Motion_to_deem_rfas_admittedMotionCal. Super. - 2nd Dist.December 2, 2019Electronically FILED by Superior Court of California, County of Los Angeles on 07/20/2020 10:30 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Reed,Depu 1 2 3 Un Oo 0 2 10 11 12 13 14 15 16 17 18 19 20 21 2p 23 24 25 26 27 28 Brian N. Winn (State Bar No. 86779) Laura M. Hoalst (State Bar No. 101082) Jason M. Burrows (State Bar No. 309882) Amit Taneja (State Bar No. 304559) Grace Gail Cara (State Bar No. 315558) Cherrie Y. Tan (State Bar No. 324871) Katrina Trinh (State Bar No. 327357) Juan Villanueva (State Bar No. 328049) Winn Law Group, A Professional Corporation 110 E Wilshire Ave Ste 212, Fullerton CA 92832 Telephone: (714) 446-6686, Fax No.: (714) 446-6680 File No: 19-12526-0-M2D-FMM- (1910-00) Attorneys for Plaintiff SUPERIOR COURT OF CALIFORNIA LOS ANGELES COUNTY CAVALRY SPV [, LLC, VS. LUCIO A AGUAYO, ET AL. Plaintiff, Defendant(s). Case No. 19NWLC46884 "LIMITED CIVIL MATTER" NOTICE OF AND MOTION TO DEEM FACTS AS ADMITTED. MEMORANDUM OF POINTS AND AUTHORITIES AND SUPPORTING DECLARATION; AND REQUEST FOR ATTORNEY FEES OF $200.00 PLUS FILING FEE OF $60.00 [CRC §3.1702, CCP§§2023.010 AND 2033.280(b)] DATE: November 19, 2020 TIME: 10:30am DEPT: A RESERVATION: 780185136084 TO ALL INTERESTED PARTIES PLEASE TAKE NOTICE: 1 11 Page 1 MOTION TO DEEM FACTS AS ADMITTED/PROOF OF SERVICE Clerk oO 0 N n R W ND B O N N N N N N N N m m m e m p m e m b e d e m p m e m pe a 0 NN A nh B A R W O N = O Y N N D W N em On November 19, 2020, at 10:30am, or as soon thereafter as the matter may be heard in Department of the above entitled court located at 12720 NORWALK BLVD., NORWALK, CA 90650, Plaintiff, CAVALRY SPV I, LLC (hereinafter "PLAINTIFF") will and does move the court for an order deeming admitted each matter stated in Request for Admissions Set Number One as propounded upon Defendant, LUCIO A AGUAYO AKA LUCIO ALONSO AGUAYO AKA LUCIO AGUAYO (hereinafter "DEFENDANT"), and for an order imposing sanctions against Defendant pursuant to CCP§2033.280(c). This motion is made on the grounds that Defendant has failed to answer Request for Admissions that are relevant to the subject matter of this litigation that have been propounded upon Defendant. This motion is based upon this notice, the attached declarations, the attached memorandum of points and authorities, the pleadings and records on this file herein and any other such oral and documentary evidence that may be presented at the hearing on this matter. 1 1 Page 2 MOTION TO DEEM FACTS AS ADMITTED/PROOF OF SERVICE oO 0 0 a D W N = N N N N N N N N N m m m e e s e m e d e m pe e a a pe = - BE -C - E S E ' s S U O E NO a ) {i Notice is further hereby given: if you wish to oppose the relief requested in this motion you must timely file a written reply to this motion in compliance with all court rules, if you fail to do so the court may treat your failure to respond as a waiver of your right to oppose this motion and may grant the requested relief. Dated: July 14, 2020 Winn Law Group, A P.C. — > Brian N. Winn [] [ ] Laura M. Hoalst ] [ 1 Jason M. Burrows Amit Taneja [ ] Grace Gail Cara [ ] Cherrie Y. Tan [ ] Katrina Trinh [ ] Juan Villanueva Attorney for PLAINTIFF Page 3 MOTION TO DEEM FACTS AS ADMITTED/PROOF OF SERVICE W e a N RA W R N O N R N O N N N R rm em em em e m p s em pe t em pe = J o C INTRODUCTION 1. On April 23, 2020, Plaintiff propounded Request for Admissions Set Number One upon Defendant. No reply, timely or otherwise, was ever served by Defendant. Copies of the discovery documents are attached hereto as Exhibit A. 2. On June 3, 2020, Plaintiff's attorney made demand upon Defendant for their responses to the above stated discovery. That demand informed the Defendant that if they failed to respond, the Plaintiff would move the Court for an order deeming the matters in the request for admissions admitted. A copy of that demand is attached hereto as Exhibit "B". 3. The above stated demand also informed Defendant sanctions would be sought should the Plaintiff be forced to make a Motion to Deem. The Defendant did not respond to either the propounded discovery or the demand letter. 4. Plaintiff's attorney has spent one (1) hour preparing this motion and estimates that another one (1) hour will be spent appearing on this motion. Plaintiff's attorneys normal billing rate for these matters is $200.00 per hour. MEMORANDUM OF POINTS AND AUTHORITIES L THE COURT SHOULD ORDER THE REQUESTS FOR ADMISSIONS ADMITTED AND ISSUE A MONETARY SANCTION. A. If Defendant fails to respond to a Request for Admissions, the Court must enter an order deeming the Requests Admitted. Code of Civil Procedure Section 2033.280 (b) and (c) states in its relevant part: The requesting party may move for an order that the genuineness of any documents and the truth of any matters specified in the requests be deemed admitted, as well as for a monetary sanction under Chapter 7 (commencing with Section 2023.010). The court shall make this order, ... CCP Section 2033.280 (b) I" Page 4 MOTION TO DEEM FACTS AS ADMITTED/PROOF OF SERVICE O e J S N n n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 In the current case, the Defendant has failed to serve any answers to the propounded admissions, if Defendant continues in their failure to respond or make a response that is not in substantial compliance with the requirements of the Code, the Court must deem all of the requests admitted. B. The Court must impose a monetary sanction against the Defendant. The Code of Civil Procedure dictates the imposition of a monetary sanction against a party and/or attorney for the failure of that party or attorney to respond to a request for admission. ...It is mandatory that the court impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) on the party or attorney, or both, whose failure to serve a timely response to requests for admission necessitated this motion. CCP Section 2033.280 (¢). Accordingly, Plaintiff respectfully requests that this court impose monetary sanctions against Defendant in the amount of $200.00. Winn Law Group, A P.C. Dated: July 14, 2020 [ 1 Brian N. Winn [ ] Laura M. Hoalst ] [ 1 Jason M. Burrows Amit Taneja [ } Grace Gail Cara [ ] Cherrie Y. Tan [ ] Katrina Trinh [ ] Juan Villanueva Attorney for PLAINTIFF Page 5 MOTION TO DEEM FACTS AS ADMITTED/PROOQOF OF SERVICE DECLARATION I, the undersigned, declare as follows: I. Tam an attorney at law duly admitted to practice before all courts of the State of California. I have first hand personal knowledge of the things declared herein and if called to testify I could and Would competently testify thereto. 2. Iam associated with Winn Law Group, A P.C. the attorneys for the Plaintiff in this matter. I am currently the attorney responsible for the litigation of the above captioned file. In preparation for making this motion and declaration, I reviewed the file that is kept in the ordinary course of business of Winn Law Group for the above captioned matter. The exhibits attached to this motion specifically, Request for Admissions Set Number One and Demand Letter to Defendant are true and accurate copies of documents contained in the file. 3. My review of the file also disclosed that the Request for Admissions, Set Number One, were sent to the Defendant on April 23, 2020. No response to the Request for Admissions, Set Number One, was received from the Defendant. 4. Plaintiff then sent a Meet and Confer letter to the Defendant on June 3, 2020 demanding that they respond to the Request for Admissions, Set Number One, without objection. Again, no response was received from the Defendant. 5. Ihave reviewed all of the Request for Admissions and in my professional opinion as an attorney at law, I believe them all to be necessary and relevant to the subject litigation. 1 I 11 Page 6 MOTION TO DEEM FACTS AS ADMITTED/PROOF OF SERVICE o e 0 a y un bh 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 6. Ihave spent one (1) hours in preparation for, and drafting this motion. I anticipate another one (1) hour will be spent traveling to and appearing at this motion. The normal and customary rate charged to Plaintiff is two hundred dollars ($200.00) per hour. The fees attributable to this motion are $200.00 plus the $60.00 filing fee. I declare under penalty of perjury of the laws of the State of California that the foregoing 1s true and correct. Dated: July 14, 2020 — > [ ] Brian N. Winn [ ] Laura M. Hoalst [ ] Jason M. Burrows Amit Taneja [ ] Grace Gail Cara [ 1 Cherrie Y. Tan [ ] Katrina Trinh [ ] Juan Villanueva Declarant Page 7 MOTION TO DEEM FACTS AS ADMITTED/PROOF OF SERVICE o e 3 S N n p 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 EXHIBIT “A" (Request for Admissions) BRIAN N, WINN WINN LAW GROUP POST OFFICE BOX 1216 FULLERTON, CALIFORNIA 92836 LAURA McCARTHY HOALST pe TELEPHONE: (714) 446-6686 da orc oan A PROFESSIONAL CORPORATION “Toll Fee Telephono: 5 GRACE GAIL CARA PAX: (714) 46-6680 LIob THE CHAPMAN BUILDING ; ligase ech 110 B. WILSHIRE AVE, SUITE 212 PMA: Cle gman: FULLERTON, CA 92832-1109 April 23, 2020 Lucio A Aguayo 5929 Carmelita Ave Apt B Huntington Park CA 90255-3357 RE: Case Name: CAVALRY SPV I LLC v. LUCIO A AGUAYO Court Case No.: I9NWLC46884 Our File No.: 19-12526-0-DI1-FMM (1910-00) Dear Sir/Madam: Enclosed are the following discovery demands made upon you: 1. Form Interrogatories; 2. Special Interrogatories; and 3 Request for Admissions You have chosen to represent yourself in this action. Since you are representing yourself you are held to the standards of an attorney. The California courts have repeatedly held that parties that chose to represent themselves are entitled to the same, but not greater, rights than represented litigants and are presumed to know the rules. Wantuch vs. Davis (1995) 32 Cal. App.4th 786; Lawrence vs. Superior Court (1988) 206 Cal App.3d 611, We are not your attorney. You are acting as your own attorney. Your time to respond to the discovery is limited. We are not allowed to help you answer the discovery. Please be aware, that if you chose to do nothing, we may seek to have your answer struck, seek to have facts deemed admitted, seek to compel your answers and/or seek monetary sanctions, Thank you for your prompt attention in this matter. This law firm is a debt collector, as defined by 15 U.S.C. section 1692(a)(6), and this is an attempt to collect a debt. Any information obtained by us will be used for that purpose. Sincerely, WINN LAW GROUP, AP.C. ___—— { 1 Brian N. Winn { ] Laura M, Hoalst [ ] John E. Gordon [ 1 Jason M. Burrows plait Taneja [ ] Grace Gail Cara [ ] Cherrie Y. Tan { ] Katrina Trinh { 1 Juan Villanueva DISC-020 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name and Address): ror Court Use Only Brian N. Winn (SBN 86779) Laura M. Hoalst (SBN 101082) John EF. Gordon (SBN 180053) Jason M. Burrows (SBN 305882) Amit Taneja (SBN 304559) Grace Gail Cara (SBN 315558) Cherrie Y. Tan {SBN 324871} Katrina Trinh (SEN 327357) Juan Villanueva (SBN 328049) WINN LAW GROUP, A PROFESSIONAL CORPORATION 11C E. WILSHIRE AVE., SUITE 212, FULLERTON, CA 92832 File No: 19-12526-0~-DI1 FMM TELEPHONE NO.: (714) 446-6686 FAX NO.: (714) 446-6680] ATTORNEY FOR PLAINTIFF i . STREETADDRESS: 12720 Norwalk Bivd. MAILING ADDRESS: 12720 Norwalk Blvd. CITY AND ZIP CODE: Norwalk 80650 BRANCH NAME:SOUTHEAST DISTRICT, LIMITED v REQUESTS FOR ADMISSION Case Number, [ ] Truth of Facts [ ] Genuineness of Documents AAMICAGREL Requesting Party: CAVALRY spV I, LLC Answering Party: LUCIO A AGUAYO, et al. Set No.: ONE INSTRUCTIONS Requests for admission are written requests by a party to an action requiring that any other parly lo the action either admit or deny, under oath, the truth of certain facts or the genuineness of certain documents. For information on timing, the number of admissions a party may recuiest from any other party, service of requests and responses, restrictions on the style, format, and scope of requests for admission and responses to requests, and other details, see code of Civil Procedure sections 94-95, 1013, and 2033.010-2033.420 and the case law relating {o those sections. An answering party should consider carefully whether fo admit or deny the truth of facts or the genuineness of documents. With limited exceptions, an answering party will not be allowed to change an answer to a request for admission. There may be penalties if an answering party falls to admit the truth of any fact or the genuineness of any document when requested to do so and the requesting party later proves that the fact is true or that the document is genuine. Thess penalties may include, among other things, payment of the requesting party's attomey's fees incurred in making that proof. Unless there is an agreement or a court order providing otherwise, the answering party must respond in writing to requests for admission within 30 days after they are served, or within 5 days after service in an unlawful detainer action. There may be significant penalties If an answering party fails to provide a timely written response to each request for admission. These penalties may include, among other things, an order that the facts in issue are deemed true or that the documents in issue are deemed genuine for purposes of the case. Answers to Requests for Admission must be given under cath. The answering party should use the following language at the end of the responses: | declare under penatly of perjury under the laws of the State of California that the foregooing answers are true and correct. April 23, 2020 (DATE) (SIGNATURE) These Instructions are only a summary and are not intended to provide complete information about requests for admission. This Requests for Admission form does not change existing law relating to requests for admissions, nor does it affect an answering party's right to assert any privilege or fo make any objection, REQUESTS FOR ADMISSION You are requested to admit within 30 days after service, or within 5 days after service In an unlawful detainer action, of this Requests for Admission that: 1.[ X ) Each of the following facts is true (if more than one, number each fact consecutively): l X ] Continued on Attachment 1 . . 2. The original of each of the following documents, coples of which are attached, is genuine (If more then one, number each document conseculively): [ 1Continued on Attachment 2 Brian N. Winn {] Laura M. Hoalst John E. Gordon |} Jason M. Burrows > — Amit Taneja [] Grace Gail Cera Chemie Y, Tan [] Katrina Trinh Juan Villanueva {TYPE OR PRINT NAME) {SIGNATURE OF PARTY OR ATTORNEY) Page 1 of 4 Form Approved for onal Use Code Civil , Nticial Conch of Cfo REQUESTS FOR ADMISSION £6 94.65, 2003.010-2035.420, 2053.11 DIST020 [Rev. January 1, 2008] OW 00 3 0 Uh bh W O N ee N O N D N N N B O R w t m l m d e d p d pe d a p m ® 3 a uo R I B B E B E 5 3 2 0 F r 5 0 8 0 - 2 3 Brian N. Winn (State Bar No. 86779) Laura M. Hoalst (State Bar No. 101082) John E. Gordon (State Bar No. 180053) Jason M. Burrows (State Bar No. 309882) Amit bo (State Bar No, 304559) Grace Gail Cara (State Bar No. 315558) Cherrie Y. Tan (State Bar No. 324871) Katrina Trinh (State Bar No. 327357) Juan Villanueva (State Bar No. 328049) Winn Law Group, A Professional Corporation 110 E Wilshire Ave Ste 212, Fullerton CA 92832 Edloghone: (714) 446-6686, Fax No.: (714) 446-6680 File No: 19-12526-0-DI1-FMM- (1910-00) Attorneys for Plaintiff SUPERIOR COURT OF CALIFORNIA LOS ANGELES COUNTY CAVALRY SPVILILC, Case No. 19NWLC46884 Plaintiff, vs. REQUEST FOR ADMISSIONS (SET ONE) LUCIO A AGUAYO, ET AL. "LIMITED CIVIL. MATTER" Defendant(s). REQUESTING PARTY ............ PLAINTIFF, CAVALRY SPV ILLC RESPONDING PARTY ........ DEFENDANT, LUCIO A AGUAYO AKA LUCIO ALONSO AGUAYO AKA LUCIO AGUAYO Within 30 days after service of this document, you are requested to admit that each of the following facts is true: I. Admit to the genuineness of the documents attached hereto as EXHIBIT 1, monthly billing statements for Citibank, N.A. with the Account Number XXXXXXXXXXXX1943 subsequently X3OXXXXXXX XX 6855. 2. You applied for and opened a credit card account with Citibank, N.A.. i Page 1 REQUEST FOR ADMISSIONS; PROOF OF SERVICE Ww 00 3 o b s Ww O N B O N D N R N N N N ee k d ea k e R t a d e d pe p d pe a 0 N N WM A W N =m O W N N bh W N o m o o 3. A credit card was issued to you by Citibank, N.A. with the Account Number XXXKXXKXXXXXX1943 subsequently XXXXXXXXXXXX6855 (hereinafter referred to as, "account™). 4. You used the credit card and made charges and made payments to the account. 5. Monthly billing statements, attached hereto as EXHIBIT 1, were mailed to you at 5929 Carmelita Ave Apt B Huntington Park CA 90255-3357, indicating monthly debits, credit and payments made on the account. 6. You were mailed and received a Cardholder Agreement for this account. 7. The date of last payment, or transaction, occurred on July 9, 2018, on the account. 8. On February 13, 2019, you were indebted to Citibank, N.A. the sum of $6,964.64 on an account stated for charges to your account, 9. On March 27, 2019, you were indebted to Plaintiff the sum of $6,818.55 on an account stated for charges to the account. i mn i Page 2 REQUEST FOR ADMISSIONS; PROOF OF SERVICE W 0 3 & o s W O N ee N O N O N O N R O N RN O N O N k m r e e m e t e d p e d m t ee t ed 0 3 dA W N = D Ww N N W bh W O N o m o o 10. All conditions precedent to payment of the unpaid principal balance due on your Citibank, N.A. , Account Number XXOXXXXXXXXX1943 have been performed, waived, satisfied, or extinguished. 11. You have no valid affirmative defenses to this action. Winn Law Group, A P.C. Dated: April 23, 2020 = = [ ] Brien N. Wim [ J Laura M. Hoalst [} John E. Gordon [ 1 Jason M. Burrows Ath Amit Taneja [ ] Grace Gail Cara [] Cherrie Y. Tan [ 1 Katrina Trinh [ } Juan Villanueva Attorney for PLAINTIFF Page 3 REQUEST FOR ADMISSIONS; PROOF OF SERVICE "EXHIBIT 1 LUCIO A AGUAYO Member Since 2014 Account number ending in: 6855 Billing Period:01/12/18-02/13/18 FEBRUARY STATEMENT Minimum payment due: §95.73 New balance as of 02/13/18: $5,643.53 Payment due date: 03/09/18 Late Payment Warning:If we do not receive your minimum payment by the date listed above, you may have to pay a Iate fee of up to $35 and your APRs may be increased up to the variable Penalty APR of 29.59%. Minimum Payment Warning: /f you make only the minimum payment each period, you will pay more in interest and it wil} take you longer to pay off your balance. For example: If you make no additional | You will pay off the i And you will end up charges using this card balance shown on this paying an estimated 0 end each month you pay... : statement in about... tal of... Only the minimum payment | 21 year(s) $15,082 SE $210 3 year(s) (Savings=$7,522) For information about credit counseling services, call 1-877-337-8187. Pay your bli from virtually anywhere with the Cit] Mobile® App and CItP Onfine 2 To download: Text 'AppiE’ to MyCitl (692484) or go to your device's app store, Or visit www.clticards.com Account Summary www.citicards.com Customer Service 1-800-823-4086 TTY-hearing-impaired services only 1-800-325-2865 BOX 6500 SIOUX FALLS, SD 57417 Previous balance $5,723.80 Payments -8120.00 Credits -$0.00 Purchases +$0.00 Cash advances +50.00 Fees +50.00 Interest +539.73 New balance $5,643.53 Credit Limit Credit limit $5890 includes $0 cash advance limit Available credit $246 Savings Spotlight Your Dlamond Preferred Lifetime Savings: $2,047.59 See page 3 to view your Savings Summary. Minimum payment due New balance Payment due date Amount enclosed: $95.73 $5,643.53 03/09/18 Account number ending in 6855 000000 VIOO AO LUCIO A AGUAYOD CiTi CARDS 5929 CARMELITA AVE PO BOX 78048 APT B Phoenix, AZ 85062-8045 HUNTINGTON PARK CA 90255-3357 15009 0009573 0564353 002000 EGG 1 Customer Service 1-800-823-4086 Pagezof 2 TTY-hearing-impalred services only 1-800-325-2865 www.citicards.com LUCIO A AGUAYO Account Summary Trans, Post date date Description Amount Payments, Credits and Adjustments 02/09 PAYMENT THANK YCU -$120.00 Fees charged Tota! fees charged In this billing perlod $0.00 interest charged Date Description Amount 02413 INTEREST CHARGED TO STANDARD PURCH $1.76 02/13 INTEREST CHARGED TO PUR PR-11/02/17. $20.10 02/13 INTEREST CHARGED TO OFFER-007 $1.87 $39.73 Totel interest charged in this bliling pertod 2018 totals year-to-date Total fees charged In 2016 Total Interest charged in 2018 $0.00 $75.44 Interest charge calculation Days In billing cycle: 33 Your Annual Psrcestage Rate {APR} the annua! interest rate on your account. Annual! prrcental Baisnce subject rate (AP Intarest charge Balance type ) to interest rate PURCHASES Standard Purch 29,99% (V) $286.36 (D) $7.76 i Pur Prizm 21.249 (V) $1,046.78 (D} $20.10 Offer 7 2.95% $4,301.78 (0) $1.87 (Balance Transfer Rate Expires 04/01/18) ADVANCES Standard Adv 29.99%(V) $0.00(D} $0.00 Your Annual Percentage Rate (APR) Is the annual Interest rate on your account, APRs followed by (VJ may vary. Balances followed by (D) are determined by the dally balance method (including current transactions). Account messages SAVINGS SPOTLIGHT DETAILS INTEREST: If you have promotional balances on your account, we have estimated your savings. This savings is the difference between the interest that was assessed against the promotional balances using the promotional APRs and the estimated interest that would have been assessed against these same balances using the Enhanced Purchase APRs. This savings amount does not include any balance transfer fees. This savings is from your billing period covered by this statement. CITIEASY DEALS: If you made a pu rchase on Citi Easy Deals, your savings is the difference between the retail price and the price you paid. This savings is from the prior calendar month. CITI PRICE REWIND: If you received a Citi Price Rewind refund, savings is the refunded amount. This savings is from the prior calendar month. CITI DIAMOND PREFERRED LIFETIME SAVINGS: The savings from interest, Citi Easy Deals and Citi Price Rewind since you became a Citi Diamond Preferred member. This savings amount does not Include any balance transfer fees. Savings Spotlight Your Citi® Diamond Preferred® Savings Summary From This Billing Perlod: & Interest: $7246 TOTAL SAVINGS $72.46 See Account Messages for more information about Savings Spotiight Citi Easy Deals” To tind out your current tier: Visit citieasydeals.com or cafl the number provided above. —p— a ida Deals you can access, by tier: Coupons for local dining and shoppin AAS Minimum Annual Purchases: $100 Base tier benefit Plus deals on gift cards and magazines Re - ® Minimum Annual Purchases: $500 * Base and Enhanced tier benefits ® Plus deals on merchandise, travet and dally deals » For complete detalls, go to citleasydeals.com Customer Service 1-800-823-4086 www.clticards.com TTY-hearing-impaired services only 1-800-325-2865 LUCIO A AGUAYO Did you know that with a Single phone call, a Citi Client First Account Specialist can provide you with information and options that may be available on all of your Citibank accounts? Please contact us Monday - Friday 7:00AM - 10:00PM; Saturday 7:00AM : 7:00PM; Sunday 8:00AM - 7:00PM Central time at 1-866-680-8625 to speak with an Account Specialist for more Information. Please be sure to pay on time. If you submit your payment by mail, we su you mall it no later than 03/02/2018 to allow enough time for regular ma reach us. ie Page 30f3 1 LUCIO A AGUAYO Member Since 2014 Account number ending in: 6855 Billing Perlod:02/14/18-03/13/18 MARCH STATEMENT Minimum payment due: §91.81 New balance as of 03/13/18: $5,866.24 Payment due date: 04/09/18 Late Payment Warning: If we do not recelve 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 variable Penalty APR of 29.99%. Minimum Payment Warning: if you make only the minimum payment each period, you will pay more in interest and It will teke you longer Lo pay off your balance, For example: If you make no sdditlonai You will pay off the And you will end up charges using this card balance shown on this paying an estimated and each month you pay... | statement in about... ai of... Only the minimum payment : 22 year(s) 516398 £7,992 $222 LL 3 year(s) (savings=$8, 406) For Information about credit counseling services, call 677-337-8187. Pay your bill from virtuaily anywhere with the CII Meblie® App and CHIP Onfine 5 To download: (EB Text "Appi5* to MyCitl (692464) or go to your device's app store. Or visit www.citicerds.com 000000 VIOD AD www.citicards.com Customer Service 1-800-823-4086 TTY-hearing-impalred services only 1-800-325-2865 BOX 6500 SIOUX FALLS, SD 57117 Account Summary Previous balance $5,643.53 Payments -5120.00 Credits -$0.00 Purchases +$308.90 Cash advances +50.00 Fees +50.00 Interest +$33.81 New balance $5,866.24 Credit Limit Credit limit $5,890 Includes $0 cash advance mit Available credit £23 Savings Spotlight Your Plamond Preferred Lifetime Savings: $2,108.18 See page 3 to view your Savings Summary. Minimum payment due $91.81 New balance $5,866.24 Payment due date 04/08/18 Amount enclosed: Account number ending in 6855 LUCIO A AGUAYD CITi CARDS 5929 CARMELITA AVE PO BOX 78045 APTB Phoenix, AZ 85062-8045 HUNTINGTON PARK CA 90255-3357 15000 0009181 0586624 0012000 WENERERSGSESEEER 0912 www.clticards.com LUCIO A AGUAYO Account Summary Customer Service 1-800-823-4086 TTY-hearing-Impalred services only 1-800-325-2865 Trans. Post date date Description Amount Payments, Credits and Adjustments 03/07 PAYMENT THANK YOU $120.00 Standard Purchases 03/10 03/10 ROSS STORES #292 LAJOLLA CA $246.46 03M 03/41 EXPEDIA 7336140919124 EXPEDIA.COM WA $62.44 Fees charged Total fees charged In this biling period $0.00 interest charged Date Description Amount 03/13 INTEREST CHARGED TO STANDARD PURCH $6.85 03/13 INTEREST CHARGED TO PUR PR-1/02/17. $17.03 03/13 INTEREST CHARGED TO OFFER-007 $9.93 Total interest charged In this biling period $33.81 2018 totals year-to-date Total fees charged in 2018 $0.00 Total interest charged in 2018 $109.25 Interest charge calculation Your Annual Percentage Rate {APR)Is the annual interest rate on your account. Annual patesctage Balance subject Days In billing cycle: 28 i Standard Adv en Your Annuai Percentage Rate (APR) Is the annual Interest rate on your account. APRs followed Balance type rete (APR) to Interest rate Interest charge PURCHASES Standard Purch 29.99%(v) $297.66(D) $6.85 Pur Pr 10217 21.24% (V) $1,045.34 (D) $17.03 Offer 7 2.99% $4,328.38 (D) $9.93 {Balance Transfer Rate Expires 04/01/18) ADVANCES 2999%(v) $000) _S0.00 by (V) may vary. Balances {followed by (D) are determined by the dally balance method {including current transactions), Page2 of 3 Savings Spotlight Your Citi® Diamond Preferred® Savings Summary Frem This Billing Period: E Interest: $60.59 . TOTAL SAVINGS $60.59 108.18 See Account Messages for more information about Savings Spotlight Citi Easy Deals” To find out your current tier: Visit citieasydeals.com or cali the number provided above. Deals you can access, by tier: Minimum Annual Purchases: $0.00 __ Coupons for focal dining and shopping | Eohanceddier = + Minimum Annual Purchases: $100 » Base tier benefit ¢- Plus deals on gift cards and magazines & Minimum Annual Purchases: $500 = Base and Enhanced tier benefits # Plus deals on merchandise, travel and dally deals » For complete details, go to citieasydeals.com www.clticards.com Customer Service 1-800-823-4088 TTY-hearing-impaired services only 1-800-325-2865 LUCIO A AGUAYO Account messages SAVINGS SPOTLIGHT DETAILS INTEREST: If you have promotional balances on your account, we have estimated your savings. This savings is the difference between the interest that was assessed against the promotional balances using the promotional APRs and the estimated interest that would have been assessed against these same balances using the Enhanced Purchase APRs. This savings amount does not include any balance transfer fees, This savings is from your billing period covered by this statement. CITI EASY DEALS: If you made a furchase on Citi Easy Deals, your savings is the difference between the retail price and the price you pad. This savings is from the prior calendar month. CITI PRICE REWIND: if you received a Citi Price Rewind refund, savings Is the refunded amount. This savings is from the prior calendar month. CIT DIAMOND PREFERRED LIFETIME SAVINGS: The savings from interest, Citi Easy Deals and Citi Price Rewind since you became a Citi Diamond Preferred cardmember, This savings amount does not include any balance transfer fees. Did you know that with a single phone call, a Citi Client First Account Specialist can provide you with information and options that may be available on all of your Citibank accounts? Please contact us Monday - Friday 7:00AM - 10:00PM; Saturday 7:00AM - 7:00PM; Sunday 8:00AM - 7:00PM Central time at 1-866-680-8625 to speak with an Account Specialist for more information. Please be sure to py on time. if you submit your feyenark by mail, we suggest you mail it no later than 04/02/2018 to allow enough time for regular mail to reach us. Page 3 of 3 LUCIO A AGUAYO Member Since 2014 Account number ending In; 6855 Billing Period: 03/14/18-04/12/18 APRIL STATEMENT www.citicards.com Customer Service 1-800-823-4086 TTY-hearing-impaired services only 1-800-325-2865 BOX 6500 SIOUX FALLS, SD 57117 Account Summary Minimum payment due: $124.28 Previous balance $5,866.24 New balance as of 04/12/18: $5,812.52 payments Nis Payment due date: 05/09/18 Be +$4,282.61 Cash advances +$0.00 Fees +$0.00 Late Payment Warning: If we do not recelve your minimum payment by the Interest +566.28 date listed above, you may have to pay a late fee of up to $35 and your APRs New balance $5,812.52 may be increased up to the varlable Penalty APR of 29.99%. Minimum Payment Warning: if you make only the minimum payment each Credit Limit period, you will pay more In interest and it will take you longer to pay off your Credit timit $5,890 balance. For example: includes $0 cash advance limit make dditional 1 Y it tf ¢ And TH : TR using this card Balance rela this pa ig, an. pedir Available credit $17 and each month you pay... | statement in about... ofal of... Only the minimum payment | 22 year(s) $16,267 $223 3 year(s) Bovgsb8.238) For Information about credit counseting services, call 1-877-327-8187. Savings Pay your bli from virtually anywhere with the Cit] Moblis® App and CHIP Onfine vas, To download: i Text 'ApplS' to MyCRI (692484) or go to your device's app store. Or visit www.cltlcands.com 000000 VIQO AD LUCIO A AGUAYO 5929 CARMELITA AVE APTH HUNTINGTON PARK CA $0255-3357 Spotlight Your Diamond Preferred Lifetime Savings: . $2,149.49 See page 3 to view your Savings Summary. Minimum payment due New balance Payment due date Amount enclosed: Account number ending In 6855 CiTI CARDS PO BOX 78045 Phoenix, AZ 85062-8045 15000 0012424 0581252 0012000 EEGGG_—_—_—_———— Cc 4 $124.28 $5,812,852 05/09/18 Customer Service 1-800-823-4086 Page 2 of 3 www.clticards.com TTY-hesring-impalred services only 1-800-325-2865 LUCIO A AGUAYD Account Summary Trans, Post date date Description Amount Payments, Credits and Adjustments 04/09 PAYMENT THANK YOU —— -$120.00 04/02 OFFER 07 PROMOTIONAL APR ENDED 04/01/18 $4,282.61 Purchases Prior to 11/02/17 04/02 OFFER O7 MOVED TC PUR PRIOR TO 11/02A7 $4,282.61 Fees charged Tota! fees charged In this billing peried $0.00 interest charged Date Description Amount 04/12 INTEREST CHARGED TO STANDARD PURCH $13.47 04/12 INTEREST CHARGED TQ PUR PR-11/02/17. $46.13 04/12 INTEREST CHARGED TO OFFER-007 $6.68 Total Interest charged in this bling parled $66.28 2018 totals year-to-date Total fees charged in 2018 $0.00 Total interest charged in 2018 $175.53 Interest charge calculation Days m billing cycle: 30 | Your Annuai Percentage Rate (APR)Is the annual interest rale on your account. Annual percentage Balance subject Interest chargs Bafence type rate (APR) to Interest rate PURCHASES Standard Purch 29.99% (V) $546.41(D) $13.47 Pur Pr 110217 21.49% (V) $2,611.58 (D) $46.13 offer 7 2.99% $2,716.77 (D) §6.68 (Balance Transfer Rate Expired 04/01/18) ADVANCES Standard Adv 29.99% (V) $0000) $0.00 | Your Annual Percentage Rate (APR) Is the annual interest rate on your account. APRs followed by (V) may vary. Balances followed by (D) are determined by the dally balance method (including current transactions). An offer has expired. For each expired offer, this month's statement shows a corresponding debit and credit transaction to move the remaining offer balance to the standard APR for purchases. Individual transactions made before offer expiration may also have corresponding debit and credit transactions if the transaction was received by us after the expiration date. Savings Spotlight Your Citi® Dlamond Preferred® Savings Summary From This Billing Period: i Interest: $41.31 TOTAL SAVINGS $41.31 See Account Message for more information about Savings Spotlight Citi Easy Deals” To find out your current tier: Visit citieasydsals.com or call the number provided above, Dash you can access, by tier: ~ Minimum Annual Purchases: $0.00 Coupons for oe] Sng and a Age Ei oo + Minimum Anrussl Piieehagas: $100 i Base tier benefit - Plus deals Sagi =a cards and SS Plus Tier = Minimum Annual Purchases: $500 ® Base and Enhanced tier benefits = Plus deals on merchandise, travel and dally deals » For complete details, go to citleasydeals.com www.clticards.com Customer Service 1-800-823-4086 LUCIO A AGUAYG TTY-hearing-impaired services only 1-800-325-2865 Account messages SAVINGS SPOTLIGHT DETAILS INTEREST: if you have promotional balances on your account, we have estimated your savings. This savings is the difference between the interest that was assessed against the promotional balances using the promotional APRs and the estimated interest that would have been assessed against these same balances using the Enhanced Purchase APRs. This savings amount does not include any balance transfer fees. This savings is from your billing period covered by this statement. CITt EASY DEALS: if you made a purchase on Citi Easy Deals, your savings is the difference between the retail price and the price you paid. This savings is from the prior calendar month, CITI PRICE REWIND: if you received a Citi Price Rewind refund, savings is the refunded amount. This savings is from the prior calendar month. CITI DIAMOND PREFERRED LIFETIME SAVINGS: The savings from interest, Citi Easy Deals and Citi Price Rewind since you became a Citi Diamond Preferred cardmember. This savings amount does not Include any balance transfer fees. Did you know that with a single phone call, a Citi Client First Account Specialist can provide you with information and options that may be available on all of your Citibank accounts? Please contact us Monday - Friday 7:00AM - 10:00PM; Saturday 7:00AM - 7:00PM; Sunday 8:00AM - 7:00PM Central time at 1-866-680-8625 to speak with an Account Specialist for more information. Please be sure to pay on time. if you submit your payment by mall, we Sugoest you mail it no later than 05/02/2018 to allow enough time for regular mail to reach us. Page 3of 3 LUCIO A AGUAYD Member Since 2014 Account number ending in: 6855 Billing Period:04/13/18-05/11/18 MAY STATEMENT MInimum payment due: §162.64 New balance as of 05/11/18: $5,858.78 Payment due date: 06/09/18 Late Payment Warning: If 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 variable Penalty APR of 29.999. Minimum Payment Warning: If you make phe the minimum payment each period. you will pay more In interest and it will take you longer to pay off your alance. For example: if you make no additional | You will pay off the And you will end up charges using this card balance shown on this paying an estimated and each month you pay... | statement in about... otal of... Only the minimum payment | 22 year(s) $16,462 ns re ry $225 | 3 year(s) {Savings=$8,362) For information about credit counseling services, call 1-877-337-8187. Pay your bili from virtually anywhere with the Cit! Meblie® App and CitP Online cre To download: Text ‘AppiB* to MyCitl (692484) or go to your device's app store. www.clticards.com Customer Service 1-800-822-4086 TTY-hearing-impalred services only 1-800-325-2865 BOX 6500 SIOUX FALLS, SD 57117 Account Summary Previous balance $5,812.52 Payments -$124.28 Credits -$0.00 Purchases +$65.90 Cash advances +80.00 Fees +£0.00 Interest +5104.64 New balance $5,858.78 Credit Limit Credit limit $5,890 includes $0 cash advance Emit Available credit $3 Savings Spotlight Your Diamond Preferred Lifetime Savings: $2,149.49 See page 3 to view your Savings Summary. Minimum payment due New balance Payment due date $162.64 $5,850.78 06/09/18 Or Visit www.citicards com Amount enclosed: 000000 VIO AC Account number ending in 6855 LUCIO A AGUAYOD CITI CARDS 5929 CARMELITA AVE PO BOX 76045 APTB Phoenix, AZ 85062-8045 HUNTINGTON PARK CA 90285-3357 15000 003k2k4 0585878 0012400 CEKEEERNEEEREERED 0915 www. clticards.com LUCIO A AGUAYD Account Summary Trans. Post date date Description Amount Payments, Credits and Adjustments 05/09 PAYMENT THANK YOU -$124.28 Stendard Purchases 04/20 04/20 EXPEDIA 7346361026558 EXPEDIA.COM WA $65.90 Fees charged Tota! fees charged In this billing period $0.00 Interest charged Date Description Amount 05/1 INTEREST CHARGED TO STANDARD PURCH $13.77 05/1 INTEREST CHARGED TO PUR PR-11/02/17, $90.87 Total Interest charged in this titling period $104.64 2018 totals year-to-date Totaf fees charged In 2018 $0.00 i Tota! Interest charged in 2018 $280.47 "Interest charge calculation Days In billing cycle: 29 Your Annuef Percentage Rate (APR)Is the annual interest rate on your account. Annual percentage Balance subject Balance type rate (APR} to Interest rate interest charge PURCHASES Standard Purch 29.99% (V) $578.07 (D) $B. Pur Pr 1io217 2L49% (V) $5,321.90(D) $90.87 ADVANCES Standard Adv 29.99% (V) $0.00 (D} $0.00 Your Annual Percentage Rate (APR) Is the annual Interest rate on your account. APRs followed by {V) may vary. Balances followed by (D) are determined by the dally balance method (inciuding current transactions). Account messages SAVINGS SPOTLIGHT DETAILS INTEREST: If you have promotional balances on your account, we have estimated your savings. This savings is the difference between the interest that was assessed against the promotional balances using the promotional APRs and the estimated interest that would have been assessed against these same balances using the Enhanced Purchase APRs. This savings amount does net include any balance transfer iees. This savings is from your billing period covered by this statement. CITI EASY DEALS: If you made a purciney on Citi Easy Deals, your savings is the difference between the retail price and the price you paid. This savings is from the prior calendar month, CITI PRICE REWIND: If you received a Citi Price Rewind refund, savings is the refunded amount. This savings is from the prior calendar month. CITI DIAMOND PREFERRED LIFETIME SAVINGS: The savings from interest, Citi Easy Deals and Citi Price Rewind since you became a Citi Diamond Preferred cardmember. This savings amount does not include any balance transfer fees. Customer Service 1-800-823-4088 TTY-hearing-impalred services only 1-800-325-2865 Page2 of 3 Savings Spotlight Your Citi® Diamond Preferred® Savings Summary Citi Diamond Preferred Lifetime Savings E Interest: $2,149.49 See Account Messages for more information about Savings Spotlight Citi Easy Deals” Te find out your current tier: Visit citleasydeals.com or cali the number provided above. Deals you can access, by tier: CER Minimum Annual Purchases: $0.00 Coupons for local dining and shopping Ane + Minimum Annual Purchases: $100 + Base fler benefit * Plus deals on gift cards and magazines ® Minimum Annual Purchases: $500 ® Base and Enhanced tler benefits ® Plus deals on merchandise, travel and daily deals » For complete details, go to citieasydeals.com www.clticards.com Customer Service 1-800-823-4086 : TTY-hearing4mpalred s -800-325- LUCIO A AGUAYO hearing-impaired services only 1-800-325-2865 Did you know that with a single phone call, a Citi Client First Account Specialist can provide you with information and options that may be available on all of your Citibank accounts? Please contact us Monday - Friday 7:00AM - 10:00PM; Saturday 7:00AM - 7:00PM; Sunday 8:00AM - 7:00PM Central time at 1-866-680-8625 to speak with an Account Specialist for more information. If we need to contact you about your account, our records show your phone number(s) as 323-562-0860 (home), 562-867-5155 (work), 323-770-2939 (mobile). If this information isn't correct, please call the customer service number on the back of your card or update it online at www.citicards.com. Please be sure to pay on time. If you submit your ayant by mall, we suggest you rk it no later than 06/02/2018 to allow. encugh time for regular mal to reach us. Page3of 3 Citi® Diam citi LUCIO A AGUAYD Member Since 2014 Account number ending in: 6855 Billing Perlod:08/12/18-06/13/18 JUNE STATEMENT www.citicards.com Customer Service 1-800-823-4086 TTY-hearing-impaired services only 800-325-2865 BOX 6500 SIOUX FALLS, sD STITT Account Summary Minimum payment due: $177.05 Previous balance $5,858.78 New balance as of 06/13/18: $5,815.19 yes Bind Payment due date: 07/09/18 Purchases +2500 Cash advances +50.00 fees +50.00 Late Payment Warning: If we do not receive your minimum payment by the interest +5119.05 date listed above, you may have to pay a late fee of up to $35 and your APRs New balance $5,815.19 may de Increased up to the Penalty APR of 28.99%. Minimum Payment Warning: (f you make only the minimum payment each Credit Limit period, you will pay more In Interest and it will take you longer to pay off your Credit limit $5,890 balance. For example: includes $0 cash advance limit Ki Hi ff t MH 5 : pire EN LT ELL ai on a imated Available credit $74 and each month you pay... | statement In about... tal of... Only the minimum payment | 22 year(s) $16,310 & $8,028 $22 Sem (Savings=s8282) For information about credit counseling services, call 1-877-317-8187, 000000 VIOO AD LUCIO A AGUAYO 5929 CARMELITA AVE APTB HUNTINGTON PARK CA 90255-3357 Savings Spotlight Your Diamond Preferred Lifetime Savings: $2,149.49 See page 3 to view your Savings Summary. Pay your bill from virtually anywhere with the Cit) Moblie® App and CHP Onfine MINIMUM payment due New balance 2 To downipad: Text "AppiS' to MyCit] (692484) Payment due date or go to your device's app store. Or viskt www.citicards.com Amount enclosed: Account number ending in 6855 CITI CARDS PO 80OX 78045 Phoenix, AZ 85062-8045 15000 DOL?705 DS5A1519 D01t200 UREERENNEEEED 041.5 $177.05 $5,815.19 07/09/18 www. clticards.com Customer Service 1-800-823-4086 Page of 3 TTY-hearing-impaired services only 1-800-325-2665 LUCIO A AGUAYO Account Summary Trans, Post date date Description Amount Payments, Credits end Adjustments 056/09 PAYMENT THANK YOU -$162.64 Fees charged Total foes charged in this billing paried $0.00 Interest charged Date Description Amount 06/13 INTEREST CHARGED TO STANDARD PURCH $16.13 06/13 INTEREST CHARGED TO PUR PR-11/02/17. $102.92 Total Interest charged in this biffing perlod $119.08 2018 totals year-to-date Total fees charged In 2018 $0.00 Total Interest charged In 2018 $399.22 | Interest charge calculation © Days In billing cycle: 33 Your Annual Percentage Rute tAPR)s the annual interest rate on your account. Annuaf percentage Balance subject Balance type rate (APR) to interest rate interest charge PURCHASES . Standard Purch 29.99% (V) $594.50 (D) $1613 Pur Pr 110217 21.49% (V) $5,296.96(D) $102.92 ADVANCES | Standard Adv 29.99% (V) $0.00 (D) $0.00 Your Annual Percentage Rate (APR) is the annual Interest rate on your account, APRS followed by {V) may vary. Balances followed by (D) are determined by the dally balance method (including current transactions). Account messages SAVINGS SPOTLIGHT DETAILS INTEREST: if you have promotional balances on your account, we have estimated your savings. This savings is the difference between the interest that was assessed against the promotional balances using the promotional APRs and the estimated interest that would have been assessed against these same balances using the Enhanced Purchase APRs. This savings amount does not include any balance transfer fees, This savings is from your billing period covered by this statement. CITI EASY DEALS: If you made a purchase on Citi Easy Deals, your savings is the difference between the retail price and the price you paid. This savings is from the prior calendar month. CITI PRICE REWIND: if you received a Citi Price Rewind refund, savings is the refunded amount. This savings is from the prior calendar month, CITI DIAMOND PREFERRED LIFETIME SAVINGS: The savings from interest, Citi Easy Deals and Citi Price Rewind since you became a Citi Diamond Preferred cardmember. This savings amount does not include any balance transfer fees, Did you know that with a single phone call, a Citi Client First Account Specialist can prove you with information and options that may be available on all of your Citibank accounts? Please contact us Monday - Friday 7:00AM - 10:00PM; Saturday 7:00AM - 7:00PM; Sunday 8:00AM - T:00PM Central time at 1-866-680-8625 to speak with an Account Specialist for more information. Savings Spotlight Your Citi® Diamond Preferred® Savings Summary Cit] Diamond Preferred Lifetime Savings $2,149.49 : EE Interest: i See Account Messages for more information about Savings Spotlight Citi Easy Deals" To find out your current tier: Visit citleasydeals.com or call the number provided above, Minimurn Annual Purchases: $0.00 Coupons for local dining and shoppl Ari Po * Minimum Annual Purchases: $100 - Base tier benefit * Plus deals on gift cards and magazines » Minimum Annual Purchases: $500 » Rase and Enhanced tier benefits » Plus deals on merchandise, travel and dally deals ¢ » For complete details, go to cltieasydeals.com www.citicards.com Customer Service 1-800-823-4086 Page 3 of 3 TTY-hearing-impalred servi -800-325- LUCIO A AGUAYO g-impalred serv ces only 1-800-325-2865 Please be sure to 4 on time. If you submit your payment by mail, we suggest you ed it no later than 07/02/2018 to allow enough time for regular mail to reach us. LUCIC A AGUAYO Member Since 2014 Account number ending in: 6855 Bllfing Period:06/14/18-07/12/18 JULY STATEMENT Minimum payment due: §162.95 New balance as of 07/12/18: 55,813.51 Payment due date: 08/09/18 Late Payment Warning: If we do not recelve 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:if you make only the minimum payment each period, you will pay more In Interest and It wiil take you longer to pay off your alance. For example: If you make no additional | You will pay off the And you will end up charges using this card balance shawn on this poying &h estimated and each month you pay.. | statement in about... otal of... Only the minimum payment | 22 year(s) $16,532 $8,064 TT $224 3 year(s) (Savings=$8,468) For information about credit counseling services, call 1-877-337-8187, Pay your blif from virtually anywhere with the Cit] Mobile® App and CHP Online ge: To download: Text 'AppiS’ te MyCRI (692484) or 06 to your device's app store. Or visit www.iticards.com 000000 VIOO AD www.clticards.com Customer Service 1-800-823-4088 TTY-hearing-impaired services only 1-800-326-2865 BOX 6500 SIOUX FALLS, SD STi? Account Summary Previous balance $5,815.19 Payments $177.05 Credits -$0.00 Purchases 4870.42 Cash advances +50.00 Fees +50.00 interest +$104.95 New balance $5,813.51 Credit Limit Credit limit $5,890 includes $O cash advance limit Avaliable credit $76 Savings Spotlight Your Diamond Preferred Lifetime Savings: $2,149.49 See page 3 to view your Savings Summary. Minimum payment due New balance Payment due date Amount enclosed: Account number ending in 6855 LUCIO A AGUAYO CIT{ CARDS 5929 CARMELITA AYE PD BOX 78045 APTB Phoenix, AZ 85062-8045 HUNTINGTON PARK CA 90255-3357 15000 0OLe295 058135) 0017700 CENEEUENURERNENERP 0417 $162.95 $5,813.51 osfoe/is | www. clticards.com LUCIO A AGUAYO Account Summary Trans. Post date date Description Payments, Credits and Adjustments 07/09 PAYMENT THANK YOU Standard Purchases Customer Service 1-800-823-4086 Page 2 of 3 TTY-hearing-impalred services only 1-800-325-2865 Amount Savings Spotlight $177.05 Your Citi® Diamond Preferred® Savings Summary 07/10 07/10 76 - UNITED PACIFIC 561 BELLFLOWER CA $25.00 Citi Diamond Preferred o7/i0 07/10 EL PORTAL MEXICAN GRILL SAN DIEGO CA 510.45 Lifetime Savings oi 07/1 CHEVRON 0201934 BELLFLOWER CA $23.99 ' ; Fees charged Total fees charged In this blifing period $0.00 { interest charged : Date Description Amount oth INTEREST CHARGED TO STANDARD PURCH $14,35 orh2 INTEREST CHARGED TO PUR PR-1/02/17. $90.60 Total interest charged In this billing period $104.95 2018 totals year-to-date Total fees charged in 2018 $0.00 i Total Interest charged in 2018 $504.17 | ‘caleulation TTT om ie: 29 RE interest charge ulatio Days In bifing cycle: 2 See Account Messages Your Annual Percentage Rate (APR)IS the annuai interest rate on your account, for more information about Annual percentage Balance subject Savings Spotlight Balance type rate (APR) to interest rate interest charge PURCHASES os Standard Purch 2090% (Vv) $602.25 (D) $14.35 Citi Easy Deals” i Fr PY TIEN 2174%(V) $5245.23 (D) $9060 To find out your current tier: ADVANCES Visit citleasydeals.com or call the Standard Adv 29.99% (V) $0.00 (>) $0.00 number provided above. 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 dally balance method Deals you can access, by tier: {including current transactions). ~ Minimum Annual Purchases: $0.00 _ Coupons for local il me : ~ Minimum Asal Purchase: $100 Base tier benefit + Plus deals on gift cards and & Buh HI ET = Minimum Annuat Purchases: $500 w Base and Enhanced tier benefits ® Plus deals on merchandise, travel and daily deals » For complete detalls, go to citleasydeals.com www.citicards.com Customer Service 1-800-823-4086 i i d 1; lo -! a! LUCIO A AGUAYO TTY-hearing{mpaired services only 1-800-325-2865 Account messages SAVINGS SPOTLIGHT DETAILS INTEREST: If you have promotional balances on your account, we have estimated your savings. This savings Is the difference between the interest that was assessed against the promotional balances using the promotional APRs and the estimated interest that would have been assessed against these same balances using the Enhanced Purchase APRs. This savings amount does not include any balance transfer fees, This savings is from your billing period covered by this statement, CITIEASY DEALS: If you made a purchase on Citi Easy Deals, your savings is the difference between the retall price and the price you paid. This savings is from the prior calendar month. CIT! PRICE REWIND: If you received a Citi Price Rewind refund, savings is the refunded amount. This savings is from the prior calendar month. CiTi DIAMOND PREFERRED LIFETIME SAVINGS: The savings from interest, Citl Easy Deals and Citi Price Rewind since you became a Citi Diamond Preferred cardmember. This savings amount does not include any balance transfer fees. Did you know that with a Engle hone call, a Citi Client First Account Specialist can provice you with information and options that may be available on all of your Citibank accounts? Please contact us Monday - Friday T:00AM - 10:00PM; Saturday 7:00AM - 7:00PM; Sunday 8:00AM - 7:00PM Central time at 1-866-680-8625 to speak with an Account Specialist for more information. Please be sure to bay on time. if you submit your payment by mail, we tigoeat you ie it no later than 08/02/2018 {o allow enough time for regular mali to reach us. Page 3 of 3 LUCIO A AGUAYO Member Since 2014 Account number ending in: 6855 Billing Period:07/13/18-08/13/18 AUGUST STATEMENT Minimum payment due: $508.22 New balance as of 08/13/18: $6,031.69 Payment due date: 09/09/18 Late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to pay a Jate fee of up to $35 and your APRs may be increased up to the Penalty APR of 29.99%. Minimum Payment Warning: if you make der the minimum payment each period, you will pay more in interest and it will Lake you longer to pay off your balance. For example; if you make no additional You wiil pay off the And you wili end up charges using this card balance shown on this paying an estimated and each month you pay... | statement In about... al of... Only the minimum payment | 22 year(s) | $16,640 For Information about credit counseling services, call 1-677-337-8188, www.citicards.com Customer Service 1-800-823-4086 TTY-hearing-Impaired services only 1-800-325-2865 BOX 6500 SIOUX FALLS, 5D 57117 Your account Is past due. Please pay at least the minimum payment due, which includes a past due amount of $162.95 and an overlimit amount of $141.69. Account Summary Previous balance $5,813.51 Payments -$0.00 Credits -$0.00 Purchases +$74.60 Cash advances +$0.00 Fees +$25.00 Interest +5118,58 New balance $6,031.69 Credit Limit Credit limit $5890 Includes $0 cash advance limit Savings Spotlight Your Diamond Preferred Lifetime Savings: $2,149.49 See page 3 to view your Savings Summary. Pay your bili frem virtually anywhere 508, with the CI Moblie® App and CHP Onin MiMUM payment due $508.22 New balance $6,031.69 ze To download: Text TAppIS* to My Citi (692484) Payment due date 09/09/18 or go to your device's app store, Or visit www.citicerds.com Amount enclosed: 000000 Vi 00 AO Account number ending In 6855 LUCIO A AGUAYO CITI CARDS PO BOX T8045 RAER FARMEITA AVE Phoenix, AZ 85062-8045 HUNTINGYON PARK CA 90255-3357 15000 DD50822 DLD316T 0017700 CEEEEEENERENENEREy 0915 www.clticards.com LUCIO A AGUAYO Account Summary Trans. Post Customer Service 1-800-823-4086 TTY-heating-impaired services only 1-800-325-2865 date date Description Amount Standard Purchases orhe 07/13 SHELL OIL 57442726600 ENCINITAS CA $20.00 othe OT/13 MCDONALD'S F18327 OCEANSIDE CA $6.45 oThs 07/15 BURGERKING #11298 MAYWOOD CA $5.25 or/6 07/16 SUPERIORI43GROCERS MAYWOOD CA $30.32 o1/6 07/16 FIESTA DEL MAR MAYWOOD CA Si2.58 Fees charged Date Description Amount oBA3 LATE FEE - JUL PAYMENT PAST DUE $25.00 Tote! fees charged In this billing period $25.00 interest charged Date Description Amount 08/3 INTEREST CHARGED TO STANDARD PURCH $19.45 08/13 INTEREST CHARGED TO PUR PR-11/02/17. $95.13 $118.56 Total interest charged In this blifing period 2018 totals year-to-date Total fees charged in 2018 Total Interest charged In 2018 $25.00 $622.75 Le Interest charge calculation Your Annual Percentage Rate (APR)Is the annual Interest rate on your account. Days In billing cycle: 32 Annual patcentaye Balsnce subject PR) Balance type ate (Al to Interest rate interest charge PURCHASES Standard Purch 29.99% $739.76 (0) $19.45 Pur Pr 10217 21.74% $5,20119 (D) $99.13 ADVANCES _ Standard Adv 29.99% $0.00 (D) $0.00 Your Annual Percentage Rate (APR) is the annual interest rate on your account. APRs followed by {V) may vary. Balances followed by (D) are determined by the dally balance method (including current transactions). Page 2 of 3 Savings Spotlight Your Citi® Diamond Preferred® Savings Summary Citl Diamond Preferred Lifetime Savings E Interest: $2,149.49 See Account Messages for more information about Savings Spotlight Citi Easy Deals" To find out your current tier: Visit citieasydeais.com or call the number provided above, Deals you can access, by tier: * Minimum Annual Purchases: $0.00 Coupons for cal Aden: and dis) Enhanced Tier E - » Minimum Annual Purchiieess $100 Base tler benefit + Plus deals en gift cards and in bia CHE n Minimum Annual Purchases: $500 % Base and Enhanced tier benefits ® Plus deals on merchandise, travel and dally deals » For complete detalls, go to cltleasydeais.com www.cfticards.com Customer Service 1-800-823-4086 TY-h + i -800-325- LUCIO A AGUAYO T earing-impalred services only 1 00-325-2865 Account messages SAVINGS SPOTLIGHT DETAILS INTEREST: If you have promotional balances on your account, we have estimated your savings. This savings Is the difference between the interest that was assessed against the promotional balances using the promotional APRs and the estimated interest that would have been assessed against these same balances using the Enhanced Purchase APRs. This savings amount does not include any balance transfer fees. This savings is from your billing period covered by this statement. CITIEASY DEALS: If you made a purchase on Citi Easy Deals, your savings is the difference between the retail price and the price you paid. This savings is from the prior calendar month. CITI PRICE REWIND: If you received a Citi Price Rewind refund, savings is the refunded amount. This savings is from the prior calendar month. CITI DIAMOND PREFERRED LIFETIME SAVINGS: The savings from interest, Citi Easy Deals and Citi Price Rewind since you became a Citi Diamond Preferred cardmember. This savings amount does not inciude any balance transfer fees, 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 untif your next statement. Did you know that with a single phone call, a Citi Client First Account Specialist can provide you with information and options that may be available on all of your Citibank accounts? Please contact us Monday - Friday T:00AM - 10:00PM; Saturday 7:00AM - 7:00PM; Sunday 8:00AM - 7:00PM Central time at 1-866-680-8625 to speak with an Account Specialist for more information. Piease be sure to pay on time. If you submit your payrwnt by mail, we suggest you mail it no later than 09/02/2018 to allow enough time for reqular mail to reach us. Page 3 of 3 LUCIO A AGUAYO Member Since 2014 Account number ending in: 1943 Customer Service 1-800-823-4086 8illing Perled:08/14/18-09/13/18 www.elticards.com TTY-hearing-lmpalred services only 1-800-325-2865 BOX 6500 SIOUX FALLS, SD 57117 Your account is past due. Please pay at SEPTEMBER STATEMENT $875.10 least the minimum payment due, which Minimum payment due: 875.10 includes a past due amount of $366.53 and New balance as of 09/13/18: $6,184.63 an overlimit amount of $294.63. Payment due date: 10/09/18 +53 Account Summary Previous balance $6,031.69 Payments -80.00 Late Payment Warning: If we do not receive your minimum payment by the Credits -$0.00 date listed above, you may have to pay a late fee of up to $35 and your APRs Purchases +80.00 may be Increased up to the Penalty AFR of 28.99%. Cash advances +80.00 Minimum Payment Warning: if you make only the minimum payment each Fees +$35.00 period, you will pay more In interest and it wilt take you longer to pay off your Interest +8117.94 Since mob iE You will pay off the And you will end up New balance "80453 i n estimated . End Sach month you pay. | statement in abou | otal oie Credit Limit es Credit limit £5,890 Only the minimum payment | 21year(s) $16,383 Includes $0 cash advance Iimit For information about credit counseling services, call 1-877-337-8188. O00O0OMC 20 A0 LUCIO AAGUAYD 5929 CARMELITA AVE APT SB HUNTINGTON PARK CA 90255-3357 Savings Spotlight Your Diamond Preferred Lifetime Savings: $2,149.49 See page 3 to view your Savings Summary. Fay your oq from wictualy aha. Minimum payment due $875.10 £ wo Toons dd New balance $6,184.63 FE Text AppiE*to MyCHt! (692484) Payment due date 10/09/18 * or go to your device's app store. Or visit www.citicards.com Amount enclosed: Account number ending in 1943 CITI CARDS PO BOX 78045 Phaenix, AZ 85062-8045 15000 D0&?5L0 Db1AYL3 D0L7700 EEEECUSENNSEAEE 051: www.citlcards.com LUCIO A AGUAYD Account Summary Trans. Post date date Description Amount Fees charged Date Description Amount 09/13 LATE FEE - AUG PAYMENT PAST DUE $35.00 Total fees charged In this billing period $235.00 interest charged Date Description Amount 09/13 INTEREST CHARGED TO STANDARD PURCH $20.09 09/13 INTEREST CHARGED TO PUR PR-I1/02/17. 897.85 Totaf Interest charged In this billing period $111.94 2018 totals year-to-date Total fees charged in 2018 $60.00 $740.69 Total interest charged in 2018 et ET TT —— Interest charge calculation Days in bliifng cycle: 31 Your Annual Percentage Rate (APRNs the annua! Interest rate on your account. Annugl percentage Balance subject Balance type rate {APR} to Interest rate Interest charge PURCHASES LL Standard Purch 29.99% (V) $788.91(D) $20.09 | Pur Pr 110217 21.74% (Vv) $5.299.66(D) $97.85 ADVANCES 7 Standard Adv 999%) ~~ S000) $0.00] —— ———————— Your Annual Percentage Rate (APR) Is the annual interest rate on your account. APRs followed by {V) may vary. Balances followed by (D) are determined by the daily balance method (Including current transactions). Account messages SAVINGS SPOTLIGHT DETAILS INTEREST: If you have promotional balances on your account, we have estimated your savings. This savings is the difference between the interest that was assessed against the promotional balances using the promotional APRs and the estimated interest that would have been assessed against these same balances using the Enhanced Purchase APRs. This savings amount does not include any balance transfer fees. This savings is from your billing period covered by this statement. CITIEASY DEALS: if you made A purctise on Citi Easy Deals, your savings is the difference between the retail price and the price you paid. This savings is from the prior calendar month. ’ CITI PRICE REWIND: if you recelved a Citi Price Rewind refund, savings is the refunded amount. This savings is from the prior calendar month. CITI DIAMOND PREFERRED LIFETIME SAVINGS: The savings from interest, Citi Easy Deals and Citi Price Rewind since you became a Citi Diamond Preferred cardmember, This savings amount does not include any balance transfer fees. Please note that if we received your pay by phone or online payment between 5 fm ET and midnight ET on the last day of your billing period, your payment will not be reflected until your next statement, Customer Service 1-800-823-4086 TTY-hearing-impaired services only 1-800-325-2865 Page 20f3 Savings Spotlight Your Citi® Diamond Preferred® Savings Summary Citi Dlamond Preferred Lifetime Savings $2,149.49 £ interest: a See Account Messages for more information about Savings Spotlight Citi Easy Deals™ To find out your current tier: Visit citieasydeals.com or call the number provided above. Deals you can access, by tler: 3 BT Minimum Annual Purchases: $6.00 Coupons for local dining and shopping Antaris = Minimum Annual Purchases: $100 Base tier benefit Plus deals on gift cards and magazines ® Minimum Annual Purchases: $500 = Base and Enhanced tier benefits ¥ Plus deals on merchandise, trave! and dally deals » For complete detalls, go to citleasydeals.com www.citlcards.com Customer Service 1-800-823-4086 TTY¥-hearing-impaired services only 1-B00-325-2865 LUCIO A AGUAYO You're an important Citibank customer with multiple accounts, so we're pleased to infroduce Citi Client First - which allows you to manage all of your accounts with a single phone call. An Account Specialist is here to listen and help. All you have to do is call! Please contact us Monde - Friday 7:00AM - 10:00PM; Saturday 7:00AM - 7:00PM; Sunday B:00AM - 7:00PM Central time at 1-866-680-8625 to speak with an Account Specialist for more information. Please be sure to pay on time, If Lou submit your payment by mail, we Sufgest you mail it no later than 10/02/2018 to allow enough time for regular mail to reach us. Pagel of 3 LUCIO A AGUAYD Member Since 2014 Account number ending in: 1943 Billing Period:09/14/18-10/11/18 OCTOBER STATEMENT Minimum payment due: New balance as of 10/11/18: Payment due date: Late Payment Warning: if 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 $1,228.92 $6,330.04 11/08/18 www.clticards.com Customer Service 1-800-823-4086 TTY-hearing-impaired services only 1-800-325-2865 BOX 6500 SIOUX FALLS, SD 57117 Your account is past due, Piease pay at least the minimum payment due, which Includes a past due amount of $580.47 and an overlimit amount of $440.04. may be increased up to the Penalty APR of 29.99%, Minimum Payment Warning: if you make only the minimum payment each period, you will pay more In Interest and it wiil take you longer to pay off your balance. For example: If you make no additonal charges using this card and each month you pay... Only the minimum payment | 21 year(s) { You will pay off the balance shown on this pv statement in about... otef of... And you will end up $16,192 For informatien about credit counseling services, call 1-877-337-8188, CO00QOMC 20 A0 LUCIO A AGUAYO 5929 CARMELITA AVE APTB HUNTINGTON PARK CA 90255-3357 Fay your blil from virtually anywhere with the Citi Moblie® App and CItP Onfine cx To download: L Text 'App15* to MyCiti (692484) or go to your device's app stove. Or vist www.eiticards.com ng an estimated Account Summary Previous balance $6,184.63 Payments -$0.00 Credits $0.00 Purchases +50.00 Cash advances +$0.00 Fees +$35.00 Interest +$110.41 New balance £6,330.04 Credit Limit Credit limit $5,890 Includes $0 cash advance limit Savings Spotlight Your Diamond Preferred Lifetime Savings: $2,149.49 See page 3 to view your Savings Summary. Minimum payment due $1,228.92 New balance 56,330.04 Payment due date 11/09/16 Amount enclosed: Account number ending In 1943 CITI CARDS PC BOX 7BD45 Phoenix, AZ 85062-8045 15000 0122872 0633004 0017700 CEEEEEEREEREEEE 1 3 www.citicards.com Customer Service 1-800-823-4086 Page 2 of 3 TTY-hearing-impalred services only 1-800-325-2866 LUCIO A AGUAYD Account Summary Trans. Post date date Description Amount Fees charged Date Description Amount fo/it LATE FEE - SEP PAYMENT PAST DUE $35.00 Totel fees charged In this billing period $35.00 Interest charged Date Description Amount 10/4 INTEREST CHARGED TO STANDARD PURCH $19.41 10/1 INTEREST CHARGED TO PUR PR-11/02/T, $91.00 Total Interest changed In this bliling perlod $110.41 2018 totals year-to-date Total fees charged in 2018 $95.00 Total interest charged in 2018 $851.10 Interest charge calculation Days In billing cycle; 28 Your Annual Percentage Rate (APR)!s the annus! Interest rate on your account. Annual percentage Balance subject Interest charge Balance type rate (APR) to Interest rate : PURCHASES Standard Purch 25.99% (V) $843.64 (D) $19.41 Pur Pr #0217 21.99% (v) $5,394.06) $91.00 ADVANCES Standard Adv 29.99%(V) _ $000() _ $0.00 Your Annual Percentage Rate (APR) Is the annual interest rate on your account. APRs foliowed by {V) may vary. Balances followed by (D) are determined by the daily balance method {Including current transactions). Account messages SAVINGS SPOTLIGHT DETAILS INTEREST: if you have promotional balances on your account, we have estimated your savings. This savings is the difference between the interest that was assessed against the promotional balances using the promotional APRs and the estimated interest that would have been assessed against these same balances using the Enhanced Purchase APRs. This savings amount does not include any balance transfer fees, This savings is from your billing period covered by this statement. CITI EASY DEALS: If you made a purchase on Citi Easy Deals, your savings is the difference between the retail price and the price you paid. This savings is fromthe prior calendar month. CITI PRICE REWIND: if you received a Citi Price Rewind refund, savings is the refunded amount. This savings is from the prior calendar month, CITI DIAMOND PREFERRED LIFETIME SAVINGS: The Savings from interest, Citi Easy Deals and Citi Price Rewind since you became a Citi Diamond Preferred cardmember. This savings amount does not include any balance transfer fees, Please note that if we received your pay by phone or online payment between 5 p.m. ET and midnight ET on the (ast day of your billing period, your payment will not be reflected until your next statement. If you have not received your new card, please calf the Customer Service number on this statement. 5 Savings Spotlight Your Citi® Diamond Preferred® Savings Summary Citt Diamond Preferred Lifetime Savings $2,149.49 £ Interest: See Account Messages for more Information about Savings Spotlight Citi Easy Deals" To tind out your current tier: Visit citieasydeals.com or call the number provided above. Deals you can access, by tier: Minimum Annual Purchases: $0.00 Coupons for local dining and shopping Enhanceddier. Minimum Annual Purchases: $100 Base tier benefit t Pius deals on gift cards and magazines Ely . = Minimum Annual Purchases: $500 x Base and Enhanced tier benefits ® Pius deals on merchandise, travel and dally deals » For complete detalls, go to cltieasydeals.com www.elticards.com Customer Service 1-800-823-4086 TTY-hearing-impalred services only 1-800-325-2865 LUCIO A AGUAYO Your account is currently past due. To avoid account closure and loss of charging privileges, please make your minimum payment on or before the due date. As a Client First customer we can discuss repayment options that you may qualify for on all your various Citibank accounts with a single phone call. Please contact us Monday - Friday 7:00AM - 10:00PM; Saturday 7:00AM - 7:00PM; Sunday 8:00AM - 7:00PM Central time at 1-877-362-0171 to speak with an Account Specialist for more information. Please be sure to bay on time. If you submit your payment by mail, we suggest you mall it no later than 11/02/2018 to allow enough time for regular mail to reach us. Page 3 of 3 LUCIO A AGUAYD Member Since 2014 Account number ending In: 1943 Billing Perlod:10/12/18-1/13/18 NOVEMBER STATEMENT Minimum payment due: $1,630.24 New balance as of 11/13/18: $6,498.70 Payment due date: 12/09/18 See LU back of this statement for important Information about how to avoid paying Interest on purchases. Late Payment Warning: if 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 Penaity APR of 29.9944, Miniraum Payment Warning: (f you make only the minimum payment each perlod, you will pay more In interest and It wii! take you longer to pay off your balance. For example: If you make no additional } Yau wlll pay off the And you wil end up charges using this card { balance shown on this paving an estimated and each month you pay.. | statement in about... otai of... Only the minimum payment | 21 year(s) | $15,915 For information about credit counseling services, call 1-877-337-8188. O0000OMC 20A 0 LUCIO A AGUAYO 5929 CARMELITA AVE APTB HUNTINGTON PARK CA 90255-3357 Pay your biif from virtually anywhere with the Citi Moblie® App end CHP Online Ei To downioads Text "Appi5™ to MyCit] (652464) or go to your device's app store, Or visit www.clticards.com www.clticards.com Customer Service 1-800-823-4086 TTY hearing-impaired services only 1-800-325-2865 BOX 6500 SIOUX FALLS, SD 57117 Your account Is past due. Please pay at least the minimum payment due, which includes a past due amount of $788.88 and an overfimit amount of $608.70. Account Summary Previous balance $6,330.04 Payments -£0.00 Credits -$0.00 Purchases +80.00 Cash advances +$0.00 Fees +535.00 Interest +$133.66 New balance $6,498.70 Credit Limit Credit limit $5,890 inciudes $0 cash advance imit Savings Spotlight Your Diamond Preferred Lifetime Savings: $2,149.49 See page 3 to view your Savings Summary. Minimum payment due $1,630.24 New balance $6,498.70 Payment due date 12/09/18 Amount enclosed: Account number ending in 1943 CITI CARDS PO BOX 78045 Phoenix, AZ 85062-8045 15000 03b3084 DbLY9870 DOL?700 AEEIRENEENEENERSD [145149 www.citlcards.com LUCIO A AGUAYC | Customer Service 1-800-823-4086 Page of 3 TTY-hearing-impalred services only 1-800-325-2865 important Changes to Your Account Terms "Detalls About the Changes“below, The following Is a summary of changes being made to your account terms. These changes will take effect on 01/12/19. For more information, please see You have the right to reject these changes. However, if you reject these changes, you will no longer be able to use your account for new transactions. You can reject the changes by calling us at 1-866-915-9424 by otfizhe. Revised Terms as of 01/12/19 Late Fee Up to 539 Returned Payment Fee Up to §39 Details About the Changes: The following paragraphs replace the corresponding paragraphs in Section 4 of your Card Agreement in the "Fees section. Late Fee: Up to $39. We have the right to charge you a late fee If you don't pay at least an amount equal to the Minimum Payment Due minus any Overlimit Amount by the payment due date. The late fee is $28 and, if you make another Late Payment Within the next 6 Billing Periods the late fee will be $39. The amount of your late fee will never be higher than your Minimum Payment Due. Returned Payment Fee:Up to $39. We have the right to charge you a Returned Payment fee of $28 if your bank doesn't honor your payment. If that happens, we'll resubmit the payment request. if your bank doesn't honor another payment within 6 consecutive Billing Periods, the Returned Payment fee will go up to $39. This amends your Card Agreement. Please keep this information for future reference. Account Summary Trans. Post date date Description Amount Fees charged Date Description Amount nha LATE FEE - OCT PAYMENT PAST DUE $35.00 Total fees charged In this bllling period $35.00 interest charged Date Description Amount nz INTEREST CHARGED TO STANDARD PURCH $24.92 13 INTEREST CHARGED TO PUR PR-N/02A17. $109.24 Total Interest charged In this billing period $133.66 2018 totals year-to-date Total fees charged In 2018 $130.00 | Total Interest charged In 2018 $984.76 | Savings Spotlight Your Citi® Diamond Preferred® Savings Summary Citi Diamond Preferred Lifetime Savings FE interest: $2,149.49 See Account Messages for more information about Savings Spotlight Citi Easy Deals” To find out your current tier: Visit citieasydeals.com or call the number provided above. Deals you can access, by tier: Min mum Annual Purchases: $0.00 Coupons for focal dining end shopping Anan ae ~ Minimum Annual Purchases: $100 Base tier benefit Plus deals on gift cards and magazines Jee. a = Minimum Annuat Purchases: $500 ® Base and Enhanced tier benefits = Pius deals on merchandise, travet and daily deals » For complete detalls, go to cltieasydeals.com Customer Service 1-800-823-4086 www. citicards.com LUCIO A AGUAYD TTY-hearing-impalred services only 1-800-325-2865 Interest charge calculation Days In biling cycle: 33 Your Annual Percentage Rate {APR)Is the annual Interest rate on your account. Bal Annual percentage Balance subject ance type | rate (APR) to interest rate Interest charge PURCHASES Standard Purch 29.99% (V) $900.51(D) $24.42 Pur Pr 110217 21.99% (v) $5,494.09(0) $105.24 ADVANCES Standard Adv 29.99% (V) $0.00 (D) $0.00 Your Annus! 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 SAVINGS SPOTLIGHT DETAILS INTEREST: if you have promotional balances on your account, we have estimated your savings. This savings Is the difference between the interest that was assessed against the promotional balances using the promotional APRs and the estimated interest that would have been assessed against these same balances using the Enhanced Purchase APRs. This savings amount does not include any balance transfer fees. This savings is from your billing period covered by this statement. CITt EASY DEALS: If you made a purchase on Citi Easy Deals, your savings is the difference between the retail price and the price you paid. This savings is from the prior calendar month. CITI PRICE REWIND: lf you received a Citi Price Rewind refund, savings is the refunded amount. This savings is from the prior calendar month. CITI DIAMOND PREFERRED LIFETIME SAVINGS: The savings from interest, Citi Deals and Citi Price Rewind since you became a Citi Diamond Preferred cardmember. This savings amount does not include any balance transfer fees. Your account is currently past due. To avoid account closure and loss of charging privileges, please make your minimum payment on or before the due date. As a Client First customer we can discuss repayment options that you may qualify for on all your various Citibank accounts with a single phone call. Please contact us Monday - Friday 7:00AM - 10:00PM; Saturday 7:00AM - 7:00PM; Sunday 8:00AM - 7:00PM Central time at 1-877-362-0171 to speak with an Account Specialist for more information. If we need to contact you about your account, our records show Lyour Fone number(s) as 323-562-0860 (home), 562-867-5155 (work), 323-770-2939 (mobile). If this Information isn't correct, please call the customer service number on the back of your card or update it online at www.citicards.com. Please be sure to Ld on time. If Jou submit your payment by mail, we Suge you nel it no later than 12/02/2018 te allow enough time for regular mail fo reach us. ©2018 Citibank, N.A. ) Citi, Citi with Arc Design are registered service marks of Citigroup Inc, Page3of3 LUCIO A AGUAYD Member Since 2014 Account number ending In:1943 Billing Period:11/14/18-1213/18 DECEMBER STATEMENT Minimum payment due: New balance as of 12/13/18: Payment due date: See the back of this statement for important information paying Interest on purchases. . $2,016.96 $6,658.56 01/09/19 about how to avoid Late Payment Warning: If 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 29.95%. Minimum Payment Warning: If you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your alance. For example: If you make no additional | You will pay off the And you will end up charges using this card bafance shown on this pe fing a estimated oO re and each month you pay.. . statement In about... Only the minimum payment | 20 year(s) $15,437 For information about credit counseling services, call 1-877-337-8188, Fay your bil from virtually anywhere with the Cit Moblie® App and CIP Online ize To downlodd: Text ‘App1S* to MyCIti (692484) www.clticards.com Customer Service 1-800-823-4086 TTY-hearing-impaired services only 1-800-325-2865 BOX 6500 SIOUX FALLS, SD 57117 Your account is past due. Please pay at least the minimum payment due, which Includes a past due amount of $1021.54 and an overlimit amount of $768.56. Account Summary Previous balance $6,498.70 Payments -$0.00 Credits -$0.00 Purchases +$0.00 Cash advances +$0.00 Fees +$35.00 Interest +$124.86 New balance $6,658.56 Credit Limit Credit limit $5,890 Includes $0 cash advance limit Savings Spotlight Your Diamond Preferred Lifetime Savings: $2,149.49 See page 3 to view your Savings Summary. Minimum payment due $2,016.96 New balance $6,658.56 Payment due date 01/09/19 oF go to your device's app store. Or viskt www.clticands.com Amount enclosed: Account number ending in1943 000000 MC 32A0 LUCIO A AGUAYO CITI CARDS 5929 CARMELITA AVE PO BOX 78045 APTB Phoenix, AZ 85062-8045 HUNTINGTON PARK CA 50255-3357 15000 0201b9b ObL585L O0L7700 UNEEEEEREREEEEEE 0517 www.citicards.com LUCIO A AGUAYO Account Summary Trans. Post date date Description Amount Fees charged Date Description Amount 12/13 LATE FEE - NOY PAYMENT PAST DUE $35.00 Total fees charged in this billing period $35.00 Interest charged Date Description Amount z2/m INTEREST CHARGED TO STANDARD PURCH $23.85 2/3 INTEREST CHARGED TO PUR PR-11/02A7. $101.21 Total interest charged In this biting perlod $124.86 | 2018 totals year-to-date Total fees charged in 2018 $165.00 Total interest charged in 2018 $1,109.62 interest charge calculation Days In billing cycle: 30 Your Annual Percentage Rate (APR}!s the annual Interest rate on your account. Annual Dastantane Balance subject APR) to interest rate Balance type rate ( Interest charge PURCHASES Standard Purch 29.99% (V) $959.53 (D) $23.65 Pur Pr 110217 21.99% (V) $5,599.31(D) $101.21 ADVANCES Standard Ady o. 299% $0000) $0.00 Your Annual Percentage Rate (APR) Is the annual Interest rate on your account. APRs followed by (V) may vary. Balances foliowed by (D) are determined by the daliy balance method (including current transactions). Account messages SAVINGS SPOTLIGHT DETAILS INTEREST: If you have promotional balances on your account, we have estimated your savings. This savings is the difference between the interest that was assessed against the promotional balances using the promotional APRs and the estimated Interest that would have been assessed against these same balances using the Enhanced Purchase APRs. This savings amount does not include any balance transfer fees. This savings is from your biling period covered by this statement. CITIEASY DEALS: If you made a purchase on Citi Easy Deals, your savings is the difference between the retail price and the price you paid. This savings is {rom the prior calendar month. CITI PRICE REWIND: if you received a Citi Price Rewind refund, savings is the refunded amount. This savings is from the prior calendar month. CITI DIAMOND PREFERRED LIFETIME SAVINGS: The savings from interest, Citi Easy Deals and Citi Price Rewind since you became a Citi Diamond Preferred cardmember. This savings amount does not include any balance transfer fees. 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 statement. Customer Service 1-800-823-4086 TTY-hearing-impaired services only 1-800-325-2865 Page20f3 Savings Spotlight Your Citi® Diamond Preferred® Savings Summary Cit] Dlamond Preferred Lifetime Savings B Interest: $2,149.49 See Account Messages for more information about Savings Spotlight E t rr 1 S A A R RA R te r e m www. citicards.com Customer Service 1-800-823-4086 TTY-hearing-impalred services only 1-800-325-2865 LUCIO A AGUAYO Please be sure to pay on time. if you submit your payment by mall, we pect you mail it no later than 01/02/2019 to allow enough time for regular mail to reach us. ©2018 Citibank, N.A. . » Citi, Citi with Arc Design are registered service marks of Citigroup inc. Pagel of 3 LUCIO A AGUAYD Member Since 2014 Account number ending In: 1943 Billing Period:12/14/18-01/1/19 JANUARY STATEMENT Minimum payment due: $2,404.94 New balance as of 01/11/19: $6,818.55 Payment due date: 02/09/19 See the back of this statement for Important information about how to avoid paying interest on purchases. Late Payment Warning: If 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 {0 the Penaity APR of 25.99%, Minimum Pay Warning: If 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: It you make no additional | You will pay off the i And you will end up charges using this card balance shown on this paying an estimated statement in about... otal of... end each month you pay... Only the minimum payment | 19 year(s) | $15,212 For information about credit counseling services, call 1-877-337-8188, Pay your blll from virtually anywhere with the Ctl Moblie® App and CHP Online Za: To download: (i Text 'Appi5* to MyCitl (692484) or go to your device's app store, Or visit www.cRicards.com www.citicards.com Customer Service 1-800-823-4086 TTY-hearing-impalred services only 1-800-325-2865 BOX 6500 SIOUX FALLS, SD 57117 Your account is past due, Please pay at least the minimum payment due, which includes a past due amount of $1248.40 and an overlimit amount of $928.55, Account Summary Previous balance $6,658.56 Payments $0.00 Credits -80.00 Purchases +$0.00 Cash advances +$0.00 Fees +$35.00 Interest +8124.99 New balance $6,818,558 Credit Limit Credit limit $5,890 Includes $0 cash advance limit Savings Spotlight Your Diamond Preferred Lifetime Savings: $2,149.49 See page 3 to view your Savings Summary. Minimum payment due $2,404.94 New balance £6,818.55 Payment due date 02/09/19 Amount enclosed: Account number ending In1943 CO000O MC 32 AD LUCIO A AGUAYO 5929 CARMELITA AVE APT 8B HUNTINGTON PARK CA 90256-3357 15000 D24049Y4 DbA1855 0017700 mien 0415 CIT CARDS PO BOX 78048 Phoenix, AZ B5062-B045 | Customer Service 1-800-823-4086 Page2 of 3 www.clticards.com TTY-hearing-impaired services only -B00-325-2865 LUCIO A AGUAYO Account Summary Trans. Post date date Description Amount Savings Spotlight Fees charged Your Citi® Diamond Preferred® Date Description Amount oi/1t LATE FEE - DEC PAYMENT PAST DUE $35.00 Savings Summary Total fess charged In this billing period $35.00 Citl Diamond Preferred Lifetime Savings interest charged ¥ Interests $2,149.49 Date Description Amount ; oy INTEREST CHARGED TO STANDARD PURCH $24.27 oi INTEREST CHARGED TC PUR PR-1/02A7. $100.72 Tots! interest chargad In this billing period $124.99 2019 totals year-to-date Total fees charged In 2019 $35.00 Total Interest charged In 2019 $124.99 Interest charge calculation Days In biliing cycle: 29 Your Annual Percontege Rate (APR)Is the annual interest rate on your account, Annus percentage Balance subject Balance type rate (APR} to Interest rate interest charge ; PURCHASES Standard Purch 29.99% (V) $1,018.47 (D) $24.27 Pur Pr 10217 22.24% (V) $5,700.24 (D) $100.72 & & B : e¢ Accou essages ADVANCES for more information about Standard Adv 2999%() $0000) $0.00 Savings Spotlight Your Annual Percentage Rate (APR) Is the annual interest rate on your account, APRs folfowed by (V) may vary. Balances followed by (D) are determined by the dally balance method (including current transactions). Account messages SAVINGS SPOTLIGHT DETAILS INTEREST: If you have promotional balances on your account, we have estimated your savings. This savings is the difference between the interest that was assessed against the promotional balances using the promotional APRs and the estimated interest that would have been assessed against these same balances using the Enhanced Purchase APRs. This savings amount does not include any balance transfer fees. This savings is from your billing period covered by this statement. CITIEASY DEALS: If you made a purchase on Citi Easy Deals, your savings is the difference between the retail price and the price you paid. This savings is {rom the prior calendar month. CITI PRICE REWIND: If you received a Citi Price Rewind refund, savings is the refunded amount. This savings is from the prior calendar month. CITI DIAMOND PREFERRED LIFETIME SAVINGS: The savings from interest, Citi Easy Deals and Citi Price Rewind since you became a Citi Diamond Preferred cardmember. This savings amount does not include any balance transfer fees. Please note that if we received your pay by phone or online payment between 5 pan ET and midnight ET on the last day of your billing period, your payment will not be reflected until your next statement. www.clticards.com Customer Service 1-800-823-4086 ‘F a “ w jo » LUCIO A AGUAYO TY-hearing Impaired services only 1-800-325-2865 Please be sure to pay on time. if you submit your payment by mall, we suggest you Hh it no later than 02/02/2019 to allow enough time for regular mail to reach us. ©2018 Citibank, N.A. Citi, Citi with Arc Design are registered service marks of Citigroup Inc. Page30f3 LUCIO A AGUAYO Member Since 2014 Account number ending In:1943 Billing Perlod:01/12/19-02/13/19 FEBRUARY STATEMENT www.citicards.com Customer Service 1-800-823-4086 TTY-hearlng-Impaired services only 1-800-325-2865 BOX 6500 SIOUX FALLS, SD 57117 Your account is past due, Please pay at least the minimum payment due, which Minimum payment due: . 6,964.64 includes a past due amount of $1476.39 and New balance as of 02/13/19: 6,964.64 an overlimit amount of $1074.64 Payment due date: tor] 03/09/19 0% See the back of this statement for Important Information about how to avoid Account Summary paying inierest on PUT Previous balance $6,818.55 Payments $0.00 Late Payment Warning: if we do not receive your minimum payment by the Credits -$0.00 date listed above, you may have to pay a late fee of up to $35 and your APRs Purchases +$0.00 may be increased up to the Penalty APR of 29.99%. Cash advances +$0.00 Minimum Payment Warning:(f you make only the minimum payment each Fees +$0.00 period, you will pay mere In interest and it will take you longer to pay off your Interest +$146.09 balance, For example: le Ealnnos $5,964.64 Charon veing (ots cord | Bence Doon ants | And you wil and up, ges nN i and each moth You pay... | statement in about.. Rota oi Credit Limit aes - Credit limit $5,890 | io Only the minimum payment | 1 month(s) | $6,965 Forinformation about credit counseling services, cali 1-877-337-8188. Pay your blll from virtuslly anywhere with the Cit] Moblie® App and CP Online vse To dowhioad: ( Text *AppiS* to MyCitl (692404) or go to your device's app store. Or visit www.citicards com 000000OMC 32 A0 Includes $0 cash advance limit Savings Spotlight Your Diamond Preferred Lifetime Savings: $2,149.49 See page 3 to view your Savings Summary. Minimum payment due $6,964.64 New balance $6,964.64 Payment due date 03/09/19 Amount enclosed: Account number ending in 1943 LUCIO A AGUAYOD 5929 CARMELITA AVE APT B HUNTINGTON PARK CA 90255-3357 15000 Ob9bYbY4 ObTbYk4 0017700 EREREREEREEEREEES 0519 CITi CARDS PO BOX 78045 | Phoenix, AZ B5062-8045 www.citicards.com Customer Service 1-800-823-4086 Page20f3 TTY-hearing-impalred services only 1-800-325-2865 LUCIO A AGUAYD Account Summary Trans. Post date date Description Amount Fees charged Total fess charged in this blifing period $0.00 Interest charged Date Description Amount 02/13 INTEREST CHARGED TO STANDARD PURCH $29.29 02/3 INTEREST CHARGED TO PUR PR-11/02/17. $16.80 Total interest charged In this bliling period $146.09 2019 totals year-to-date Total fees charged in 2015 $35.00 Tota! interest charged in 2019 $27.08 | Interest charge calculation Days In biling cycle: 33 Your Annual Percentage Rate (APR)Is the annual Interest rate on your account. e Balance subject Annual percent Balance type rete {APR) fo interest rate Interest charge PURCHASES Standard Purch 29.99% (Vv) $1,080.20 (D) $29.29 pur priiozi 22.24% (v) $5,808.91(D) $116.80 ADVANCES Standard Adv 29.98% (V) $0.00 @) §0.00 Your Annual Percentage Rate (APR) is the annual Interest rate on your account. APRs followed by (V) may vary. Balances followed by (D) are determined by the daily balance method {including current transactions). Account messages SAVINGS SPOTLIGHT DETAILS INTEREST: If you have promotional balances on your account, we have estimated your savings. This savings is the difference between the interest that was assessed against the promotional balances using the promotional APRs and the estimated interest that would have been assessed against these same balances using the Enhanced Purchase APRs. This savings amount does not include any balance transfer fees. This savings is from your billing period covered by this statement. CITI EASY DEALS: If you made a purchase on Citi Easy Deals, your savings is the difference between the retail price and the price you paid. This savings is from the prior calendar month. CITI PRICE REWIND: If you received a Citi Price Rewind refund, savings is the refunded amount, This savings Is from the prior calendar month. CITI DIAMOND PREFERRED LIFETIME SAVINGS: The savings from interest, Citi Easy Deals and Citi Price Rewind since you became a Citi Diamond Preferred cardmember. This savings amount does not include any balance transfer fees. Please note that if we received your pay by Phone or onfine 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 statement. Please be sure to bay on time. If you subrnit your payment by mail, we suggest you mail It no later than 03/02/2019 to aliow enough time for regular mail to reach us. Savings Spotlight Your Citi® Diamond Preferred® Savings Summary Citi Dlamond Preferred Lifetime Savings $2,149.49 E interest: See Account Messages for more Information about Savings Spotiight www. clticards.com Customer Service 1-800-823-4086 Page3of3 TTY: X i -800-325- LUCIO A AGUAYO Y-hearing-impaired services only 1 800-325-2865 ©2018 Citibank, N.A. Citi, Citi with Arc Design are registered service marks of Citigroup Inc. 0 0 9 bs Ww O N — p s - 12} 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE I am employed in the County of Orange. My business address is 110 E. Wilshire Ave., Ste. 212, Fullerton, CA 92832, where the mailing occurred. Iam over the age of 18 years and am not a party to this cause. Iam readily familiar with the practices of Winn Law Group, A Professional Corporation for collection and processing of correspondence for mailing with the United States Postal Service. Such correspondence is deposited with the United States Postal Service the same day in the ordinary course of business. On April 23, 2020, I served the document in this action bearing the title: REQUEST FOR ADMISSIONS (SET ONE) by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Lucio A Aguayo 5929 Carmelita Ave Apt B Huntington Park CA 90255-3357 I placed such envelope for collection and mailing on this date following ordinary business practices. Executed on April 23, 2020, at Fullerton, California. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. e— 4 Freddie Montenegro Legal Secretary Page 4 REQUEST FOR ADMISSIONS; PROOF OF SERVICE 1 | Brian N. Winn (State Bar No. 86779) Laura M. Hoalst (State Bar No. 101082) 2 | John E. Gordon (State Bar No. 180053) 3 || Jason M. Burrows (State Bar No. 309882) Amit Taneja (State Bar No. 304559) 4 Il Grace Gail Cara (State Bar No. 315558) 5 || Cherrie Y. Tan (State Bar No. 324871) Katrina Trinh (State Bar No. 327357) 6 || Juan Villanueva (State Bar No. 328049) Winn Law Group, A Professional Corporation 7 | 110 E Wilshire Ave Ste 212, Fullerton CA 92832 g || Telephone: (714) 446-6686, Fax No.: (714) 446-6680 File No: 19-12526-0-DI1-FMM- (1910-00) 9 || Attomeys for Plaintiff 10 11 SUPERIOR COURT OF CALIFORNIA 12 LOS ANGELES COUNTY 13 CAVALRY SPVILLC, 14 Case No. 19NWLC46884 15 Plaintiff, vs SPECIAL INTERROGATORIES 16 (SET ONE) LUCIO A AGUAYO, ET AL. 17 "LIMITED CIVIL MATTER" 18 ‘ Defendant(s), 19 50 || REQUESTING PARTY ............ PLAINTIFF, CAVALRY SPV ILLC 21 | RESPONDING PARTY ........ DEFENDANT, LUCIO A AGUAYO AKA LUCIO 22 || ALONSO AGUAYO AKA LUCIO AGUAYO 23] SETNUMBER.............. A ONE gy Please answer or otherwise respond to each of the following special interrogatories within 26 30 days after service of this document on you: 27 4 HI 28 Page 1 SPECIAL INTERROGATORIES; PROOF OF SERVICE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1. (Hereinafter, "request" refers to and means "a request for the admission of a fact which is made by plaintiff in Set One of Plaintiff's Request for Admissions, dated April 23, 2020 and served herewith.") For each of your responses that is not an unqualified admission, please state all facts upon which you base that response, identifying that response by reference to the number of the request to which it is made. 2. For each of your responses that is not an unqualified admission, please state the name, address, and telephone number of all persons who have knowledge of the facts supporting your response, identifying that response by reference to the number of the request to which it is made. 3. For each of your responses that is not an unqualified admission, please identify all documents which support your response, identifying that response by reference to the number of the request to which it is made. WINN LAW GROUP, A P.C. Dated: April 23, 2020 — = [ ) Brian N. Winn [ ] Laura M. Hoalst { 1 John E. Gordon [ ] Jason M. Burrows Amit Taneja [ 1 Grace Gail Cara [] Cherrie Y. Tan [ 1 Katrina Trinh { ] Juan Villanueva Attorney for PLAINTIFF Page 2 SPECIAL INTERROGATORIES; PROOF OF SERVICE 1 2 3 4 5 6 7 8 9 10 11 12 I 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE I am employed in the County of Orange. My business address is 110 BE. Wilshire Ave., Ste. 212, Fullerton, CA 92832, where the mailing occurred. Iam over the age of 18 years and am not a party to this cause. Iam readily familiar with the practices of Winn Law Group, A Professional Corporation for collection and processing of correspondence for mailing with the United States Postal Service. Such correspondence is deposited with the United States Postal Service the same day in the ordinary course of business. On April 23, 2020, I served the document in this action bearing the title: SPECIAL INTERROGATORIES (SET ONE) by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Lucio A Aguayo 5929 Carmelita Ave Apt B Huntington Park CA 90255-3357 . ~~ I'placed such envelope for collection and mailing on this date following ordinary business practices. Executed on April 23, 2020, at Fullerton, California. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Freddie Montenegro Legal Secretary Page 3 SPECIAL INTERROGATORIES; PROOF OF SERVICE DISC-004 ATTORNEY CR PARTY WITHOUT ATTORNEY (Name, Stale Bar number, and address): 110 E. WILSHIRE AVENUE TELEPHONE NO: 714-446-6686 FAX NO. (Optonaly 714-446-6680 E-MAIL ADDRESS (Options): ATTORNEY FOR (Name) PLAINTIFF FULLERTON, CA 92832 BRIAN N. WINN (State Bar No.: 86779) WINN LAW GROUP A P.C 12720 Norwalk Blvd Norwalk CA 90650 SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles SHORT TITLE: CAVALRY SPVILLC v LUCIO A AGUAYO Asking Party: CAVALRY SPVILLC Answering Party: LUCIO A AGUAYO Set No.: ONE FORM INTERROGATORIES—LIMITED CIVIL CASES (Economic Litigation) CASE NUMBER: 19NWLC46884 Sec. 1. Instructions to All Parties (a) Interropatories are written questions prepared by a parly to an action that are sent to any other party in the action to be answered under oath. The Interrogatories below are form interrogatories approved for use in economic litigation. {b} For time limitations, requirements for service on other parties, and other details, see Code of Civil Procedure sections 2030.010-2030.410 and the cases construing those sections. (c) These form interrogatories do not change existing law relating to interrogatories, nor do they affect an answering party's right to assert any privilege or make any objection. Sec. 2. Instructions to the Asking Party {a) These interrogatories are designed for optional use by parties under economic litigation in limited civil cases. See Code of Civil Procedure sections 90 through 100. However, these interrogatories also may be used in unlimited civil cases. {b) There are restrictions on discovery for most limited civil cases. These restrictions limit the number of interrogatories that may be asked. For details, read Code of Civil Procedure section 94. {c} Some of these interrogatories are similar to questions in the Case Questionnaire for Limited Civil Cases (form DISC-010) and may be omifted if the Information sought has already been provided in a completed Case Questionnaire. (d) Check the box next to each interrogatory that you want the answering party to answer. Use care in choosing those interrogatories that apply to the case and are within the restrictions discussed above. {e) You may Insert your own definition of INCIDENT in Section 4, but only where the action arises from a course of conduct or a series of events occurring over a period of time. (H The interrogatories in section 116.0, Defendant's Conten- tions - Personal injury, should not be used until defendant has had a reasonable opportunity fo conduct an investigation or discovery of plaintiff's injuries and damages. {g) Additional Interrogatories may be attached, subject to the restrictions discussed above. Sec. 3. Instructions to the Answering Party {2) Subject to the restrictions discussed above, you must answer or provide another appropriate response to each interrogatory that has been chacked helow. Form Approved for Optional Uss Jusiclel - Council of California DISCO [Rev. January 1, 2007) {b} As ageneral rule, within 30 days efter you are served with these interrogatories, you must serve your responses on the asking party and serve copies of your responses on all other parties who have appeared. See Code of Civil Procedure sections 2030.260-2030.270 for details. (c} Each answer must be as complete and straight-forwerd as the information reasonably avaliable to you permits. If an interrogatory cannot be answered completely, answer it to the extent possible. (d)} If you do not have enough personal knowledge to fully answer an interrogatory, say so, but make a reasonable and good faith effort to get the information by asking other persons or organizations, uniess the Information Is equally available to the asking party. (e) Whenever an interrogatory may be answered by referring to a document, the document may be attached as an exhibit to the response and referred to in the response. If the document has more than one page, refer to the pege and section where the answer to the interrogatory can be found. (f) Whenever an address and telephone number for the same person are requested in more than one interrogatory, you are required to furnish them in answering only the first interrogatory asking for that information. (g) Your answers to these interrogatories must be verified, dated, and signed, You may wish to use the following form at the end of your answers: I declare under penalty of perjury under the laws of the State of California thet the foregoing answers are true and correct. FORM INTERROGATORIES - LIMITED CIVIL CASES {Economic Litigation) (DATE) Sec. 4. Definitions Words in BOLDFACE CAPITALS in these interrogatories are defined as follows: {Check one of the following): (a) [v] (1) INCIDENT includes the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding. (SIGNATURE) Page tof d Coats of Givi Procedure, §§ 84, 2030.010-2030.410, 2033,710 [] (2) INCIDENT means (insert your definition here or on a separate, altached sheet labeled "Sec. 4(e) (2)7): (b} YOU OR ANYONE ACTING ON YOUR BEHALF includes you, your agents, your employees, your Insurance companies, their agents, their employees, your attorneys, your accountants, your investigators, and anyone else acting on your behalf. {c) PERSON Includes 2 natural person, firm, assoclation, organization, partnership, business, trust, corporation, or public entity. {d} DOCUMENT means a wiking, as defined in Evidence Code section 250, and includes the original or a copy of hand- writing, typewriting, printing, photostating, photogrephing, electronically stored information, and every other means of recording upon any tangible thing and form of communicating or representation, Including letters, words, pictures, sounds, or symbols, or combinations of them, {8) HEALTH CARE PROVIDER Includes any PERSON referred to in Code of Civit Procedure section 667.7(e)3). {f) ADDRESS means the street address, including the city, state, and zip code. Sec. 5. interrogatories The following interrogatories have been approved by the Judicial Councll under Code of Civil Procedure section 2033.710: CONTENTS 101.0 Identity of Persons Answering These interrogatories 102.0 General Background information - individual 103.0 General Background Information - Business Entity 104.0 Insurance 105.0 [Reserved] 106.0 Physical, Mental, or Emotional Injuries 107.0 Property Damage 108.0 Loss of Income or Earning Capacity 108.0 Other Demages 110.0 Medical History . 111.0 Other Claims and Previous Claims 112.0 investigation - General 113.0 [Reserved] 114.0 Statutory or Regulatory Violations 115.0 Claims and Defenses 116.0 Defendant's Contentions - Personal Injury 117.0 [Reserved] 120.0 How the incident Occurred - Motor Vehicle 1250 [Reserved] 130.0 [Reserved] 135.0 {Reserved] 150.0 Contract 160.0 [Reserved] 170.0 [Reserved] 101.0 Identity of Persone Answering These Interrogatories 101.1 State the name, ADDRESS, telephone number, and relationship to you of each PERSON who prepared or assisted in the preparation of the responses {0 these interrogatories. {Do not identify anyone who simply typed or reproduced the responses.) DISCQ04 (Rev. Janudey 1, 2007] DISC-004 102.0 General Background Information - Individual 102.1 State your nee, any other names by which you have been known. and your ADDRESS. 102.2 State the date and place of your birth. 102.3 State, as of the time of the INCIDENT, your driver's license number, the state of issuance, the expiration date, and any restrictions. 102.4 State each residence ADDRESS for the last five years and the dates you lived at each ADDRESS. 102.5 State the name, ADDRESS, and telephone number of each employer you have had over the past five years and the dates you worked for each. [] 102.6 Describe your work for each employer you have had over the past five years. [1] 102.7 State the name and ADDRESS of each academic or vocational school you have attended, beginning with high school, and the dates you attended each, J 102.8 If you have ever been convicted of a felony, state, for each, the offense, the date and place of conviction, and the court and case number. [ 102.9 State the name, ADDRESS, and telephone number of any PERSON for whom you were acting as an agent or employee at the time of the INCIDENT. ] 102.10 Describe any physical, emotional, or mental disability or condition that you had that may have contributed to the occurrence of the INCIDENT. [1 102.11 Describe the nature and quantity of any alcoholic beverage, marijuana, or other drug or medication of any kind that you used within 24 hours before the INCIDENT. 103.0 General Background Information - Business Entity [1 103.1 State your cument business name and ADDRESS, type of business entity, and your title. 104.0 Insurance 1 104.1 State the name and ADDRESS of each insurance company and the policy number and policy limits of each policy that may cover you, In whole or in part, for the damages related to the INCIDENT. 105.0 [Reserved] 106.0 Physical, Mental, or Emotional Injuries [] 106.1 Describe each injury or finess related io the INCIDENT. LC] 106.2 Describe your present complaints about each Injury or iliness related {o the INCIDENT. in 106.3 State the neme, ADDRESS, and telephone number of each HEALTH CARE PROVIDER who treated or examined you for each injury or illness related to the INCIDENT and the dates of treatment or examination. FORM INTERROGATORIES-LIMITED CIVIL CASES Page 2otd {Economic Litigation) [7] 106.4 State the type of treatment or examination given to you by each HEALTH CARE PROVIDER for each injury or liness related 10 the INCIDENT. [] 108.5 State the charges made by each HEALTH CARE PROVIDER for each Injury or illness related to the INCIDENT. [[] 106.6 State the nature and cost of each health care service related to the INCIDENT not previously listed (for example, medication, ambulance, nursing, prosthetics). [7] 106.7 State the nature and cost of the health care services you anticipate in the future as a result of the INCIDENT. [C] 108.8 State the name and ADDRESS of each HEALTH CARE PROVIDER who has advised you that you may need future health care services as a result of the INCIDENT. 107.0 Property Damage ] 107.1 Remize your property damage and, for each item, state the amount or atlach an temized bill or estimate. 108.0 Loss of Income or Earning Capacity 1 108.1 State the name and ADDRESS of each employer or other source of the earnings or income you have lost as a result of the INCIDENT. [] 108.2 Show how you compute the aamings or income you have lost, from each employer or other source, as a result of the INCIDENT, [T] 108.3 State the name and ADDRESS of each employer or other source of the eaamings or income you expect to lose in the future as a result of the INCIDENT. [1 108.4 Show how you compute the earnings or income you expect to lose in the future, from each employer or other source, as the result of the INCIDENT. 109.0 Other Damages [] 108.1 Describe each other tem of damage or cost thei you attribute to the INCIDENT, stating the dates of occurrence and the amount. 110.0 Medical History ] 110.1 Describe and give the date of each complaint or injury, whether occurring before or after INCIDENT, that involved the same part of your body claimed to have been injured in the INCIDENT. [1 110.2 State the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER who examined or treated you for each Injury or complaint, whether occurring before or sfter the INCIDENT, that involved the same part of your body claimed to have been injured in the INCIDENT and the dates of examination or treatment. DISC-004 111.0 Other Claims and Previous Claims [J 111.1 entity each personal injury claim that YOU OR ANYONE ACTING ON YOUR BEHALF have made within the past ten years and the dates. ] 111.2 State the case name, court, and case number of each personal Injury action or claim filed by YOU OR ANYONE ACTING ON YOUR BEHALF within the past ten years. 112.0 Investigation - General [1 112.1 State the name, ADDRESS, and telephone number of each individual who has knowledge of facts relating to the INCIDENT, and specify his or her area of knowledge. [7] 112.2 State the name, ADDRESS, and telephone number of each Individual who gave a written or recorded statement relating to the INCIDENT and the date of the statement. ] 112.3 State the name, ADDRESS, and telephone number of each PERSON who has the original or a copy of a written or recorded statement relating to the INCIDENT. [] 112.4 identify each document or photograph that describes or depicts any place, object, or indivicual conceming the INCIDENT or plaintiff's injuries, or attach a copy. {if you do not attach a copy, state the name, ADDRESS, and telephone number of each PERSON who had the original document or photograph or a copy.) [J 112.5 identity each other item of physical evidence that shows how the INCIDENT occurred or the nature or extent of plaintiff's injuries, and state the location of each item, and the name, ADDRESS, and telephone number of each PERSON who has it. 113.0 [Reserved] 114.0 Statutory or Regulatory Violations 114.1 If you contend that any PERSON involved in the INCIDENT violated any statute, ordinance, or regulation and that the violation was a cause of the INCIDENT, identify each PERSON and the statute, ordinance, or regulation, 115.0 Claims and Defenses [] 115.1 State In detall the facts upon which you base your claims that the PERSON asking this interrogatory is responsible for your damages. 115.2 State in detall the facts upon which you base your contention that you are not responsible, in whole or In part, for plaintiff's damages. [J 115.3 State the name, ADDRESS, and the telephone number of each PERSON, other than the PERSON asking this interrogatory, who is responsible, in whole or in part, for damages claimed in this action. “DISCE54 Rev. Janiscy 1, 2007] FORM INTERROGATORIES-LIMITED CiVil. CASES Page 30fd {Economic Litigation) 116.0 Defendant's Contentions - Personal Injury [Sea Instruction 2(f)] J 116.1 If you contend that any PERSON, other than you or plaintiff, contributed to the occurrence of the INCIDENT or tha injuries or damages claimed by plaintiff, state the name, ADDRESS, and telephone number of each individual who has knowledge of the facts upon which you base your contention. ] 116.2 If you contend that plaintiff wes not injured in the INCIDENT, state the name, ADDRESS, and telephone number of each individual who has knowledge of the facts upon. which yot base your contention. [J 116.3 if you contend that the injuries or the extent of the injuries claimed "by plaintiff were not caused by the INCIDENT, state the name, ADDRESS, and telephone number of each individual who has knowledge of the facts upon which you base your contention. ] 116.4 if you contend that any of the services fumished by any HEALTH CARE PROVIDER were not related to the INCIDENT, state the name, ADDRESS, and telephone number of each individual who has knowledge of the facts upon which you base your contention. ] 116.5 If you contend that any of the costs of services fumished by any HEALTH CARE PROVIDER were unreasonable, identify each service that you dispute, the cost, and the HEALTH CARE PROVIDER. 116.6 If you contend that any part of the loss of earnings or income claimed by plaintiff was unreasonable, identify each part of the loss that you dispute and each source of the income or earnings, J 116.7 H you contend that any of the properly damage claimed by plaintiff was not caused by the INCIDENT, identify each item of properly damage that you dispute. 1186.8 If you contend that any of the costs of repairing the properly damage claimed by plaintiff were unreasonable, identify each cost item that you dispute. ] 11 6.8 if you contend that, within the last ten years, plaintiff made a claim for personal injuries that are related to the injuries claimed in the INCIDENT, identify each related injury and the date. 1 116.10 If you contend that, within the past ten years, plaintiff made a claim for personal injuries that are related to the injuries claimed in the INCIDENT, state the name, court, and case number of each action filed. 117.0 {Reserved} 120.0 How the Incident Occurred - Motor Vehicle [C] 120.1 State how the INCIDENT occurred. [J 120.2 For each vehicle involved in the INCIDENT, stete the year, make, model, and license number. [J 120.3 For each vehicle involved In the INCIDENT, state the name, ADDRESS, and telephone number of the driver. DISC004 (Rev. January 1, 2007) FORM INTERROGATORIES-LIMITED CIVIL CASES {Economic Litigation) DISC-004 [LJ 1204 For each vehicle involved in the INCIDENT, state the name, ADDRESS, and telephone number of each occupant other than the driver. . 120.5 For each vehicle involved in the INCIDENT, state the name, ADDRESS, and telephone number of each regis- tered owner. 120.6 For each vehicle involved in the INCIDENT, state the name, ADDRESS, and telephone number of each lessee. [J 120.7 For each vehicle involved in the INCIDENT, state the name, ADDRESS, and telephone number of each owner other than the registered owner or lien holder. [] 120.8 For each vehicle involved In the INCIDENT, state the name of each owner who gave permission or consent to the driver io operate the vehicle. 150.0 Contract 150.1 identify all DOCUMENTS that are part of the agreement and for each state the name, ADDRESS, and telephone number of the PERSON who has each DOCU- MENT. 150.2 State each part of the agreement not In writing, the name, ADDRESS, and telephone number of each PERSON agreeing to that provision, and the date that pant ofthe agreement was made. 160.3 Identify all DOCUMENTS that evidence each part of the agreement not in writing, and for each stats the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. [] 150.4 Identfy all DOCUMENTS that are pani of each mod- fication to the agreement, and for each state the name ADDRESS, and telephone number of the PERSON who has each DOCUMENT. [7] 150.5 state each modification not in writing, the date, and the name, ADDRESS, and telephone number of the PERSON agreeing to the modification, and the date the modification was made. [[] 150.6 Identify all DOCUMENTS that evidence each modification of the agreement not in writing and for each state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. Ol 150.7 Describe and give the date of every act or omission that you claim Is a breach of the agreement. 150.8 (dentify each agreement excused and state why per- formance was excused. 150.9 Identify each agreement terminated by mutual agree- ment and state why it was terminated, including dates. 150.10 Identify each unenforceable agreement and state the facts upon which your enswer Is based, 1 150.11 Identify each ambiguous agreement and state the facts upon which your answer Is based. Pagod of 4 W o 9 a y A Ww 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE I'am employed in the County of Orange. My business address is 110 B. Wilshire Ave., Ste. 212, Fullerton, CA 92832, where the mailing occurred. 1am over the age of 18 years and am not a party to this cause. Iam readily familiar with the practices of Winn Law Group, A Professional Corporation for collection and processing of correspondence for mailing with the United States Postal Service. Such correspondence is deposited with the United States Postal Service the same day in the ordinary course of business. On April 23, 2020, I served the document in this action bearing the title; FORM INTERROGATORIES (SET ONE) by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Lucio A Aguayo 5929 Carmelita Ave Apt B Huntington Park CA 90255-3357 I placed such envelope for collection and mailing on this date following ordinary business practices. Executed on April 23, 2020, at Fullerton, California. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Freddfe Montenegro Legal Secretary Page s FORM INTERROGATORIES; PROOF OF SERVICE AB A A A LUCIO A AGUAYO 5929 CARMELITA AVE APT B HUNTINGTON PARK CA 90255-3357 WW 0 0 3 O N Wn Hh O W N ) e e B R O N N N N N R O N O N m m m s e m pe p d ek m d e m pe e p m «© J AN Bs W R =m O O 0 N Y R W em o O EXHIBIT “B" (Discovery Demand Letter) BRIAN N. WINN WINN LAW GROUP POST OFFICE BOX 1216 FULLERTON, CALIFORNIA 92836 LAURA McCARTHY BOALST JOHN E. GORDON TELEPHONE: (714) 446-6686 JASON M. BURROWS A PROFESSIONAL CORPORATION Toll Free oir Febeigs AMIT TANEJA FAX: (714) 446-6680 GRACE GAIL CARA CHERRIEY. TAN THE CHAPMAN BUILDING E-MAIL: Info@winnlawgroup,com KATRINA TRINH 110 E. WILSHIRE AVE, SUITE 212 JUAN VILLANUEVA FULLERTON, CA 92832-1109 June 3, 2020 Lucio A Aguayo 5929 Carmelita Ave Apt B Huntington Park CA 90255-3357 Case: CAVALRY SPV |, LLC vs. LUCIO A AGUAYO, et al. Court & Case No: Norwalk Court, I9NWLC46884 Dear Sir/Madam: On April 23, 2020, on behalf of CAVALRY SPV I, LLC, pursuant to C.C.P. § 2033, we requested that LUCIO A AGUAYO admit the genuineness of documents and/or the truth of facts. (Copy enclosed.) To date, we have not received defendant’s response. Under section 2033.280(b), Defendant waived their right to object to any of the requests we propounded on behalf of our client. Accordingly, we now demand that fey serve us with their response to request for admissions on or before June 18, 2020 WITHOUT OBJECTION. Notice: "The requesting party may move for an order that the genuineness of any documents and the truth of any matters specified in the requests be deemed admitted, as well as for a monetary sanction under Chapter 7 (commencing with Section 2023.010). The court shall make this order, unless it finds that the arty to whom the requests for admission have been directed has served, before the hearing on the motion, a proposed response to the requests for admission that is in substantial com atice with Section 2033.220. It is mandatory that the court impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) on the party or attorney, or both, whose failure to serve a timely response to requests for admission necessitated this motion." (C.C.P. § 2033.230 (b) and (c).) THIS LAW FIRM IS A DEBT COLLECTOR, AS DEFINED BY 15 U.S.C. 1692(a)(6), AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED BY US WILL BE USED FOR THAT PURPOSE. Sincerely yours, Winn Law Group, A P.C. [ ] Brian N. Winn [ )/Laurg M. Hoalst [ 1] John E. Gordon [ Jason M. Burrows { 1 Amit Taneja [ 1 Grade Gail Cara [ 1 Cherrie Y. Tan [ 1 Rayrina Trinh [1 Juan Villanueva JEG: FMM FILE NO: 19-12526-0-RAD © 0 N N hh BR W N es B R O N N N N N O N N N N m r m em mm ed e m pe e m ee s WW N y n n A W N = C Y N Y Dd W N m o PROOF OF SERVICE I am employed in the County of Orange. My business address is 110 E. Wilshire Avenue, Suite 212, Fullerton, CA 92832, where the mailing occurred. 1am over the age of 18 years and am not a party to this cause. Iam readily familiar with the practices of Winn Law Group, A Professional Corporation for collection and processing of correspondence for mailing with the United States Postal Service. Such correspondence is deposited with the United States Postal Service the same day in the ordinary course of business. On July 14, 2020, I served the document in this action bearing the title: NOTICE OF AND MOTION TO DEEM FACTS AS ADMITTED. MEMORANDUM OF POINTS AND AUTHORITIES AND SUPPORTING DECLARATION; AND REQUEST FOR ATTORNEY FEES OF $200.00 PLUS FILING FEE OF $60.00 by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Lucio A Aguayo 5929 Carmelita Ave Apt B Huntington Park CA 90255-3357 I placed such envelope for collection and mailing on this date following ordinary business practices. Executed on July 14, 2020, at Fullerton, California. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. = Freddie M Montenegro Legal Secretary Page § MOTION TO DEEM FACTS AS ADMITTED/PROOF OF SERVICE Make a Reservation | Journal Technologies Court Portal https://portal-lasc journaltech.com/public-portal/?q=calendar/reserv. Journal Technologies Court Portal Make a Reservation CAVALRY SPV, LLC, AS ASSIGNEE OF CITIBANK, N.A., vs LUCIO A AGUAYO Case Number: 19NWLC46884 Case Type: Civil Limited Category: Collections Case - Purchased Debt (Charged Off Consumer Debt Purchased on or after January 1,2014) Date Filed: 2019-12-02 Location: Norwalk Courthouse - Department A Reservation Case Name: CAVALRY SPV |, LLC, AS ASSIGNEE OF CITIBANK, Case Number: N.A., vs LUCIO A AGUAYO 19NWLC46884 Type: Status: Motion to Deem RFAs Admitted RESERVED Filing Party: CAVALRY SPV |, LLC, as assignee of CITIBANK, N.A,, Location: {Plaintiff Norwalk Courthouse - Department A Date/Time: Number of Motions: 11/19/2020 10:30 AM 1 Reservation ID: Confirmation Code: 780185136084 CR-RWDYFTWYSRCZWF6DR Fees Description Fee Qty j Amount, Motion to Deem RFAs Admitted 60.00 1 60.00 Credit Card Percentage Fee (2.75%) 1.65 1 : 165 TOTAL $61.65 ; Payment Amount: Type: $61.65 MasterCard Account Number: Authorization: XXXX8430 50261Q ~ ¥4 Print Receipt i + Reserve Another Hearing | A View My Reservations | Tof2 7/14/2020, 9:11 AM
