Preview
FILED: WESTCHESTER COUNTY CLERK 04/22/2024 07:10 PM INDEX NO. 60891/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024
CONSUMER CREDIT TRANSACTION
Date Purchased:
SUPREME COURT OF THE STATE OF NEW YORK Index №
COUNTY OF WESTCHESTER X
Crown Asset Management, LLC SUMMONS
Plaintiff, Plaintiff's Address:
-against- 3100 Breckinridge Blvd. Suite 725
Duluth GA 30096
STACY CAPUTO
Defendant(s).
The Basis of Venue is:
CPLR SEC. 503(f). Defendants
residence is in the County of
WESTCHESTER.
X
Defendant(s) Address:
DEF1- 9 BRIDGE LN, CROTON ON HUDSON NY 10520
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 Plaintiff's 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 16, 2024
Matter # 514615 ____________________________
Stephen Einstein Scott Morris
Anthony S. Poulin Dianne Ramdeen
Sharil Clarke Joseph G. Devine
Chester Andrew Guala Gerard W. DeStefano
Richa Bhandari
Tromberg, Morris & Poulin, PLLC.
Attorneys for the Plaintiff
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
*SM0000514615*
S_S_SUP-SUM
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SUPREME COURT OF THE STATE OF NEW YORK INDEX №:
COUNTY OF WESTCHESTER
Crown Asset Management, LLC
Plaintiff,
-against-
COMPLAINT
STACY CAPUTO
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 GA.
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 Comenity Bank (hereinafter "Original Creditor"), the Original
Creditor as defined by CPLR §105(q-1), bearing an account number on the most recent statement ending
in #XXXXXXXXXXXX2960, 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 05/31/2023 in the amount of $1,550.01. 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 06/16/2023. 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: Comenity Bank 06/16/2023 $1,550.01
7. Upon information and belief the date of last payment on this account was 09/20/2022 in the amount
of $300.00.
S_S_COM-RTL
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8. At this time, Defendant(s) owes $1,550.01 on the Account. This amount includes a charge-off
balance of $1,550.01, 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 $1,550.01, 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 16th day of April, 2024.
____________________________
Matter # 514615 Stephen Einstein Scott Morris
Anthony S. Poulin Dianne Ramdeen
Sharil Clarke Joseph G. Devine
Chester Andrew Guala Gerard W. DeStefano
Richa Bhandari
S_S_COM-RTL
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EXHIBIT “A”
(CHARGE-OFF/ LAST STATEMENT)
Matter #: 514615
S_EXH-COSM
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PAGE 1 OF 4
Summary of account activity Payment information
Account no. ****-****-****-2960 New balance $1,550.01
Minimum payment due $348.00
Previous balance +$1,472.40 Payment due date 06/07/2023
---------------------------------------
Payments -0.00
Other credits Minimum Payment Warning: If you make only the minimum
-0.00
Payment for each period, you will pay more in interest and it will
Purchases +0.00
Other debits take you longer to pay off your balance. For example:
+0.00
Cash advance +0.00 If you make no additional You will pay off And you will
Balance transfer +0.00 charges using this card the balance shown end up paying an
and each month you pay: on the statement estimated total
Fees charged +41.00
in about: of:
Interest charged +36.61
New balance +$1,550.01 Only the minimum payment 5 years $2,669
inhmadon regaMng c counseHng seMces,
Past due amount $296.00
call 1-800-284-1706.
Credit limit $1,030.00
Available credit $0.00
Cash credit limit $0.00
Available cash $0.00
Statement closing date 05/12/2023
Days in billing cycle 30
Details of your transactions
TRANS DATE TRANSACTION DESCRIPTION/LOCATION AMOUNT
Fees
05/07/2023 I-ATE FEE 41.00
TOTAL FEES FOR THIS PERIOD $41.00
Interest charged
Interest Charge on Purchases $36.61
Interest Charge on Cash Advances $0.00
Total Interest For This Period $36.61
2023 totals year to date
Total fees charged in 2023 $205.00
Total interest charged in 2023 $162.47
Interest charge calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account. See BALANCE COMPUTATION
METHOD on page 2 for more details. Minimum interest charge may exceed interest charge below, per your credit card
agreement.
TYPEOF BALANCE SUBJECT INTEREST
BALANCE APR TO INTEREST RATE CHARGE
Purchases 29.74% (v) 1,498.13 (DA) 36.61
Cash Advances 29.99% (v) 0.00 (DA) 0.00
Additional important messages
As a result of your delinquent payment status, your account has been temporarily suspended. Your account will be
evaluated for reinstatement as you continue to make consistent, on-time payments.
(CONTINUED)
NOTICE: See reverse side for important information.
Please tear at perforation above
Account
****-****-****-2960
number
COmenity® New balance Minimum payment
. $1,550.01 $348.00
Yes, I have moved or updated my Mailed payments must reach us
¡ e-mail address - see reverse. Amount enclosed: by 6 pm ET on 06/07/2023.
$
Please make check payable to:
" III"' 'l'I'll"'
I I I I Illl'I'P I "I "P I I
Please return this portion along with your payment to:
STACY CAPUTO
P.O. Box 650968
9 BRIDGE LN
CROTON ON HUDSON NY 10520-3537 Dallas TX 75265-0968
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eepthis portionfor your records--------------------------------------------------------i5 x*NÒ
ÏÑ-TËTË5d.xour duedateis alleast 5 aysafter e cioseoi-each
billingcycle.Wewill notchargeyouintereston purchasesif you payyour
WhatToDoIf YouThinkYouFindA MistakeOn YourStatement entirebalanceby theduedateeachmonth.Wewill begincharginginterest
Ifyouthinkthereis anerroronyourstatement,writeto usat: ComenityBank, on balancetransfersandcashadvancesonthetransactiondate.Wewill
POBox 182782,Columbus,OH43218-2782. beginto chargeintereston newpurchasesmadeundera LowAPR, Equal
Inyourletter,giveusthe followinginformation: Paymentor BudgetPaymentCreditPlanfromthedateof purchase.
Accountinformation:Yournameandaccountnumber.
. Dollaramount·Thedollaramountof thesuspectederror. BALANCECOMPUTATION METHOD.Wecalculateinterestseparatelyfor
Descriptionof Problem:Ifyouthinkthereis anerroronyourbill, eachbalanceusingthe method(s)describedbelow.Thetwolettersin
describewhatyoubelieveis wrongandwhyyoubelieveit is a parenthesesnextto theBalanceSubjectto InterestRatecolumnin the
mistake. InterestChargeCalculationsectiononthisstatementcorresponds to the
Youmustcontactuswithin60daysaftertheerrorappearedonyour following:
statement.Youmustnotifyusof any potentialerrorsin writing.You maycall
us, butif youdowearenotrequiredto investigateany potentialerrorsand (DA)Wefiguretheinterest chargeonthisbalancebyapplyingtheperiodic
you mayhaveto paytheamountin question. rateto the "dailybalance"foreachday in the billingperiod.Togetthe "daily
Whileweinvestigatewhetheror nottherehasbeenan error,the following balance"wetakethe
beginningbalanceeachday,addany newtransactions
aretrue: andfeesandsubtractany paymentsor credits(treatingany netcredit
. Wecannottry to collecttheamountin question,or reportyouas balanceas a zerobalance).Thisgivesusthe daily balance.
delinquentonthatamount.
. Thechargein questionmayremainonyourstatement,andwe may CUSTOMER SERVICE.VisitCOMENITY.NET/COMENITYCARD or call
continueto chargeyouinterestonthatamount.But,if wedetermine 1-855-823-1001 (TDD/TTY1-800-695-1788). Sendall inquiriesto:
thatwemadea mistake,youwill nothaveto paytheamount i n CUSTOMER SERVICE,POBox 182273,Columbus,OH43218-2273.
questionor any interestor otherfeesrelatedto thatamount.
. Whileyoudo nothaveto paytheamountin question,youare TELEPHONE MONITORING. To provideyouwith high-qualityservice,phone
responsiblefortheremainderof yourbalance. communication withus is monitoredand/orrecorded.
. Wecanapplyany unpaidamountagainstyourcreditlimit. ADDITIONAL INFORMATION. Abbreviationsonyourstatementmeanthe
following:(v) meansvariablerate(thisratemayvary);WV INTPAYRQ
YourRightsIf YouAre DissatisfiedWithYourCreditCardPurchases meansWAlVEINTEREST, PAYMENTREQUIRED; WV INTEQPYmeans
Ifyouaredissatisfiedwiththegoodsor servicesthatyouhavepurchased WAlVEINTEREST, EQUALPAYMENT; WV INTLOWPMTmeansWAIVE
withyourcreditcard,andyouhavetriedin goodfaithto correcttheproblem INTEREST, LOW PAYMENT; DFINTPYRQmeansDEFER INTEREST,
withthe merchant,you mayhavetherightnotto paythe remainingamount PAYMENTREQUIRED; DEFINTEQPYmeansDEFERINTEREST, EQUAL
dueonthepurchase. PAYMENT;DFINTLOWPMTmeansDEFERINTEREST, LOWPAYMENT
andLOWAPREQPAYmeansLOWAPR, EQUALPAYMENT.You maypay
To usethis right,all of the followingmustbetrue: all of yourAccountbalanceat any timewithoutpenalty.
1.Thepurchasemusthavebeenmadein yourhomestateor within100 NOTICEABOUTELECTRONIC CHECKCONVERSION. Whenyouprovide
milesof yourcurrentmailingaddress,andthepurchasepricemusthave a checkas payment,youauthorizeuseitherto useinformationfromyour
beenmorethan$50.(Note:Neitherof theseis necessaryif yourpurchase checkto makea one-timeelectronicfundtransferfromyouraccountor to
wasbasedonanadvertisement wemailedto you,or if weownthe company processthepaymentas a checktransaction.
thatsoldyouthegoodsor services.)
2. Youmusthaveusedyourcreditcardforthepurchase.Purchasesmade PAYMENTS. Paymentsin U.S.dollarsreceivedby theapplicableduedate
withcashadvancesfromanATMor witha checkthataccessesyourcredit andcutofftimewill becreditedas of thedatereceived.Mailedor ovemighted
cardaccountdo notqualify. paymentsmustalsomeettherequirements below.Otherwise,a payment
3.Youmustnotyet havefully paidforthepurchase. maynotbecreditedfor up to fivedaysor mayberejected.Thiscardis
issuedby ComenityBankpursuantto a licensefromMastercardIntemational
Ifall of thecriteriaabovearemetandyouarestilldissatisfiedwiththe Incorporated.Mastercardis a registeredtrademarkof Mastercard
purchase,contactus in writingat: ComenityBank,POBox 182782, IntemationalIncorporated.
Columbus,OH43218-2782. Mailingor Overnight(cutofftime 6:00p.m.EasternTime(ET)):
. Senda personalcheck,moneyorder,traveler'scheckor cashier's
Whilewe investigate,thesamerulesapplyto thedisputedamountas checkto thenameandaddressonthepaymentstub(regularmail)or
discussedabove.Afterwefinishour investigation, wewilltellyouour 3000KellwayDrive,Suite120,Carrollton,TX75006(ovemight).
decision.At that point,if wethinkyouoweanamountandyoudo not paywe . Includeyourpaymentstub,usetheretumenvelopeprovidedwithyour
may reportyouas delinquent. statement,writeyouraccountnumberonthecheckandsendone
paymentwithonepaymentstub.
CREDITREPORTING. We mayreportinformationaboutyouraccountto . Donotstapleor clip yourpaymentto the stub,sendany
creditbureaus.Latepayments,missedpayments,or otherdefaultsonyour correspondence withyourpaymentor sendcashor gift certificates.
accountmaybereflectedin yourcreditreport. PayBy Phone(cutofftime 5:00p.m.ET): Callustollfreeat
1-855-823-1001(TDD/TTY 1-800-695-1788).
NOTICEOFCREDITREPORTDISPUTES Online(cutofftime 5:00p.m.ET):VisitCOMENITY.NET/COMENITYCARD.
Ifyoubelieveinformationwereportedto a consumerreportingagencyis
inaccurate,notifyusat ComenityBank,POBox 182789,Columbus,OH
43218-2789. Pleaseprovide:
. Yournameandaccountnumber
. Youraddressandtelephonenumber
. Whatinformationyoudisputeandwhyyoubelieveit is inaccurate
. If available,a copyof thesectionof thecreditreportshowingthe
informationyouaredisputing
Sendall bankruptcynoticesand relatedcorrespondenceto Comenity
Bank,BankruptcyDepartment,POBox 182125,Columbus,OH
43218-2125.
PAYMENTSMARKED"PAIDINFULL".AIIwrittencommunications
regardingdisputedamountsthatinclude any checkor otherpayment
instrumentmarkedwith"paymentin full" or similarlanguage,mustbesentto:
3000KellwayDrive,Suite120,Carrollton,TX75006.
DONOTUSETHEENCLOSEDREMITTANCE ENVELOPE.
- We mayacceptpaymentsentto any otheraddresswithoutlosingany of our
rights.
New information
Title (optional) _____ First Name MI
Last Name Soc. Sec. No
Street Address
Apt. No. RR PO Box
City State __ Zip Code Foreign Map Code
Home Phone Work Phone
Email Address
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PAGE 3 OF 4
Additional important messages - continued
How can you take charge against ID Theft? Visit idtheft.gov to find out.
IMMEDIATE ATTENTION REQ UIRED! Your Account is extremely past due and will be written off as a bad debt SOON.
To avoid this, you must pay the Minimum payment amount shown on this statement at least 4 days prior to the end of the
month in which this statement closed. You can find the Statement closing date in the Summary of account activity on
page 1 of this statement. If you are not able to pay the Minimum payment amount, we may still be able to assist you. Call
us immediately at 1-855-617-8089 (TDD/TTY 1-800-695-1788) to discuss your payment options. If written off, the bad
debt will be reported to the three major credit bureaus and our Recovery team will determine the appropriate steps, as
permitted and available under applicable law, to protect our interests.
IMPORTANT INFORMATION ABOUT LATE FEE CREDITS
We may occasionally provide a credit for the amount, part or all, of a late fee charged to your account. If we do, we will
charge a fee of up to $41.00 for any subsequent late payment. In addition, we may reverse the credit and repost the
charge to your account if you fail to make the minimum payment due on or before the due date in the next billing period.
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EXHIBIT “B”
(LAST USE OF CARD STATEMENT/ BALANCE)
Matter #: 514615
S_EXH-LPAM
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PAGE 1 OF 2
Summary of account activity Payment information
Account no. ****-****-****-2960 New balance $1,049.94
Minimum payment due $40.00
Previous balance +$1,054.09 Payment due date 11/07/2022
Payments -300.00
Other credits Late payment warning:
-0.00
If we do not receive your minimum payment by 11/07/2022 you
Purchases +275.00
Other debits +0.00 nlay haye to pay up to a $41 00 late fee
Cash advance +0.00 Minimum Payment Warning: If you make only the minimum
Balance transfer +0.00 payment for each period, you will pay more in interest and it will
Fees charged +0.00 take you longer to pay off your balance. For example:
Interest charged +20.85 If you make no additional You will pay off And you will
New balance +$1,049.94 charges using this card the balance shown end up paying an
and each month you pay: on the statement estimated total
Past due amount $0.00 in about: of:
Credit limit $1,030.00 Only the minimum payment 3 years $1,614
Available credit -$19.00 $43 3 years $1,548
Cash credit limit $0.00 (Savings = $66)
at m nt closing date 10/13/2022
2 706
Days in billing cycle 31
Details of your transactions
TRANS DATE TRANSACTION DESCRIPTION/LOCATION AMOUNT
09/19/2022 PAYMENT - THANK YOU -300.00
10/05/2022 THE HOME DEPOT 6178 FISHKILL NY 275.00
Interest charged
Interest Charge on Purchases $20.85
Interest Charge on Cash Advances $0.00
Total Interest For This Period $20.85
2022 totals year to date
Total fees charged in 2022 $242.00
Total interest charged in 2022 $142.61
Interest charge calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account. See BALANCE COMPUTATION
METHOD on page 2 for more details. Minimum interest charge may exceed interest charge below, per your credit card
agreement.
TYPE OF BALANCE SUBJECT INTEREST
BALANCE APR TO INTEREST RATE CHARGE
Purchases 27.24% (v) 901.92 (DA) 20.85
Cash Advances 28.24% (v) 0.00 (DA) 0.00
NOTICE: See reverse side for important information.
Please tear at perforation above
Account
****-****-****-2960
number
New balance Minimum payment
$1,049.94 $40.00
Yes, I have moved or updated my Mailed payments must reach us
¡ e-mail address - see reverse. Amount enclosed: by 6 pm ET on 11/07/2022.
$
Please make check payable to:
"
II"'lPI IlPll 'I "IllI I P Pl'llllPI I
Please return this portion along with your payment to:
STACY CAPUTO
P.O. Box 650968
9 BRIDGE LN
CROTON ON HUDSON NY 10520-3537 Dallas TX 75265-0968
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NYSCEF DOC. NO. 1 Index No. Year RECEIVED NYSCEF: 04/22/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WESTCHESTER
Crown Asset Management, LLC
Plaintiff
-against-
STACY CAPUTO
Defendant(s)
SUMMONS AND COMPLAINT
Signature (Rule 130-1. 1-a)
____________________________
Stephen Einstein Scott Morris
Anthony S. Poulin Dianne Ramdeen
Sharil Clarke Joseph G. Devine
Chester Andrew Guala Gerard W. DeStefano
Richa Bhandari
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
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
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
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SUPREME COURT OF THE STATE OF NEW YORK INDEX №:
COUNTY OF WESTCHESTER
Crown Asset Management, LLC
Plaintiff,
-against-
STACY CAPUTO
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 (MANDATORY 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
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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 16, 2024
____________________________
Stephen Einstein Scott Morris
Anthony S. Poulin Dianne Ramdeen
Sharil Clarke Joseph G. Devine
Chester Andrew Guala Gerard W. DeStefano
Richa Bhandari
Tromberg, Morris & Poulin, PLLC.
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
www.tmppllc.com
TO: STACY CAPUTO
9 BRIDGE LN
CROTON ON HUDSON NY 10520
Matter # 514615
S_S-EFI
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Preview
FILED: WESTCHESTER COUNTY CLERK 04/22/2024 07:10 PM INDEX NO. 60891/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 CONSUMER CREDIT TRANSACTION Date Purchased: SUPREME COURT OF THE STATE OF NEW YORK Index № COUNTY OF WESTCHESTER X Crown Asset Management, LLC SUMMONS Plaintiff, Plaintiff's Address: -against- 3100 Breckinridge Blvd. Suite 725 Duluth GA 30096 STACY CAPUTO Defendant(s). The Basis of Venue is: CPLR SEC. 503(f). Defendants residence is in the County of WESTCHESTER. X Defendant(s) Address: DEF1- 9 BRIDGE LN, CROTON ON HUDSON NY 10520 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 Plaintiff's 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 16, 2024 Matter # 514615 ____________________________ Stephen Einstein Scott Morris Anthony S. Poulin Dianne Ramdeen Sharil Clarke Joseph G. Devine Chester Andrew Guala Gerard W. DeStefano Richa Bhandari Tromberg, Morris & Poulin, PLLC. Attorneys for the Plaintiff 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 *SM0000514615* S_S_SUP-SUM 1 of 12 FILED: WESTCHESTER COUNTY CLERK 04/22/2024 07:10 PM INDEX NO. 60891/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 SUPREME COURT OF THE STATE OF NEW YORK INDEX №: COUNTY OF WESTCHESTER Crown Asset Management, LLC Plaintiff, -against- COMPLAINT STACY CAPUTO 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 GA. 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 Comenity Bank (hereinafter "Original Creditor"), the Original Creditor as defined by CPLR §105(q-1), bearing an account number on the most recent statement ending in #XXXXXXXXXXXX2960, 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 05/31/2023 in the amount of $1,550.01. 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 06/16/2023. 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: Comenity Bank 06/16/2023 $1,550.01 7. Upon information and belief the date of last payment on this account was 09/20/2022 in the amount of $300.00. S_S_COM-RTL 2 of 12 FILED: WESTCHESTER COUNTY CLERK 04/22/2024 07:10 PM INDEX NO. 60891/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 8. At this time, Defendant(s) owes $1,550.01 on the Account. This amount includes a charge-off balance of $1,550.01, 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 $1,550.01, 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 16th day of April, 2024. ____________________________ Matter # 514615 Stephen Einstein Scott Morris Anthony S. Poulin Dianne Ramdeen Sharil Clarke Joseph G. Devine Chester Andrew Guala Gerard W. DeStefano Richa Bhandari S_S_COM-RTL 3 of 12 FILED: WESTCHESTER COUNTY CLERK 04/22/2024 07:10 PM INDEX NO. 60891/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 EXHIBIT “A” (CHARGE-OFF/ LAST STATEMENT) Matter #: 514615 S_EXH-COSM 4 of 12 FILED: WESTCHESTER COUNTY CLERK 04/22/2024 INDEX 07:10NO. PM 60891/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 PAGE 1 OF 4 Summary of account activity Payment information Account no. ****-****-****-2960 New balance $1,550.01 Minimum payment due $348.00 Previous balance +$1,472.40 Payment due date 06/07/2023 --------------------------------------- Payments -0.00 Other credits Minimum Payment Warning: If you make only the minimum -0.00 Payment for each period, you will pay more in interest and it will Purchases +0.00 Other debits take you longer to pay off your balance. For example: +0.00 Cash advance +0.00 If you make no additional You will pay off And you will Balance transfer +0.00 charges using this card the balance shown end up paying an and each month you pay: on the statement estimated total Fees charged +41.00 in about: of: Interest charged +36.61 New balance +$1,550.01 Only the minimum payment 5 years $2,669 inhmadon regaMng c counseHng seMces, Past due amount $296.00 call 1-800-284-1706. Credit limit $1,030.00 Available credit $0.00 Cash credit limit $0.00 Available cash $0.00 Statement closing date 05/12/2023 Days in billing cycle 30 Details of your transactions TRANS DATE TRANSACTION DESCRIPTION/LOCATION AMOUNT Fees 05/07/2023 I-ATE FEE 41.00 TOTAL FEES FOR THIS PERIOD $41.00 Interest charged Interest Charge on Purchases $36.61 Interest Charge on Cash Advances $0.00 Total Interest For This Period $36.61 2023 totals year to date Total fees charged in 2023 $205.00 Total interest charged in 2023 $162.47 Interest charge calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. See BALANCE COMPUTATION METHOD on page 2 for more details. Minimum interest charge may exceed interest charge below, per your credit card agreement. TYPEOF BALANCE SUBJECT INTEREST BALANCE APR TO INTEREST RATE CHARGE Purchases 29.74% (v) 1,498.13 (DA) 36.61 Cash Advances 29.99% (v) 0.00 (DA) 0.00 Additional important messages As a result of your delinquent payment status, your account has been temporarily suspended. Your account will be evaluated for reinstatement as you continue to make consistent, on-time payments. (CONTINUED) NOTICE: See reverse side for important information. Please tear at perforation above Account ****-****-****-2960 number COmenity® New balance Minimum payment . $1,550.01 $348.00 Yes, I have moved or updated my Mailed payments must reach us ¡ e-mail address - see reverse. Amount enclosed: by 6 pm ET on 06/07/2023. $ Please make check payable to: " III"' 'l'I'll"' I I I I Illl'I'P I "I "P I I Please return this portion along with your payment to: STACY CAPUTO P.O. Box 650968 9 BRIDGE LN CROTON ON HUDSON NY 10520-3537 Dallas TX 75265-0968 5 of 12 FILED: WESTCHESTER COUNTY CLERK 04/22/2024 INDEX 07:10NO. PM 60891/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 eepthis portionfor your records--------------------------------------------------------i5 x*NÒ ÏÑ-TËTË5d.xour duedateis alleast 5 aysafter e cioseoi-each billingcycle.Wewill notchargeyouintereston purchasesif you payyour WhatToDoIf YouThinkYouFindA MistakeOn YourStatement entirebalanceby theduedateeachmonth.Wewill begincharginginterest Ifyouthinkthereis anerroronyourstatement,writeto usat: ComenityBank, on balancetransfersandcashadvancesonthetransactiondate.Wewill POBox 182782,Columbus,OH43218-2782. beginto chargeintereston newpurchasesmadeundera LowAPR, Equal Inyourletter,giveusthe followinginformation: Paymentor BudgetPaymentCreditPlanfromthedateof purchase. Accountinformation:Yournameandaccountnumber. . Dollaramount·Thedollaramountof thesuspectederror. BALANCECOMPUTATION METHOD.Wecalculateinterestseparatelyfor Descriptionof Problem:Ifyouthinkthereis anerroronyourbill, eachbalanceusingthe method(s)describedbelow.Thetwolettersin describewhatyoubelieveis wrongandwhyyoubelieveit is a parenthesesnextto theBalanceSubjectto InterestRatecolumnin the mistake. InterestChargeCalculationsectiononthisstatementcorresponds to the Youmustcontactuswithin60daysaftertheerrorappearedonyour following: statement.Youmustnotifyusof any potentialerrorsin writing.You maycall us, butif youdowearenotrequiredto investigateany potentialerrorsand (DA)Wefiguretheinterest chargeonthisbalancebyapplyingtheperiodic you mayhaveto paytheamountin question. rateto the "dailybalance"foreachday in the billingperiod.Togetthe "daily Whileweinvestigatewhetheror nottherehasbeenan error,the following balance"wetakethe beginningbalanceeachday,addany newtransactions aretrue: andfeesandsubtractany paymentsor credits(treatingany netcredit . Wecannottry to collecttheamountin question,or reportyouas balanceas a zerobalance).Thisgivesusthe daily balance. delinquentonthatamount. . Thechargein questionmayremainonyourstatement,andwe may CUSTOMER SERVICE.VisitCOMENITY.NET/COMENITYCARD or call continueto chargeyouinterestonthatamount.But,if wedetermine 1-855-823-1001 (TDD/TTY1-800-695-1788). Sendall inquiriesto: thatwemadea mistake,youwill nothaveto paytheamount i n CUSTOMER SERVICE,POBox 182273,Columbus,OH43218-2273. questionor any interestor otherfeesrelatedto thatamount. . Whileyoudo nothaveto paytheamountin question,youare TELEPHONE MONITORING. To provideyouwith high-qualityservice,phone responsiblefortheremainderof yourbalance. communication withus is monitoredand/orrecorded. . Wecanapplyany unpaidamountagainstyourcreditlimit. ADDITIONAL INFORMATION. Abbreviationsonyourstatementmeanthe following:(v) meansvariablerate(thisratemayvary);WV INTPAYRQ YourRightsIf YouAre DissatisfiedWithYourCreditCardPurchases meansWAlVEINTEREST, PAYMENTREQUIRED; WV INTEQPYmeans Ifyouaredissatisfiedwiththegoodsor servicesthatyouhavepurchased WAlVEINTEREST, EQUALPAYMENT; WV INTLOWPMTmeansWAIVE withyourcreditcard,andyouhavetriedin goodfaithto correcttheproblem INTEREST, LOW PAYMENT; DFINTPYRQmeansDEFER INTEREST, withthe merchant,you mayhavetherightnotto paythe remainingamount PAYMENTREQUIRED; DEFINTEQPYmeansDEFERINTEREST, EQUAL dueonthepurchase. PAYMENT;DFINTLOWPMTmeansDEFERINTEREST, LOWPAYMENT andLOWAPREQPAYmeansLOWAPR, EQUALPAYMENT.You maypay To usethis right,all of the followingmustbetrue: all of yourAccountbalanceat any timewithoutpenalty. 1.Thepurchasemusthavebeenmadein yourhomestateor within100 NOTICEABOUTELECTRONIC CHECKCONVERSION. Whenyouprovide milesof yourcurrentmailingaddress,andthepurchasepricemusthave a checkas payment,youauthorizeuseitherto useinformationfromyour beenmorethan$50.(Note:Neitherof theseis necessaryif yourpurchase checkto makea one-timeelectronicfundtransferfromyouraccountor to wasbasedonanadvertisement wemailedto you,or if weownthe company processthepaymentas a checktransaction. thatsoldyouthegoodsor services.) 2. Youmusthaveusedyourcreditcardforthepurchase.Purchasesmade PAYMENTS. Paymentsin U.S.dollarsreceivedby theapplicableduedate withcashadvancesfromanATMor witha checkthataccessesyourcredit andcutofftimewill becreditedas of thedatereceived.Mailedor ovemighted cardaccountdo notqualify. paymentsmustalsomeettherequirements below.Otherwise,a payment 3.Youmustnotyet havefully paidforthepurchase. maynotbecreditedfor up to fivedaysor mayberejected.Thiscardis issuedby ComenityBankpursuantto a licensefromMastercardIntemational Ifall of thecriteriaabovearemetandyouarestilldissatisfiedwiththe Incorporated.Mastercardis a registeredtrademarkof Mastercard purchase,contactus in writingat: ComenityBank,POBox 182782, IntemationalIncorporated. Columbus,OH43218-2782. Mailingor Overnight(cutofftime 6:00p.m.EasternTime(ET)): . Senda personalcheck,moneyorder,traveler'scheckor cashier's Whilewe investigate,thesamerulesapplyto thedisputedamountas checkto thenameandaddressonthepaymentstub(regularmail)or discussedabove.Afterwefinishour investigation, wewilltellyouour 3000KellwayDrive,Suite120,Carrollton,TX75006(ovemight). decision.At that point,if wethinkyouoweanamountandyoudo not paywe . Includeyourpaymentstub,usetheretumenvelopeprovidedwithyour may reportyouas delinquent. statement,writeyouraccountnumberonthecheckandsendone paymentwithonepaymentstub. CREDITREPORTING. We mayreportinformationaboutyouraccountto . Donotstapleor clip yourpaymentto the stub,sendany creditbureaus.Latepayments,missedpayments,or otherdefaultsonyour correspondence withyourpaymentor sendcashor gift certificates. accountmaybereflectedin yourcreditreport. PayBy Phone(cutofftime 5:00p.m.ET): Callustollfreeat 1-855-823-1001(TDD/TTY 1-800-695-1788). NOTICEOFCREDITREPORTDISPUTES Online(cutofftime 5:00p.m.ET):VisitCOMENITY.NET/COMENITYCARD. Ifyoubelieveinformationwereportedto a consumerreportingagencyis inaccurate,notifyusat ComenityBank,POBox 182789,Columbus,OH 43218-2789. Pleaseprovide: . Yournameandaccountnumber . Youraddressandtelephonenumber . Whatinformationyoudisputeandwhyyoubelieveit is inaccurate . If available,a copyof thesectionof thecreditreportshowingthe informationyouaredisputing Sendall bankruptcynoticesand relatedcorrespondenceto Comenity Bank,BankruptcyDepartment,POBox 182125,Columbus,OH 43218-2125. PAYMENTSMARKED"PAIDINFULL".AIIwrittencommunications regardingdisputedamountsthatinclude any checkor otherpayment instrumentmarkedwith"paymentin full" or similarlanguage,mustbesentto: 3000KellwayDrive,Suite120,Carrollton,TX75006. DONOTUSETHEENCLOSEDREMITTANCE ENVELOPE. - We mayacceptpaymentsentto any otheraddresswithoutlosingany of our rights. New information Title (optional) _____ First Name MI Last Name Soc. Sec. No Street Address Apt. No. RR PO Box City State __ Zip Code Foreign Map Code Home Phone Work Phone Email Address 6 of 12 FILED: WESTCHESTER COUNTY CLERK 04/22/2024 INDEX 07:10NO. PM 60891/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 PAGE 3 OF 4 Additional important messages - continued How can you take charge against ID Theft? Visit idtheft.gov to find out. IMMEDIATE ATTENTION REQ UIRED! Your Account is extremely past due and will be written off as a bad debt SOON. To avoid this, you must pay the Minimum payment amount shown on this statement at least 4 days prior to the end of the month in which this statement closed. You can find the Statement closing date in the Summary of account activity on page 1 of this statement. If you are not able to pay the Minimum payment amount, we may still be able to assist you. Call us immediately at 1-855-617-8089 (TDD/TTY 1-800-695-1788) to discuss your payment options. If written off, the bad debt will be reported to the three major credit bureaus and our Recovery team will determine the appropriate steps, as permitted and available under applicable law, to protect our interests. IMPORTANT INFORMATION ABOUT LATE FEE CREDITS We may occasionally provide a credit for the amount, part or all, of a late fee charged to your account. If we do, we will charge a fee of up to $41.00 for any subsequent late payment. In addition, we may reverse the credit and repost the charge to your account if you fail to make the minimum payment due on or before the due date in the next billing period. 7 of 12 FILED: WESTCHESTER COUNTY CLERK 04/22/2024 07:10 PM INDEX NO. 60891/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 EXHIBIT “B” (LAST USE OF CARD STATEMENT/ BALANCE) Matter #: 514615 S_EXH-LPAM 8 of 12 FILED: WESTCHESTER COUNTY CLERK 04/22/2024 INDEX 07:10NO. PM 60891/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 PAGE 1 OF 2 Summary of account activity Payment information Account no. ****-****-****-2960 New balance $1,049.94 Minimum payment due $40.00 Previous balance +$1,054.09 Payment due date 11/07/2022 Payments -300.00 Other credits Late payment warning: -0.00 If we do not receive your minimum payment by 11/07/2022 you Purchases +275.00 Other debits +0.00 nlay haye to pay up to a $41 00 late fee Cash advance +0.00 Minimum Payment Warning: If you make only the minimum Balance transfer +0.00 payment for each period, you will pay more in interest and it will Fees charged +0.00 take you longer to pay off your balance. For example: Interest charged +20.85 If you make no additional You will pay off And you will New balance +$1,049.94 charges using this card the balance shown end up paying an and each month you pay: on the statement estimated total Past due amount $0.00 in about: of: Credit limit $1,030.00 Only the minimum payment 3 years $1,614 Available credit -$19.00 $43 3 years $1,548 Cash credit limit $0.00 (Savings = $66) at m nt closing date 10/13/2022 2 706 Days in billing cycle 31 Details of your transactions TRANS DATE TRANSACTION DESCRIPTION/LOCATION AMOUNT 09/19/2022 PAYMENT - THANK YOU -300.00 10/05/2022 THE HOME DEPOT 6178 FISHKILL NY 275.00 Interest charged Interest Charge on Purchases $20.85 Interest Charge on Cash Advances $0.00 Total Interest For This Period $20.85 2022 totals year to date Total fees charged in 2022 $242.00 Total interest charged in 2022 $142.61 Interest charge calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. See BALANCE COMPUTATION METHOD on page 2 for more details. Minimum interest charge may exceed interest charge below, per your credit card agreement. TYPE OF BALANCE SUBJECT INTEREST BALANCE APR TO INTEREST RATE CHARGE Purchases 27.24% (v) 901.92 (DA) 20.85 Cash Advances 28.24% (v) 0.00 (DA) 0.00 NOTICE: See reverse side for important information. Please tear at perforation above Account ****-****-****-2960 number New balance Minimum payment $1,049.94 $40.00 Yes, I have moved or updated my Mailed payments must reach us ¡ e-mail address - see reverse. Amount enclosed: by 6 pm ET on 11/07/2022. $ Please make check payable to: " II"'lPI IlPll 'I "IllI I P Pl'llllPI I Please return this portion along with your payment to: STACY CAPUTO P.O. Box 650968 9 BRIDGE LN CROTON ON HUDSON NY 10520-3537 Dallas TX 75265-0968 9 of 12 FILED: WESTCHESTER COUNTY CLERK 04/22/2024 07:10 PM INDEX NO. 60891/2024 NYSCEF DOC. NO. 1 Index No. Year RECEIVED NYSCEF: 04/22/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF WESTCHESTER Crown Asset Management, LLC Plaintiff -against- STACY CAPUTO Defendant(s) SUMMONS AND COMPLAINT Signature (Rule 130-1. 1-a) ____________________________ Stephen Einstein Scott Morris Anthony S. Poulin Dianne Ramdeen Sharil Clarke Joseph G. Devine Chester Andrew Guala Gerard W. DeStefano Richa Bhandari 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 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 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 FILED: WESTCHESTER COUNTY CLERK 04/22/2024 07:10 PM INDEX NO. 60891/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/22/2024 SUPREME COURT OF THE STATE OF NEW YORK INDEX №: COUNTY OF WESTCHESTER Crown Asset Management, LLC Plaintiff, -against- STACY CAPUTO 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 (MANDATORY 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 FILED: WESTCHESTER COUNTY CLERK 04/22/2024 07:10 PM INDEX NO. 60891/2024 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 16, 2024 ____________________________ Stephen Einstein Scott Morris Anthony S. Poulin Dianne Ramdeen Sharil Clarke Joseph G. Devine Chester Andrew Guala Gerard W. DeStefano Richa Bhandari Tromberg, Morris & Poulin, PLLC. 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 www.tmppllc.com TO: STACY CAPUTO 9 BRIDGE LN CROTON ON HUDSON NY 10520 Matter # 514615 S_S-EFI 12 of 12