On September 02, 2022 a
Party Statement
was filed
involving a dispute between
Td Bank Usa, N.A.,
and
Melissa M Conyers,
for Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
in the District Court of Saratoga County.
Preview
FILED: SARATOGA COUNTY CLERK 11/28/2022 12:35 PM INDEX NO. EF20221945
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/28/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SARATOGA
INDEX NUMBER EF20221945
TD BANK USA, N.A.
PLAINTIFF, FILE NO. F062394
-AGAINST- AFFIRMATION
MELISSA M CONYERS
DEFENDANT.
AFFIRMATION OF NON-EXPIRATION OF STATUTE OF LIMITATIONS
Joseph Ranaldo, 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 August 11, 2021. The statute of limitations for the cause of action asserted herein is
three years based on the law in New York. The written action was filed on or about September 2,
2022. 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: November 23, 2022
JEseph Ranaldo, Esq
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Document Filed Date
November 28, 2022
Case Filing Date
September 02, 2022
Category
Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
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FILED: SARATOGA COUNTY CLERK 11/28/2022 12:35 PM INDEX NO. EF20221945 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/28/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SARATOGA INDEX NUMBER EF20221945 TD BANK USA, N.A. PLAINTIFF, FILE NO. F062394 -AGAINST- AFFIRMATION MELISSA M CONYERS DEFENDANT. AFFIRMATION OF NON-EXPIRATION OF STATUTE OF LIMITATIONS Joseph Ranaldo, 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 August 11, 2021. The statute of limitations for the cause of action asserted herein is three years based on the law in New York. The written action was filed on or about September 2, 2022. 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: November 23, 2022 JEseph Ranaldo, Esq 11111111111111111111111111111ll11111111111111 1111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111 1 of 1