Preview
FILED: NASSAU COUNTY CLERK 11/20/2020 11:43 AM INDEX NO. 606231/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/20/2020
AFFIDAVIT OF FACTS AND SALE OF ACCOUNT BY CITIBANK, N.A.
(Debt Buyer Actions)
STATE OF MISSOURI )
) ss.
COUNTY OF PLATTE )
Account Holder: PATRICIA WILLIAMS Account #: ending in 4170
SSN/EIN/TIN #: xxx-xx-1718
The undersigned, being duly sworn, deposes and says:
1. I am an employee of Citibank, N.A. ("Citibank"), an Original Creditor as defined in
Section 202.27-a of the New York Uniform Civil Rules forThe Supreme Court and The
County Court, and I have personal knowledge of and access to Citibank's books and records
("Business Records"), including elcetronic records, relating to a pool of charged-off consumer
credit accounts sold or assigned by Citibank to Cavalry SPV I,LLC ("Debt Buyer"), on
08/23/2019 (the "Sale"), which inciüded the account 4170 ("Account") of the consumer
PATRICIA WILLIAMS ("Consumer") identified in the exhibits attached hereto and
incorporated herein. As part of the Sale, Citibank assigned allof itsinterest in the Account,
including the right to any proceeds from the Accounts, to Debt Buyer, and Citibank transferred
business records relating to the Account to Debt Buyer. A true and correct copy of the bill of
sale which pertains to the Account is attached as an exhibit to thisaffidavit.
2. In my position, I also have personal knowledge of Citibank's procedures for creating
and maintaining Citibank's business records pertaining to the Account ("Business Records"),
including Citibank's procedures relating to the sale and-assignment of consumer credit
accounts. Citibank's Business Records were made in the regular course of business and itwas
the regular course of such business to make the Business Records. The Business Records were
made at or near the time of the events recorded. Based on my knowledge of Citibank's
Business Records, I have personal knowledge of the facts set forth in this affidavit.
3. Citibank and Consumer were parties to a credit agreement ("Agreement"), the terms of
which are reflected in the last statement sent to Consumer Citibank prior to charge-
billing by
off, which is attached hereto as an exhibit. Consüñwr agreed to pay Citibank for allgoods,
services and cash advañces provided pursuant to the Agicement. The date and the amount of
the last payment, ifany, made by Consumer are set forth in an exhibit attached hereto and
made a part hereof. Consumer defaulted and a demand for payment was made by Citibank. A
true and correct copy of the Agrccmcat is attached as an exhibit to this affidavit.
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FILED: NASSAU COUNTY CLERK 11/20/2020 11:43 AM INDEX NO. 606231/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/20/2020
4. At the time of the Sale, Consumer owed the amount set forth in the exhibits attached
hereto and made a part hereof, which exhibits may also show the name of Consumer; the last
four digits of the Account number, the date and amount of the charge-off balance; the date and
amount of the last gayumut, ifany; the total amounts, ifapplicable, of any post-charge-off
interest and post-charge-off fees and clairges; any post-charge-off credits or payments made by
or on behalf of Consumer; and the balance due at the time of the Sale. The above statements
are true and correct to the best of my personal knowledge.
I solemaly affirm under the pena!6es of perjury and upon personal knowledge that the cesterns
of the foregoing paper are true.
EXECUTED on J () , 20.J_@.
Signature
Connie Campbell
Name
STATE OF MISSOURI )
) as.
COUNTY OF PLATTE )
Subscribed and sworn to before me by _ço-p lecamdelj this day
of 20 .
CAROLYN E HUGHES
Public See
Notary
My commission expires:
Personally known _ OR
Produced identification
Type of identification produced:
as Emsw B *
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FILED: NASSAU COUNTY CLERK 11/20/2020 11:43 AM INDEX NO. 606231/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/20/2020
CERT1FICATE OF CONFORhiITY
I, Frahnaaz Shoukatali. an attomey-at-law of the State of Missouri who is licensed to
practice law in the State of Missouri and is fully acquainted with the laws of the State of
Missouri pertaining to the acknowledgement or proof of deeds of real property to be recorded
therein, do hereby certify that I am duly qualified to make this certificate of conformity pursuant
to Section 299-a of the Real Property Law of the State of New York and hereby certify that the
acknowledgement or proof upon the foregoing document was taken by Carolyn E. Hughes. a
notary pubile in the State of h4issouri, in the manner prescribed by the laws of the State ot
Missouri and confonus to the laws thereof in allrespects.
IN WITNESS WHEREOF, I have hereunto set my signature, this day of
September, 2019
Missouri Bar # 68388
Frahnaaz Shoukatali
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FILED: NASSAU COUNTY CLERK 11/20/2020 11:43 AM INDEX NO. 606231/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/20/2020
Conknot ID: CVilMUMAAO21819
Document ID: CV8MUMAAO22119C2
Document ID: 081319CV 1MU3FMB1
BILL OF SALE AND ASSIGN1¼ENT
THIS BILL OF SALE AND ASSIGNMENT dated August 23, 2019, is by Citibank, N.A., a
national banking assüciüiica organized under the laws of the United States, located at 701 East
605 57117 to SPV
Street North, Sioux Falls,SD (the "Bank") Cavalry 1, LLC, organized under the
laws of the State of Delaware, with itsheadquarters/principal place of business at 500 Summit
Lake Drive, Suite 400, Valhalla, NY 10595 ("Buyer").
For value received and subject to the terms and conditions of the Master Purchase and Sale
Agreement dated Febmary 18, 2019 and Addendum No. 2 dated February 21, 2019, between
Buyer and the Bank (the "Agreement"), the Bank does hereby transfer, sell,assign, convey. grant,
bargain, set over and deliver to Buyer, and to Buyer's successors and assigns, the Accounts
described in Exhibit 1 to the Addêüdü= and the finni electronic file.
Citibank, N,A.
(Signature)
asyeewbsi
Name:
Title: Authorized Party
.
Cavaky 021859
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FILED: NASSAU COUNTY CLERK 11/20/2020 11:43 AM INDEX NO. 606231/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/20/2020
Contract ID: CV8MUMAAO21819
Document ID: CV8MUMAA022119C2
Document ID:081319CV l MU3FMAl
Exhibit 1
The individual Accoua.ts transferred are described in the imal siêctrañic fileand delivered
by the Bank to Buyer, the same deemed aiiadied hereto by this reference.
# of
Lot Sale ID Accounts Sale Balance Cut-Off Date
Brands OS1319CV1MU3FM 08/13/2019
Fresh Flow
Cavaky 021819
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FILED: NASSAU COUNTY CLERK 11/20/2020 11:43 AM INDEX NO. 606231/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/20/2020
PATRICIA W1LUAMS
www.ettleards.com
Member Since 2017 Account nur-borending 19:4170 Customer Servica 1•866-69&5673
Bi ingPeriod:06/t4/19•07/11/19 TTY-hearing-irrpairedservicesonly 1-800-325-2865
BOX 65005IOUX FALLS, 50 57117
JULY STATEMENT Account Summary
Minimum payment due: $10,82337 Previous balance $10,822.72
New balance as of 07/11/19: $10,823.57 Payments •$0,00
Payment due date: 08/09/19 Credits •$0.00
See the ast nae of this statemeM
forlinoorta© inDwation about how to Purchases +$0.00
avoid on purcnases.
paying inferest Cash advances +$0.00
Fees +$0.00
Interest +$0.85
War balance $10,823.57
'Mrer Payment Warning:Ifyou make on'ythe stmimum payment each
period,you wil:pay more in inbrestand it wii.
take you longertopay offyour
balance.For example·
Credit Limit
15you make no additional ! You will
pay off
the And you wilt end up Credit timit $11,200
charges ostagthiscard ; balanceshown on this an estimated Includes53,400cash advance thnit
and each month you pay- statement in about... I-
Only the min mum payment 1roo this) $10.824
For information
about cr&dettoonsergseave, cain377-337-8168New York
residents
ma Banken
contact the New Y©4 5tate apartment to obtain a comparative
It card rates, fees ad
listing of cre grace aerledsy ca11c.g1·B77-2264697.
Savings
Spotlight
Your Citi Simplicity Lifetime Savings:
$3,779J6
See page 3 to view your
Savings Summary.
P
Pay your blit
from anywhere
virtually
Mobild' M'nhaum payment due $10,823.57
with thecltt App and citP online
New balance $10,823.57
To download'
Text 'ApplS$ to MyCRI (692404) Payment due date 08/09/19
or go to your device%app 3%ft.
or vanwww.ealeards.com
Amount enclosed:
030000 M 32 A O Account number ending in 4170
PATRICIA WILLIAMS CITI CARDS
783 TAFT ST PO Box 70166
NORTH BELLMORE NY 11710-1219 PhiladelphiaPA 19176-0166
15009 1082357 1082357 0020000 51170 0'i03
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FILED: NASSAU COUNTY CLERK 11/20/2020 11:43 AM INDEX NO. 606231/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/20/2020
www.elticards.com Custeer Service 1-666-696-5673 Page 2 of 3
TTY-hearicq impaired serviceson y 1-800-325-2865
PATRICIA WILLIAMS
Account Summary re
Trans PW
dat e ate Dhmr i × Amognt
rees energ,a Savings Spotlight
Totalfees charged In this period $0.00 Your Citi Simplicity®
bliting
Savings Summary
Interest charged From This Period:
Billing
Date Description Arnou"t O Interest: $158.87
. .-.-..
......-...................................
......
...,-.-......
_.-..-..-....__ ___.-....
07/11 INTEREST CHARGED TO STANDARD PURCH 50,85
Totalinterestcharged in this period
bliling $0485
2019 totals year-to-date
Totalfees charged in 2019 $Q.00
. ....-.-..-...............-...-...-.-.--.
...-.-..-....-.....--.-.........-. -...-.-.-.
Totalinterestcharged in2019 $0.85
TOTAL
Interest charge calculation Days In billing cycle: 28
SAVINGS
Annual percente e Balancesubject
Balancetype rate (AP ) tointerestrate lattrestcharge
.-
..... ... - .. . ...-..-. . -. .
fyRCH E5_,_
Standard Parch 0.00% $1,61839 (0) $0.00
.E pired 07/
0/19)
..3.. 0DEC.
Standard Parch 19.24% (y} $1.61839(0) $0.85
CITI SIMPLICITY LIFETIME SAVINGS:
(5tandard Purchase
-..._.-....-.-
BalTmOf for 4
Rate After
.- - - -
07/1c /19)
- --...- .......------ - +- e .
0.00% $9.20433 (O $0.00 . G
Ba Tra er Ra e
.. acy 16/19) -..--- .--.--.....-.....- --..... See Accousit Messages
ADVANCES
-.--.-.-.-.-.------.- ------ - -- for more information about
StandardAdv 19.24% (V) $0.00 (D) $0.00 Savings Spotlight
Rate (APRr is the annual laterest
Your Annual Percentage rate on your account. APRs foi owed
by (0) ate de*ermined
by (V) may vary. Balances followed by the cally balance method
transactionss
current
(including
Account messages
important changes are coming to some of your Card Benefits.
The following is a summary of changes that arebeing made toyour card
benefits. Ef fective
September 2 2019, Worldwide Car Rental Insurance, frip
Cancellation & litterruptionProte lon, Worldwide Travel Accident insurance,
Citi'Price Rewind, and 90 Return Protection willbe discontinued and will
Day
no longer be provided forpurchases made on or after thatdate. Coverage for
purchases made before that date willcontinue tobe available,and you may
continue tofilefor benefitsin accordance with the current benefit terms.We
are making these changes so thatwe can continue providing thekey benefits
that our customers use and value most at no additionalcost. Thischange
requires no action an our part. If youhave any questions,please callthe
number on the back o your card.
As a cardmember, you willcontinue toreceive a range of other card benefits
FICO® Credit Citi® Theft and Citi
including Score, identity Solutions,
Entertainment. For more information on card benefits, visit .
cardbenefits.citi.com.
7 of 13
FILED: NASSAU COUNTY CLERK 11/20/2020 11:43 AM INDEX NO. 606231/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/20/2020
www.citleards.com Customer Servico+866-696-5673 Page 3 of 3
TTY-hearirgimpaired servicesonlyF800-325-2863
PATRICIA WILLIAMS
SAVINGS SPOTLIGHT DETAILS
INTEREST: ifyou have promotional balances on your account, we have
estimated your savings.This savings is thedifference betwasa theinterest
that was assessed a ast the promotional balances using the promotional
APRs and the esti ed interestthat would have been assessed against these
same b±ncas usingthe Enhanced Purchase APRs. This savings amount does
not include any balance transferfees. Thissavings is from your billingperiod
covered by thisstatement.
NO LATE FEE: Savings on late feeis determined by raviswing your payments
and calculating what your latefee would have been on our card without this
benefit If ou paid latepriorto May 2014,savings on lae fee is determined by
using a $1 latefee (ifyour minimum payment due was lessthan $15, weused
that amount as the savings amount). This sawmgs is from your billingperiod
covered by thisstatement.
CITI EASY DEALS: If youmade a purchase on CitiEasy Deals,your savings is
the dif ferencebetween the retailprice and the priceyou paid.This savings is
from the priorcalendar month.
CITIPRICE REWIND: Ifyou received a CitiPriceRewind refund, savings isthe
refunded amount. This savingsis from the priorcalendar month.
CITI 5IMPLICITY LIFETIME SAVINGS: The savings from interest.no latefee,
CitiEasy Deals and CitiPriceRewind since you became a CitiSimplici
cardmemb£r. This savings amount does not include any balance trans erfees.
Please note thatifwe received your pay by phone or online payment between
5 p.m. ET and midni ht ET on the lastday of your billingperiod,your payment
willnot be reflect untilyour next statement.
Please be sure topay on time. If yousubmit your payment by mail,we suggest
you mailitno laterthan 08/02/ 2019 to allow enough time for regularmail to
reach us.
©2018 Citibank, N.A.
Citi,Citiwith Arc Design are registered servicemarks of Citigroup Inc.
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FILED: NASSAU COUNTY CLERK 11/20/2020 11:43 AM INDEX NO. 606231/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/20/2020
PATRICIA WILt.1AMS
www.citicards.com
Member State 2C7 Accst su+ber end ng n: 417 customer service 1•a66496-5673
Period:05/14/19-06/13/19
Bil·:ng TY mpa!red services 1-800 326 2865
hearing only
BOX 6530 SIOUX FALLS, SD 5707
Your account Ispast due. Please pay at
JUNE STATEMENT
least the minimum payment due, which
Minimum payment due: $1,127.00
includes a past due amount of $965.00.
New balance as of 06/13/19: $10,822.72
Payment due dete: 07/09/19 Account Summary
a st g e t I .forin portant tormator abe -t how to
atdn$Z Previous balance $10,822.72
Payments -50.00
Credits -50,00
Purchases +$0.00
MinimumPayment f youmake the minrrnum payment each Cash advances +$0.00
Warning onïy
period,you wN pay more and it w i
in interest take ycu knqwr tr pay ofIycu Fees +$0.00
balance.For example: Interest +50.00
If youmake no addit!en:! | You w111pay off
the
1
And you w18 end up New balance $10,822.72
charges usingitdscard balanceshown on this an estimated
and each month you pay- statement In about- f.
Credit Limit
only the minimum payment 26 yearN . 525.391 Credit limit $11,200
Includes$3300 Pash advan e mit
For Information counseen
about tredit servl:cs.cah1-877·337-8188New
YGrk
re dents ma contad IceNew York State Bank.Department to ablain
a emperative
is ing of cre
it c.Trdrates, feesand
gra;epe:LA y ca ngt877•226.5697.
Savings
Spotlight
Your Citi Simplicity Lifetime Savings:
$3,6 20.29
See page 3 to view your
Savings Summary.
Pay your bill
from anywhere
virtually Minimum payment due $1,127.00
with theCitiMobli# App and CitPOnilne
ΰft°""ApŸUPtoNyetH
(692484) Payment due date 07/09/19
w got-yourdevice's appstore,
Cevisit www.citicards4em
Amount enclosed:
MC 32 A O Account number ending in 4170
000000
PATRICIA WILLIAMS CITI CARDS
783 TAFT $7 PO Box 70166
NORTH BELLMORE NY 11710-1219 Phliadelphia
PA 19176 0166
15009 0112700 1082272 0020000 8670 090 3
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FILED: NASSAU COUNTY CLERK 11/20/2020 11:43 AM INDEX NO. 606231/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/20/2020
www.elticards.com Customer Service t•a66-696-5673 Page 2 of 3
TTY hearing impa;red servicesoxy 1 800 325 2865
PATRICIA WILLIAMS
Account Sumrnary
Trans. Post
date date Description ' Amount
-...-..............--.-
...-..-.........- ...,. ... .
-.......... . .. .. .. ....-
..... .
..
Fees charged Savings Spotlight
In this so.oo Your Simplicity*
Totat feescharged period
billing Citi
Savings Summary
Interest charged From This Period:
aginag
Totalinterest charged in this period
billing $O.00 O interest: $176.84
No Late Fee: $35.00
2019 totals year-to-date
Totat fees charged in 2019 $0.00
...
.....-.-...-...-.......-..............-.-.---....-. ......
..... ...- ..
. . ...... .
Total laterestcharged in 2019 $0.00
Iraterest charge calculation cays in bi
ing cyc e:at
2°" A5"°*'?"f''aR.3**!.tApus an antagfate on yow moon
Balance TOTAL
Annual percenta e subject
Balance type rate (AP ) toInterestrate interestcharge SAVINGS
. UA5ES
Standard Purch 0.00% $1.618.39 (D 50,00
Rate Expires 07/10/19
(Introductory
.ate pl es O 6 9
i,. .
ADVANCES
$3,620.29
Rate (APR) is the annual interest
Your Annual Percentage rate on your account. APRs followed
by (0) are determined
by (V) reay vary. Balances followed by the daily ha an e method
See Account Messages
Oncluding current
transactions).
for more information about
Account inessages Savings Spotitcht
SAVINGS SPOTLIGHT DETAILS
INTEREST: If you have promotional balances on your account, we have
estimated your savings. Thissavings isthe dif ferencebetween the interest
that was assessed against the promotional balances using the promotional
APRs and theestimated interest thatwould have been assessed against these
same balances using the Enhanced Purchase APRs. This savings amount does
not include any balance transfer fees.This savings isfrom your period
billing
covered by thisstatement.
NO LATE FEE: Savings on late fee is determined by reviewing your ayments
and calculating what your latefee would have been on our card w thout this
benefit.If ou paid latepriorto May 2014, savings on lae fee is determined by
using a $1 latefee (ifyour minimum payment due was lessthan $15,we used
that amount as the savings amount). Thissavings is from your billingperiod
covered by thisstatement.
CITI EASY DEALS: 11you made a purchase on CitiEasy Deals, your savings is
the dif ferencebetween the retailprice and the priceyou paid.This savings is
from theprior calendar month.
CITI PRICE REWIND: If youreceived a CitiPrice Rewind refund,savings
' isthe
refunded amount This savings is f rom
the prior calendar month.
CITI SIMPLICITY LIFETIME SAVINGS: The savings from interest,no latefee,
CitiEasy Deats and CitiPrice Rewind sinceyou became a CitiSimplic
cardmember. This savings amount does not includeany balance trans fees.
Please note thatifwe received your pay by phone or online payment between
5 p.rn.ET and midnight ET on the lastday of your billingperiod,your payment
willnot be reflected untilyour next statement.
10 of 13
FILED: NASSAU COUNTY CLERK 11/20/2020 11:43 AM INDEX NO. 606231/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/20/2020
www.citicards.com Customer Service 1-066-896-5673 Page3cl3
TTY-hearing•!rrpairedservicesonly1-800-325-2865
PATRICIA W4LLIAMS
Please be sure to pa on time. if yousubmit your payment by mail,we suggest
you maid itno later t an 07/02/2019 to allow enough time forregular mail to
reach us.
42018 Citibank, N.A.
Citi,Citiwith Arc Design are registered service marks of Citigroup inc.
11 of 13
FILED: NASSAU COUNTY CLERK 11/20/2020 11:43 AM INDEX NO. 606231/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/20/2020
4170
SA1.E5EGMENT
PRODUGT IDENT1FRER CODE
. PROpUCT_DijSCRiMON_
5ALE ID OB1319 CV1M U3 FM
SALE AMOUNT $ 10, 82 2. 72
PRINGlPAL
PRE CHARGAPOFF INTEREST
PilEGHARGE OFF EEES
POST CHARGE Of!F INTERiiST
QtARGE OFF BA14N $10,823.5) I
BAEAN
ccounr OPEN DATE
DEF4ULT DATE
GHARGE OFF DATE 11-M-15 {
RAST PAYMENT AMOUNT $200,00 â€
tAST PAVMi!NT DATE 19-Nov-10
1AST PURCHA55•AMOUNT
1AST PURCHASiE D_&TE 07-Jan-1
LAST BAp‡is TRANSFER &MOUNT
LAST 1BALANGTRANS R DATE
(AST CASH ADVA8lGE SMOUNT
LAST CASH ADVANGBDATE
TOTAL PAYMENTS POST CHARGE QFF
TOTAL NSF POST CHARGE OFF
10T4 CREDITS POST CHAREE OFF
CONSUMER FIRST AND MtDDLENAME PATR10/
CONSUMER 145T NA E W1LR
CONSUMER BliSIDENG ADDRESS 1
CONSU.MER RESIDENCE ADDR1!SS 2
CONSUMER RESIDENG Off
CONSUAGER STATE
capsuivtER mP cong
CONSUMiiR RESID
CONSUMi!R RESIDENCE PHONE
BAD NÇMBER INDiCATOR
CopsuMERssNonsp
CONSUAGER 8IRTH DATE
AWARENES5 1NDICATOR
ATTORNEY NAME
ATTORNEY PHONE
ATTORNEY ADDRESS
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FILED: NASSAU COUNTY CLERK 11/20/2020 11:43 AM INDEX NO. 606231/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 11/20/2020
ATroRNEY GTY
ATTORNEY STATE
ATTORNEY ZIP CODE
88NKRUPTGY OfAPTER
BANKRUFrGY FRR DATE
BKPROOF OF QAIM PRINGPAL
BK PROOF OF GAIM INTERI5T
85 PROOF OF QAGM FEE
aggiKRUPrGY GASE.NUMBER
samgUPTGT TRUSTI!E
co-BOR80MR:FIRST AND MIDD E
ca.moRnoweRLAsrNAwn
N OR SIN
!LTEACCO NT
NUyBER1
PRIOR ACCOUNT NUMBER1
PRIOR ACCOUIWF NUMBER B
PRI.0R ACCOURT'NUligBER 4
PRIOR ACCOUBJIPNU 5
UINDING_UMIL1
LENDING isvEL 2
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