Preview
FILED: TIOGA COUNTY CLERK 12/21/2022 12:01 PM INDEX NO. 2022-00062766
NYSCEFSUPREME
DOC. NO.COURT
1 OF THE STATE OF NEW YORK Index No. RECEIVED NYSCEF: 12/21/2022
COUNTY OF TIOGA Date Filed: ________________
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CITIBANK, N.A.
SUMMONS (ORIGINAL)
Plaintiff
-against-
GRANT H MORSE The basis of venue is:
DEFENDANT'S RESIDENCE
Defendant(s) Plaintiff's Residence:
---------------------------------------- 5800 SOUTH CORPORATE PLACE
SIOUX FALLS, SD 57108
CONSUMER CREDIT TRANSACTION County of MINNEHAHA
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, or, if the complaint is not served with this summons
to serve a notice of appearance, on the Plaintiff's Attorney(s) within
TWENTY days after the service of this summons, exclusive of the day of
service (or within THIRTY 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.
Dated: Islandia, New York
RUBIN & ROTHMAN, LLC
Attorneys for Plaintiff
12/20/22 1787 Veterans Highway
Islandia, N.Y. 11749
(631) 234-1500
DEFENDANT(S) ADDRESS:
GRANT H MORSE
1517 E RIVER RD NICHOLS, NY 13812-2533
WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
NYC DCA LIC. 2045512
Our File No. 1453590 Y 41 0- 0 U SZM 000
000006434046
1 of 8
FILED: TIOGA COUNTY CLERK 12/21/2022 12:01 PM INDEX NO. 2022-00062766
NYSCEFSUPREME
DOC. NO.COURT
1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 12/21/2022
COUNTY OF TIOGA Index No.
----------------------------------------
CITIBANK, N.A.
Plaintiff
-against- COMPLAINT (ORIGINAL)
GRANT H MORSE
Defendant(s)
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Plaintiff, by its attorneys, complaining of the defendant(s), alleges:
AS AND FOR A FIRST CAUSE OF ACTION
1. Defendant(s) resides in the county in which this action is brought;
or transacted business in the county in which this action is brought
in person or through an agent, or this cause of action arose out of
said transaction. Plaintiff is not required to be licensed by the
NYC Dept of Consumer Affairs because it is the original creditor.
2. Plaintiff is a national bank located in South Dakota.
3. Defendant(s) used a revolving credit account with Plaintiff and
agreed to make payments for goods and services charged, balance
transfers, and/or cash advances made upon such card.
4. Defendant(s) later defaulted on the terms of the agreement.
5. The last payment was received on or about 2/03/22 in the amount of
$ 157.00.
6. The last four digits of the account number printed on the most recent
monthly statement recording a purchase transaction, last payment or
balance transfer are 6234
7. The account balance printed on the most recent monthly statement
recording a purchase transaction, last payment or balance transfer is
$ 5,163.57.
8. The plaintiff is the entity that owned the consumer credit account at
the date of default giving rise to the cause of action and is the
original creditor as defined by CPLR 105(q-1).
12/20/22
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FILED: TIOGA COUNTY CLERK 12/21/2022 12:01 PM INDEX NO. 2022-00062766
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/21/2022
9. Defendant(s) failed to make the payments due pursuant to the credit
account and $ 6,135.47 is now due and owing to plaintiff from
defendant. This amount includes a charge-off balance of $ 6,135.47,
post charge-off interest of $ .00, post charge-off non-interest
charges or fees and/or other balance adjustments of $ .00,
less post charge-off payments, balance adjustments and/or credits made
on the debt of $ .00 .
10. A copy of the charge-off statement issued for the account at issue
is attached hereto.
WHEREFORE, plaintiff requests judgment against defendant(s) in the sum of
$ 6,135.47 and the costs and disbursements of this action.
RUBIN & ROTHMAN, LLC
Attorneys for Plaintiff
1787 Veterans Highway
Islandia, NY 11749
(631) 234-1500
Deponent is an attorney associated with Rubin & Rothman, LLC. To the best
of deponent's knowledge, information and belief, formed after an inquiry
reasonable under the circumstances, the summons and complaint or the
contentions therein are not frivolous as defined in section 130-1.1(c)
of the Rules of the Chief Adm. and the matter was not obtained through
illegal conduct or in violation of 22 NYCRR 1200, Rule 4.5.
Dated: 12/20/22
___________. ______________________
SUBY MATHEW
WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
NYC DCA LIC. 2045512
Our
OUR File
FILE No.
NO. 1453590 X 43 0- 0 U SZM 000
000006434046
3 of 8
FILED: TIOGA COUNTY CLERK 12/21/2022 12:01 PM INDEX NO. 2022-00062766
NYSCEFSUPREME
DOC. NO.COURT
1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 12/21/2022
COUNTY OF TIOGA
----------------------------------------
CITIBANK, N.A.
Plaintiff
-against- Index No.
GRANT H MORSE
Defendant(s)
----------------------------------------
NOTICE OF COMMENCEMENT OF ACTION
SUBJECT TO MANDATORY ELECTRONIC FILING
PLEASE TAKE NOTICE that the matter captioned above, which has been
commenced by filing of the accompanying documents with the County Clerk, is
subject to mandatory electronic filing pursuant to Section 202.5-bb of the
Uniform Rules for the Trial Courts. This notice is being served as
required by Subdivision (b)(3) of that Section.
The New York State Courts Electronic Filing System ("NYSCEF") is
designed for the electronic filing of documents with the County Clerk and
the court and for the electronic service of those documents, court docu-
ments, and court notices upon counsel and self-represented parties. Counsel
and/or parties who do not notify the court of a claimed exemption (see
below) as required by Section 202.5-bb(e) must immediately record their
representation within the e-filed matter on the Consent page in NYSCEF.
Failure to do so may result in an inability to receive electronic notice of
document filings.
Exemptions from mandatory e-filing are limited to: 1)attorneys who
certify in good faith that they lack the computer equipment and (along with
all employees) the requisite knowledge to comply; and 2) self-represented
parties who choose not to participate in e-filing. For additional informa-
tion about electronic filing, including access to Section 202.5-bb, consult
the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource
Center at 646-386-3033 or efile@courts.state.ny.us.
Dated: 12/20/22
__________.
____________________ RUBIN & ROTHMAN, LLC
SUBY MATHEW 1787 VETERANS HIGHWAY
RUBIN & ROTHMAN, LLC ISLANDIA, NY 11749
(631) 234-1500
NYDOCS@RUBINROTHMAN.COM
To: GRANT H MORSE
1517 E RIVER RD
NICHOLS, NY 13812-2533
WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
NYC DCA LIC. 2045512
Our File No. 1453590 X 44 0- 0 U SZM 000
000006434046
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Preview
FILED: TIOGA COUNTY CLERK 12/21/2022 12:01 PM INDEX NO. 2022-00062766 NYSCEFSUPREME DOC. NO.COURT 1 OF THE STATE OF NEW YORK Index No. RECEIVED NYSCEF: 12/21/2022 COUNTY OF TIOGA Date Filed: ________________ ---------------------------------------- CITIBANK, N.A. SUMMONS (ORIGINAL) Plaintiff -against- GRANT H MORSE The basis of venue is: DEFENDANT'S RESIDENCE Defendant(s) Plaintiff's Residence: ---------------------------------------- 5800 SOUTH CORPORATE PLACE SIOUX FALLS, SD 57108 CONSUMER CREDIT TRANSACTION County of MINNEHAHA 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, or, if the complaint is not served with this summons to serve a notice of appearance, on the Plaintiff's Attorney(s) within TWENTY days after the service of this summons, exclusive of the day of service (or within THIRTY 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. Dated: Islandia, New York RUBIN & ROTHMAN, LLC Attorneys for Plaintiff 12/20/22 1787 Veterans Highway Islandia, N.Y. 11749 (631) 234-1500 DEFENDANT(S) ADDRESS: GRANT H MORSE 1517 E RIVER RD NICHOLS, NY 13812-2533 WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. NYC DCA LIC. 2045512 Our File No. 1453590 Y 41 0- 0 U SZM 000 000006434046 1 of 8 FILED: TIOGA COUNTY CLERK 12/21/2022 12:01 PM INDEX NO. 2022-00062766 NYSCEFSUPREME DOC. NO.COURT 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 12/21/2022 COUNTY OF TIOGA Index No. ---------------------------------------- CITIBANK, N.A. Plaintiff -against- COMPLAINT (ORIGINAL) GRANT H MORSE Defendant(s) ---------------------------------------- Plaintiff, by its attorneys, complaining of the defendant(s), alleges: AS AND FOR A FIRST CAUSE OF ACTION 1. Defendant(s) resides in the county in which this action is brought; or transacted business in the county in which this action is brought in person or through an agent, or this cause of action arose out of said transaction. Plaintiff is not required to be licensed by the NYC Dept of Consumer Affairs because it is the original creditor. 2. Plaintiff is a national bank located in South Dakota. 3. Defendant(s) used a revolving credit account with Plaintiff and agreed to make payments for goods and services charged, balance transfers, and/or cash advances made upon such card. 4. Defendant(s) later defaulted on the terms of the agreement. 5. The last payment was received on or about 2/03/22 in the amount of $ 157.00. 6. The last four digits of the account number printed on the most recent monthly statement recording a purchase transaction, last payment or balance transfer are 6234 7. The account balance printed on the most recent monthly statement recording a purchase transaction, last payment or balance transfer is $ 5,163.57. 8. The plaintiff is the entity that owned the consumer credit account at the date of default giving rise to the cause of action and is the original creditor as defined by CPLR 105(q-1). 12/20/22 2 of 8 FILED: TIOGA COUNTY CLERK 12/21/2022 12:01 PM INDEX NO. 2022-00062766 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/21/2022 9. Defendant(s) failed to make the payments due pursuant to the credit account and $ 6,135.47 is now due and owing to plaintiff from defendant. This amount includes a charge-off balance of $ 6,135.47, post charge-off interest of $ .00, post charge-off non-interest charges or fees and/or other balance adjustments of $ .00, less post charge-off payments, balance adjustments and/or credits made on the debt of $ .00 . 10. A copy of the charge-off statement issued for the account at issue is attached hereto. WHEREFORE, plaintiff requests judgment against defendant(s) in the sum of $ 6,135.47 and the costs and disbursements of this action. RUBIN & ROTHMAN, LLC Attorneys for Plaintiff 1787 Veterans Highway Islandia, NY 11749 (631) 234-1500 Deponent is an attorney associated with Rubin & Rothman, LLC. To the best of deponent's knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the summons and complaint or the contentions therein are not frivolous as defined in section 130-1.1(c) of the Rules of the Chief Adm. and the matter was not obtained through illegal conduct or in violation of 22 NYCRR 1200, Rule 4.5. Dated: 12/20/22 ___________. ______________________ SUBY MATHEW WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. NYC DCA LIC. 2045512 Our OUR File FILE No. NO. 1453590 X 43 0- 0 U SZM 000 000006434046 3 of 8 FILED: TIOGA COUNTY CLERK 12/21/2022 12:01 PM INDEX NO. 2022-00062766 NYSCEFSUPREME DOC. NO.COURT 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 12/21/2022 COUNTY OF TIOGA ---------------------------------------- CITIBANK, N.A. Plaintiff -against- Index No. GRANT H MORSE Defendant(s) ---------------------------------------- NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING PLEASE TAKE NOTICE that the matter captioned above, which has been commenced by filing of the accompanying documents with the County Clerk, is subject to mandatory electronic filing pursuant to Section 202.5-bb of the Uniform Rules for the Trial Courts. This notice is being served as required by Subdivision (b)(3) of that Section. The New York State Courts Electronic Filing System ("NYSCEF") is designed for the electronic filing of documents with the County Clerk and the court and for the electronic service of those documents, court docu- ments, and court notices upon counsel and self-represented parties. Counsel and/or parties who do not notify the court of a claimed exemption (see below) as required by Section 202.5-bb(e) must immediately record their representation within the e-filed matter on the Consent page in NYSCEF. Failure to do so may result in an inability to receive electronic notice of document filings. Exemptions from mandatory e-filing are limited to: 1)attorneys who certify in good faith that they lack the computer equipment and (along with all employees) the requisite knowledge to comply; and 2) self-represented parties who choose not to participate in e-filing. For additional informa- tion about electronic filing, including access to Section 202.5-bb, consult the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center at 646-386-3033 or efile@courts.state.ny.us. Dated: 12/20/22 __________. ____________________ RUBIN & ROTHMAN, LLC SUBY MATHEW 1787 VETERANS HIGHWAY RUBIN & ROTHMAN, LLC ISLANDIA, NY 11749 (631) 234-1500 NYDOCS@RUBINROTHMAN.COM To: GRANT H MORSE 1517 E RIVER RD NICHOLS, NY 13812-2533 WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. NYC DCA LIC. 2045512 Our File No. 1453590 X 44 0- 0 U SZM 000 000006434046 4 of 8 FILED: TIOGA COUNTY CLERK 12/21/2022 12:01 PM INDEX NO. 2022-00062766 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/21/2022 . 5 of 8 FILED: TIOGA COUNTY CLERK 12/21/2022 12:01 PM INDEX NO. 2022-00062766 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/21/2022 . 6 of 8 FILED: TIOGA COUNTY CLERK 12/21/2022 12:01 PM INDEX NO. 2022-00062766 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/21/2022 . 7 of 8 FILED: TIOGA COUNTY CLERK 12/21/2022 12:01 PM INDEX NO. 2022-00062766 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/21/2022 . 8 of 8