Preview
FILED: ROCKLAND COUNTY CLERK 12/23/2021 03:13 PM INDEX NO. 034654/2021
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 12/23/2021
INDEX NO. 034654/2021
F I LED : ROCKLAND COUNTY CLERK 0 8 / 03/2 0 2 1 0 5 : 4 0 PM|
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/03/2021
CONSUMER CREDIT TRANSACTION
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ROCKLAND
CAVALRY SPV AS ASSIGNEE OF Index No.:
I, LLC,
Date Purchased
CITIBANK, N.A.,
Plaintiff,
SUMMONS
vs. The basis of the venue designated is
The defendant resides in the
County of Rockland
JOEL WAGSCHAL, The transaction took place in the
Defendant. County of Rocldand
_ ____
To the above-named Defendant:
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve
a copy of your answer, or, if the complaiñt is not served with this summons, to serve a notice of
appearance, on the Plaintiff's Attorney(s) at the address stated below within 20 days after the
service of this summons, exclusive of the day of service (or within 30 days aller 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, judgmcñt will be taken against you by default for the
relief demanded in the complaint.
Dated: East s ,
MAND LAW~GROUP, LLP
Heather A. son, Esq.
Brandon M. razen, Esq.
Attorneys for Plaintiff
5965 Transit Road, Suite 500
East Amherst, New York 14051
(833) 769-2757
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FILED: ROCKLAND COUNTY CLERK 12/23/2021 03:13 PM INDEX NO. 034654/2021
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 12/23/2021
INDEX NO. 034654/2021
IF ILED : ROCKLAND COUNTY CLERK 0 8 / 03/202 1 0 5 : 4 0 PM1
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/03/2021
TO: JOEL WAGSCHAL
109 GROVE ST # 112
MONSEY, NY 10952-3600
WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
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FILED: ROCKLAND COUNTY CLERK 12/23/2021 03:13 PM INDEX NO. 034654/2021
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 12/23/2021
[FILED : ROCKLAND COUNTY CLERK 0 8 / 03 /2 INDEX NO. 034654/2021
0 2 1 0 5 : 4 0 PM)
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/03/2021
CONSUMER CREDIT TRANSACTION
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ROCKLAND
CAVALRY SPV I, LLC, AS ASSIGNEE ÒF
CITIBANK, N.A.,
COMPLAINT
Plaintiff,
vs. Index No.:
JOEL WAGSCHAL,
Defendant.
___
Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., by its attorneys,
Mandarich Law Group, LLP, complaining of the Defendant, JOEL WAGSCHAL, alleges the
following:
1. Plaintiff is a foreign limited liability company organized and existing by virtue of the laws
of Delaware, with a principal place of business located at 500 Summit Lake Drive, Suite 400,
Valhalla, New York 10595.
2. Upon information and belief, Defendant JOEL WAGSCHAL, was and is a natural person
residing at 109 GROVE ST # 112 , County of Rockland, State of New York.
3. Plaintiff took by assignment and/or purchased, for value, all rights, title, and interest of
certain accounts, including the account identified below, which originated with Citibank, N.A.
(hereinafter the "Original Creditor").
4. Original Creditor issued a consumer credit card account to the Defendant (original account
number ending in XXXXXXXXXXXX3871) (hereinafter the "Account"), which is the subject of
this action.
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FILED: ROCKLAND COUNTY CLERK 12/23/2021 03:13 PM INDEX NO. 034654/2021
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 12/23/2021
FILED : ROCKLAND COUNTY _CLERK 0 8 / 0 3 / 2 0 2 1 INDEX NO. 034654/2021
0 5 : 4 0 PM)
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/03/2021
5. Defendant entered into an agreement with the Original Creditor and made purchases,
received cash, merchandise, and/or credit on the Account.
6. Defendant agreed to but failed to make payments on said Account and $8,311.00 is now
due and owing to the Plaintiff from Defendant, which amount has been demanded and remains
unpaid.
7. Defendant is in default and Plaintiff, as owner of the Account, is authorized to proceed
with this action.
8. Plaintiff has suffered damages in the amount of $8,311.00, together with the costs and
disbursements incurred in this action.
WHEREFORE, Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK,
N.A., respectfully requests judgment against the Defendant, JOEL WAGSCHAL, for the sum
of $8,311.00, all costs and disbursements of this action, with interest from the date of any
ju¼-mcat granted or ordered, and for such other and further relief as this Court deems just and
proper.
Dated: East erst, New York
, 20___ By:
MAND L GROUP, LLP
Heather A. ohnson, Esq.
Brandon . Wrazen, Esq.
Attorneys for Plaintiff
5965 Transit Road, Suite 500
East Amherst, New York 14051
(833) 769-2757
MLG- 4458422
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FILED: ROCKLAND COUNTY CLERK 12/23/2021 03:13 PM INDEX NO. 034654/2021
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 12/23/2021
INDEX NO. 034654/2021
F I LED : ROCKLAND COUNTY CLERK 0 8 / 03/2 0 2 1 0 5 : 4 0 Pli
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/03/2021
TO: JOEL WAGSCHAL
109 GROVE ST # 112
MONSEY, NY 10952-3600
WE ARE ATTEMPTING TUCOLLECT A DEBT AND ANY INFORMATION WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT
COLLECTOR.
5 of 5
Preview
FILED: ROCKLAND COUNTY CLERK 12/23/2021 03:13 PM INDEX NO. 034654/2021 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 12/23/2021 INDEX NO. 034654/2021 F I LED : ROCKLAND COUNTY CLERK 0 8 / 03/2 0 2 1 0 5 : 4 0 PM| NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/03/2021 CONSUMER CREDIT TRANSACTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND CAVALRY SPV AS ASSIGNEE OF Index No.: I, LLC, Date Purchased CITIBANK, N.A., Plaintiff, SUMMONS vs. The basis of the venue designated is The defendant resides in the County of Rockland JOEL WAGSCHAL, The transaction took place in the Defendant. County of Rocldand _ ____ To the above-named Defendant: YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer, or, if the complaiñt is not served with this summons, to serve a notice of appearance, on the Plaintiff's Attorney(s) at the address stated below within 20 days after the service of this summons, exclusive of the day of service (or within 30 days aller 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, judgmcñt will be taken against you by default for the relief demanded in the complaint. Dated: East s , MAND LAW~GROUP, LLP Heather A. son, Esq. Brandon M. razen, Esq. Attorneys for Plaintiff 5965 Transit Road, Suite 500 East Amherst, New York 14051 (833) 769-2757 1 of 5 FILED: ROCKLAND COUNTY CLERK 12/23/2021 03:13 PM INDEX NO. 034654/2021 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 12/23/2021 INDEX NO. 034654/2021 IF ILED : ROCKLAND COUNTY CLERK 0 8 / 03/202 1 0 5 : 4 0 PM1 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/03/2021 TO: JOEL WAGSCHAL 109 GROVE ST # 112 MONSEY, NY 10952-3600 WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. 2 of 5 FILED: ROCKLAND COUNTY CLERK 12/23/2021 03:13 PM INDEX NO. 034654/2021 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 12/23/2021 [FILED : ROCKLAND COUNTY CLERK 0 8 / 03 /2 INDEX NO. 034654/2021 0 2 1 0 5 : 4 0 PM) NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/03/2021 CONSUMER CREDIT TRANSACTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND CAVALRY SPV I, LLC, AS ASSIGNEE ÒF CITIBANK, N.A., COMPLAINT Plaintiff, vs. Index No.: JOEL WAGSCHAL, Defendant. ___ Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., by its attorneys, Mandarich Law Group, LLP, complaining of the Defendant, JOEL WAGSCHAL, alleges the following: 1. Plaintiff is a foreign limited liability company organized and existing by virtue of the laws of Delaware, with a principal place of business located at 500 Summit Lake Drive, Suite 400, Valhalla, New York 10595. 2. Upon information and belief, Defendant JOEL WAGSCHAL, was and is a natural person residing at 109 GROVE ST # 112 , County of Rockland, State of New York. 3. Plaintiff took by assignment and/or purchased, for value, all rights, title, and interest of certain accounts, including the account identified below, which originated with Citibank, N.A. (hereinafter the "Original Creditor"). 4. Original Creditor issued a consumer credit card account to the Defendant (original account number ending in XXXXXXXXXXXX3871) (hereinafter the "Account"), which is the subject of this action. 3 of 5 FILED: ROCKLAND COUNTY CLERK 12/23/2021 03:13 PM INDEX NO. 034654/2021 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 12/23/2021 FILED : ROCKLAND COUNTY _CLERK 0 8 / 0 3 / 2 0 2 1 INDEX NO. 034654/2021 0 5 : 4 0 PM) NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/03/2021 5. Defendant entered into an agreement with the Original Creditor and made purchases, received cash, merchandise, and/or credit on the Account. 6. Defendant agreed to but failed to make payments on said Account and $8,311.00 is now due and owing to the Plaintiff from Defendant, which amount has been demanded and remains unpaid. 7. Defendant is in default and Plaintiff, as owner of the Account, is authorized to proceed with this action. 8. Plaintiff has suffered damages in the amount of $8,311.00, together with the costs and disbursements incurred in this action. WHEREFORE, Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., respectfully requests judgment against the Defendant, JOEL WAGSCHAL, for the sum of $8,311.00, all costs and disbursements of this action, with interest from the date of any ju¼-mcat granted or ordered, and for such other and further relief as this Court deems just and proper. Dated: East erst, New York , 20___ By: MAND L GROUP, LLP Heather A. ohnson, Esq. Brandon . Wrazen, Esq. Attorneys for Plaintiff 5965 Transit Road, Suite 500 East Amherst, New York 14051 (833) 769-2757 MLG- 4458422 4 of 5 FILED: ROCKLAND COUNTY CLERK 12/23/2021 03:13 PM INDEX NO. 034654/2021 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 12/23/2021 INDEX NO. 034654/2021 F I LED : ROCKLAND COUNTY CLERK 0 8 / 03/2 0 2 1 0 5 : 4 0 Pli NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/03/2021 TO: JOEL WAGSCHAL 109 GROVE ST # 112 MONSEY, NY 10952-3600 WE ARE ATTEMPTING TUCOLLECT A DEBT AND ANY INFORMATION WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. 5 of 5