On October 16, 2023 a
AFFIRMATION IN SUPPORT
was filed
involving a dispute between
Discover Bank,
and
Amber Verity,
for Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
in the District Court of Oswego County.
Preview
FILED: OSWEGO COUNTY CLERK 12/28/2023 04:36 PM INDEX NO. EFC-2023-1465
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 12/28/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF OSWEGO
INDEX NUMBER EFC-2023-1465
DISCOVER BANK FILE NO. D173360
PLAINTIFF, AFFIRMATION IN SUPPORT OF
-AGAINST- ENTRY OF JUDGMENT
AMBER VERITY
|||||||||||||||||||||||||||||||||||||||||||||
DEFENDANT.
Joseph Ranaldo, 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 an attorney employed by 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 AMBER VERITY (hereinafter the "Defendant").
Additional Notice Pursuant to CPLR § 3215(g)(3)
3. On October 25, 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.
AMBER VERITY
426 MAIN ST PHOENIX, NY 13135
1 of 2
FILED: OSWEGO COUNTY CLERK 12/28/2023 04:36 PM INDEX NO. EFC-2023-1465
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 12/28/2023
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 December 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: December 22, 2023
Joseph Ranaldo, Esq.
2 of 2
Document Filed Date
December 28, 2023
Case Filing Date
October 16, 2023
Category
Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
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FILED: OSWEGO COUNTY CLERK 12/28/2023 04:36 PM INDEX NO. EFC-2023-1465 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 12/28/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF OSWEGO INDEX NUMBER EFC-2023-1465 DISCOVER BANK FILE NO. D173360 PLAINTIFF, AFFIRMATION IN SUPPORT OF -AGAINST- ENTRY OF JUDGMENT AMBER VERITY ||||||||||||||||||||||||||||||||||||||||||||| DEFENDANT. Joseph Ranaldo, 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 an attorney employed by 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 AMBER VERITY (hereinafter the "Defendant"). Additional Notice Pursuant to CPLR § 3215(g)(3) 3. On October 25, 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. AMBER VERITY 426 MAIN ST PHOENIX, NY 13135 1 of 2 FILED: OSWEGO COUNTY CLERK 12/28/2023 04:36 PM INDEX NO. EFC-2023-1465 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 12/28/2023 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 December 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: December 22, 2023 Joseph Ranaldo, Esq. 2 of 2