On October 31, 2023 a
ANSWER
was filed
involving a dispute between
Oswego Hospital,
and
Nicollette P. Woolworth,
for Other Matters - Consumer Credit (Non-Card) Transaction
in the District Court of Oswego County.
Preview
FILED: OSWEGO COUNTY CLERK 11/30/2023 02:16 PM INDEX NO. EFC-2023-1533
OYle-
NYSCEF DOC. NO. CO
5 0 COURT COUNTY OF O RECEIVEDPart:
NYSCEF: 11/30/2023
WRITTEN ANSWER
Plaintiff(s)
-against- CONSUMER CREDIT TRANSACTION
Co CC wj O
EFC-ZOZ3-
Defendant(s) index Number: 15
ANSWER. (Check all that apply)
1. General Denial: I deny the allegations in the Complaint. OS EGC COL3NTY CLERES
SERVICE 2023 NCU 30 P SS
2. O I did not receive a copy of the Summons and Complaint.
3. O I received the Summons and Complaint, but service was not correct as required by law.
DEFENSES
4. It is not my debt. I am a victim of identity theft or mistaken identity.
5. I have paid all or part of the alleged debt.
6. I dispute the amount of the debt.
7. I had no business dealings with Plaintiff (Plaintiff lacks standing).
8. There is no record of plaintiff having a license to collect debt (only for cases filed in New York City, Buffalo and
other municipalities requiring debt collectors to be licensed).
9. Plaintiff does not allege a debt collector's license number in the Complaint (only for cases filed in New York
City, Buffalo and other municipalities requiring debt collectors to be licensed).
10. O Statute of limitations (the time has passed to sue on this debt).
11. O This debt has been discharged in bankruptcy.
12. O The collateral (property) was not sold at a commercially reasonable price.
13. O Failure to provide proper notice before selling collateral (property).
14. O Failure to mitigate damages (Plaintiff did not take reasonable steps to limit damages).
15. O Unjust enrichment (the amount demanded is excessive compared with the original debt).
16. O Violation of the duty of good faith and fair dealing.
17. O Unconscionability (the contract is unfair).
18. ¤ Laches (plaintiff has excessively delayed in bringing this lawsuit to my disadvantage).
19-a. ¤ OUTSIDE OF NEW YORK CITY ONLY: Lack of personal jurisdiction under Uniform City Court Act § 213 (applies if
you do not work in the city where the case was filed and you are not a resident of that city or (for all counties
except Westchester and Nassau counties) you are not a resident of a town next to that city within the same
county).
19-b. O SUFFOLK COUNTY: Lack of personal jurisdiction; the defendant is not a resident and/or was not served in, or
there was no transaction of business in, that portion of Suffolk County for which a District Court has been
established (Towns of Huntington, Babylon, Islip, Smithtown and Brookhaven).
20. Defendant is in the military.
OTHER
21. Other Reasons
22. Please take notice that my only source of income is , which is exempt from collection.
COUNTERCLAIM(S)
23. Counterclaim(s): $ Reason:
VERIFICATION
State of New York, County of C be r() ss:
/h co p)d+c ld0Ç [ LJ0GT {f being duly sworn, deposes and says: I have read the Answer in Writing and know
the contents to be true from my own knowledge, except as to those matters stated on information and belief, and as to
those matters I believe them to be true.
Sworn to f me this 2() day of , 202-¯¯ Î
NA UY L. BELCHEN
Public, State of New York
Nn n4 RPAA7QA79 Signature of Defendant
Notary Public Qualified in Oswego County D fendant's
Commission Expires Dec 15, 20 ddress: ON CD
This case is scheduled to appear on the court calendar as follows:
1 of 1
Document Filed Date
November 30, 2023
Case Filing Date
October 31, 2023
Category
Other Matters - Consumer Credit (Non-Card) Transaction
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Preview
FILED: OSWEGO COUNTY CLERK 11/30/2023 02:16 PM INDEX NO. EFC-2023-1533 OYle- NYSCEF DOC. NO. CO 5 0 COURT COUNTY OF O RECEIVEDPart: NYSCEF: 11/30/2023 WRITTEN ANSWER Plaintiff(s) -against- CONSUMER CREDIT TRANSACTION Co CC wj O EFC-ZOZ3- Defendant(s) index Number: 15 ANSWER. (Check all that apply) 1. General Denial: I deny the allegations in the Complaint. OS EGC COL3NTY CLERES SERVICE 2023 NCU 30 P SS 2. O I did not receive a copy of the Summons and Complaint. 3. O I received the Summons and Complaint, but service was not correct as required by law. DEFENSES 4. It is not my debt. I am a victim of identity theft or mistaken identity. 5. I have paid all or part of the alleged debt. 6. I dispute the amount of the debt. 7. I had no business dealings with Plaintiff (Plaintiff lacks standing). 8. There is no record of plaintiff having a license to collect debt (only for cases filed in New York City, Buffalo and other municipalities requiring debt collectors to be licensed). 9. Plaintiff does not allege a debt collector's license number in the Complaint (only for cases filed in New York City, Buffalo and other municipalities requiring debt collectors to be licensed). 10. O Statute of limitations (the time has passed to sue on this debt). 11. O This debt has been discharged in bankruptcy. 12. O The collateral (property) was not sold at a commercially reasonable price. 13. O Failure to provide proper notice before selling collateral (property). 14. O Failure to mitigate damages (Plaintiff did not take reasonable steps to limit damages). 15. O Unjust enrichment (the amount demanded is excessive compared with the original debt). 16. O Violation of the duty of good faith and fair dealing. 17. O Unconscionability (the contract is unfair). 18. ¤ Laches (plaintiff has excessively delayed in bringing this lawsuit to my disadvantage). 19-a. ¤ OUTSIDE OF NEW YORK CITY ONLY: Lack of personal jurisdiction under Uniform City Court Act § 213 (applies if you do not work in the city where the case was filed and you are not a resident of that city or (for all counties except Westchester and Nassau counties) you are not a resident of a town next to that city within the same county). 19-b. O SUFFOLK COUNTY: Lack of personal jurisdiction; the defendant is not a resident and/or was not served in, or there was no transaction of business in, that portion of Suffolk County for which a District Court has been established (Towns of Huntington, Babylon, Islip, Smithtown and Brookhaven). 20. Defendant is in the military. OTHER 21. Other Reasons 22. Please take notice that my only source of income is , which is exempt from collection. COUNTERCLAIM(S) 23. Counterclaim(s): $ Reason: VERIFICATION State of New York, County of C be r() ss: /h co p)d+c ld0Ç [ LJ0GT {f being duly sworn, deposes and says: I have read the Answer in Writing and know the contents to be true from my own knowledge, except as to those matters stated on information and belief, and as to those matters I believe them to be true. Sworn to f me this 2() day of , 202-¯¯ Î NA UY L. BELCHEN Public, State of New York Nn n4 RPAA7QA79 Signature of Defendant Notary Public Qualified in Oswego County D fendant's Commission Expires Dec 15, 20 ddress: ON CD This case is scheduled to appear on the court calendar as follows: 1 of 1