On August 28, 2023 a
AFFIRMATION - SIGNED NON-SOL
was filed
involving a dispute between
Synchrony Bank,
and
Emily Gigante,
for Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
in the District Court of St. Lawrence County.
Preview
FILED: ST. LAWRENCE COUNTY CLERK 11/13/2023 11:36 AM INDEX NO. EFCV-23-165113
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/13/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ST LAWRENCE
INDEX NUMBER EFCV-23-165113
SYNCHRONY BANK
PLAINTIFF, FILE NO. G1758518
-AGAINST- AFFIRMATION
EMILY GIGANTE
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 2, 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 August 28,
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: November 9, 2023
Josb fh Ta a fo Esq.
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Document Filed Date
November 13, 2023
Case Filing Date
August 28, 2023
Category
Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
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FILED: ST. LAWRENCE COUNTY CLERK 11/13/2023 11:36 AM INDEX NO. EFCV-23-165113 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 11/13/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ST LAWRENCE INDEX NUMBER EFCV-23-165113 SYNCHRONY BANK PLAINTIFF, FILE NO. G1758518 -AGAINST- AFFIRMATION EMILY GIGANTE 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 2, 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 August 28, 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: November 9, 2023 Josb fh Ta a fo Esq. 11111111111111111111111111111111111111111111111111 1111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111111 1 of 1