DeclarationCal. Super. - 6th Dist.November 23, 2020Electronically Filed by Superior Court of CA, County of Santa Clara, on 3/18/2021 11:44 AM Reviewed By: D Harris Case #20CV373911 Envelope: 6061154 20CV373911 Santa Clara - Civil D Harris Christopher D. Mandarich SB 220693 MANDARICH LAW GROUP, LLP P.O. Box 109032 Chicago, IL 60610 Phone: 877.285.4918 Facsimile: 818.888.1260 Attorneysfor Plaintifi’: LVNVFunding LLC SUPERIOR COURT OF CALIFORNIA COUNTY 0F SANTA CLARA ) Case No.2 20CV373911LVNV Funding LLC, ) 8 Plaintiff, g 9 ) DECLARATION PURSUANT TO CODE VS- ) 0F CIVIL PROCEDURE §1033 10 Hongngoc V Luu, ) Defendant. ) 11 ) ) 12 I declare as follows: 13 1. I am the attorney ofrecord for the Plaintiff. I have personal knowledge of the facts 14 set forth herein, and if called as a witness I would and could so testify competently. l5 2. Attached as Exhibit “A” is a true and correct copy of the letter which was mailed 16 t0 the Defendant advising of Plaintiff’s intent to file suit in the Superior Court pursuant to CCP § 1 033. 1 7 I declare under penalty ofperjury that the forgoing is true and correct under the laws of the 18 State of California, 19 Executed at Chicago, Illinois on March 4, 2021 2 0 21 MANDARICH LAW GROUP, LLP 22 JU/M23 p ' _ [X] Chrlstopher D. Mandarich 2 4 Attorneysfor Plaintifif LWV V Funding LLC 2 5 2 6 27 2 8 DECLARATION PURSUANT T0 CCP 1033 EXHIBIT A Pe-ase-v-y-IRe' MANDARICH LAw GROUP, LLP nggnggmggfiggjgggggP.O. Box 109032 Chicago, IL 60610 P: 877.285.4918 Attorneys at Law PRACTICE IN THE FOLLOWING STATES: F: 818.888.1260 Alaska, California, Connecticut, www.mandarichlaw.com District of Columbia, Florida, Georgia, You may also contact us via email at Idaho, Illinois, Iowa, Kansas, Michigan, |NFO@MANDARICHLAW.COM Missouri, Nebraska, Nevada, New October 30, 2020 York, North Carolina, Ohio, Oregon, South Carolina, Virginia, Washington OF COUNSEL Thomas M. McGreal (CA, HI) Crystal Flynn (UT) Sent via US Mail Hongngoc V Luu 3900 Moorpark Ave Apt 162 San Jose CA 951 17-1834 Current Creditor: LVNV Funding LLC Our File No.: 4354538 Original Creditor: Citibank, NA. ' ' ' XXXXXXXXXXXX3624 Current Balance Due: $4,0 1 9.50 Charge Off Date 10/24/20 1 7 NOTICE OF INTENTION TO SUE AND INCUR COSTS Dear Hongngoc V Luu, We represent LVNV Funding LLC. If we are unable to resolve this matter within ten (10) days of the date of this letter, our client has authorized us to file a lawsuit to collect the balance owing on the above-referenced account. You are hereby notified that pursuant to California Code of Civil Procedure Section 1033, should legal action result in a judgment against you, you may also be found liable for various court costs, including, but not limited to, filing fees and service ofprocess fees. Please give this matter your prompt attention and contact our office toll-free at 877.285.491 8. Sincerely, Mandarich Law Group, LLP THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE- USED FOR THAT PURPOSE. SEE REVERSE SIDE OR ATTACHED FOR AN IMPORTANT STATEMENT OF YOUR RIGHTS. l||||||lNllllllllllllllfllllflllllllllllllWlillHNlllNlUlHIll) IMPORTANT NOTICE OF RIGHTS We are required under state and/or federal law(s) t0 notify consumers of certain rights. This list does not include a complete list of rights you may have under state or federal laws or regulations. Federal Law or other state laws may also provide you with similar 0r even greater rights. In California: The state Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt Collection Practices Act require that, except under unusual circumstances, collectors may not contact you before 8 a.m. or after 9 p.m. They may not harass you by, using threats 0f violence or arrest or by using obscene language. Collectors may not use false or misleading statements or call you at work if they know or have reason to know that you may not receive personal calls at work. For the most part, collectors may not tell another person, other than your attorney or spouse, about your debt. Collectors may contact another person to confirm your location 0r enforce a judgment. For more information about debt collection activities, you may contact The Federal Trade Commission at 1-877-FTC-HELP or www.ftc.gov. As required by law, you are hereby notified that a negative credit report reflecting on your credit record may be submitted by the creditor to a credit reporting agency if you fail to fulfill the terms of your credit obligations. Mandarich Law Group, LLP | P.O. Box 109032 Chicago, IL 60610, | 877.285.4918’/
