Free Motion to Remand - District Court of California - California

Case 3:08-cv-00846-JLS-JMA

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MICHAEL A. CONGER, ESQUIRE (State Bar #147882) LAW OFFICE OF MICHAEL A. CONGER 16236 San Dieguito Road, Suite 4-14 Mailing: P.O. Box 9374 Rancho Santa Fe, California 92067 Telephone: (858) 759-0200 Facsimile: (858) 759-1906
Attorney for Plaintiff Fabrizio Balestri

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8 9 10 11 12 v. CIT GROUP, INC., STUDENT LOAN XPRESS, INC., and DOES 1 to 30, inclusive, Defendants. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, Fabrizio Balestri, declare as follows:

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA
FABRIZIO BALESTRI, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) CASE NO: 08-CV-0846-JLS (JMA) DECLARAnON OF FABRIZIO BALESTRI IN SUPPORT OF MOTION TO REMAND

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1.

I am the former president and chief executive officer of Student Loan Xpress, Inc.,

and the plaintiff in this matter. I have personal knowledge of the matters stated herein and if called to do so could testify competently thereto.

2.

Attached as Exhibit A is a true and correct conformed copy of the complaint, with

exhibits, I filed on April 11, 2008, in the Superior Court of the State of California, County of San Diego. 3. I am a citizen of California, where I have resided with my family for 18 years.

While employed by SLX, I was employed in and lived in San Diego, California. 4. Student Loan Xpress, Inc. ("SLX") was founded in 2002 as a subsidiary of

Educational Lending Group, Inc., which was acquired by CIT Group, Inc., in 2005. 5. Attached as Exhibit B is a true and correct copy of an SLX marketing document,

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which shows that 146 ofSLX' 232 employees (62.9%) work in San Diego, California. 6. Although SLX has no manufacturing production activities, all of its sales and


marketing activities are located in San Diego. SLX printed, mailed, and approved tens of
thousands of student loan applications annually from its San Diego headquarters.
7. SLX' call center, which probably provides the most contact with the public of all

of SLX' activities, is located in San Diego. 8. Attached as Exhibit C are true and correct copies of the first pages of SLX'

responses to requests for bids or proposals from the University of San Francisco, the University of Denver, and the University of Louisville. As these exemplars demonstrate, SLX always identified SLX as being based in San Diego. 9. 10. SLX' accounting and human resources activities take place in San Diego. Attached as Exhibit D are true and correct copies of business cards from the

following SLX executives: · · · · · · · · · · · · LeeAnn Rohman, chief operating officer; Margaret Bazini, chief financial officer; David Beach, executive vice president and chief marketing officer; Gary Rohmann, executive vice president of business development; Travis Mottet, senior vice president, information and sales support; Donna North, senior vice president, human resources; Ken Guerrero, vice president, academic services; Nicole Casali Joseph, vice president, marketing; Daniel W. King, vice president, call center operations; Rick Nicols, vise president, telephony; Daniel Passov, vice president, online marketing; and Erin Guerrero, vice president, business development.

These key SLX corporate officers all work from and reside in San Diego, California.

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I declare under penalty of perjury under the laws of the State of California that the

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foregoing is true and correct.
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Executed this 9th day of June, 2008, at San Diego, California.

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By:

,-::"/s'--"I----:-.,-_ _. , -

_

Fabrizio Balestri

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EXHIBIT A


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MICHAEL A. CONGER, ESQUIRE (State Bar #147882)
LAW OFFICE OF MICHAEL A. CONGER
16236 San Dieguito Road, Suite 4-14
Mailing: P.O. Box 9374
Rancho Santa Fe, California 92067
Telephone: (858) 759-0200
Facsimile: (858) 759-1906
Attorney for Plaintiff Fabrizio Balestri

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SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO FABRIZIO BALESTRI, Plaintiff,
v.

10 11 12 13 14

) ) )
) ) )

CASE NO:
37-200s.-00081786-CU-BC-CTL

CIT GROUP, INC., STUDENT LOAN XPRESS, INC., and DOES 1 to 30, inclusive, Defendants.

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1.

) ) ) ) )

COMPLAINT FOR BREACH OF CONTRACT AND VIOLATION OF LABOR CODE SECTION 201

Fabrizio Balestri ("BALESTRI") is an individual residing in San Diego,

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II

California. 2. Defendant CIT Group, Inc. ("CIT") is a Delaware corporation doing business in

San Diego, California. 3. Defendant STUDENT LOAN XPRESS, INC. ("SLX"), is the successor to

Educational Lending Group, Inc. SLX is Delaware Corporation with its principle place of business in San Diego, California, and is a wholly-owned subsidiary of CIT.
4.

The true names or capacities, whether individual, corporate, associate, or

otherwise, of defendants DOES 1 to 30, inclusive, are unknown to plaintiff, who therefore sues
said defendaIlts by such tlctitious 5.
DailIes.

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Plaintiff is informed and believes and thereon alleges that each of the defendants

designated herein as a DOE is responsible in some manner for the events and happenings herein
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Complaint for Breach of Contract and Violation of Labor Code Section 201

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referred to, and caused injury and damages proximately thereby to plaintiff as herein alleged.
Plaintiffwill seek leave of court to amend this complaint to set forth the true names and
capacities of such named defendants when their identities become known to him.


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6.

Plaintiff is informed and believes and thereon alleges that each defendant named

in this action, including DOE defendants, at all relevant times, was the agent, ostensible agent, servant, employee, representative, assistant, joint venturer, and/or co-conspirator of each of the other defendants, and was at all times acting within the course and scope of his, her, or its authority as agent, ostensible agent, servant, employee, representative, joint venturer, and/or co-conspirator, and with the same authorization, consent, permission or ratification of each of the other defendants. 7. On January 4,2005, BALESTRI, SLX (the successor to Educational Lending

group, Inc.), and CIT entered into a three-year employment agreement, a true and correct copy of which is attached at Exhibit 1 ("the January 4, 2005 agreement"). 8. On January 10, 2006, the parties modified paragraph six of their January 4, 2005

agreement and entered into a "Retention Bonus Plan." A true and correct copy of that agreement is attached at Exhibit 2 (the "Retention Bonus Plan" agreement).
9.

On May 24, 2007, CIT and SLX terminated BALESTRI without cause (as that

term is defined at page 3 of in the parties' January 4, 2005 agreement).

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II

FIRST CAUSE OF ACTION - BREACH OF CONTRACT (Against CIT, SLX and Does 1-10)
10. BALESTRI incorporates by reference and realleges paragraphs 1 through 9 as

though fully set forth herein. 11. Pursuant to the terms of the parties' January 4, 2005 employment agreement, if

BALESTRI was terminated without cause the defe~dants agreed to pay BALESTRI, "in a single lump sum ... an amount equal to one and one half times the sum of (i) [BALESTRI' s] highest annual base salary ... , plus (ii) the amount of the annual bonus [he] earned during the [2006] calendar year. ..." (Exh. 1, p. 3, 4j\ 8.) 12. Based on BALESTRI's highest base salary and 2006 bonus, he should have been
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Complaint for Breach of Contract and Violation of Labor Code Section 201

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paid $675,000 by the defendants upon termination without cause but was not. 13. Defendants failed to pay BALESTRl in accordance with paragraph 8 of the

parties' January 4, 2005 agreement, thereby breaching that agreement. 14. 15. BALESTRl has performed all terms of the parties' January 4, 2005 agreement. BALESTRl has been damaged by defendants' breach in the amount of $675,000.

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SECOND CAUSE OF ACTION - BREACH OF CONTRACT (Against CIT, SLX and Does 1l-20)
16. BALESTRl incorporates by reference and realleges paragraphs

1 through 9 as

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though fully set forth herein. 17. Pursuant to the Retention Bonus Plan agreement, BALESTRl was entitled to an

additional bonus of $1 ,000,000 if certain targets for loan volume were met. 18. 19. During BALESTRl's employment, the targets were achieved. However, Defendants failed to pay BALESTRl in accordance with the Retention

Bonus Plan agreement, thereby breaching that agreement. 20. 21. $1,000,000. BALESTRl has performed all terms of the Retention Bonus Plan agreement. BALESTRl has been damaged by defendants' breach in the amount of

THIRD CAUSE OF ACTION - VIOLATION OF LABOR CODE SECTION 201 (Against CIT, SLX and Does 21-30)
22. BALESTRl incorporates by reference and realleges paragraphs 1 through 21 as

though fully set forth herein. 22. Pursuant to Labor Code section 201, upon termination, BALESTRl was, within

72 hours, entitled to be paid $1,675,000 in wages, as defined by Labor Code section 200, by the defendants according to the January 4, 2005 agreement and the Retention Bonus Plan agreement. 23. Defendants failed to pay BALESTRl's wages in compliance with Labor Code

26 . section 201.


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Therefore, pursuant to Labor Code sections 201 and 203, BALESTRl is entitled to


recover unpaid wages of$I,675,000, plus waiting time penalties of at least $137,671.23.


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Complaint for Breach of Contract and Violation of Labor Code Section 201

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WHEREFORE, Plaintiff prays:
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Compensatory damages, Waiting time penalties; Pre-judgment interest calculated from the date payments were due; Costs; and Such other and further relief as the court determines necessary and proper.

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Dated: April 11, 2008 9
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LAW OFFICE OF MICHAEL A. CONGER

By:

£!C.,.-l--\-,~l----r- -
Attorney for Plaintiff

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Jury trial demanded. 15
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Complaint for Breach of Contract and Violation of Labor Code Section 20 I


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EXHIBIT 1


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..L..:.t teNDING GROUP, INC.
................. ' ' ' ' " " ·

D~
~

Education LeFlding Group, tne.
12760 iiigh Bluff Drive. Sui.e 210 San Diego. California 92131)-2018
; r , · " '" "" .


Telephone (858) 511.£080 facsimHe (858) 517-5079

January 4, 2005 Mr. Fabrizio Balestri

985 vVind50r Creek Court


Cardifl:: CA 92007


Dcar Fabrizio:
This letter is being written to you in connection with the execution of an Agreement and
Plan of Merger (the "Merger Agreemem") between and among Education Lending
Group, Inc. ("EDLG"), CIT Group Inc. C'CIT"), and a wholly-o\vned subsidiary of CIT.
You and we have agreed that if the acquisition ofEDlG by err in the manner
contemplated by the Merger Agreement occurs, you will continue in your current
position as President and Chief Executive Officer of Student Loan Xpress, Inc. generally
on the same basis as govern5 your current employment but with the additional terms
specified below in this letter. Assuming you agree that this letter correctly sets forth the
relationship bet\veen you and EDLG that we have agreed upon, you should countersign
both Oliginal copies of this letter in the place provided, retain one fully executed copy for
your records and· return the other copy to me.

Jf the acquisition of EDLG by CIT in the manner contemplated by the Merger Agreement
occurs, the following additional temlS will appiy to your employment by EDLG and/or
Student Loan Express, Inc. ("SLX") from and after the Effective Time (as defined in the
Merger Agreement):


I. Three-Year Term. Until and unless terminated by either party, the teon of your
employment under this letter (the "Employment Period") will commence at the Effective
Time and extend through the third anniversary of the Effective Time.
2. Title and Duties. You will retain your current title of President and Chief Executive
Ot11ccr of SLX. You will continue to perfonn the same duties with respect to SLX thar
you were perfool1ing for SLX during 2004. Unless othenvise directed by the Board of
Directors of EDLG, you . .viIl continue to report to the Chief Operating Officer of EDLG.

3. Base Salal)'. Your base salary will be at the rate of at least $2iO,OOO per year, payable
in accordance with CIT's normal payToll procedures and subject to increase following
regular periodic reviews.


4. Annuai Incentive Compensation. For 2005, you will continue to be entitled to bonuses
under EDLG's existing annual bonus program. substantially on the SBme basis as in effect
before the Effective Time,


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5. Long-Term Incentive Compensation During the Employment Period, you will be entitled to participate in CIT's Long-Term Equity Compensation Plan (the "ECP") and be eligible to receive such awards thereunder as CIT may from time to time determine. For the calendar year 2005. you will be entitled to receive grants under the fep that include at least the fonowing;
(a) A grant of options with a value as of the date of grant, detennined on the Black-Scholes method, equal to $315,000 (i.e.. one and one-halftimes your base salary as of the Effectiye Time) with three-year diffvesting on the third anniversary of the Effective Time, an exercise price equal to the fair market value of a share of CIT stock on the date of grant, and other terms generally comparable to those applicable to option grants made to other executives under the ECP.
(b) A grant of performance shares for shares of CIT stock with an aggregate value, derennined without regard to any restrictions on vesting or transfer, equal to $105,000 (i.e., one-balf times your bases salary as of the Effective Time) with vesting and other remTS generally comparable to the vesting and other tenns applicable to performance share grants made to other executives under the ECP.
6. Sfa.r Bonus. If you remain in the employ of EDLG and/or SLX through the third
anniversary of the Effective Time, you will be eligible for a stay bonus in an aggregate
amount of up to $525,000 (the "Maximum Stay Bonus").


(a) Time Vested Ponion. One half of tile Maximum Stay Bonus (i.e., $262,500) will be available as a time vested stay bonus and will be paid to you wlthin ten days after the third anniversary of the Effective Time if you remain in the employ ofEDLG and/or SLX through the third anniversary of the Effective Time. (b) Performance Vested Portion. The second half of the Maximum Stay Bonus (i.e., $262,500) wm be availabie as a performance vested stay bonus and will be paid to you within ten days of the third anniversary ofthc Effective Time if
(i) you remain in the employ afEDLG and'or SLX through the third anniversary of the Effective Time, and (ii) EDLG has achieved the levels of Loan origina.tions for calendar fears 2005, 2006, and 2007, viewed in the aggregate, that were anticipated ill materials provided by EDLG to CIT in December of 2004 (the "Target Originations Leve1"). If EDLG does not w.::hicve the Target Originations Level, no payment wiII be made to you under this paragraph (b j.

V'7cations. Throughout rhe Employment Period you will continue to be entirled to at least five weeks of vacation per year, such vacation to be taken in accordance with the EDLG vacation policy as that policy was in effect during 2004.
7.

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...L.:..t t"t.dYDL\'G GROCP, Lve.
8.

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Parment upon Termination Without Cause. If EDLG terminates your employment without cause before the third anniversarj of the Effective Time, EDLG \vill pay to you, subject to your execution of a release of claims in a form reasonably satisfactory to ED l("J, in a single lump sum. not more thaD ten days after the date of your termination, an amount equal to one and one half times the sum of (i) your highest annual base salary during the EmployTI1cnt Period, plus (ij) the amount of tile annual bonus you earned during the calendar year immediately preceding the calendar year in which you are terminated without cause. For these purposes, EDLG will have "Cause" to terminate your employment if, as of the date of tennination, any of the following circumstances have occurred (and, if reasonably susceptible to cure, remain uncured for 30 days after notice to you from EDLG of an intention to treat the circumstance as Cause for tel111ination) you have (a) materially failed to devote your entire business time, energy, talent, and best effOlts to the perfonnance of your duties specified above; (b) been negligent, inSUbordinate, or disloyal in the performance of your duties specified above; (c) failed to follow direction from the Board of Directors with respect to a specified course of conduct; Cd) been convicted of any crime involving an act of dishonesty; or (e) committed an act or series of acts of dishonesty in the course of your employment.
9. Non-Solicitation. During the period commencing on the Effective Time and continuing through the third anniversary of the Effective Time (the "Restricted Period"), you shall not (a) solicit, diven, or take away, or attempt to divert or take away, either directly or indirectly, any of EDLG' s customers, clients, members, patrons, or any other person ,vith wbom you know or have reason to know then has a business or prospective business relationship with EDLG or (b) recruit or solicit any individual who is then an employee or other service provider to EDLO or any individual who w'as an employee or service provider to EDLG within the then most recent three-month period for employment or retention with you or any person or entity other than the EDLG with whom you are then associated. For purposes of clause (b) of the previous sentence, "recruit or solicit" means directly or indirectly to initiate correspondence, a telephone call, e-mail, or other fonn of oral, written, or electronic communication or a personal meeting with respect to the retention ofsuch individual or to facilitate any of the foregoing by a third party. For purposes ofthis Section 9 and Section 10 below, "EDLG" shall be deemed to include EDLG and each direct or indirect subsidiary thereof 10. Non-Competition. During the Restricted Period, you shall not, directly or indirectly, withom the prior written consent of the C1T Officers, own, manage, operate, join, control, or participate in the ownership, management, operation, or control of, or be connected as an officer. employee, partner, STockholder, consultant, or otherwise, in any business or organization that directly or indirectly comperes with EDLG's Business. For these purposes, the term "EDLG's Business" shall mean studem loan origination, ser,:icing, purcha.sing, selling, and sccurlrlzatioi1; providi!1g or- rnarkcting student loan products.;
j

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services, or solutions to students, parents, schools, alumni associations, or similar groups; originating or purchasing guaranteed student loans or consolidation Joans; offering or purchasing alternative supplemental loans guaranteed by third-party guarantors; selling originated loans to the secondary market; earning revenue by interest income or otherwise on any of the foregoing loans; offering consolidation loan products; or any other business activity in which EDLG is engaged during the Restricted Period or any business or activity materially relared to any of the foregoing. I I. Equitable Relief In addition to other remedies provided by l:nv or equity, upon breach by you of any of the restrictions contained in either of Section 10 or II above, EDLG shaLL be entitled to seek through a court a temporary or pennanent injunction against you prohibiting any further breach of any such restrictions.

[REMAiNDER OF PAGE INTENTiONALLY LEFT BLAhK.]

{Signature Page Folloll/sJ

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.-l..:.t ftXDfSG GROCI'. f'\C.

D~

12. ConfidetUiality. You remain subject to the tenus of the Confidentiality Agreement
you have previously executed in favor ofEDLG.

Fabrizio. we look torward to your continued employ'TI1Cnr fullo\\'ing the Effective Time.
Sincerely,
Education Lending Group, inc.

/"'

BY_\.~~~--DOl;
.I

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....~.----......"\,

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1£' ~ / '/'

AS L f'EIST


EVP and Secretary


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FROM

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EXHIBIT 2


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Apr 23 07 lO:50a

p.2 .

_

Vincent J. Schera
SVP, Human ResoUtees

CIT Group, Inc. Ona CIT Drive Ltvingston, NJ 07039

973-740-5347
Fax: 973·597·
Vjwl.S¢"",'Pcit.com

EDUCATION LENDING GROUP, INC.

January 10, 2006

Fabrizio "Breeze" Balestri President and CEO Student Loan Express, Inc. 12680 High Bluff Dri ve Suite 400 San Diego, CA 92130

Re:
Dear Fabrizio:

Retention Bonus Plan

The following sets forth the tenus and conditions of your Retention Bonus Plan and supersedes my letter to you dated August 22, 2005: . Retention Bonus Plan: Should Education Lending Group, Inc. (HEDLG") achieve Cumulative Total Disbursed Loan Volume (as set forth below) of$8.5BB for calendar years 2005,2006, and 2007, then you shall be paid the amount of $1 ,000,000, subject to deductions for required Federal and state tax: payments and withholdings. For purposes hereof, Total Disbursed Loan Volume ("TDLV") shall be determined each applicable calendar year period by calculating the total amount of loan volume disbursed and/or generated by all marketing channels ofEDLG, including secondary market purchases through SAL, Strategic Alliances, and portfolio purchase:

Calendar Year
2005

lDLV Amount $2,000,000,000
$2,800,000,000

Cumulative TDLV NiA
$4,800.000,000 $8.500.000,000

2006
2007

$3,700,000.000

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Apr 23 07 lO:51a

1".3

However, notwithstanding the above, any secondary market purchases in excess of the amounts set forth below for the applicable calendar year will be excluded from the calculation of TDlV:

Calendar Year
2005 2006
2007

Maximum Secondary Market Purchase Volume
Amount
$50,000,000

$100,000,000
$100,000,000

In addition, EDLG must, as a component of IDLV, have a minimum SLX Disbursed
Loan Volume (defined as Student Loan Xpress Loan Vohime disbursed and/or generated) each applicable calendar year or on a cumulative basis, the amounts set forth below:
Calendar Year
2005

SLX Disbursed Loan Volw:ne Amount
$1,000,000,000 $1,500,000,000 $1,950,000,000

2006 2007

Cumulative NIA $2,500,000,000 $4,450,000,000

This letter replaces and supercedes in its entirety paragr:wh 6, labeled "Stay Bonus", set forth in a letter dated January 4, 2005 from EDLG t(,) you.

Please sign below to confmn your understanding of these arrangements and return to me at your earliest convenience.
EDLG:
Executive:

EDUCATION LENDING GROUP, INC. a Delaware corporation

FABRIZIO BALESTRI

By:_/7","""~~~,,,,-,,~~=,,::~==-

_

Vincent Schera Senior V ice President

LFb"'Bal. - .

a fIZloestn

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EXHIBIT B


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StudentLoa

ress~)
A CIT Company

-YJ/r'(fJlfl JJI

SLX
Business Units

Student Loan Xpress (San Diego, Cincinnati, & Cleveland)
San Diego
(146 employees):
· Corporate · Sales & Marketing · Call Center · Accounting · Compliance · HR Department
Regional Representatives
(60+ employees)

Cleveland
(29 employees):
· Finance · IT Department

Cincinnati
(57 employees):
· Private Loans · HR Support · IT/Telephony

Xpress Loan Servicing (Cleveland-SLX subsidiary) [218 employees]
· Originations · Servicing · Collections · Compliance

private and confidential - not to be distributed

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EXHIBIT C


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University of San Francisco
School as Lender
Request for Bid (RFB)

January 26, 2007

Presented by:

StudentLoa
A CIT Company

Student Loan Xpress, Inc. 12680 High Bluff Drive, Suite 400 San Diego, CA 92130

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UNIVERSITY OF DENVER,

Response to FFElP School as lender
Request for Bid (RFB)

March 31, 2006

Presented By:

A CIT C"mpony

Student Loan Xpress, Inc. 12680 High Bluff Drive, Suite 400 San Diego, CA 92130

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lNl\iET{sln"oj IDUISVILLE
",,;0'=

m"-">

,

-

dare f() be gt(fa!

Response to Request for Proposal
Alumni Association
Student Loan Consolidation

December 9, 2005

Presented By:

StudentLoa
A CIT Company

Student Loan Xpress, Inc. 12680 High Bluff Drive Suite 400 San Diego, CA 92130

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EXHIBIT D


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StudentLoa~reS)

A CIT CompQlly

LeeAnn Rohman Chief Operating Officer Chief Sales Officer

12680 High Bluff Drive, Suite 310 San Diego, CA 92130 Direct: 866.311.8138 Cell: 865,716,7668 Fax: 858.480.2524 Email: [email protected]

Studentloa~ress~

A CIT Company

Margaret Bazini Chief Financial Officer

12680 High Bluff Drive, Suite 310 San Diego, CA 92130 Direct: 858.611.6603 Fax: 858.611.6079 Email: [email protected]

Case 3:08-cv-00846-JLS-JMA

Document 7-2

Filed 06/09/2008

Page 27 of 30

StudentLoa~ress~

A CIT Comporly

David Beach Executive Vice President

12680 High Bluff Drive, Suite 310 San Oiego, CA 92130

Chief Marketing Officer

Direct 658,617,6010
Fax 858.617.6079 Email [email protected]

Studentloa~reSS"

A (IT Company

Gary Rohmann Executive Vice President, Business Development

12680 High Bluff Drive, Suite 310
San Diego, CA 92130
Direct: 888.290.7986
Cell: 865.803.7404
Fax: 858.480.2523
Email: [email protected]


Case 3:08-cv-00846-JLS-JMA

Document 7-2

Filed 06/09/2008

Page 28 of 30

Studentloa~ress@

A. CIT Compoll)'

Travis Mottet Senior Vice President Information & Sales Support

12680 High Blu1l Drive, Suite 400
San Diego, CA 92130
Direct 858.617.6025
fax 619.374.7104
Email [email protected]


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A

en Company

Donna North Senior Vice President Human Resources

12680 High Blult Drive, Suite 310 San Diego, CA 92130 Direct 858.617.6624 Fax 858.617.6610 Email [email protected]

Case 3:08-cv-00846-JLS-JMA

Document 7-2

Filed 06/09/2008

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StudentLoa~re
Ken Guerrero Vice President Academic Services 12680 High 81uff Drive. Suite 400 San Diego. CA 92130 Direct: 858.617.6824 Fax: 858.480.2547 Email: [email protected]

®

A. CIT Company

StudentLoa~ress®

A CIT Compony

Nicole Casali Joseph Vice President. Marketing

12680 High Bluff Drive. Suite 310 San Diego, CA 92130 Direct 858.617.6012 Cell 619.990.3569 Fax 858.617.6616 Email [email protected]

StudentLoa~ress@

A CIT Compony

Daniel W. King
Vice President.
Call Center Operations


12680 High Bluff Drive. Suite 400 San Diego. CA 92130 Direct 858.617.6021 Cell 619.971.3699 Email [email protected]

Case 3:08-cv-00846-JLS-JMA

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Filed 06/09/2008

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Studentloa~ress

Rick Nichols Vice President - Telephony 12680 High Bluff Orive, Suite 400 San Diego, CA 92130 Direct: 858.611.6092 fax: 858.480.2525 Email: [email protected]

A (IT Compony

Studentloa~ress®

A ell Compony

Daniel Passov
Vice President
Online Marketing


12680 High Bluff Drive. Suite 310
San Diego. CA 92130
Direct: 858.611.6015
fax: 858.611.6616
Email: [email protected]


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A (I r Compony

Erin Guerrero Vice President Business Development

12680 High Bluff Drive, Suite 400
San Diego, CA 92130
Direct 866.159.1131 ext. 6011
fax 858.480.2529
Email [email protected]