Preview
FILED: SUFFOLK COUNTY CLERK 01/24/2024 11:15 PM INDEX NO. 602133/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/24/2024
CONSUMER CREDIT TRANSACTION
Date Purchased:
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK X
Cavalry SPV I, LLC SUMMONS
Plaintiff, Plaintiff's Address:
-against- 1 American Lane, Suite 220
Greenwich CT 06831
ANDREA E STIEDL
Defendant(s).
The Basis of Venue is:
CPLR SEC. 503(f). Defendants
residence is in the County of
SUFFOLK.
X
Defendant(s) Address:
DEF1- 4 ROBINS CIR, CALVERTON NY 11933-9755
TO THE ABOVE NAMED DEFENDANT(S):
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your
answer on the Plaintiff's Attorney(s) within 20 days after the service of this summons, exclusive of the day of
service, or within 30 days after service is complete if this summons is not personally delivered to you within the
State of New York; and in the case of your failure to appear or answer, judgment will be taken against you by
default for the relief demanded in the complaint.
We are attorneys attempting to collect a debt. Any information obtained will be used for that purpose.
Dated: January 10, 2024
Matter # 509892 ____________________________
Stephen Einstein Scott Morris
Anthony S. Poulin Joseph J. Cassotta
Elladia Lopez Joseph G. Devine
Chester Andrew Guala Gerard W. DeStefano
Richa Bhandari
Tromberg, Morris & Poulin, PLLC.
Attorneys for the Plaintiff
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
*SM0000509892*
S_S_SUP-SUM
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FILED: SUFFOLK COUNTY CLERK 01/24/2024 11:15 PM INDEX NO. 602133/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/24/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
Cavalry SPV I, LLC
Plaintiff,
-against-
COMPLAINT
ANDREA E STIEDL
Defendant(s).
Plaintiff, by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges
that:
1. Plaintiff is an active foreign entity conducting business in the state of CT.
2. Upon information and belief, the Defendant(s) resides or has an office in the venue in which this
action is brought, or the Defendant(s) transacted business within the venue in which this action is brought,
either in person or through an agent, and the instant cause of action arose out of said transaction.
3. Based upon a reasonable inquiry, the Statute of Limitations for the cause of action asserted herein
has not expired.
AS AND FOR A FIRST CAUSE OF ACTION
4. Upon information and belief the Defendant(s) hereto entered into a Revolving Credit Account
Agreement (hereinafter "Account") with Citibank, N.A. (hereinafter "Original Creditor"), the Original
Creditor as defined by CPLR §105(q-1), bearing an account number on the most recent statement ending
in #XXXXXXXXXXXX6182, as so evidenced in the statement attached hereto, wherein Defendant(s)
agreed to pay Original Creditor all amounts charged to said Account.
5. Upon information and belief, Defendant(s) incurred charges by use of the said Account and
Original Creditor closed the Account and
subsequently charged it off on 11/16/2021 in the amount of $8,837.00. Pursuant to CPLR §3016(j) a
copy of the Charge-Off Statement is attached hereto.
6. Susequently, the Original Creditor sold/ assigned the Account, including all rights, title and interest
in and to the outstanding balance owed by Defendant(s). Plaintiff, purchased and/or took by assignment
the account herein on or about 09/28/2023. The complete chain of sale and assignment and dates sold
and/or assigned are as follows:
Assignor Date of Transfer Amt. at Time of Transfer
Transfer 1: Citibank, N.A. 9/28/2023 $8,837.00
7. Upon information and belief the date of last payment on this account was 03/18/2021 in the amount
of $400.00.
S_S_COM-RTL
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FILED: SUFFOLK COUNTY CLERK 01/24/2024 11:15 PM INDEX NO. 602133/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/24/2024
8. At this time, Defendant(s) owes $8,837.00 on the Account. This amount includes a charge-off
balance of $8,837.00, post-charge-off interest of $0.00, non-interest charges or fees accrued since charge-
off of $0.00, less any post-charge-off credits or payments made by or on behalf of the Defendant of $0.00;
and that amount has not been paid despite due demand.
WHEREFORE, Plaintiff demands judgment against Defendant(s) in the sum of $8,837.00, plus costs
and disbursements.
CERTIFICATION: Deponent is an attorney associated with Tromberg, Morris & Poulin, PLLC. Deponent
certifies that, to the best of their knowledge, information and belief, formed after an inquiry reasonable
under the circumstances, the presentation of the paper or the contentions therein are not frivolous as defined
in section 130-1.1(c) of the Chief Administrative Judge, and an initiating pleading, the matter was not
obtained through illegal conduct, and the matter was not obtained in violation of Part 1200. Rule 4.5 of this
Title. Affirmed this 10th day of January, 2024.
____________________________
Matter # 509892 Stephen Einstein Scott Morris
Anthony S. Poulin Joseph J. Cassotta
Elladia Lopez Joseph G. Devine
Chester Andrew Guala Gerard W. DeStefano
Richa Bhandari
S_S_COM-RTL
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FILED: SUFFOLK COUNTY CLERK 01/24/2024 11:15 PM INDEX NO. 602133/2024
NYSCEF DOC. NO. 1 Index No. Year RECEIVED NYSCEF: 01/24/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
Cavalry SPV I, LLC
Plaintiff
-against-
ANDREA E STIEDL
Defendant(s)
SUMMONS AND COMPLAINT
Signature (Rule 130-1. 1-a)
____________________________
Stephen Einstein Scott Morris
Anthony S. Poulin Joseph J. Cassotta
Elladia Lopez Joseph G. Devine
Chester Andrew Guala Gerard W. DeStefano
Richa Bhandari
LAW OFFICE OF
TROMBERG, MORRIS & POULIN, PLLC.
Attorney(s) for Plaintiff
Office and Post Office Address
39 Broadway, Suite 1250
New York, New York 10006
(212) 267-3550
Fax (212) 227-9656
Service of a copy of the within ___________________ is hereby admitted.
Dated,
Attorney(s) for Plaintiff(s)
Sir: Please take notice
NOTICE OF ENTRY:
That within is a (certified) true copy of a duly entered in the office of the clerk
of the within named court on
NOTICE OF SETTLEMENT
That an order __________________ of which the within is a true copy of a
Settlement to the HON. ___________________ Presented for one of the
judges
Of the within named court, at
On the ___ day of _____ 2024 at __ A.M
Dated,
S_S_SUP-BB
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FILED: SUFFOLK COUNTY CLERK 01/24/2024 11:15 PM INDEX NO. 602133/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/24/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
Cavalry SPV I, LLC
Plaintiff,
-against-
ANDREA E STIEDL
Defendant(s).
NOTICE OF COMMENCEMENT OF ACTION
SUBJECT TO MANDATORY ELECTRONIC FILING
PLEASE TAKE NOTICE that the matter captioned above has been commenced as an
required by CPLR § 2111 and Uniform Rule § 202.5-bb (MANDATORY ELECTRONIC FILING).
This notice is being served as required by that rule.
NYSCEF is designed for the electronic filing of documents with the County Clerk and the
court and for the electronic service of those documents, court documents, and court notices upon
counsel and unrepresented litigants who have consented to electronic filing.
Electronic filing offers significant benefits for attorneys and litigants, permitting papers to be
filed with the County Clerk and the court and served on other parties simply, conveniently, and
quickly. NYSCEF case documents are filed with the County Clerk and the court by filing on the
NYSCEF Website, which can be done at any time of the day or night on any day of the week. The
documents are served automatically on all consenting e-filers as soon as the document is uploaded to
the website, which sends out an immediate email notification of the filing.
The NYSCEF System charges no fees for filing, serving, or viewing the electronic case record,
nor does it charge any fees to print any filed documents. Normal filing fees must be paid, but this can
be done on-line.
Parties represented by an attorney: 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; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is
pending. 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 operational knowledge to comply with e-filing
requirements. [Section 202.5-bb(e)]
Parties not represented by an attorney: Unrepresented litigants are exempt from efiling.
They can serve and file documents in paper form and must be served with documents in paper
form. However, an unrepresented litigant may participate in e-filing. For information on how to
participate in e-filing, unrepresented litigants should contact the appropriate clerk in the court where
the action was filed or visit www.nycourts.gov/efileunrepresented. Unrepresented litigants also are
encouraged to visit www.nycourthelp.gov or contact the Help Center in the court where the action
was filed. An unrepresented litigant who consents to e-filing may cease participation at any time.
However, the other parties may continue to e-file their court documents in the case.
S_S-EFI
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FILED: SUFFOLK COUNTY CLERK 01/24/2024 11:15 PM INDEX NO. 602133/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/24/2024
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: efile@nycourts.gov).
Dated: January 10, 2024
____________________________
Stephen Einstein Scott Morris
Anthony S. Poulin Joseph J. Cassotta
Elladia Lopez Joseph G. Devine
Chester Andrew Guala Gerard W. DeStefano
Richa Bhandari
Tromberg, Morris & Poulin, PLLC.
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
www.tmppllc.com
TO: ANDREA E STIEDL
4 ROBINS CIR
CALVERTON NY 11933-9755
Matter # 509892
S_S-EFI
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Preview
FILED: SUFFOLK COUNTY CLERK 01/24/2024 11:15 PM INDEX NO. 602133/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/24/2024 CONSUMER CREDIT TRANSACTION Date Purchased: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK X Cavalry SPV I, LLC SUMMONS Plaintiff, Plaintiff's Address: -against- 1 American Lane, Suite 220 Greenwich CT 06831 ANDREA E STIEDL Defendant(s). The Basis of Venue is: CPLR SEC. 503(f). Defendants residence is in the County of SUFFOLK. X Defendant(s) Address: DEF1- 4 ROBINS CIR, CALVERTON NY 11933-9755 TO THE ABOVE NAMED DEFENDANT(S): YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer on the Plaintiff's Attorney(s) within 20 days after the service of this summons, exclusive of the day of service, or within 30 days after service is complete if this summons is not personally delivered to you within the State of New York; and in the case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. We are attorneys attempting to collect a debt. Any information obtained will be used for that purpose. Dated: January 10, 2024 Matter # 509892 ____________________________ Stephen Einstein Scott Morris Anthony S. Poulin Joseph J. Cassotta Elladia Lopez Joseph G. Devine Chester Andrew Guala Gerard W. DeStefano Richa Bhandari Tromberg, Morris & Poulin, PLLC. Attorneys for the Plaintiff 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 *SM0000509892* S_S_SUP-SUM 1 of 6 FILED: SUFFOLK COUNTY CLERK 01/24/2024 11:15 PM INDEX NO. 602133/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/24/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK Cavalry SPV I, LLC Plaintiff, -against- COMPLAINT ANDREA E STIEDL Defendant(s). Plaintiff, by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges that: 1. Plaintiff is an active foreign entity conducting business in the state of CT. 2. Upon information and belief, the Defendant(s) resides or has an office in the venue in which this action is brought, or the Defendant(s) transacted business within the venue in which this action is brought, either in person or through an agent, and the instant cause of action arose out of said transaction. 3. Based upon a reasonable inquiry, the Statute of Limitations for the cause of action asserted herein has not expired. AS AND FOR A FIRST CAUSE OF ACTION 4. Upon information and belief the Defendant(s) hereto entered into a Revolving Credit Account Agreement (hereinafter "Account") with Citibank, N.A. (hereinafter "Original Creditor"), the Original Creditor as defined by CPLR §105(q-1), bearing an account number on the most recent statement ending in #XXXXXXXXXXXX6182, as so evidenced in the statement attached hereto, wherein Defendant(s) agreed to pay Original Creditor all amounts charged to said Account. 5. Upon information and belief, Defendant(s) incurred charges by use of the said Account and Original Creditor closed the Account and subsequently charged it off on 11/16/2021 in the amount of $8,837.00. Pursuant to CPLR §3016(j) a copy of the Charge-Off Statement is attached hereto. 6. Susequently, the Original Creditor sold/ assigned the Account, including all rights, title and interest in and to the outstanding balance owed by Defendant(s). Plaintiff, purchased and/or took by assignment the account herein on or about 09/28/2023. The complete chain of sale and assignment and dates sold and/or assigned are as follows: Assignor Date of Transfer Amt. at Time of Transfer Transfer 1: Citibank, N.A. 9/28/2023 $8,837.00 7. Upon information and belief the date of last payment on this account was 03/18/2021 in the amount of $400.00. S_S_COM-RTL 2 of 6 FILED: SUFFOLK COUNTY CLERK 01/24/2024 11:15 PM INDEX NO. 602133/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/24/2024 8. At this time, Defendant(s) owes $8,837.00 on the Account. This amount includes a charge-off balance of $8,837.00, post-charge-off interest of $0.00, non-interest charges or fees accrued since charge- off of $0.00, less any post-charge-off credits or payments made by or on behalf of the Defendant of $0.00; and that amount has not been paid despite due demand. WHEREFORE, Plaintiff demands judgment against Defendant(s) in the sum of $8,837.00, plus costs and disbursements. CERTIFICATION: Deponent is an attorney associated with Tromberg, Morris & Poulin, PLLC. Deponent certifies that, to the best of their knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the presentation of the paper or the contentions therein are not frivolous as defined in section 130-1.1(c) of the Chief Administrative Judge, and an initiating pleading, the matter was not obtained through illegal conduct, and the matter was not obtained in violation of Part 1200. Rule 4.5 of this Title. Affirmed this 10th day of January, 2024. ____________________________ Matter # 509892 Stephen Einstein Scott Morris Anthony S. Poulin Joseph J. Cassotta Elladia Lopez Joseph G. Devine Chester Andrew Guala Gerard W. DeStefano Richa Bhandari S_S_COM-RTL 3 of 6 FILED: SUFFOLK COUNTY CLERK 01/24/2024 11:15 PM INDEX NO. 602133/2024 NYSCEF DOC. NO. 1 Index No. Year RECEIVED NYSCEF: 01/24/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK Cavalry SPV I, LLC Plaintiff -against- ANDREA E STIEDL Defendant(s) SUMMONS AND COMPLAINT Signature (Rule 130-1. 1-a) ____________________________ Stephen Einstein Scott Morris Anthony S. Poulin Joseph J. Cassotta Elladia Lopez Joseph G. Devine Chester Andrew Guala Gerard W. DeStefano Richa Bhandari LAW OFFICE OF TROMBERG, MORRIS & POULIN, PLLC. Attorney(s) for Plaintiff Office and Post Office Address 39 Broadway, Suite 1250 New York, New York 10006 (212) 267-3550 Fax (212) 227-9656 Service of a copy of the within ___________________ is hereby admitted. Dated, Attorney(s) for Plaintiff(s) Sir: Please take notice NOTICE OF ENTRY: That within is a (certified) true copy of a duly entered in the office of the clerk of the within named court on NOTICE OF SETTLEMENT That an order __________________ of which the within is a true copy of a Settlement to the HON. ___________________ Presented for one of the judges Of the within named court, at On the ___ day of _____ 2024 at __ A.M Dated, S_S_SUP-BB 4 of 6 FILED: SUFFOLK COUNTY CLERK 01/24/2024 11:15 PM INDEX NO. 602133/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/24/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK Cavalry SPV I, LLC Plaintiff, -against- ANDREA E STIEDL Defendant(s). NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING PLEASE TAKE NOTICE that the matter captioned above has been commenced as an required by CPLR § 2111 and Uniform Rule § 202.5-bb (MANDATORY ELECTRONIC FILING). This notice is being served as required by that rule. NYSCEF is designed for the electronic filing of documents with the County Clerk and the court and for the electronic service of those documents, court documents, and court notices upon counsel and unrepresented litigants who have consented to electronic filing. Electronic filing offers significant benefits for attorneys and litigants, permitting papers to be filed with the County Clerk and the court and served on other parties simply, conveniently, and quickly. NYSCEF case documents are filed with the County Clerk and the court by filing on the NYSCEF Website, which can be done at any time of the day or night on any day of the week. The documents are served automatically on all consenting e-filers as soon as the document is uploaded to the website, which sends out an immediate email notification of the filing. The NYSCEF System charges no fees for filing, serving, or viewing the electronic case record, nor does it charge any fees to print any filed documents. Normal filing fees must be paid, but this can be done on-line. Parties represented by an attorney: 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; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is pending. 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 operational knowledge to comply with e-filing requirements. [Section 202.5-bb(e)] Parties not represented by an attorney: Unrepresented litigants are exempt from efiling. They can serve and file documents in paper form and must be served with documents in paper form. However, an unrepresented litigant may participate in e-filing. For information on how to participate in e-filing, unrepresented litigants should contact the appropriate clerk in the court where the action was filed or visit www.nycourts.gov/efileunrepresented. Unrepresented litigants also are encouraged to visit www.nycourthelp.gov or contact the Help Center in the court where the action was filed. An unrepresented litigant who consents to e-filing may cease participation at any time. However, the other parties may continue to e-file their court documents in the case. S_S-EFI 5 of 6 FILED: SUFFOLK COUNTY CLERK 01/24/2024 11:15 PM INDEX NO. 602133/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/24/2024 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: efile@nycourts.gov). Dated: January 10, 2024 ____________________________ Stephen Einstein Scott Morris Anthony S. Poulin Joseph J. Cassotta Elladia Lopez Joseph G. Devine Chester Andrew Guala Gerard W. DeStefano Richa Bhandari Tromberg, Morris & Poulin, PLLC. 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 www.tmppllc.com TO: ANDREA E STIEDL 4 ROBINS CIR CALVERTON NY 11933-9755 Matter # 509892 S_S-EFI 6 of 6