 2d 680, 688 (Cal. App. 2d Dist. 1959); In re Marley, 29 Cal. 2d 525, 529 (Cal. 1946) (“Where qualifying words such as knowingly, intentionally, or fraudulently are omitted from provisions creating the offense it is held that guilty knowledge and intent are not eclements of the offense.”).

DEFENDANTS’ ROUTINE PRACTICES

24. It 1s the standard practice and policy of Defendants to send, or cause to be sent, initial collection communications in the form of Exhibit “1” which seek to collect charged-off consumer debts incurred for personal, family, or household purpose.

25. It i1s the standard practice and policy of Defendants to send initial collection communications in the form of Exhibit “1” which contain the notice required by the CFDBPA, California Civil Code § 1788.52(d)(1), in smaller than 12-point type.

CLASS ALLEGATIONS

26. Plantiff brings this action on behalf of a class of all other persons similarly situated.

27. Plaintiff tentatively defines the Class as (1) all persons with addresses in California (i1) to whom MCCARTHY, BURGESS & WOLFF, INC., sent, or caused to be sent, an initial written communication in the form of Exhibit “1” on behalf of CROWN (iii) in an attempt to collect a charged- off consumer debt originally owed to SYNCHRONY BANK, (iv) which was sold or resold to CROWN on or after January 1, 2014, (v) which were not returned as undeliverable by the U.S. Post Office (vi) during the period one year prior to the date of filing this action through the date of class certification.

28. Excluded from the Class would be any officers, directors, or legal representatives of Defendants, and any judge, justice, or judicial officer presiding over this matter and the members of their immediate families and judicial staff. Plaintiff reserves the right to modify the Class definition and Class period based on the results of discovery.

29. The Class is so numerous that joinder of all members is impractical. On information and belief, collection notices in the form of Exhibit “1” have been sent to hundreds of 30. Defendants have acted with respect to the Class, in a manner generally applicable to Plaintiff and each Class member. There is a well-defined community of interest in the questions of law and fact involved in this action, which affects all Class members. Questions of law and fact common to the Class predominate over any questions peculiar to individual Class members. The common questions include:

a. Whether Defendants are debt buyers; and

b. Whether Defendants sent Plaintiff and the Class initial written communication in the form of Exhibit “1”, which contain the notice required by the CFDBPA, California Civil Code § 1788.52(d)(1), in smaller than 12-point type.

31. There are no individual questions of law or fact, other than whether a Class member was sent the offending collection communication, which can be determined by ministerial inspection of Defendants’ records.

32. Plaintiff will fairly and adequately represent and protect the interest of the Class members. Plaintiff 1s committed to vigorously litigating this matter. Plaintiff has retained counsel experienced in handling class claims and litigation brought pursuant to various consumer protection statutes, including the California Fair Debt Buying Practices Act, California Civil Code §§ 1788.50- 1788.64 (“CFDBPA™), the federal Fair Debt Collection Practices Act, 15 U.S.C. §§ 1692-1692p (“FDCPA”) and the California Rosenthal Fair Debt Collection Practices Act, California Civil Code §§ 1788-1788.33 (“RFDCPA”). Neither Plaintiff nor her counsel have any interests which might cause them not to vigorously pursue this claim. Plaintiff and her counsel will vigorously pursue this matter.

33. Plaintiff’s claims are typical of the claims of the other members of the Class in that Plaintiff and other Class members were similarly harmed by the actions of Defendants and the Plaintiff 1s a member of the Class she seeks to represent and she has suffered harm due to the unfair, deceptive and unlawful practices of Defendants.

34. Defendants have acted or refused to act, with respect to some or all issues presented in this Complaint, on grounds generally applicable to the Class, thereby making it appropriate to provide relief with respect to the Class as a whole.

35. A class action is a superior method for the fair and efficient adjudication of this controversy. Most of the Class members who received written communications in the form of Exhibit “1” have no knowledge that their rights are being violated by illegal collection practices. The interest of the Class members 1n individually controlling the prosecution of separate claims against Defendants is small because the maximum damages in an individual action are $1,000, pursuant to California Civil Code § 1788.62(a)(2). Management of this class action 1s likely to present significantly fewer difficulties than those presented in many other class actions.

36. A class action i1s the best available method of the efficient adjudication of this litigation because individual litigation of Class members’ claims would be impracticable and unduly burdensome to the courts, and have the potential to result in inconsistent or contradictory judgments. There are no unusual difficulties likely to be encountered in the management of this litigation as a class action. A class action presents fewer management problems and provides the benefits of single adjudication, economies of scale, and comprehensive supervision by a single court.

37. Certification of the Class under California Code of Civil Procedure § 382 is appropriate in that:

a. The questions of law or fact common to the members of the Class predominate over any questions affecting only individual members; and

b. A class action is superior to other available methods for the fair and efficient adjudication of the controversy.

38. Certification of a class under California Code of Civil Procedure § 382 is also appropriate in that Defendants acted on grounds generally applicable to the Class, thereby making appropriate declaratory relief with respect to the Class as a whole.

39. Plaintiff and the Class are entitled to an award of attorney fees and costs against Defendants, pursuant to the CFDBPA, California Civil Code § 1788.62(c)(1).

FIRST CAUSE OF ACTION CALIFORNIA FAIR DEBT BUYING PRACTICES ACT

40. Plaintiff brings the first cause of action against Defendants under the California Fair Debt Buying Practices Act (“CFDBPA”), California Civil Code §§ 1788.50-1788.64.

41. Plamtiff repeats, realleges, and incorporates by reference all preceding paragraphs as though fully set forth herein.

42. Plaintiff 1s a “debtor” as that term 1s defined by California Civil Code § 1788.2(h), as incorporated by California Civil Code § 1788.50(c).

43. Defendant, CROWN, is a “debt collector” as that term is defined by California Civil Code § 1788.2(c), as incorporated by California Civil Code § 1788.50(c).

44, Defendant, CROWN, is a “debt buyer” as that term is defined by California Civil Code § 1788.50(a)(1).

45. The financial obligation alleged to be owed by Plamtiff to CROWN is a “consumer debt” as that term 1s defined by California Civil Code § 1788.2(f), as incorporated by California Civil Code § 1788.50(c).

46. The financial obligation alleged to be owed by Plaintiff to CROWN is a “charged- 47. Defendants’ first written communication to Plaintiff provided the notice required by the CFDBPA, California Civil Code § 1788.52(d)(1), in smaller than 12-point type.

48. Defendants have engaged in a pattern and practice of violating the CFDBPA, California Civil Code § 1788.52(d)(1).

49. As a result of Defendants’ violations of the CFDBPA, Plaintiff is entitled to an award of statutory damages in an amount not less than one hundred dollars ($100) nor greater than one thousand dollars ($1,000) against each Defendant, pursuant to California Civil Code § 1788.62(a)(2).

50. As a result of Defendants’ pattern and practice of violating the CFDBPA, the Class is entitled to an award of statutory damages in an amount not to exceed the lesser of five hundred thousand dollars ($500,000) or 1 percent of the net worth of each Defendant, pursuant to California Civil Code § 1788.62(b).

51. As a result of Defendants’ violations of the CFDBPA, Plaintiff and the Class are entitled to an award of reasonable attorney’s fees and costs, pursuant to California Civil Code § 1788.62(c¢).

REQUEST FOR RELIEF

Plaintiff requests that this Court:

a) Assume jurisdiction in this proceeding;

b) Certify this case as a class action and appoint Plaintiff and Plaintiff’s counsel to represent the Class;

c) Find that Defendants violated the California Fair Debt Buying Practices Act, California Civil Code § 1788.52(d)(1);

d) Award Plaintiff statutory damages in an amount not less than $100 nor greater 1788.62(a)(2); e) Award the Class statutory damages in an amount not to exceed the lesser of five hundred thousand dollars ($500,000) or 1 percent of the net worth of each

Defendant, pursuant to California Civil Code § 1788.62(b);

N

Enter an Order enjoining Defendants from continuing the practices at issue in

this case, pursuant to California Civil Code § 3422;

g) Award Plaintiff the costs of this action and reasonable attorney’s fees, pursuant to California Civil Code § 1788.62(c);

h) Award Plaintiff treble damages, pursuant to California Civil Code § 3345; and

1) Award Plaintiff such other and further relief as may be just and proper. CONSUMER LAW CENTER, INC.

Dated: December 4, 2018 By: /s/ Fred W. Schwinn

Fred W. Schwinn (SBN 225575)

[1Raeon R. Roulston (SBN 255622)

[ ] Matthew C. Salmonsen (SBN 302854) CONSUMER LAW CENTER, INC.

1435 Koll Circle, Suite 104

San Jose, California 95112-4610

Telephone Number: (408) 294-6100

Facsimile Number: (408) 294-6190

Email Address: fred.schwinn@sjconsumerlaw.com

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