Dear Mr. Katruzov,
This letter constitutes formal written demand pursuant to Florida law. As of the date of this notice, you remain indebted to me personally, Valerii Lolin, in the total principal sum of $20,000.00 (Twenty Thousand and 00/100 US Dollars).
On June 14–16, 2021, at your explicit personal request and under your specific representations regarding down payments for commercial Kenworth T680 vehicles, I transferred and advanced funds totaling $20,000.00 directly from my personal Bank of America checking account (Adv Plus Banking *5192) to your personal Bank of America checking account (*9652 [redacted]).
| Transaction Reference | Date | Description | Amount Due |
|---|---|---|---|
| BofA Transfer Conf # HDM0QUN8O | 06/16/2021 | Direct Account Transfer from *5192 to Katruzov *9652 | $10,000.00 |
| BofA Payment Conf # RN62J-12S02 | 06/15/2021 | Direct Payment Submission to Evgeny Katruzov | $10,000.00 |
| Formal Demand Invoice # 002 | 09/25/2026 | Return of borrowed personal funds / Loan repayment | $20,000.00 |
| TOTAL PRINCIPAL AMOUNT OUTSTANDING: | $20,000.00 USD | ||
These funds were extended as a loan in good faith with your promise of prompt repayment. Despite my repeated personal demands, warnings regarding collection proceedings, and the recent formal invoice delivered via Bank of America / Bill.com (Invoice #002), you have consistently failed, neglected, and refused to repay the borrowed amount, and have ceased all contact.
DEMAND IS HEREBY MADE that you pay the full principal amount of $20,000.00 within fourteen (14) calendar days from your receipt of this letter, no later than October 9, 2026.
Remittance may be completed through:
- Online payment portal via Bank of America / Bill.com: https://paymentportal-b1.bofa.bill.com/p/008b1ISQAMFGHAGG10he
- Direct transfer / Wire transfer to my personal Bank of America checking account *5192 (instructions available upon request).
- Cashier’s Check or Bank Draft made payable directly to Valerii Lolin.
NOTICE OF INTENT TO SUE:
Be advised that if payment in full is not received by the deadline stated above, I will immediately instruct legal counsel to initiate civil litigation against you individually in the County Court of the Seventh Judicial Circuit in and for Flagler County, Florida. The complaint will assert claims including, without limitation:
- Breach of Oral / Implied Contract;
- Unjust Enrichment and Money Had and Received;
- Fraudulent Misrepresentation and Inducement.
In addition to the principal debt of $20,000.00, I will seek the maximum statutory interest permitted under Florida Statute § 55.03, full court filing and service costs, and all allowable fees.
Upon entry of judgment, I will promptly enforce all available post-judgment collection mechanisms, including recording a Judgment Lien against your real property located in Palm Coast, Flagler County, FL, and obtaining a Writ of Garnishment against your bank accounts at Bank of America (Account ending in *9652 [redacted]) and any other financial institutions.
Govern yourself accordingly.
Valerii Lolin
Signature / Date