On February 10, 2023 a
Complaint,Petition
was filed
involving a dispute between
American Express National Bank,
and
Tammy Ellis
Aka Tammy M Ellis,
for Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
in the District Court of Oswego County.
Preview
FILED: OSWEGO COUNTY CLERK 02/10/2023 03:49 PM INDEX NO. EFC-2023-0204
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/10/2023
CONSUMER CREDIT TRANSACTION
SUPREME COURT
COUNTY OF OSWEGO STATE OF NEW YORK
AMERICAN EXPRESS NATIONAL BANK, Index No.
Plaintiff
- vs. - S U MM O N S
TAMMY ELLIS AKA TAMMY M ELLIS, The basis of the venue designated is
Defendant's residence.
407 POPLE RIDGE RD
MEXICO, NY 13114 Plaintiff's address:
Defendant(s) 115 W. Towne Ridge Parkway
Sandy, UT 84070
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) residence.
DATED: 2/10/23
[ ]JASONP.VERHAGEN,ESQ.
b(] JOSEPH JAKAS, ESQ.
[ ] ELIZABETH CLARKE, ESQ.
[ ] STEPHANIE 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
262126030597
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FILED: OSWEGO COUNTY CLERK 02/10/2023 03:49 PM INDEX NO. EFC-2023-0204
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/10/2023
SUPREME COURT
COUNTY OF OSWEGO STATE OF NEW YORK
AMERICAN EXPRESS NATIONAL BANK, Index No.
Plaintiff,
vs. COMPLAINT
TAMMY ELLIS AKA TAMMY M ELLIS,
Defendant(s).
Plaintiff, by and through its attorneys, Zwicker & Associates P.C., complaining of
Defendant(s), respectfully alleges upon information and belief:
1. Plaintiff is a National Bank located in Utah. 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 1008.
5. The balance printed on the most recent monthly statement recording a purchase
transaction, last payment, or balance transfer was $4,915.97.
6. The last payment, in the amount of $165.00 posted to the account on 06/07/21.
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 $5,621.92, itemized as
follows: $5,621.92, the total amount due at charge-off; plus $0.00, the total amount of interest
accrued since charge-off; plus $0.00, the total amount of non-interest charges or fees accrued since
262126030597
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FILED: OSWEGO COUNTY CLERK 02/10/2023 03:49 PM INDEX NO. EFC-2023-0204
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/10/2023
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 $5,621.92 against Defendant(s),
and court costs to the extent permitted by applicable law.
DATED:
AdM'
2/10/23
[ ] JASON P. VERHAGEN, ESQ.
[X] JOSEPH JAKAS, ESQ.
[ ] ELIZABETH CLARKE, ESQ.
[ ] STEPHANIE 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
262126030597
3 of 3
Document Filed Date
February 10, 2023
Case Filing Date
February 10, 2023
Category
Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
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