On February 02, 2017 a
Answer
was filed
involving a dispute between
Banco Popular North America,
and
Amy Trevino A K A Amy Jaeger A K A Amparo Trevino A K A Amparo Jaeger A K A Amy Trevino-Jaeger,
James Munet,
John Doe And Jane Doe 1-2,
Jpmorgan Chase Bank, N.A.,
Ny Life Insurance,
Raul Munet,
for Special Proceedings - Other (enforcement / turn over)
in the District Court of New York County.
Preview
INDEX NO. 151069/2017
(FILED: NEW YORK COUNTY CLERK 0370272017 01:16 PM
NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 03/02/2017
Supreme Court of the State of New York
County of New York
WRITTEN ANSWER
ACTION FOR MONEY ONLY
Index Number 151069/2017
Banco Popular North America
Plaintiff/ Judgement Creditor
-against-
Amy Trevino a/k/a Amy Jaeger a/k/a
Trevino a/k/a Amparo Jaeger a/k/a
Respondent/ Judgement Debtor
James Munet,
Raul Munet
Respondents/ Transferees
NY Life Insurance,
JP Morgan Chase Bank, N.A.,
and "JOHN DOE and JANE DOE #1-2,"
said names being fictitious, it being
CH the intention of
signate any and all persons,
petitioner to de-
occupants and tenets having a lease
in any units comprising 1045 Virginia
Avenue, Bronx, New York 10472
Respondents/ Garnishees
XDefendant RAUL MUNET answers the Complaint as follows:
ANSWER: (Check all that apply)
1 General Denial: I deny the allegations in the Complaint.
1 of 2
. INDEX NO. 151069/2017
NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 03/02/2017
SERVICE
2. I did not receive a copy of the Summons and Complaint.
3 I received the Summons and Complaint, but service was not correct as required by law.
DEFRNSES
4 I do not owe this debt.
5 I did not incur this debt. I am a victim of identity theft or mistaken identity.
6. I have paid all or part of the alleged debt
7 I dispute the amount of the debt.
8 Plaintiff is required to be licensed by the department consumer affairs of the City of New York and
does
not allege a license number in the Complaint.
9 Statute of limitations (the time has passed to sue on this debt: more than six years)
10. This debt has been discharged in bankruptcy
11 The collateral (property) was not sold at a commercially reasonable price
12. Unjust enrichment (the amount demanded is excessive compared with the original debt)
13. Violation of the duty of good faith and fair dealing.
14. Unconscionability (the contract is unfair).
15. Laches (plaintiff has excessively delayed in bringing this lawsuit to my disadvantage),
16. Defendant is in the military.
17. Other
OTHER
18 Please take notice that my only source of income is , which is
exempt from collection.
COUNTERCLAIM(S)
19. Counterclaim(s): $.
Reason:
VERIFICATION
State of New York, County of Ss:
RAUL being duly sworn, deposes and says: I have read the Answer in
Writing and know the contents to
be true from my own knowledge, except as to those matters stated on information and belief, and as to
those matters I believe them to
be true.
Sworn to before me this 22__ day of february 20 17. Affidavit No.-1,686-
Identifted bY driver’ s license 799039 of
Signature of Defendant Lita
—_ hs ommonweal 3.
Notary/Court Emplo:
ZA f_boos boraid aaa
Defendant’s address 0,
Sella:
This case is scheduled to appear on me dat Dlg sk
Date: Part: Room: Time: Both sides’ a
i 3 Sk 3
Lea. JOSEPHINE Ms
RODRIGUES
Se
-
ag
2 of 2
Document Filed Date
March 02, 2017
Case Filing Date
February 02, 2017
Category
Special Proceedings - Other (enforcement / turn over)
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INDEX NO. 151069/2017 (FILED: NEW YORK COUNTY CLERK 0370272017 01:16 PM NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 03/02/2017 Supreme Court of the State of New York County of New York WRITTEN ANSWER ACTION FOR MONEY ONLY Index Number 151069/2017 Banco Popular North America Plaintiff/ Judgement Creditor -against- Amy Trevino a/k/a Amy Jaeger a/k/a Trevino a/k/a Amparo Jaeger a/k/a Respondent/ Judgement Debtor James Munet, Raul Munet Respondents/ Transferees NY Life Insurance, JP Morgan Chase Bank, N.A., and "JOHN DOE and JANE DOE #1-2," said names being fictitious, it being CH the intention of signate any and all persons, petitioner to de- occupants and tenets having a lease in any units comprising 1045 Virginia Avenue, Bronx, New York 10472 Respondents/ Garnishees XDefendant RAUL MUNET answers the Complaint as follows: ANSWER: (Check all that apply) 1 General Denial: I deny the allegations in the Complaint. 1 of 2 . INDEX NO. 151069/2017 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 03/02/2017 SERVICE 2. I did not receive a copy of the Summons and Complaint. 3 I received the Summons and Complaint, but service was not correct as required by law. DEFRNSES 4 I do not owe this debt. 5 I did not incur this debt. I am a victim of identity theft or mistaken identity. 6. I have paid all or part of the alleged debt 7 I dispute the amount of the debt. 8 Plaintiff is required to be licensed by the department consumer affairs of the City of New York and does not allege a license number in the Complaint. 9 Statute of limitations (the time has passed to sue on this debt: more than six years) 10. This debt has been discharged in bankruptcy 11 The collateral (property) was not sold at a commercially reasonable price 12. Unjust enrichment (the amount demanded is excessive compared with the original debt) 13. Violation of the duty of good faith and fair dealing. 14. Unconscionability (the contract is unfair). 15. Laches (plaintiff has excessively delayed in bringing this lawsuit to my disadvantage), 16. Defendant is in the military. 17. Other OTHER 18 Please take notice that my only source of income is , which is exempt from collection. COUNTERCLAIM(S) 19. Counterclaim(s): $. Reason: VERIFICATION State of New York, County of Ss: RAUL being duly sworn, deposes and says: I have read the Answer in Writing and know the contents to be true from my own knowledge, except as to those matters stated on information and belief, and as to those matters I believe them to be true. Sworn to before me this 22__ day of february 20 17. Affidavit No.-1,686- Identifted bY driver’ s license 799039 of Signature of Defendant Lita —_ hs ommonweal 3. Notary/Court Emplo: ZA f_boos boraid aaa Defendant’s address 0, Sella: This case is scheduled to appear on me dat Dlg sk Date: Part: Room: Time: Both sides’ a i 3 Sk 3 Lea. JOSEPHINE Ms RODRIGUES Se - ag 2 of 2