On December 30, 2019 a
Complaint,Petition
was filed
involving a dispute between
Portfolio Recovery Associates,Llc,
and
Christopher Priest,
for Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff
in the District Court of Livingston County.
Preview
FILED: LIVINGSTON COUNTY CLERK 12/30/2019 08:19 AM INDEX NO. 001131-2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/30/2019
Mary F. Strickland , County Clerk
Livingston County Government Center
6 Court Street, Room 201
fl A ÏÏ Geneseo, New York 14454
182' ~
(585) 243-7010 Fax (585) 243-7928
Livingston County Clerk Recording Page
Received From: Return To:
TARAH EVE JORDAN TARAH EVE JORDAN
Document Type: CIVIL ACTION - MISC Document Desc: SUMMONS + COMPLAINT
Plaintiff Defendant
PORTFOLIO RECOVERY ASSOCIATES,LLC PRIEST CHRISTOPHER
Recorded Information:
State of New York
Index #: 001131-2019
County of Livingston
EFiling through NYSCEF
Livingston County Clerk
This sheet constitutesthe Clerk's endemement equind by section 319 of the Real Property Law ofthe State ofNew York
AKB
Do Not
1 ofDetach
3
Index
INDEX #
NO.: 001131-2019
001131-2019
FILED: LIVINGSTON COUNTY CLERK 12/30/2019 08:19 AM
SUPREME
NYSCEF DOC. COURT
NO. 1 OF THE STATE OF NEW YORK INDEX # RECEIVED NYSCEF: V
12/30/2019 V
COUNTY OF LIVINGSTON SUMMONS
PORTFOLIO RECOVERY ASSOCIATES,LLC PLAINTIFF'S ADDRESS
PLAINTIFF, 120 CORPORATE BLVD
NORFOLK VA 23502
- AGAINST - X
DEFENDANT'S ADDRESSES 55
CHRISTOPHER PRIEST 157 WADSWORTH AVE
DEFENDANT(S). AVON NY 14414
CONSUMER CREDIT TRANSACTION ==
THE BASIS OF THE VENUE IS:
A DEFENDANT RESIDES IN THE COUNTY OF LIVINGSTON
THE TRANSACTION TOOK PLACE IN THE COUNTY OF LIVINGSTON
TO THE ABOVE NAMED DEFENDANT(S): CHRISTOPHER PRIEST
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 THE SERVICE IS COMPLETE IF THIS
SUMMONS IS NOT PERSONALLY DELIVERED TO YOU WITHIN THE STATE OF NEW YORK).
UPON YOUR FAILURE TO ANSWER, JUDGMENT WILL BE TAKEN AGAINST YOU FOR THE
RELIEF DEMANDED IN THE COMPLAINT, TOGETHER WITH THE DISBURSEMENTS OF
THIS ACTION.
DATED THE 12 DAY OF DECEMBER , 2019
FORSTER & GARBUS LLP
FILE NO. ATTORNEY(S) FOR PLAINTIFF
E311065206137 60 MOTOR PARKWAY
ORIG CRED: SYNCHRONY BANK COMMACK, NY 11725
ORIG ACCT# END IN: 6137 (631) 393-9400
NOTE: THE LAW PROVIDES THAT:
(A) IF THIS SUMMONS IS SERVED BY ITS DELIVERY TO YOU PERSONALLY WITHIN
THE COUNTY OF LIVINGSTON YOU MUST APPEAR AND ANSWER WITHIN 20 DAYS AFTER
SUCH SERVICE: OR
(B) IF THIS SUMMONS IS SERVED BY DELIVERY TO ANY PERSON OTHER THAN YOU
OR IS SERVED OUTSIDE THE COUNTY OF LIVINGSTON OR BY PUBLI-
PERSONALLY, ,
CATION, OR BY ANY MEANS OTHER THAN PERSONAL DELIVERY TO YOU WITHIN THE
COUNTY OF LIVINGSTON YOU ARE ALLOWED 30 DAYS AFTER SERVICE IS COMPLETE
WITHIN WHICH TO APPEAR AND ANSWER.
2 of 3
Index NO.
INDEX #: 001131-2019
001131-2019
FILED: LIVINGSTON COUNTY CLERK 12/30/2019 08:19 AM
SUPREME
NYSCEF DOC. COURT
NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 12/30/2019
COUNTY OF LIVINGSTON FORMAL COMPLAINT
________________________________________________
PORTFOLIO RECOVERY ASSOCIATES,LLC
PLAINTIFF,
- AGAINST -
CHRISTOPHER PRIEST
DEFENDANT(S).
________________________________________________
PLAINTIFF, BY ITS ATTORNEY(S), COMPLAINING OF THE DEFENDANT(S), UPON
INFORMATION AND BELIEF, ALLEGES:
1. THAT THE DEFENDANT(S) RESIDES IN THE COUNTY IN WHICH THIS ACTION IS
BROUGHT; OR THAT THE DEFENDANT(S) TRANSACTED BUSINESS WITHIN THE COUNTY
IN WHICH THIS ACTION IS BROUGHT IN PERSON OR THROUGH HIS AGENT AND THAT
THE INSTANT CAUSE OF ACTION AROSE OUT OF SAID TRANSACTION
2. ON INFORMATION AND BELIEF THE DEFENDANT IS INDEBTED TO THE PLAINTIFF FOR
GOODS AND SERVICES PURCHASED OR MONEY ADVANCES MADE ON AN OPEN ACCOUNT ON A
THEORY OF ACCOUNT STATED. PLAINTIFF'S ASSIGNOR RENDERED A STATEMENT TO THE
DEFENDANT WHICH WAS HELD WITHOUT OBJECTION BY DEFENDANT WITHIN A REASONABLE
TIME PERIOD. PLAINTIFF, AS PURCHASER OF THIS ACCOUNT, ORIGINALLY OWNED BY THE
BELOW CREDITOR, PURCHASED IT FOR VALUE; THE DEFENDANT WAS NOTIFIED OF SAME.
3. THERE REMAINS A BALANCE ON SAID ACCOUNT OF $ 1,022.57, DUE AND OWING ON
PLAINTIFF'S CAUSE OF ACTION. NO PART OF SAID SUM HAS BEEN PAID ALTHOUGH DULY
DEMANDED.
4. DEFENDANT(S) IS IN DEFAULT AND DEMAND FOR PAYMENT HAS BEEN MADE.
CHAIN OF TITLE:
PORTFOLIO RECOVERY ASSOCIATES,LLC who purchased this account from SYNCHRONY
BANK on 03/21/2018.
THERE IS NOW DUE PLAINTIFF FROM DEFENDANT(S) THE AMOUNT SET FORTH IN
THE COMPLAINT, NO PART OF WHICH HAS BEEN PAID, ALTHOUGH DULY DEMANDED.
WHEREFORE, PLAINTIFF DEMANDS JUDGMENT AGAINST DEFENDANT(S) FOR THE SUM OF
1,022.57
TOGETHER WITH THE DISBURSEMENTS OF THIS ACTION
WE ARE DEBT COLLECTORS; ANY FORSTER & GARBUS LLP
INFORMATION OBTAINED WILL BE USED ATTORNEY(S) FOR PLAINTIFF
IN ATTEMPTING TO COLLECT THIS DEBT. 60 MOTOR PARKWAY
COMMACK, NY 11725
DATED: THE 12 DAY OF DECEMBER , 2019 .
TESSE.GUNTHERTARAHJORDANJOSEPHMATZA
PURSUANT TO PART 130-1.1-aOF THE RULES OF THE
CHIEFADMINISTRATOR THIS SIGNATUREAPPLIES
TO THEATTACHEDSUMMONSAND COMPLAINT
E311065206137 3 of 3
Document Filed Date
December 30, 2019
Case Filing Date
December 30, 2019
Category
Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff
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FILED: LIVINGSTON COUNTY CLERK 12/30/2019 08:19 AM INDEX NO. 001131-2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/30/2019 Mary F. Strickland , County Clerk Livingston County Government Center 6 Court Street, Room 201 fl A ÏÏ Geneseo, New York 14454 182' ~ (585) 243-7010 Fax (585) 243-7928 Livingston County Clerk Recording Page Received From: Return To: TARAH EVE JORDAN TARAH EVE JORDAN Document Type: CIVIL ACTION - MISC Document Desc: SUMMONS + COMPLAINT Plaintiff Defendant PORTFOLIO RECOVERY ASSOCIATES,LLC PRIEST CHRISTOPHER Recorded Information: State of New York Index #: 001131-2019 County of Livingston EFiling through NYSCEF Livingston County Clerk This sheet constitutesthe Clerk's endemement equind by section 319 of the Real Property Law ofthe State ofNew York AKB Do Not 1 ofDetach 3 Index INDEX # NO.: 001131-2019 001131-2019 FILED: LIVINGSTON COUNTY CLERK 12/30/2019 08:19 AM SUPREME NYSCEF DOC. COURT NO. 1 OF THE STATE OF NEW YORK INDEX # RECEIVED NYSCEF: V 12/30/2019 V COUNTY OF LIVINGSTON SUMMONS PORTFOLIO RECOVERY ASSOCIATES,LLC PLAINTIFF'S ADDRESS PLAINTIFF, 120 CORPORATE BLVD NORFOLK VA 23502 - AGAINST - X DEFENDANT'S ADDRESSES 55 CHRISTOPHER PRIEST 157 WADSWORTH AVE DEFENDANT(S). AVON NY 14414 CONSUMER CREDIT TRANSACTION == THE BASIS OF THE VENUE IS: A DEFENDANT RESIDES IN THE COUNTY OF LIVINGSTON THE TRANSACTION TOOK PLACE IN THE COUNTY OF LIVINGSTON TO THE ABOVE NAMED DEFENDANT(S): CHRISTOPHER PRIEST 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 THE SERVICE IS COMPLETE IF THIS SUMMONS IS NOT PERSONALLY DELIVERED TO YOU WITHIN THE STATE OF NEW YORK). UPON YOUR FAILURE TO ANSWER, JUDGMENT WILL BE TAKEN AGAINST YOU FOR THE RELIEF DEMANDED IN THE COMPLAINT, TOGETHER WITH THE DISBURSEMENTS OF THIS ACTION. DATED THE 12 DAY OF DECEMBER , 2019 FORSTER & GARBUS LLP FILE NO. ATTORNEY(S) FOR PLAINTIFF E311065206137 60 MOTOR PARKWAY ORIG CRED: SYNCHRONY BANK COMMACK, NY 11725 ORIG ACCT# END IN: 6137 (631) 393-9400 NOTE: THE LAW PROVIDES THAT: (A) IF THIS SUMMONS IS SERVED BY ITS DELIVERY TO YOU PERSONALLY WITHIN THE COUNTY OF LIVINGSTON YOU MUST APPEAR AND ANSWER WITHIN 20 DAYS AFTER SUCH SERVICE: OR (B) IF THIS SUMMONS IS SERVED BY DELIVERY TO ANY PERSON OTHER THAN YOU OR IS SERVED OUTSIDE THE COUNTY OF LIVINGSTON OR BY PUBLI- PERSONALLY, , CATION, OR BY ANY MEANS OTHER THAN PERSONAL DELIVERY TO YOU WITHIN THE COUNTY OF LIVINGSTON YOU ARE ALLOWED 30 DAYS AFTER SERVICE IS COMPLETE WITHIN WHICH TO APPEAR AND ANSWER. 2 of 3 Index NO. INDEX #: 001131-2019 001131-2019 FILED: LIVINGSTON COUNTY CLERK 12/30/2019 08:19 AM SUPREME NYSCEF DOC. COURT NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 12/30/2019 COUNTY OF LIVINGSTON FORMAL COMPLAINT ________________________________________________ PORTFOLIO RECOVERY ASSOCIATES,LLC PLAINTIFF, - AGAINST - CHRISTOPHER PRIEST DEFENDANT(S). ________________________________________________ PLAINTIFF, BY ITS ATTORNEY(S), COMPLAINING OF THE DEFENDANT(S), UPON INFORMATION AND BELIEF, ALLEGES: 1. THAT THE DEFENDANT(S) RESIDES IN THE COUNTY IN WHICH THIS ACTION IS BROUGHT; OR THAT THE DEFENDANT(S) TRANSACTED BUSINESS WITHIN THE COUNTY IN WHICH THIS ACTION IS BROUGHT IN PERSON OR THROUGH HIS AGENT AND THAT THE INSTANT CAUSE OF ACTION AROSE OUT OF SAID TRANSACTION 2. ON INFORMATION AND BELIEF THE DEFENDANT IS INDEBTED TO THE PLAINTIFF FOR GOODS AND SERVICES PURCHASED OR MONEY ADVANCES MADE ON AN OPEN ACCOUNT ON A THEORY OF ACCOUNT STATED. PLAINTIFF'S ASSIGNOR RENDERED A STATEMENT TO THE DEFENDANT WHICH WAS HELD WITHOUT OBJECTION BY DEFENDANT WITHIN A REASONABLE TIME PERIOD. PLAINTIFF, AS PURCHASER OF THIS ACCOUNT, ORIGINALLY OWNED BY THE BELOW CREDITOR, PURCHASED IT FOR VALUE; THE DEFENDANT WAS NOTIFIED OF SAME. 3. THERE REMAINS A BALANCE ON SAID ACCOUNT OF $ 1,022.57, DUE AND OWING ON PLAINTIFF'S CAUSE OF ACTION. NO PART OF SAID SUM HAS BEEN PAID ALTHOUGH DULY DEMANDED. 4. DEFENDANT(S) IS IN DEFAULT AND DEMAND FOR PAYMENT HAS BEEN MADE. CHAIN OF TITLE: PORTFOLIO RECOVERY ASSOCIATES,LLC who purchased this account from SYNCHRONY BANK on 03/21/2018. THERE IS NOW DUE PLAINTIFF FROM DEFENDANT(S) THE AMOUNT SET FORTH IN THE COMPLAINT, NO PART OF WHICH HAS BEEN PAID, ALTHOUGH DULY DEMANDED. WHEREFORE, PLAINTIFF DEMANDS JUDGMENT AGAINST DEFENDANT(S) FOR THE SUM OF 1,022.57 TOGETHER WITH THE DISBURSEMENTS OF THIS ACTION WE ARE DEBT COLLECTORS; ANY FORSTER & GARBUS LLP INFORMATION OBTAINED WILL BE USED ATTORNEY(S) FOR PLAINTIFF IN ATTEMPTING TO COLLECT THIS DEBT. 60 MOTOR PARKWAY COMMACK, NY 11725 DATED: THE 12 DAY OF DECEMBER , 2019 . TESSE.GUNTHERTARAHJORDANJOSEPHMATZA PURSUANT TO PART 130-1.1-aOF THE RULES OF THE CHIEFADMINISTRATOR THIS SIGNATUREAPPLIES TO THEATTACHEDSUMMONSAND COMPLAINT E311065206137 3 of 3