On October 16, 2023 a
AFFIRMATION - NON-EXPIRATION OF SOL
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.
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FILED: OSWEGO COUNTY CLERK 12/28/2023 04:36 PM INDEX NO. EFC-2023-1465
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 12/28/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF OSWEGO
INDEX NUMBER EFC-2023-1465
DISCOVER BANK
PLAINTIFF, FILE NO. D173360
-AGAINST- AFFIRMATION
AMBER VERITY
DEFENDANT.
AFFIRMATION OF NON-EXPIRATION OF STATUTE OF LIMITATIONS
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. The statute of limitations for the cause of action asserted herein commenced running on or
about December 1, 2022. The statute of limitations for the cause of action asserted herein
is three years based on the law in New York. The action was filed on or about October 16,
2023. 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: December 22, 2023
Joseøtf Ranaldo sq.
1 of 1
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. 9 RECEIVED NYSCEF: 12/28/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF OSWEGO INDEX NUMBER EFC-2023-1465 DISCOVER BANK PLAINTIFF, FILE NO. D173360 -AGAINST- AFFIRMATION AMBER VERITY DEFENDANT. AFFIRMATION OF NON-EXPIRATION OF STATUTE OF LIMITATIONS 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. The statute of limitations for the cause of action asserted herein commenced running on or about December 1, 2022. The statute of limitations for the cause of action asserted herein is three years based on the law in New York. The action was filed on or about October 16, 2023. 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: December 22, 2023 Joseøtf Ranaldo sq. 1 of 1