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  • Dnf Associates Llc v. Kristin DebellisOther Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
  • Dnf Associates Llc v. Kristin DebellisOther Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
						
                                

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FILED: ERIE COUNTY CLERK 12/26/2018 04:36 PM INDEX NO. 806354/2018 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 12/26/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ERIE INDEX NUMBER 806354/2018e DNF Associates LLC PLAINTIFF, FILE NO. C569359 -AGAINST- KRISTIN DEBELLIS DEFENDANT. 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 5/5/2014. The statute of limitations for the cause of action asserted herein is four years based on the law in Ohio, which is where Sterling Jewlers, the original creditor of the Account, is located. The written action was filed on or about April 23, 2018. 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: November 30, 2018 Mitchell G. Slamowitz, Esq. 11111111111111111111111111111111IIIIllIIIIIII 1111111111111111111111111111111111111111111111111111111111111111IIIIIIIIIIIIIIIIIIllIIIIIIIIIIIIllIIIIIIIIIIIIIllIIIIIIIIIIIIIlll111111111111111111111 1 of 1