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  • Capital One Bank (Usa), N.A. v. Kristin HartmanOther Matters - Consumer Credit (Card) Original Creditor Plaintiff document preview
  • Capital One Bank (Usa), N.A. v. Kristin HartmanOther Matters - Consumer Credit (Card) Original Creditor Plaintiff document preview
						
                                

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FILED: ORANGE COUNTY CLERK 08/30/2021 10:03 AM INDEX NO. EF003860-2021 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 08/30/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE INDEX NUMBER EF003860-2021 CAPITAL ONE BANK (USA), N.A. PLAINTIFF, FILE NO. N463645 -AGAINST- KRISTIN HARTMAN 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 December 30, 2020. The statute of limitations for the cause of action asserted herein is three years based on the law in Virginia, which is where CAPITAL ONE BANK , the original creditor of the Account, is located. The written action was filed on or about June 8, 2021. 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 25, 2021 Mitchell G. Slamowitz, Esq. IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIllIIIIIIIIIIIllIIIIIEEiii!!!IIIIIIIIIIIIIIIIIIIIIIIIIIIIllIIIIIIIIIIIIIIIIIIIIIIIIIll 1 of 1