On December 11, 2019 a
Complaint,Petition
was filed
involving a dispute between
Discover Bank,
and
Matthew Kim,
for Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
in the District Court of Clinton County.
Preview
FILED: CLINTON COUNTY CLERK 12/11/2019 03:06 PM INDEX NO. 2019-00020028
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2019
CONSUMER CREDIT TRANSACTION
SUPREME COURT
COUNTY OF CLINTON STATE OF NEW YORK
DISCOVER BANK, Index No.___________
Plaintiff
- VS.- SUMMONS
MATTHEW KIM, The basis of the venue designated is
Defendant’s residence.
47 DICKSON POINT RD
PLAEI’SBURGH, NY 12901 Plaintiff’s address:
Defendant(s) do Discover Products Inc.
6500 New Albany Road
New Albany, OH 43054
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 attorneys for plaintiff within 20 days after the service of the
Summons, exclusive of the days of service (or within 30 days afier the service is complete if this
summons is not personally delivered to you within the State of New York); and in case of your
failure to appear or answer, judgment will be taken against you by default for the relief
demanded herein. The basis of venue is the Defendant(s) residence.
DATED:&O9 tcfffl\trrc
RVERHAGE?ESQ.
[JflIbREANA SARKIS, ESQ.
[4STEPHANIE MARIE WALLACE, ESQ.
LARRY T. POWELL, ESQ.
ELIZABETH DEERY, ESQ.
[]GAETANO MONTALBANO, ESQ.
ZWICKER & ASSOCIATES, P.C.
A Law Firm Engaged in Debt Collection
100 CORPORATE WOODS, SUITE 230
ROCHESTER, NY 14623
(585)427-0482
1 of 2
FILED: CLINTON COUNTY CLERK 12/11/2019 03:06 PM INDEX NO. 2019-00020028
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2019
SUPREME COURT
COUNTY OF CLINTON STATE OF NEW YORK
DISCOVER BANK, Index No.________
Plaintiff,
VS. COMPLAINT
MATTHEW KIM,
Defendant(s).
PLAINTIFF, by and through its attorneys, Zwicker & Associates PC., complaining of
Defendant(s), respectthlly alleges upon information and belief.
1. Plaintiff is a FDIC-insured Delaware State Bank.
2. That upon information and belief the Defendant(s) is/are a resident of the county where this
action is brought.
3. That the Defendant(s) entered into a credit agreement (“Agreement”) with the Plaintiff
consisting of account ending in 9892.
4. That the Defendant(s) breached the terms of the aforementioned Agreement.
5. That there is now due and owing to the Plaintiff from the Defendant(s) as a result of the
aforementioned breach of the Agreement by the Defendant(s), the sum of 55,228.9!.
WHEREFORE the Plaintiff, DISCOVER BANK, demands judgment against the
Defendant(s). MATTHEW KIM, for the sum of 55,228.91, post-judgment interest, the costs and
disbursements of this action, and for such other and ffirther relief as the Court deems just and proper.
DATED: a- t -r( icoioqj 1____
{ ]JASO .VERHAGE ,ESQ
[] REANA SARKIS. ESQ.
STEPHANIE MARIE WALLACE, ESQ.
LARRY T. POWELL, ESQ.
ELIZABETH DEERY, ESQ.
[1 GAETANO MONTALBANO, ESQ.
ZWICKER & ASSOCIATES, P.C.
A Law Firm Engaged in Debt Collection
100 CORPORATE WOODS. SUITE 230
ROCHESTER, NY 14623
(585)427-0482
2 of 2
Document Filed Date
December 11, 2019
Case Filing Date
December 11, 2019
Category
Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
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FILED: CLINTON COUNTY CLERK 12/11/2019 03:06 PM INDEX NO. 2019-00020028 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2019 CONSUMER CREDIT TRANSACTION SUPREME COURT COUNTY OF CLINTON STATE OF NEW YORK DISCOVER BANK, Index No.___________ Plaintiff - VS.- SUMMONS MATTHEW KIM, The basis of the venue designated is Defendant’s residence. 47 DICKSON POINT RD PLAEI’SBURGH, NY 12901 Plaintiff’s address: Defendant(s) do Discover Products Inc. 6500 New Albany Road New Albany, OH 43054 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 attorneys for plaintiff within 20 days after the service of the Summons, exclusive of the days of service (or within 30 days afier the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded herein. The basis of venue is the Defendant(s) residence. DATED:&O9 tcfffl\trrc RVERHAGE?ESQ. [JflIbREANA SARKIS, ESQ. [4STEPHANIE MARIE WALLACE, ESQ. LARRY T. POWELL, ESQ. ELIZABETH DEERY, ESQ. []GAETANO MONTALBANO, ESQ. ZWICKER & ASSOCIATES, P.C. A Law Firm Engaged in Debt Collection 100 CORPORATE WOODS, SUITE 230 ROCHESTER, NY 14623 (585)427-0482 1 of 2 FILED: CLINTON COUNTY CLERK 12/11/2019 03:06 PM INDEX NO. 2019-00020028 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2019 SUPREME COURT COUNTY OF CLINTON STATE OF NEW YORK DISCOVER BANK, Index No.________ Plaintiff, VS. COMPLAINT MATTHEW KIM, Defendant(s). PLAINTIFF, by and through its attorneys, Zwicker & Associates PC., complaining of Defendant(s), respectthlly alleges upon information and belief. 1. Plaintiff is a FDIC-insured Delaware State Bank. 2. That upon information and belief the Defendant(s) is/are a resident of the county where this action is brought. 3. That the Defendant(s) entered into a credit agreement (“Agreement”) with the Plaintiff consisting of account ending in 9892. 4. That the Defendant(s) breached the terms of the aforementioned Agreement. 5. That there is now due and owing to the Plaintiff from the Defendant(s) as a result of the aforementioned breach of the Agreement by the Defendant(s), the sum of 55,228.9!. WHEREFORE the Plaintiff, DISCOVER BANK, demands judgment against the Defendant(s). MATTHEW KIM, for the sum of 55,228.91, post-judgment interest, the costs and disbursements of this action, and for such other and ffirther relief as the Court deems just and proper. DATED: a- t -r( icoioqj 1____ { ]JASO .VERHAGE ,ESQ [] REANA SARKIS. ESQ. STEPHANIE MARIE WALLACE, ESQ. LARRY T. POWELL, ESQ. ELIZABETH DEERY, ESQ. [1 GAETANO MONTALBANO, ESQ. ZWICKER & ASSOCIATES, P.C. A Law Firm Engaged in Debt Collection 100 CORPORATE WOODS. SUITE 230 ROCHESTER, NY 14623 (585)427-0482 2 of 2