Declaration CCP 1033Cal. Super. - 6th Dist.April 27, 2021Electronically Filed by Superior Court of CA, County of Santa Clara, on 8/12/2021 10:20 AM Reviewed By: A. Villanueva Case #21CV381053 Envelope: 7047679 21CV381053 Santa Clara - Civil A. Villanueva l6 l7 l8 l9 20 2| 22 23 24 25 26 27 28 Matthew W. Quall #l 83759 Ranject K. Brat, #297142 Tiffany A. Pack, #323159 Claudia Yvette Case, #328212 Ingrid V. Cacro, #3 l 7349 QUALL CARDOT, LLP 205 E. River Park Cimlc Suite 110 Fresno, CA 93720 (888) 289-123] Phone (559) 418-0330 Fax Attorneys for Plaintiff SUPERIOR COURT 0F CALIFORNIA COUNTY OF SANTA CLARA CAVALRY SPV I. LLC, CASE N0. 21CV381053 DECLARATION REGARDING CODE OF plainfim CIVIL PROCEDURE § 1033 V. P VANTRAN .an individual, and DOES l to 100, inclusive, Defendants. I, the undersigned anomey, hereby declare as follows: 1. I am an attorney duly admitted to practice before all of the courts of the State o California and am an attorney in the law firm of Quall Cardot, LLP, attorneys of record herein f0] Plaintifi‘ in the abovc-captioned action. 2. Pn'or to the initiation of this action. Defendant was sent a notice that if a lawsuit wafi initiated on this claim, that the Defendant could be held to pay court costs. A copy of this letter is attached hereto and incorporated herein. I declare under penalty of pcljury under the laws of the State of California that thc foregoing is true and correct. Executed on 8 [7 [1 ‘ at Fresno, California. 4A1 {kW. Tiffany A: Pack: Esq'.Wm, Esq. IngriHreaet-o, Esq. Declaration Regarding CCP§ l033 - l CARDOT Attorneys at Law 205 East Riva- Park Circle, Suite 110 Fresno, California 93720 Phone: 888-289-1231 Fax: 559-418-0330 APR 20 2021 P VAN TRAN 2645 SBELIUS AVE SAN JOSE CA 95122-1344 '3“ GUALL ab Re: Charge-Ofi‘Creditor: Dcpmmwm Stores Nafional Bank Currmt Creditor: CAVALRY SPV I, LLC Account No.-00$ Our Reference No. 21840632 Amount Due: $4,879.33 DeflPVANTRAN: NOTICE 0F INTENTION T0 FILE LAWSUIT Thiscomrnmficafionisfiomadebtcollecmr.'I'hisiunattanptmocollectadebtandanyinfoxmaflon obm'nndwillbeusedfonhatpmpose. We have hem retained by CAVALRY SPV I, LLC file owner ofthe above Mameed account, to collect fiom you the entirc balance on an accoImt you held with Depamnmt Stores Nafional Bank, AccountNumba-loos (the “Accomm. CAVALRY spv I, LLC is the owner of the Account. The outstanding balance on your account is $4,879.33. Please be advised that Current Creditor: CAVALRY SPV I, LLC intends tomm its clnim for payment of the above-referenced Account through the filing of a lawsuit against you. Pursuant to California Code of Civil Procedure Section lO33(b)(2), this lens advises you that Curmt Creditor: CAVALRY SPV I, Lm intmds to pursue lifigafion against you in Santa Clam County Superior Court of California and mat me litigation could result in ajudynmt against you which may include court costs and nmary disbursmwnts as pamiaed by Section 1033(b)(2), all of which you couldbmme responsible Ens all ed under California applicable law. Quall mcm “Manhewwauam 1mmxnm[ 1WyAJackmwquvmom ]1ngidV.Cm “Notice: See ravage side for inmortmt information.” The California Consumm' Privacy Act (CCPA) requires that we disclose the categories ofpmnal information we typically collect about a consumer. Those categories are: (a) personal idwtifying informau'on, like name, address and bank amount number, us well as other idmtifying information, which we obtain fi'am the oonsuma’s creditor, aedit rcpmts and Omar shp trace tools, and thc comma", (b) health insurance hformation, which we obtain fiom the consumer's «editor or the consumer. ifwe are collecu’ng medical debt; (c) characta'istics such as age, geodet, etc., which we obtain fiom the consumer’s creditor and consumer‘s credit report; (d) mil information, which we obm'n fi-om the oonsuma’s auditor and the consuma‘s «edit report; (e) internet activity, which we collect iffix:comma visim our website or payment portal; (t) gaolocm'on and GPS data, whidl we obtfin fiom process savers; (g) recording, whichm madewhm the consumer has a tclqhonc oonvasafion with us; (h) professional and employmem telated informau'on. which we obtain fiom the comet‘s creditor, creditmporu'ngagencies, andothasfiptmoeaoumea; (i) educational infomuu'on, which weohm fium the consumers creditor, audit repoflin:um“, and other skip unce sources; and G) biomcu'ic information, including but mt limited no physical descripu'ons Ind photos, which we obtain fiumthe consumer’s aeditotnndpmcess mifflnmisahwafigaswell asvoiceptints (aufio recoding) when the consume has a telephone convasan‘on wifll us. All of the information mat is collected will be used for debt oollecfion pulpows. Our privacy policies can be fmmd at www.quanwdotcom/pfivacy-policy. Quall Cmdot, LLP does not and will not sell pasonal information. The CCPA also allows consumus to requmt that businesses delete information that is collected, and also provides for some exceptions. Quail Carder, LLP believes that it fills within an exception. If you wish to request the categories of infmmation or the actual information we have collected about you, or wish to requw dclcu'on, please call us at 1-833-777-6978 or download our request form at www.quallcardot.mmlprivacy-policy and email the completed form to us at info@ www.quallcardotcom. To request this notice be pmvidcd inm altunuu'vc format, please call us at 1-833-177-6978 email us at info@ www.quallcudotoom.
