Preview
FILED: CORTLAND COUNTY CLERK 07/06/2022 01:43 PM INDEX NO. EF22-280
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/06/2022
File # K130142
CONSUMER CREDIT TRANSACTION
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF CORTLAND
_________________________________
CROWN ASSET MANAGEMENT, LLC
Plaintiff, Index No.
-against- SUMMONS
AMY L KING A/K/A AMY KING
Plaintiff's Residence Address
3100 BRECKINRIDGE BLVD #725
DULUTH GA 30096
Defendant(s).
The Basis of this venue
designated is:
Defendant's residence
_________________________________
Defendant's Residence Address:
6872 STATE ROUTE 41
HOMER, NY 130778761
YOU ARE HEREBY SUMMONED to answer the complaint in this
action and to serve a copy of your answer, or, if the complaint
is not served with this summons, to serve a notice of appearance
on the plaintiff's attorney within twenty (20) days after the
service of this summons exclusive of the days of service (or
within thirty (30) days after the service is complete if this
summons is not personally delivered to you within the State of
New York).
You are hereby notified that should you fail to appear or
answer, judgment will be taken against you by default for the
relief demanded in the complaint.
Dated: 07/01/2022 PRESSLER, FELT & WARSHAW, LLP
Attorneys for Plaintiff
305 Broadway Suite 802
New York, NY 10 7
(888)312-860
[X] By:
a , Esq.
David B. Warshaw Esq.
[ ] By:
Ryan R. Tappan Esq.
[ ] By:
Craig S. Stiller Esq.
[ ] By:
Howard Schachter Esq.
[ ] By:
Patrick Wong Esq.
2022321694 EF22-280
07/06/2022 01:43:46PM
Pages 6
SUMMONS + COMPLAINT
Elizabeth Larkin, County Clerk
1 of 6
FILED: CORTLAND COUNTY CLERK 07/06/2022 01:43 PM INDEX NO. EF22-280
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/06/2022
File # Kl30142
SUPREME COURT OF THE STATE OF NEW YORK - COUNTY OF CORTLAND
__----------------------__________
CROWN ASSET MANAGEMENT, LLC
Plaintiff(s) Index No.
-against- COMPLAINT
AMY L KING A/K/A AMY KING
Defendant(s)
__________________________________
Plaintiff through its attorney, Pressler, Felt & Warshaw, LLP
complains of the Defendant(s) and alleges upon information and
belief as follows:
FACTS COMMON TO ALL COUNTS
1. CROWN ASSET MANAGEMENT, LLC (hereinafter "Plaintiff") is a
limited liability company formed under the the laws of the State
of Georgia.
2. AMY L KING A/K/A AMY KING (hereinafter "Defendant") resides
within the jurisdictional limits of this court.
3. Plaintiff is the current owner of the obligation sued upon,
and was assigned all the rights, title and interest to
Defendant's COMENITY BANK account number ending in 8858
(hereinafter "the Account").
4. The Plaintiff is not the original creditor. The Account
originated with COMENITY BANK. The name of the entity that owned
the Account at the date of default giving rise to a cause of
action is COMENITY BANK. The chain of title including COMENITY
BANK and all post default owners of the debt are as follows:
a. COMENITY BANK to Crown Asset Management, LLC on
11/08/21 with an amount due at the time of sale or
assignment in the amount of $2,601.54.
2 of 6
FILED: CORTLAND COUNTY CLERK 07/06/2022 01:43 PM INDEX NO. EF22-280
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/06/2022
FIRST CAUSE OF ACTION
5. Plaintiff repeats and incorporates the allegations set forth
in FACTS COMMON TO ALL COUNTS as if set forth at length herein.
6. Plaintiff alleges that Defendant is the responsible person for
this Account.
7. Upon information and belief, the statute of limitations for
the cause of action asserted herein is 3 years and therefore has
not expired.
8. Attached is a copy of the charge off statement.
9. The last four digits of the account number printed on the most
recent monthly statement recording a purchase transaction, last
payment or balance transfer is 8858.
10. The Account balance printed on the most recent monthly
statement recording a purchase transaction, last payment or
balance transfer is $1,988.34.
11. The last payment to the Account was on 02/26/21 in the amount
of $95.00.
12. By use of the Account, Defendant agreed to pay all the
amounts due on the Account.
13. Defendant failed to repay the balance owed on the Account,
which is now in default.
14. The amount due is $2,601.54, which is itemized as follows:
a. The total amount of the debt due as of charge-off:
$2,601.54.
b. The total amount of interest accrued since charge-off:
$0.00.
c. The total amount of non-interest charges or fees
accrued since charge-off: $0.00.
d. The total amount of payments and/or credits made on
the debt since charge-off:$0.00
15. There is now due and owing the Plaintiff, as the assignee of
the Account, from Defendant, the sum of $2,601.54.
3 of 6
FILED: CORTLAND COUNTY CLERK 07/06/2022 01:43 PM INDEX NO. EF22-280
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/06/2022
WHEREFORE, Plaintiff demands judgment against AMY L KING A/K/A AMY
KING
for the sum of $2,601.54 plus costs and disbursements of this
action and for such further and other relief as the Court deems
just and proper.
Dated: 07/01/2022 PRESSLER, FELT & WARSHAW, LLP
Attorneys for Plaintiff
305 Broadway Suite 802
New York, NY 10 7
(888)312-860
[X] By:
a Esq.
David B. Warshaw Esq.
[ ] By:
Ryan R. Tappan Esq.
[ ] By:
Craig S. Stiller Esq.
[ ] By:
Howard Schachter Esq.
[ ] By:
Patrick Wong Esq.
THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A
DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
4 of 6
FILED: CORTLAND COUNTY CLERK 07/06/2022 01:43 PM INDEX NO. EF22-280
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/06/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF CORTLAND
---------------------------------------------------------------x
CROWN ASSET MANAGEMENT, LLC
Plaintiff/Petitioner,
- against - Index No.
AMY L KING A/K/A AMY KING
Defendant/Respondent.
----------------------------------------x
NOTICE OF ELECTRONIC FILING
(Mandatory Case)
(Uniform Rule § 202.5-bb)
You have received this Notice because:
1) The Plaintiff/Petitioner, whose name is listed above, has filed this case using the
New York State Courts E-filing system ("NYSCEF"), and
2) You are a Defendant/Respondent (a party) in this case.
" If you are represented by an attorney:
Attorneys"
Give this Notice to your attorney. (Attorneys: see "Information for pg. 2).
" If you are not represented by an attorney:
You will be served with all documents in paper and you must serve and file your
documents in paper, unless you choose to participate in e-filing.
If you choose to participate in e-filing, you must have access to a computer and a
scanner or other device to convert documents into electronic format, a connection
to the internet, and an e-mail address to receive service of documents.
The benefits of participating in e-filing include:
" and filing your documents
serving electronically
" free access to view and print your e-filed documents
" your number of trips to the courthouse
limiting
" court fees on-line (credit card
paying any needed)
To register for e-filing or for more information about how e-filing works:
" visit: www.nycourts.gov/efile-unrepresented or
" contact the Clerk's Office or Center at the court where the case was filed. Court
Help
contact information can be found at www.nycourts.gov
Page 1 of 2 EFM-1
5 of 6
FILED: CORTLAND COUNTY CLERK 07/06/2022 01:43 PM INDEX NO. EF22-280
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/06/2022
To find legal information to help you represent yourself visit www.nycourthelp.gov
Information for Attorneys
(E-filing is Mandatory for Attorneys)
An attorney representing a party who is served with this notice must either:
1) immediately record his or her representation within the e-filed matter on the
NYSCEF site www.nycourts.gov/efile ; or
2) file the Notice of Opt-Out form with the clerk of the court where this action is
pending and serve on all parties. Exemptions from mandatory e-filing are limited to
attorneys who certify in good faith that they lack the computer hardware and/or
scanner and/or internet connection or that they lack (along with allemployees subject
to their direction) the knowledge to operate such equipment. [Section 202.5-bb(e)]
For additional information about electronic filing and to create a NYSCEF account, visit the
NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center
(phone: 646-386-3033; e-mail: nyscef@nycourts.gov).
Dated: 07/01/2022
Ian Z. Winograd
305 Broadway Suite 802
Name
Pressler, Felt & Warshaw, LLP New NY 10007
York,
Firm Name Address
1-888-312-8600
Phone
iwinograd@pfwattorneys.com
E-Mail
To: AMY L KING A/K/A AMY KING
6872 STATE ROUTE 41
HOMER, NY 130778761
PFW FileNumber Kl30142 2/24/20
Index # Page 2 of 2 EFM-1
6 of 6
Preview
FILED: CORTLAND COUNTY CLERK 07/06/2022 01:43 PM INDEX NO. EF22-280 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/06/2022 File # K130142 CONSUMER CREDIT TRANSACTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF CORTLAND _________________________________ CROWN ASSET MANAGEMENT, LLC Plaintiff, Index No. -against- SUMMONS AMY L KING A/K/A AMY KING Plaintiff's Residence Address 3100 BRECKINRIDGE BLVD #725 DULUTH GA 30096 Defendant(s). The Basis of this venue designated is: Defendant's residence _________________________________ Defendant's Residence Address: 6872 STATE ROUTE 41 HOMER, NY 130778761 YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance on the plaintiff's attorney within twenty (20) days after the service of this summons exclusive of the days of service (or within thirty (30) days after the service is complete if this summons is not personally delivered to you within the State of New York). You are hereby notified that should you fail to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: 07/01/2022 PRESSLER, FELT & WARSHAW, LLP Attorneys for Plaintiff 305 Broadway Suite 802 New York, NY 10 7 (888)312-860 [X] By: a , Esq. David B. Warshaw Esq. [ ] By: Ryan R. Tappan Esq. [ ] By: Craig S. Stiller Esq. [ ] By: Howard Schachter Esq. [ ] By: Patrick Wong Esq. 2022321694 EF22-280 07/06/2022 01:43:46PM Pages 6 SUMMONS + COMPLAINT Elizabeth Larkin, County Clerk 1 of 6 FILED: CORTLAND COUNTY CLERK 07/06/2022 01:43 PM INDEX NO. EF22-280 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/06/2022 File # Kl30142 SUPREME COURT OF THE STATE OF NEW YORK - COUNTY OF CORTLAND __----------------------__________ CROWN ASSET MANAGEMENT, LLC Plaintiff(s) Index No. -against- COMPLAINT AMY L KING A/K/A AMY KING Defendant(s) __________________________________ Plaintiff through its attorney, Pressler, Felt & Warshaw, LLP complains of the Defendant(s) and alleges upon information and belief as follows: FACTS COMMON TO ALL COUNTS 1. CROWN ASSET MANAGEMENT, LLC (hereinafter "Plaintiff") is a limited liability company formed under the the laws of the State of Georgia. 2. AMY L KING A/K/A AMY KING (hereinafter "Defendant") resides within the jurisdictional limits of this court. 3. Plaintiff is the current owner of the obligation sued upon, and was assigned all the rights, title and interest to Defendant's COMENITY BANK account number ending in 8858 (hereinafter "the Account"). 4. The Plaintiff is not the original creditor. The Account originated with COMENITY BANK. The name of the entity that owned the Account at the date of default giving rise to a cause of action is COMENITY BANK. The chain of title including COMENITY BANK and all post default owners of the debt are as follows: a. COMENITY BANK to Crown Asset Management, LLC on 11/08/21 with an amount due at the time of sale or assignment in the amount of $2,601.54. 2 of 6 FILED: CORTLAND COUNTY CLERK 07/06/2022 01:43 PM INDEX NO. EF22-280 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/06/2022 FIRST CAUSE OF ACTION 5. Plaintiff repeats and incorporates the allegations set forth in FACTS COMMON TO ALL COUNTS as if set forth at length herein. 6. Plaintiff alleges that Defendant is the responsible person for this Account. 7. Upon information and belief, the statute of limitations for the cause of action asserted herein is 3 years and therefore has not expired. 8. Attached is a copy of the charge off statement. 9. The last four digits of the account number printed on the most recent monthly statement recording a purchase transaction, last payment or balance transfer is 8858. 10. The Account balance printed on the most recent monthly statement recording a purchase transaction, last payment or balance transfer is $1,988.34. 11. The last payment to the Account was on 02/26/21 in the amount of $95.00. 12. By use of the Account, Defendant agreed to pay all the amounts due on the Account. 13. Defendant failed to repay the balance owed on the Account, which is now in default. 14. The amount due is $2,601.54, which is itemized as follows: a. The total amount of the debt due as of charge-off: $2,601.54. b. The total amount of interest accrued since charge-off: $0.00. c. The total amount of non-interest charges or fees accrued since charge-off: $0.00. d. The total amount of payments and/or credits made on the debt since charge-off:$0.00 15. There is now due and owing the Plaintiff, as the assignee of the Account, from Defendant, the sum of $2,601.54. 3 of 6 FILED: CORTLAND COUNTY CLERK 07/06/2022 01:43 PM INDEX NO. EF22-280 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/06/2022 WHEREFORE, Plaintiff demands judgment against AMY L KING A/K/A AMY KING for the sum of $2,601.54 plus costs and disbursements of this action and for such further and other relief as the Court deems just and proper. Dated: 07/01/2022 PRESSLER, FELT & WARSHAW, LLP Attorneys for Plaintiff 305 Broadway Suite 802 New York, NY 10 7 (888)312-860 [X] By: a Esq. David B. Warshaw Esq. [ ] By: Ryan R. Tappan Esq. [ ] By: Craig S. Stiller Esq. [ ] By: Howard Schachter Esq. [ ] By: Patrick Wong Esq. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 4 of 6 FILED: CORTLAND COUNTY CLERK 07/06/2022 01:43 PM INDEX NO. EF22-280 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/06/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF CORTLAND ---------------------------------------------------------------x CROWN ASSET MANAGEMENT, LLC Plaintiff/Petitioner, - against - Index No. AMY L KING A/K/A AMY KING Defendant/Respondent. ----------------------------------------x NOTICE OF ELECTRONIC FILING (Mandatory Case) (Uniform Rule § 202.5-bb) You have received this Notice because: 1) The Plaintiff/Petitioner, whose name is listed above, has filed this case using the New York State Courts E-filing system ("NYSCEF"), and 2) You are a Defendant/Respondent (a party) in this case. " If you are represented by an attorney: Attorneys" Give this Notice to your attorney. (Attorneys: see "Information for pg. 2). " If you are not represented by an attorney: You will be served with all documents in paper and you must serve and file your documents in paper, unless you choose to participate in e-filing. If you choose to participate in e-filing, you must have access to a computer and a scanner or other device to convert documents into electronic format, a connection to the internet, and an e-mail address to receive service of documents. The benefits of participating in e-filing include: " and filing your documents serving electronically " free access to view and print your e-filed documents " your number of trips to the courthouse limiting " court fees on-line (credit card paying any needed) To register for e-filing or for more information about how e-filing works: " visit: www.nycourts.gov/efile-unrepresented or " contact the Clerk's Office or Center at the court where the case was filed. Court Help contact information can be found at www.nycourts.gov Page 1 of 2 EFM-1 5 of 6 FILED: CORTLAND COUNTY CLERK 07/06/2022 01:43 PM INDEX NO. EF22-280 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/06/2022 To find legal information to help you represent yourself visit www.nycourthelp.gov Information for Attorneys (E-filing is Mandatory for Attorneys) An attorney representing a party who is served with this notice must either: 1) immediately record his or her representation within the e-filed matter on the NYSCEF site www.nycourts.gov/efile ; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is pending and serve on all parties. Exemptions from mandatory e-filing are limited to attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or internet connection or that they lack (along with allemployees subject to their direction) the knowledge to operate such equipment. [Section 202.5-bb(e)] For additional information about electronic filing and to create a NYSCEF account, visit the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone: 646-386-3033; e-mail: nyscef@nycourts.gov). Dated: 07/01/2022 Ian Z. Winograd 305 Broadway Suite 802 Name Pressler, Felt & Warshaw, LLP New NY 10007 York, Firm Name Address 1-888-312-8600 Phone iwinograd@pfwattorneys.com E-Mail To: AMY L KING A/K/A AMY KING 6872 STATE ROUTE 41 HOMER, NY 130778761 PFW FileNumber Kl30142 2/24/20 Index # Page 2 of 2 EFM-1 6 of 6