Preview
System Generated Hearing Date: 12/9/2024 11:00 AM
Location: Court Room 1101
Judge: Allegretti, J ohn Michael
FILED
1/8/2024 10:02 AM
IRIS Y. MARTINEZ
CIRCUIT CLERK
COOK COUNTY, IL
20241100561
Courtroom, 1101
25867367
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
20241100561
Cavalry SPV I, LLC
Plaintiff,
VS. Return Date:
Rosa Gonzalez
Defendant(s). Amount Claimed: $4,733.55
Plus Court Costs
COMPLAINT
Plaintiff, Cavalry SPV I, LLC, by its attorneys, Blitt and Gaines PC, as and for its complaint
herein against Defendant(s), hereby alleges as follows:
1 The Defendant(s) utilized a charge account and/or line of credit issued by Citibank, N.A.
or its predecessor in interest, which was opened on April 16, 2019.
The last four digits of the account number at time of charge off was ******#*****3464,
Periodic statements were sent to Defendant(s) by regular mail or electronically which set
forth in detail, all debits and credits, the total balance due, the interest rate and the minimum
payment.
Defendant(s) eventually failed to make the minimum payment(s).
Attached hereto and incorporated herein is a copy of either the charge-off statement or last
periodic statement provided to Defendant prior to charge-off.
Defendant(s) did not object to the statement, indicate that the statement contains an error,
nor indicate that it was erroneous in any respect within a reasonable period of time.
Plaintiff was assigned all rights and title to the account. Plaintiff is currently the bona fide
owner thereof.
After receiving all payments, debits, credits and set offs, there is now due and owing from
Defendant(s) to Plaintiff the sum of $4,733.55.
By reason of the foregoing, Plaintiff is entitled to judgment against Defendant(s) for
Account Stated in the sum of $4,733.55, plus court costs.
10. Despite due demand, Defendant(s) have failed and/or refused to pay the amount due and
owing as indicated on the final statement.
11 This suit has been filed within the relevant statute of limitations.
WHEREFORE, the Plaintiff, requests judgment against Defendant(s) for Account Stated
in the sum of $4,733.55, plus court costs; and for such other and further reliefas this Court deems
just and proper.
Blitt and Gaines, P.C. /s/ Eric L. Meyer ARDC# 6299506
Attorney at Law
775 Corporate Woods Parkway
Vernon Hills, IL 60061
(866) 729-4276 TTY: 711
pleadings2@blittandgaines.com
23097959
32887
This is an attempt to collect a debt by a debt collector and any information obtained will be used
for that purpose.
Cavalry SPV I, LLC
Plaintiff,
v
ROSA GONZALEZ
Defendant
CREDIT CARD OR DEBT BUYER COLLECTION ACTION AFFIDAVIT
(SUPREME COURT RULE 280.2)
Comes now affiant, and states:
1, Eileen Fitzgerald, am a designated representative of Cavalry SPV I, LLC (“Plaintiff”). Iam an employee of
Cavalry Portfolio Services, LLC (“CPS”). CPS performs collection services for Plaintiff.
Iam of adult age and am fully authorized by Plaintiff to make the following representations. J am familiar
with the record keeping practices of CPS and Plaintiff. The following representations are true according
to documents kept in the normal course of CPS’ and Plaintiff's business:
1 IDENTIFICATION ABOUT THE CONSUMER DEBT ORACCOUNT
Complete the tables.
a._As of charge-off date:
Last four Nature of the debt,
Date the
digits of (credit card debt,
Full name of the Defendant(s) account was
Full name of the creditor the payday loan, retail
as it appears on the account opened or the
account installment loan,
debt originated
number etc.)
Citibank, N.A. ROSA GONZALEZ 3464 04/16/2019 REVOLVING
b. The most recent activity on the account prior to or after charge-off, includes:
Charge-off Date of Last
Charge-off Amount of Payments/Credits/ Adjustments
Balance as defined Payment (on or
Date Last Payment Since Charge-off Date**
by ISCR 280.1(c) about)*
$4,733.55 06/22/2023 11/21/2022 $102.57 $.00
*Last Payment on the account, pre- or post-charge-off
**Credits, payments or adjustments made within 30 days of the signing of this affidavit may not be
reflected
c. Fora revolving credit account, Plaintiff further certifies that it has in its possession and can produce
on request the most recent monthly statement recording a purchase, transaction, last payment, or
balance transfer
2. PROOF OF OWNERSHIP OR RIGHT TO SUE FOR DEBT BUYERS
Complete the table and list the prior owners or creditors since the charge-off date. Start with the
first assignment through the current creditor or owner of the consumer debt. List in chronological
order, beginning with the first assignment:
From (Name) To (Name) Date of Assignment (on or about)
Citibank, N.A. Cavalry SPV I, LLC 08/18/2023
O Does not apply — Plaintiff is the charge-off creditor.
ADDITIONAL ACCOUNT INFORMATION AFTER CHARGE-OFF
Plaintiff is seeking additional amounts after the charge-off date:
M No*
O Yes.
C1 Total amount of interest accrued: $ >
O Total amount of non-interest charges or fee accrued $ 3
O Plaintiff is seeking attorney’s fees in the amount of $
O Returned payment(s) in the amount of $ 3
Balance due and owing as of 11/02/2023: $4,733.55
*Costs prayed for in the Complaint will not be reflected.
Legitvcmimistigor
go~ iw.
NOTARY mane OF CONNECTICUT
Karol Canela
Notary Public, State of Connecticut
My Commission Expires 11/30/2026
Costco Anywhere Visé Card by Citi citi | CosTco
ROSA GONZALEZ www.citicards.com
Member Since 2019 Account number ending in: 3464 Customer Service 1-855-378-6467
Billing Period: 05/23/23-06/22/23 TTY:711
PO Box 790046 ST. LOUIS, MO 63179-0046
JUNE STATEMENT Account Summary
Minimum payment due: $4,733.55 Previous balance $4,652.90
New balance as of 06/22/23: $4,733.55
Payments -$0.00
Credits -$0.00
Payment due date: 06/22/23 Purchases +$0.00
See the last pa
avoid paying int f ferest
je of this
on
statement for important information about how to
purchases. Cash advances +$0.00
Fees +$0.00
Interest +$80.65
Late Payment Warning: If we do not receive your minimum payment by the date
New balance $4,733.55
listed above, you may have to pay a late fee of up to $41 and your APRs may be
increased up to the Penalty APR of 29.99%. Credit Limit
Minimum payment warning:If you make only the minimum payment each Credit Limit $4,000
period, you will pay more in interest, and it will take you longer to pay off Includes $1,200.00 cash advance limit
your balance. For example:
If you make no additional
charges using this card
and each month you pay... about.
ill pay
‘on the ff‘statement
the balance
in
And you will end up
paying an estimated total
Only the minimum payment 1 months $4,734
For information about credit counseling services, call 1-877-337-8188.
For Payments, send check to: Citi Cards, PO BOX 78019, Phoenix, AZ, 85062-8019
Pay your I from virtually anywhere Minimum payment due $4,733.55
with the Citi Mobile® App and Citi® Online
New balance $4,733.55
To download:
Text ‘App15' to MyCiti (692484) Payment due date 06/22/23
Oo go to your device's app store.
Or visit www.citicards.com
Amount enclosed:
000000
NC 32 A0 Account number ending in 3464
Please make check payable to Citi Cards.
ROSA GONZALEZ Citi Cards
8214 S SCOTTSDALE AVE PO BOX 78019
CHICAGO IL 60652-3016 Phoenix, AZ 85062-8019
45109 0473355 0473355 0010¢00 a 1600
www.citicards.com Customer Service 1-855-378-6467 Page 2 of 2
TTY:711
ROSA GONZALEZ
CARDHOLDER SUMMARY
ROSA GONZALEZ Card ending in 3464
New Charges $0.00
ACCOUNT SUMMARY
Sale Post
Date Date Description Amount
ROSA GONZALEZ
No Activity
Fees Charged
TOTAL FEES FOR THIS PERIOD $0.00
Interest Charged
06/: 22 INTEREST CHARGED TO STANDARD PURCH $3.67
TOTAL INTEREST FOR THIS PERIOD .65,
2023 totals year-to-date
Total fees charged in 2023 $205.00
Total interest charged in 2023 $437.25
Interest charge calculation Days in billing cycle: 31
Your Annual Percentage Rate (APR)is the annual interest rate on your account.
Balance type
Annual percentat
rate (API ft je) Balance subject
to interest rate Interest charge
Standard Purch 20.24% (V) $213.61 (D) $3.67
Pur Pr 011223 20.24% (V) $4,478.20 (D) $76.98
Standard Adv 29.99% (V) $0.00 (D) $0.00
Your Annual Percentage Rate (APR) is the annual interest rate on your account. APRs followed
by (V) may vary. Balances followed by (D) are determined by the daily balance method
(including current transactions).
Account messages
Please note that if we received your pay by phone or online payment between
5 p.m. ET and midnight ET on the last day of your billing period, your payment
was credited as of the date of receipt, but will not be reflected until your next
statement.
©2023 Citibank, N.A.
Citi, and Citi with Arc Design are registered service marks of Citigroup Inc.
Visa® is a registered trademark of Visa International Service Association and
used under license.
Preview
System Generated Hearing Date: 12/9/2024 11:00 AM Location: Court Room 1101 Judge: Allegretti, J ohn Michael FILED 1/8/2024 10:02 AM IRIS Y. MARTINEZ CIRCUIT CLERK COOK COUNTY, IL 20241100561 Courtroom, 1101 25867367 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS 20241100561 Cavalry SPV I, LLC Plaintiff, VS. Return Date: Rosa Gonzalez Defendant(s). Amount Claimed: $4,733.55 Plus Court Costs COMPLAINT Plaintiff, Cavalry SPV I, LLC, by its attorneys, Blitt and Gaines PC, as and for its complaint herein against Defendant(s), hereby alleges as follows: 1 The Defendant(s) utilized a charge account and/or line of credit issued by Citibank, N.A. or its predecessor in interest, which was opened on April 16, 2019. The last four digits of the account number at time of charge off was ******#*****3464, Periodic statements were sent to Defendant(s) by regular mail or electronically which set forth in detail, all debits and credits, the total balance due, the interest rate and the minimum payment. Defendant(s) eventually failed to make the minimum payment(s). Attached hereto and incorporated herein is a copy of either the charge-off statement or last periodic statement provided to Defendant prior to charge-off. Defendant(s) did not object to the statement, indicate that the statement contains an error, nor indicate that it was erroneous in any respect within a reasonable period of time. Plaintiff was assigned all rights and title to the account. Plaintiff is currently the bona fide owner thereof. After receiving all payments, debits, credits and set offs, there is now due and owing from Defendant(s) to Plaintiff the sum of $4,733.55. By reason of the foregoing, Plaintiff is entitled to judgment against Defendant(s) for Account Stated in the sum of $4,733.55, plus court costs. 10. Despite due demand, Defendant(s) have failed and/or refused to pay the amount due and owing as indicated on the final statement. 11 This suit has been filed within the relevant statute of limitations. WHEREFORE, the Plaintiff, requests judgment against Defendant(s) for Account Stated in the sum of $4,733.55, plus court costs; and for such other and further reliefas this Court deems just and proper. Blitt and Gaines, P.C. /s/ Eric L. Meyer ARDC# 6299506 Attorney at Law 775 Corporate Woods Parkway Vernon Hills, IL 60061 (866) 729-4276 TTY: 711 pleadings2@blittandgaines.com 23097959 32887 This is an attempt to collect a debt by a debt collector and any information obtained will be used for that purpose. Cavalry SPV I, LLC Plaintiff, v ROSA GONZALEZ Defendant CREDIT CARD OR DEBT BUYER COLLECTION ACTION AFFIDAVIT (SUPREME COURT RULE 280.2) Comes now affiant, and states: 1, Eileen Fitzgerald, am a designated representative of Cavalry SPV I, LLC (“Plaintiff”). Iam an employee of Cavalry Portfolio Services, LLC (“CPS”). CPS performs collection services for Plaintiff. Iam of adult age and am fully authorized by Plaintiff to make the following representations. J am familiar with the record keeping practices of CPS and Plaintiff. The following representations are true according to documents kept in the normal course of CPS’ and Plaintiff's business: 1 IDENTIFICATION ABOUT THE CONSUMER DEBT ORACCOUNT Complete the tables. a._As of charge-off date: Last four Nature of the debt, Date the digits of (credit card debt, Full name of the Defendant(s) account was Full name of the creditor the payday loan, retail as it appears on the account opened or the account installment loan, debt originated number etc.) Citibank, N.A. ROSA GONZALEZ 3464 04/16/2019 REVOLVING b. The most recent activity on the account prior to or after charge-off, includes: Charge-off Date of Last Charge-off Amount of Payments/Credits/ Adjustments Balance as defined Payment (on or Date Last Payment Since Charge-off Date** by ISCR 280.1(c) about)* $4,733.55 06/22/2023 11/21/2022 $102.57 $.00 *Last Payment on the account, pre- or post-charge-off **Credits, payments or adjustments made within 30 days of the signing of this affidavit may not be reflected c. Fora revolving credit account, Plaintiff further certifies that it has in its possession and can produce on request the most recent monthly statement recording a purchase, transaction, last payment, or balance transfer 2. PROOF OF OWNERSHIP OR RIGHT TO SUE FOR DEBT BUYERS Complete the table and list the prior owners or creditors since the charge-off date. Start with the first assignment through the current creditor or owner of the consumer debt. List in chronological order, beginning with the first assignment: From (Name) To (Name) Date of Assignment (on or about) Citibank, N.A. Cavalry SPV I, LLC 08/18/2023 O Does not apply — Plaintiff is the charge-off creditor. ADDITIONAL ACCOUNT INFORMATION AFTER CHARGE-OFF Plaintiff is seeking additional amounts after the charge-off date: M No* O Yes. C1 Total amount of interest accrued: $ > O Total amount of non-interest charges or fee accrued $ 3 O Plaintiff is seeking attorney’s fees in the amount of $ O Returned payment(s) in the amount of $ 3 Balance due and owing as of 11/02/2023: $4,733.55 *Costs prayed for in the Complaint will not be reflected. Legitvcmimistigor go~ iw. NOTARY mane OF CONNECTICUT Karol Canela Notary Public, State of Connecticut My Commission Expires 11/30/2026 Costco Anywhere Visé Card by Citi citi | CosTco ROSA GONZALEZ www.citicards.com Member Since 2019 Account number ending in: 3464 Customer Service 1-855-378-6467 Billing Period: 05/23/23-06/22/23 TTY:711 PO Box 790046 ST. LOUIS, MO 63179-0046 JUNE STATEMENT Account Summary Minimum payment due: $4,733.55 Previous balance $4,652.90 New balance as of 06/22/23: $4,733.55 Payments -$0.00 Credits -$0.00 Payment due date: 06/22/23 Purchases +$0.00 See the last pa avoid paying int f ferest je of this on statement for important information about how to purchases. Cash advances +$0.00 Fees +$0.00 Interest +$80.65 Late Payment Warning: If we do not receive your minimum payment by the date New balance $4,733.55 listed above, you may have to pay a late fee of up to $41 and your APRs may be increased up to the Penalty APR of 29.99%. Credit Limit Minimum payment warning:If you make only the minimum payment each Credit Limit $4,000 period, you will pay more in interest, and it will take you longer to pay off Includes $1,200.00 cash advance limit your balance. For example: If you make no additional charges using this card and each month you pay... about. ill pay ‘on the ff‘statement the balance in And you will end up paying an estimated total Only the minimum payment 1 months $4,734 For information about credit counseling services, call 1-877-337-8188. For Payments, send check to: Citi Cards, PO BOX 78019, Phoenix, AZ, 85062-8019 Pay your I from virtually anywhere Minimum payment due $4,733.55 with the Citi Mobile® App and Citi® Online New balance $4,733.55 To download: Text ‘App15' to MyCiti (692484) Payment due date 06/22/23 Oo go to your device's app store. Or visit www.citicards.com Amount enclosed: 000000 NC 32 A0 Account number ending in 3464 Please make check payable to Citi Cards. ROSA GONZALEZ Citi Cards 8214 S SCOTTSDALE AVE PO BOX 78019 CHICAGO IL 60652-3016 Phoenix, AZ 85062-8019 45109 0473355 0473355 0010¢00 a 1600 www.citicards.com Customer Service 1-855-378-6467 Page 2 of 2 TTY:711 ROSA GONZALEZ CARDHOLDER SUMMARY ROSA GONZALEZ Card ending in 3464 New Charges $0.00 ACCOUNT SUMMARY Sale Post Date Date Description Amount ROSA GONZALEZ No Activity Fees Charged TOTAL FEES FOR THIS PERIOD $0.00 Interest Charged 06/: 22 INTEREST CHARGED TO STANDARD PURCH $3.67 TOTAL INTEREST FOR THIS PERIOD .65, 2023 totals year-to-date Total fees charged in 2023 $205.00 Total interest charged in 2023 $437.25 Interest charge calculation Days in billing cycle: 31 Your Annual Percentage Rate (APR)is the annual interest rate on your account. Balance type Annual percentat rate (API ft je) Balance subject to interest rate Interest charge Standard Purch 20.24% (V) $213.61 (D) $3.67 Pur Pr 011223 20.24% (V) $4,478.20 (D) $76.98 Standard Adv 29.99% (V) $0.00 (D) $0.00 Your Annual Percentage Rate (APR) is the annual interest rate on your account. APRs followed by (V) may vary. Balances followed by (D) are determined by the daily balance method (including current transactions). Account messages Please note that if we received your pay by phone or online payment between 5 p.m. ET and midnight ET on the last day of your billing period, your payment was credited as of the date of receipt, but will not be reflected until your next statement. ©2023 Citibank, N.A. Citi, and Citi with Arc Design are registered service marks of Citigroup Inc. Visa® is a registered trademark of Visa International Service Association and used under license.