Complaint,Petition: Second Round Sub Llc v. Sarah Dusen

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                                INDEX   NO.   E160294/2016
(FILED: NIAGARA COUNTY CLERK 1272872016 12:18 PM
 NYSCEF    DOC.   NO.   1                                                                     RECEIVED     NYSCEF:     12/28/2016
                                  CONSUMER CREDIT TRANSACTION
     Supreme Court of the State of New York                                   Index No.
    County of NIAGARA                                                  Date purchased:

          SECOND ROUND SUB LLC
                                                               Plaintiff's Residence
                                                               4150 Freidrich Ln
                                                               Austin, TX 78744

                                       Plaintiff,


                             -AGAINST-                                         SUMMONS

          SARAH DUSEN
          1157 CAIN RD
          YOUNGSTOWN, NY       14174

                                       Defendant(s)

                                                        The Basis of Venue is: Defendant's Residence

    To the above named defendant(s):

    YOU ARE HEREBY SUMMONED to appear in the SUPREME COURT OF THE STATE OF NEW YORK,
    COUNTY OF NIAGARA, at the office of the clerk of the said Court at Court located at 775 3RD STREET
    NIAGARA FALLS, NY 14301; in the county of NIAGARA, State of New York. You may appear in this matter by
     serving an answer or a notice of appearance on the plaintiff's attorney, or by making a motion which has the effect
    of extending the time to answer. You must appear within 20 days after the service of this summons, exclusive of
    the day 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 in the complaint.


    Dated 12/23/2016

                             S/ Anthony Poulin

                             By: Anthony Poulin
                             Stephen Einstein and Associates, P.C.
                             NYC DCA Licience #2044935
                             Attorneys for Plaintiff
                             39 Broadway - Suite 1250
                             New York, NY 10006
                             212-267-3550




     1148280-1    / CRNSEC     / 1012M000133909 56027/1                                            UM                wT
Filed in Niagara County Clerk's Office                12/28/2016 of 3                      Index # E160294/2016
Supreme Court of the State of New York
County of NIAGARA

SECOND ROUND SUB LLC
               PLAINTIFF(S)                                       Index No.
                                         COMPLAINT
        -AGAINST-

SARAH DUSEN
                          DEFENDANT(S)
Plaintiff by its attorneys, Stephen Einstein and Associates, P.C., complaining of the defendant(s) respectfully
allege upon information and belief as follows:
1 Plaintiff, SECOND ROUND SUB LLC is a LIMITED LIABILITY COMPANY doing business within the State
   of TX, located at 4150 Freidrich Ln, Austin, TX 78744.
2. Upon information and belief defendant(s) resides or is employed in the county in which this action is brought; or
   that the defendant(s) transacted business within the county in which this action is brought in person or through
   an agent and that the instant cause of action arose out of said transaction.
   Upon information and belief that the defendant(s) entered into a Retail Charge Account Agreement [Account
   Num#XXXXXXXXXXXX9926], with SYNCHRONY BANK FKA GE CAPITAL RETAIL BANK wherein
   defendant(s) agreed to pay SYNCHRONY BANK FKA GE CAPITAL RETAIL BANK all amounts charged to
   said account by the authorized use thereof.
   Upon information and belief the agreement containing the terms and conditions governing the use of the charge
   account, including terms of payment was mailed to defendant(s).
   Plaintiff, as purchaser and assignee of the account owns and retains all beneficial rights and interests therein.
   Upon information and belief thereafter defendant incurred charges by use of the said Charge Account in the sum
   of $1903.62 no part of which sum has been paid, although duly demanded.

WHEREFORE, Plaintiff demands judgment against the defendant(s) for the sum of $1903.62, plus the costs of
this action.

Dated 12/23/2016
                          S/ Anthony Poulin

                          Stephen Einstein and Associates, P.C.
                          NYC DCA Licience #2044935
                          Attorneys for Plaintiff
                          39 Broadway - Suite 1250
                          New York, NY 10006
                          212-267-3550




1148280-1      / CRNSEC     / 1012M000133909 56027/l, o¢ 3                                  IUCNA
Index No.                    Year 20

SUPREME COURT OF THE STATE OF NEW YORK, COUNTY OF NIAGARA

SECOND ROUND SUB LLC
                                  PLAINTIFF(S)                          Index No.
                   -AGAINST-

SARAH DUSEN
                                  DEFENDANT(S)


                           SUMMONS AND COMPLAINT

                           Signature (Rule 130-1.1-a(b))

                           S/ Anthony Poulin
                           Anthony Poulin
                           Stephen Einstein & Associates, P.C.
                           Attorneys for Plaintiff
                           39 Broadway - Suite 1250
                           New York, NY 10006
                           212-267-3550


         To
         Attorney(s) for

         Service of a copy of the within                         is hereby admitted.
         Dated,
                                           Attorney(s) for

Please take notice
() NOTICE OF ENTRY
that the within is a (certified) true copy of a duly entered in the office of the clerk of the within named court on
20
() NOTICE OF SETTLEMENT
that an order                   of which the within is a true copy will be presented for settlement to the HON.
one of the judges of the within named court, at on               20     at     M.
Dated,                                 Yours, etc.

                           Stephen Einstein & Associates, P.C.
                           Attorneys for Plaintiff
                           39 Broadway - Suite 1250
                           New York, New York 10006
                           212-267-3550 ext. 2492
To Attorney(s) for


1148280-1       / CRNSEC     / 1012M000133909 56027/13 o¢ 3                                  IUCNA