`NYSCEF DOC. NO. 6
`
`INDEX NO. 2021-4
`
`RECEIVED NYSCEF: 05/18/2021
`
`AFFIDAVIT
`DEBT
`
`OF FACTS
`BUYER
`
`AND PURCHASE
`PLAINTIFF
`(Debt
`
`OF ACCOUNT
`Buyer
`
`Actions)
`
`BY
`
`The
`
`undersigned,
`
`being
`
`duly
`
`sworn,
`
`deposes
`
`and
`
`say:
`
`I am an authorized
`1.
`of Cavalry
`representative
`I, LLC,
`("Plaintiff")
`electronics
`books
`and
`Plaintiff's
`records
`("Business
`Records"),
`records,
`including
`J BROWN . The
`of WILLIAM
`the Account
`four
`digits
`last
`account
`of
`("Account")
`knowledge
`of Plaintiff's
`have
`personal
`I also
`In my position,
`************4701.
`its procedures
`and maintaining
`its Business
`Records,
`including
`creating
`Records
`Business
`Plaintiffs
`of consumer
`assignment
`credit
`accounts.
`to make
`of business
`business
`course
`and it was the regular
`course
`of such
`the events
`recorded.
`Business
`were made
`at or near
`of
`Records
`the time
`knowledge
`the facts
`of Plaintiff's
`I have
`of
`set
`forth
`personal
`
`and I have
`
`access
`to
`to the
`relating
`are
`number
`for
`procedures
`and
`to the purchase
`relating
`in the
`regular
`were made
`the Business
`Records.
`The
`knowledge
`Based
`on my
`in this
`affidavit.
`
`SPV
`
`Records,
`
`On September
`from Citibank,
`the Account
`or was assigned
`Plaintiffpurchased
`2.
`9, 2019,
`its interest
`all of
`in the Account,
`N.A.
`that
`"Purchase").
`At
`(the
`assigned
`time, Citibank,
`including
`the right
`As part
`of
`the Purchase,
`Business
`Records
`to any proceeds
`from the Account,
`to Plaintiff.
`were
`to Account
`transferred
`the Purchase,
`those
`Business
`Records
`to Plaintiff.
`relating
`were maintained
`in the ordinary
`course
`of Plaintiff's
`
`Following
`Business.
`
`N.A.
`
`3.
`follows:
`
`The
`
`complete
`
`chain
`
`of
`
`title,
`
`with
`
`the
`
`date
`
`of each
`
`sale
`
`or assignment
`
`of
`
`the Account,
`
`is as
`
`Citibank,
`
`N.A.
`
`September
`
`9, 2019
`
`a.
`b.
`c.
`
`4.
`balance
`
`$0.00,
`
`At
`time, Defendant
`this
`owes
`of $3,745.65,
`post-charge-off
`less post-charge-off
`credits
`
`$3,668.16
`interest
`or payments
`
`amount
`on the Account.
`includes
`This
`fees
`post-charge-off
`of $0.00,
`and
`of Defendant
`by or on behalf
`made
`
`the charge-off
`and
`charges
`of $77.49.
`
`of
`
`deponent
`WHEREFORE,
`costs
`and
`disbursements
`
`judgment
`demands
`this
`action.
`
`of
`
`against
`
`Defendant
`
`for
`
`$3,668.16,
`
`together
`
`with
`
`the
`
`statements
`
`are true
`
`and
`
`correct
`
`to the
`
`best
`
`of
`
`y knowledge
`
`of
`
`intiff's
`
`business
`
`The
`above
`records.
`
`Dated
`
`By
`
`-
`
`S
`of
`
`orn
`
`o before me this1
`\
`, 20
`-,
`
`n
`
`day
`
`Notary
`
`Publi
`
`21488315
`
`Mietiel Saa
`NOTARYPUBUC)STATEOFNEWYORK
`RegistrationNo.01SAM01992
`Qualifiedin WestchesterCounty
`CommissionExpires12_3'2023
`
`1 of 1
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