Preview
FILED: SUFFOLK COUNTY CLERK 06/18/2024 10:58 AM INDEX NO. 614932/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/18/2024
SUPREMECOURTOF THE STATEOF NEWYORK CONSUMER CREDIT
COUNTYOF SUFFOLK TRANSACTION
Our File No. CC18541
Credit Corp Solutions Inc
Court Index No.
Date Purchased:
SUMMONS
Plaintiff
Plaintiff's address:
-against-
180 West Election Road, S
Dayanara Rivadeneira
Defendant (s)
IIII151 IIIll 1111111111111111111
The basis of venue is:
1111111111111
The defendant(s) reside in the State of New York, County of SUFFOLK
To the above named defendant (s):
PLEASETAKE NOTICETHAT YOUAREHEREBYSUMMONED
to answer the complaint of the herein and to serve a copy of your answer on the
Plaintiff
Plaintiff at the address indicatedbelow within 20 days after service of this Summons
(not counting the date of service itself), or within 30 days after service is complete if the
Summonsis not delivered personally to you within the State of New York.
YOUAREHEREBYNOTIFIED THAT should you fail to answer, a judgment will be
entered against you by default for the relief demanded in the complaint.
Dated: February 22, 2024
& PHILLIPS,
KIRSCHENBAUM P.C.
Attorneys for Plaintiff
BY:
RONALDFERRARO
40 Daniel Street, Suite 7
P.O. Box 9000
Farmingdale, NY 11735-9000
(516) 746-1144
Defendant (s) Address:
1472 Sag Harbor Tpke Apartment 1 Sag Harbor NY 11963
WEAREDEBTCOLLECTORS-THISIS AN ATTEMPTTO COLLECTA DEBTANDANY
INFORMATIONOBTAINEDWILL BE USEDFORTHATPURPOSE.
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FILED: SUFFOLK COUNTY CLERK 06/18/2024 10:58 AM INDEX NO. 614932/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/18/2024
SUPREMECOURT OF THESTATEOF NEWYORK Our File No. CC18541
COUNTYOF SUFFOLK
Credit Corp Solutions Inc Court Index No.
Plaintiff COMPLAINT
-against-
************1798
Dayanara Rivadeneira
Defendant (s)
alleges:
Plaintiff, by its attorneys, complaining of the defendant(s), respectfully
authorized to do business in the State of NewYork.
1. Plaintiff is a corporation
Department of Consumer
Plaintiff is licensed as a debt collector by the New York City
Affairs, license number 1474393.
is brought.
2. That the defendant(s) resides in the county in which this action
not
3. Upon information and belief the causes of action asserted herein are
outside the applicable statute of limitations.
FORA FIRST CAUSEOF ACTION
The defendant(s) heretofore entered into a credit card agreement with the
4.
account number ended in
Plaintiff, original creditor, Synchrony Bank, where the original
************1798.
and
Under the terms of the agreement the defendant(s) were authorized to,
5.
advances and were obligated to repay
did make, charges, purchases and/or obtained cash
the same together with applicable interest.
The last payment on the instant account was received on or
6. defendant('s')
about July 13, 2021 in the amount of $100.00.
7. The account balance printed on the most recent monthly statement recording
a purchase transaction, last payment or balance transfer was $2,665.24.
additional payments as they became due
8. Defendant(s) defaulted in making
leaving a final balance due
and owing as of February 14, 2022 in the amount of $3,300.89,
broken down as follows:
Total amount due at charge-off: $3,300.89
Total interest since charge-off: $0.00
Total non-interest charges since charge-off: $0.00
Total payments/credits since charge-off: $0.00
9. Plaintiff is the purchaser of this account where the original account number
ended in ************1798 and is authorized to proceed with this action. The date on which
the balance herein became due was February 14, 2022
and the Chain of Title, with the
is as follows:
date and amount of each sale or assignment of the account,
March 19, 2022 $3,300.89
Synchrony Bank
March 19, 2022 $3,300.89
Credit Corp Solutions Inc
is/are liable to plaintiff as a result of defendant(s) breach of
10. Defendant(s)
agreement.
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FILED: SUFFOLK COUNTY CLERK 06/18/2024 10:58 AM INDEX NO. 614932/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/18/2024
FORA SECOND
CAUSEOFACTION
11. That heretofore, plaintiff, or the assignor, rendered to defendant(s) monthly,
just
full, and true accounts of the indebtedness due and owing by defendant(s) as a result
of the aforesaid transaction, which is the sum set forth above, and said statements were
delivered without objection.
to defendant(s)
12. Upon information and belief, on or about February 14, 2022 a final statement
of account was mailed to the defendant(s).
13. Defendant(s) is/are liable for an account stated for the amount claimed
above.
WHEREFORE, plaintiff demands judgment against the defendant(s) for the sum of
$3,300.89 together with costs and disbursements.
February 22, 2024 & PHILLIPS,
RSCHENBAUM P.C.
Attorneys for Plaintiff
40 Daniel Street, Suite 7
RONALDFERRARO rm ngdale NY 11735-9000
(516) 746-1144
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FILED: SUFFOLK COUNTY CLERK 06/18/2024 10:58 AM INDEX NO. 614932/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/18/2024
SUPREMECOURTOF THESTATEOF NEWYORK Index No.
COUNTYOF SUFFOLK Our File No. CC18541
____________________________________________Ç
Credit Corp Solutions Inc
Plaintiff,
-against-
Dayanara Rivadeneira
Defendant(s),
.._______________________-------____________Ç
NOTICEOF COMMENCEMENT
OFACTION
SUBJECTTOMANDATORY
ELECTRONICFILING
PLEASETAKENOTICEthat above, which has been
the matter captioned
commenced by filing of the accompanying documents with the County Clerk via the NewYork State
Courts Electronic Filing System ("NYSCEF"), is subject to mandatory electronic filing pursuant to
Section 202.5-bb of the Uniform Rules for the Trial Courts. This notice is being served as required
by Subdivision (b) (3) of that Section.
Counsel and/or parties must either: 1) immediately record their representation within the
e-filed matter on the Consent/Represent page in NYSCEF; or 2) file the Notice of Opt-Out form to
claim one of the limited exemptions from mandatory e-filing (see below). Failure to record
representation may result in an inability to receive electronic notice of any document filings.
Claiming an exemption will require the exempt party to serve and be served with hard copy
documents.
Counsel and unrepresented parties who intend to participate must first create a
in e-filing
NYSCEFaccount and obtain a user ID and password. For additional information about electronic
filing and to create a NYSCEF account, visit the NYSCEF website at www.nycourts.qov/efile or
contact the NYSCEF Resource Center (phone: 646-386-3033; e-mail: efile@nycourts.qov; mailing
address: 60 Centre Street, New York, New York 10007).
Exemptions from mandatory e-filing (Section 202.5-bb(e)) are limited to:
1) 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; and
4
2) parties who expect to represent themselves and who choose not to p icipate in e-filing.
(Such parties are encouraged to visit www
vcoutthelp.cov or conta the Help Center in
the court where the action is pending.) )t 4
RONALDFERRARO
Date: February 22, 2024 KlRSCHENBAUM
& PHILLIPS, P.C.
Dayanara Rivadeneira 40 Daniel Street, Suite 7
1472 Sag Harbor Tpke Apartment 1 P.O. Box 9000
Sag Harbor NY 11963 Farmingdale, NY 11735
Telephone (516) 746-1144
efile@collectlaw.com
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Preview
FILED: SUFFOLK COUNTY CLERK 06/18/2024 10:58 AM INDEX NO. 614932/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/18/2024 SUPREMECOURTOF THE STATEOF NEWYORK CONSUMER CREDIT COUNTYOF SUFFOLK TRANSACTION Our File No. CC18541 Credit Corp Solutions Inc Court Index No. Date Purchased: SUMMONS Plaintiff Plaintiff's address: -against- 180 West Election Road, S Dayanara Rivadeneira Defendant (s) IIII151 IIIll 1111111111111111111 The basis of venue is: 1111111111111 The defendant(s) reside in the State of New York, County of SUFFOLK To the above named defendant (s): PLEASETAKE NOTICETHAT YOUAREHEREBYSUMMONED to answer the complaint of the herein and to serve a copy of your answer on the Plaintiff Plaintiff at the address indicatedbelow within 20 days after service of this Summons (not counting the date of service itself), or within 30 days after service is complete if the Summonsis not delivered personally to you within the State of New York. YOUAREHEREBYNOTIFIED THAT should you fail to answer, a judgment will be entered against you by default for the relief demanded in the complaint. Dated: February 22, 2024 & PHILLIPS, KIRSCHENBAUM P.C. Attorneys for Plaintiff BY: RONALDFERRARO 40 Daniel Street, Suite 7 P.O. Box 9000 Farmingdale, NY 11735-9000 (516) 746-1144 Defendant (s) Address: 1472 Sag Harbor Tpke Apartment 1 Sag Harbor NY 11963 WEAREDEBTCOLLECTORS-THISIS AN ATTEMPTTO COLLECTA DEBTANDANY INFORMATIONOBTAINEDWILL BE USEDFORTHATPURPOSE. 1 of 4 FILED: SUFFOLK COUNTY CLERK 06/18/2024 10:58 AM INDEX NO. 614932/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/18/2024 SUPREMECOURT OF THESTATEOF NEWYORK Our File No. CC18541 COUNTYOF SUFFOLK Credit Corp Solutions Inc Court Index No. Plaintiff COMPLAINT -against- ************1798 Dayanara Rivadeneira Defendant (s) alleges: Plaintiff, by its attorneys, complaining of the defendant(s), respectfully authorized to do business in the State of NewYork. 1. Plaintiff is a corporation Department of Consumer Plaintiff is licensed as a debt collector by the New York City Affairs, license number 1474393. is brought. 2. That the defendant(s) resides in the county in which this action not 3. Upon information and belief the causes of action asserted herein are outside the applicable statute of limitations. FORA FIRST CAUSEOF ACTION The defendant(s) heretofore entered into a credit card agreement with the 4. account number ended in Plaintiff, original creditor, Synchrony Bank, where the original ************1798. and Under the terms of the agreement the defendant(s) were authorized to, 5. advances and were obligated to repay did make, charges, purchases and/or obtained cash the same together with applicable interest. The last payment on the instant account was received on or 6. defendant('s') about July 13, 2021 in the amount of $100.00. 7. The account balance printed on the most recent monthly statement recording a purchase transaction, last payment or balance transfer was $2,665.24. additional payments as they became due 8. Defendant(s) defaulted in making leaving a final balance due and owing as of February 14, 2022 in the amount of $3,300.89, broken down as follows: Total amount due at charge-off: $3,300.89 Total interest since charge-off: $0.00 Total non-interest charges since charge-off: $0.00 Total payments/credits since charge-off: $0.00 9. Plaintiff is the purchaser of this account where the original account number ended in ************1798 and is authorized to proceed with this action. The date on which the balance herein became due was February 14, 2022 and the Chain of Title, with the is as follows: date and amount of each sale or assignment of the account, March 19, 2022 $3,300.89 Synchrony Bank March 19, 2022 $3,300.89 Credit Corp Solutions Inc is/are liable to plaintiff as a result of defendant(s) breach of 10. Defendant(s) agreement. 2 of 4 FILED: SUFFOLK COUNTY CLERK 06/18/2024 10:58 AM INDEX NO. 614932/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/18/2024 FORA SECOND CAUSEOFACTION 11. That heretofore, plaintiff, or the assignor, rendered to defendant(s) monthly, just full, and true accounts of the indebtedness due and owing by defendant(s) as a result of the aforesaid transaction, which is the sum set forth above, and said statements were delivered without objection. to defendant(s) 12. Upon information and belief, on or about February 14, 2022 a final statement of account was mailed to the defendant(s). 13. Defendant(s) is/are liable for an account stated for the amount claimed above. WHEREFORE, plaintiff demands judgment against the defendant(s) for the sum of $3,300.89 together with costs and disbursements. February 22, 2024 & PHILLIPS, RSCHENBAUM P.C. Attorneys for Plaintiff 40 Daniel Street, Suite 7 RONALDFERRARO rm ngdale NY 11735-9000 (516) 746-1144 3 of 4 FILED: SUFFOLK COUNTY CLERK 06/18/2024 10:58 AM INDEX NO. 614932/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/18/2024 SUPREMECOURTOF THESTATEOF NEWYORK Index No. COUNTYOF SUFFOLK Our File No. CC18541 ____________________________________________Ç Credit Corp Solutions Inc Plaintiff, -against- Dayanara Rivadeneira Defendant(s), .._______________________-------____________Ç NOTICEOF COMMENCEMENT OFACTION SUBJECTTOMANDATORY ELECTRONICFILING PLEASETAKENOTICEthat above, which has been the matter captioned commenced by filing of the accompanying documents with the County Clerk via the NewYork State Courts Electronic Filing System ("NYSCEF"), is subject to mandatory electronic filing pursuant to Section 202.5-bb of the Uniform Rules for the Trial Courts. This notice is being served as required by Subdivision (b) (3) of that Section. Counsel and/or parties must either: 1) immediately record their representation within the e-filed matter on the Consent/Represent page in NYSCEF; or 2) file the Notice of Opt-Out form to claim one of the limited exemptions from mandatory e-filing (see below). Failure to record representation may result in an inability to receive electronic notice of any document filings. Claiming an exemption will require the exempt party to serve and be served with hard copy documents. Counsel and unrepresented parties who intend to participate must first create a in e-filing NYSCEFaccount and obtain a user ID and password. For additional information about electronic filing and to create a NYSCEF account, visit the NYSCEF website at www.nycourts.qov/efile or contact the NYSCEF Resource Center (phone: 646-386-3033; e-mail: efile@nycourts.qov; mailing address: 60 Centre Street, New York, New York 10007). Exemptions from mandatory e-filing (Section 202.5-bb(e)) are limited to: 1) 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; and 4 2) parties who expect to represent themselves and who choose not to p icipate in e-filing. (Such parties are encouraged to visit www vcoutthelp.cov or conta the Help Center in the court where the action is pending.) )t 4 RONALDFERRARO Date: February 22, 2024 KlRSCHENBAUM & PHILLIPS, P.C. Dayanara Rivadeneira 40 Daniel Street, Suite 7 1472 Sag Harbor Tpke Apartment 1 P.O. Box 9000 Sag Harbor NY 11963 Farmingdale, NY 11735 Telephone (516) 746-1144 efile@collectlaw.com 4 of 4