On October 12, 2021 a
Party Statement
was filed
involving a dispute between
Synchrony Bank,
and
Andrea Robinson,
for Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
in the District Court of Yates County.
Preview
FILED: YATES COUNTY CLERK 04/18/2022 11:12 AM INDEX NO. 2021-5267
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/18/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF YATES
INDEX NUMBER 2021-5267
SYNCHRONY BANK
PLAINTIFF, FILE NO. G1745569
-AGAINST-
ANDREA ROBINSON
DEFENDANT.
AFFIRMATION OF NON-EXPIRATION OF STATUTE OF LIMITATIONS
Mitchell G. Slamowitz, Esq., an attorney duly admitted to the practice of law in the State
of New York, hereby affirms the following to be true pursuant to CPLR § 2106 and under the
penalties of perjury states that:
1. The statute of limitations for the cause of action asserted herein commenced running
on or about December 18, 2020. The statute of limitations for the cause of action asserted herein
is four years based on the law in Utah, which is where SYNCHRONY BANK , the original
creditor of the Account, is located. The written action was filed on or about October 12, 2021.
Based on my reasonable inquiry, I believe the applicable statute of limitations for the cause of
action asserted herein did not expire prior to the filing of this action.
WHEREFORE, Plaintiff respectfully requests the entry of a default judgment against the
Defendant(s).
I certify that, to the best of my knowledge, information, and belief, formed after an
inquiry reasonable under the circumstances, that the presentation of this judgment and all
papers or the contentions herein are not frivolous as defined in 22 NYCRR 130-
accompanying §
1-1(a).
Dated: April 13, 2022
Mitchell . Slamowitz, Esq.
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Document Filed Date
April 18, 2022
Case Filing Date
October 12, 2021
Category
Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
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FILED: YATES COUNTY CLERK 04/18/2022 11:12 AM INDEX NO. 2021-5267 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/18/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF YATES INDEX NUMBER 2021-5267 SYNCHRONY BANK PLAINTIFF, FILE NO. G1745569 -AGAINST- ANDREA ROBINSON DEFENDANT. AFFIRMATION OF NON-EXPIRATION OF STATUTE OF LIMITATIONS Mitchell G. Slamowitz, Esq., an attorney duly admitted to the practice of law in the State of New York, hereby affirms the following to be true pursuant to CPLR § 2106 and under the penalties of perjury states that: 1. The statute of limitations for the cause of action asserted herein commenced running on or about December 18, 2020. The statute of limitations for the cause of action asserted herein is four years based on the law in Utah, which is where SYNCHRONY BANK , the original creditor of the Account, is located. The written action was filed on or about October 12, 2021. Based on my reasonable inquiry, I believe the applicable statute of limitations for the cause of action asserted herein did not expire prior to the filing of this action. WHEREFORE, Plaintiff respectfully requests the entry of a default judgment against the Defendant(s). I certify that, to the best of my knowledge, information, and belief, formed after an inquiry reasonable under the circumstances, that the presentation of this judgment and all papers or the contentions herein are not frivolous as defined in 22 NYCRR 130- accompanying § 1-1(a). Dated: April 13, 2022 Mitchell . Slamowitz, Esq. 11111111111111111111111111111111111111111111111111 1111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111 1 of 1