CITY COURT CITY OF SCHENECTADY COUNTY OF SCHENECTADY STATE OF NEW YORK

Cavalry SPV I, LLC, As Assignee of GE Money Bank , Plaintiff, v. John Doe, Defendant. NOTICE TO ADMIT Court Index No. ###

The Defendant JOHN DOE (Defendant) pursuant to New York CPLR Article 31, requests that Plaintiff CAVALRY SPV I, LLC (Plaintiff), answer the following interrogatories separately, fully and completely, in writing and under oath within twenty (20) days of service hereof:

DEFINITIONS
A. B. C. D. E. F. Acquiring Bank: A bank that contracts with merchants to accept, process, and settle credit card transactions. Associations: The organizations that provide rules, advertising, and settlement services. Authorization: The process of obtaining permission from the issuing bank to accept the card for payment. Cardholder: A person to Whom a cardholder has been issued. Cardholder Agreement: A written, legal contract between the issuer and the cardholder. It contains the terms of the account and a schedule of various fees. Fedwire: The Federal Reserve Banks (FRB) nationwide real-time gross settlement electronic funds and securities transfer network. It is a credit transfer system. Each funds transfer is settled individually against an institutions reserve or clearing account on the books of the Federal Reserve. The issuing bank pays the Association using Fedwire. To use Fedwire, a bank must hold an account at the Federal Reserve Bank and settlement is drawn from the account. The issuing bank makes payments by sending a message over Fedwire that authorizes the Federal Reserve Bank to electronically debit the banks Federal Reserve Bank account for the net settlement amount and transfer

the funds to the settlement bank. The transfers are essentially instantaneous. The settlement bank then pays the merchant bank using Fedwire. G. Interchange: The exchange of transaction data, information, and money between acquiring and issuing institutions participating in a payment network and in accordance with the Associations by-laws and rules. Issuers: Financial institutions that supply (issue) cards to cardholders for use in performing transactions. Merchants: Sellers of goods, services, and/or other information who accept credit cards as payment for these items. They have a signed merchant agreement to honor credit cards and display the service mark. Merchant Processing: The routing of electronic transmissions from merchants through the payment network for clearing and settlement. It is a separate and distinct business line from credit card issuing. Merchant processing activity is, for the most part, off-balance sheet and involves gathering sales information from the merchant, collecting funds from the issuing bank, and paying the merchant. Point-of-Sale Transactions: Face-to-Face transactions in which the cardholder uses the physical card at a merchants physical place of business. Securitization: The process by which financial assets are transformed into securities. Securitized Trust: A trust into which receivables have been transferred. Settlement: As the card sales transaction value moves from merchant to acquiring bank to issuer, each party buys and sells the sales ticket. Settlement is what occurs when the acquiring bank and the issuer exchange funds during that process.

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REQUESTS FOR ADMISSIONS

1. 2. 3. 4. 5. 6. The Defendant did not request that the Plaintiff issue the credit card referred to in the Plaintiffs Complaint. The Defendant did not request that The Plaintiffs assignor issue the credit card referred to in the Plaintiffs Complaint. The Plaintiff is not a merchant. The Plaintiffs assignor is not a merchant. The Plaintiff is not an acquiring bank. The Plaintiffs assignor is not an acquiring bank. 2

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The Plaintiff does not have in its possession a cardholder agreement executed by the Defendant. The Plaintiffs assignor does not have in its possession a cardholder agreement executed by the Defendant. The Plaintiff has no personal knowledge of any point-of-sale transactions involving the Defendant and the credit card account referenced in the Complaint. The Plaintiffs assignor has no personal knowledge of any point-of-sale transactions involving the Defendant and the credit card account referenced in the Complaint. The Plaintiff did not authorize Fedwire to debit its account an amount equal to $2,764.93 in order to settle the charges referenced in the Complaint. The Plaintiffs assignor did not authorize Fedwire to debit its account an amount equal to $2,764.93 in order to settle the charges referenced in the Complaint. The Plaintiff did not sell or deliver any goods to the Defendant as alleged in the Complaint. The Plaintiffs assignor did not sell or deliver any goods to the Defendant as alleged in the Complaint. The Plaintiff did not suffer any damages as a result of any breach of payment by the Defendant. The Plaintiffs assignor did not suffer any damages as a result of any breach of payment by the Defendant. The Plaintiff did not lend the Defendant an amount equal to $2,764.93. The Plaintiffs assignor did not lend the Defendant an amount equal to $2,764.93. The Plaintiff has no evidence that the Defendant promised to pay the Plaintiff as alleged in the complaint. The Plaintiffs assignor has no evidence that the Defendant promised to pay the Plaintiff as alleged in the complaint. The Defendant did not receive an amount equal to $2,764.93 from the Plaintiff. The Defendant did not receive an amount equal to $2,764.93 from The Plaintiffs assignor.

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The Plaintiff transferred the receivable arising from the credit card account to a Securitized Trust, resulting in the securitization of the receivable. The Plaintiffs assignor transferred the receivable arising from the credit card account to a Securitized Trust, resulting in the securitization of the receivable. The Plaintiff received an amount equal to $2,764.93 from the securitization of the receivable in exchange for the transfer of the subject credit card account receivable. The Plaintiffs assignor received an amount equal to $2,764.93 from the securitization of the receivable in exchange for the transfer of the subject credit card account receivable. Dated: April 8, 2013 .. John Doe, Defendant Pro Se Address Phone No.

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TO: Richard Roe Attorney for Plaintiff