Preview
INDEX NO. 511488/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024
CONSUMER CREDIT TRANSACTION
Date Purchased:
SUPREME COURT OF THE STATE OF NEW YORK Index Ne
COUNTY OF KINGS xX
Cavalry SPV1, LLC SUMMONS
Plaintiff, Plaintiff's Address:
-against- 1 American Lane, Suite 220
Greenwich CT 06831
SHANTEL RISHER
Defendant(s).
The Basis of Venue is:
CPLR SEC. 503(f). Defendants
residence is in the County of KINGS.
Defendant(s) Address:
DEF1- 424 ELTON ST, BROOKLYN NY 11208-2130
TO THE ABOVE NAMED DEFENDANT(S):
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your
answer on the Plaintiffs Attorney(s) within 20 days after the service of this summons, exclusive of the day of
service, or within 30 days after service is complete if this summons is not personally delivered to you within the
State of New York; and in the case of your failure to appear or answer, judgment will be taken against you by
default for the relief demanded in the complaint.
We are attorneys attempting to collect a debt. Any information obtained will be used for that purpose.
Dated: April 9, 2024
Matter #515296
O ‘tephen Einstein 1 Scott Morris
(Anthony S. Poulin (J Dianne Ramdeen
X Sharil Clarke L Joseph G. Devine
(Chester Andrew Guala (Gerard W. DeStefano
(J Richa Bhandari oO
Tromberg, Morris & Poulin, PLLC.
Attorneys for the Plaintiff
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
ADU
S_S_SUP-SUM
1 of 12
INDEX NO. 511488/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024
SUPREME COURT OF THE STATE OF NEW YORK INDEX Ne:
COUNTY OF KINGS
Cavalry SPV I, LLC
Plaintiff,
-against-
COMPLAINT
SHANTEL RISHER
Defendant(s).
Plaintiff, by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges
that:
1 Plaintiff is an active foreign entity conducting business in the state of CT. Plainiff is licensed by the
NYC Department of Consumer Affairs, Debt Collection Agency License #1327348.
2. Upon information and belief, the Defendant(s) resides or has an office in the venue in which this
action is brought, or the Defendant(s) transacted business within the venue in which this action is brought,
either in person or through an agent, and the instant cause of action arose out of said transaction.
3. Based upon a reasonable inquiry, the Statute of Limitations for the cause of action asserted herein
has not expired.
AS AND FOR A FIRST CAUSE OF ACTION
4. Upon information and belief the Defendant(s) hereto entered into a Revolving Credit Account
Agreement (hereinafter "Account") with Citibank, N.A. (hereinafter "Original Creditor"), the Original
Creditor as defined by CPLR §105(q-1), bearing an account number on the most recent statement ending
in #XXXXXXXXXXXX4700, as so evidenced in the statement attached hereto, wherein Defendant(s)
agreed to pay Original Creditor all amounts charged to said Account.
5. Upon information and belief, Defendant(s) incurred charges by use of the said Account and
defaulted. As a result of the Defendant’s default the Original Creditor closed the Account and
subsequently charged it off on 09/13/2023 in the amount of $2,074.10. Pursuant to CPLR §3016(j) a
copy of the Charge-Off Statement is attached hereto.
6. Susequently, the Original Creditor sold/ assigned the Account, including all rights, title and interest
in and to the outstanding balance owed by Defendant(s). Plaintiff, purchased and/or took by assignment
the account herein on or about 10/27/2023. The complete chain of sale and assignment and dates sold
and/or assigned are as follows:
Assignor Date of Transfer Amt. at Time of Transfer
Transfer 1: Citibank, N.A. 10/27/2023 $2,074.10
7. Upon information and belief the date of last payment on this account was 01/30/2023 in the amount
of $49.47.
S_S_COM-RTL
2 of 12
INDEX NO. 511488/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024
8. At this time, Defendant(s) owes $2,074.10 on the Account. This amount includes a charge-off
balance of $2,074.10, post-charge-off interest of $0.00, non-interest charges or fees accrued since charge-
off of $0.00, less any post-charge-off credits or payments made by or on behalf of the Defendant of $0.00;
and that amount has not been paid despite due demand.
WHEREFORE, Plaintiff demands judgment against Defendant(s) in the sum of $2,074.10, plus costs
and disbursements.
CERTIFICATION: Deponent is an attorney associated with Tromberg, Morris & Poulin, PLLC. Deponent
certifies that, to the best of their knowledge, information and belief, formed after an inquiry reasonable
under the circumstances, the presentation of the paper or the contentions therein are not frivolous as defined
in section 130-1.1(c) of the Chief Administrative Judge, and an initiating pleading, the matter was not
obtained through illegal conduct, and the matter was not obtained in violation of Part 1200. Rule 4.5 of this
Title. Affirmed this 9th day of April, 2024.
Matter #515296 en Einstein O Scott Morris
(_] Anthony S. Poulin LJ Dianne Ramdeen
XJ Sharil Clarke (1 Joseph G. Devine
[_] Chester Andrew Guala ([] Gerard W. DeStefano
{J Richa Bhandari Oo
S_S_COM-RTL
3 of 12
INDEX NO. 511488/2024
FILED: KINGS COUNTY CLERK 04/2272024 05:49 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024
EXHIBIT “A”
(CHARGE-OFF/ LAST STATEMENT)
Matter #: 515296
S_EXH-COSM
4 of 12
INDEX NO. 511488/2024
NYSCEF Di NO Q4 024
Corttim PLN]+) (M1 OF- EJs ha OF-T | roth
SHANTEL RISHER Billing Inquiries and Customer Service
Member Since 2022 Account number ending in: 4700 BOX 6500 SIOUX FALLS, SD 57117
Billing Period: 08/12/23-09/13/23 1-800-846-8444, (TTY: 711)
www.citicards.com
SEPTEMBER STATEMENT Account Summary
Minimum payment due: $2,074.10 Previous balance $2,020.01
New balance as of 09/13/23: $2,074.10 Payments -$0.00
Payment due date: 09/13/23 Credits -$0.00
See the last page of this statement for Important information about how to Purchases +$0.00
avoid paying interest on purchase: Cash advances +$0.00
Fees +$0.00
Late Payment Warning: If we do not receive your minimum payment by the Interest +$54.09
date listed above, you may have to pay a late fee of up to $41 and your APRs New balance $2,074.10
may be increased up to the Penalty APR of 29.99%.
Minimum Payment Warning: If you make only the minimum payment each Credit Limit
period, you will pay more in interest and it will take you longer to pay off your Credit limit $1,500
balance. For example: Includes $500 cash advance limit
If you make no additional You will pay off the And you will end up
charges using this card balance shown on this paying an estimated
and each month you pay... statement in about... total of. .
Only the minimum payment 1 month(s) $2,074
For information about credit counseling services, call 1-877-337-8188.
For Payments, send check to: CITI CARDS, PO Box 70166, Philadelphia PA, 19176-0166
® Pay online www.citicards.com
$2,074.10
©
Minimum payment due
Pay by phone 1-800-846-8444
New balance $2,074.10
© Pay by mail Use this coupon
* Enclosea valid check or money order payable
Payment due date 09/13/23
to CITI CARDS. No cash or foreign currency. Amount enclosed:
‘© Write the last four digits of your
account number on your check
000000 MC 34 A0 Account number ending in 4700
Please make check payable to CITI CARDS.
SHANTEL RISHER CITI CARDS.
424 ELTON ST PO Box 70166
BROOKLYN NY 11208 Philadelphia PA 19176-0166
INDEX NO. 511488/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF 04/22/2024
www.citicards.com Customer Service 1-800-846-8444 Page 2 of 2
(TTY: 711)
SHANTEL RISHER
Account Summary
Trans. Post
date date Description Amount
Fees charged
Total fees charged in this billing period $0.00
Interest charged
Date Descri tion Amount
9/3 INTEREST CHARGED TO STANDARD PURCH $54.09
Total interest charged in this billing period $54.09
2023 totals year-to-date
Total fe hi 2023 $235.00
Total interest charged in 2023 $374.13
Interest charge calculation Days in billing cycle: 33
Your Annual Percentage Rate (APR) the annual interest rate on your account.
Annual percentage Balance subject
Balance type tate (APR) to interest rate Interest charge
Standard Purch 29.24% (V) $2,046.12 (D) $54.09
Standard Adv 29.99% (V) $0.00 (D) $0.00
Your Annual Percentage Rate (APR) is the annual interest rate on your account. APRs followed
by (V) may vary. Balances followed by (D) are determined by the daily balance method
(including current transactions).
Account messages
Minimum Payment Due includes past due amounts. Your account may be with
a collection vendor and when you call our number, you may be referred to the
vendor. You may reach us at the toll-free number shown above.
Monday-Friday 7am to 10 pm, Saturday 7 am to 7 pm, and Sunday 8 am to 7
pm Central Time.
© 2023 Citibank, N.A.
Citi, Citi and Arc Design and other marks used herein are service marks of
Citigroup Inc. or its affiliates, used and registered throughout the world.
6 of 12
INDEX NO. 511488/2024
FILED: KINGS COUNTY CLERK 04/2272024 05:49 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024
EXHIBIT “B”
(LAST USE OF CARD STATEMENT/ BALANCE)
Matter #: 515296
S_EXH-LPAM
7 of 12
INDEX NO. 511488/2024
NYSCEF Di NO Q4 024
Corttim DYN]+) (-M Of-
Fy sha OF-T | otha
SHANTEL RISHER www.citicards.com
Member Since 2022 Account number ending in: 4700 Customer Service 1-855-473-4583
Billing Period: 01/13/23-02/13/23 TTY:711
BOX 6500 SIOUX FALLS, SD 57117
Your account is over the credit limit by
FEBRUARY STATEMENT $37.02. Please pay at least the Minimum
Minimum payment due: $89.60 Payment Due, which includes an Overlimit
New balance as of 02/13/23: $1,537.02 Amount.
Payment due date: 03/09/23
See the last pa je of this statement for important information about how to Account Summary
avoid paying in ‘erest on purchases.
Previous balance $1,475.42
Payments $49.47
Late Payment Warning: |f we do not receive your minimum payment by the Credits -$0.00
date listed above, you may have to pay a late fee of up to $41 and your APRs Purchases +$73.49
may be increased up to the Penalty APR of 29.99%. Cash advances +$0.00
Minimum Payment Warning: If you make only the minimum payment each Fees +$0.00
period, you will pay more in interest and it will take you longer to pay off your Interest +$37.58
balance. For example:
New balance $1,537.02
If you make no additional You will pay off the And you will end up
charges using this card balance shown on this aying an estimated
and éach month you pay... statement in about... otal of... Credit Limit
Credit limit $1,500
Only the minimum payment | 6 year(s) $3,089 Includes $500 cash advance limit
For information about credit counseling services, call 1-877-337-8187.New York
residents may contact the New York State Department of Financial Services at (800)
342-3736 or www.dfs.ny.gov for free information on comparative credit card rates, fees
and grace periods.
En
thankyou =~:
from citi
Total Available
ThankYou® Points: 299
as of 01/31/23
» See page 3 for more information
about your rewards
For Payments, send check to: CITI CARDS, PO Box 70166, Philadelphia PA, 19176-0166.
Pay your bill from virtually anywhere Minimum payment due $89.60
with the Citi Mobile® App and Citi® Online
New balance $1,537.02
To download:
Text 'Appt5' to MyCiti (692484) Payment due date 03/09/23
or go to your device's app store.
Or visit www.citicards.com
Amount enclosed:
000000 MC 00 AO Account number ending in 4700
Please make check payable to CITI CARDS.
SHANTEL RISHER CITI CARDS.
424 ELTON ST PO Box 70166
BROOKLYN NY 11208-2130 Philadelphia PA 19176-0166
= INDEX NO. 511488/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024
www.citicards.com Customer Service 1-855-473-4583 Page 2 of 2
TTY:711
SHANTEL RISHER
a
Account Summary
Trans. thankyou =.
from citi
Post
date date Description Amount
Member |D: NN? 768
Payments, Credits and Adjustments
Total ThankYou Points Balance:
01/30 PAYMENT THANK YOU $49.47
Standard Purchases 299
oie o1/i9 DD/BR #310001 Q35 BROOKLYN NY $5.96 ThankYou Points from Citi Double Cash Card
01/20 01/20 DD/BR #310001 935 BROOKLYN NY $8.78 Purchases: 73
Payments: 49
Total Earned this Period: 122
02/02 02/02 DD/BR #310001 Q35 BROOKLYN NY $9.87
» Visit thankyou.com to redeem points
or see full rewards details
02/06 02/06 DD/BR #310001 Q35 BROOKLYN NY $3.58 Bonus Points may take one to two billing
cycles to appear on your statement. Please
Fees charged refer to the specific terms and conditions
$0.00
pertaining to the promotion for further details.
Total fees charged in this billing period
Interest charged
Date Description Amount
02/13 INTEREST CHARGED TO STANDARD PURCH $37.58 TWO WAYS TO EARN!
Total interest charged in this billing period $37.58
Earnings This Billing Period
GW ThankYou Points on Purchases
1 point per $1
2023 totals year-to-date
Eligible Purchases: $73.49
Total fees charged 2023 $0.00 ThankYou Points Earned: 73
Total interest charged in 2023 $72.05 ThankYou Points on Payments
1 point per $1
Interest charge calculation Days in billing cycle: 32 Eligible Payments $49.47
ThankYou Points Earned: 49
1 Pe Rate (APR)i th It.
Annual percent Balance subject
Balance type rate( 3 to interest rate Interest charge PURCHASE TRACKER AND HOW
PURCHASES. POINTS FOR PAYMENTS WORKS
Standard Purch $1,504.73 (D) $37.58 1. Total Payments Made: $49.47
28.49% (V)
Note: payments are eligible to earn up to the
amount in your Purchase Tracker
Standard Adv 29.74% (V) $0.00 (D) $0.00
2. Purchase Tracker: $1,411.75
Your Annual Percentage Rate (APR) is the annual interest rate on your account. APRs followed 3. Eligible Payments: $49.47
by (V) may vary. Balances followed by (D) are determined by the daily balance method 4. ThankYou Points on
(including current transactions). Eligible Payments 49
Account messages 5. Ending Purchase Tracker: $1,362.28
Your account is over the credit limit by $37.02. Please pay at least the Purchase Tracker- When you make a purchase,
Minimum Payment Due, which includes an Overlimt Amount. If you have that amount goes into your Purchase Tracker.
already sent us this payment, thank you. Balance transfers, cash advances, fees and
interest are not included, Make a payment and the
© 2022 Citibank, N.A Purchase Tracker gets reduced by that amount.
Citi, Citi and Arc Design and other marks used herein are service marks of When the Purchase Tracker reaches $0, you won't
Citigroup Inc. or its affiliates, used and registered throughout the world. earn points for payments until more purchases
are made.
IT'S EASY TO REDEEM
jw fi} WX
Redeem at thankyou.com, on the
Citi Mobile® App or at citicards.com.
Redemption values vary depending on how you
dl hoose to redeem your points.
9 of 12
gs) a 70 BEX NO. 511488/2024
UU 04
NYSCEF BOC. NO. 1 Index No. Year RECEIVED NYSCEF: 04/22/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
= =
Cavalry SPV I, LLC
Plaintiff
-against-
SHANTEL RISHER
Defendant(s)
= =
SUMMONS AND COMPLAINT
=
@
=
ur (Rule 130-1. 1-a)
oO Stephe' Einstein LJ Scott Morris
oO Anthony S. Poulin Oo Dianne Ramdeen
[X{ Sharil Clarke LJ Joseph G. Devine
CL Chester Andrew Guala Gerard W. DeStefano
(J Richa Bhandari O
= =
LAW OFFICE OF
TROMBERG, MORRIS & POULIN, PLLC.
Attorney(s) for Plaintiff
Office and Post Office Address
39 Broadway, Suite 1250
New York, New York 10006
(212) 267-3550
Fax (212) 227-9656
= = =
Service of a copy of the within is hereby admitted.
Dated,
Attorney(s) for Plaintiff(s)
— — —
Sir: Please take notice
Ol NOTICE OF ENTRY:
That within is a (certified) true copy of a duly entered in the office of the clerk
of the within named court on
O NOTICE OF SETTLEMENT
That an order of which the within is a true copy of a
Settlement to the HON. Presented for one of the
judges
Of the within named court, at
On the day of 2024 at__ A.M
Dated,
S_S_SUP-BB
10 of 12
INDEX NO. 511488/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF 04/22/2024
SUPREME COURT OF THE STATE OF NEW YORK INDEX Ne:
COUNTY OF KINGS
Cavalry SPV I, LLC
Plaintiff,
-against-
SHANTEL RISHER
Defendant(s).
NOTICE OF COMMENCEMENT OF ACTION
SUBJECT TO MANDATORY ELECTRONIC FILING
PLEASE TAKE NOTICE that the matter captioned above has been commenced as an
electronically filed case in the New York State Courts Electronic Filing System (“NYSCEF”) as
required by CPLR § 2111 and Uniform Rule § 202.5-bb (AVAILABILITY OF ELECTRONIC
FILING). This notice is being served as required by that rule.
NYSCEF is designed for the electronic filing of documents with the County Clerk and the
court and for the electronic service of those documents, court documents, and court notices upon
counsel and unrepresented litigants who have consented to electronic filing.
Electronic filing offers significant benefits for attorneys and litigants, permitting papers to be
filed with the County Clerk and the court and served on other parties simply, conveniently, and
quickly. NYSCEF case documents are filed with the County Clerk and the court by filing on the
NYSCEF Website, which can be done at any time of the day or night on any day of the week. The
documents are served automatically on all consenting e-filers as soon as the document is uploaded to
the website, which sends out an immediate email notification of the filing.
The NYSCEF System charges no fees for filing, serving, or viewing the electronic case record,
nor does it charge any fees to print any filed documents. Normal filing fees must be paid, but this can
be done on-line.
Parties represented by an attorney: An attorney representing a party who is served with this
notice must either: 1) immediately record his or her representation within the e-filed matter on the
NYSCEF site; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is
pending. Exemptions from mandatory e-filing are limited to attorneys who certify in good faith that
they lack the computer hardware and/or scanner and/or internet connection or that they lack (along
with all employees subject to their direction) the operational knowledge to comply with e-filing
requirements. [Section 202.5-bb(e)]
Parties not represented by an attorney: Unrepresented litigants are exempt from efiling.
They can serve and file documents in paper form and must be served with documents in paper
form. However, an unrepresented litigant may participate in e-filing. For information on how to
participate in e-filing, unrepresented litigants should contact the appropriate clerk in the court where
the action was filed or visit www.nycourts.gov/efileunrepresented. Unrepresented litigants also are
encouraged to visit www.nycourthelp.gov or contact the Help Center in the court where the action
was filed. An unrepresented litigant who consents to e-filing may cease participation at any time.
However, the other parties may continue to e-file their court documents in the case.
S_S-EFI
11 of 12
INDEX NO. 511488/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024
For additional information about electronic filing and to create a NYSCEF account, visit the
NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone: 646-
386-3033; e-mail: efile@nycourts.gov).
Dated: April 9, 2024
hen Einstein O Scott Morris
LJ Anthony S. Poulin LJ Dianne Ramdeen
XX] Sharil Clarke L Joseph G. Devine
(J) Chester Andrew Guala_ [_] Gerard W. DeStefano
(J Richa Bhandari
Tromberg, Morris & Poulin, PLLC.
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
www.tmpplic.com
TO: SHANTEL RISHER
424 ELTON ST
BROOKLYN NY 11208-2130
Matter # 515296
S_S-EFI
12 of 12
Preview
INDEX NO. 511488/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 CONSUMER CREDIT TRANSACTION Date Purchased: SUPREME COURT OF THE STATE OF NEW YORK Index Ne COUNTY OF KINGS xX Cavalry SPV1, LLC SUMMONS Plaintiff, Plaintiff's Address: -against- 1 American Lane, Suite 220 Greenwich CT 06831 SHANTEL RISHER Defendant(s). The Basis of Venue is: CPLR SEC. 503(f). Defendants residence is in the County of KINGS. Defendant(s) Address: DEF1- 424 ELTON ST, BROOKLYN NY 11208-2130 TO THE ABOVE NAMED DEFENDANT(S): YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer on the Plaintiffs Attorney(s) within 20 days after the service of this summons, exclusive of the day of service, or within 30 days after service is complete if this summons is not personally delivered to you within the State of New York; and in the case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. We are attorneys attempting to collect a debt. Any information obtained will be used for that purpose. Dated: April 9, 2024 Matter #515296 O ‘tephen Einstein 1 Scott Morris (Anthony S. Poulin (J Dianne Ramdeen X Sharil Clarke L Joseph G. Devine (Chester Andrew Guala (Gerard W. DeStefano (J Richa Bhandari oO Tromberg, Morris & Poulin, PLLC. Attorneys for the Plaintiff 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 ADU S_S_SUP-SUM 1 of 12 INDEX NO. 511488/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 SUPREME COURT OF THE STATE OF NEW YORK INDEX Ne: COUNTY OF KINGS Cavalry SPV I, LLC Plaintiff, -against- COMPLAINT SHANTEL RISHER Defendant(s). Plaintiff, by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges that: 1 Plaintiff is an active foreign entity conducting business in the state of CT. Plainiff is licensed by the NYC Department of Consumer Affairs, Debt Collection Agency License #1327348. 2. Upon information and belief, the Defendant(s) resides or has an office in the venue in which this action is brought, or the Defendant(s) transacted business within the venue in which this action is brought, either in person or through an agent, and the instant cause of action arose out of said transaction. 3. Based upon a reasonable inquiry, the Statute of Limitations for the cause of action asserted herein has not expired. AS AND FOR A FIRST CAUSE OF ACTION 4. Upon information and belief the Defendant(s) hereto entered into a Revolving Credit Account Agreement (hereinafter "Account") with Citibank, N.A. (hereinafter "Original Creditor"), the Original Creditor as defined by CPLR §105(q-1), bearing an account number on the most recent statement ending in #XXXXXXXXXXXX4700, as so evidenced in the statement attached hereto, wherein Defendant(s) agreed to pay Original Creditor all amounts charged to said Account. 5. Upon information and belief, Defendant(s) incurred charges by use of the said Account and defaulted. As a result of the Defendant’s default the Original Creditor closed the Account and subsequently charged it off on 09/13/2023 in the amount of $2,074.10. Pursuant to CPLR §3016(j) a copy of the Charge-Off Statement is attached hereto. 6. Susequently, the Original Creditor sold/ assigned the Account, including all rights, title and interest in and to the outstanding balance owed by Defendant(s). Plaintiff, purchased and/or took by assignment the account herein on or about 10/27/2023. The complete chain of sale and assignment and dates sold and/or assigned are as follows: Assignor Date of Transfer Amt. at Time of Transfer Transfer 1: Citibank, N.A. 10/27/2023 $2,074.10 7. Upon information and belief the date of last payment on this account was 01/30/2023 in the amount of $49.47. S_S_COM-RTL 2 of 12 INDEX NO. 511488/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 8. At this time, Defendant(s) owes $2,074.10 on the Account. This amount includes a charge-off balance of $2,074.10, post-charge-off interest of $0.00, non-interest charges or fees accrued since charge- off of $0.00, less any post-charge-off credits or payments made by or on behalf of the Defendant of $0.00; and that amount has not been paid despite due demand. WHEREFORE, Plaintiff demands judgment against Defendant(s) in the sum of $2,074.10, plus costs and disbursements. CERTIFICATION: Deponent is an attorney associated with Tromberg, Morris & Poulin, PLLC. Deponent certifies that, to the best of their knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the presentation of the paper or the contentions therein are not frivolous as defined in section 130-1.1(c) of the Chief Administrative Judge, and an initiating pleading, the matter was not obtained through illegal conduct, and the matter was not obtained in violation of Part 1200. Rule 4.5 of this Title. Affirmed this 9th day of April, 2024. Matter #515296 en Einstein O Scott Morris (_] Anthony S. Poulin LJ Dianne Ramdeen XJ Sharil Clarke (1 Joseph G. Devine [_] Chester Andrew Guala ([] Gerard W. DeStefano {J Richa Bhandari Oo S_S_COM-RTL 3 of 12 INDEX NO. 511488/2024 FILED: KINGS COUNTY CLERK 04/2272024 05:49 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 EXHIBIT “A” (CHARGE-OFF/ LAST STATEMENT) Matter #: 515296 S_EXH-COSM 4 of 12 INDEX NO. 511488/2024 NYSCEF Di NO Q4 024 Corttim PLN]+) (M1 OF- EJs ha OF-T | roth SHANTEL RISHER Billing Inquiries and Customer Service Member Since 2022 Account number ending in: 4700 BOX 6500 SIOUX FALLS, SD 57117 Billing Period: 08/12/23-09/13/23 1-800-846-8444, (TTY: 711) www.citicards.com SEPTEMBER STATEMENT Account Summary Minimum payment due: $2,074.10 Previous balance $2,020.01 New balance as of 09/13/23: $2,074.10 Payments -$0.00 Payment due date: 09/13/23 Credits -$0.00 See the last page of this statement for Important information about how to Purchases +$0.00 avoid paying interest on purchase: Cash advances +$0.00 Fees +$0.00 Late Payment Warning: If we do not receive your minimum payment by the Interest +$54.09 date listed above, you may have to pay a late fee of up to $41 and your APRs New balance $2,074.10 may be increased up to the Penalty APR of 29.99%. Minimum Payment Warning: If you make only the minimum payment each Credit Limit period, you will pay more in interest and it will take you longer to pay off your Credit limit $1,500 balance. For example: Includes $500 cash advance limit If you make no additional You will pay off the And you will end up charges using this card balance shown on this paying an estimated and each month you pay... statement in about... total of. . Only the minimum payment 1 month(s) $2,074 For information about credit counseling services, call 1-877-337-8188. For Payments, send check to: CITI CARDS, PO Box 70166, Philadelphia PA, 19176-0166 ® Pay online www.citicards.com $2,074.10 © Minimum payment due Pay by phone 1-800-846-8444 New balance $2,074.10 © Pay by mail Use this coupon * Enclosea valid check or money order payable Payment due date 09/13/23 to CITI CARDS. No cash or foreign currency. Amount enclosed: ‘© Write the last four digits of your account number on your check 000000 MC 34 A0 Account number ending in 4700 Please make check payable to CITI CARDS. SHANTEL RISHER CITI CARDS. 424 ELTON ST PO Box 70166 BROOKLYN NY 11208 Philadelphia PA 19176-0166 INDEX NO. 511488/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF 04/22/2024 www.citicards.com Customer Service 1-800-846-8444 Page 2 of 2 (TTY: 711) SHANTEL RISHER Account Summary Trans. Post date date Description Amount Fees charged Total fees charged in this billing period $0.00 Interest charged Date Descri tion Amount 9/3 INTEREST CHARGED TO STANDARD PURCH $54.09 Total interest charged in this billing period $54.09 2023 totals year-to-date Total fe hi 2023 $235.00 Total interest charged in 2023 $374.13 Interest charge calculation Days in billing cycle: 33 Your Annual Percentage Rate (APR) the annual interest rate on your account. Annual percentage Balance subject Balance type tate (APR) to interest rate Interest charge Standard Purch 29.24% (V) $2,046.12 (D) $54.09 Standard Adv 29.99% (V) $0.00 (D) $0.00 Your Annual Percentage Rate (APR) is the annual interest rate on your account. APRs followed by (V) may vary. Balances followed by (D) are determined by the daily balance method (including current transactions). Account messages Minimum Payment Due includes past due amounts. Your account may be with a collection vendor and when you call our number, you may be referred to the vendor. You may reach us at the toll-free number shown above. Monday-Friday 7am to 10 pm, Saturday 7 am to 7 pm, and Sunday 8 am to 7 pm Central Time. © 2023 Citibank, N.A. Citi, Citi and Arc Design and other marks used herein are service marks of Citigroup Inc. or its affiliates, used and registered throughout the world. 6 of 12 INDEX NO. 511488/2024 FILED: KINGS COUNTY CLERK 04/2272024 05:49 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 EXHIBIT “B” (LAST USE OF CARD STATEMENT/ BALANCE) Matter #: 515296 S_EXH-LPAM 7 of 12 INDEX NO. 511488/2024 NYSCEF Di NO Q4 024 Corttim DYN]+) (-M Of- Fy sha OF-T | otha SHANTEL RISHER www.citicards.com Member Since 2022 Account number ending in: 4700 Customer Service 1-855-473-4583 Billing Period: 01/13/23-02/13/23 TTY:711 BOX 6500 SIOUX FALLS, SD 57117 Your account is over the credit limit by FEBRUARY STATEMENT $37.02. Please pay at least the Minimum Minimum payment due: $89.60 Payment Due, which includes an Overlimit New balance as of 02/13/23: $1,537.02 Amount. Payment due date: 03/09/23 See the last pa je of this statement for important information about how to Account Summary avoid paying in ‘erest on purchases. Previous balance $1,475.42 Payments $49.47 Late Payment Warning: |f we do not receive your minimum payment by the Credits -$0.00 date listed above, you may have to pay a late fee of up to $41 and your APRs Purchases +$73.49 may be increased up to the Penalty APR of 29.99%. Cash advances +$0.00 Minimum Payment Warning: If you make only the minimum payment each Fees +$0.00 period, you will pay more in interest and it will take you longer to pay off your Interest +$37.58 balance. For example: New balance $1,537.02 If you make no additional You will pay off the And you will end up charges using this card balance shown on this aying an estimated and éach month you pay... statement in about... otal of... Credit Limit Credit limit $1,500 Only the minimum payment | 6 year(s) $3,089 Includes $500 cash advance limit For information about credit counseling services, call 1-877-337-8187.New York residents may contact the New York State Department of Financial Services at (800) 342-3736 or www.dfs.ny.gov for free information on comparative credit card rates, fees and grace periods. En thankyou =~: from citi Total Available ThankYou® Points: 299 as of 01/31/23 » See page 3 for more information about your rewards For Payments, send check to: CITI CARDS, PO Box 70166, Philadelphia PA, 19176-0166. Pay your bill from virtually anywhere Minimum payment due $89.60 with the Citi Mobile® App and Citi® Online New balance $1,537.02 To download: Text 'Appt5' to MyCiti (692484) Payment due date 03/09/23 or go to your device's app store. Or visit www.citicards.com Amount enclosed: 000000 MC 00 AO Account number ending in 4700 Please make check payable to CITI CARDS. SHANTEL RISHER CITI CARDS. 424 ELTON ST PO Box 70166 BROOKLYN NY 11208-2130 Philadelphia PA 19176-0166 = INDEX NO. 511488/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 www.citicards.com Customer Service 1-855-473-4583 Page 2 of 2 TTY:711 SHANTEL RISHER a Account Summary Trans. thankyou =. from citi Post date date Description Amount Member |D: NN? 768 Payments, Credits and Adjustments Total ThankYou Points Balance: 01/30 PAYMENT THANK YOU $49.47 Standard Purchases 299 oie o1/i9 DD/BR #310001 Q35 BROOKLYN NY $5.96 ThankYou Points from Citi Double Cash Card 01/20 01/20 DD/BR #310001 935 BROOKLYN NY $8.78 Purchases: 73 Payments: 49 Total Earned this Period: 122 02/02 02/02 DD/BR #310001 Q35 BROOKLYN NY $9.87 » Visit thankyou.com to redeem points or see full rewards details 02/06 02/06 DD/BR #310001 Q35 BROOKLYN NY $3.58 Bonus Points may take one to two billing cycles to appear on your statement. Please Fees charged refer to the specific terms and conditions $0.00 pertaining to the promotion for further details. Total fees charged in this billing period Interest charged Date Description Amount 02/13 INTEREST CHARGED TO STANDARD PURCH $37.58 TWO WAYS TO EARN! Total interest charged in this billing period $37.58 Earnings This Billing Period GW ThankYou Points on Purchases 1 point per $1 2023 totals year-to-date Eligible Purchases: $73.49 Total fees charged 2023 $0.00 ThankYou Points Earned: 73 Total interest charged in 2023 $72.05 ThankYou Points on Payments 1 point per $1 Interest charge calculation Days in billing cycle: 32 Eligible Payments $49.47 ThankYou Points Earned: 49 1 Pe Rate (APR)i th It. Annual percent Balance subject Balance type rate( 3 to interest rate Interest charge PURCHASE TRACKER AND HOW PURCHASES. POINTS FOR PAYMENTS WORKS Standard Purch $1,504.73 (D) $37.58 1. Total Payments Made: $49.47 28.49% (V) Note: payments are eligible to earn up to the amount in your Purchase Tracker Standard Adv 29.74% (V) $0.00 (D) $0.00 2. Purchase Tracker: $1,411.75 Your Annual Percentage Rate (APR) is the annual interest rate on your account. APRs followed 3. Eligible Payments: $49.47 by (V) may vary. Balances followed by (D) are determined by the daily balance method 4. ThankYou Points on (including current transactions). Eligible Payments 49 Account messages 5. Ending Purchase Tracker: $1,362.28 Your account is over the credit limit by $37.02. Please pay at least the Purchase Tracker- When you make a purchase, Minimum Payment Due, which includes an Overlimt Amount. If you have that amount goes into your Purchase Tracker. already sent us this payment, thank you. Balance transfers, cash advances, fees and interest are not included, Make a payment and the © 2022 Citibank, N.A Purchase Tracker gets reduced by that amount. Citi, Citi and Arc Design and other marks used herein are service marks of When the Purchase Tracker reaches $0, you won't Citigroup Inc. or its affiliates, used and registered throughout the world. earn points for payments until more purchases are made. IT'S EASY TO REDEEM jw fi} WX Redeem at thankyou.com, on the Citi Mobile® App or at citicards.com. Redemption values vary depending on how you dl hoose to redeem your points. 9 of 12 gs) a 70 BEX NO. 511488/2024 UU 04 NYSCEF BOC. NO. 1 Index No. Year RECEIVED NYSCEF: 04/22/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS = = Cavalry SPV I, LLC Plaintiff -against- SHANTEL RISHER Defendant(s) = = SUMMONS AND COMPLAINT = @ = ur (Rule 130-1. 1-a) oO Stephe' Einstein LJ Scott Morris oO Anthony S. Poulin Oo Dianne Ramdeen [X{ Sharil Clarke LJ Joseph G. Devine CL Chester Andrew Guala Gerard W. DeStefano (J Richa Bhandari O = = LAW OFFICE OF TROMBERG, MORRIS & POULIN, PLLC. Attorney(s) for Plaintiff Office and Post Office Address 39 Broadway, Suite 1250 New York, New York 10006 (212) 267-3550 Fax (212) 227-9656 = = = Service of a copy of the within is hereby admitted. Dated, Attorney(s) for Plaintiff(s) — — — Sir: Please take notice Ol NOTICE OF ENTRY: That within is a (certified) true copy of a duly entered in the office of the clerk of the within named court on O NOTICE OF SETTLEMENT That an order of which the within is a true copy of a Settlement to the HON. Presented for one of the judges Of the within named court, at On the day of 2024 at__ A.M Dated, S_S_SUP-BB 10 of 12 INDEX NO. 511488/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF 04/22/2024 SUPREME COURT OF THE STATE OF NEW YORK INDEX Ne: COUNTY OF KINGS Cavalry SPV I, LLC Plaintiff, -against- SHANTEL RISHER Defendant(s). NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING PLEASE TAKE NOTICE that the matter captioned above has been commenced as an electronically filed case in the New York State Courts Electronic Filing System (“NYSCEF”) as required by CPLR § 2111 and Uniform Rule § 202.5-bb (AVAILABILITY OF ELECTRONIC FILING). This notice is being served as required by that rule. NYSCEF is designed for the electronic filing of documents with the County Clerk and the court and for the electronic service of those documents, court documents, and court notices upon counsel and unrepresented litigants who have consented to electronic filing. Electronic filing offers significant benefits for attorneys and litigants, permitting papers to be filed with the County Clerk and the court and served on other parties simply, conveniently, and quickly. NYSCEF case documents are filed with the County Clerk and the court by filing on the NYSCEF Website, which can be done at any time of the day or night on any day of the week. The documents are served automatically on all consenting e-filers as soon as the document is uploaded to the website, which sends out an immediate email notification of the filing. The NYSCEF System charges no fees for filing, serving, or viewing the electronic case record, nor does it charge any fees to print any filed documents. Normal filing fees must be paid, but this can be done on-line. Parties represented by an attorney: An attorney representing a party who is served with this notice must either: 1) immediately record his or her representation within the e-filed matter on the NYSCEF site; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is pending. Exemptions from mandatory e-filing are limited to attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or internet connection or that they lack (along with all employees subject to their direction) the operational knowledge to comply with e-filing requirements. [Section 202.5-bb(e)] Parties not represented by an attorney: Unrepresented litigants are exempt from efiling. They can serve and file documents in paper form and must be served with documents in paper form. However, an unrepresented litigant may participate in e-filing. For information on how to participate in e-filing, unrepresented litigants should contact the appropriate clerk in the court where the action was filed or visit www.nycourts.gov/efileunrepresented. Unrepresented litigants also are encouraged to visit www.nycourthelp.gov or contact the Help Center in the court where the action was filed. An unrepresented litigant who consents to e-filing may cease participation at any time. However, the other parties may continue to e-file their court documents in the case. S_S-EFI 11 of 12 INDEX NO. 511488/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 For additional information about electronic filing and to create a NYSCEF account, visit the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone: 646- 386-3033; e-mail: efile@nycourts.gov). Dated: April 9, 2024 hen Einstein O Scott Morris LJ Anthony S. Poulin LJ Dianne Ramdeen XX] Sharil Clarke L Joseph G. Devine (J) Chester Andrew Guala_ [_] Gerard W. DeStefano (J Richa Bhandari Tromberg, Morris & Poulin, PLLC. 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 www.tmpplic.com TO: SHANTEL RISHER 424 ELTON ST BROOKLYN NY 11208-2130 Matter # 515296 S_S-EFI 12 of 12