On February 27, 2024 a
Answer
was filed
involving a dispute between
Jpmorgan Chase Bank, N.A.,
and
Igor Grebenyuk,
for Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
in the District Court of Greene County.
Preview
FILED: GREENE COUNTY CLERK 03/18/2024 04:37 PM INDEX NO. EF2024-180
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 03/18/2024
COURT COUNTY OF f£Y19 Part:
TP r??× n drase Bank
,
M A,,
WRITTEN ANSWER
PlaintiH(s)
-against- CONSUMER CREDIT TRANSACTION
EGot2 GKE BENYUK
Defendant(s) index Number: E F 2024- Mo
ANSWER: (Check all that apply)
1. E General Denial: I deny the allegations in the Complaint.
SERVICE
2. O I did not receive a copy of the Summons and Complaint.
3. O I received the Summons and Complaint, but service was not correct as required by law.
DEFENSES
4. I do not owe this debt.
5. It is not my debt. I am a victim of identity theft or mistaken identity.
6. I have paid all or part of the alleged debt.
7. I dispute the amount of the debt.
8. I had no business dealings with Plaintiff (Plaintiff lacks standing).
9. , There is no record of plaintiff having a license to collect debt (only for cases filed in New York City, Buffalo and
other municipalities requiring debt collectors to be licensed).
10. O Plaintiff does not allege a debt collector's license number in the Complaint (only for cases filed in New York
City, Buffalo and other municipalities requiring debt collectors to be licensed).
11. Statute of limitations (the time has past to sue on this debt).
12. O This debt has been discharged in bankruptcy.
13. O The collateral (property) was not sold at a commercially reasonable price.
14. O Failure to provide proper notice before selling collateral (property).
15. O Failure to mitigate damages (Plaintiff did not take reasonable steps to limit damages).
16. ¤ Unjust enrichment (the amount demanded is excessive compared with the original debt).
17. ¤ Violation of the duty of good faith and fair dealing.
18. O Unconscionability (the contract is unfair).
19. O Laches (plaintiff has excessively delayed in bringing this lawsuit to my disadvantage).
20-a. O OUTSIDE OF NEW YORK CITY ONLY: Lack of personal jurisdiction under Uniform Cuy Court Act § 213 (applies if
you do not work in the city where the case was filed and you are not a resident of that
city or (for all counties
except Westchester and Nassau counties) you are not a resident of a town next to that city within the same
county).
20-b. O SUFFOLK COUNTY: Lack of personal jurisdiction; the defendant is not a resident and/or was not served in, or
there was no transaction of business in, that portion of Suffolk County for which a District Court has been
established (Towns of Huntington, Babylon, Islip, Smithtown and Brookhaven).
21. O Defendant is in the military.
OTHER
22. ' O Other Reasons
23. O Please take notice that my only source of income is , which is exempt from collection.
COUNTERCLAIM(S)
24. O Counterclaim(s): $ Reason:
VERIFICATION
State of Ne York County of £ff Lyr ss:
o '6 idd. , being duly sworn, deposes and says: I have read the Answer in Writing and know
the contents to be true rom my own knowledge, except as to those matters stated on information and belief, and as to
those matters I believe them to be true.
Sworn t efore m this / 8u\day of ( rCA , 20c
Signatureof Defendant
This case is scheduled to appear on the court calendar as follows:
Date: Part: Room: Time: Both sides notified:OYesONo
ucs-cc-1
1 of 2
FILED: GREENE COUNTY CLERK 03/18/2024 04:37 PM INDEX NO. EF2024-180
NYSCEF DOC. NO. 6New York State Unified Court System RECEIVED NYSCEF: 03/18/2024
nvcourts.gov
UCS-CCR1 (04/2022)
Page 1 of 2
Additional Notice of Lawsuit
nvcourthelp.aov
Name of Court: SUPREME COURT OF THE STATE OF NEW YORK, COUNTY OF
County: GREENE
Street Address: 411 Main St Suite 212
City, State, Zip Code: Catskill, New York 12414
Name of Defendant: IGOR GREBENYUK
Defendant Address: 7907 MAIN ST, HUNTER, NY 12442
Plaintif': JPMorgan Chase Bank, N.A.
Defendant: IGOR GREBENYUK
Original Creditor: JPMorgan Chase Bank, N.A.
Index Number: EF2024-180
Attention: a lawsuit has been filed against you claiming that you owe money for an unpaid consumer
debt.
You may wish to contact an attorney.
"answer"
You should respond to the lawsuit as soon as possible by filing an which may be done at
the court clerk's office listed above.
If you do not respond to the lawsuit, the court may enter a money judgment against you. Once
entered, a judgment is good and can be used against you for twenty years, and your personal
property and money, including a portion of your paycheck and/or bank account, inay be taken from
you. Also, a judgment may affect your credit score and can affect your ability to rent a home, find a
job, or take out a loan.
You CANNOT be arrested or sent to jail for owing a debt.
Additional information can be found at the New York State Court System website.
Sources of information and assitance:
The court encourages you to inform yourself about your options as a defendant in this lawsuit. In
addition to seeking assistance from a private attorney or legal aid office, there are free legal
assistance computer programs that you can use online to help you represent yourself in this lawsuit.
For further information, or to locate a legal aid program near you, you may visit the LawHelpNY
website or the New York State Court System website, which has information for representing yourself
and links to other resources at:
https://www.nycourts.gov/courthelp/MonevProblems/whenYouOwe.shtml.
ADA Accommodations Spoken or Sign Language 1-800-COURT-NY
ada@nycourts.gov interpreter@nycourts.gov (268-7869)
2 of 2
Document Filed Date
March 18, 2024
Case Filing Date
February 27, 2024
Category
Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: GREENE COUNTY CLERK 03/18/2024 04:37 PM INDEX NO. EF2024-180 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 03/18/2024 COURT COUNTY OF f¬£Y19 Part: TP r??× n drase Bank , M A,, WRITTEN ANSWER PlaintiH(s) -against- CONSUMER CREDIT TRANSACTION EGot2 GKE BENYUK Defendant(s) index Number: E F 2024- Mo ANSWER: (Check all that apply) 1. E General Denial: I deny the allegations in the Complaint. SERVICE 2. O I did not receive a copy of the Summons and Complaint. 3. O I received the Summons and Complaint, but service was not correct as required by law. DEFENSES 4. I do not owe this debt. 5. It is not my debt. I am a victim of identity theft or mistaken identity. 6. I have paid all or part of the alleged debt. 7. I dispute the amount of the debt. 8. I had no business dealings with Plaintiff (Plaintiff lacks standing). 9. , There is no record of plaintiff having a license to collect debt (only for cases filed in New York City, Buffalo and other municipalities requiring debt collectors to be licensed). 10. O Plaintiff does not allege a debt collector's license number in the Complaint (only for cases filed in New York City, Buffalo and other municipalities requiring debt collectors to be licensed). 11. Statute of limitations (the time has past to sue on this debt). 12. O This debt has been discharged in bankruptcy. 13. O The collateral (property) was not sold at a commercially reasonable price. 14. O Failure to provide proper notice before selling collateral (property). 15. O Failure to mitigate damages (Plaintiff did not take reasonable steps to limit damages). 16. ¤ Unjust enrichment (the amount demanded is excessive compared with the original debt). 17. ¤ Violation of the duty of good faith and fair dealing. 18. O Unconscionability (the contract is unfair). 19. O Laches (plaintiff has excessively delayed in bringing this lawsuit to my disadvantage). 20-a. O OUTSIDE OF NEW YORK CITY ONLY: Lack of personal jurisdiction under Uniform Cuy Court Act § 213 (applies if you do not work in the city where the case was filed and you are not a resident of that city or (for all counties except Westchester and Nassau counties) you are not a resident of a town next to that city within the same county). 20-b. O SUFFOLK COUNTY: Lack of personal jurisdiction; the defendant is not a resident and/or was not served in, or there was no transaction of business in, that portion of Suffolk County for which a District Court has been established (Towns of Huntington, Babylon, Islip, Smithtown and Brookhaven). 21. O Defendant is in the military. OTHER 22. ' O Other Reasons 23. O Please take notice that my only source of income is , which is exempt from collection. COUNTERCLAIM(S) 24. O Counterclaim(s): $ Reason: VERIFICATION State of Ne York County of £ff Lyr ss: o '6 idd. , being duly sworn, deposes and says: I have read the Answer in Writing and know the contents to be true rom my own knowledge, except as to those matters stated on information and belief, and as to those matters I believe them to be true. Sworn t efore m this / 8u\day of ( rCA , 20c Signatureof Defendant This case is scheduled to appear on the court calendar as follows: Date: Part: Room: Time: Both sides notified:OYesONo ucs-cc-1 1 of 2 FILED: GREENE COUNTY CLERK 03/18/2024 04:37 PM INDEX NO. EF2024-180 NYSCEF DOC. NO. 6New York State Unified Court System RECEIVED NYSCEF: 03/18/2024 nvcourts.gov UCS-CCR1 (04/2022) Page 1 of 2 Additional Notice of Lawsuit nvcourthelp.aov Name of Court: SUPREME COURT OF THE STATE OF NEW YORK, COUNTY OF County: GREENE Street Address: 411 Main St Suite 212 City, State, Zip Code: Catskill, New York 12414 Name of Defendant: IGOR GREBENYUK Defendant Address: 7907 MAIN ST, HUNTER, NY 12442 Plaintif': JPMorgan Chase Bank, N.A. Defendant: IGOR GREBENYUK Original Creditor: JPMorgan Chase Bank, N.A. Index Number: EF2024-180 Attention: a lawsuit has been filed against you claiming that you owe money for an unpaid consumer debt. You may wish to contact an attorney. "answer" You should respond to the lawsuit as soon as possible by filing an which may be done at the court clerk's office listed above. If you do not respond to the lawsuit, the court may enter a money judgment against you. Once entered, a judgment is good and can be used against you for twenty years, and your personal property and money, including a portion of your paycheck and/or bank account, inay be taken from you. Also, a judgment may affect your credit score and can affect your ability to rent a home, find a job, or take out a loan. You CANNOT be arrested or sent to jail for owing a debt. Additional information can be found at the New York State Court System website. Sources of information and assitance: The court encourages you to inform yourself about your options as a defendant in this lawsuit. In addition to seeking assistance from a private attorney or legal aid office, there are free legal assistance computer programs that you can use online to help you represent yourself in this lawsuit. For further information, or to locate a legal aid program near you, you may visit the LawHelpNY website or the New York State Court System website, which has information for representing yourself and links to other resources at: https://www.nycourts.gov/courthelp/MonevProblems/whenYouOwe.shtml. ADA Accommodations Spoken or Sign Language 1-800-COURT-NY ada@nycourts.gov interpreter@nycourts.gov (268-7869) 2 of 2