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Case Number: CONO-20-019717 Division: 70
Filing # 115132407 E-Filed 10/16/2020 04:33:42 PM
IN THE COUNTY COURT IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.:
CAVALRY SPV I, LLC, AS ASSIGNEE
OF CITIBANK, N.A.
Plaintiff,
vs.
HADI M BADREDDINE,
Defendant.
/
COMES NOW the Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., by
and through its undersigned counsel, and sues Defendant, HADI M BADREDDINE, and states as
follows:
GENERAL ALLEGATIONS
1. This is an action for damages that are within the jurisdictional limits of this court exclusive of
costs.
2. Venue of this action is proper in the county named above because the Defendant is a resident
of this county and/or because the Defendant executed the subject agreement in this county.
3. Upon Defendant’s request, the original creditor, Citibank N.A., issued a credit account in the
name of Defendant bearing the account number XXXXXXXXXXX
4. Prior to the commencement of this action, Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE
OF CITIBANK, N.A., acquired Defendant’s account originated by the original creditor, see
attached Exhibit “A”, and as such is entitled to all rights originally bestowed upon the original
creditor.
5. Although demands have been made by Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF
CITIBANK, N.A., upon Defendant for payment, Defendant has failed or refused to pay the
amount due and owing on the account.
6. Plaintiff and its predecessors have duly performed all promises and conditions precedent as
required.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/22/2020 01:03:34 PM.****COUNT I- ACCOUNT STATED
Plaintiff readopts and re-alleges allegations one (1) through seven (7) above and further states as
follows:
7.
Before the institution of this action, Plaintiff's predecessor in interest and the Defendant,
HADI M BADREDDINE, had business transactions between them where the parties agreed
upon a resulting balance. Plaintiff is an assignee and as such obtains all rights of the original
creditor to be repaid.
There are no unresolved billing disputes made in response to receiving the account statements
and, therefore, there is a prima facie case establishing the correctness of the account balance.
See, Farley v. Chase Bank, USA, NA, 37 So. 3d 936 (Fla. 4" DCA 2010). Copies of any
available statements are attached hereto and incorporated herein as Composite Exhibit “B”.
By using and/or making payments on the subject account, the Defendant accepted the resulting
balance.
. After adjustment for any credits or payments made after charge off of the account, Defendant
owes Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., the amount of
$9,531.82.
WHEREFORE Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A.,
respectfully requests this Honorable Court enter Judgment in its favor against Defendant, HADI M
BADREDDINE, in the sum of $9,531.82 together with court costs as described herein and any other just
and further relief as this Honorable Court deems just and proper.
Respectfully submitted,
ANDREU, PALMA, LAVIN, & SOLIS, PLLC
(f Vee A. Basa Paes - FEN (01/262
887 Donald Ross Road
Juno Beach, FL 33408
Tel. (877)229-5972
Fax. (800)391-2178
Email: eservice@andreupalma.com
2002003057EXHIBIT AContract ID: CV3MUMAA021819
Document ID: CV8MUMAA022119C2
Document ID: 111419CV1MU3FMBI
BILL OF SALE AND ASSIGNMENT
THIS BILL OF SALE AND ASSIGNMENT dated November 22, 2019, is by Citibank, N.A., a
national banking association organized under the laws of the United States, located at 5800 South
Corporate Place, Sioux Falls, SD 57108 (the "Bank") to Cavalry SPV I, LLC, organized under the
laws of the State of Delaware, with its headquarters/principal place of business at 500 Summit
Lake Drive, Suite 400, Valhalla, NY 10595 ("Buyer").
For value received and subject to the terms and conditions of the Master Purchase and Sale
Agreement dated February 18, 2019 and Addendum No. 2 dated February 21, 2019, between
Buyer and the Bank (the "Agreement"), the Bank does hereby transfer, sell, assign, convey, grant,
bargain, set over and deliver to Buyer, and to Buyer's successors and assigns, the Accounts
described in Exhibit 1 to the Addendum and the final electronic file,
Citibank, N.A.
By:
(Siggature)
Name: ____ Gary Goldberg
Title: ___Authorized Party __
Cavalry 021819 lExhibit 1
Contract ID: CV8MUMAA021819
Document ID: CV8MUMAA022119C2
Document ID: 111419CV1MU3FMA 1
The individual Accounts transferred are described in the final electronic file and delivered
by the Bank to Buyer, the same deemed attached hereto by this reference,
#of
Lot Sale ID Accounts Sale Balance Cut-Off Date
Brands 111419CVIMU3FM = 11/14/2019
Fresh Flow
Cavalry 021819Purchase Date: 11/22/2019
1010
Data Excerpt from Exhibit 1**
ield Name
\CCOUNT OPEN DATE 19-Jul-10
jun-
NSUMER STATE.
NSUMER SSN OR SIN*
IOR ACCOUNT NUMBER 1
*Data displayed has been redacted for consumer privacy
**The data contained in this document was extracted from the electronic records transmitted by the seller
concerning the referenced accountEXHIBIT BCiti® Dividend Card
HADI M BADREDDINE
Member Since 2010 Account number ending in: |
Billing Period: 07/20/19-08/21/19
AUGUST STATEMENT
Minimum payment due: $215.00
New balance as of 08/21/19: $9,531.82
Payment due date: 09/17/19
See the last page of this statement for important information about how to
avoid paying interest on purchases.
Late Payment Warning: !f we do not receive your minimum payment by the
date listed above, you may have to pay a late fee of up to $35 and your APRs
may be increased up to the Penalty APR of 29.99%.
Minimum Payment Warning:/f you make only the minimum payment each
period, you will pay more in interest and it will take you longer to pay off your
balance. For example:
If you make no additional
charges using this card
and each month you pay...
You will pay off the And you will end up
balance shown on this paving an estimated
statement in about... ‘otal of...
Only the minimum payment | 4 year(s) $10,887
$1,052
(Savings=-$165)
$307 3 year(s)
For information about credit counseling services, call 1-877-337-8188.
Pay your bill from virtually anywhere
with the Citi Mobile App and Cit? Online
To download:
Text 'Appt5' to MyCitl (692484)
or go to your device's app store.
Or visit www.citicards.com
000000 PW 44.A0
HADI M BADREDDINE
1600 N 15TH TER
HOLLYWOOD FL 33020-3267
www.citicards.com
Customer Service 1-866-775-0556
TTY-hearing-impaired services only 1-800-325-2865
BOX 6062 SIOUX FALLS, SD 57117
Your account is past due $848.62 and
overlimit $131.82. You're in a payment
program; please pay at least the minimum
payment due or the amount listed in the
terms and agreement letter sent to you at
time of enrollment.
Account Summary
Previous balance $9,446.01
Payments -$0.00
Credits -$0.00
Purchases +$0.00
Cash advances +$0,00
Fees +$0.00
Interest +$84.91
New balance $9,531.82
Credit Limit
Revolving Credit limit $9,400
Includes $2,300 cash advance limit
Minimum payment due $215.00
New balance $9,531.82
Payment due date os/17/19
Amount enclosed:
Account number ending in | |
CITI CARDS
PO BOX 9001037
Louisville, KY 40290-1037www.citicards.com Customer Service 1-866-775-0556
TTY-hearing-impaired services only 1-800-325-2865
HADI M BADREDDINE
Account Summary
Trans. Post
date date Description Amount
Fees charged
Total fees charged in this billing period $0.00
Interest charged
Date Description Amount
o8/2l INTEREST CHARGED TO STANDARD ADV $1153
oi INTEREST CHARGED TOSTANDARDPURCH $73.38
Total interest charged in this billing period $64.91
2019 totals year-to-date
Total fees charged in 2019 $35.00
Total interest charged in 2019 $697.09
Interest charge calculation Days in billing cycle: 33
Your Annual Percentage Rate (APR)is the annual interest rate on your account.
Annual percentage Balance subject
Balance type Tate (APR) tointerest rate _Interest charge
PURCHASES
Standard Adv 9.90% $1,288.52 (D) $1.53
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
will not be reflected until your next staternent.
©2018 Citibank, N.A.
Citi, Citi with Arc Design are registered service marks of Citigroup Inc.
Page 2 of 2Citi® Dividend Card
HADI M BADREDDINE
Member Since 2010 Account number ending in
Billing Period:02/22/19-03/21/19
MARCH STATEMENT
Minimum payment due: $215.00
New balance as of 03/21/19: $9,577.83
Payment due date: 04/17/19
See the last page of this statement for important information about how to
avoid paying interest on purchases.
Late Payment Warning: !f we do not receive your minimum payment by the
date listed above, you may have to pay a late fee of up to $35 and your APRs
may be increased up to the Penalty APR of 29.99%.
Minimum Payment Warning:|f you make only the minimum payment each
period, you will pay more in interest and it will take you longer to pay off your
balance. For example:
If you make no additional
charges using this card
and each month you pay...
You will pay off the And you will end up
balance shown on this paving an estimated
statement in about... ‘otal of...
Only the minimum payment | 5 year(s) $11,932
$1,124
(Savings=$808)
$309 3 year(s)
For information about credit counseling services, call 1-877-337-8188.
Pay your bill from virtually anywhere
with the Citi Mobile App and Cit? Online
To download:
Text 'Appt5' to MyCitl (692484)
or go to your device's app store.
Or visit www.citicards.com
000000 PW 44.A0
HADI M BADREDDINE
1600 N 15TH TER
HOLLYWOOD FL 33020-3267
www.citicards.com
Customer Service 1-866-775-0556
TTY-hearing-impaired services only 1-800-325-2865
BOX 6062 SIOUX FALLS, SD 57117
Your account is past due $213.62 and
overlimit $177.83. You're in a payment
program; please pay at least the minimum
payment due or the amount listed in the
terms and agreement letter sent to you at
time of enrollment.
Account Summary
Previous balance $9,719.11
Payments -§280.00
Credits -$0.00
Purchases +$65.00
Cash advances +$0,00
Fees +$0.00
Interest +$73.72
New balance $9,577.83
Credit Limit
Revolving Credit limit $9,400
Includes $2,300 cash advance limit
Minimum payment due $215.00
New balance $9,577.83
Payment due date o4/17/19
Amount enclosed:
Account number ending in iil
CITI CARDS
PO BOX 9001037
Louisville, KY 40290-1037www.citicards.com Customer Service 1-866-775-0556 Page 2 of 2
TTY-hearing-impaired services only 1-800-325-2865
HADI M BADREDDINE
Account Summary
Trans. Post
date date Description Amount
Payments, Credits and Adjustments
03/16 PAYMENT THANK YOU -$215.00
Fees charged
Total fees charged in this billing period $0.00
Interest charged
Date Description Amount
03/21 INTEREST CHARGED TO PUR PR-OI/11/19.
Total interest charged in this billing period $73.72
2019 totals year-to-date
Total fees charged in 2019 $35.00
Total interest charged in 2019 $303.10
Interest charge calculation Days in billing cycle:28
Your Annual Percentage Rate (APR)is the annual interest rate on your account.
Annual percentage Balance subject
Balance type Tate (APR) to interest rate Interest charge
PURCHASES
Standard Purch
Pur Pr Omg
Adv Pr O119 9.90% $1,280.67 (D) $9.72
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
©2018 Citibank, N.A.
Citi, Citi with Arc Design are registered service marks of Citigroup Inc.
Preview
Case Number: CONO-20-019717 Division: 70 Filing # 115132407 E-Filed 10/16/2020 04:33:42 PM IN THE COUNTY COURT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A. Plaintiff, vs. HADI M BADREDDINE, Defendant. / COMES NOW the Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., by and through its undersigned counsel, and sues Defendant, HADI M BADREDDINE, and states as follows: GENERAL ALLEGATIONS 1. This is an action for damages that are within the jurisdictional limits of this court exclusive of costs. 2. Venue of this action is proper in the county named above because the Defendant is a resident of this county and/or because the Defendant executed the subject agreement in this county. 3. Upon Defendant’s request, the original creditor, Citibank N.A., issued a credit account in the name of Defendant bearing the account number XXXXXXXXXXX 4. Prior to the commencement of this action, Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., acquired Defendant’s account originated by the original creditor, see attached Exhibit “A”, and as such is entitled to all rights originally bestowed upon the original creditor. 5. Although demands have been made by Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., upon Defendant for payment, Defendant has failed or refused to pay the amount due and owing on the account. 6. Plaintiff and its predecessors have duly performed all promises and conditions precedent as required. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/22/2020 01:03:34 PM.****COUNT I- ACCOUNT STATED Plaintiff readopts and re-alleges allegations one (1) through seven (7) above and further states as follows: 7. Before the institution of this action, Plaintiff's predecessor in interest and the Defendant, HADI M BADREDDINE, had business transactions between them where the parties agreed upon a resulting balance. Plaintiff is an assignee and as such obtains all rights of the original creditor to be repaid. There are no unresolved billing disputes made in response to receiving the account statements and, therefore, there is a prima facie case establishing the correctness of the account balance. See, Farley v. Chase Bank, USA, NA, 37 So. 3d 936 (Fla. 4" DCA 2010). Copies of any available statements are attached hereto and incorporated herein as Composite Exhibit “B”. By using and/or making payments on the subject account, the Defendant accepted the resulting balance. . After adjustment for any credits or payments made after charge off of the account, Defendant owes Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., the amount of $9,531.82. WHEREFORE Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., respectfully requests this Honorable Court enter Judgment in its favor against Defendant, HADI M BADREDDINE, in the sum of $9,531.82 together with court costs as described herein and any other just and further relief as this Honorable Court deems just and proper. Respectfully submitted, ANDREU, PALMA, LAVIN, & SOLIS, PLLC (f Vee A. Basa Paes - FEN (01/262 887 Donald Ross Road Juno Beach, FL 33408 Tel. (877)229-5972 Fax. (800)391-2178 Email: eservice@andreupalma.com 2002003057EXHIBIT AContract ID: CV3MUMAA021819 Document ID: CV8MUMAA022119C2 Document ID: 111419CV1MU3FMBI BILL OF SALE AND ASSIGNMENT THIS BILL OF SALE AND ASSIGNMENT dated November 22, 2019, is by Citibank, N.A., a national banking association organized under the laws of the United States, located at 5800 South Corporate Place, Sioux Falls, SD 57108 (the "Bank") to Cavalry SPV I, LLC, organized under the laws of the State of Delaware, with its headquarters/principal place of business at 500 Summit Lake Drive, Suite 400, Valhalla, NY 10595 ("Buyer"). For value received and subject to the terms and conditions of the Master Purchase and Sale Agreement dated February 18, 2019 and Addendum No. 2 dated February 21, 2019, between Buyer and the Bank (the "Agreement"), the Bank does hereby transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to Buyer's successors and assigns, the Accounts described in Exhibit 1 to the Addendum and the final electronic file, Citibank, N.A. By: (Siggature) Name: ____ Gary Goldberg Title: ___Authorized Party __ Cavalry 021819 lExhibit 1 Contract ID: CV8MUMAA021819 Document ID: CV8MUMAA022119C2 Document ID: 111419CV1MU3FMA 1 The individual Accounts transferred are described in the final electronic file and delivered by the Bank to Buyer, the same deemed attached hereto by this reference, #of Lot Sale ID Accounts Sale Balance Cut-Off Date Brands 111419CVIMU3FM = 11/14/2019 Fresh Flow Cavalry 021819Purchase Date: 11/22/2019 1010 Data Excerpt from Exhibit 1** ield Name \CCOUNT OPEN DATE 19-Jul-10 jun- NSUMER STATE. NSUMER SSN OR SIN* IOR ACCOUNT NUMBER 1 *Data displayed has been redacted for consumer privacy **The data contained in this document was extracted from the electronic records transmitted by the seller concerning the referenced accountEXHIBIT BCiti® Dividend Card HADI M BADREDDINE Member Since 2010 Account number ending in: | Billing Period: 07/20/19-08/21/19 AUGUST STATEMENT Minimum payment due: $215.00 New balance as of 08/21/19: $9,531.82 Payment due date: 09/17/19 See the last page of this statement for important information about how to avoid paying interest on purchases. Late Payment Warning: !f we do not receive your minimum payment by the date listed above, you may have to pay a late fee of up to $35 and your APRs may be increased up to the Penalty APR of 29.99%. Minimum Payment Warning:/f you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: If you make no additional charges using this card and each month you pay... You will pay off the And you will end up balance shown on this paving an estimated statement in about... ‘otal of... Only the minimum payment | 4 year(s) $10,887 $1,052 (Savings=-$165) $307 3 year(s) For information about credit counseling services, call 1-877-337-8188. Pay your bill from virtually anywhere with the Citi Mobile App and Cit? Online To download: Text 'Appt5' to MyCitl (692484) or go to your device's app store. Or visit www.citicards.com 000000 PW 44.A0 HADI M BADREDDINE 1600 N 15TH TER HOLLYWOOD FL 33020-3267 www.citicards.com Customer Service 1-866-775-0556 TTY-hearing-impaired services only 1-800-325-2865 BOX 6062 SIOUX FALLS, SD 57117 Your account is past due $848.62 and overlimit $131.82. You're in a payment program; please pay at least the minimum payment due or the amount listed in the terms and agreement letter sent to you at time of enrollment. Account Summary Previous balance $9,446.01 Payments -$0.00 Credits -$0.00 Purchases +$0.00 Cash advances +$0,00 Fees +$0.00 Interest +$84.91 New balance $9,531.82 Credit Limit Revolving Credit limit $9,400 Includes $2,300 cash advance limit Minimum payment due $215.00 New balance $9,531.82 Payment due date os/17/19 Amount enclosed: Account number ending in | | CITI CARDS PO BOX 9001037 Louisville, KY 40290-1037www.citicards.com Customer Service 1-866-775-0556 TTY-hearing-impaired services only 1-800-325-2865 HADI M BADREDDINE Account Summary Trans. Post date date Description Amount Fees charged Total fees charged in this billing period $0.00 Interest charged Date Description Amount o8/2l INTEREST CHARGED TO STANDARD ADV $1153 oi INTEREST CHARGED TOSTANDARDPURCH $73.38 Total interest charged in this billing period $64.91 2019 totals year-to-date Total fees charged in 2019 $35.00 Total interest charged in 2019 $697.09 Interest charge calculation Days in billing cycle: 33 Your Annual Percentage Rate (APR)is the annual interest rate on your account. Annual percentage Balance subject Balance type Tate (APR) tointerest rate _Interest charge PURCHASES Standard Adv 9.90% $1,288.52 (D) $1.53 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 will not be reflected until your next staternent. ©2018 Citibank, N.A. Citi, Citi with Arc Design are registered service marks of Citigroup Inc. Page 2 of 2Citi® Dividend Card HADI M BADREDDINE Member Since 2010 Account number ending in Billing Period:02/22/19-03/21/19 MARCH STATEMENT Minimum payment due: $215.00 New balance as of 03/21/19: $9,577.83 Payment due date: 04/17/19 See the last page of this statement for important information about how to avoid paying interest on purchases. Late Payment Warning: !f we do not receive your minimum payment by the date listed above, you may have to pay a late fee of up to $35 and your APRs may be increased up to the Penalty APR of 29.99%. Minimum Payment Warning:|f you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: If you make no additional charges using this card and each month you pay... You will pay off the And you will end up balance shown on this paving an estimated statement in about... ‘otal of... Only the minimum payment | 5 year(s) $11,932 $1,124 (Savings=$808) $309 3 year(s) For information about credit counseling services, call 1-877-337-8188. Pay your bill from virtually anywhere with the Citi Mobile App and Cit? Online To download: Text 'Appt5' to MyCitl (692484) or go to your device's app store. Or visit www.citicards.com 000000 PW 44.A0 HADI M BADREDDINE 1600 N 15TH TER HOLLYWOOD FL 33020-3267 www.citicards.com Customer Service 1-866-775-0556 TTY-hearing-impaired services only 1-800-325-2865 BOX 6062 SIOUX FALLS, SD 57117 Your account is past due $213.62 and overlimit $177.83. You're in a payment program; please pay at least the minimum payment due or the amount listed in the terms and agreement letter sent to you at time of enrollment. Account Summary Previous balance $9,719.11 Payments -§280.00 Credits -$0.00 Purchases +$65.00 Cash advances +$0,00 Fees +$0.00 Interest +$73.72 New balance $9,577.83 Credit Limit Revolving Credit limit $9,400 Includes $2,300 cash advance limit Minimum payment due $215.00 New balance $9,577.83 Payment due date o4/17/19 Amount enclosed: Account number ending in iil CITI CARDS PO BOX 9001037 Louisville, KY 40290-1037www.citicards.com Customer Service 1-866-775-0556 Page 2 of 2 TTY-hearing-impaired services only 1-800-325-2865 HADI M BADREDDINE Account Summary Trans. Post date date Description Amount Payments, Credits and Adjustments 03/16 PAYMENT THANK YOU -$215.00 Fees charged Total fees charged in this billing period $0.00 Interest charged Date Description Amount 03/21 INTEREST CHARGED TO PUR PR-OI/11/19. Total interest charged in this billing period $73.72 2019 totals year-to-date Total fees charged in 2019 $35.00 Total interest charged in 2019 $303.10 Interest charge calculation Days in billing cycle:28 Your Annual Percentage Rate (APR)is the annual interest rate on your account. Annual percentage Balance subject Balance type Tate (APR) to interest rate Interest charge PURCHASES Standard Purch Pur Pr Omg Adv Pr O119 9.90% $1,280.67 (D) $9.72 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 ©2018 Citibank, N.A. Citi, Citi with Arc Design are registered service marks of Citigroup Inc.