Hinsdale Law Firm, P. C.
SAN NiATEO COUN'fY
Airport Boulevard, Suite 106B
Burlingame, California 94010
JAN 1 9 201
Telephone: ( 650) 342- 4800
Court
Facsimile: ( 650) 342- 4845
D«
Attorney for Plaintiff
SUPERIOR COURT OF CALIFORNIA —COUNTY OF SAN MATEO
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LIMITED CIVIL DIVISION
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PENGUIN GROUP ( USA) INC.,
CASE NO.
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COMPLAINT FOR MONEY
CONLAN PRESS, INCORPORATED, a
PRINCIPAL: $ 3, 389. 95
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COLLECTION CASE
Plaintiff,
corporation; DOES ONE through TWENTY,
Defendants.
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Plaintiff alleges as follows:
FIRST CAUSE OF ACTION
2l
.
The true names and capacities, whether corporate, associate, individual or otherwise, of
defendants Doe One to Twenty, inclusive, are unknown to plaintiff who therefore sues said
defendants by such fictitious names and plaintiff will ask leave to amend this Complaint to set
I forth their true names and capacities when the same are ascertained.
Complaint for Money
Penguin Group vs. Conlan Press, et al.Page 2 n
. Plaintiff is informed and believes, and on such information and belief, alleges that at all
times herein mentioned, each of the defendants was acting as the agent and/ or servant of each
of the other defendants and all actions alleged herein were within the course and scope of the
defendant' s agency and/ or employment.
. This cause of action is not subject to the provisions of Sections 1812. 10 or 2984.4 of
the Civil Code of the State of California. The defendants reside and/ or the obligation was
entered into within this judicial district.
. Plaintiff s attorneys notified defendants in writing that they intended to sue and that suit
lo
could result in judgment, including costs pursuant to Section 1033 of the California Code of
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Civil Procedure. Notice was sent by first class mail, postage prepaid, and not returned by the
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Within the last four years defendants, and each of them, became indebted to plaintiff in
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the agreed sum of $3, 889. 95 for goods sold and delivered and/ or services rendered to
defendants, and defendants then and there agreed to pay said amount.
l7
. No part of said sum has been paid, except for the sum of $500. 00, although demand
therefor has been made, and there is now due, owing and unpaid the sum of $3, 389. 95, together
with interest thereon at the rate of 10% per year from March 18, 2009.
SECOND CAUSE OF ACTION
. Plaintiff realleges and incorporates herein by reference each and every allegation
contained in paragraphs 1, 2, 3, 4 and 6 of the First Cause of Action.
. Within the last four years defendants, and each of them became indebted to plaintiff on
I a book account for a balance due in the amount of $3, 389.95.
Complaint for Money
Penguin Group vs. Conlan Press, et al. Page 3 9. This book account accrued after January l, 1987. Plaintiff is entitled to attorneys fees
of the lesser of $1, 000. 00 or 25% of the principal balance, to wit the sum of $847.49, pursuant
to 1717. 5 Civil Code.
THIRD CAUSE OF ACTION
. Plaintiff realleges and incorporates herein by reference each and every allegation
contained in paragraphs l, 2, 3, 4 and 6 of the First Cause of Action.
.
Within the last four years there was an account stated by and between plaintiff and
defendants, and each of them, whereby it was agreed that defendants were indebted to plaintiff
in the sum of $3, 389. 95.
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a) The amount of $3, 389. 95, together with interest thereon at the rate of 10%
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per year
from March 18, 2009;
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WHEREFORE, plaintiff prays for judgment against defendants and each of them, for:
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b) Attorneys fees of $847. 49 pursuant to 1717. 5 Civil Code;
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c)
Dated:
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Cost of suit and such other and further relief as the Court deems proper.
I
HINSDALE LAW FIRM, P. C.
January 1 l, 2012
By
Jane Z. Hinsdale
Complaint for Money
Penguin Group vs. Conlan Press, et al.Page 4
PDF Page 1
PlainSite Cover Page
PDF Page 2
r
Jane Z. Hinsdale, CSB # 57308
1
Hinsdale Law Firm, P. C.
SAN NiATEO COUN'fY
433 Airport Boulevard, Suite 106B
2
Burlingame, California 94010
3
JAN 1 9 201
Telephone: ( 650) 342- 4800
Court
1
Facsimile: ( 650) 342- 4845
4
D«
Attorney for Plaintiff
5
6
7
SUPERIOR COURT OF CALIFORNIA —COUNTY OF SAN MATEO
g
9
LIMITED CIVIL DIVISION
io
111
11
PENGUIN GROUP ( USA) INC.,
CASE NO.
o °
o 0
C.'-'•
o
12
L,
o0
13
v @
o v
u m
vs.
COMPLAINT FOR MONEY
CONLAN PRESS, INCORPORATED, a
PRINCIPAL: $ 3, 389. 95
14
c
L
v
c $. ,,-
15
S ¢
M°
COLLECTION CASE
Plaintiff,
corporation; DOES ONE through TWENTY,
16
Defendants.
r
is
19
Plaintiff alleges as follows:
20
FIRST CAUSE OF ACTION
2l
22
1.
The true names and capacities, whether corporate, associate, individual or otherwise, of
23
defendants Doe One to Twenty, inclusive, are unknown to plaintiff who therefore sues said
24
defendants by such fictitious names and plaintiff will ask leave to amend this Complaint to set
25
I forth their true names and capacities when the same are ascertained.
26
27
28
Complaint for Money
Penguin Group vs. Conlan Press, et al.
PDF Page 3
n
2. Plaintiff is informed and believes, and on such information and belief, alleges that at all
1
2
times herein mentioned, each of the defendants was acting as the agent and/ or servant of each
3
of the other defendants and all actions alleged herein were within the course and scope of the
4
defendant' s agency and/ or employment.
5
3. This cause of action is not subject to the provisions of Sections 1812. 10 or 2984.4 of
6
the Civil Code of the State of California. The defendants reside and/ or the obligation was
entered into within this judicial district.
8
9
4. Plaintiff s attorneys notified defendants in writing that they intended to sue and that suit
lo
could result in judgment, including costs pursuant to Section 1033 of the California Code of
11
o °
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a:
?
0
o °°
12
V] a7 N
7
wo
o U
13
l4
Civil Procedure. Notice was sent by first class mail, postage prepaid, and not returned by the
I Post Office..
5.
Within the last four years defendants, and each of them, became indebted to plaintiff in
p
a C E o
c a
15
z¢
M°
the agreed sum of $3, 889. 95 for goods sold and delivered and/ or services rendered to
16
defendants, and defendants then and there agreed to pay said amount.
l7
6. No part of said sum has been paid, except for the sum of $500. 00, although demand
8
19
therefor has been made, and there is now due, owing and unpaid the sum of $3, 389. 95, together
20
with interest thereon at the rate of 10% per year from March 18, 2009.
21
SECOND CAUSE OF ACTION
22
7. Plaintiff realleges and incorporates herein by reference each and every allegation
23
contained in paragraphs 1, 2, 3, 4 and 6 of the First Cause of Action.
24
25
26
8. Within the last four years defendants, and each of them became indebted to plaintiff on
I a book account for a balance due in the amount of $3, 389.95.
27
28
Complaint for Money
Penguin Group vs. Conlan Press, et al.
2
PDF Page 4
9. This book account accrued after January l, 1987. Plaintiff is entitled to attorneys fees
1
of the lesser of $1, 000. 00 or 25% of the principal balance, to wit the sum of $847.49, pursuant
2
3
to 1717. 5 Civil Code.
4
THIRD CAUSE OF ACTION
5
10. Plaintiff realleges and incorporates herein by reference each and every allegation
6
contained in paragraphs l, 2, 3, 4 and 6 of the First Cause of Action.
7
11.
8
9
Within the last four years there was an account stated by and between plaintiff and
defendants, and each of them, whereby it was agreed that defendants were indebted to plaintiff
10
in the sum of $3, 389. 95.
11
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0
c
ca
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a) The amount of $3, 389. 95, together with interest thereon at the rate of 10%
l3
per year
from March 18, 2009;
14
o'
a
WHEREFORE, plaintiff prays for judgment against defendants and each of them, for:
12
ai
a
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a
l5
b) Attorneys fees of $847. 49 pursuant to 1717. 5 Civil Code;
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c)
17
Dated:
l8
Cost of suit and such other and further relief as the Court deems proper.
I
HINSDALE LAW FIRM, P. C.
January 1 l, 2012
19
By
Jane Z. Hinsdale
20
21
22
23
24
25
26
27
28
Complaint for Money
Penguin Group vs. Conlan Press, et al.
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