On June 13, 2023 a
Party Statement
was filed
involving a dispute between
Td Bank Usa, N.A.,
and
Kera R Snyder,
for Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
in the District Court of Erie County.
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FILED: ERIE COUNTY CLERK 08/24/2023 12:44 PM INDEX NO. 807268/2023
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 08/24/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ERIE
INDEX NUMBER 807268/2023
TD BANK USA, N.A.
PLAINTIFF, FILE NO. F066823
-AGAINST- AFFIRMATION
KERA R SNYDER
DEFENDANT.
AFFIRMATION OF NON-EXPIRATION OF STATUTE OF LIMITATIONS
Mitchell G. Slamowitz, Esq., an attorney duly admitted to the practice of law in the State
of New York, hereby affirms the following to be true pursuant to CPLR § 2106 and under the
penalties of perjury states that:
1. The statute of limitations for the cause of action asserted herein commenced running on or
about October 7, 2022. The statute of limitations for the cause of action asserted herein is
three years based on the law in New York. The action was filed on or about June 13, 2023.
Based on my reasonable inquiry, I believe the applicable statute of limitations for the
cause of action asserted herein did not expire prior to the filing of this action.
WHEREFORE, Plaintiff respectfully requests the entry of a default judgment against the
Defendant(s).
I certify that, to the best of my knowledge, information, and belief, formed after an
inquiry reasonable under the circumstances, that the presentation of this judgment and all
papers or the contentions herein are not frivolous as defined in 22 NYCRR 130-
accompanying §
1-1(a).
Dated: August 22, 2023
Mitchell . Slamowitz, Esq.
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Document Filed Date
August 24, 2023
Case Filing Date
June 13, 2023
Category
Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
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FILED: ERIE COUNTY CLERK 08/24/2023 12:44 PM INDEX NO. 807268/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 08/24/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ERIE INDEX NUMBER 807268/2023 TD BANK USA, N.A. PLAINTIFF, FILE NO. F066823 -AGAINST- AFFIRMATION KERA R SNYDER DEFENDANT. AFFIRMATION OF NON-EXPIRATION OF STATUTE OF LIMITATIONS Mitchell G. Slamowitz, Esq., an attorney duly admitted to the practice of law in the State of New York, hereby affirms the following to be true pursuant to CPLR § 2106 and under the penalties of perjury states that: 1. The statute of limitations for the cause of action asserted herein commenced running on or about October 7, 2022. The statute of limitations for the cause of action asserted herein is three years based on the law in New York. The action was filed on or about June 13, 2023. Based on my reasonable inquiry, I believe the applicable statute of limitations for the cause of action asserted herein did not expire prior to the filing of this action. WHEREFORE, Plaintiff respectfully requests the entry of a default judgment against the Defendant(s). I certify that, to the best of my knowledge, information, and belief, formed after an inquiry reasonable under the circumstances, that the presentation of this judgment and all papers or the contentions herein are not frivolous as defined in 22 NYCRR 130- accompanying § 1-1(a). Dated: August 22, 2023 Mitchell . Slamowitz, Esq. IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIllIIIIIIIII IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIllIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIllIIIIIIIIIIIIIIIIIIIIIIIIIII 1 of 1