On May 19, 2021 a
Exhibit,Appendix
was filed
involving a dispute between
Midland Credit Management, Inc,
and
Kristal L Gessler,
for Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff
in the District Court of Saratoga County.
Preview
FILED: SARATOGA COUNTY CLERK 10/07/2021 02:28 PM INDEX NO. EF20211477
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 10/07/2021
STATE OF NEW YORK
SUPREME COURT COUNTY OF SARATOGA
Mi)LAND - AMENDED ANSWER
CREDIT MANAGEMENT, INC.
Plaintiff, . Index No. EF20211477
Against
KRISTAL L. GESSLER,
Defendant.
Defendant, as and for an answer to.the plaintiff's cordplaiñt, through her attorneys,
Pentkowski & Pastore, sets forth as follows:
1. Defendant lacks knowledge or information sufficient to form a belief as to the truth or
falsity of the allegations contained in paragraphs 1 and 6 of the plaintiff's complaint.
2. Defendant admits the allegations coñtained in paragraph 2 of the plaintiff's complaint.
3. Defendant denies the allegations contained in paragraphs 3, 4, 5,7 and 8 of the
plaintiff's complaint.
4. Defêñdant denies each and every other allegation in plaintiff's complaint not
previously admitted or denied.
AS AND FOR A FIRST AFFIRMATIVE DEFENSE, DEFENDANT ALLEGES:
5. Plaintiff lacks personal jurisdiction over defendant.
WHEREFORE, defendant demands judgment against the plaintiff dismissing the
plaintiff's complaint in allrespects, together with costs and disbursements of this action and such
PENTKOWSKI & PASTORE
FILED: SARATOGA COUNTY CLERK 10/07/2021 02:28 PM INDEX NO. EF20211477
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 10/07/2021
other further and different reliefas to this Court may seem just and proper.
Dat d: August , 2021
PENTK PA O
Da d . Pentkowski, Esq.
Attorneys for Defendant
P.O. Box 445
Clifton Park NY 12065
TO: PRESSLER, FELT & WARSHAW, LLP
Steven P. Bann, Esq.
Attorneys for Plaintiff
305 Broadway, Suite 802
New York, NY 10007
PENTKOWSKI & PASTORE
FILED: SARATOGA COUNTY CLERK 10/07/2021 02:28 PM INDEX NO. EF20211477
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 10/07/2021
PENTKOWSKI&PASTORE
.ATTORNEYS AT LAW
PO BOX 445
CLIFION PARK, NY 12065
-
TEL (518)383-S300
H. Pen FAX (518)383-5347 OFFICE LOCATION
David owski
John P. Pasto
e 5 IDNGKILL ROAD
BALISTON LAKE, NY
August 24, 2021
Pressler, Felt & Warshaw, LLP
Steven P. Bann, Esq.
305 Broadway, Suite 802
New York, NY 10007
Re: Midland Credit Management, Inc. vs. Kristal L. Gessler
De -Mr. Bann:
Ene sed ple fir d a copy of the defendant's amended answer with regard to the above action.
V , uly ours,
H. n wski
HP/ps
Enc.
... ..
FILED: SARATOGA COUNTY CLERK 10/07/2021 02:28 PM INDEX NO. EF20211477
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 10/07/2021
SUPREME
COURT
STATE OF NEW YORK. COUNTY OF Index No. Year
MIDLAND CREDIT MANAGEMENT, INC.,
PlaintifE
Against
KRISTAL L. GESSLER,
Defendant.
AMENDED ANSWER
PENTKOWSKI & PASTORE
Attornegs)for Defendant
0.#Iceand PostOpice Address, Telephone
P.O.Box445
CUFTONPARK, NEWYORK12065-0445
(518)383-5300
Signature (Rule 130-1.1-a)
Printnamebeneath
Service of a copyof thewithinis herebyadmitted.
Attorney(s)for
PLEASE TAKE NOTICE:
O NOTICE OF ENTRY
that the within is a (certified)true copy ofa
duly entered in the officeof the clerk of the within named court on
O NOTICE OF SETTLEMENT
that an order of which the within is a truecopy
will be presented for settlement to the HON. one of the judges of the
within named Court, at
on at M.
Dated,
Yours, etc.
PENTKOWSKI & PASTORE
FILED: SARATOGA COUNTY CLERK 10/07/2021 02:28 PM INDEX NO. EF20211477
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 10/07/2021
PERTKOWSKI&PASßRE
ALBANY NY 120
ATTORNEYS AT3fAW ..r ·-
PO BOX 445
CLIFTON PARK, NY 12065
02
000
MAI
t
Pressler, Felt & Warshaw, LLP
Steven P. Bann, Esq.
305 Broadway, Suite 802
New York, NY 10007
Document Filed Date
October 07, 2021
Case Filing Date
May 19, 2021
Category
Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff
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FILED: SARATOGA COUNTY CLERK 10/07/2021 02:28 PM INDEX NO. EF20211477 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 10/07/2021 STATE OF NEW YORK SUPREME COURT COUNTY OF SARATOGA Mi)LAND - AMENDED ANSWER CREDIT MANAGEMENT, INC. Plaintiff, . Index No. EF20211477 Against KRISTAL L. GESSLER, Defendant. Defendant, as and for an answer to.the plaintiff's cordplaiñt, through her attorneys, Pentkowski & Pastore, sets forth as follows: 1. Defendant lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in paragraphs 1 and 6 of the plaintiff's complaint. 2. Defendant admits the allegations coñtained in paragraph 2 of the plaintiff's complaint. 3. Defendant denies the allegations contained in paragraphs 3, 4, 5,7 and 8 of the plaintiff's complaint. 4. Defêñdant denies each and every other allegation in plaintiff's complaint not previously admitted or denied. AS AND FOR A FIRST AFFIRMATIVE DEFENSE, DEFENDANT ALLEGES: 5. Plaintiff lacks personal jurisdiction over defendant. WHEREFORE, defendant demands judgment against the plaintiff dismissing the plaintiff's complaint in allrespects, together with costs and disbursements of this action and such PENTKOWSKI & PASTORE FILED: SARATOGA COUNTY CLERK 10/07/2021 02:28 PM INDEX NO. EF20211477 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 10/07/2021 other further and different reliefas to this Court may seem just and proper. Dat d: August , 2021 PENTK PA O Da d . Pentkowski, Esq. Attorneys for Defendant P.O. Box 445 Clifton Park NY 12065 TO: PRESSLER, FELT & WARSHAW, LLP Steven P. Bann, Esq. Attorneys for Plaintiff 305 Broadway, Suite 802 New York, NY 10007 PENTKOWSKI & PASTORE FILED: SARATOGA COUNTY CLERK 10/07/2021 02:28 PM INDEX NO. EF20211477 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 10/07/2021 PENTKOWSKI&PASTORE .ATTORNEYS AT LAW PO BOX 445 CLIFION PARK, NY 12065 - TEL (518)383-S300 H. Pen FAX (518)383-5347 OFFICE LOCATION David owski John P. Pasto e 5 IDNGKILL ROAD BALISTON LAKE, NY August 24, 2021 Pressler, Felt & Warshaw, LLP Steven P. Bann, Esq. 305 Broadway, Suite 802 New York, NY 10007 Re: Midland Credit Management, Inc. vs. Kristal L. Gessler De -Mr. Bann: Ene sed ple fir d a copy of the defendant's amended answer with regard to the above action. V , uly ours, H. n wski HP/ps Enc. ... .. FILED: SARATOGA COUNTY CLERK 10/07/2021 02:28 PM INDEX NO. EF20211477 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 10/07/2021 SUPREME COURT STATE OF NEW YORK. COUNTY OF Index No. Year MIDLAND CREDIT MANAGEMENT, INC., PlaintifE Against KRISTAL L. GESSLER, Defendant. AMENDED ANSWER PENTKOWSKI & PASTORE Attornegs)for Defendant 0.#Iceand PostOpice Address, Telephone P.O.Box445 CUFTONPARK, NEWYORK12065-0445 (518)383-5300 Signature (Rule 130-1.1-a) Printnamebeneath Service of a copyof thewithinis herebyadmitted. Attorney(s)for PLEASE TAKE NOTICE: O NOTICE OF ENTRY that the within is a (certified)true copy ofa duly entered in the officeof the clerk of the within named court on O NOTICE OF SETTLEMENT that an order of which the within is a truecopy will be presented for settlement to the HON. one of the judges of the within named Court, at on at M. Dated, Yours, etc. PENTKOWSKI & PASTORE FILED: SARATOGA COUNTY CLERK 10/07/2021 02:28 PM INDEX NO. EF20211477 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 10/07/2021 PERTKOWSKI&PASßRE ALBANY NY 120 ATTORNEYS AT3fAW ..r ·- PO BOX 445 CLIFTON PARK, NY 12065 02 000 MAI t Pressler, Felt & Warshaw, LLP Steven P. Bann, Esq. 305 Broadway, Suite 802 New York, NY 10007