GABA LAW
`Rodolfo Gaba, Jr. (State Bar No. 230475)
`25 Mauchly (cid:127) Suite 300
`Irvine, California 92618
`888-391-1228 Phone / 949-207-7108 Facsimile
`updates@gaba.law
`
`9/10/2024
`
`Attorneys for Plaintiff
`NORGUARD INSURANCE COMPANY
`[194539.001]
`Debt Collector License Pending
`SUPERIOR COURT OF THE STATE OF CALIFORNIA
`FOR THE COUNTY OF SAN MATEO, SAN MATEO HALL OF JUSTICE
`
`24-CLJ-05636
`Case No.:
`COMPLAINT FOR FAILURE TO
`PAY INSURANCE PREMIUMS
`
`DEMAND: $15419.39
`LIMITED CIVIL
`
`)))))))))))))
`
`NORGUARD INSURANCE COMPANY,
` Plaintiff,
` vs.
`COPPERGOLD ELECTRIC INC., A
`CORPORATION; and DOES 1 to 100,
`inclusive,
` Defendants.
`
`Plaintiff NORGUARD INSURANCE COMPANY (“Plaintiff”) alleges the following
`causes of action against COPPERGOLD ELECTRIC INC., A CORPORATION; and
`DOES 1-100, inclusive (the “Defendant”), as follows:
`1.
`Plaintiff is, and at all times relevant was, a corporation, organized and
`existing under and by virtue of the laws of the state of its incorporation.
`2.
`Plaintiff alleges on information and belief that the Defendants, or some of
`them, maintain a principal place of business within the above-referenced County and
`Judicial District.
`3.
`The true names and capacities, whether individual, corporate, associate,
`or otherwise, of Defendants Does 1-100, inclusive, are unknown to Plaintiff, who
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`COMPLAINT - 1
`
`

`

`therefore sues said Defendants by such fictitious names. Plaintiff alleges on information
`and belief that each of the Defendant designated herein as a fictitiously named
`defendant is, in some manner, responsible for the events and happenings referred to,
`either contractually or tortiously, and/or that such fictitiously named Defendant claim
`some right, title or interest to the property described herein below and/or that such
`fictitiously named Defendant are liable in some manner for the obligation described
`herein below. When Plaintiff ascertains the true names and capacities of Does 1-100,
`Plaintiff will amend this complaint accordingly.
`4.
`Plaintiff alleges on information and belief that at all times herein
`mentioned, all Defendants named herein each acted in concert and conspired with or
`aided and abetted each other to do the acts complained of in this complaint, and that
`each defendant acted as an agent for the other at all times.
`5.
`Plaintiff alleges on information and belief that the obligation sued upon is
`not subject to the provisions of Civil Code §2984.4 or Civil Code §1812.10.
`6.
`Within the last four years, Defendants, and each of them, applied for an
`insurance policy from the Plaintiff. Subsequently, Plaintiff did in fact issue policy
`number COWC048020 for the period 08/23/2019 to 08/23/2020, to the Defendants, and
`each of them.
`7.
`On or about 03/01/2021, Defendants became indebted to Plaintiff in the
`sum of $18419.39 for unpaid premiums under the policy. A copy of the invoice is
`attached hereto as Exhibit 1. Defendants subsequently paid $3000.00 which reduced
`the balance to $15419.39.
`8.
`Although demand therefore has been made, no part of $15419.39 has
`been paid, and said balance, together with interest thereon at the maximum statutory
`rate of 10.0000% per annum, from 10/06/2023, is now due, owing and unpaid.
`////
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`COMPLAINT - 2
`
`

`

`WHEREFORE, Plaintiff prays for judgment in its favor and against Defendants,
`and each of them, and Does 1-100, as follows:
`9.
`For damages in the principal sum of $15419.39;
`10.
`For interest thereon at the rate of 10.0000% per annum, from
`10/06/2023;
`11.
`12.
`
`For costs of suit incurred herein;
`For such other and further relief as this court may deem just and proper.
`
`Dated: 09/05/2024
`
`GABA LAW
`
` By:________________________________
`Rodolfo Gaba Jr.
`Attorneys for Plaintiff
`NORGUARD INSURANCE COMPANY
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`COMPLAINT - 3
`
`

`

`EXHIBIT “1”
`
`EXHIBIT “1”
`
`

`

`Coppergold Electric Inc
`PO Box 82
`Daly City, CA 94016
`
`In response to the ongoing COVID-19 crisis, we have payment options available for our customers experiencing financial
`hardships as a result of the COVID-19 pandemic. We will also continue to comply with any directives issued by state
`departments of insurance on billing issues. We value your business and want to do what we can to help you during this
`difficult time. If you are experiencing financial hardship as a result of the COVID-19 pandemic, please call us at
`800-673-2465 to discuss billing and make alternative payment arrangements.
`SELF SERVICE IS AVAILABLE 24/7 on our Policyholder Service Center available from https://policyholder.guard.com or
`our BHGUARD mobile app.
`TO PAY YOUR BILL ONLINE OR ENROLL IN OUR DIRECT DRAFT PROGRAM: Log in at https://policyholder.guard.com
`and click "Billing & Payments" or from guard.com go to "Policyholders" and click Online Payments. Easiest way to pay your
`bill - try our BHGUARD mobile app!
`GO GREEN! You can save time and trees by opting to receive your policy documents from us electronically on our
`Policyholder Service Center: https://policyholder.guard.com. Within your Account Summary on the home page, click the "Go
`Green" button. Or use our BHGUARD mobile app and select "Go Green" on the Policy Details screen.
`Payment detail by transaction date is available at our Policyholder Service Center: https://policyholder.guard.com
`Premium calculation detail for each payroll check date is available at our Policyholder Service Center:
`https://policyholder.guard.com
`Questions? Call our Customer Service Representatives at 800-673-2465, or e-mail csr@GUARD.com. Or login to the
`Policyholder Service Center at https://policyholder.guard.com and chat with a representative. Please provide the Policy
`Number or Customer ID shown at the top of this page when you call.
`
`e
`
`Register for our Policyholder Service
`Center at www.guard.com/pscregister/
`or download the BHGUARD app today!
`
`Date
`08/28/2019 Beginning Premium
`10/07/2019 Endorsement
`02/08/2021 Final Audit
`
`

`

`Actual Earned Premium
`Payments Applied
`Account Balance
`AMOUNT DUE 03/01/2021
`
`Make your check payable to WestGUARD Insurance Company and remit with the coupon below.
`
`

`

`DOWNLOAD OUR MOBILE APP!
`Policyholder Service Center
`
`"Berkshire
`GUARD Companies
`
`i
`ma GUARD
`
`_ - _
`
`Register
`Today!
`
`www.guard.com/
`pscregister/
`
`We value cur policyholders, so we take advantage
`of technology to offer fast and easy online
`self-service solutions.
`
`Available from www.guard.com/pscregister/ or mobile app, our
`Poticyhoider Service Canter is the gateway to a wide range of
`resources used by our customers to manage their insurance
`with us. From reperting a claim to making a payment online ta
`reviewing helpful loss control information, our service center is
`designed to offer convenient access to the tools you use most!
`
`Our BHGUARD mobile app offers many of the same features
`with the latest technology always in mind. Get the app on
`Google Play or download fram the Apple App Store, today!
`Need heip? Contact 1-800-673-2465 or csr@quard.com.
`
`COVERAGE-SPECIFIC FEATURES
`Workers' Compensation
`Find a physician
`Complete a premium audit
`Download state posting notices
`Implement a return-to-work program
`Report payroll (self-reporting policy)
`Commercial Auto
`Access vehicle insurance ID cards
`View all vehicles under a policy
`
`ACCOUNT MANAGEMENT
`> View and print policy documents
`> Generate a Certificate of
`Insurance {COT}
`> Download loss control materials
`2 Search our video library
`> Chat llve with a representative
`> Go paperless
`2 Access other news and resources
`
`BILLING & PAYMENTS
`> Make a credit card payment
`> Transfer funds from your bank
`> Submit multi-policy payments
`> Set up re-eccurring payments
`> View billing history
`
`CLAIMS
`> Report 4 new claim
`2 Upload photes and documents
`> View policy loss history
`2 Monitor the status of a claim
`> Chat with an adjuster
`
`Visit www.guard.com/pscregister/ or
`download the BHGUARD app today! / SERVICE CENTER
`
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`GUARD Ineurance Companies (HHGKC) with principal place of business al 39 Publkc Square, Wilkes-Barre, PA 18701 & BHGN September11,2020.
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