Consumer complaint received 2025-05-22 00:00:00
Product: Debt collection — Credit card debt
Issue: False statements or representation — Attempted to collect wrong amount
Company: CITIBANK, N.A.
State: CA

Complaint narrative:
XXXX XXXX XXXX XXXX. 

XXXX XXXX XXXX. 

XXXX XXXX XXXXXXXX XXXX XXXXXXXX ( XXXX ) XXXX | XXXX XX/XX/XXXX VIA EMAIL TO : XXXX CC : XXXX ( General Counsel, XXXX XXXX XXXX ), et al. 

XXXX XXXX XXXX and XXXX XXXX XXXX XXXX XXXX XXXX. 

( Ultimate Successor-in-Interest to XXXX XXXX XXXX XXXX ) XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX : XXXX & FINAL PRE-LITIGATION DEMAND IMMEDIATE AND FULL COMPENSATION REQUIRED FOR EXTENSIVE DAMAGES ARISING FROM XXXX XXXX XXXX / XXXX XXXX XXXX 'S CALCULATED FRAUDULENT LITIGATION, PERVASIVE FDCPA & XXXX VIOLATIONS, UNLAWFUL RETALIATION, SYSTEMIC CORPORATE MISCONDUCT, AND CONTINUED OBSTRUCTION BY SUCCESSOR ENTITIES IN XXXXXXXX XXXX XXXX XXXX ( XXXX XXXX XXXX vs. XXXX ) Full Amount Demanded for Comprehensive Pre-Litigation Settlement of All Claims : {$100000.00} Dear XXXX XXXX, This letter constitutes an ultimate, final, exhaustive, and unequivocally comprehensive pre-litigation demand directed to you, as President and Chief XXXX XXXX of XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX as XXXX XXXX parent company and successor-in-interest, bears full, direct, and non-delegable legal and financial responsibility for the severe and extensive liabilities incurred by its acquired subsidiary, XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX I demand immediate payment of the full sum of {$100000.00} to compensate for the profound and multi-faceted damages inflicted upon me over more than XXXX years. These damages stem directly from a meticulously documented, calculated scheme involving extrinsic fraud upon the XXXX XXXX XXXX XXXX and myself ; flagrant and persistent violations of the XXXX Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692 et seq. ; violations of XXXX XXXX XXXX  Fair Debt Collection Practices Act ( XXXX ), XXXX. XXXX. XXXX XXXX et seq. ; unlawful retaliation ; and other egregious misconduct perpetrated by XXXX XXXXe and its authorized legal agent at the time, XXXX XXXX XXXX XXXX XXXX ( " XXXX '' ), concerning XXXX Case No. XXXX. 

This demand is the culmination of years of effort seeking accountability for actions that were not merely negligent, but demonstrably fraudulent, illegal, undertaken in bad faith, and potentially retaliatory. The conduct detailed herein resulted in direct financial theft through unlawful wage garnishment ( including attempted bank levies ) procured via a void judgment, substantial consequential financial losses, severe and prolonged emotional distress, damage to my personal and professional standing, and the unconscionable forced expenditure of my personal resources over the better part of XXXX years. The demanded sum represents a comprehensive accounting of these harms and the applicable legal penalties, reflecting the gravity of the misconduct attributable to XXXX 's subsidiary, XXXX XXXX. XXXX XXXX XXXX 's continued failure to rectify this situation, despite numerous documented attempts by me to resolve it since uncovering the fraud in XXXX ( including communications directed specifically to you during your tenure as CEO and to other XXXX XXXX XXXX, necessitates this final ultimatum before the immediate commencement of comprehensive litigation against XXXX and all responsible subsidiary entities. 

I. THE PARTIES AND XXXX XXXX XXXX XXXX INDISPUTABLE RESPONSIBILITY XXXX XXXX XXXX XXXX : The original plaintiff and debt owner whose actions, undertaken directly and through its agent XXXX XXXX XXXX, form the basis of this demand. 
XXXX XXXX XXXXXXXX XXXX : The law firm retained by XXXX XXXX as its agent to prosecute XXXX Case No. XXXX. XXXX XXXX is legally responsible for the actions and omissions of its agent, XXXX, undertaken within the scope of that agency, including the fraud, statutory violations, and retaliatory conduct detailed herein. 
XXXX XXXX XXXX XXXX XXXX : The parent corporation that acquired XXXX XXXXXXXX XXXX XXXX XXXX XXXX, thereby assuming its XXXX and its substantial liabilities, including direct responsibility for the damages arising from XXXX XXXX XXXX prior unlawful conduct and fraudulently procured judgment. 
XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  : A prominent XXXX subsidiary acting as the operational successor managing XXXX XXXX XXXX portfolio and affairs. Communications with XXXX counsel ( e.g., XXXX XXXX, XXXX XXXX ) constitute communications with XXXX 's agent regarding these liabilities. 
XXXX XXXX XXXX, as XXXX XXXX parent and successor, can not legally or ethically shield itself from the documented fraud and illegal acts committed by its subsidiary, XXXX XXXX, and its agents. XXXX 's persistent failure to address this matter substantively, despite years of my outreach with clear evidence, only compounds the original wrongdoing and demonstrates a continued disregard for consumer rights and legal accountability. 

XXXX. EXHAUSTIVE FACTUAL CHRONOLOGY : A XXXXYEAR TIMELINE OF DECEIT, ILLEGALITY, RETALIATION, AND CORPORATE FAILURE The history of XXXX XXXX XXXX pursuit of the alleged debt in XXXX Case No. XXXX is not XXXX of legitimate debt collection efforts but reveals a deliberate and sustained manipulation of the judicial process by XXXX XXXX  and XXXX XXXX XXXX, resulting in a void judgment and unlawful financial injury : Debt Origin & Statute of Limitations ( XXXX ) : The underlying matter concerned an alleged debt originating from a Citibank credit card account. My last payment on this account was made in XX/XX/XXXX. Pursuant to XXXX XXXX of XXXX XXXX XXXX, the applicable XXXX-year statute of limitations ( XXXX ) to commence legal action to enforce this debt irrevocably expired in XX/XX/XXXX. After this date, any lawsuit seeking collection was legally barred and its continued pursuit constituted a violation of law. 
XXXX XXXX  ( XXXX ), XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX : XXXX XXXX filed an initial XXXX on this debt ( XXXX Case No. XXXX ) in XXXX. After I, acting XXXX XXXX, challenged the validity of service and requested dismissal with prejudice, XXXX voluntarily dismissed that action without prejudice on XX/XX/XXXX. 
Second Lawsuit Filing ( XXXX XXXX ) & Unlawful Retaliation ( XX/XX/XXXX ) : XXXX XXXX, via XXXX, re-filed the lawsuit as XXXX Case No. XXXX on XX/XX/XXXX notably, just months before the XXXX was due to expire, and shortly after the dismissal of the first suit which I had actively contested. The swift re-filing and subsequent aggressive pursuit of this second action, despite the looming XXXX XXXX and after I had successfully asserted my rights regarding the first improperly served lawsuit, strongly suggests a retaliatory motive by XXXX XXXX XXXX, acting on behalf of XXXX XXXX. This retaliatory litigation, aimed at punishing me for asserting my rights, constitutes an abusive practice under the FDCPA ( XXXX ) and a malicious abuse of process. 
XXXX Expires ( XX/XX/XXXX ) : The statute of limitations definitively expired in XX/XX/XXXX. 
XXXX 's Documented Admission of Expired XXXX ( XX/XX/XXXX ) : The critical, irrefutable evidence of XXXX XXXX knowing state of mind is the XX/XX/XXXX letter sent by XXXX XXXX XXXX XXXX XXXX by XXXX XXXX XXXX XXXX XXXX an attorney at XXXX ) XXXX the XXXX XXXX General concerning this specific XXXX account XXXX In this official communication, after reviewing the file, XXXX stated unequivocally : " The billing statements evidence a date of last payment of XX/XX/XXXX. Therefore, the statute of limitations to enforce this debt expired on XX/XX/XXXX. ". This admission proves, beyond any doubt, that months before committing the fraud detailed below, XXXX XXXX, through its authorized legal agent XXXX, possessed documented, actual knowledge that the debt was time-barred and legally unenforceable via lawsuit. 
Defendant 's Active Defense vs. XXXX 's Neglect & Dereliction of Duty ( XXXX XXXX ) : While XXXX XXXX knew the XXXX had expired, I was actively defending the lawsuit XXXX XXXX. I filed a Motion to XXXX XXXX 's XXXX on XX/XX/XXXX. This motion was actively briefed by both parties through XX/XX/XXXX ( XXXX filed opposition XX/XX/XXXX, I filed a reply XX/XX/XXXX ). In stark contrast to my diligence, XXXX XXXX XXXX demonstrated profound neglect of its own professional obligations and a disregard for court procedure. 
XXXX 's Failure to Appear & Resulting Dismissal ( XXXX XXXX ) : XXXX XXXX XXXX XXXX XXXX duty to appear at mandated Status Conferences scheduled for XX/XX/XXXX, and again on XX/XX/XXXX, resulting in continuances. XXXX has a fundamental, non-delegable duty to attend scheduled court hearings. As a direct consequence of XXXX 's repeated non-appearance and failure to prosecute, the XXXX dismissed the entire action ( XXXX ) on XX/XX/XXXX. 
The Fraudulent Motion to Reinstate & Calculated Concealment ( XX/XX/XXXX ) : Demonstrating extraordinary bad faith and a clear intent to deceive the XXXX and myself, just XXXX weeks after the dismissal resulting from its own neglect, XXXX filed a Motion to Vacate that dismissal on XX/XX/XXXX. This motion is the locus of the extrinsic fraud perpetrated upon the XXXX and myself. Despite possessing the XX/XX/XXXX letter confirming the XXXX had expired almost a full year prior, XXXX deliberately and fraudulently concealed this known, dispositive fact from the XXXX and from me in its moving papers seeking reinstatement. XXXX sought XXXX XXXX ( presumably under XXXX XXXX for its own prior neglect ) while actively hiding the truth that the underlying claim was legally dead, rendering reinstatement improper, futile, and a violation of law. This calculated omission constitutes a profound breach of the duty of candor owed to the tribunal ( Rule XXXX, XXXX of XXXX. XXXX ) and clear misrepresentation by concealment. 
Compounded Fraud : Concealment of XXXX & XXXX Illegality : The fraud was further compounded by XXXX 's active concealment that attempting to reinstate and pursue litigation on this known time-barred debt was, in itself, an illegal act violating both the federal FDCPA ( 15 U.S.C. 1692e & 1692f prohibiting false representations about a debt 's legal status and unfair/unconscionable collection means ) and XXXX XXXX XXXXXXXX ( XXXX. XXXX. XXXX XXXX et seq. ). Litigating known time-barred debts is a well-established violation ( XXXX v. XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX failed to disclose it was asking the court to facilitate federally and state-prohibited conduct. 
Improper Reinstatement Based on Fraud ( XX/XX/XXXX ) : Deceived by XXXX fraudulent omissions regarding the XXXX and the illegality of the action, and having received no notice of these dispositive contrary facts in the moving papers, the XXXX granted the unopposed motion and reinstated the case. This XXXX was procured directly by XXXXXXXX XXXX  extrinsic fraud, which prevented both the XXXX and myself from addressing the fundamental legal bar to the action at that critical juncture. My non-opposition was a direct result of this fraud relying reasonably on the clear XXXX bar and XXXXXXXX XXXX professional duties, I was deprived of understanding the necessity of opposing a motion predicated on such profound deceit. 
XXXX XXXX & XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX : All subsequent proceedings were fatally tainted by the fraudulent reinstatement. The trial held on XX/XX/XXXX ( where XXXX XXXX, instead of addressing the merits, reportedly deflected from his firms prior neglect by complaining about my earlier, proper XXXX XXXX XXXXXXXX ) and the resulting judgment are void or voidable as fruit of the poisonous treethe fraudulent reinstatement. Based solely on this void judgment, XXXX XXXX  unlawfully garnished {$13000.00} from my wages via the XXXX XXXX XXXX XXXX 's Department between approximately XX/XX/XXXX and XX/XX/XXXX. Furthermore, during this period, XXXX XXXX XXXX, on behalf of XXXX XXXX, filed multiple liens against me and attempted to levy a bank account of mine at XXXX XXXX XXXXXXXX, compounding the unlawful collection efforts on a judgment procured by fraud. 
XXXX of Fraud and Diligent Pursuit of Resolution ( XXXX ) : The full extent of XXXXXXXX XXXX XXXXXXXX, pre-existing knowledge and the calculated nature of the fraud during the reinstatement phase became clear to me upon detailed investigation and obtaining the XX/XX/XXXX XXXX Letter XXXX XXXX. Since this discovery, I have acted with unwavering diligence, engaging in extensive documented communication efforts starting in XXXX with XXXX XXXX XXXX successor entity ( XXXX ) and its counsel ( XXXX XXXXXXXX XXXX XXXX XXXXXXXX ) and executives ( including direct communications and demands to you, XXXX XXXX, as CEO of XXXX  ), presenting this irrefutable evidence of fraud and illegality, and demanding restitution. 
Pattern of Systemic Corporate Misconduct ( XXXX XXXX ) : The actions taken against me were not isolated but occurred within a context of systemic disregard for consumer rights by XXXX XXXX, for which XXXX bears successor liability. This pattern is evidenced by major regulatory enforcement actions imposing substantial penalties : FTC XXXX XXXX : Required XXXX XXXX to pay {$2.00} XXXX to settle charges that it systematically engaged in deceptive collection practices including pursuing time-barred debts without proper disclosures and substantiation, misrepresenting its intention to sue, and placing debt on credit reports without notification. 
CFPB XXXX Settlement : Required XXXX XXXX XXXX and XXXX XXXX to pay {$15.00} XXXX partly for violating a prior consent order aimed at curbing similar unlawful practices, including improper litigation tactics, robo-signing, handling of time-barred debt, and suing consumers without proper documentation. These settlements establish corporate notice and a pattern of conduct highly relevant to establishing the knowing, willful, and potentially malicious nature of the actions in my case. 
Persistent Obfuscation, Deflection, and Intimidation by XXXX  ( XXXX ) : My diligent efforts since XXXX to obtain redress based on the clear evidence of fraud have been consistently met with bad faith from XXXX 's representatives. XXXX XXXX ( XXXX XXXX, formerly of XXXX ) engaged in protracted gaslighting, mischaracterizing the fraud as a " court approved process, '' ignoring the FDCPA violations, and falsely attempting to shift blame onto me. External counsel XXXX XXXX issued a cease and desist letter on XX/XX/XXXX, reinforcing these false narratives and attempting intimidation while utterly failing to address the documented fraud. The recent XX/XX/XXXX misdirection involving XXXX XXXX XXXX  ( which now operates from XXXX XXXX XXXXXXXX XXXX  former XXXX address and employs XXXX XXXX, despite denying acquisition or liability assumption ) further illustrates the ongoing difficulties in obtaining straightforward accountability from entities connected to XXXX XXXX network. This consistent pattern of denial, deflection, and obfuscation by XXXX and its agents compounds the original harm and demonstrates a continued refusal to acknowledge or rectify the documented fraud perpetrated by its subsidiary 's agent. 
XXXX. DETAILED LEGAL VIOLATIONS PERPETRATED BY XXXX XXXX & AGENTS The conduct described above constitutes multiple, severe, and actionable violations of law : Extrinsic Fraud Upon the Court & Defendant : The intentional concealment by XXXX ( XXXX XXXX 's agent ) of its documented knowledge of the expired XXXX during the critical Motion to Vacate Dismissal proceedings prevented a fair adversary hearing on reinstatement, fundamentally undermining the integrity of the judicial process and thereby constituting extrinsic fraud. This is not mere intrinsic fraud ( like perjury during trial ) but a fraud that prevented me from fully presenting my defense to the reinstatement itself. XXXX law provides robust mechanisms to address such fundamental injustices. 
Right to Vacate Judgment Procured by Extrinsic Fraud : A judgment procured by extrinsic fraud is against public policy and may be vacated by an independent action in equity or, where the fraud amounts to rendering the judgment void ( e.g., for lack of due process or jurisdiction effectively nullified by the fraud ), by motion under XXXX XXXX ( d ). 
Courts have inherent equitable power to set aside judgments obtained by extrinsic fraud after the time for statutory relief has passed, provided the aggrieved party acts with diligence upon discovering the fraud. Seminal cases like XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, establish that " equity will relieve an injured party from the effect of a judgment procured by extrinsic fraud, mistake or excusable neglect which was not the result of negligence or laches on his part. '' Extrinsic fraud includes " conduct which prevents the party from presenting his claim or defense to the court, '' including " concealment of facts which, if known to the court, would have prevented the rendition of a judgment. '' ( In re XXXX of XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX concealment of the known XXXX bar directly prevented the court and me from addressing this dispositive issue at the reinstatement phase. 
The requirement is reasonable diligence in seeking relief after discovery of the fraud ( XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ). As detailed, I have acted with such diligence. 
Fair Debt Collection Practices Act ( FDCPA ) Violations ( 15 U.S.C. 1692 et seq. ) : XXXX, but not limited to : XXXX ( XXXX ) ( A ) : False representation of the character, amount, or legal status of the debt ( by litigating a known time-barred debt as if legally enforceable and by obtaining a judgment based on such fraud ). 
XXXX ( XXXX ) : Threatening to take ( and actually taking ) legal action ( reinstating the lawsuit, proceeding to trial, obtaining judgment, and garnishing wages, including attempted levies ) that could not legally be taken due to the XXXX bar. 
XXXX ( XXXX ) : Use of false representations and deceptive means ( specifically, concealing the XXXX expiry from the court and defendant during the reinstatement motion ) to attempt to collect the debt and obtain a judgment. 
XXXX : Use of unfair or unconscionable means to collect or attempt to collect any debt ( most notably, abusing the court process by litigating a claim known to be time-barred ). 
XXXX ( XXXX ) : Collecting an amount ( the garnished wages and attempting further levies ) not permitted by law, as it stemmed directly from a void judgment procured by fraud and multiple FDCPA violations. 
XXXX : The aggressive, potentially retaliatory nature of the continued litigation after the first dismissal, particularly the fraudulent reinstatement and pursuit to judgment, constitutes harassment or abuse. 
XXXX Fair Debt Collection Practices Act ( XXXX ) Violations ( Cal. XXXX. XXXX XXXX et seq. ) : XXXX : Expressly incorporates violations of the FDCPA ( sections XXXX through XXXX ) as violations of the RFDCPA, thereby making all the above FDCPA violations also state law violations. 
XXXX ( a ), ( XXXX ), ( f ) : Making untrue or misleading representations regarding the debt, its legal status, or the implications of nonpayment ; threatening or taking actions not legally permissible. 
Potential Additional Common Law Torts : The deliberate, documented, and harmful nature of the conduct by XXXX XXXX XXXX XXXX claims for common law fraud ( deceit ), abuse of process ( willful misuse of legal procedure for an improper purpose, including retaliatory litigation and pursuing judgment on a known false premise ), and intentional infliction of emotional distress. 
IV. REFUTATION OF ALL ANTICIPATED AND PREVIOUSLY ASSERTED DEFENSES XXXX XXXX XXXX has no valid defense for the actions of its subsidiary, XXXX XXXX, and its agent, XXXX XXXX XXXX : Laches/Passage of Time : This defense fails utterly. As established, the claim for relief from a judgment based on extrinsic fraud is governed by equity, and the relevant period for assessing diligence runs from the discovery of the fraud, not the date of the original judgment. I discovered the documented proof of XXXX 's fraudulent concealment in XXXX and have acted with demonstrable and unwavering diligence since then, including extensive pre-litigation attempts to resolve this matter with XXXX XXXX XXXX including yourself, XXXX XXXX ) which were consistently rebuffed. An entity that perpetrates and benefits from fraud can not then claim prejudice from the victim 's diligent efforts to uncover and rectify that fraud, especially when its own agents actively concealed the wrongdoing. Returning unlawfully obtained funds does not constitute undue prejudice ; it is a matter of equity and law. 
" XXXX Approved Process ''/ Waiver : The argument previously advanced by XXXX XXXX XXXX XXXX XXXX XXXX XXXX reinstatement was merely a " court approved process '' under XXXX XXXX and that I somehow waived defenses by not opposing the fraudulently induced motion or by not re-litigating the XXXX at XXXX trial predicated on fraud is specious, offensive, and legally untenable. A procedural mechanism like XXXX XXXX can not be used as a shield to legitimize an outcome procured through fraudulent concealment of dispositive facts and active violation of federal law. The process itself was irredeemably tainted by the fraud at its inception ( the motion to reinstate ). Furthermore, one can not waive rights or defenses XXXX was effectively prevented from fairly and fully asserting due to the opposing party 's extrinsic fraud and concealment. The primary duty was on XXXX XXXX not to commit fraud upon the court in the first instance. 
" Unclean Hands '' XXXX by XXXX : XXXX XXXX dare to assert an " unclean hands '' defense against me, such an argument would be utterly baseless and a transparent attempt to deflect from its own ( and its predecessor 's agent 's ) profound misconduct. The doctrine of unclean hands is an equitable defense applicable only when the party seeking relief has themselves engaged in misconduct directly related to the specific matter in which relief is sought and which has prejudiced the opposing party in that same transaction. Any allegations regarding the tone or frequency of my communications, undertaken over many years while facing documented fraud, obfuscation, and illegal collection efforts, do not constitute " unclean hands '' that would bar my claims for relief from XXXX XXXX 's documented fraud and statutory violations in procuring and enforcing a void judgment. XXXX XXXX, by engaging in fraudulent litigation, violating federal and state consumer protection laws, and benefiting from a judgment procured by deceit, is unequivocally the party with demonstrably " unclean hands '' in this matter. XXXX, as its successor, can not cleanse these hands by attacking the victim of its predecessors fraud. The focus must remain on the original, documented fraud perpetrated by XXXX XXXX 's agent, which XXXX is now liable for. 
V. COMPREHENSIVE ASSESSMENT OF DAMAGES FULL DEMAND FOR PRE-LITIGATION SETTLEMENT The cumulative effect of XXXX XXXX XXXX sustained fraudulent and illegal conduct warrants the imposition of full compensation covering all facets of the harm inflicted : Actual Financial Damages : Restitution of All Unlawfully Garnished Wages : {$13000.00}. 
Accrued Pre-Judgment Interest ( Calculated XXXX ) : {$17000.00}. ( Calculated estimate @ 10 % simple interest per annum from XXXX garnishment dates to XX/XX/XXXX ; subject to precise calculation and potential adjustment based on applicable statutory rates under California law ). 
Damages for Demonstrable Harm to Creditworthiness : Amount to be determined based on evidence of negative reporting, impact on credit access/terms, and costs to repair. 
Out-of-Pocket Expenses : Amount to be determined based on evidence of costs incurred pursuing this matter. 
Statutory Damages for Violations of Consumer Protection Laws : FDCPA Statutory Damages : {$1000.00} ( Maximum per action under XXXX U.S.C. XXXX ( a ) ( XXXX ) ( A ) ). 
XXXX XXXX Damages : {$1000.00} ( Maximum per action under XXXX. XXXX. Code XXXX ( b ) ). 
Damages for Severe and Prolonged Emotional Distress : {$25000.00}. This sum is demanded as compensation for the significant, substantial, and prolonged emotional distress endured for well over XXXX years. This distress includes, but is not limited to : the immense stress, anxiety, and feelings of helplessness associated with facing fraudulent litigation initiated by a major corporation ; the humiliation and financial hardship resulting from the unlawful wage garnishment and attempted bank levies ; the damage to my personal and professional reputation ; the loss of peace of mind ; and the extreme frustration and anger caused by years of dealing with corporate denial, gaslighting, and obfuscation from XXXX XXXX and its successors. This figure represents a conservative pre-litigation valuation for this profound harm ; the actual damages proven at trial could be substantially higher. 
Punitive Damages : {$50000.00}. Punitive damages pursuant to California XXXX XXXX XXXX are unequivocally warranted and demanded due to the clear and convincing evidence of malice, oppression, and fraud demonstrated by XXXX XXXX and its agent XXXX XXXX XXXX. This conduct includes : ( a ) the intentional and deliberate concealment of the known expired statute of limitations from the XXXX XXXX XXXX XXXX a direct act of fraud upon the tribunal ; ( b ) the knowing pursuit of litigation in direct violation of federal and state consumer protection laws ( FDCPA & XXXX ) ; ( c ) this unlawful conduct being entirely consistent with a documented pattern of similar widespread misconduct by Asset Acceptance leading to significant regulatory penalties ( XXXX ), evidencing corporate ratification or reckless disregard ; ( d ) the retaliatory nature of the litigation campaign ; and ( XXXX ) the subsequent sustained obfuscation and denial by successor counsel when confronted with irrefutable evidence of the fraud. This pattern of egregious conduct requires the imposition of substantial punitive damages necessary to punish XXXX XXXX and to deter such unlawful corporate behavior in the future. This amount is demanded for pre-litigation settlement and is subject to significant increase at trial based on full evidence of reprehensibility and XXXX XXXX  financial condition. 
XXXX XXXX : Full vacatur of the void judgment in XXXX XXXX XXXX. XXXX and mandatory, verifiable correction of all related adverse information on my credit reports by XXXX XXXX. 
TOTAL CALCULATED & ESTIMATED DAMAGES DEMANDED FOR PRE-LITIGATION SETTLEMENT : {$100000.00} ( {$13000.00} [ Garnishment ] + {$17000.00} [ Interest Est. ] + {$1000.00} [ FDCPA XXXX. ] + {$1000.00} [ XXXX XXXX. ] + {$25000.00} [ Emotional Distress ] + {$50000.00} [ Punitive Damages ] ) VI. FINAL DEMAND FOR IMMEDIATE PAYMENT DEADLINE XX/XX/XXXX AND CONSEQUENCES OF NON-COMPLIANCE This letter constitutes XXXX XXXX XXXX 's absolute final opportunity to amicably and fully resolve all claims arising from the fraudulent and illegal conduct of XXXX XXXX and its agents in XXXX Case No. XXXX before comprehensive litigation is initiated. 

I hereby demand immediate payment from XXXX XXXX XXXX XXXX XXXX of the full {$100000.00}. 

This payment must be remitted in the form of a certified check payable to XXXX XXXX XXXX XXXX and physically received at my address listed above no later than XXXX ( XXXX ) calendar days from the date of this letter, which is Friday, XX/XX/XXXX. 

Should XXXX XXXX XXXX XXXX XXXX fail to comply fully with this demand by the specified deadline, or fail to engage in immediate, good faith negotiations leading to a satisfactory resolution, I will, without any further notice, immediately commence comprehensive legal action against XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, and any other liable individuals or entities. This lawsuit will vigorously pursue the full range of all actual damages ( including precisely calculated interest, proven credit damages, and costs ), statutory damages under both FDCPA and XXXX, full compensation for severe emotional distress, substantial punitive damages reflecting the malicious and fraudulent nature of the conduct, plus all recoverable litigation costs and attorney 's fees as provided by law. Concurrent formal legal action will be taken in the XXXX XXXX XXXX XXXX to vacate the void judgment based upon the extrinsic fraud detailed herein. 

Given the irrefutable documentary evidence establishing intentional fraud and clear violations of law, XXXX XXXX 's history of regulatory sanctions for similar conduct, and the persistent bad faith demonstrated by successor counsel in response to my legitimate grievances, continued denial or delay by XXXX is untenable and will only exacerbate XXXX 's ultimate liability. It is strongly and unequivocally advised that XXXX XXXX XXXX address this egregious matter responsibly and immediately to avoid the substantial financial exposure, reputational damage, and public scrutiny of protracted litigation over these well-documented and deeply concerning facts. 

Govern yourselves accordingly. 

Sincerely, XXXX XXXX XXXX XXXX.

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation