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Received a dunning letter from ARS National Services, Inc., PO Box 463023, Escondido, CA 92046-3023 It looks a LOT like this letter: http://www.creditinfocenter.com/community/topic/286881-should-i-settle-please-help/ You can see thier site at arsnational dot com I am trying to decide if I should settle or not. I don't have much time left to take them up on their 50 cents on the dollar offer. May 20th is the deadline for them to receive payment. For the first step, I am thinking of sending them a DV letter. Thier first letter to me is dated April 30, 2013 and offers the 50% deal if I pay them by May 20. Yesturday (May 11) I received ANOTHER letter from ARS. This letter is dated May 8, 2013 and says they are authorized to accept the same 50% "in full settlement of the above referenced acount, provided your payment reaches this office by 05/13/2013. Well this is pretty stupid. Today is sunday, and May 13 is Monday. I don't know how they thought I was going to pull that off, especially since I got the letter yesturday, not to mention the fact that this letter contradicts the April 30 letter (which had a 'due' date of May 20). Looked up my credit report. It shows the Citibank charge off and some amout past due (not the full amount). Does not say it was sold or transferred, but it may be too early. The most recently inquiry by Citibank was in May 2013, so this just happened, as I posted this May 12. The confusing thing is that the sentence about making payments payable to says: CITIBANK PO Bbox 469100 Escondido, CA 92046-9100 Because this address is only a few PO boxes away from ARS's, it leads me to think ARS is cashing the checks even if they are made out to Citibank. I searched this forum, but did not find anything really concrete. http://www.creditinfocenter.com/community/topic/315454-citibankars-national/ I also found this thread: http://www.creditinfocenter.com/community/topic/304567-settlement-letter-from-chase-telling-me-to-contact-ars-national-services-inc/ But I did not receive a letter from Citibank as the person in the above thread did from Chase. I did just receive another statement from Citibank for this account. Its just another statement showing even more interest accrued. Does anyone know if ARS National Services, Inc does collections on behalf of Citibank (assigned debt) or do they purchase the debt (junk debt buyer or JDB) ? Does Citibank sue for debt in Nevada?

So about 8 months ago I was served by Citi or the company representing them ( The Moore law Group) for a debt I owed the credit card company in 2018. Anyways since I was nervous and wasn’t too familiar with what to do next, i didn’t want to continue being sued so I contacted The Moore law group directly and agreed to make payments on the full amount owed. I didn’t know I was able to negotiate. The question that I keep having is what happens when I finish paying off the debt? Will it show up in my credit report as paid off? I have asked multiple times and they tell me they don’t report to the credit bureaus and they give me numbers to contact CITI bank but the numbers I call always leads me back to their department. So I’m worried if my payments are even going towards my debt. Does any one have any helpful advice on what I should do.? Thank you in advance.

Hi Everybody, I am being sued by Cavalry SPV I, LLC for a Citibank credit card account I defaulted on while I was having a very rough few years (depression, divorce, joblessness, underemployment, homelessness, loss of family member, etc.). Things have turned around since - credit score recovering and thankfully, never had to file bankruptcy. I believe in paying back my debts but Citibank got too greedy and lost me. Had their terms not have kept changing, they'd probably still be reaping the minimum payments off me (that is, of course their whole purpose as an institution?). I had gotten the card while in college to use for emergencies and to build credit. I used the card for about 9 years, usually paying it off entirely but occasionally racking up a big debt following a vacation, for instance, or when I had to buy a new computer, buy a suit for a wedding, etc. I should have known better than to just make the minimum payments on it as the debt never got any smaller. They got greedy and hiked the interest rate from its initial 11.99% or 14.99% to 29.99% suddenly, which was a shock as I had never been late on a payment and was always utilizing below 50% of my limit. I called to see if they could lower it but their response was "that's just how it is - but we can reduce it to 27.99% for a month since you're a valued customer etc". This happened about 3 times. My wife and I separated and I moved back to California where I changed careers and started working freelance resulting in unreliable income and sleeping on couches. My income became too scant to make those minimum payments. After 9-ish years of always paying on time, I defaulted one month. I called Citibank and asked if I could postpone the $250 min payment for a month due to financial difficulty and they simply said no. An overdue paycheck finally landed and I was ready to make that minimum payment but when I logged in to do so, the minimum payment had now jumped to $600 (late fee and previous minimum payment). I defaulted another month and again when I got paid and was keen to make a payment the new minimum had jumped again to a figure that was even further out-of-reach. I called Citibank to see about options I had - whether I needed to close the account or create a repayment plan but they wanted a huge chunk right upfront to even initiated something, plus a commitment to pay another large chunk the next month. I was effectively buried. And meanwhile they kept adding late fees and accruing interest. The amount owed ballooned to a figure nearly double what I had ever spent on the card in the first place. Had I been smarter, maybe I would have tried to get a loan with lower interest to pay off the account or something but the priority of this Citibank thing began to be lower as I started facing some other real problems. It's all been a very valuable lesson on interest rates and credit cards and it's unfortunate I wasn't able to keep paying it before they sent it to collections. Cue the sad violins. I've been reading tons of posts and am hoping to beat this. Here's my answers to the standard questions - I hope to get all my questions answered as well as keep you all posted on how I do... 1. Who is the named plaintiff in the suit? Cavalry SPV I, LLC, as Assignee of Citibank, N.A. 2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.) Mandarich Law Group, LLP. 3. How much are you being sued for? ~$8,500. 4. Who is the original creditor? (if not the Plaintiff) Citibank. 5. How do you know you are being sued? (You were served, right?) Served. 6. How were you served? (Mail, In person, Notice on door) In person. 7. Was the service legal as required by your state? Yes. 8. What was your correspondence (if any) with the people suing you before you think you were being sued? None. 9. What state and county do you live in? Los Angeles, CA. 10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations) 3 years, 4 months ago. 11. When did you open the account (looking to establish what card agreement may be applicable)? 2006. 12. What is the SOL on the debt? To find out: 4 years. 13. What is the status of your case? Suit served? Motions filed? "Pending" 14. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) No. 15. Did you request debt validation before the suit was filed? Note: if you haven't sent a debt validation request before being sued, it likely won't help create FDCPA violations, but disputing after being sued could be useful to show the court that you dispute the debt ('account stated' vs. 'breach of contract'). No. 16. How long do you have to respond to the suit? (This should be in your paperwork). If you don't respond to the lawsuit notice you will lose automatically. In 99% of the cases, they will require you to answer the summons, and each point they are claiming. We need to know what the "charges" are. Please post what they are claiming. Did you receive an interrogatory (questionnaire) regarding the lawsuit? 30 days to respond. Did not receive an interrogatory. Here's what they are claiming: Cavalry is the owner of the debt I owed to Citibank and I have to pay them. 1. The damages and money in the sum of [$8,500]; 2. Cost of suit incurred; 3. Other such relief as the Court deems just and proper; 4. Plaintiff remits all damages in excess of the jurisdictional amount of this Court. 17. What evidence did they send with the summons? An affidavit? Statements from the OC? Contract? List anything else they attached as exhibits. Just statements. Just statements from the OC. Exhibit A: Account Stated (a statement from when I first defaulted); Exhibit B: Open Book Account (a statement from a few months later) That's it. 18. How did you find out about this site? Googled "Sued by Cavalry SPV" After reading a lot of threads, I'm planning on doing a General Denial and asking for BOP. Just wondering, anybody else that is dealing with this (or has before) what did you put on your General Denial form?

1. Who is the named plaintiff in the suit? Portfolio Recovery Associates LLC 2. What is the name of the law firm handling the suit? Weber & Olcese P.L.C. 3. How much are you being sued for? ~$3,900 + Court Costs 4. Who is the original creditor? (if not the Plaintiff) Home Depot (by Citibank) 5. How do you know you are being sued? (You were served, right?) Served 6. How were you served? (Mail, In person, Notice on door) In person 7. Was the service legal as required by your state? Yes 8. What was your correspondence (if any) with the people suing you before you think you were being sued? Received a letter prior to being served and I sent in a DV (that stated that I dispute this debt) 9. What state and county do you live in? Georgia, Forsyth County 10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations) 10/15 11. When did you open the account (looking to establish what card agreement may be applicable)? ~12/2004 12. What is the SOL on the debt? Not sure? 13. What is the status of your case? Suit served? Motions filed? Served 5/2019, Answered 6/2019 (denied w/ arbitration as affirmative defense), Court 7/2019 (prepared MTC Arbitration) 14. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) Yes, to the lawfirm only when I initially received a letter. 15. Did you request debt validation before the suit was filed? Note: if you haven't sent a debt validation request before being sued, it likely won't help create FDCPA violations, but disputing after being sued could be useful to show the court that you dispute the debt ('account stated' vs. 'breach of contract'). Yes. 17. What evidence did they send with the summons? An affidavit? Statements from the OC? Contract? List anything else they attached as exhibits. They sent copies of statements from the OC from 2015 and 2016. A copy of a bill of sale to PRA. Well it finally happened, the judge denied my MTC arbitration because of the small claims verbiage below: He said that the wording was not ambiguous, and any statement otherwise or whether there was a clause in it at all did not matter. I tried to describe the other SCOTUS cases, and he would not hear it and said that this matter was brought to small claims, so now it is no longer subject to arbitration. He shut me down at every argument I had about the arbitration clause, and asked if I wanted to mediate w/ the attorney. I asked for a continuance, and the plaintiff said I see no reason for a continuance and the judge agreed so he denied the continuance. I did create an AAA case AFTER I was served, so when I told him that I even had an arbitration case started, he said it did not matter. At this point I was lost and did not know what to do. So I went to the attorney and said that I could write a check for $1000 right now the settle the case, and he said his client refused. I told him that’s really all I had, so then the attorney requested a continuance and it was granted for him. Should I have just gone to trial and let the judge find for the plaintiff after denying my MTC for arbitration? I was scared to do that because what I’m ultimately trying to do is avoid a judgement on my record. I’d rather try to settle than have a judgement. I was thinking maybe I could appeal, but I’ve never gone through that process, and wonder what would happened if my appeal was denied or if I lost there too? Any advice? I go back to court next month. I’ve attached the CCA both current, and the one while my card was active and both do contain that “small claims” verbiage. arbitration-2016.pdf arbitration-current.pdf

I was just served last Friday Night. I have been following the threads on here an the advice so far has been unbelievable. I have a couple of questions that I wanted to double check. The first is I didn't see any thing that was labeled VERIFIED, the only thing that was attached was a statement from August 2013 showing that my last payment was made July 2013. I am assuming this means it is unverified? I just wanted to make sure that my first step is filing a POS - 050 or genial denial http://www.courts.ca.gov/documents/pld050.pdf. Also, a notice of case assignment was attached. Does that mean anything separately? It's a CRC 3.740 case. What I am confused about is it says a defendant must general appear within 30 days of service of the complaint. My next question is do I have to file a POS - 030 as well? I am a bit confused as to if it is necessary or not. Also, does the BOP have to come from someone else or can it be mailed from me? I am bit confused on that as well. My last question is part of the documents filed was copies of a suit against someone else in Fresno with their name on it, not me. My cases paperwork filed in San Diego is attached as well, but I am confused as to why the paperwork from a case against a lady was attached as well? I apologize if these are simple questions. I honestly had no idea what to do until I found this site and all the responses & realized that I can fight this & win. I have answered the questions below as well. Thank you for you help in advance! 1. Who is the named plaintiff in the suit? Calvary SPV I, LLC 2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.) Lawyers out of Fullerton, Ca 3. How much are you being sued for? $4,800 4. Who is the original creditor? (if not the Plaintiff) Citibank 5. How do you know you are being sued? (You were served, right?) Yes 6. How were you served? (Mail, In person, Notice on door) In person 7. Was the service legal as required by your state? Yes 8. What was your correspondence (if any) with the people suing you before you think you were being sued? A letter saying that they now had the debt & to verify in 30 days, which I didn't 9. What state and county do you live in? San Diego, California 10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations) July 2013 11. What is the SOL on the debt? 4 years 12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or looking it up online (many states have this information posted - when you find the online court site, search by case number or your name). Suit served. I have 30 days to answer 13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) No 14. Did you request debt validation before the suit was filed? Note: if you haven't sent a debt validation request, don't bother doing this now - it's too late. No. 15. How long do you have to respond to the suit? (This should be in your paperwork). If you don't respond to the lawsuit notice you will lose automatically. In 99% of the cases, they will require you to answer the summons, and each point they are claiming. We need to know what the "charges" are. Please post what they are claiming. Did you receive an interrogatory (questionnaire) regarding the lawsuit? 30 days to respond; Does 1 to 10 Inclusive ( I think this is what is meant) 16. What evidence did they send with the summons? An affidavit? Statements from the OC? Contract? List anything else they attached as exhibits. An old Citibank statement from 08/2013

Hi All, I went into work and got a notice from my payroll that my wages are being garnished via Unifund with the help of Kenosian and Miele. I did search the forums and read some threads on Unifund/KenosianMiele but nothing specific to wage garnishment. The debt is from 2006/07, court case is from 2013, I was never personally served but I think my parents received it through FedEx--at that time I was away at college. In the past few months my phone was blowing up with robot debt collectors, all claiming to be from a "firm" regarding an "urgent" matter. I answered one of these calls and when I asked for specifics like account # or last time card was charged they couldn't provide any information other than my address; so I thought the calls were bogus. I didnt think anything of it since it was clear they didnt have much information but when reviewing the EWO, the debt was exactly what the collector claimed over the phone, and now my wages are being garnished next month. I wanted to see if there is anything I could do? I've read other posts talking about filing a motion to vacate default judgment or just calling up Unifund to work something out? I've included the court case details that i obtained from the San Bernardino county website. I have a copy of the suit but not sure which parts to post or if i'm able to do anything about it. Any advice is greatly appreciated! BTW, The closest forum I found to my issue was below, but let me know if there is a better thread:

Plaintiff is Citibank/Sears. I've been searching the forums and I know this has been answered but I need to file a motion for continuance tomorrow (today since it's 2:00 am). Initial hearing was 8/15, trial set for 9/5. My at-risk daughter was moved to a new facility on 8/15 so only my husband went to court. On 8/22 she ran and between social services, police, FBI trafficking task force and NCMEC, etc. I haven't done anything else - I spent 5 hours with the FBI today alone. I have to contact the plaintiff attorney and then I have to file the motion, correct? I believe in Jefferson County it's the generic form JDF 76 Motion to _____ and submit it with a blank JDF 77 Order. I don't know what to say to the attorney and put in the motion. How do I word the motion if attorney agrees/if they don't agree? If they don't grant the continuance then I'll figure out what to do next, but doing something is easier than undoing it. I apologize, this sounds so whiny... it's hard to change from one hellacious event to another and I just need some wording... and sleep. : / I've fought social services in court, obtained guardianship of my grandson when my daughter died, defended my handicapped sister in a section 8 eviction (with POA). I can do this.

Hi. Please be gentle. I have been reading quite a few posts and now think I know enough information to be a little bit dangerous... My wife was served a summons almost 30 days ago. I am about to file the official responses with the superior court system, but I just read about arbitration and JAMS. The original creditor was Citibank. The amount my wife is being sued for is $8,235.57. I don't want to make any mistakes when doing this, so I am asking for any and all assistance here. Her official responses are a denial of all allegations (attorney friend via the phone--she has no real experience with collection company law, but she knew enough to assist with the answers and suggest I find an attorney out here). I have been reading about JAMS and arbitration, but I can't really figure out what exactly I need to do. My wife's account Q/A is below: 1. Who is the named plaintiff in the suit? Cavalry SPV I, LLC2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.) Quall Cardot, LLP, in Fresno, CA3. How much are you being sued for? $8,235.574. Who is the original creditor? (if not the Plaintiff) Citibank5. How do you know you are being sued? (You were served, right?) I was served, and the summons was also mailed.6. How were you served? (Mail, In person, Notice on door) In person and via the mail7. Was the service legal as required by your state? As far as I can tell, yes.Process Service Requirements by State - Summons Complaint8. What was your correspondence (if any) with the people suing you before you think you were being sued? They called and left a message on her cellphone (paraphrased) ".....if you can arrange a time for us to serve you, we won't have to go to your place of employment and tell your boss about it...."9. What state and county do you live in? Orange County, CA10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations) 09/10/201311. What is the SOL on the debt? 4 years12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or looking it up online (many states have this information posted - when you find the online court site, search by case number or your name). Suit Served--not in default yet. I need to file the response today to stay within the 30 day time period.13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) No14. Did you request debt validation before the suit was filed? Note: if you haven't sent a debt validation request, don't bother doing this now - it's too late. Have not done so yet.15. How long do you have to respond to the suit? (This should be in your paperwork). If you don't respond to the lawsuit notice you will lose automatically. In 99% of the cases, they will require you to answer the summons, and each point they are claiming. We need to know what the "charges" are. Please post what they are claiming. Did you receive an interrogatory (questionnaire) regarding the lawsuit? 30 days There are 24 allegations--I can list them but it will take a quite a bit of time and space. She is being sued in her Maiden Name, not that it changes anything. I was able to attach a redacted copy of the official summons.16. What evidence did they send with the summons? An affidavit? Statements from the OC? Contract? List anything else they attached as exhibits. 2 exhibits--one is the credit card statement showing the last payment and balance, and the 2nd is a receipt showing that they purchased a bulk of debt from Citibank--nothing specifically listing my wife's account. Lyn Summons, redacted.pdf

So I have a small claims suit against me in a few months with a JDB. Citibank is the OC and the debt is within SOL. The JDB is Calvary and I'm unsure if their validation letter is legitimate. Second, I'm unsure if arbitration is allowed in small claims for the user agreement. I only have mobile and it will not let me attach the user agreement. Any help is appreciated. I'd like to settle the debt favorably with what I have available which is about 60% of the total cost alleged. IS arbitration recommended or should I attempt negotiating with JDB?

Unfortunately I am back in small claims. After receiving a notice in 2015 from the same law firm regarding a Citibank card, I send a DV (within 30 days). I never heard back. This account went through several players and not one would budge on settlement payment/plan. So I forgot about it. In January 2017 I suddenly received a package in the mail. Please see the attached below. I am thinking I may have yet another violation of the FDCPA - the DV cover letter states "Plaintiff Citibank" and Defendant "Me". Nothing was filed until March 09 2017. The amount on the complaint is $4,500 and the filing fee. I have to answer by tomorrow and am going to do this once I post here. I want to to a MTC again but, how does the Citibank SC exclusion work? I read that "Usually the language in a credit card agreement that has the small claims exception is ambiguous, and as many courts have stated, any ambiguity in a contract is construed against the maker. " The paragraph after the small claims language is thus (2017 agreement): Arbitration limits• Individual Claims filed in a small claims court are not subject to arbitration, as long as the matter stays in small claims court. • We won’t initiate arbitration to collect a debt from you unless you choose to arbitrate or assert a Claim against us. If you assert a Claim against us, we can choose to arbitrate, including actions to collect a debt from you. You may arbitrate on an individual basis Claims brought against you, including Claims to collect a debt. From a 2011 CA - What about Claims filed in Small Claims Court? Claims filed in a small claims court are not subject to arbitration, so long as the matter remains in such court and advances only an individual (non-class, non-representative) Claim. What about debt collections? We and anyone to whom we assign your debt will not initiate an arbitration proceeding to collect a debt from you unless you assert a Claim against us or our assignee. We and any assignee may seek arbitration on an individual basis of any Claim asserted by you, whether in arbitration or any proceeding, including in a proceeding to collect a debt. You may seek arbitration on an individual basis of any Claim asserted against you, including in a proceeding to collect a debt. Thank YOU!!!!! The "DV" package contained the following: 1. Bill of Sale - on a blank 8 1/2x11 sheet of paper - no logos, no notary, no seal, no nothing! and 3 statements( 2 copies of each) 3 affidavits (see below as I typed them out) and a computer print out with last 4 of SSN, last payment date, charge off date and name/address/DOB 2. Affidavit from Citibank “Document Control Officer” Susie DeSha, stating my account was sold to Atlantic – dated , 2015 3. Affidavit of Angela Campbell – Atlantic Credit Atty. Relationship mgr. , 2016 – State of NH “1. I am employed as an Attorney Relationship Manager by Atlantic Credit & Finance, Inc (“ACF”) servicer of this account on behalf of ATLANTIC CREDIT & FINANCE SPECIAL FINANCE UNIT, LLC (“Plaintiff”). I am a competent person over the age of eighteen years of age, and I am authorized to make this affidavit on Plaintiff’s behalf. In this affidavit, I make my statements about this account based upon my personal review and knowledge of those account records maintained by ACF on Plaintiff’s behalf and that are pertinent to those statements (“Pertinent Records”). 2. Plaintiff is current owner of, and/or successor to, the obligation sued upon, and was assigned all the rights, title and interest to defendant's CITIBANK NA account xxxxxxxxxxxx- (herein "the account"). 3. As a result of Plaintiff’s purchase of the account, ACF acquired certain account records from the seller and incorporated those records into ACF’s own permanent business records. Those acquired and incorporated records are kept by ACF in the regular course of business on behalf Plaintiff. 4. The acquired and incorporated records are treated as trustworthy and accurate, and are relied upon by Plaintiff and ACF in purchasing and servicing this account because, the original creditor was required to keep careful records of the account at issue in this case as required by law and/or suffer business loss. 5. I have access to and have reviewed the Pertinent Records (including pertinent electronic records) concerning the account maintained by ACF. The electronic records reviewed consist of data acquired from the seller when Plaintiff purchased the account, together with records generated by ACF in connection with servicing the account since the day the account was purchased by Plaintiff. In addition, I reviewed the documents that are attached to this affidavit. 6. As set forth in the records attached hereto, on or about X/X/2015, the account was sold from Citibank, N.A. to Atlantic Credit & Finance Special Finance Unit, LLC. If applicable, the account was then sold to the following debt buyers in order of occurrence on or about: 7. Attached hereto are the following records regarding the account: Bill of Sale(s) and Assignment and/or Affidavit(s)of Sale for the above referenced sales) of the account. Seller data sheet reflecting the individual account data extracted and printed from electronic records provided to the seller to ACF pursuant to the Bill of Sale/Assignment in connection with the sae=le of the account to Plaintiff. 8. The documents attached hereto are true and correct copies of the originals, being a reproduction of the records on file on behalf of Plaintiff based upon my review, except to the extent that confidential and privileged information anf/or personal identifying information is omitted or redacted as required by local rules, and applicable state and federal law. 4. Affidavit of Angela Campbell – Atlantic Credit Atty. Relationship mgr. , 2016 “1. I am employed as an Attorney Relationship Manager by Atlantic Credit & Finance, Inc and have access to pertinent records of this account maintained on behalf of Plaintiff by its agents. I am a competent person over the age of eighteen years of age, and make the statements herein based upon personal knowledge of those account records maintained on plaintiff's behalf. Plaintiff is current owner of, and/or successor to, the obligation sued upon, and was assigned all the rights, title and interest to defendant's CITIBANK NA account xxxxxxxxxxxx- (herein "the account"). In connection with plaintiff's acquisition of the account, relevant account records and information have also been by the original creditor or its agents/assigns. I have access to and have reviewed the records pertaining to the account and am authorized to make this affidavit on the plaintiff's behalf. 2. I am familiar with the manner and method by which the business records I have reviewed are created and maintained on behalf of the plaintiff pertaining to this account. The records are kept in the regular course of business. It was in the regular course of business for a person with knowledge of the act or event recorded to make the record or data compilation, or for a person with knowledge to transmit information thereof to be included in such record. In the regular course of business, the record or compilation was made at or near the time of the act or event. 3. The account shows that the defendant(s) owe(s) a balance of $XXX.xx, based upon my review of business records kept on behalf of Plaintiff, Defendant(s) opened a CITIBANK, N.A, account, and the account was charged off on X/X/2015 4. Those business records that I have reviewed do not indicate that the defendant is a minor or incapacitated person. 5. Attached hereto is a true and correct copy of a statement of account, bill(s) of sale and/or billing statement(s) relating to this account, as reflected in plaintiff's business records and/or records provided to plaintiff by original creditor (or its agents/assigns) in connection with the plaintiff's purchase and/or assignment of the account. 6. The documents attached hereto are true and correct copies of the originals, except to the extent that confidential and privileged information is omitted or redacted and personal identifying information is omitted or redacted as required by local rules, and applicable state and federal law.

Missouri resident. OC were 3 credit cards. I tried to work things out a few years ago but could pay nothing. They sold the debt, a few different times. Cavalry ended up with it. I am now in a better place financially, was gathering funds and trying to prep my tax return to call and make an offer. It took longer than expected. I have since received letters from the attorney for a law firm representing them. Questions: I can sum up the questions as: “What do I do?” but more specifically….. 1- Is this when they truly become litigious, or is this another bargaining tool? 2- I don’t have the funds to pay the full amount, though I could probably come up with 60%. Do I send letters of DV to buy a little time while I attempt to scrape together more? 3- Do I go to a credit counselor and let them fight and bargain with the attorney? 4 - Do I dare attempt an offer letter to the attorney? Law firm based in Kansas City, KS but licensed in MO and KS. Will provide name of firm if helpful. Letters summarized with what I understand to be pertinent information. THANKS FOR THE HELP!!! ---------------------------------------- 1st letter: Jan 23, 2017 RE: Account balance w Cavalry SPV Cavalry account No: 111111111 (not real number) Original Creditor: Citibank, NA Creditor: Cavalry SPV The above debt has been referred to our law office….we hereby demand payment of debt (~$4500) as of Jan 23. Please direct all phone calls, payments and inquiries to our office. You may call and ask for Jane Doe ext 123. Notice: This is a from a debt collector and is an attempt to collect a debt. Unless you notify this office within 30 days, etc, etc. (Please return this portion w/payment to: XYZ Law Group. Amount paid: $_________ ) ---------------------------------------- 2nd letter: Jan 26, 2017 RE: Account balance w Cavalry SPV Cavalry account No: 111111222 Original Creditor: Citibank, NA Creditor: Cavalry SPV The above debt has been referred to our law office….we hereby demand payment of debt (~$3900) as of Jan 23. Please direct all phone calls, payments and inquiries to our office. You may call and ask for Jane Doe ext 123. Notice: This is a from a debt collector and is an attempt to collect a debt. Unless you notify this office within 30 days, etc, etc. (Please return this portion w/payment to: XYZ Law Group. Amount paid: $_________ ) ---------------------------------------- 3rd letter: Feb 10, 2017 RE: Account balance w Cavalry SPV Cavalry account No: 111111333 Original Creditor: Citibank, NA Creditor: Cavalry SPV The above debt has been referred to our law office….we hereby demand payment of debt (~$2300) as of Jan 23. Please direct all phone calls, payments and inquiries to our office. You may call and ask for Jane Doe ext 123. Notice: This is a from a debt collector and is an attempt to collect a debt. Unless you notify this office within 30 days, etc, etc. (Please return this portion w/payment to: XYZ Law Group. Amount paid: $_________ )

Hello, I am currently getting sued for a debt that I now know for sure I do not owe. The gist is I answered a summons with a general denial of the debt based on lack of information (asserted no affirmative defenses) in CO's simplified procedures. I have a pre-trial conference in February. Attorney sent a disclosure statement with printout of a few online statements, (worth noting two months of statements they claimed were in the document packet were actually missing (not sure if mistake or on purpose)). I was recently able to access my old bank account to find I made several payments to Citibank after the date they claimed was my "last payment". These payments don't appear on the statements sent by the collection agency. Additionally, I discovered I may be a victim of Citibank based on the 2016 CFPB order, the situation/circumstances and time period is in line with the activity on the account. However it's difficult to prove quickly since Citibank can't even access my account due to it being in collections or tell me if I'm included in the consent order. Looks like I will be filing a consumer complaint which takes ~14 days. Even if I'm not it's very shady because the statements sent by the collections agency show an inflated amount of debt owed on the credit card and now it's obvious that account should have never been sent to collections as I was making the payments requested by Citi...an issue similarly stated in the CFPB order. Based on my conversation with CFPB it is unclear if Citibank finished locating and notifying all the victims. I am curious if I file a complaint with the Consumer Financial Protection Bureau (CFPB) will this stop the lawsuit immediately and give time to figure out what's going on? Also if I file the complaint, do I send proof of complaint along with my bank statements when I return the disclosure statement to the Attorney? Or should the complaint be filed with the debt collection agency instead of Citibank? Or complaint against both. Disclosure information isn't filed with the court, so would you recommend a motion I could file with the court before the pre-trial?

I am looking for anyone who has copies of a Bill of Sale or Assignment from Citibank with Patricia Halls signature. I have collected two (from a Cavalry and Midland case) that seem to be different signatures and I suspect robosigning. The wording on the Bill of Sale is also different. I am particularly interested in any notarized signatures from her. This person seems to be on many JDB cases and I am trying to establish if this is like the Mortgage robosigning scandal. These are usually generic forms without any personal information on them, but if there is, you can certainly redact it. I will post my findings here if I get any responses. Thanks!

I had a credit card with Citibank which climbed to a balance of $27K. Over the past 3 years I defaulted on this and a few other cards due to a downturn in my business and loss of income. The debt was purchased by a third party company and I received a collection letter from their attorney. in December of 2015. I responded with a letter of dispute and validation requested, and elected arbitration "stated in any underlying agreement". Instead I received a personally served notice of a filing of lawsuit in my local county court filed by Absolute Resolution Corp. for the full amount plus legal fees. So, can anyone enlighten me as to what options I may have, other than fighting it in court (which I cannot afford for the most part) what the possible outcome would be? Thanks

Need some help. I am 2 months away from the SOL of 4 years on this debt. I just received the letter on 8/1. the last payment made on the account is 10/14/2011. what should my first steps be in trying to push this out past the SOL?

I have received a summons on Dec 9th from Midland stating count 1 Breach of Contract and count 2 Unjust Enrichment. They attached an affidavit from their legal specialist that included a bill of sale, assignment and billing statement from Citibank, (Best Buy) I did not submit an answer instead a MTD or in alternate Compel Private Arbitration with Jams also included exhibit of contract (Citibank) attachment, on the same day (Dec 24th) I sent a letter to attorneys for litigation waiver and election to arbitrate. I also sent a letter to JAMS electing arbitration with the Return Receipt from my letter to attorney. I received an answer Jan 6th stating that the attached cardholder agreement is Not relevant to subject debt or applicable to subject debt, that it is a random document.. Also defendant has not attempted to show how alleged agreement is admissable under AZ rules of Evidence. Exhibit cannot be authenticated for admissable, without exhibit defendant has nothing to establish debt was governed by arbitration provisions. They ask the court to strike my MTD and file an answer by a date certain at the discretion of the court. My question is if I have 5 days to answer their response.. If so I believe it is by this Wednesday, Jan 13th. What can I do to make my exhibit work to compel an arbitration. Do I need to file an "answer" to this going back to their first complaint filed. I am uploading the case filings. I have followed this forum for suggestions on court proceedings but at this time I need some help on what to do next? Any suggestions are appreciated. 4- Midland Resp to MTD.pdf 3- letter to execute arbitration.pdf 1-complaint.pdf 2- MTD Midland.pdf

February 23, 2016 CONTACT: Office of Communications Tel: (202) 435-7170 CONSUMER FINANCIAL PROTECTION BUREAU ORDERS CITIBANK TO PROVIDE RELIEF TO CONSUMERS FOR ILLEGAL DEBT SALES AND COLLECTION PRACTICES Citibank Sold Credit Card Debt with Inflated Interest Rates; Debt Collectors for Citibank Altered Affidavits Washington, D.C. –The Consumer Financial Protection Bureau today took two separate actions against Citibank for illegal debt sales and debt collection practices. In the first action, the CFPB ordered Citibank to provide nearly $5 million in consumer relief and pay a $3 million penalty for selling credit card debt with inflated interest rates and for failing to forward consumer payments promptly to debt buyers. The second action is against both Citibank and two debt collection law firms it used that falsified court documents filed in debt collection cases in New Jersey state courts. The CFPB ordered Citibank and the law firms to comply with a court order that Citibank refund $11 million to consumers and forgo collecting about $34 million from nearly 7,000 consumers. "Citibank sent inaccurate information to buyers when it sold off credit card debt and it also used law firms that altered court documents," said CFPB Director Richard Cordray. "Today's action provides redress to consumers who were victimized by slipshod practices as part of our ongoing work to fight abuses in the debt collection market." Citibank, N.A., is a national bank with headquarters in New York, N.Y., that issues consumer credit cards. From 2010 to 2013, Citibank sold portfolios of charged-off credit card accounts. It typically provided debt buyers with information about the consumer and the debt, including the supposed annual percentage rate (APR). A “charged-off” account is one the bank deems unlikely to be repaid, but may sell to a debt buyer, usually for a fraction of face value. The debt buyer then can try to collect on those accounts. Illegal Debt Sales Practices Citibank broke the law when, from February 2010 until June 2013, it provided inaccurate and inflated APR information for almost 130,000 credit card accounts it sold to debt buyers. These buyers then used the exaggerated APR in debt collection attempts. Citibank also failed to promptly forward to debt buyers approximately 14,000 customer payments totaling almost $1 million. The CFPB found that Citibank violated the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act. Specifically, Citibank: Overstated the annual percentage rate in accounts sold to debt buyers: Between February 2010 and June 2013, Citibank overstated the APR for 128,809 accounts it sold to 16 different debt buyers. For some accounts, Citibank claimed the APR was 29 percent when it was actually 0 percent. Consumers paid about $4.89 million to debt buyers who used an APR inflated by more than 1 percent in collection efforts. Delayed sending consumer payments to debt buyers: From 2010 to 2013, Citibank delayed forwarding to debt buyers nearly 14,000 payments made by consumers, totaling almost $1 million. This delayed the updating of account balances and subjected consumers to collection efforts from debt buyers after they had already, in reality, paid off their account. Enforcement action Under the Dodd-Frank Act, the CFPB has the authority to take action against institutions or individuals engaged in unfair, deceptive, or abusive acts or practices. Under the CFPB’s order addressing illegal debt sales practices, Citibank must: Refund an estimated $4.89 million to roughly 2,100 consumers: Citibank must refund all payments consumers made from Feb. 1, 2010 to Nov. 14, 2013 to debt buyers that referenced an inflated APR provided by Citibank in their collection efforts where the discrepancy was more than 1 percent. Accurately document the debt it sells: Citibank must provide certain account documents when it sells debt, such as the credit agreement and recent account statements. Stop selling debt it cannot verify: Citibank cannot sell debts if it cannot provide documentation, if the consumers notified Citibank of identity theft or unauthorized use, if consumers allege in writing that they do not owe the amount claimed, or if the account is within 150 days of the end of the statute of limitations. Include certain protections in debt sales contracts: Citibank must include provisions in its debt sales contracts prohibiting the debt buyer from reselling the debt. Provide consumers with basic information about the debt: When it sells a debt, Citibank must give consumers information about the debt, such as the name of the original creditor, the credit agreement, and recent account statements. Pay civil money penalties: Citibank must pay a $3 million penalty to the CFPB’s Civil Penalty Fund. The full text of the CFPB’s consent order on debt sales is found at: http://files.consumerfinance.gov/f/201602_cfpb_consent-order-citibank-na.pdf Altered Affidavits Separately, the CFPB is taking action today against Citibank, two of its affiliates – Department Stores National Bank and CitiFinancial Servicing, LLC – and two debt collection law firms for altering affidavits filed in debt collection lawsuits. Citibank retained Faloni & Associates, LLC, of Fairfield, N.J., and Solomon & Solomon, P.C., of Albany, N.Y. to collect credit card debt on its behalf in New Jersey state courts. Citibank filed sworn statements attesting to the accuracy of the debt allegedly owed. Citibank then provided the affidavits to their attorneys to file with New Jersey courts. The two firms retained by Citibank altered the dates of the affidavits, the amount of the debt allegedly owed, or both, after the affidavits were executed. This violated the Fair Debt Collection Practices Act. In May 2011, Citibank learned that one of its law firms had altered affidavits and stopped referring new credit card accounts to it. At Citibank’s request, a New Jersey court dismissed actions pending as of Sept. 12, 2011 that Citibank identified as involving altered affidavits or incorrect information. The CFPB’s order requires Citibank to comply with the New Jersey state court order, in which Citibank had to refund $11 million collected from consumers and stop collection of an additional $34 million in debts, both of which Citibank has done. Solomon & Solomon, P.C., must pay a $65,000 penalty to the Bureau’s Civil Penalty Fund. Faloni & Associates, LLC, must pay $15,000. Consistent with the Bureau’s Responsible Business Conduct bulletin, the CFPB did not impose civil money penalties on Citibank for this violation, especially in light of its efforts to recompense harmed consumers. The full text of the CFPB’s consent order against Citibank, N.A., Department Stores National Bank, and CitiFinancial Servicing, LLC, related to the altered affidavits matters is available at: http://files.consumerfinance.gov/f/201602_cfpb_consent-order-citibank-na-department-stores-national-bank-and-citifinancial-servicing-llc.pdf The full text of the CFPB’s consent order against Faloni & Associates relating to the altered affidavits matters is available at: http://files.consumerfinance.gov/f/201602_cfpb_consent-order-faloni-and-associates-llc.pdf The full text of the CFPB’s consent order against Solomon & Solomon relating to the altered affidavits matters is available at: http://files.consumerfinance.gov/f/201602_cfpb_consent-order-solomon-and-solomon-pc.pdf

The big things that stand out to me is PRA has made little to no effort to contact me by phone or snail mail. The notice to appear has a hand written date of early February yet it was dropped off at the door (not handed to anyone) weeks later and dangerously close to appearance date. I'm not sure if the process service requirements of my state were met or what I can do since it would be my word against the server.. No one signed, no person received it, it was just left at the door yet. When researching the case the agent reported some fictitious female name as who he left it with. The sole inhabitant is disabled and unable to answer the door. Weird stuff about the accused debt is that the card was not used so the last payment date pre-dates the purchase. The only other thing that stands out to me is in the counts, PRA states CITIBANK and I the defendant agreed to the resulting balance for the account.. Which I absolutely did not. I'm assuming they can make that statement by default to non-payment or a lack of correspondence on my part at some point? In any event there has been almost no attempt by anyone to contact me regarding this alleged debt. I've been doing research on the whole thing and it's amazing how little time they gave me to prepare for this.. Looking at the case history, they've been doing all this since last year. Only now, < 3wks from the pretrial mediation date have I received my first notice of these proceedings and this case against me. I'm not sure what to bring.. Can I motion for things on the spot? Am I simply asking for more time to prepare? What can I actually do besides potentially mediate OR request a trial date be set. Anyhow, thank you to anyone who contributes any time to this matter. I've been out of work for almost five years now and taking care of two sick people for the better part of three.

Hello folks, first of let me send out a thanks boy am I glad I ran into this site so much information, knowledge, and some pretty great folks all put into one place Awesome. Now to the not so awesome thing I was served a couple weeks ago and need to make a move as my 30 days will be up in the coming days (I know I should not have waited this long but I did have to deal with some pretty hard personal issues during these past weeks). So Calvary SPV is suing me as assignee of Citibank NA here in California for under $5,000 the summons includes a photocopy of a credit card statement (does this mean verified) I know my first thing to do is respond to the summons and ask for verification but would like to see if I can get a more detailed info on how to do that correctly and ask you members does a statement show proof of verification. Thanks in advance

So, I currently have a thread for a summons I received from midland on a BOA card I had. Today I was served by midland once again for a citi bank card I had. I know it probably wouldn't matter considering midland has all my information on where I live now, however, would it have made any difference if I just didn't answer the door? 1. Who is the named plaintiff in the suit? Midlund Funding LLC 2. What is the name of the law firm handling the suit? (should be listed at the top of the complaint.) a midland law firm. 3. How much are you being sued for? $2,388 4. Who is the original creditor? (if not the Plaintiff) CitiBank 5. How do you know you are being sued? (You were served, right?) My Brother accepted papers. 6. How were you served? (Mail, In person, Notice on door) In person, to my brother, for me . 7. Was the service legal as required by your state? I'm not sure Process Service Requirements by State - Summons Complaint 8. What was your correspondence (if any) with the people suing you before you think you were being sued? None 9. What state and county do you live in? Arizona, Pima county 10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations) August 31, 2009 11. What is the SOL on the debt? To find out: 6 years 12. What is the status of your case? Suit served? Motions filed? You can find this by a) calling the court or looking it up online (many states have this information posted - when you find the online court site, search by case number or your name). I've just been served at this point and nothing else. 13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) No, we got in spot where we couldn't pay and have never heard anything from CitiBank 14. Did you request debt validation before the suit was filed? Note: if you haven't sent a debt validation request, don't bother doing this now - it's too late. No 15. How long do you have to respond to the suit? (This should be in your paperwork). If you don't respond to the lawsuit notice you will lose automatically. In 99% of the cases, they will require you to answer the summons, and each point they are claiming. We need to know what the "charges" are. Please post what they are claiming. Did you receive an interrogatory (questionnaire) regarding the lawsuit? 20 days. As for the midland boa summons, I elected arbitration with attorney, filed my answer which requested arbitration, and filed MTD/MTC. Should I do the same for the citibank. Thanks so much for all your help, this time when I was served I wasn't as nervous because I have people like you willing to help and I have learned so much already. Thanks

Hello, I am being sued by Midland Funding original creditor Citibank(Home Depot). I must answer by 5/28/15. I am very willing to fight this to the end, but the amount of evidence/account information included is slightly intimidating. I have reviewed a lot of information on here, but have not been able to find a case with as much up front documentation as I have been provided. I will post all of my documents recieved in the following post. Please give any feedback possible. Thank you for your time.

Hello all! This is my first time posting so I apologize if I am in the wrong place. I missed a payment because of a stupid mistake and would like to get a late payment remark removed from my account. I paid off the late payment immediately and was finally getting my credit score up past 700 because of eliminating some utilization. Of course timing is awful and this late payment happened right when I was doing well because of computer error and me failing to double check that I had all my payments in. Now my score is below 640. I want to ask your expert opinions on a goodwill letter I have constructed. From everything that I have heard, Citi is one of the worst places to deal with getting a late payment removed. Calling them provided me with no help in this matter but I did get a late fee waived without having to say anything. Here is my letter: --------------------------------------------------------------------------------------------------------------------- Citibank 701 E 60th Street N Sioux Falls, SD 57104-0432 Regarding: Acct # xxxx-xxxx-xxxx-xxxx Dear Sir or Madam, I am writing to you today regarding my credit card account # xxxx-xxxx-xxxx-xxxx which I have had for only a short time. I originally opened my account with Zales to purchase my fiancée’s engagement ring. I am planning on purchasing our wedding bands through this account with Zales as well. The purpose of my correspondence is to see if you would be willing to give me a second chance and make a "goodwill" adjustment on the reporting of this account to the three credit agencies. I am very happy with the service that you offer and I plan to do business in the future with your company. I have high expectations of myself and I did not start off on the right foot. I missed the first payment of my account mistakenly thinking I had submitted it only to find out later that I had not. At this point I became past due of more than 30 days and a late payment mark was sent to the crediting agencies. My credit limit was also lowered after this occurrence. I know that payment was my responsibility and I am not attempting to justify this breach of my user agreement, rather I am only trying to show that this does not reflect my actual credit worthiness. I have never been late on any other accounts in any circumstance which is reflected on my credit report. I am sincerely hoping you might review the conditions under which this non-payment occurred and consider removing the negative trade line associated with this account from my three credit reports. As soon as I became aware of the balance I contacted customer service and paid the $156.00 balance in full immediately. I sincerely apologize for this action. As insurance, I have setup automatic payments to be taken from my account in the future. I am in hope to repair my credit in order to purchase a home this year and start my family. This mark is the only thing preventing me from that. I hope that Citibank is willing to work with me on erasing this mark from my credit reports. I sincerely hope that I can repair my status with your company and I look forward to continue working with you! Best Regards, Ferin ------------------------------------------------------------------------------------------------------------- I have never done this before and I tend to apologize too much so I don't want to sound too needy. Is it too early to ask for this removal as I haven't been with them for more than a few months? I also do not have any other citi accounts as my other cards are Chase and my bank is M&T. Please let me know if anyone here has any input! Tough criticism is greatly appreciated.

So here's my story: I was let go from my job in September 2014, where I had a corporate visa through citibank. I accepted another job a few days later, that required a move from GA to FL. Not realizing that citibank corporate cards, and citibank consumer cards were different business units, I thought I had done well when I updated my citibank consumer card and when they affirmed that it would updated all citibank accounts. In October 2014 I paid off what I thought was my remaining balance of $3800. I didn't received any correspondence or calls from citibank, and so I didn't think about them again. Fast forward to January 2015 Things have been going well in FL, and my wife and I decided to buy our first home. My mortgage broker told me I should enable credit monitoring atleast until the mortgage is finalized. This is when it all started. I received a credit monitoring alert on January 18th stating I had a new account, and a 90d late (!!!) I immediately log in and see that my old citibank corporate card is now a new tradeline in my credit report, and that it is showing as 90d late. I call citibank, and am told that I need to speak to a different group of folks that are only open weekdays (1-855-589-6912). I'm not entirely sure who this is, but I suspect it's collections. Having read a great deal on this forum on an old citibank thread from 2011, I call them up, and plead my case. Asking them to make a "goodwill adjustment" to make sure I can still close on my mortgage. The man I speak to seems pretty jaded, and says he doesn't know what that is, and that he can forward my account to a supervisor. I'm told to call back tomorrow. I have otherwise perfect credit, if a short history (I moved from the UK 5 years ago) so that one 90d late dropped my credit score by nearly 80 points (!!!) I know that in the old thread there was a list of citibank e-mail addresses. However, it's from 2011, and I'm thinking most are invalid now. Has anyone had any luck in a case similar to mine in getting a commitment on late removal? What is the best way to deal with this situation? Thanks CICers!

I just received the plaintiff's response to my plea to the jurisdiction, and special exception I sent off courtesy of the help from Texasrocker. Each reply was in a separate envelope. My court date for this is October 29th so any helpful info will greatly be appreciated. I am just now trying to figure out what the next steps would be or how to properly object to (and get this stuff thrown out) this info they obviously are going to bring up as evidence. The only thing they have my info on is the affidavit from the expert "custodian of records" for Portfolio Recovery, Larry Whitaker. ** Objection hearsay, chain of custody, as Mr. Whitaker is not an expert to the financial records of Citibank...** But the bill of sale from Patricia Hall is very generic. Then behind that is a blank "Exhibit 1 Asset Schedule" it looks like they blanked everything out. Then the printout of all my info from an excel spreadsheet and down @ the bottom says " Data provided by Portfolio Recovery Associates, LLC from electronic records provided by Citibank, NA pursuant to the sale of accounts from Citibank to PRA" In the response, the mention Texas DOT v. Arzate, 159 s.w.3d 188,190( Rex. el paso 2004, no pet) I think it is supposed to be Tex not rex. and then Bland ISD v. Blue, 34 s.w.3d 547,554 (TEX. 2000) --------------------------------------------------------------------------------------- Since they separated the Plea to Jurisdiction and the special exceptions, I will do the same. And again any help will be appreciated.

1. Who is the named plaintiff in the suit? Unifund CCR, LLC 2. What is the name of the law firm handling the suit? Kenosian and Miele 3. How much are you being sued for? $24,XXX.XX 4. Who is the original creditor? Citibank 5. How do you know you are being sued? Summons delivered at door 6. How were you served? Person 7. Was the service legal as required by your state? Yes 8. What was your correspondence (if any) with the people suing you before you think you were being sued? None 9. What state and county do you live in? California 10. When is the last time you paid on this account? (looking to establish if you are outside of the statute of limitations) Per the complaint, Sept., 2010 11. What is the SOL on the debt? 4 years 12. What is the status of your case? Suit served and trial date set for just over 30 days from now. 13. Have you disputed the debt with the credit bureaus (both the original creditor and the collection agency?) No 14. Did you request debt validation before the suit was filed? No 15. How long do you have to respond to the suit? Responded already with a general denial within 30 days of service. Trial date is now just a hair over 30 days away. We need to know what the "charges" are. Cause of Action 1. Breach of Contract 2. Monies had & received 3. open book 4. account stated Did you receive an interrogatory (questionnaire) regarding the lawsuit? yes 16. What evidence did they send with the summons? a note of Verification from the Attorney (Miele) of Unifund that all statements in the compliant are true and correct. ---------------------------------------------------------------------------------------------------------------------------------------------- I. I filed a PLD-050 General Denial with the court along with a POS-040 proof of service, and mailed copy to plaintiff via CMRR. II. I sent BOP and they responded with 14 months of Citibank statements III. I sent a Meet and Confer letter, to which they responded with Supplement Responses that included same 14 months of statements, plus Bill of sale between Citibank and a receivables company, and a Bill of sale between the receivables company and a distressed asset company, and a bill of sales between the distressed asset company and Unifund. IV. I received Plaintiff's request for Production of Documents and Admission I need to respond in the next few days V. I sent CCP 96 and received responses: A. Plaintiff intends to call me as a witness B. Documents that Plaintiff intends to offer at trial: 1. Business Records Affidavit signed by Document Control Officer for Citibank - notarized in Missouri 2. 14 months of Citibank statements 3. Bill of sale between Citibank and a receivables company, and a Bill of sale between the receivables company and a distressed asset company, and a bill of sales between the distressed asset company and Unifund. 4. Citibank Card Agreement that has no signature other than the CEO of Citibank. VI. I received: A. Notice to attend trial B. CCP 96 C. Declaration of authorized representative in lieu of live testimony CCP98 from authorized representative for Unifund. What should I do, now?