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  • Lvnv Funding Llc v. Blake DeneshaOther Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
  • Lvnv Funding Llc v. Blake DeneshaOther Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
  • Lvnv Funding Llc v. Blake DeneshaOther Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
  • Lvnv Funding Llc v. Blake DeneshaOther Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
  • Lvnv Funding Llc v. Blake DeneshaOther Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
  • Lvnv Funding Llc v. Blake DeneshaOther Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
  • Lvnv Funding Llc v. Blake DeneshaOther Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
  • Lvnv Funding Llc v. Blake DeneshaOther Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
						
                                

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FILED: ST. LAWRENCE COUNTY CLERK 09/25/2023 03:38 PM INDEX NO. EFCV-23-165226 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/25/2023 File # D214591 CONSUMER CREDIT TRANSACTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SAINT LAWRENCE --------------------------------- LVNV FUNDING LLC Plaintiff, Index No. -against- SUMMONS BLAKE DENESHA Plaintiff's Residence Address 355 S MAIN STREET SUITE 300-D GREENVILLE SC 29601 Defendant(s). The Basis of this venue designated is: Defendant's residence --------------------------------- Defendant's Residence Address: 200 E MAIN ST APT 2 GOUVERNEUR, NY 13642-1582 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 within twenty (20) days after the service of this summons exclusive of the days of service (or within thirty (30) days after the service is complete if this summons is not personally delivered to you within the State of New York). You are hereby notified that should you fail to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: 09/22/2023 PRESSLER, FELT & WARSHAW, LLP Attorneys for Plaintiff 305 Broadway Suite 505 New York, NY 10007 (888)312-8600 [X] By: ____________________________ Ian Z. Winograd , Esq. [ ] By:____________________________ David B. Warshaw Esq. [ ] By:____________________________ Ryan R. Tappan Esq. [ ] By:____________________________ Craig S. Stiller Esq. [ ] By:____________________________ Howard Schachter Esq. [ ] By:____________________________ Patrick Wong Esq. [ ] By:____________________________ Renuka Vipat Esq. 1 of 6 FILED: ST. LAWRENCE COUNTY CLERK 09/25/2023 03:38 PM INDEX NO. EFCV-23-165226 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/25/2023 File # D214591 SUPREME COURT OF THE STATE OF NEW YORK - COUNTY OF SAINT LAWRENCE ---------------------------------- LVNV FUNDING LLC Plaintiff(s) Index No. -against- COMPLAINT BLAKE DENESHA Defendant(s) ---------------------------------- Plaintiff through its attorney, Pressler, Felt & Warshaw, LLP complains of the Defendant(s) and alleges upon information and belief as follows: FACTS COMMON TO ALL COUNTS 1. LVNV FUNDING LLC (hereinafter "Plaintiff") is a limited liability company formed under the the laws of the State of Delaware. 2. BLAKE DENESHA (hereinafter "Defendant") resides within the jurisdictional limits of this court. 3. Plaintiff is the current owner of the obligation sued upon, and was assigned all the rights, title and interest to Defendant's CREDIT ONE BANK, N.A. account number ending in 7656 (hereinafter "the Account"). 4. The Plaintiff is not the original creditor. The Account originated with CREDIT ONE BANK, N.A. The name of the entity that owned the Account at the date of default giving rise to a cause of action is CREDIT ONE BANK, N.A. The chain of title including CREDIT ONE BANK, N.A. and all post default owners of the debt are as follows: a. CREDIT ONE BANK, N.A. to MHC RECEIVABLES, LLC AND FNBM, LLC on 12/31/21 with an amount due at the time of sale or assignment in the amount of $858.65. b. MHC RECEIVABLES, LLC AND FNBM, LLC to CREDIT ASSET SALES LLC on 01/19/22. c. CREDIT ASSET SALES LLC to RESURGENT ACQUISITIONS LLC on 01/19/22. d. RESURGENT ACQUISITIONS LLC to LVNV FUNDING LLC on 01/19/22. 2 of 6 FILED: ST. LAWRENCE COUNTY CLERK 09/25/2023 03:38 PM INDEX NO. EFCV-23-165226 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/25/2023 FIRST CAUSE OF ACTION 5. Plaintiff repeats and incorporates the allegations set forth in FACTS COMMON TO ALL COUNTS as if set forth at length herein. 6. Plaintiff alleges that Defendant is the responsible person for this Account. 7. Upon information and belief, the statute of limitations for the cause of action asserted herein is 3 years and therefore has not expired. 8. Attached is a copy of the charge off statement. 9. The last four digits of the account number printed on the most recent monthly statement recording a purchase transaction, last payment or balance transfer is 7656. 10. The Account balance printed on the most recent monthly statement recording a purchase transaction, last payment or balance transfer is $541.66. 11. The Defendant made no payment on the Account. 12. By use of the Account, Defendant agreed to pay all the amounts due on the Account. 13. Defendant failed to repay the balance owed on the Account, which is now in default. 14. The amount due is $858.65, which is itemized as follows: a. The total amount of the debt due as of charge-off: $858.65. b. The total amount of interest accrued since charge-off: $0.00. c. The total amount of non-interest charges or fees accrued since charge-off: $0.00. d. The total amount of payments and/or credits made on the debt since charge-off:$0.00 15. There is now due and owing the Plaintiff, as the assignee of the Account, from Defendant, the sum of $858.65. 3 of 6 FILED: ST. LAWRENCE COUNTY CLERK 09/25/2023 03:38 PM INDEX NO. EFCV-23-165226 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/25/2023 WHEREFORE, Plaintiff demands judgment against BLAKE DENESHA for the sum of $858.65 plus costs and disbursements of this action and for such further and other relief as the Court deems just and proper. Dated: 09/22/2023 PRESSLER, FELT & WARSHAW, LLP Attorneys for Plaintiff 305 Broadway Suite 505 New York, NY 10007 (888)312-8600 [X] By: ____________________________ Ian Z. Winograd , Esq. [ ] By:____________________________ David B. Warshaw Esq. [ ] By:____________________________ Ryan R. Tappan Esq. [ ] By:____________________________ Craig S. Stiller Esq. [ ] By:____________________________ Howard Schachter Esq. [ ] By:____________________________ Patrick Wong Esq. [ ] By:____________________________ Renuka Vipat Esq. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 4 of 6 FILED: ST. LAWRENCE COUNTY CLERK 09/25/2023 03:38 PM INDEX NO. EFCV-23-165226 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/25/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SAINT LAWRENCE ------------------------------------------------------------------x LVNV FUNDING LLC Plaintiff/Petitioner, - against - Index No. BLAKE DENESHA Defendant/Respondent. ------------------------------------------------------------------x NOTICE OF ELECTRONIC FILING (Mandatory Case) (Uniform Rule § 202.5-bb) You have received this Notice because: 1) The Plaintiff/Petitioner, whose name is listed above, has filed this case using the New York State Courts E-filing system (“NYSCEF”), and 2) You are a Defendant/Respondent (a party) in this case. ! If you are represented by an attorney: Give this Notice to your attorney. (Attorneys: see “Information for Attorneys” pg. 2). ! If you are not represented by an attorney: You will be served with all documents in paper and you must serve and file your documents in paper, unless you choose to participate in e-filing. If you choose to participate in e-filing, you must have access to a computer and a scanner or other device to convert documents into electronic format, a connection to the internet, and an e-mail address to receive service of documents. The benefits of participating in e-filing include: ! serving and filing your documents electronically ! free access to view and print your e-filed documents ! limiting your number of trips to the courthouse ! paying any court fees on-line (credit card needed) To register for e-filing or for more information about how e-filing works: ! visit: www.nycourts.gov/efile-unrepresented or ! contact the Clerk’s Office or Help Center at the court where the case was filed. Court contact information can be found at www.nycourts.gov Page 1 of 5 of 6 2 EFM-1 FILED: ST. LAWRENCE COUNTY CLERK 09/25/2023 03:38 PM INDEX NO. EFCV-23-165226 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/25/2023 To find legal information to help you represent yourself visit www.nycourthelp.gov Information for Attorneys (E-filing is Mandatory for Attorneys) An attorney representing a party who is served with this notice must either: 1) immediately record his or her representation within the e-filed matter on the NYSCEF site www.nycourts.gov/efile ; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is pending and serve on all parties. Exemptions from mandatory e-filing are limited to attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or internet connection or that they lack (along with all employees subject to their direction) the knowledge to operate such equipment. [Section 202.5-bb(e)] For additional information about electronic filing and to create a NYSCEF account, visit the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone: 646-386-3033; e-mail: nyscef@nycourts.gov). Dated: 09/22/2023 Ian Z. Winograd ______________________________ 305 Broadway Suite 505 Name _______________________________ Pressler, Felt & Warshaw, LLP New York, NY 10007 ______________________________ _______________________________ Firm Name Address 1-888-312-8600 _______________________________ Phone IWinograd@pfwattorneys.com E-Mail To: BLAKE DENESHA 200 E MAIN ST APT 2 GOUVERNEUR, NY 13642-1582 PFW File Number D214591 2/24/20 Index # Page 2 6of 2 6 of EFM-1