Preview
Electronically Filed
3/25/2024 8:54 AM
Superior Court of California
Vanessa Thomas, State Bar #323167 County of Stanislaus
RAUSCH STURM LLP Clerk of the Court
250 N. Sunnyslope Road, Suite 300 By: Dora Perez, Deputy
Brookfield WI 53005
Telephone: (877) 215-2552
Facsimile: (877) 396-4464 $370 PAID
E-mail Address: LawfirmCA @rauschsturm.com
Attorneys for Plaintiff
California License No. 10685-99
SUPERIOR COURT OF THE § ‘ATE OF CALIFORNIA
COUNTY OF STANISLAUS, MODESTO DOWNTOWN COURTHOUSE
CV-24-002268
GALAXY INTERNATIONAL PURCHASING, LLC, Case No.:
Plaintiff, COMPLAINT FOR:
10 1. BREACH OF CONTRACT
vs. (Rule 3.740 Collections)
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KAITLYN STETLER;
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and DOES | through 10, inclusive, PRAYER AMOUNT: $21,712.27
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Defendants. LIMITED CIVIL CASE
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Plaintiff GALAXY INTERNATIONAL PURCHASING, LLC (“Plaintiff”) alleges the following facts as to all
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causes of action as follows:
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18 1 Plaintiff is qualified to do business in California.
19 2. This Court is proper for this action because Plaintiff is informed and believes that Defendant KAITLYN
20 STETLER is a resident within the jurisdictional boundaries of this Court.
21 3. Plaintiffis informed and believes that Defendant KAITLYN STETLER and Defendants sued by the fictitious
22 names DOES | through 10 (“Defendants”) are responsible for the alleged debt; however, Plaintiffis unaware of the
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true names and capacities of DOES | through 10 and will seek leave of this Court to amend this Complaint when the
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true names and capacities have been ascertained.
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4. Plaintiff believes that at all times mentioned herein, Defendants, and each of them, were the agent, servant,
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employee, or employer, and acted in the capacity and as agent, of each and of the other Defendants. Plaintiff also
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believes that each of the Defendants is jointly and severally liable in the actions were taken for the benefit of the
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Mayne,
J ohn R
This e356 nap pean sesinst to Juage
1 Deparment forll purposes including Tri.
COMPLAINT 4838085"
Defendants’ separate and/or community property. Plaintiff also believes that each of the Defendants is jointly and
severally liable in that the actions were taken for the benefit of the Defendants’ separate and/or community property.
5. Pursuant to California Civil Code, section 1788.58, subsection (a)(1), Plaintiffis a debt buyer as defined by
California Civil Code, section 1788.50, subsection (a).
6. Pursuant to California Civil Code, section 1788.58, subsection (a)(2), Plaintiff is seeking to recover the
amount of $21,712.27 from Defendants. This is the past-due balance on a loan or borrower agreement, which was
obtained and used by Defendants in exchange for value received from the original creditor, LendingClub Bank,
National Association, with the original account number ending in *****8244 (the "Account"). The amount due is
the result of loan proceeds and/or goods accepted by Defendants that have not been repaid as agreed and, upon
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information and belief, were for personal, family, or household purposes.
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12 7. Pursuant to California Civil Code, section 1788.58, subsection (a)(3), Plaintiff is the sole owner of the
13 obligation sued upon. Attached hereto and incorporated herein by reference as Exhibit 1 is a true and correct copy
14 of the Bill of Sale(s). The account was purchased by the Plaintiff on or around November 30, 2022.
15 8. Pursuant to California Civil Code, section 1788.58, subsection (a)(4), the Account balance at the time of
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charge-off was $21,712.27.
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9. Pursuant to California Civil Code, section 1788.58, subsection (a)(5), Plaintiff alleges that the date of the
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last payment was May 3, 2022. Attached hereto and incorporated herein by reference as Exhibit 2 is a true and
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correct copy of a transaction history for Defendants' Account.
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10. Pursuant to California Civil Code, section 1788.58, subsection (a)(6), Plaintiff alleges that the name of
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22 the creditor at the time of charge-off was Wilmington Savings Fund Society FSB D/B/A Christiana Trust Ttee of
23 Alternative Lending Holdings Trust PLEP (serviced by Lending Club). On information and belief, Plaintiff further
24 alleges that an address used by Wilmington Savings Fund Society FSB D/B/A Christiana Trust Ttee of Alternative
25 Lending Holdings Trust PLEP (serviced by Lending Club) at the time of charge-off was 71 STEVENSON STREET
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SUITE 300, SAN FRANCISCO CA 94105. At the time of charge-off, the redacted account number associated with
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this debt was *****8244.
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2
COMPLAINT 4838085
11. Pursuant to California Civil Code, section 1788.58, subsection (a)(7), Plaintiff alleges that the name of
the debtor(s) as it appears in the records of Wilmington Savings Fund Society FSB D/B/A Christiana Trust Ttee of
Alternative Lending Holdings Trust PLEP (serviced by Lending Club) is KAITLYN STETLER and the last known
address as it appeared in the records of Wilmington Savings Fund Society FSB D/B/A Christiana Trust Ttee of
Alternative Lending Holdings Trust PLEP (serviced by Lending Club) is 424 WADDELL WAY, MODESTO,CA
95357.
12. Pursuant to California Civil Code, section 1788.58, subsection (a)(8), Plaintiffis informed and believes
that the name and address of all post charge-off purchasers of the Account are as follows:
a. Galaxy International Purchasing, LLC, 4730 South Ft Apache Rd STE 300, Las Vegas, NV 89147.
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13. Pursuant to California Civil Code, section 1788.58, subsection (a)(9), Plaintiff alleges that it has complied
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12 with the provisions of Civil Code, section 1788.52.
13 14. Pursuant to California Civil Code, section 1788.58(b), attached hereto and incorporated herein by
14 reference as Exhibit 3 is a true and correct copy of the contract or agreement or a copy of a statement recording a
15 purchase transaction, last payment, or balance transfer as required by California Civil Code, section 1788.52,
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subsection (b).
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15. Before filing this suit, all rights, title and interest to the Account were sold and assigned to Plaintiff.
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Plaintiff owns the Account and is entitled to collect on the Account as if it were the original creditor. To the extent
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that Plaintiff acts in its capacity as successor-in-interest to the original creditor or its assigns, references herein to
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Plaintiff may include Plaintiff's predecessor-in-interest.
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22 16. Before commencement of this action, Plaintiff informed Defendant in writing that it intended to file this
23 action and that this action could result in a judgment against Defendant that would include court costs allowed by
24 California Code of Civil Procedure, section 1033, subsection (b)(2).
25 FIRST CAUSE OF ACTION - (Breach of Contract)
26 17. Plaintiff realleges and incorporates by reference all of the foregoing paragraphs.
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3
COMPLAINT 4838085
18. Defendants explicitly or impliedly entered into a contract with the original creditor where it was agreed
that by Defendants' receipt of loan proceeds and/or goods, Defendants would be indebted based on the terms of the
loan or borrower agreement.
19. Defendants' acceptance of the loan proceeds and/or goods constituted Defendants' acceptance of the terms.
of the loan or borrower agreement, and by these terms, Defendants agreed to repay the balance due and to pay interest
on the unpaid balance, late charges, and other fees associated with the account.
20. All duties, obligations, and conditions owed to Defendants have been duly performed by Plaintiff or by
Plaintiff's assignor(s).
21. Within the statutory period, Defendants breached the loan by failing to repay the amounts due.
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11 22. Defendants, and each of them, have failed and have refused to pay Plaintiff the sum now due and owing,
12 despite Plaintiff's demand for payment, and thus, are in breach of the agreement.
13 23. As the direct and proximate result of Defendants’ breach, Plaintiff has been damaged in the amount of
14 $21,712.27.
15 SECOND CAUSE OF ACTION - (Open Book Account)
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24. Plaintiff realleges and incorporates by reference all of the foregoing paragraphs.
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25. Defendants had financial transactions with Plaintiff’s predecessor when Defendants opened, used, and
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derived benefit from the Account through Defendants' own use of the loan proceeds and/or goods, or by another's
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use at Defendants’ direction. By using the loan proceeds, Defendants expressly agreed or impliedly promised to repay
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Plaintiff.
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22 26. Within the past four years, Defendants became indebted on the Plaintiff's predecessor in the sum of
23 $21,712.27 on the account.
24 27. Plaintiff’ s predecessor maintained in the regular course of its business an electronic record of the activity
25 on the account, reflecting the debits, credits, charges, fees, and unpaid amount due.
26 28. Plaintiff has made demand upon Defendants for repayment of the unpaid balance due on the account;
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however, Defendant has failed to satisfy the balance due.
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29. As of the date of this pleading, there is due and owing the unpaid sum of $21,712.27.
4
COMPLAINT 4838085
WHEREFORE, Plaintiff prays for judgment against Defendants as follows:
1 For the unpaid principal balance of $21,712.27;
2. For post-judgment interest at the statutory rate;
3 For costs of suit;
4 For such other relief as the Court may deem just and proper.
We
DATED: 03/13/2024 RAUSCH STURM LLP
Vanessa Thomas
Attorneys for Plaintiff
ATTORNEY CONTACT INFO:
Vanessa Thomas
10 Phone: (279) 333-8001
E-mail: VThomas@rauschsturm.com
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COMPLAINT 4838085
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25 EXHIBIT 1
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4838085
DocuSign Envelope >
BILL OF SALE
LendingClub Corporation, a Delaware corporation (“LendingClub”) and Galaxy International Purchasing,
LLC, a Nevada limited liability company (“Buyer”) executed an Account Purchase Agreement — Forward Flow
dated as of April 24, 2020 (“Agreement”). The terms of the Agreement will govern this Bill of Sale and any
capitalized but undefined terms herein will have the meanings given to such terms in the Agreement.
For value received and in further consideration of the mutual covenants and conditions set forth in the
Agreement, the Investors referenced in the data file named Lot22-1100_LendingClub_FinalData.xlsx hereby
transfer(s), sell(s), conveys(s), grant(s), and deliver(s) to Buyer, its successors and assigns, without recourse except
as set forth in the Agreement, to the extent of its ownership, the Accounts as set forth in the Account Schedule
attached hereto as Exhibit I delivered by Seller to Buyer on the Closing Date, and as further described in the
Agreement.
Pursuant to the Agreement, on November 30, 2022, the Closing Date, each Investor will sell (or cause to
be sold) a pool of Accounts held by such Investors and described in the Account Schedule attached to this Bill of
Sale.
LendingClub represents and warrants that each of the undersigned Investors (other than LendingClub,
where LendingClub is the Investor) has executed a limited power of attorney between such Investor and
LendingClub wherein a designated power is for LendingClub to act as attorney-in-fact for such Investor and to
execute this Bill of Sale on behalf of such Investor and take any action and execute any instruments or documents
that LendingClub may deem reasonably necessary or advisable in connection with the transfers contemplated
thereby.
Lot Number: 22-1100
Total Unpaid Balance:
Number of Accounts:
DATED: November 30, 2022
LC Legal Reviewed
SELLER: LC Trust I
By: LENDINGCLUB CORPORATION, as Administrator
by: (toma pa
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Corporation
Decutiredby
By: [trawl Pat.
Name (print): Brandon Pace
Title: Chief Administrative Officer
DocuSign Envelope >
SELLER: ADF-National Holdings LLC
By: LENDINGCLUB CORPORATION, as attorney-in-fact
wy (Brad fo
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Alliant Credit Union
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Docutlradby
By: br Pace,
Name (punt): Brandon Pace
Title: Chief Administrative Officer
SELLER: ALPHACENTRIC PRIME MERIDIAN INCOME
FUND
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Doeusigned by:
By: Pace
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Anchor Bank
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By: (Gomera
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Banco Popular de Puerto Rico
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Dorusianet by
By: Pace
Name (print): |Brandon Pace
Title: Chief Administrative Officer
SELLER: Banco Popular North America
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Dosusigned by
B ae Pace
Name (print): Brandon Pace
Title: Chief Administrative Officer
DocuSign Envelope >
SELLER: BankNewport
By: LENDINGCLUB CORPORATION, as attorney-in-fact
by: (tral pee
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: BTG Pactual Absolute Return Master Fund, L.P.
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Docutlradby
By: br Pace,
Name (punt): Brandon Pace
Title: Chief Administrative Officer
SELLER: California First National Bank
By: LENDINGCLUB CORPORATION, as attorney-in-fact
DecsSignd by
By: | Gvandou. Pac
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Callune Participations s.a.r.1.
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Docuslnadby
B tr Pace.
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Carter Bank & Trust
By: LENDINGCLUB CORPORATION, as attorney-in-fact
ay: (Sl
Deevsigea by
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Central Pacific Bank
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By: (tradi fa,
Name (print): Brandon Pace
Title: Chief Administrative Officer
DocuSign Envelope >
SELLER: CIGPF I Corp.
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Deeusignd by
By: we Pace
Name (pint): Brandon Pace
Title: Chief Administrative Officer
SELLER: CML Borrower Trust
By: LENDINGCLUB CORPORATION, as attorney-in-fact
DecsSignd by
By: a. Pace
Name (pint): Brandon Pace
Title: Chief Administrative Officer
SELLER: Commercial Bank of California
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Deeusignd by
By: (eBrandon Pace
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Congressional Bank
By: LENDINGCLUB CORPORATION, as attorney-in-fact
DecsSignd by
a. Pace
py: L¢
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Consumer Lending Receivables Grantor Trust
2019-A CLRT 2019-A
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Docutlradby
By: tre Pace,
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Consumer Loan Underlying Bond (Club)
Certificate Issuer Trust I
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Decutiredby
By: ( traucdnn. Pat.
Name (print): Brandon Pace
Title: Chief Administrative Officer
DocuSign Envelope >
SELLER: CONSUMER LOAN UNDERLYING BOND
(CLUB) CREDIT TRUST 2020-P1
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Deevsigea by
pay; [Brandan fe.
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: CONSUMER LOAN UNDERLYING BOND
(CLUB) GRANTOR TRUST 2017-NP2
By: LENDINGCLUB CORPORATION, as attorney-in-fact
ce
ned
By: a. Pace
Name mt y Brandon Pace
Title: Chief Administrative Officer
SELLER: Consumer Loan Underlying Bond (CLUB)
Grantor Trust 2017-P1
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Doeusigned by:
By: Pace
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: CONSUMER LOAN UNDERLYING BOND
(CLUB) GRANTOR TRUST 2017-P2
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Ci
siredoy
By: Pace,
Name mint); Brandon Pace
Title: Chief Administrative Officer
SELLER: CONSUMER LOAN UNDERLYING BOND
(CLUB) GRANTOR TRUST 2018-P1
By: LENDINGCLUB CORPORATION, as attorney-in-fact
by: (tran fu
Name (print): |Brandon Pace
Title: Chief Administrative Officer
SELLER: CONSUMER LOAN UNDERLYING BOND
(CLUB) GRANTOR TRUST 2018-P2
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By: (Brio pa.
Name (print): Brandon Pace
Title: Chief Administrative Officer
DocuSign Envelope >
SELLER: CONSUMER LOAN UNDERLYING BOND
(CLUB) GRANTOR TRUST 2018-P3
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By: (trade fo
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: CONSUMER LOAN UNDERLYING BOND
(CLUB) GRANTOR TRUST 2019-HP1
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By: (trod ho.
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Consumer Loan Underlying Bond (CLUB)
Grantor Trust 2019-P1
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Ce
Docuslnadby
By: Pace.
Name mint); Brandon Pace
Title: Chief Administrative Officer
SELLER: CONSUMER LOAN UNDERLYING BOND
(CLUB) GRANTOR TRUST 2019-P2
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Dosusigned by
py: [Erandan.fo.
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: CONSUMER UNDERLYING BOND
SECURITIZATION, SERIES 2018-1 GRANTOR TRUST
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Docuslredby
By: Pace
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: COPPER CANYON TRUST
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Deevsigea by
py, [Erandew Pu.
Name (print): "Brandon Pace
Title: Chief Administrative Officer
DocuSign Envelope >
SELLER: County Bank
By: LENDINGCLUB CORPORATION, as attorney-in-fact
re
Decutiredby
By: Pace,
Name mint): Brandon Pace
Title: Chief Administrative Officer
SELLER: Deerwood Bank
By: LENDINGCLUB CORPORATION, as attorney-in-fact
ae
Docuslgned by
By: Pace,
Name mt): Brandon Pace
Title: Chief Administrative Officer
SELLER: DL INVESTMENT SARL, ACTING ON
BEHALF COMPARTMENT MOONSTONE 2
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By: (tran fate
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: DL Investment Sarl, Compartment Moonstone 1
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By: (trad fa
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: DYNAMIC CREDIT LOAN INVESTMENT DAC
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By: (traclac pee
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Edge Focus High Yield Fund, LP
By: LENDINGCLUB CORPORATION, as attorney-in-fact
by. (Goma pa
Name (print): Brandon Pace
Title: Chief Administrative Officer
DocuSign Envelope >
SELLER: Fasanara Apex I
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By: (Brae fa
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: FRANKLIN INVESTORS SECURITIES TRUST
- FRANKLIN LOW DURATION TOTAL RETURN FUND
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Dosusigned by
By: {Erandaw faa.
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: FRANKLIN INVESTORS SECURITIES TRUST
- FRANKLIN TOTAL RETURN FUND
oe
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Doeusigned by:
By: Pace
Name (print) : Brandon Pace
Title: Chief Administrative Officer
SELLER: FRANKLIN LIMITED DURATION INCOME
TRUST
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Deevsigea by
By; [Brandon fe.
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: GOLDEN CAPS TRUST
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Dorusianet by
B Pace
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: HALMAN-ALDUBI I2P1ST, LIMITED
PARTNERSHIP
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By: (brand Paw
Name (print): Brandon Pace
Title: Chief Administrative Officer
DocuSign Envelope >
SELLER: HCG Consumer Credit II Trust
By: LENDINGCLUB CORPORATION, as attorney-in-fact
DecsSignd by
By: (tbrand a. Pace
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: HCG CONSUMER CREDIT IV, LLC
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By: (Goad ho.
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: HCG CONSUMER CREDIT V TRUST
By: LENDINGCLUB CORPORATION, as attorney-in-fact
DecsSignd by
By: | Gvandou. Pac
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: HCG FINANCE DAC TRUST
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By: (Goat ho.
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: HCL Trust I
By: LENDINGCLUB CORPORATION, as attorney-in-fact
DecsSignd by
By: a. Pace
Name (pani): “Brandon Pace
Title: Chief Administrative Officer
SELLER: Heritage Bank NA
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Deevsigea by
By: Brandon. Paw
Name (print): Brandon Pace
Title: Chief Administrative Officer
DocuSign Envelope >
SELLER: IBI Consumer Credit, LP
By: LENDINGCLUB CORPORATION, as attorney-in-fact
DecsSignd by
By: (tbrand a. Pace
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: ILA CAPITAL TRUST
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Docuslnadby
By: |& Pace.
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Jewett City Savings Bank
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Docutlradby
By: br Pace,
Name print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Jonesboro State Bank
By: LENDINGCLUB CORPORATION, as attorney-in-fact
DecsSignd by
a. Pace
py: L¢
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: Katla Ventures Trust
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Dosusigned by
By: (é me Pace
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: KiWi Private Credit Fund LP
By: LENDINGCLUB CORPORATION, as attorney-in-fact
ocular by:
By: Paw.
Name (pani): |‘Brandon Pace
Title: Chief Administrative Officer
DocuSign Envelope >
SELLER: KOOKMIN BANK AS TRUSTEE OF HANWHA
CONSUMER CREDIT PRIVATE FUND |
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Deevsigea by
pay; [Brandan fe.
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Bank
By: LENDINGCLUB CORPORATION, as attorney-in-fact
DecsSignd by
By; | Brandan. Pace
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificate Issuer Trust Series
2022-NP5
By: LENDINGCLUB CORPORATION, as attorney-in-fact
wy, (eulte
Dosusigned by
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificate Issuer Trust Series
2022-P4
By: LENDINGCLUB CORPORATION, as attorney-in-fact
DecsSignd by
By: (ebrand a. Pace
Name (print): "Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificate Issuer Trust,
Series 2022-LCX1
By: LENDINGCLUB CORPORATION, as attorney-in-fact
by: (eral pee
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificate Issuer Trust,
Series 2022-LCX2
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Deevsigea by
By; [Branden au.
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificate Issuer Trust.
Series 2022-LCX3
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By: Pace,
Name (pri ; Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificate Issuer Trust.
Series 2022-NP1
By: LENDINGCLUB CORPORATION, as attorney-in-fact
by (Pra be fu
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificate Issuer Trust.
Series 2022-NP2
By: LENDINGCLUB CORPORATION, as attorney-in-fact
By Pred
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificate Issuer Trust,
Series 2022-NP3
By: LENDINGCLUB CORPORATION, as attorney-in-fact
by: (eco:be fea.
Name (print). Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificate Issuer Trust.
Series 2022-NP4
By: LENDINGCLUB CORPORATION, as attorney-in-fact
by: (era be tw
Name (print): : Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificate Issuer Trust.
Series 2022-NP6
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Desusirothy
By: brs Pot.
Name (print): "Brandon Pace
Title: Chief Administrative Officer
DocuSign Envelope >
SELLER: LendingClub Loan Certificate Issuer Trust,
Series 2022-P3
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Decutiredby
By: [enardour Pace.
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificate Issuer Trust,
Series 2022-P5
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Deeusignd by
Brandon Pace
By: (e
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificates Issuer Trust,
Series 2021-NP1
By: LENDINGCLUB CORPORATION, as attorney-in-fact
ree
Dosusigned by
By: me Pace
Name Tint); Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificates Issuer Trust,
Series 2022-P1
By: LENDINGCLUB CORPORATION, as attorney-in-fact
by: (trae ho.
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Loan Certificates Issuer Trust,
Series 2022-P2
By: LENDINGCLUB CORPORATION, as attorney-in-fact
Deecsiged by
By; {Brandan Pace
Name (print): Brandon Pace
Title: Chief Administrative Officer
SELLER: LendingClub Receivables Trust
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Electronically Filed 3/25/2024 8:54 AM Superior Court of California Vanessa Thomas, State Bar #323167 County of Stanislaus RAUSCH STURM LLP Clerk of the Court 250 N. Sunnyslope Road, Suite 300 By: Dora Perez, Deputy Brookfield WI 53005 Telephone: (877) 215-2552 Facsimile: (877) 396-4464 $370 PAID E-mail Address: LawfirmCA @rauschsturm.com Attorneys for Plaintiff California License No. 10685-99 SUPERIOR COURT OF THE § ‘ATE OF CALIFORNIA COUNTY OF STANISLAUS, MODESTO DOWNTOWN COURTHOUSE CV-24-002268 GALAXY INTERNATIONAL PURCHASING, LLC, Case No.: Plaintiff, COMPLAINT FOR: 10 1. BREACH OF CONTRACT vs. (Rule 3.740 Collections) 11 KAITLYN STETLER; 12 and DOES | through 10, inclusive, PRAYER AMOUNT: $21,712.27 13 Defendants. LIMITED CIVIL CASE 14 15 Plaintiff GALAXY INTERNATIONAL PURCHASING, LLC (“Plaintiff”) alleges the following facts as to all 16 causes of action as follows: 17 18 1 Plaintiff is qualified to do business in California. 19 2. This Court is proper for this action because Plaintiff is informed and believes that Defendant KAITLYN 20 STETLER is a resident within the jurisdictional boundaries of this Court. 21 3. Plaintiffis informed and believes that Defendant KAITLYN STETLER and Defendants sued by the fictitious 22 names DOES | through 10 (“Defendants”) are responsible for the alleged debt; however, Plaintiffis unaware of the 23 true names and capacities of DOES | through 10 and will seek leave of this Court to amend this Complaint when the 24 true names and capacities have been ascertained. 25 4. Plaintiff believes that at all times mentioned herein, Defendants, and each of them, were the agent, servant, 26 employee, or employer, and acted in the capacity and as agent, of each and of the other Defendants. Plaintiff also 27 believes that each of the Defendants is jointly and severally liable in the actions were taken for the benefit of the 28 Mayne, J ohn R This e356 nap pean sesinst to Juage 1 Deparment forll purposes including Tri. COMPLAINT 4838085" Defendants’ separate and/or community property. Plaintiff also believes that each of the Defendants is jointly and severally liable in that the actions were taken for the benefit of the Defendants’ separate and/or community property. 5. Pursuant to California Civil Code, section 1788.58, subsection (a)(1), Plaintiffis a debt buyer as defined by California Civil Code, section 1788.50, subsection (a). 6. Pursuant to California Civil Code, section 1788.58, subsection (a)(2), Plaintiff is seeking to recover the amount of $21,712.27 from Defendants. This is the past-due balance on a loan or borrower agreement, which was obtained and used by Defendants in exchange for value received from the original creditor, LendingClub Bank, National Association, with the original account number ending in *****8244 (the "Account"). The amount due is the result of loan proceeds and/or goods accepted by Defendants that have not been repaid as agreed and, upon 10 information and belief, were for personal, family, or household purposes. 11 12 7. Pursuant to California Civil Code, section 1788.58, subsection (a)(3), Plaintiff is the sole owner of the 13 obligation sued upon. Attached hereto and incorporated herein by reference as Exhibit 1 is a true and correct copy 14 of the Bill of Sale(s). The account was purchased by the Plaintiff on or around November 30, 2022. 15 8. Pursuant to California Civil Code, section 1788.58, subsection (a)(4), the Account balance at the time of 16 charge-off was $21,712.27. 17 9. Pursuant to California Civil Code, section 1788.58, subsection (a)(5), Plaintiff alleges that the date of the 18 last payment was May 3, 2022. Attached hereto and incorporated herein by reference as Exhibit 2 is a true and 19 correct copy of a transaction history for Defendants' Account. 20 10. Pursuant to California Civil Code, section 1788.58, subsection (a)(6), Plaintiff alleges that the name of 21 22 the creditor at the time of charge-off was Wilmington Savings Fund Society FSB D/B/A Christiana Trust Ttee of 23 Alternative Lending Holdings Trust PLEP (serviced by Lending Club). On information and belief, Plaintiff further 24 alleges that an address used by Wilmington Savings Fund Society FSB D/B/A Christiana Trust Ttee of Alternative 25 Lending Holdings Trust PLEP (serviced by Lending Club) at the time of charge-off was 71 STEVENSON STREET 26 SUITE 300, SAN FRANCISCO CA 94105. At the time of charge-off, the redacted account number associated with 27 this debt was *****8244. 28 2 COMPLAINT 4838085 11. Pursuant to California Civil Code, section 1788.58, subsection (a)(7), Plaintiff alleges that the name of the debtor(s) as it appears in the records of Wilmington Savings Fund Society FSB D/B/A Christiana Trust Ttee of Alternative Lending Holdings Trust PLEP (serviced by Lending Club) is KAITLYN STETLER and the last known address as it appeared in the records of Wilmington Savings Fund Society FSB D/B/A Christiana Trust Ttee of Alternative Lending Holdings Trust PLEP (serviced by Lending Club) is 424 WADDELL WAY, MODESTO,CA 95357. 12. Pursuant to California Civil Code, section 1788.58, subsection (a)(8), Plaintiffis informed and believes that the name and address of all post charge-off purchasers of the Account are as follows: a. Galaxy International Purchasing, LLC, 4730 South Ft Apache Rd STE 300, Las Vegas, NV 89147. 10 13. Pursuant to California Civil Code, section 1788.58, subsection (a)(9), Plaintiff alleges that it has complied 11 12 with the provisions of Civil Code, section 1788.52. 13 14. Pursuant to California Civil Code, section 1788.58(b), attached hereto and incorporated herein by 14 reference as Exhibit 3 is a true and correct copy of the contract or agreement or a copy of a statement recording a 15 purchase transaction, last payment, or balance transfer as required by California Civil Code, section 1788.52, 16 subsection (b). 17 15. Before filing this suit, all rights, title and interest to the Account were sold and assigned to Plaintiff. 18 Plaintiff owns the Account and is entitled to collect on the Account as if it were the original creditor. To the extent 19 that Plaintiff acts in its capacity as successor-in-interest to the original creditor or its assigns, references herein to 20 Plaintiff may include Plaintiff's predecessor-in-interest. 21 22 16. Before commencement of this action, Plaintiff informed Defendant in writing that it intended to file this 23 action and that this action could result in a judgment against Defendant that would include court costs allowed by 24 California Code of Civil Procedure, section 1033, subsection (b)(2). 25 FIRST CAUSE OF ACTION - (Breach of Contract) 26 17. Plaintiff realleges and incorporates by reference all of the foregoing paragraphs. 27 28 3 COMPLAINT 4838085 18. Defendants explicitly or impliedly entered into a contract with the original creditor where it was agreed that by Defendants' receipt of loan proceeds and/or goods, Defendants would be indebted based on the terms of the loan or borrower agreement. 19. Defendants' acceptance of the loan proceeds and/or goods constituted Defendants' acceptance of the terms. of the loan or borrower agreement, and by these terms, Defendants agreed to repay the balance due and to pay interest on the unpaid balance, late charges, and other fees associated with the account. 20. All duties, obligations, and conditions owed to Defendants have been duly performed by Plaintiff or by Plaintiff's assignor(s). 21. Within the statutory period, Defendants breached the loan by failing to repay the amounts due. 10 11 22. Defendants, and each of them, have failed and have refused to pay Plaintiff the sum now due and owing, 12 despite Plaintiff's demand for payment, and thus, are in breach of the agreement. 13 23. As the direct and proximate result of Defendants’ breach, Plaintiff has been damaged in the amount of 14 $21,712.27. 15 SECOND CAUSE OF ACTION - (Open Book Account) 16 24. Plaintiff realleges and incorporates by reference all of the foregoing paragraphs. 17 25. Defendants had financial transactions with Plaintiff’s predecessor when Defendants opened, used, and 18 derived benefit from the Account through Defendants' own use of the loan proceeds and/or goods, or by another's 19 use at Defendants’ direction. By using the loan proceeds, Defendants expressly agreed or impliedly promised to repay 20 Plaintiff. 21 22 26. Within the past four years, Defendants became indebted on the Plaintiff's predecessor in the sum of 23 $21,712.27 on the account. 24 27. Plaintiff’ s predecessor maintained in the regular course of its business an electronic record of the activity 25 on the account, reflecting the debits, credits, charges, fees, and unpaid amount due. 26 28. Plaintiff has made demand upon Defendants for repayment of the unpaid balance due on the account; 27 however, Defendant has failed to satisfy the balance due. 28 29. As of the date of this pleading, there is due and owing the unpaid sum of $21,712.27. 4 COMPLAINT 4838085 WHEREFORE, Plaintiff prays for judgment against Defendants as follows: 1 For the unpaid principal balance of $21,712.27; 2. For post-judgment interest at the statutory rate; 3 For costs of suit; 4 For such other relief as the Court may deem just and proper. We DATED: 03/13/2024 RAUSCH STURM LLP Vanessa Thomas Attorneys for Plaintiff ATTORNEY CONTACT INFO: Vanessa Thomas 10 Phone: (279) 333-8001 E-mail: VThomas@rauschsturm.com 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 COMPLAINT 4838085 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 EXHIBIT 1 26 27 28 4838085 DocuSign Envelope > BILL OF SALE LendingClub Corporation, a Delaware corporation (“LendingClub”) and Galaxy International Purchasing, LLC, a Nevada limited liability company (“Buyer”) executed an Account Purchase Agreement — Forward Flow dated as of April 24, 2020 (“Agreement”). The terms of the Agreement will govern this Bill of Sale and any capitalized but undefined terms herein will have the meanings given to such terms in the Agreement. For value received and in further consideration of the mutual covenants and conditions set forth in the Agreement, the Investors referenced in the data file named Lot22-1100_LendingClub_FinalData.xlsx hereby transfer(s), sell(s), conveys(s), grant(s), and deliver(s) to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Accounts as set forth in the Account Schedule attached hereto as Exhibit I delivered by Seller to Buyer on the Closing Date, and as further described in the Agreement. Pursuant to the Agreement, on November 30, 2022, the Closing Date, each Investor will sell (or cause to be sold) a pool of Accounts held by such Investors and described in the Account Schedule attached to this Bill of Sale. LendingClub represents and warrants that each of the undersigned Investors (other than LendingClub, where LendingClub is the Investor) has executed a limited power of attorney between such Investor and LendingClub wherein a designated power is for LendingClub to act as attorney-in-fact for such Investor and to execute this Bill of Sale on behalf of such Investor and take any action and execute any instruments or documents that LendingClub may deem reasonably necessary or advisable in connection with the transfers contemplated thereby. Lot Number: 22-1100 Total Unpaid Balance: Number of Accounts: DATED: November 30, 2022 LC Legal Reviewed SELLER: LC Trust I By: LENDINGCLUB CORPORATION, as Administrator by: (toma pa Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Corporation Decutiredby By: [trawl Pat. Name (print): Brandon Pace Title: Chief Administrative Officer DocuSign Envelope > SELLER: ADF-National Holdings LLC By: LENDINGCLUB CORPORATION, as attorney-in-fact wy (Brad fo Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Alliant Credit Union By: LENDINGCLUB CORPORATION, as attorney-in-fact Docutlradby By: br Pace, Name (punt): Brandon Pace Title: Chief Administrative Officer SELLER: ALPHACENTRIC PRIME MERIDIAN INCOME FUND By: LENDINGCLUB CORPORATION, as attorney-in-fact Doeusigned by: By: Pace Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Anchor Bank By: LENDINGCLUB CORPORATION, as attorney-in-fact By: (Gomera Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Banco Popular de Puerto Rico By: LENDINGCLUB CORPORATION, as attorney-in-fact Dorusianet by By: Pace Name (print): |Brandon Pace Title: Chief Administrative Officer SELLER: Banco Popular North America By: LENDINGCLUB CORPORATION, as attorney-in-fact Dosusigned by B ae Pace Name (print): Brandon Pace Title: Chief Administrative Officer DocuSign Envelope > SELLER: BankNewport By: LENDINGCLUB CORPORATION, as attorney-in-fact by: (tral pee Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: BTG Pactual Absolute Return Master Fund, L.P. By: LENDINGCLUB CORPORATION, as attorney-in-fact Docutlradby By: br Pace, Name (punt): Brandon Pace Title: Chief Administrative Officer SELLER: California First National Bank By: LENDINGCLUB CORPORATION, as attorney-in-fact DecsSignd by By: | Gvandou. Pac Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Callune Participations s.a.r.1. By: LENDINGCLUB CORPORATION, as attorney-in-fact Docuslnadby B tr Pace. Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Carter Bank & Trust By: LENDINGCLUB CORPORATION, as attorney-in-fact ay: (Sl Deevsigea by Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Central Pacific Bank By: LENDINGCLUB CORPORATION, as attorney-in-fact By: (tradi fa, Name (print): Brandon Pace Title: Chief Administrative Officer DocuSign Envelope > SELLER: CIGPF I Corp. By: LENDINGCLUB CORPORATION, as attorney-in-fact Deeusignd by By: we Pace Name (pint): Brandon Pace Title: Chief Administrative Officer SELLER: CML Borrower Trust By: LENDINGCLUB CORPORATION, as attorney-in-fact DecsSignd by By: a. Pace Name (pint): Brandon Pace Title: Chief Administrative Officer SELLER: Commercial Bank of California By: LENDINGCLUB CORPORATION, as attorney-in-fact Deeusignd by By: (eBrandon Pace Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Congressional Bank By: LENDINGCLUB CORPORATION, as attorney-in-fact DecsSignd by a. Pace py: L¢ Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Consumer Lending Receivables Grantor Trust 2019-A CLRT 2019-A By: LENDINGCLUB CORPORATION, as attorney-in-fact Docutlradby By: tre Pace, Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Consumer Loan Underlying Bond (Club) Certificate Issuer Trust I By: LENDINGCLUB CORPORATION, as attorney-in-fact Decutiredby By: ( traucdnn. Pat. Name (print): Brandon Pace Title: Chief Administrative Officer DocuSign Envelope > SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) CREDIT TRUST 2020-P1 By: LENDINGCLUB CORPORATION, as attorney-in-fact Deevsigea by pay; [Brandan fe. Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2017-NP2 By: LENDINGCLUB CORPORATION, as attorney-in-fact ce ned By: a. Pace Name mt y Brandon Pace Title: Chief Administrative Officer SELLER: Consumer Loan Underlying Bond (CLUB) Grantor Trust 2017-P1 By: LENDINGCLUB CORPORATION, as attorney-in-fact Doeusigned by: By: Pace Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2017-P2 By: LENDINGCLUB CORPORATION, as attorney-in-fact Ci siredoy By: Pace, Name mint); Brandon Pace Title: Chief Administrative Officer SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2018-P1 By: LENDINGCLUB CORPORATION, as attorney-in-fact by: (tran fu Name (print): |Brandon Pace Title: Chief Administrative Officer SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2018-P2 By: LENDINGCLUB CORPORATION, as attorney-in-fact By: (Brio pa. Name (print): Brandon Pace Title: Chief Administrative Officer DocuSign Envelope > SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2018-P3 By: LENDINGCLUB CORPORATION, as attorney-in-fact By: (trade fo Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2019-HP1 By: LENDINGCLUB CORPORATION, as attorney-in-fact By: (trod ho. Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Consumer Loan Underlying Bond (CLUB) Grantor Trust 2019-P1 By: LENDINGCLUB CORPORATION, as attorney-in-fact Ce Docuslnadby By: Pace. Name mint); Brandon Pace Title: Chief Administrative Officer SELLER: CONSUMER LOAN UNDERLYING BOND (CLUB) GRANTOR TRUST 2019-P2 By: LENDINGCLUB CORPORATION, as attorney-in-fact Dosusigned by py: [Erandan.fo. Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: CONSUMER UNDERLYING BOND SECURITIZATION, SERIES 2018-1 GRANTOR TRUST By: LENDINGCLUB CORPORATION, as attorney-in-fact Docuslredby By: Pace Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: COPPER CANYON TRUST By: LENDINGCLUB CORPORATION, as attorney-in-fact Deevsigea by py, [Erandew Pu. Name (print): "Brandon Pace Title: Chief Administrative Officer DocuSign Envelope > SELLER: County Bank By: LENDINGCLUB CORPORATION, as attorney-in-fact re Decutiredby By: Pace, Name mint): Brandon Pace Title: Chief Administrative Officer SELLER: Deerwood Bank By: LENDINGCLUB CORPORATION, as attorney-in-fact ae Docuslgned by By: Pace, Name mt): Brandon Pace Title: Chief Administrative Officer SELLER: DL INVESTMENT SARL, ACTING ON BEHALF COMPARTMENT MOONSTONE 2 By: LENDINGCLUB CORPORATION, as attorney-in-fact By: (tran fate Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: DL Investment Sarl, Compartment Moonstone 1 By: LENDINGCLUB CORPORATION, as attorney-in-fact By: (trad fa Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: DYNAMIC CREDIT LOAN INVESTMENT DAC By: LENDINGCLUB CORPORATION, as attorney-in-fact By: (traclac pee Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Edge Focus High Yield Fund, LP By: LENDINGCLUB CORPORATION, as attorney-in-fact by. (Goma pa Name (print): Brandon Pace Title: Chief Administrative Officer DocuSign Envelope > SELLER: Fasanara Apex I By: LENDINGCLUB CORPORATION, as attorney-in-fact By: (Brae fa Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: FRANKLIN INVESTORS SECURITIES TRUST - FRANKLIN LOW DURATION TOTAL RETURN FUND By: LENDINGCLUB CORPORATION, as attorney-in-fact Dosusigned by By: {Erandaw faa. Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: FRANKLIN INVESTORS SECURITIES TRUST - FRANKLIN TOTAL RETURN FUND oe By: LENDINGCLUB CORPORATION, as attorney-in-fact Doeusigned by: By: Pace Name (print) : Brandon Pace Title: Chief Administrative Officer SELLER: FRANKLIN LIMITED DURATION INCOME TRUST By: LENDINGCLUB CORPORATION, as attorney-in-fact Deevsigea by By; [Brandon fe. Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: GOLDEN CAPS TRUST By: LENDINGCLUB CORPORATION, as attorney-in-fact Dorusianet by B Pace Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: HALMAN-ALDUBI I2P1ST, LIMITED PARTNERSHIP By: LENDINGCLUB CORPORATION, as attorney-in-fact By: (brand Paw Name (print): Brandon Pace Title: Chief Administrative Officer DocuSign Envelope > SELLER: HCG Consumer Credit II Trust By: LENDINGCLUB CORPORATION, as attorney-in-fact DecsSignd by By: (tbrand a. Pace Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: HCG CONSUMER CREDIT IV, LLC By: LENDINGCLUB CORPORATION, as attorney-in-fact By: (Goad ho. Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: HCG CONSUMER CREDIT V TRUST By: LENDINGCLUB CORPORATION, as attorney-in-fact DecsSignd by By: | Gvandou. Pac Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: HCG FINANCE DAC TRUST By: LENDINGCLUB CORPORATION, as attorney-in-fact By: (Goat ho. Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: HCL Trust I By: LENDINGCLUB CORPORATION, as attorney-in-fact DecsSignd by By: a. Pace Name (pani): “Brandon Pace Title: Chief Administrative Officer SELLER: Heritage Bank NA By: LENDINGCLUB CORPORATION, as attorney-in-fact Deevsigea by By: Brandon. Paw Name (print): Brandon Pace Title: Chief Administrative Officer DocuSign Envelope > SELLER: IBI Consumer Credit, LP By: LENDINGCLUB CORPORATION, as attorney-in-fact DecsSignd by By: (tbrand a. Pace Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: ILA CAPITAL TRUST By: LENDINGCLUB CORPORATION, as attorney-in-fact Docuslnadby By: |& Pace. Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Jewett City Savings Bank By: LENDINGCLUB CORPORATION, as attorney-in-fact Docutlradby By: br Pace, Name print): Brandon Pace Title: Chief Administrative Officer SELLER: Jonesboro State Bank By: LENDINGCLUB CORPORATION, as attorney-in-fact DecsSignd by a. Pace py: L¢ Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Katla Ventures Trust By: LENDINGCLUB CORPORATION, as attorney-in-fact Dosusigned by By: (é me Pace Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: KiWi Private Credit Fund LP By: LENDINGCLUB CORPORATION, as attorney-in-fact ocular by: By: Paw. Name (pani): |‘Brandon Pace Title: Chief Administrative Officer DocuSign Envelope > SELLER: KOOKMIN BANK AS TRUSTEE OF HANWHA CONSUMER CREDIT PRIVATE FUND | By: LENDINGCLUB CORPORATION, as attorney-in-fact Deevsigea by pay; [Brandan fe. Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Bank By: LENDINGCLUB CORPORATION, as attorney-in-fact DecsSignd by By; | Brandan. Pace Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Loan Certificate Issuer Trust Series 2022-NP5 By: LENDINGCLUB CORPORATION, as attorney-in-fact wy, (eulte Dosusigned by Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Loan Certificate Issuer Trust Series 2022-P4 By: LENDINGCLUB CORPORATION, as attorney-in-fact DecsSignd by By: (ebrand a. Pace Name (print): "Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Loan Certificate Issuer Trust, Series 2022-LCX1 By: LENDINGCLUB CORPORATION, as attorney-in-fact by: (eral pee Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Loan Certificate Issuer Trust, Series 2022-LCX2 By: LENDINGCLUB CORPORATION, as attorney-in-fact Deevsigea by By; [Branden au. Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Loan Certificate Issuer Trust. Series 2022-LCX3 By: LENDINGCLUB CORPORATION, as attorney-in-fact By: Pace, Name (pri ; Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Loan Certificate Issuer Trust. Series 2022-NP1 By: LENDINGCLUB CORPORATION, as attorney-in-fact by (Pra be fu Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Loan Certificate Issuer Trust. Series 2022-NP2 By: LENDINGCLUB CORPORATION, as attorney-in-fact By Pred Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Loan Certificate Issuer Trust, Series 2022-NP3 By: LENDINGCLUB CORPORATION, as attorney-in-fact by: (eco:be fea. Name (print). Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Loan Certificate Issuer Trust. 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Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Loan Certificate Issuer Trust, Series 2022-P5 By: LENDINGCLUB CORPORATION, as attorney-in-fact Deeusignd by Brandon Pace By: (e Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Loan Certificates Issuer Trust, Series 2021-NP1 By: LENDINGCLUB CORPORATION, as attorney-in-fact ree Dosusigned by By: me Pace Name Tint); Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Loan Certificates Issuer Trust, Series 2022-P1 By: LENDINGCLUB CORPORATION, as attorney-in-fact by: (trae ho. Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Loan Certificates Issuer Trust, Series 2022-P2 By: LENDINGCLUB CORPORATION, as attorney-in-fact Deecsiged by By; {Brandan Pace Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LendingClub Receivables Trust By: LENDINGCLUB CORPORATION, as attorney-in-fact Dosusigned by py; [Erandan.fa. Name (print): Brandon Pace Title: Chief Administrative Officer DocuSign Envelope > SELLER: Leo Acquisitions OV Trust By: LENDINGCLUB CORPORATION, as attorney-in-fact oe Deeusignd by Brandon Pace By: Name mint): Brandon Pace Title: Chief Administrative Officer SELLER: Leo Acquisitions OV Trust Prime By: LENDINGCLUB CORPORATION, as attorney-in-fact DecsSignd by By; | Brandan. Pace Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Loan Asset Holdings Trust 2021 M-2 By: LENDINGCLUB CORPORATION, as attorney-in-fact Decutiredby By: mm Pace, Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: Loan Asset Holdings Trust I] 2022-1 By: LENDINGCLUB CORPORATION, as attorney-in-fact Deevsigea by By: (Brandan face Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LOAN ASSET ISSUER II LLC By: LENDINGCLUB CORPORATION, as attorney-in-fact Docutlradby B ts Pace, Name (print): Brandon Pace Title: Chief Administrative Officer SELLER: LOAN ASSET ISSUER LLC By: LENDINGCLUB CORPORATION, as attorney-in-fact By: (era pa Name (print): Brandon Pace Title: Chief Administrative Officer DocuSign Envelope > SELLER: MountainOne Bank By: LENDINGCLUB CORPORATION, as attorney-in-fact DecsSignd by By: (tbrand a. 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