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BUSINESS AND TRIAL LAWYERS
Schreiber Law, LLC
53 Stiles Road, Suite A102
Salem, NH 03079
TELEPHONE (603) 870-5333 TOLL FREE (800) 423-8142
TTY (866)718-3328 FACSIMILE (603) 870-0077
HOURS: MON.-FRI. 8:30 A.M. TO 5:30 P.M. (ET)
May 9, 2024
IRIS M AVILA
406 FRANKLIN AVE FL2
HARTFORD, CT 06114-2518
Re: Cavalry SPV1, LLC / IRIS M AVILA
Dear IRIS M AVILA:
Enclosed is a Writ and Complaint for a debt incurred and unpaid. There is still time to resolve this matter and
avoid further litigation. If you would like to make arrangement, please call us at 800-423-8142.
Ver rhly yours,
REJBER LAW, LLC
OU Jeffyéy A. Schreiber
Ou ther Q. Wallace
0 David M. Fumudoh, Jr.
Attorney at Law
7500/HRO
4393742
THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
SMALL CLAIMS WRIT STATE OF CONNECTICUT
{ Pj ee
I
AND NOTICE OF SUIT SUPERIOR COURT
JOC Re 13 SMALL CLAIMS SESSION { .
GS. §§ Si-15, S1-S4S.9} panne jud.ct.g0¥ f
5
Type or print legibly. This Smal Clsims Wat and Notice of \f must be served on {delivered fo}
the defendants) before filing it with the court. See instructions to Plain! on reverse,
1.) Locston ‘rformation that will determine where the tnai will O: 7} Case type code (See list on reverse page 1)
Defendant’s Residence Major: Si Minor: 15
3.)is this a claim between a iandicrd and a tenant (renter|? 4.) if vou answered "Yes" to question #3, state the town where the rental oremises ’s locates:
(Seect ona) =] Yes [X] Ne 1
Parties Name (Last First Middte Inizial) and Address P.O. Bor, Town: Sure;
of Each Party (Number. Sweet, Zip; Counzy. if nor USA
5} First
Name: Cavalry SPV, LLC {Select one) Lic © Parmersivp pot
dddress: 1 AMERICAN LANE SUITE 220 GREENWICH, CT 06831
Plaintiff Di inewiduat [[] CBA | Corporation
Telephone:
8.) Name, address, and zip code of Attomey for Plamtrfis) ‘Atiomey’s Juris Number Taliephone number (w/area code)
‘SCHREIBER LAW, LLC, 53 STILES RD., A-102 434988 603-870-5333
SALEM, NH, 03079
7.) First
Name: IRIS M AVILA
406 FRANKLIN AVE FL 2 HARTFORD, CT 06114-2518,
(Seectone) CJ ULC 1] Partnership 4
Address: (Xl individual (] DBA |] Corporation
Defendant
Telephone:
Fee more than | plantifficefendant, attach Continuation of Parties {form JD-CV-57) and select this box Cl
8.) if this. claim is a consumer debt, whch is 3 debt or obligation made primarily for personal, famity, or household reasons, give the reasons why you believe
that the statute of linvtations has not expired
DEFENDANT'S LAST PAYMENT TOWARDS THE ACCOUNT OCCURRED ON 01/19/2023, WHICH IS WITHIN THE APPLICABLE STATUTE OF LIMITATIONS
PERIOD.
1.) How did you check in the last 6 months that the address given for defendant(s) = accurate?
Select ali boxes that apply and provide the dates that the address was checked.
[DJ I ehecked town or city records {for example, checking a street list or tax records} Perper a (date checked)
[1] tchecked with the Deparment of Motor Vehicles (date checked)
with that retum address
[[] lreceived comespandence {letters or other mail) from the defendant (date checked)
[J | received other proof from the defendant that the address is cumert
(description
of
and date che ash
[X] | mailed by frst class mail, at least 4 weeks before this small claims action was filed, 3 letter to t the
_ Wetene
defendant at the
03/19/2024 lecked
address used and the letter has not been returned to me by the United States Postal Service _ letter)
TO.) Amount dames” { Phis prejudgment interest"*
$1267.44 Plus Costs [Ci Plus couble damages for security deposit withheld”
"The Amount Claimed may not be more than §5.000. Do not include amounts *if you select one or more bow: you MUST explain
{or pre-judgment interest or doubling the security deposit in box 10. how much you want for each item in section 17 below.
To Defendant(s}
11.) You are being sued. The Plaintif/s) claims you owe the above amount pius costs and pre-juagman interest and‘or double damages fora withheld
securty depos (f seicted) for the follawing reasons:
Citibank, N.A./The Home Depot (“original creditor”) issued defendant a credit ("Account") with the Account number XXXXXXXXXXXX3371 and upon use of
that Account, defendant became obligated to make timely payments. Defendant defaulted on that obli 1m and owes the balance due on the Account.
Plaintiff acquired the Account and is the bona fide owner of the Account. Despite demand, defendant .d to, or was unable to, pay. Plaintiff demands
judgment for the amount claimed together with costs and post-judgment interest in accordance with CT Gen. Stat. Sec. 37-3a. Plaintiff requests that the
Court further order a nominal payment order commencing three (3) weeks from the date of the judgment. Defendant i Ison ets tI
supporting documents.). ELY P| N TE RI AN O
w Hampshire
-_
Notary Publi c Neion Expir
i Comm! iss
that he or she has read the claim above andth | form: nd. ti th
The peyden ring below, being duly sworn,therestates
is good ground to suppor the eiaim and the sformati st
Coe ES 11 Bs: of his
orherknow)édge. sformation and belief,
12) rH _— Type meme or EpAen Saning ate a = spplicsb For Court Use Only (Dais/Stamp)
Cteather se eeeid, Furmudoh, I, E50.
sefoteiimen O14 {24 _| ADA NOTICE
Signs;
(AM
tk, Not
hd YAS
The Judicial Branch of the State of Cornectiout complies with He Americans with
Dissbilites Act (ADA). ff you nesd 3 reasonable accomynocaticn in accordance with the
Docker Number
ADA, contact 3 court clerk or an ADA contact person listed at wwrw,jud.ct goviADA.
Print Form Pape lof Reset Form
INSTRUCTIONS TO DEFENDANT
(NOTICE TO PERSON BEING SUED)
JOCV-121 Rev. 7-12
Please read the instructions carefully.
For more information, get a copy of HOW SMALL CLAIMS COURT WORKS (form JDP-CV-45) from the Clerk's Office
or from our website at www.jud.ct.gov/faq/smaliclaims.html.
What Do | Have To Do To Defend This Case?
The person suing you (the Plaintiff) delivered to you (served you with) a copy of the Small Claims Writ and Notice of
Suit; and related documents, if any. The plaintiff will now file the Small Claims Writ and Notice of Suit and related
documents with the court. The court will send you an Answer form and a Counterclaim form with the number the court
assigns to the case, called the "docket number" of the case, and the date you must file your Answer, and Counterclaim
if you make one, by. The Answer form and the Counterclaim form should be sent to you soon but it could take up to 6
weeks depending on when the plaintiff files the case with the court.
The Answer is your response or reply to the plaintiff's claim. If you claim the plaintiff owes you money, this is called a
Counterclaim. There is a $90.00 fee to file a Counterclaim. Your Answer, and your Counterclaim if you make one,
should be specific but brief. Fill out the entire Answer form, and the Counterclaim form if you make a Counterclaim,
and sign them. Keep a copy of each for yourself and send a copy to each attorney or other representative of the
plaintiff, or if the plaintiff is representing himself or herself, to the plaintiff. Send the original Answer form to the court by
mail, fax or hand delivery at the address or fax number shown below on or before the answer date. If you make a
Counterclaim, mail the original Counterclaim with the $90.00 fee to the court or hand deliver them to the address
shown below on or before the answer date. You cannot fax a Counterclaim and its filing fee to the court. Please
be sure to give us any change of your address.
Do not answer until you get the Answer form and Counterclaim form from the court but if you do not get an Answer
form and Counterclaim form within 6 weeks of being served, contact the court to ask why. If you do not file an Answer
in writing with the court, a money judgment could enter against you. This is called a default judgment.
You may make an agreement with the plaintiff before the plaintiff files the lawsuit in court or at any time before the
court enters a judgment. You may hire a lawyer to represent you if you want to.
You can find helpful information on our website at: http:/Awww.jud.ct.gov/fag/smaliclaims.html and you may check the
status of your case after it has been given a docket number at: http :/Avww.jud2.ct.gov/Small_Claims/.
if you have any questions, you can visit or call the Centralized Small Claims Office at 80 Washington Street,
Hartford, CT 06106. The telephone number in the Hartford area is 860-756-7800. The toll free telephone number in
Connecticut is 866-383-5927. The fax number is (860) 756-7805.
You do not need an attorney even if the plaintiff has one. However, you can have an attorney if you want to hire one.
If you want to use the regular rules of court in this case or if you want the right to appeal this case, you must file a
motion to transfer the case to the regular civil or housing docket of the superior court. You may need an attorney to
help you in filing that motion and you will have to pay fees te file it. The motion to transfer must be filed, in writing, with
an affidavit and with the correct fees, on or before the answer date.
What Happens If | Do Not File An Answer? If you do not file an Answer, the file will be reviewed by a magistrate who
will decide whether a judgment can enter without a hearing for the full amount of the claim plus court costs, or ifa trial
needs to be scheduled.
What Happens If | File An Answer? If you file an Answer, do not go to court on the answer date. After the court
receives your Answer, a trial will be scheduled if one is required. Cases are scheduled for trial as quickly as possible.
What Should | Do If The Plaintiff Owes Me Money? If you claim the plaintiff owes you money, this is called a
Counterclaim. Explain how much the plaintiff owes you and why on the Counterclaim form. Fill out the entire
Counterclaim form and sign it. Keep a copy for yourself and send a copy to each attorney or other representative of the
plaintiff, or if the plaintiff is representing himself or herself, to the plaintiff. Mail the original Counterclaim form with the
Page 1 of 2
$90.00 fee to the court or hand deliver them to the address shown above on or before the answer date. Please be sure
to give us any change of your address.
What If | Know | Owe The Plaintiff Some Money? If you know you owe the plaintiff something, but you do not agree
with the amount the plaintiffis asking for or you are not sure how much you owe the plaintiff, you should file a written
Answer. This gives you a chance to come to court for a trial to question how the plaintiff added up the amount claimed.
What Should | Do If | Admit That 1 Owe The Plaintiff The Whole Amount? If you are sure that you owe the whole
amount but you want time to pay, you must file an Answer not later than the Answer date, stating that you want time
to pay the claim and why you are asking for the extra time to pay. You may ask for a period of time during which you
can make payments that you suggest. If you do not, and you are an individual, the court will enter a judgment with an
order of payments of $35.00 each week until the judgment is paid. if you ask to pay less than $35.00 per week and the
plaintiff does not agree, a trial will be scheduled.
A judgment against a business entity, for example, a corporation, or a judgment against a landlord for return of a
security deposit, will be ordered paid in the full amount. This will be entered as a judgment of the court.
If you pay the plaintifffplaintiff's attomey the full amount owed plus costs, if any, before the answer date, tell the court
on the Answer form. Do not send payment(s) to the court.
Where And When Do | Have To Go To Court? If a trial is required, you will be sent a notice of the date, time and
place of the trial. Even if you filed an Answer or a request for time to pay, the court can enter a judgment against you if
you do not come to court on the date and time set for the trial.
What Do I Need To Bring To Court? On the day of the trial, you must bring all your witnesses and evidence (bills,
invoices, checks) to court with you. This includes any defective or damaged goods that can be brought to court safely
and easily, estimates of damages, pictures, and anything else that you want the court to look at. Be complete and
organized in your case. A small claims judgment cannot be appealed.
ADA Notice
The Judicial Branch of the State of Connecticut complies with the Americans with Disabilities Act
(ADA). If you need a reasonable accommodation in accordance with the ADA, contact a court
clerk or an ADA contact person listed at www.jud.ct.gowADA/.
Preview
BUSINESS AND TRIAL LAWYERS Schreiber Law, LLC 53 Stiles Road, Suite A102 Salem, NH 03079 TELEPHONE (603) 870-5333 TOLL FREE (800) 423-8142 TTY (866)718-3328 FACSIMILE (603) 870-0077 HOURS: MON.-FRI. 8:30 A.M. TO 5:30 P.M. (ET) May 9, 2024 IRIS M AVILA 406 FRANKLIN AVE FL2 HARTFORD, CT 06114-2518 Re: Cavalry SPV1, LLC / IRIS M AVILA Dear IRIS M AVILA: Enclosed is a Writ and Complaint for a debt incurred and unpaid. There is still time to resolve this matter and avoid further litigation. If you would like to make arrangement, please call us at 800-423-8142. Ver rhly yours, REJBER LAW, LLC OU Jeffyéy A. Schreiber Ou ther Q. Wallace 0 David M. Fumudoh, Jr. Attorney at Law 7500/HRO 4393742 THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. SMALL CLAIMS WRIT STATE OF CONNECTICUT { Pj ee I AND NOTICE OF SUIT SUPERIOR COURT JOC Re 13 SMALL CLAIMS SESSION { . GS. §§ Si-15, S1-S4S.9} panne jud.ct.g0¥ f 5 Type or print legibly. This Smal Clsims Wat and Notice of \f must be served on {delivered fo} the defendants) before filing it with the court. See instructions to Plain! on reverse, 1.) Locston ‘rformation that will determine where the tnai will O: 7} Case type code (See list on reverse page 1) Defendant’s Residence Major: Si Minor: 15 3.)is this a claim between a iandicrd and a tenant (renter|? 4.) if vou answered "Yes" to question #3, state the town where the rental oremises ’s locates: (Seect ona) =] Yes [X] Ne 1 Parties Name (Last First Middte Inizial) and Address P.O. Bor, Town: Sure; of Each Party (Number. Sweet, Zip; Counzy. if nor USA 5} First Name: Cavalry SPV, LLC {Select one) Lic © Parmersivp pot dddress: 1 AMERICAN LANE SUITE 220 GREENWICH, CT 06831 Plaintiff Di inewiduat [[] CBA | Corporation Telephone: 8.) Name, address, and zip code of Attomey for Plamtrfis) ‘Atiomey’s Juris Number Taliephone number (w/area code) ‘SCHREIBER LAW, LLC, 53 STILES RD., A-102 434988 603-870-5333 SALEM, NH, 03079 7.) First Name: IRIS M AVILA 406 FRANKLIN AVE FL 2 HARTFORD, CT 06114-2518, (Seectone) CJ ULC 1] Partnership 4 Address: (Xl individual (] DBA |] Corporation Defendant Telephone: Fee more than | plantifficefendant, attach Continuation of Parties {form JD-CV-57) and select this box Cl 8.) if this. claim is a consumer debt, whch is 3 debt or obligation made primarily for personal, famity, or household reasons, give the reasons why you believe that the statute of linvtations has not expired DEFENDANT'S LAST PAYMENT TOWARDS THE ACCOUNT OCCURRED ON 01/19/2023, WHICH IS WITHIN THE APPLICABLE STATUTE OF LIMITATIONS PERIOD. 1.) How did you check in the last 6 months that the address given for defendant(s) = accurate? Select ali boxes that apply and provide the dates that the address was checked. [DJ I ehecked town or city records {for example, checking a street list or tax records} Perper a (date checked) [1] tchecked with the Deparment of Motor Vehicles (date checked) with that retum address [[] lreceived comespandence {letters or other mail) from the defendant (date checked) [J | received other proof from the defendant that the address is cumert (description of and date che ash [X] | mailed by frst class mail, at least 4 weeks before this small claims action was filed, 3 letter to t the _ Wetene defendant at the 03/19/2024 lecked address used and the letter has not been returned to me by the United States Postal Service _ letter) TO.) Amount dames” { Phis prejudgment interest"* $1267.44 Plus Costs [Ci Plus couble damages for security deposit withheld” "The Amount Claimed may not be more than §5.000. Do not include amounts *if you select one or more bow: you MUST explain {or pre-judgment interest or doubling the security deposit in box 10. how much you want for each item in section 17 below. To Defendant(s} 11.) You are being sued. The Plaintif/s) claims you owe the above amount pius costs and pre-juagman interest and‘or double damages fora withheld securty depos (f seicted) for the follawing reasons: Citibank, N.A./The Home Depot (“original creditor”) issued defendant a credit ("Account") with the Account number XXXXXXXXXXXX3371 and upon use of that Account, defendant became obligated to make timely payments. Defendant defaulted on that obli 1m and owes the balance due on the Account. Plaintiff acquired the Account and is the bona fide owner of the Account. Despite demand, defendant .d to, or was unable to, pay. Plaintiff demands judgment for the amount claimed together with costs and post-judgment interest in accordance with CT Gen. Stat. Sec. 37-3a. Plaintiff requests that the Court further order a nominal payment order commencing three (3) weeks from the date of the judgment. Defendant i Ison ets tI supporting documents.). ELY P| N TE RI AN O w Hampshire -_ Notary Publi c Neion Expir i Comm! iss that he or she has read the claim above andth | form: nd. ti th The peyden ring below, being duly sworn,therestates is good ground to suppor the eiaim and the sformati st Coe ES 11 Bs: of his orherknow)édge. sformation and belief, 12) rH _— Type meme or EpAen Saning ate a = spplicsb For Court Use Only (Dais/Stamp) Cteather se eeeid, Furmudoh, I, E50. sefoteiimen O14 {24 _| ADA NOTICE Signs; (AM tk, Not hd YAS The Judicial Branch of the State of Cornectiout complies with He Americans with Dissbilites Act (ADA). ff you nesd 3 reasonable accomynocaticn in accordance with the Docker Number ADA, contact 3 court clerk or an ADA contact person listed at wwrw,jud.ct goviADA. Print Form Pape lof Reset Form INSTRUCTIONS TO DEFENDANT (NOTICE TO PERSON BEING SUED) JOCV-121 Rev. 7-12 Please read the instructions carefully. For more information, get a copy of HOW SMALL CLAIMS COURT WORKS (form JDP-CV-45) from the Clerk's Office or from our website at www.jud.ct.gov/faq/smaliclaims.html. What Do | Have To Do To Defend This Case? The person suing you (the Plaintiff) delivered to you (served you with) a copy of the Small Claims Writ and Notice of Suit; and related documents, if any. The plaintiff will now file the Small Claims Writ and Notice of Suit and related documents with the court. The court will send you an Answer form and a Counterclaim form with the number the court assigns to the case, called the "docket number" of the case, and the date you must file your Answer, and Counterclaim if you make one, by. The Answer form and the Counterclaim form should be sent to you soon but it could take up to 6 weeks depending on when the plaintiff files the case with the court. The Answer is your response or reply to the plaintiff's claim. If you claim the plaintiff owes you money, this is called a Counterclaim. There is a $90.00 fee to file a Counterclaim. Your Answer, and your Counterclaim if you make one, should be specific but brief. Fill out the entire Answer form, and the Counterclaim form if you make a Counterclaim, and sign them. Keep a copy of each for yourself and send a copy to each attorney or other representative of the plaintiff, or if the plaintiff is representing himself or herself, to the plaintiff. Send the original Answer form to the court by mail, fax or hand delivery at the address or fax number shown below on or before the answer date. If you make a Counterclaim, mail the original Counterclaim with the $90.00 fee to the court or hand deliver them to the address shown below on or before the answer date. You cannot fax a Counterclaim and its filing fee to the court. Please be sure to give us any change of your address. Do not answer until you get the Answer form and Counterclaim form from the court but if you do not get an Answer form and Counterclaim form within 6 weeks of being served, contact the court to ask why. If you do not file an Answer in writing with the court, a money judgment could enter against you. This is called a default judgment. You may make an agreement with the plaintiff before the plaintiff files the lawsuit in court or at any time before the court enters a judgment. You may hire a lawyer to represent you if you want to. You can find helpful information on our website at: http:/Awww.jud.ct.gov/fag/smaliclaims.html and you may check the status of your case after it has been given a docket number at: http :/Avww.jud2.ct.gov/Small_Claims/. if you have any questions, you can visit or call the Centralized Small Claims Office at 80 Washington Street, Hartford, CT 06106. The telephone number in the Hartford area is 860-756-7800. The toll free telephone number in Connecticut is 866-383-5927. The fax number is (860) 756-7805. You do not need an attorney even if the plaintiff has one. However, you can have an attorney if you want to hire one. If you want to use the regular rules of court in this case or if you want the right to appeal this case, you must file a motion to transfer the case to the regular civil or housing docket of the superior court. You may need an attorney to help you in filing that motion and you will have to pay fees te file it. The motion to transfer must be filed, in writing, with an affidavit and with the correct fees, on or before the answer date. What Happens If | Do Not File An Answer? If you do not file an Answer, the file will be reviewed by a magistrate who will decide whether a judgment can enter without a hearing for the full amount of the claim plus court costs, or ifa trial needs to be scheduled. What Happens If | File An Answer? If you file an Answer, do not go to court on the answer date. After the court receives your Answer, a trial will be scheduled if one is required. Cases are scheduled for trial as quickly as possible. What Should | Do If The Plaintiff Owes Me Money? If you claim the plaintiff owes you money, this is called a Counterclaim. Explain how much the plaintiff owes you and why on the Counterclaim form. Fill out the entire Counterclaim form and sign it. Keep a copy for yourself and send a copy to each attorney or other representative of the plaintiff, or if the plaintiff is representing himself or herself, to the plaintiff. Mail the original Counterclaim form with the Page 1 of 2 $90.00 fee to the court or hand deliver them to the address shown above on or before the answer date. Please be sure to give us any change of your address. What If | Know | Owe The Plaintiff Some Money? If you know you owe the plaintiff something, but you do not agree with the amount the plaintiffis asking for or you are not sure how much you owe the plaintiff, you should file a written Answer. This gives you a chance to come to court for a trial to question how the plaintiff added up the amount claimed. What Should | Do If | Admit That 1 Owe The Plaintiff The Whole Amount? If you are sure that you owe the whole amount but you want time to pay, you must file an Answer not later than the Answer date, stating that you want time to pay the claim and why you are asking for the extra time to pay. You may ask for a period of time during which you can make payments that you suggest. If you do not, and you are an individual, the court will enter a judgment with an order of payments of $35.00 each week until the judgment is paid. if you ask to pay less than $35.00 per week and the plaintiff does not agree, a trial will be scheduled. A judgment against a business entity, for example, a corporation, or a judgment against a landlord for return of a security deposit, will be ordered paid in the full amount. This will be entered as a judgment of the court. If you pay the plaintifffplaintiff's attomey the full amount owed plus costs, if any, before the answer date, tell the court on the Answer form. Do not send payment(s) to the court. Where And When Do | Have To Go To Court? If a trial is required, you will be sent a notice of the date, time and place of the trial. Even if you filed an Answer or a request for time to pay, the court can enter a judgment against you if you do not come to court on the date and time set for the trial. What Do I Need To Bring To Court? On the day of the trial, you must bring all your witnesses and evidence (bills, invoices, checks) to court with you. This includes any defective or damaged goods that can be brought to court safely and easily, estimates of damages, pictures, and anything else that you want the court to look at. Be complete and organized in your case. A small claims judgment cannot be appealed. ADA Notice The Judicial Branch of the State of Connecticut complies with the Americans with Disabilities Act (ADA). If you need a reasonable accommodation in accordance with the ADA, contact a court clerk or an ADA contact person listed at www.jud.ct.gowADA/.