(Breach of Contract)   (Violation of California Business & Professions Code Sections 17200, et seq. –  Unfair Competition Law – Unlawful Prong)   (Violation of California Business & Professions Code Sections 17200, et seq. –  Unfair Competition Law - Unfair Prong)   14.  Plaintiff Moody brings this litigation, on her own behalf and on behalf of the  following Class, pursuant to Federal Rule of Civil Procedure 23:   All mortgage loan customers of Citi (or its subsidiaries), whose mortgage loan is for a one- to-four family residence located in California, and who paid Citi or its agents or loan  servicers money in advance for payment of taxes and assessments on the Property, for  insurance, or for other purposes relating to the Property, and to whom Citi and its agents  and loan servicers failed to pay interest as required by §2954.8(a). Excluded from the above  Class is any entity in which Defendant has a controlling interest, and officers or directors  of Defendant. The judge assigned to this case and the judge’s staff members are also  excluded from the Class.    15.  Plaintiff reserves the right under Rule 23 to amend or modify the Class  descriptions with greater specificity or further division into subclasses or limitation to particular  issues, based on the results of discovery and further investigation.   16.  The members of the Class are so numerous that their individual joinder is  impracticable. Because the class members may be identified through business records regularly  maintained by Defendant and its employees and agents, and through the media, the number and  identities of class members can be ascertained. Members of the Class can be notified of the  pending action by e-mail, mail, and by published notice, if necessary.   23.  Plaintiff incorporates by reference and re-alleges all paragraphs previously alleged.   26.  Plaintiff incorporates by reference and re-allege all paragraphs previously alleged.   27.  Defendant’s conduct is unfair under the UCL because it has no utility and, even if  it did, any utility is outweighed by the gravity of harm to Plaintiff and the Class members.  Defendant’s practice is also immoral, unethical, oppressive or unscrupulous and causes injury to  consumers which outweighs its benefits.   28.  Plaintiff and the Class members, and each of them, have been damaged by these  practices. Pursuant to California Business and Professions Code § 17200 et seq. Plaintiff, on her  own behalf and on behalf of all others similarly situated, seek relief as prayed for below.   29.  Plaintiff incorporates by reference and re-alleges all paragraphs previously alleged.  