EXHIBIT A 

Case 3:17-cv-00791-JSC Document 1-1 Filed 02/16/17 Page 1 of 10
Service of Process 

Transmittal 

01/18/2017 

CT Log Number 530524629 

TO: Talaya Kluttz 

Synchrony Financial 

332 Minnesota St Ste W600 

Saint Paul, MN 55101-1535 

RE: Process Served in California 

FOR: Synchrony Bank (Domestic State: UT) 

ENCLOSED ARE COPIES OF LEGAL PROCESS RECEIVED BY THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS: 

TITLE OF ACTION: Lawrence Moroge, etc., Pltf. vs. Synchrony Bank, et al., Dfts. 

DOCUMENT(S) SERVED: Summons, Complaint, Notice(s) 

COURT/AGENCY: Alameda County - Superior Court - Oakland, CA 

Case # RG16843590 

NATURE OF ACTION: Violation of the telephone consumer protection act and the Rosenthal fair debt 

collection practices act 

ON WHOM PROCESS WAS SERVED: C T Corporation System, Los Angeles, CA 

DATE AND HOUR OF SERVICE: By Process Server on 01/18/2017 at 15:00 

JURISDICTION SERVED : California 

APPEARANCE OR ANSWER DUE: Within 30 days after service 

ATTORNEY(S) / SENDER(S): L. Paul Mankin 

The Law Office of L. Paul Mankin 

4655 Cass St., Ste 112 

San Diego, CA 92109 

800-219-3577 

ACTION ITEMS: SOP Papers with Transmittal, via UPS Next Day Air 

Image SOP 

Email Notification, Talaya Kluttz talaya.l.kluttz@syf.com 

Email Notification, Synchrony Financial Litigation 

syf.litigation@synchronyfinancial.com 

SIGNED: C T Corporation System 

ADDRESS: 818 West Seventh Street 

Los Angeles, CA 90017 

TELEPHONE: 213-337-4615 

Page 1 of 1 / DB 

Information displayed on this transmittal is for CT 

Corporation's record keeping purposes only and is provided to 

the recipient for quick reference. This information does not 

constitute a legal opinion as to the nature of action, the 

amount of damages, the answer date, or any information 

contained in the documents themselves. Recipient is 

responsible for interpreting said documents and for taking 

appropriate action. Signatures on certified mail receipts 

confirm receipt of package only, not contents. 

Case 3:17-cv-00791-JSC Document 1-1 Filed 02/16/17 Page 2 of 10
SUMMONS 

(CITACION JUDICIAL) 

NOTICE TO DEFENDANT: 

(AVLSO AL DEMANDADO): 

SYNCHRONY BANK, and DOES 1 through 10 inclusive, 

YOU ARE BEING SUED BY PLAINTIFF: 

(LO ESTA DEMANDANDO EL DEMANDANTE): 

LAWRENCE KEOROGE, an individual. 

RMIVAWWWWILV 

pOLORNMAMOEMAOMP 

FILED BY FAX • 

ALAMEDA COUMN 

December 21,2016 

CLERK OF 

THE SUPERIOR COURT 

By Angelica Mendoia, Deputy 

NOTICE You have bean sued. The court may decide against you without your being beard unless you respond within 30 days. Read the information 

below. 

YouiliNet 30 CALENDAR DAYS after this summons end legal papers we sowed on you to fite a written response at this coral and have a copy 

served on the pfaidiff. A totter or phone call will not protect you. Your wedeln response must be in proper legal form if you want the court to hear your 

wise. There may be a min fonn that you can use for your response. You can firuf these cowl forms and snare information at the California Courts 

Online Sell-Help Center (wwwcourdnfo.ce.goviseeirelp), your county law library, or 'Jur courthouse nearest you. If you cannot pay Owning fee. ask 

Ore court desk for a fee warm form. II you do not lila your response on time. you may lose the case by defaniL and your wages, money, and property 

may he Mon without further warning from the court. 

'Mare are ether legal requirements. Titus may want to call an attorney right away. If you do not 'MOW an attorney, you may want to can an attorney 

referral service. If you cannot afford an attorney, you may be eligible for free Ind conriecra from a nonprofit legal services program. You can locate 

these norprofitgroups at the California Legal Services Web silo (insw.tawbelpoelikirda.on3). the California Courts Online Setf-Hdp Center 

(onrwanatbrictoasembeffholp), or by contacting your local court or county bar association. MOTE The mud has a statutory hen for waived lees end 

costs on any settkunde or arbitration award of Si 0,00e or more in a thril case. The coast's Hart must be paId Mom Ore owl will dismiss the case. 

lAVJSOJ Lo ban demandada Si no responde dantro de 30 dart to cone pada deddir en an contra ain eseucaar su keratin. Lea to InformactOn 

co:viewer*. 

Time 30 DM OE CALENDARIO *spuds* quo to enfreguen este draft y popsies (wen pare Prasatilar ulte tusiamsts Par swab en We 

carte y haver quo an entregue ens copla al demenrainle. Una carte curioYamada blank° no 1 o protagen. Su respueste par walla gene qua ester 

en Moneta Avid conecto at *see quo procesen =caw en to code. Ea postai qua hose en formulerio quo Wed puede user pore an respuesle. 

Puede enconirer egos Itumulorlas de la cone y mds arlannackin on o Wont,* de Ayudo do las Cortes do Colibmie (orew.sucorto.algov), on b 

bieffobee do byes de au condo* o onto cone quo to quadri Wawa= Si no puede pager le cut* de proseruaddn, Oa at secreted° de 1 e cute 

quo to do err formula* de menden de pogo do mobs. Si no promote su respueste 9 (tempo. puede pardor of case pot IneumplenTanto y la carte le 

podni quite, su sueido, tenons y Nem sin mas adionancia 

Hay alms midst:as regales. Es recomondabla quo same a urn abogado tatarliatamenle. Si °comes a an abogado. puede Hamar a an send* de 

runtish:1n a ettogados. Si no puede pagcre en etcogado. as posttest =mum can ts requiskos pars obterier servicies togas grekdos de un 

programed& zoned* legates sin liras* lucro. Puede enowdrer estosgnmos sin Snead, luens en et &do web do California Legal Sondem, 

tramw.lawbelpceafamia.otg), one! Centro de Ayuda de lee COrt03 do Cordon*. Orrnmsussite42.904 a Poandoso on mango canto Cate 001 

oolegb de abogodos Wats. AVM& Parley, la aorta Nona demob° a radamor las mobs yfos costes exerdwe par importer un gravamen sabre 

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pager at gravamen de to code antes de qua la eons puoda Macho, al coo. 

The name and address of the court Is: 

( E noggin) y Oman de 1a cork, es): Rene C. Davidson Courthouse 

1225 Fallon Street, 

Oakland, CA 94612 

The name, address, and telephone number of plaintiff° attorney, or plaintiff without an attorney. Is: 

nombre. la drisaItin y el amens do talikono del ebogecto del demendanie, o ' • • '' ' no liana abogedo, es): 

:M=46843590 

TO: 13232073885 From: +Restricted Date: 12/23/16 Time: 10:32 All Page: 01 /MA.... Fax Server 12/23/2016 10:32:06 AM PAGE 1/001 Fax Server 

TO: 15102671544 From: 13232073885 Date: 12/20/16 Time: 5:31 PM Page: 10/10 

SUM-100 

L. Paul Mankin (SBN 264038) 4655 Cass Street, Suite 112, San 100-219-3577 

6 

DATE: 

(Fisch 

Clerk, by 

(Seastado) 

.D8P1111, 

(AO/to) 

(For roof of sandal of dds summons, use Proof of Service of Summons "ono POS010).) 

ate cilanan use as fonnulado Proof of Service of Summons, (POS-010)). • 

NOTICE TO THE PERSON SERVED: You are served 1. 1=3 as an individual defendard. 2. ED as the person sued under the Settle:is name Of (specify): 

3, En on behalf of (specify): Synchrony Bank 

under. CiEl CCP 416.10 (corporation) =I CCP 416.60 (minor) 

M CCP 418.20 (defunct corporation) ED CCP 416.70 (conservatee) 

M CCP 410.40 (association or partnership) I= CCP 418.90 (authorized person) 

=I other isPed&i: 

4. I=1 by personal delivery on (dote): 

Tone Adapt' ler Marefahxy Ihn 

Jadzill Council cd Caftreks 

SUAICO dot mr 1, anti 

SUMMONS Coon dcli Precothis 114122C4 465 

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Pan I oil 

Case 3:17-cv-00791-JSC Document 1-1 Filed 02/16/17 Page 3 of 10
LAWRENCE MJOROGE, an individual, 

Plaintiff, 

VS. 

SYNCHRONY BANK, and DOES 1 through 

10 inclusive, 

Defendant. 

Case No.: 

COMPLAINT 

Amount not to exceed $10,000.00 

1. Violation of the Rosenthal Fair Debt 

Collection Practices Act; 

2. Violation of the Telephone Consumer 

Protection Act. 

1 

To: 13232073885 From: +Restricted Date: 12/23/16 Time: 10:31 AM Page: 01 

Fax Server 12/23/2016 10:31:31 AM PAGE 1/001 Fax Server 

To: 15102671544 From: 13232073885 Date: 12/20/16 Time: 5:31 PM Page: 02/10 

L. Paul Mankin (SBN 264038) 

The Law Office or L. Paul Mankin 

4655 Cass St:, Ste. 112 

San Diego, Ca 92109 

Phone: (800)-219-3577 

Facsimile: (323) 207-3885 

pmankin@Paulmanicin.com 

Attorney for Plaintiff 

LAWRENCE MJOROGE 

FILED BY FAX 

ALAMEDA COUNTY 

December 21, 2016 

CLERK OF 

THE SUPERIOR COURT 

By Angelica Mendota, Deputy 

CASE NUMBER: 

RG16843590 

SUPERIOR COURT OF THE STATE OF CALIFORNIA 

FOR ALAMEDA COUNTY 

LIMITED JURISDICTION 

INTRODUCTION 

1. This is an action for damages brought by an individual consumer for Defe.ndant's 

violations of the Rosenthal Fair Debt Collection Practices Act, Cal Civ. Code §1788, et seq. 

(hereinafter "RFDCPA") which prohibits debt collectors from engaging in abusive, deceptive, 

and unfair practices. Ancillary to the claims above, Plaintiff further alleges Claims for 

COMPLAINT - 1 

Case 3:17-cv-00791-JSC Document 1-1 Filed 02/16/17 Page 4 of 10
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Defendant's violations of the Telephone Consumer Protection Act., 47 U.S.C. §227, et seq.. 

(hereinafter "TCPA"). 

PARTIES 

2: Plaintiff LAWRENCE M.TOROGE ("Plaintiff"), a natural person who at all times herein 

mentioned was a resident of the City of Berkeley, County of Alameda, and State of California 

and is a "debtor" as defined by Cal. Civ. Code §1788.2(h). 

3. At all relevant times herein, Defendant, SYNCHRONY BANK (hereinafter 

"Defendant") was a company engaged, by use of mails and telephone, in the business of 

collecting a debt from Plaintiff which qualifies as a "consumer debt" as defined by Cal. Civ. 

Code §1788.2(0. Defendant regularly attempts to collect debts alleged to be due another, and 

therefore is a "debt collector" as defined by the RFDCPA, Cal. Civ. Code §1788.2(c). 

4. Plaintiff does not know the true names and capacities, whether corporate, partnership, 

associate, individual or otherwise, of Defendants sued herein as Does 1 through 10, inclusive, 

and therefore names said Defendants under provisions of Section 474 of the CaliforniaCode of 

Civil Procedure. 

5. Plaintiff is informed and believes, and on that basis alleges that Defendants Does 1 

through 10 are in some .manner responsible for acts, occurrences and transactions set forth herein 

and are legally liable to Plaintiff. 

FACTUAL ALLEGATIONS 

6. At various and multiple times prior to the filing of the instant complaint, including within 

the one year preceding the filing of this complaint, Defendant contacted Plaintiff in an attempt to 

collect an alleged outstanding debt. 

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COMPLAINT -2 

Case 3:17-cv-00791-JSC Document 1-1 Filed 02/16/17 Page 5 of 10
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7. This alleged financial obligation was the result of a "consumer credit transaction", as 

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defined by Cal. Civ. Code §1788.2(e), and is therefore a "consumer debt", as defined by Cal. 

Civ. Code §1788.2(0. 

8. Defendant has regularly placed calls to Plaintiff in its attempt to collect the alleged debt 

via Plaintiff's cellular phone. 

9. Within one year prior to the filing of this action, specifically on or around September 

2016, Defendant caused Plaintiff's telephone to ring repeatedly and continuously to annoy 

Plaintiff. Defendant communicated with Plaintiff with such frequency as to be unreasonable 

under the circumstances and to constitute harassment. The frequency and pattern of Defendant's 

telephone calls to Plaintiff evidences Defendant's intent to harass Plaintiff. 

10. Additionally, Defendant is attempting to collect an alleged debt that Plaintiff does not 

owe. 

11. As an illustrative example, on Defendant contacted Plaintiff at the following times: 8:25 

am and 11:25 am on September 24, 2016; 10:41 am and 12:51 pm On September 25, 2016; 10:15 

am and 1:15 pm on September 26,2016; 10:01 am and 1:14 pm on September 27,2016; 7:25 

am, 8:22 am, and 8:25 am on September 28, 2016. 

12. Moreover, even if Defendant once had Plaintiff's consent to contact him on his cellular 

telephone using an "ATDS", Plaintiff has since revoked that consent. 

13. On information and belief, Defendant utilized an "automatic telephone dialing system" as 

defined by 47 US.C. § 227(a)(1), to place its repeated collection calls to Plaintiff seeking to 

collect debt allegedly owed. This is evidenced bythe volume and nature of calls that Defendant 

has placed to Plaintiff's cellular phone. 

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COMPLAINT -3 

Case 3:17-cv-00791-JSC Document 1-1 Filed 02/16/17 Page 6 of 10
14. Defendant's conduct violated the RFDCPA in multiple ways, including but not limited 

to: 

a) Communicating, by telephone or in person, with plaintiff with such frequency as to 

be unreasonable and to constitute a harassment to Plaintiff under the circumstances 

(Cal. Civ. Code §1788.11(c)); 

b) Communicating at an usual time, unusual place, or unusual time and place known to 

be inconvenient for the consumer. before 8:00 am and after 8:00 pm (Cal. Civ. Code 

§ 1692c(a)(1)); 

c) Causing a telephone to ring repeatedly or continuously to annoy Plaintiff (Cal. Civ. 

Code §1788.11(d)); 

d) Committed any conduct the natural consequence orwhich-is to harass, oppress, or 

abuse any person (Cal. Civ. Code § 1692d); 

e) Caused the telephone to ring or engaged any person in telephone conversations 

repeatedly (Cal. Civ. Code § 1692d(5)). 

15. As a result of the above violations of the RFDCPA, Plaintiff suffered and continues to 

suffer injury to Plaintiff's feelings, personal humiliation, embarrassment, mental anguish and 

emotional distress, and Defendant is liable to Plaintiff for Plaintiff's actual damages, statutory 

damages, and costs and attorney's fees. 

COUNT 1: VIOLATION OF THE ROSENTHAL FAIR DEBT COLLCTION 

PRACTICES ACT 

16. Plaintiff reincorporates paragraphs 1 through 18 as if fully written herein. 

17. § 1788.17 of the RFDCPA mandates that every debt collector collecting or attempting to 

collect a consumer debt shall comply with the provisions of Sections 1692b to 1692j, inclusive, 

of, and shall be subject to the remedies in Section 1692k of, Title 15 of the United States Code 

statutory regulations contained within the FDCPA, 15 U.S.C. § 1692d, and § 1692d(5). 

18. To the extent that Defendant's actions, counted above, violated the RFDCPA, those 

actions were done knowingly and willingly: 

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COMPLAINT- 4 

Case 3:17-cv-00791-JSC Document 1-1 Filed 02/16/17 Page 7 of 10
1 

2 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff respectfully prays that judgment be entered against Defendant 

for the following: 

A. Actual damages; 

B. Statutory damages 

C. Costs and reasonable attorney's fees; and 

D. For such other and further relief as may be just and proper. 

COUNT II: VIOLATION OF THE TELEPHONE CONSUMER PROTECTION ACT 

19. Plaintiff reincorporates by reference all of the preceding paragraphs. 

20. The foregoing acts and omissions of Defendant constitute numerous and multiple 

negligent violations of the TCPA, including but not limited to each and every one of the above 

cited provisions of 47 US.C. § 227 et seq. 

21. As a result of Defendant's negligent violations of 47 US.0 § 227 et seq., Plaintiff is 

entitled an award of $500.00 in statutory damages, for each and every violation, pursuant to 47 

U.S.C. § 227(b)(3)(B). 

22. The foregoing acts and omissions of Defendant constitute numerous and multiple 

knowing and/or willful violations of the TCPA, including but not limited to each and every one 

of the above cited provisions of 47 U.S.C. § 227 et seq. 

23. As a result of Defendant's knowing and/or willful violations of 47 US.C. § 227 et seq., 

Plaintiff is entitled an award of $1,500.00 in statutory damages, for each and every violation, 

pursuant to 47 US.C. § 227(1))(3)(B) and 47 US.C. § 227(b)(3)(C). 

24. Plaintiff is entitled to and seeks injunctive relief prohibiting such conduct in the future. 

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COMPLAINT -5 

Case 3:17-cv-00791-JSC Document 1-1 Filed 02/16/17 Page 8 of 10
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PRAYER FOR RELIEF 

WHEREFORE, Plaintiff respectfully prays that judgment be entered against the Defendant for 

the following: 

A. As a result of Defendant's negligent violations of 47 U.S.C. 5227(b)(1), Plaintiff is 

entitled to and request s$500 in statutory damages, for each and every violation, 

pursuant to 47 USX. 227(b)(3)(11); 

B. As a result of Defendant's willful and/or knowing violations of 47 US C. 5227(b)(1), 

Plaintiff is entitled to and requests treble damages, as provided by statute, up to 

$1,500, for each and every violation, pursuant to 47 U.S.C. §227(b)(3)(B) and 47 

US. C. §227(b)(3)(C); 

C. Any and all other relief that the Court deems just and proper; 

PLAINTIFF HEREBY REQUESTS A JURY TRIAL 

Date: December 30, 2016 

4'::_._:> ......,...--‘..---....___.. 

Paul Mullein, Esq. 

Attorney for Plaintiff 

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COMPLAINT -6 

Case 3:17-cv-00791-JSC Document 1-1 Filed 02/16/17 Page 9 of 10
r The Law Office of L. Paul Mankin 1 1 

Ann: Mankin IV, Paul 

4655 Cass St.. Ste 112 

San Diego. CA 92109 

u erior Court of California, County of Alameda 

N1joroge 

Synchrony Bank 

Plaintiff/Petitioner(s) 

Vs. 

No. RG16843590 

NOTICE OF CASE MANAGEMENT 

CONFERENCE AND ORDER 

Limited Jurisdiction 

Defendantatespondent(s) 

(Abbreviated Title) 

To ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: 

Notice is given that a Case Management Conference has been scheduled as follows: 

Pate: 05/08/2017 

'Time: 09:00 AM 

Department: 25 

Location: Administration Building 

1221 Oak Street, Oakland CA 94612 

Internet: www.alameda.courts.ca.gov 

JudgE Ronni MacLaren 

Clerk: Angel Logan 

Clerk telephone: (510) 267-6941 

E-mail: 

Dept.25(iialameda.courts.ca.gov 

(Fax: (5N) 267-5726 

ORDERS 

I. Plaintiff must: 

a. Serve all named defendants and tile proofs of service on those defendants with the court within 60 days 

of the filing of the complaint (Cal. Rules of Court. 3.1 I0(b)); and 

b. Give notice of this conference to all other parties and file proof of service. 

Defendant must respond as stated on the summons. 

3. All parties who have appeared before the date of the conference must: 

a. Meet and confer, in person or by telephone as required by Cal. Rules of Court, rule 3.724; 

h. File and serve a completed Case Management Statement on Form CM-I10 at least 15 days before the 

Case Management Conference (Cal. Rules of Court. rule 3.725); and 

c. Post jury fees as required by Code of Civil Procedure section 631. 

4. If you do not follow the orders above, the court may issue an order to show cause why you should not be 

sanctioned under Cal. Rules of Court, rule 2.30. Sanctions may include monetary sanctions, striking pleadings 

or dismissal of the action. 

5. You are further ordered to appear in person or through your attorney of record at the Case Management 

Conference noticed above. You must be thoroughly familiar with the case and fully authorized to proceed. You 

may be able to appear at Case Management Conferences by telephone. Contact CourtCall, an independent 

vendor, at least three business days before the scheduled conference. Call 1-888-882-6878, or fax a service 

request to (888) 882-2946. The vendor charges for this service. 

6. You may tile Case Management Conference Statements by E-Delivery. Submit them directly to the E-Delivery 

Fax Number (510) 267-5732. No fee is charged for this service. For further information, go to 

ninv.rrhtnnIkt.COlfrivali.ept,11: 

7. The judge may place a Tentative Case Management Order in your case's on-line register of actions before the 

conference. This order may establish a discovery schedule, set a trial date or refer the caw to Alternate Dispute 

Resolution, such as mediation or arbitration. Check the website of each assigned department for procedures 

regarding tentative case management orders at wit•tv.rdanayht.c. is.ea.gar/de. 

Form Approved for Mandatory Use NOTICE OF CASE MANAGEMENT CONFERENCE AND ORDER Page 1 of 2 

Superior Court of California. County 

of Alameda 

ALA CIV-100 fRev. 07-01-20151 

Case 3:17-cv-00791-JSC Document 1-1 Filed 02/16/17 Page 10 of 10