Preview
FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM INDEX NO. 001056-2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019
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:
STEPHEN EINSTEIN STEPHEN EINSTEIN
39 BROADWAY SUITE 1250 39 BROADWAY SUITE 1250
NEW YORK, NY 10006 NEW YORK, NY 10006
Document Type: CIVIL ACTION - MISC Document Desc: SUMMONS + COMPLAINT
Plaintiff Defendant
CROWN ASSET MANAGEMENT LLC Pugh Evelyn
Recorded Information:
State of New York
Index #: 001056-2019
County of Livingston
EFiling through NYSCEF
Livingston County Clerk
This sheet conMM&es the Clerk's endomement equind by section 319 of the Real Property Law ofthe State ofNew York
AKB
Do Not
1 ofDetach
7
Index
INDEX #
NO.: 001056-2019
001056-2019
FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019
Date Purchased:
SUPREME COURT OF THE STATE OF NEW YORK Index N9
COUNTY OF LIVINGSTON X
Crown Asset Management, LLC SUMMONS
Plaintiff, Plaintiff's Address:
-against- 3100 Breckenridge Blvd. Suite 725
Duluth GA 30096
Evelyn Pugh
Defendant(s). The basis of Venue is
CPLR Sec. 503(f)
Defendant resides in
County of: LIVINGSTON
X Consumer Credit Transaction
Defendant(s) Address:
DEF.#1 - 3261 Ellen Caledonia NY 14423
Place,
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: October 30, 2019
Matter No. 344447.001
s O Stephanie R. Vetch
Aksana Bondartseva O Rafeena Khairullah
O Joseph J. Cassotta O Monique Aziza
O Anthony Poulin O Stephen Einstein
O Scott Morris O Alex Pesochin
Stephen Einstein & Associates, P.C.
Attorneys for the Plaintiff
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
*PDB*
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FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM INDEXIndexNO.
#: 001056-2019
001056-2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF LIVINGSTON
Crown Asset Management, LLC
Plaintiff,
VERIFIED COMPLAINT
-against-
Evelyn Pugh
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, Defendant(s) is/are resident(s) of the State of New York,
County of LIVINGSTON. Upon information and belief following Consumer Credit Transaction
occurred in County of LIVINGSTON.
AS AND FOR A FIRST CAUSE OF ACTION
3. The Defendãñt(s) hereto entered into a Credit Agreement with Plaintiff's predecessor
in interest, Comenity Bank, bearing account #XXXXXXXXXXXX7509 who charged off the
debt on 01/31/2019.
4. Upon information and belief, Plaintiff's predecessor in interest duly performed all
conditions on its part under the agreement.
5. The Plaintiff thereafter took by assignment all the rights, titleand interest to receive
the monies due pursuant to and in accordance with the said agreement and is the legal
assignee of the original creditor.
6. Upon information and belief, Plaintiff advised Defendant, in writing, of said balance
due and demanding payment. No payment has been forthcoming.
3 of 7
FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM INDEXIndex NO.
#: 001056-2019
001056-2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019
7. Defendant(s) defaulted in payment and pursuant to the terms of the agreement now
owe a balance of $2,519.34 as of 1/31/2019, no part of which has been paid despite due
demand therefore.
AS AND FOR A SECOND CAUSE OF ACTION
8. That heretofore, upon information and belief, Plaintiff's predecessor in interest
rendered to Defendant(s) monthly, full and truth accounts of the indebtedness owing by the
Defendant(s) as a result of the above Agreement, in an amount as hereinabove set forth,
which account statements were delivered to and accepted without objection by the
Defendant(s) resulting in an account stated in the sum of $2,519.34 as of 1/31/2019, no part
of which has been paid despite due demand therefore.
WHEREFORE, Plaintiff demands judgment against Defendant(s) in the sum of
$2,519.34 plus costs and disbursements.
VERIFICATION: The undersigned, affirms under penalties of perjury, that he is a member of
the firm appearing as attorney of record for the plaintiff, has read this complaint and knows its
contents, and that the same is alleged upon information and belief and believes itto be true.
Affirmant says that the grounds of his belief are documents received from the Plaintiff and/or
pre-suit investigation. This verification is made by affirmant because plaintiff's place of business
is !ocated outside the county where affirmant maintains his law practice. Affirmed this 30th day
of October, 2019.
D djdikefollis D Stephanie R. Vetch
Aksana Bondartseva D Rafeena Khairullah
D Joseph J. Cassotta D Monique Aziza
D Anthony Poulin D Stephen Einstein
D Scott Morris D Alex Pesochin
Matter No 344447.001
4 of 7
Index NO.
INDEX #: 001056-2019
001056-2019
FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019
Index No. Year
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF LIVINGSTON
Crown Asset Management, LLC
Plaintiff
-against-
Evelyn Pugh
Defendant(s)
SUMMONS AND RIFIED COMPLAINT
Si (Rule 130-1. 1-a)
Evridi e Kollis U Stephanie R. Vetch
Aksana artseva Rafeena Khairullah
Joseph J. Cassotta Monique Aziza
Anthony Poulin Stephen Einstein
Scott Morris Alex Pesochin
LAW OFFICE OF
STEPHEN EINSTEIN & ASSOCIATES, P.C.
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 of the within __ is hereby admitted.
copy
Dated,
Attorney(s) for Plaintiff(s)
Sir: Please take notice
O NOTICE OF ENTRY:
That within is a true of a duly entered in the office of the clerk of
(certified) copy
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 2019 at ___ A.M
Dated,
5 of 7
Index NO.
INDEX #: 001056-2019
001056-2019
FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF LIVINGSTON _ X
Crown Asset Management, LLC
Plaintiff/Petitioner,
-against-
INDEX N9:
Evelyn Pugh
Defendant/Respondent.
X
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 itcharge 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
with all employees subject to their the operational knowledge to with e-
(along direction) comply
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 coñtii1ue to e-file their court documents in
the case.
6 of 7
Index NO.
INDEX #: 001056-2019
001056-2019
FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019
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: October 30, 2019
ridikeKo Stephanie R. Vetch
A na Bondartseva Rafeena Khairullah
Joseph J. Cassotta Monique Aziza
(212) 267-3550
Stephen Einstein & Associates, P.C.
www.stepheneinstein.com
S.E acc. #344447.001
TO: Evelyn Pugh
3261 Ellen Place
Caledonia NY 14423
7 of 7
Preview
FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM INDEX NO. 001056-2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019 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: STEPHEN EINSTEIN STEPHEN EINSTEIN 39 BROADWAY SUITE 1250 39 BROADWAY SUITE 1250 NEW YORK, NY 10006 NEW YORK, NY 10006 Document Type: CIVIL ACTION - MISC Document Desc: SUMMONS + COMPLAINT Plaintiff Defendant CROWN ASSET MANAGEMENT LLC Pugh Evelyn Recorded Information: State of New York Index #: 001056-2019 County of Livingston EFiling through NYSCEF Livingston County Clerk This sheet conMM&es the Clerk's endomement equind by section 319 of the Real Property Law ofthe State ofNew York AKB Do Not 1 ofDetach 7 Index INDEX # NO.: 001056-2019 001056-2019 FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019 Date Purchased: SUPREME COURT OF THE STATE OF NEW YORK Index N9 COUNTY OF LIVINGSTON X Crown Asset Management, LLC SUMMONS Plaintiff, Plaintiff's Address: -against- 3100 Breckenridge Blvd. Suite 725 Duluth GA 30096 Evelyn Pugh Defendant(s). The basis of Venue is CPLR Sec. 503(f) Defendant resides in County of: LIVINGSTON X Consumer Credit Transaction Defendant(s) Address: DEF.#1 - 3261 Ellen Caledonia NY 14423 Place, 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: October 30, 2019 Matter No. 344447.001 s O Stephanie R. Vetch Aksana Bondartseva O Rafeena Khairullah O Joseph J. Cassotta O Monique Aziza O Anthony Poulin O Stephen Einstein O Scott Morris O Alex Pesochin Stephen Einstein & Associates, P.C. Attorneys for the Plaintiff 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 *PDB* 2 of 7 FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM INDEXIndexNO. #: 001056-2019 001056-2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF LIVINGSTON Crown Asset Management, LLC Plaintiff, VERIFIED COMPLAINT -against- Evelyn Pugh 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, Defendant(s) is/are resident(s) of the State of New York, County of LIVINGSTON. Upon information and belief following Consumer Credit Transaction occurred in County of LIVINGSTON. AS AND FOR A FIRST CAUSE OF ACTION 3. The Defendãñt(s) hereto entered into a Credit Agreement with Plaintiff's predecessor in interest, Comenity Bank, bearing account #XXXXXXXXXXXX7509 who charged off the debt on 01/31/2019. 4. Upon information and belief, Plaintiff's predecessor in interest duly performed all conditions on its part under the agreement. 5. The Plaintiff thereafter took by assignment all the rights, titleand interest to receive the monies due pursuant to and in accordance with the said agreement and is the legal assignee of the original creditor. 6. Upon information and belief, Plaintiff advised Defendant, in writing, of said balance due and demanding payment. No payment has been forthcoming. 3 of 7 FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM INDEXIndex NO. #: 001056-2019 001056-2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019 7. Defendant(s) defaulted in payment and pursuant to the terms of the agreement now owe a balance of $2,519.34 as of 1/31/2019, no part of which has been paid despite due demand therefore. AS AND FOR A SECOND CAUSE OF ACTION 8. That heretofore, upon information and belief, Plaintiff's predecessor in interest rendered to Defendant(s) monthly, full and truth accounts of the indebtedness owing by the Defendant(s) as a result of the above Agreement, in an amount as hereinabove set forth, which account statements were delivered to and accepted without objection by the Defendant(s) resulting in an account stated in the sum of $2,519.34 as of 1/31/2019, no part of which has been paid despite due demand therefore. WHEREFORE, Plaintiff demands judgment against Defendant(s) in the sum of $2,519.34 plus costs and disbursements. VERIFICATION: The undersigned, affirms under penalties of perjury, that he is a member of the firm appearing as attorney of record for the plaintiff, has read this complaint and knows its contents, and that the same is alleged upon information and belief and believes itto be true. Affirmant says that the grounds of his belief are documents received from the Plaintiff and/or pre-suit investigation. This verification is made by affirmant because plaintiff's place of business is !ocated outside the county where affirmant maintains his law practice. Affirmed this 30th day of October, 2019. D djdikefollis D Stephanie R. Vetch Aksana Bondartseva D Rafeena Khairullah D Joseph J. Cassotta D Monique Aziza D Anthony Poulin D Stephen Einstein D Scott Morris D Alex Pesochin Matter No 344447.001 4 of 7 Index NO. INDEX #: 001056-2019 001056-2019 FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019 Index No. Year SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF LIVINGSTON Crown Asset Management, LLC Plaintiff -against- Evelyn Pugh Defendant(s) SUMMONS AND RIFIED COMPLAINT Si (Rule 130-1. 1-a) Evridi e Kollis U Stephanie R. Vetch Aksana artseva Rafeena Khairullah Joseph J. Cassotta Monique Aziza Anthony Poulin Stephen Einstein Scott Morris Alex Pesochin LAW OFFICE OF STEPHEN EINSTEIN & ASSOCIATES, P.C. 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 of the within __ is hereby admitted. copy Dated, Attorney(s) for Plaintiff(s) Sir: Please take notice O NOTICE OF ENTRY: That within is a true of a duly entered in the office of the clerk of (certified) copy 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 2019 at ___ A.M Dated, 5 of 7 Index NO. INDEX #: 001056-2019 001056-2019 FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF LIVINGSTON _ X Crown Asset Management, LLC Plaintiff/Petitioner, -against- INDEX N9: Evelyn Pugh Defendant/Respondent. X 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 itcharge 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 with all employees subject to their the operational knowledge to with e- (along direction) comply 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 coñtii1ue to e-file their court documents in the case. 6 of 7 Index NO. INDEX #: 001056-2019 001056-2019 FILED: LIVINGSTON COUNTY CLERK 12/02/2019 05:38 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/02/2019 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: October 30, 2019 ridikeKo Stephanie R. Vetch A na Bondartseva Rafeena Khairullah Joseph J. Cassotta Monique Aziza (212) 267-3550 Stephen Einstein & Associates, P.C. www.stepheneinstein.com S.E acc. #344447.001 TO: Evelyn Pugh 3261 Ellen Place Caledonia NY 14423 7 of 7