Preview
INDEX NO. 805650/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF 04/19/2024
CONSUMER CREDIT TRANSACTION
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ERIE
CAVALRY SPV I, LLC, AS ASSIGNEE OF Index No.:
CITIBANK, N.A., Date Purchased
Plaintiff,
SUMMONS
VS. The basis of the venue designated is
The defendant resides in the
County of Erie
ANNA M DANIELS,
Defendant. O The transaction took place in the
County of Erie
To the above-named Defendant:
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve
a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of
appearance, on the Plaintiff's Attorney(s) at the address stated below within 20 days after the
service of this summons, exclusive of the day of service (or within 30 days after the service is
complete if this summons is not personally delivered to you within the State of New York); and in
case of your failure to appear or answer, judgment will be taken against you by default for the
relief demanded in the complaint.
Dated: wey.
00 VY By:
MAN
Heat
Mari:
C (RICH LAW GROUP, LLP
. Johnson, Esq.
Purpura, Esq.
Attorneys for Plaintiff
600 Essjay Rd., Suite 200
Williamsville, NY 14221
(833) 769-2757
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INDEX NO. 805650/2024
FILED: ERIE COUNTY CLERK 0471972024 01:33 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/19/2024
TO: ANNA M DANIELS
156 DIRKSON AVE
BUFFALO, NY 14224-1816
WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT
COLLECTOR.
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INDEX NO. 805650/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/19/2024
CONSUMER CREDIT TRANSACTION
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ERIE
CAVALRY SPV I, LLC, AS ASSIGNEE OF
CITIBANK, N.A.,
COMPLAINT
Plaintiff,
Index No.:
VS.
ANNA M DANIELS,
Defendant.
Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., by its attorneys,
Mandarich Law Group, LLP, complaining of the Defendant, ANNA M DANIELS, alleges the
following:
1 Plaintiff is a foreign limited liability company organized and existing by virtue of the laws
of Delaware, with a principal place of business located at 1 American Lane, Suite 220, Greenwich,
CT 06831.
2. Upon information and belief, Defendant ANNA M DANIELS, was and is a natural person
residingjat 156 DIRKSON AVE, County of Erie, State of New York.
3 Plaintiff took by assignment and/or purchased, for value, all rights, title, and interest of
certain accounts, including the account identified below, which originated with Citibank, N.A.
(hereinafter the “Original Creditor”).
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INDEX NO. 805650/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/19/2024
4 The chain of title is as follows:
Date of Assignor: Assignee: Account Balance
Assignment at Transfer:
(On or About):
3/24/2023 Citibank, N.A. Cavalry SPV I, LLC $10,212.18
5 The Original Creditor issued a consumer credit card account to the Defendant bearing an
account number ending in XXXXXXXXXXXX2658 as printed on the most recent account
statement recording a purchase transaction, payment or balance transfer (hereinafter the
“Account”), which Account is the subject of this action.
6 Defendant entered into an agreement with the Original Creditor and made purchases,
received cash, merchandise, and/or credit on the Account.
7. A copy of the Charge-Off statement for the Account is attached hereto.
8 An itemization of the Account is as follows:
Total due at charge-off: $10,212.18
Total interest accrued since charge-off: $0.00
Total non-interest charges/fees accrued since charge-off: $0.00
Total amount of payments and/or credits since charge-off: $50.00
9. The last payment on the account was made on: 10/31/2023 in the amount of $25.00.
10. The Account balance printed on the most recent Account statement provided by the
Original Creditor recording a purchase, transaction, last payment or balance transfer was
$9,547.53.
11. Defendant agreed to but failed to make payments on said Account and $10,162.18 is now
due and owing to the Plaintiff from Defendant, which amount has been demanded and remains
unpaid.
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= INDEX NO. 805650/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/19/2024
12 Defendant is in default and Plaintiff, as owner of the Account, is authorized to proceed
with this action.
13 Plaintiff has suffered damages in the amount of $10,162.18, together with the costs and
disbursements incurred in this action.
14. The causes of action asserted herein are not outside of the applicable statute of limitations
for enforcing the debt.
WHEREFORE, Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A.
respectfully requests judgment against the Defendant, ANNA M DANIELS, for the sum of
$10,162.18, all costs and disbursements of this action, with interest from the date of any judgment
\A
granted or ordered, and for such other and furt! er reliefas this Court deems just and proper.
Dated: Williamsville, New York
“4 Ln» By:
WN ICH LAW GROUP, LLP
an . Johnson, Esq.
Mari Purpura, Esq
Attorfeys for Plaintiff
600 Essjay Rd., Suite 200
Williamsville, NY 14221
(833) 769-2757
MLG-4844058
TO: .ANNA M DANIELS
156 DIRKSON AVE
BUFFALO, NY 14224-1816
WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT
COLLECTOR
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Preview
INDEX NO. 805650/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF 04/19/2024 CONSUMER CREDIT TRANSACTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ERIE CAVALRY SPV I, LLC, AS ASSIGNEE OF Index No.: CITIBANK, N.A., Date Purchased Plaintiff, SUMMONS VS. The basis of the venue designated is The defendant resides in the County of Erie ANNA M DANIELS, Defendant. O The transaction took place in the County of Erie To the above-named Defendant: YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance, on the Plaintiff's Attorney(s) at the address stated below within 20 days after the service of this summons, exclusive of the day of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: wey. 00 VY By: MAN Heat Mari: C (RICH LAW GROUP, LLP . Johnson, Esq. Purpura, Esq. Attorneys for Plaintiff 600 Essjay Rd., Suite 200 Williamsville, NY 14221 (833) 769-2757 lof 5 INDEX NO. 805650/2024 FILED: ERIE COUNTY CLERK 0471972024 01:33 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/19/2024 TO: ANNA M DANIELS 156 DIRKSON AVE BUFFALO, NY 14224-1816 WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. 2 0f 5 INDEX NO. 805650/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/19/2024 CONSUMER CREDIT TRANSACTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ERIE CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., COMPLAINT Plaintiff, Index No.: VS. ANNA M DANIELS, Defendant. Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., by its attorneys, Mandarich Law Group, LLP, complaining of the Defendant, ANNA M DANIELS, alleges the following: 1 Plaintiff is a foreign limited liability company organized and existing by virtue of the laws of Delaware, with a principal place of business located at 1 American Lane, Suite 220, Greenwich, CT 06831. 2. Upon information and belief, Defendant ANNA M DANIELS, was and is a natural person residingjat 156 DIRKSON AVE, County of Erie, State of New York. 3 Plaintiff took by assignment and/or purchased, for value, all rights, title, and interest of certain accounts, including the account identified below, which originated with Citibank, N.A. (hereinafter the “Original Creditor”). 3 0f 5 INDEX NO. 805650/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/19/2024 4 The chain of title is as follows: Date of Assignor: Assignee: Account Balance Assignment at Transfer: (On or About): 3/24/2023 Citibank, N.A. Cavalry SPV I, LLC $10,212.18 5 The Original Creditor issued a consumer credit card account to the Defendant bearing an account number ending in XXXXXXXXXXXX2658 as printed on the most recent account statement recording a purchase transaction, payment or balance transfer (hereinafter the “Account”), which Account is the subject of this action. 6 Defendant entered into an agreement with the Original Creditor and made purchases, received cash, merchandise, and/or credit on the Account. 7. A copy of the Charge-Off statement for the Account is attached hereto. 8 An itemization of the Account is as follows: Total due at charge-off: $10,212.18 Total interest accrued since charge-off: $0.00 Total non-interest charges/fees accrued since charge-off: $0.00 Total amount of payments and/or credits since charge-off: $50.00 9. The last payment on the account was made on: 10/31/2023 in the amount of $25.00. 10. The Account balance printed on the most recent Account statement provided by the Original Creditor recording a purchase, transaction, last payment or balance transfer was $9,547.53. 11. Defendant agreed to but failed to make payments on said Account and $10,162.18 is now due and owing to the Plaintiff from Defendant, which amount has been demanded and remains unpaid. 40f 5 = INDEX NO. 805650/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/19/2024 12 Defendant is in default and Plaintiff, as owner of the Account, is authorized to proceed with this action. 13 Plaintiff has suffered damages in the amount of $10,162.18, together with the costs and disbursements incurred in this action. 14. The causes of action asserted herein are not outside of the applicable statute of limitations for enforcing the debt. WHEREFORE, Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A. respectfully requests judgment against the Defendant, ANNA M DANIELS, for the sum of $10,162.18, all costs and disbursements of this action, with interest from the date of any judgment \A granted or ordered, and for such other and furt! er reliefas this Court deems just and proper. Dated: Williamsville, New York “4 Ln» By: WN ICH LAW GROUP, LLP an . Johnson, Esq. Mari Purpura, Esq Attorfeys for Plaintiff 600 Essjay Rd., Suite 200 Williamsville, NY 14221 (833) 769-2757 MLG-4844058 TO: .ANNA M DANIELS 156 DIRKSON AVE BUFFALO, NY 14224-1816 WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR 5 of 5