THIS IS A SAMPLE TEMPLATE FOR ALLEGED VIOLATIONS OF THE CALIFRORNIA LEGAL REMEDY ACT (“CLRA”) .

THIS IS NOT LEGAL ADVICE OR A SUBSITUTE FOR LEGAL ADVICE. YOU MUST SEND THIS TO THE PROPER ADDRESS WHERE YOUR LOAN SERVICER OR OTHER ENTITY REQUESTS THESE QWR’S BE SENT. SEND CERTIFIED MAIL. IF YOU ARE NOT SURE, CHECK YOUR MONTHLY MORTGAGE STATEMENT OR CALL YOUR LOAN SERVICER. IF YOU SEND IT TO THE WRONG PLACE IT MAY NOT BE TREATED AS A QWR. (DELETE THIS BEFORE SENDING). THIS DOCUMENT IS FOR YOUR OWN PERSONAL USE ONLYAS AND NO OTHER USE IS PERMISSIBLE. YOU SHOULD ONLY RAISE LEGITIMATE DISPUTES. IF YOU ARE NOT SURE OF YOUR LEGAL RIGHTS, CONTACT A LAWYER. THIS LETTER OFFERS NO WARRANTIES OR REPRESENTATIONS THAT IT WILL PROVIDE ANY TYPE OF RESULT. DELETE THIS SECTION BEFORE SENDING.

July 16, XXXX XXXXXX XXXXXX Sioux Falls, SD 57107-0210 Attn: Legal Department VIA FACSIMILE AND U.S. MAIL: (866) 869-9350 RE: NOTICE OF VIOLATION OF CALIFORNIA CONSUMER LEGAL REMEDIES ACT AND 30 DAY RIGHT TO CURE UNDER SECTION 1782. THIS IS A DEMAND LETTER AND MUST BE FORWARDED TO THE APPROPRIATE PARTY FOR IMMEDIATE RESOLUTION. FAILURE TO RESPOND TO THIS MAY RESULT IN ACTION BEING TAKEN. PLEASE TAKE NOTICE that we believe the above referenced company is in violation of the California Consumer Legal Remedies Act (California Civil Code Section 1750 et seq.) for the reasons set forth below: [state your reasons – set forth below are some grounds] (1) (2) (3)

CALIFORNIA CONSUMER LEGAL REMEDIES ACT PROHIBITED ACTS Section 1770 of the CLRA lists 23 prohibited “unfair methods of competition and unfair or deceptive acts or practices.” Any of the following acts is prohibited in regard to the sale of goods or services. The following are some of the prohibited acts under CLRA: (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) Passing off goods or services as those of another. Claiming a false geographical origination of the goods (for example: made in USA when the goods where made in Asia) Representing that goods are original or new when they are not. Representing that goods or services are of a particular standard, quality, or grade, or that goods are of a particular style or model, if they are of another. Disparaging the goods, services, or business of another by false or misleading representation of fact. Advertising goods or services with intent not to sell them as advertised. Advertising goods or services with intent not to supply reasonably expectable demand, unless the advertisement discloses a limitation of quantity. Advertising furniture without clearly indicating that it is unassembled if that is the case. Advertising unassembled furniture without indicating the assemble price if the furniture is available assembled. Making false or misleading statements concerning reasons for price reductions. Representing that a part, replacement, or repair service is needed when it is not. Representing that the subject of a transaction has been supplied in accordance with a previous representation when it has not. Representing that the consumer will receive a rebate, discount, or other economic benefit, if the earning of the benefit is contingent on an event to occur subsequent to the consummation of the transaction. Disseminating an unsolicited prerecorded message without consent. Misrepresenting the authority of a salesperson, representative, or agent to negotiate the final terms of a transaction with a consumer.

Your company has committed multiple violations of the CRLA as well as the California law of unfair competition (California Business and Professions Code Section 17200). This section prohibits fraudulent, illegal and even “unfair” business practices. California law prohibits your treatment of my account, which at the very least and at the bare minimum are completely “unfair” in addition to a breach of contract. “There is no single definition for the phrase "unfair business practices." It is an 2

evolving concept reflecting the ingenuity of unscrupulous business persons in concocting new schemes to gain advantage at someone else's expense . The existence of an unfair business practice is a question of fact determined in light of all the circumstances surrounding a case. See People ex rel. Bill Lockyer v. Fremont Life Ins. Co., 104 Cal.App.4th 508, 128 Cal.Rptr.2d 463, Cal.App. 2 Dist.,2002.” (emphasis added). Here, your company has changed the terms of my original agreement with XXXX. I have received no notice of your terms and policies, which your company claims binds me, and false claims that you have attempted to contact me when there has been no such attempts. If you have proof, I hereby request that you forward that to me for my review. Failure to provide such will verify proof of fraud, breach of contract, and dishonest dealings by XXXXXXX. III. DAMAGES AVAILABLE UNDER CALIFORNIA LAW (a) Any consumer who suffers any damage as a result of the use or employment by any person of a method, act, or practice declared to be unlawful by Section 1770 may bring an action against that person to recover or obtain any of the following: (1) Actual damages, but in no case shall the total award of damages in a class action be less than one thousand dollars ($1,000 minimum). (2) An order enjoining the methods, acts, or practices. (3) Restitution of property. (4) Punitive damages. (5) Any other relief that the court deems proper. These damages are in addition to any damages as a result of successful causes of action for fraud, misrepresentation, deceit, and other applicable causes of action. I have lost a significant amount of time and money estimated to be approximately $1,500 in lost time in dealing with this issue and the inability to access legal documents that I alone have created to assist me in my practice. I am assuming I am not the only victim of your fraudulent schemes and false billing practices (false charging of “credit card denial fees” designed to facilitate false tax write-offs) and the illegal taking down of my website after cashing my payment (along with late charges) as has allegedly been your practice in regard to my account for the last five years. IV. THIRTY (30) DAY OPPORTUNITY TO CURE THE ABOVE VIOLATIONS YOU HAVE THIRTY (30) DAYS from the date on which this notice is served upon you to do the following in order to remedy your violations: (1) Provide proof of the legal contract entered into between myself and/or my company and One Eighty Networks whom you allegedly purchased my account from. 3

(2) Provide proof of your written notice to me that you assumed my account and became the new legal owner of my account. (3) Provide me with a copy of your written policies and procedures which you claim cover and control my account. (4) Send me a copy of your billing policies and practices. (5) Send me a complete “life of loan” accounting of all payments made by my firm. (6) Re-activate my website so that I may access my legal documents. (7) Send me written proof of your companies attempts to contact my firm to discuss late payments as your representatives claim has been done (while being completely unable to document such efforts or the dates of such calls) (8) (9) Send me proof certain of what the $2.47 charge is on my billing statement representing what is claimed to be a “credit card denial” charge. Provide a detailed explanation as to why my account was shut down.

(10) Provide me with a check in the amount of $1,500 to cover my lost time, and damages in dealing with this fiasco. (11) Send me legal proof of your right to charge my account $45 per month and to charge “late fees” as has been apparently charged in the past. FAILURE TO TAKE THE ABOVE ACTION WITHIN 30 DAYS OF THE RECEIPT OF THIS NOTICE SHALL RESULT IN THE LAW OFFICES OF STEVEN C. VONDRAN , P.C. FILING A CIVIL LAWSUIT IN A CALIFORNIA STATE COURT for Damages pursuant to California Civil Code Section 1780 and for Restitution and Injunctive relief on behalf of others similarly situated pursuant to California Business and Professions Code Section 17200 et seq. and California Civil Code Section 1780, and for Punitive damages, Treble Damages, and Attorney Fees as authorized by the Statute. All information requested herein shall be provided in written format and shall be clear and understandable and mailed certified mail to the following address: 6XXXXXXXXXX XXXXXXXXX XXXXXXXX CA 92660 It is unfortunate that this is how your company treats people who have a long history of making payments with your company. This business practice will not be tolerated by me as it is detrimentally impacting my business as I write this. Regards,

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Steven C. Vondran, Esq.

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