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.
Preview
FILED: ERIE COUNTY CLERK 08/24/2023 12:44 PM INDEX NO. 807268/2023
NYSCEF DOC. NO. 9 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. FILE NO. F066823
PLAINTIFF, AFFIRMATION IN SUPPORT OF
-AGAINST- ENTRY OF JUDGMENT
KERA R SNYDER
|||||||||||||||||||||||||||||||||||||||||||||
DEFENDANT.
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. I am a partner of Selip & Stylianou, LLP, attorneys for the Plaintiff, and I am fully
familiar with the facts and circumstances herein.
2. I make this affirmation in additional support of Plaintiff s request for the entry of
judgment against KERA R SNYDER (hereinafter the "Defendant").
Additional Notice Pursuant to CPLR § 3215(g)(3)
3. On July 07, 2023, as set forth in the affidavit of service previously filed with the court, a
copy of the summons was mailed in a separate post-paid envelopes in an official
depository of the U.S. Postal Service addressed to each defaulting defendant's last known
residence address as set forth below, by first class mail in an envelope bearing the legend
confidential"
"personal and and not indicating on the outside thereof that the
communication was from an attorney or concerns an alleged debt. More than 20 days have
elapsed and the same has not been returned as undeliverable by the U.S. Postal Service; if
same was returned, the copy of the summons was re-mailed to the defendant'(s) last known
residence.
KERA R SNYDER
1878 EASTWOOD RD EAST AURORA, NY 14052
1 of 2
FILED: ERIE COUNTY CLERK 08/24/2023 12:44 PM INDEX NO. 807268/2023
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 08/24/2023
MILITARY STATUS
4. I provided Department of Defense, Defense Manpower Data Center, with the pertinent
information about the defendant, in particular the date of birth and/or social security
number, which I know because they were provided to me by the Plaintiff. I requested that
a military investigation be conducted for the purpose of entry of a judgment.
5. Based upon the response I received from the Department of Defense, Defense Manpower
Data Center, dated August 22, 2023, I am convinced that the defendant is not in any
branch of the United States military.
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.
2 of 2
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. 9 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. FILE NO. F066823 PLAINTIFF, AFFIRMATION IN SUPPORT OF -AGAINST- ENTRY OF JUDGMENT KERA R SNYDER ||||||||||||||||||||||||||||||||||||||||||||| DEFENDANT. 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. I am a partner of Selip & Stylianou, LLP, attorneys for the Plaintiff, and I am fully familiar with the facts and circumstances herein. 2. I make this affirmation in additional support of Plaintiff s request for the entry of judgment against KERA R SNYDER (hereinafter the "Defendant"). Additional Notice Pursuant to CPLR § 3215(g)(3) 3. On July 07, 2023, as set forth in the affidavit of service previously filed with the court, a copy of the summons was mailed in a separate post-paid envelopes in an official depository of the U.S. Postal Service addressed to each defaulting defendant's last known residence address as set forth below, by first class mail in an envelope bearing the legend confidential" "personal and and not indicating on the outside thereof that the communication was from an attorney or concerns an alleged debt. More than 20 days have elapsed and the same has not been returned as undeliverable by the U.S. Postal Service; if same was returned, the copy of the summons was re-mailed to the defendant'(s) last known residence. KERA R SNYDER 1878 EASTWOOD RD EAST AURORA, NY 14052 1 of 2 FILED: ERIE COUNTY CLERK 08/24/2023 12:44 PM INDEX NO. 807268/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 08/24/2023 MILITARY STATUS 4. I provided Department of Defense, Defense Manpower Data Center, with the pertinent information about the defendant, in particular the date of birth and/or social security number, which I know because they were provided to me by the Plaintiff. I requested that a military investigation be conducted for the purpose of entry of a judgment. 5. Based upon the response I received from the Department of Defense, Defense Manpower Data Center, dated August 22, 2023, I am convinced that the defendant is not in any branch of the United States military. 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. 2 of 2