On September 29, 2022 a
Complaint,Petition
was filed
involving a dispute between
U.S. Bank National Association D B A Elan Financial Services,
and
Laura M Morris,
for Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
in the District Court of Chenango County.
Preview
FILED: CHENANGO COUNTY CLERK 09/29/2022 02:02 PM INDEX NO. 2022-00005396
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/29/2022
CONSUMER CREDIT TRANSACTION
SUPREME COURT
COUNTY OF CHENANGO STATE OF NEW YORK
U.S. BANK NATIONAL ASSOCIATION d/b/a Index No.
ELAN FINANCIAL SERVICES,
Plaintiff S U M M O N S
- vs. -
The basis of the venue designated is
LAURA M MORRIS, Defendant's residence.
149 THOMPSON RD Plaintiff's address:
NORWICH, NY 13815 425 WALNUT STREET
Defendant(s) CINCINNATI, OH 45202
TO THE ABOVE-NAMED DEFENDANT(S):
YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to
serve a copy of your Answer on the attorneys for plaintiff within 20 days after the service of the
Summons, exclusive of the days of service (or within 30 days after the service is complete if this
summons is not personally delivered to you within the State of New York); and in case of your
failure to appear or answer, judgment will be taken against you by default for the relief
demanded herein. The basis of venue is the Defendant(s) res ence.
DATED:
[ ASON P. V AGEN, ESQ.
[ JOSEPH JA S, ESQ.
[ ] ELIZABET CLARKE, ESQ.
[ ] STEPHANI MAIDA, ESQ.
ZWICKER & ASSOCIATES, P.C.
A Law Firm Engaged in Debt Collection
100 CORPORATE WOODS, SUITE 230
ROCHESTER, NY 14623
(585)427-0482
ZANYLITIGATION@ZWICKERPC.COM
262350030604
1 of 3
FILED: CHENANGO COUNTY CLERK 09/29/2022 02:02 PM INDEX NO. 2022-00005396
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/29/2022
SUPREME COURT
COUNTY OF CHENANGO STATE OF NEW YORK
U.S. BANK NATIONAL ASSOCIATION d/b/a ELAN Index No.
FINANCIAL SERVICES,
Plaintiff, COMPLAINT
vs.
LAURA M MORRIS,
Defendant(s).
Plaintiff, by and through its attorneys, Zwicker & Associates P.C., complaining of
Defendant(s), respectfully alleges upon information and belief:
1. U.S. Bank National Association is a national banking association organized under
the laws of the United States of America. Plaintiff is the original creditor.
2. Defendant(s) reside(s) and/or maintain(s) an address and/or domicile sufficient to
allow this Court to maintain jurisdiction and venue of Plaintiff's claims.
3. Defendant(s) entered into a credit agreement (hereinafter "Agreement") with
Plaintiff.
4. The last four digits of the account number that was printed on the most recent
monthly statement recording a purchase transaction, last payment, or balance transfer was 9786.
5. The balance printed on the most recent monthly statement recording a purchase
transaction, last payment, or balance transfer was $6,439.27.
6. The last payment, in the amount of $148.00 posted to the account on 10/04/21.
7. Defendant(s) defaulted on the terms of the aforementioned Agreement.
8. There is now due and owing to Plaintiff from Defendant(s), as a result of the
aforementioned breach of the Agreement by Defendant(s), the sum of $6,544.48, itemized as
follows: $6,544.48, the total amount due at charge-off; plus $0.00, the total amount of interest
262350030604
2 of 3
FILED: CHENANGO COUNTY CLERK 09/29/2022 02:02 PM INDEX NO. 2022-00005396
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/29/2022
accrued since charge-off; plus $0.00, the total amount of non-interest charges or fees accrued
since charge-off; less $0.00, the total amount of payments and/or credits since charge-off.
9. The contract or other written instrument on which the action is based is attached
hereto as Exhibit A.
Wherefore, Plaintiff demands judgment in the amount of $6,544.48 against
Defendant(s).
DATED:
[ JASON P ERHAGEN, ESQ.
] JOSEP KAS, ESQ.
[ ] ELIZA TH CLARKE, ESQ.
[ ]STEPH NIE MAIDA, ESQ.
ZWICKER & ASSOCIATES, P.C.
A Law Firm Engaged in Debt Collection
100 CORPORATE WOODS, SUITE 230
ROCHESTER, NY 14623
(585)427-0482
ZANYLITIGATION@ZWICKERPC.COM
262350030604
3 of 3
Document Filed Date
September 29, 2022
Case Filing Date
September 29, 2022
Category
Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
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FILED: CHENANGO COUNTY CLERK 09/29/2022 02:02 PM INDEX NO. 2022-00005396 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/29/2022 CONSUMER CREDIT TRANSACTION SUPREME COURT COUNTY OF CHENANGO STATE OF NEW YORK U.S. BANK NATIONAL ASSOCIATION d/b/a Index No. ELAN FINANCIAL SERVICES, Plaintiff S U M M O N S - vs. - The basis of the venue designated is LAURA M MORRIS, Defendant's residence. 149 THOMPSON RD Plaintiff's address: NORWICH, NY 13815 425 WALNUT STREET Defendant(s) CINCINNATI, OH 45202 TO THE ABOVE-NAMED DEFENDANT(S): YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a copy of your Answer on the attorneys for plaintiff within 20 days after the service of the Summons, exclusive of the days of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded herein. The basis of venue is the Defendant(s) res ence. DATED: [ ASON P. V AGEN, ESQ. [ JOSEPH JA S, ESQ. [ ] ELIZABET CLARKE, ESQ. [ ] STEPHANI MAIDA, ESQ. ZWICKER & ASSOCIATES, P.C. A Law Firm Engaged in Debt Collection 100 CORPORATE WOODS, SUITE 230 ROCHESTER, NY 14623 (585)427-0482 ZANYLITIGATION@ZWICKERPC.COM 262350030604 1 of 3 FILED: CHENANGO COUNTY CLERK 09/29/2022 02:02 PM INDEX NO. 2022-00005396 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/29/2022 SUPREME COURT COUNTY OF CHENANGO STATE OF NEW YORK U.S. BANK NATIONAL ASSOCIATION d/b/a ELAN Index No. FINANCIAL SERVICES, Plaintiff, COMPLAINT vs. LAURA M MORRIS, Defendant(s). Plaintiff, by and through its attorneys, Zwicker & Associates P.C., complaining of Defendant(s), respectfully alleges upon information and belief: 1. U.S. Bank National Association is a national banking association organized under the laws of the United States of America. Plaintiff is the original creditor. 2. Defendant(s) reside(s) and/or maintain(s) an address and/or domicile sufficient to allow this Court to maintain jurisdiction and venue of Plaintiff's claims. 3. Defendant(s) entered into a credit agreement (hereinafter "Agreement") with Plaintiff. 4. The last four digits of the account number that was printed on the most recent monthly statement recording a purchase transaction, last payment, or balance transfer was 9786. 5. The balance printed on the most recent monthly statement recording a purchase transaction, last payment, or balance transfer was $6,439.27. 6. The last payment, in the amount of $148.00 posted to the account on 10/04/21. 7. Defendant(s) defaulted on the terms of the aforementioned Agreement. 8. There is now due and owing to Plaintiff from Defendant(s), as a result of the aforementioned breach of the Agreement by Defendant(s), the sum of $6,544.48, itemized as follows: $6,544.48, the total amount due at charge-off; plus $0.00, the total amount of interest 262350030604 2 of 3 FILED: CHENANGO COUNTY CLERK 09/29/2022 02:02 PM INDEX NO. 2022-00005396 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/29/2022 accrued since charge-off; plus $0.00, the total amount of non-interest charges or fees accrued since charge-off; less $0.00, the total amount of payments and/or credits since charge-off. 9. The contract or other written instrument on which the action is based is attached hereto as Exhibit A. Wherefore, Plaintiff demands judgment in the amount of $6,544.48 against Defendant(s). DATED: [ JASON P ERHAGEN, ESQ. ] JOSEP KAS, ESQ. [ ] ELIZA TH CLARKE, ESQ. [ ]STEPH NIE MAIDA, ESQ. ZWICKER & ASSOCIATES, P.C. A Law Firm Engaged in Debt Collection 100 CORPORATE WOODS, SUITE 230 ROCHESTER, NY 14623 (585)427-0482 ZANYLITIGATION@ZWICKERPC.COM 262350030604 3 of 3