On October 20, 2020 a
Complaint,Petition
was filed
involving a dispute between
Ford Motor Credit Company Llc,
Ford Motor Credit Company L L C,
and
Kim R Hinds,
Krisanne B Hinds,
for Other Matters - Consumer Credit (Non-Card) Transaction
in the District Court of Essex County.
Preview
FILED: ESSEX COUNTY CLERK 10/20/2020 10:48 AM INDEX NO. CV20-0418
NYSCEF SUPREME COURT
DOC. NO. 1 OF THE STATE OF NEW YORK Index No. RECEIVED NYSCEF: 10/20/2020
COUNTY OF ESSEX Date Filed:
________________________________________
FORD MOTOR CREDIT COMPANY LLC
SUMMONS (ORIGINAL)
Plaintiff
-against-
KIM R HINDS The basis of venue is:
KRISANNE B HINDS
DEFENDANT'S RESIDENCE
Defendant(s) Plaintiff's Residence:
---------------------------------------- 1 AMERICAN RD #904
DEARBORN, MI 48126
CONSUMER CREDIT TRANSACTION County of WAYNE
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, or, if the complaint is not served with this summons
to serve a notice of appearance, on the Plaintiff's Attorney(s) within
TWENTY days after the service of this summañs, exclusive of the day of
service (or within THIRTY days after 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, judgmeñt will be taken
against you by default for the relief demanded herein.
Dated: Islandia, New York
OCTOBER 19, 2020 RUBIN & ROTHMAN, LLC
Attorneys for Plaintiff
1787 Veterans Highway
Islandia, N.Y. 11749
(631) 234-1500
DEFENDANT(S) ADDRESS:
KIM R HINDS
341 MIDDLE RD CROWN POINT, NY 12928-2207
KRISANNE B HINDS
420 RUSSELL ST CROWN POINT, NY 12928-2516
WE ARE ATTEMPTING TO COLLECT A DEBT. ANY ImrummATION OBP A TNED WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
NYC DCA LIC. 2045512
Our File No. 1362220 Y 10 0- 0 V SLJ 000
000005915319
1 of 3
FILED: ESSEX COUNTY CLERK 10/20/2020 10:48 AM INDEX NO. CV20-0418
NYSCEF SUPREME COURT
DOC. NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 10/20/2020
COUNTY OF ESSEX Index No.
________________________________________
FORD MOTOR CREDIT COMPANY LLC
Plaintiff
-against- COMPLAINT (ORIGINAL)
KIM R HINDS
KRISANNE B HINDS
Defendant(s)
________________________________________
Plaintiff, by its attorneys, complaining of the defendant(s), alleges:
1. Defendant(s) resides in the county in which this action is brought;
or transacted business in the county in which this action is brought
in person or through an agent, or this cause of action arose out of
said transaction. Plaintiff is not required to be licensed by the
NYC Dept of Consumer Affairs because its principal business is not the
collection of debts due to another nor is it a buyer of delinquent debt.
2. Plaintiff is a foreign corporation licensed to do business
in New York State.
3. Defendant(s) entered into an automobile lease with
EGGLEFIELD BROS, INC.
in which defendant(s) agreed to pay monthly rental payments to the
dealership. The lease was subsequently assigned by the dealer to
CAB EAST LLC
(the "Titling Company") and given Acet No. ****************8565.
The account was not in default at the time of the assignment. Plaintiff
entered into a servicing agreement with the Titling Company that assigns
the anonunt to plaintiff solely for the purpose of fulfilling the
servicer's duties under the agreement, including the commencement of
legal proceedings to enforce the account.
4. Defendant(s) later defaulted on the terms of the lease, with the
result that defendant(s) owe plaintiff $ 3,077.45.
WHEREFORE, plaintiff requests judgment against defendant(s) for the sum of
$ 3,077.45 and the costs and disbursements of this action.
RUBIN & ROTHMAN, LLC
OCTOBER 19, 2020 Attorneys for Plaintiff
1787 Veterans Highway
Islandia, NY 11749
(631) 234-1500
DepGñGnt is an attorney associated with Rubin & Rothman, LLC. To the best
of deponent's knowledge, information and belief, formed after an inquiry
reasonable under the circumstances, the summons and complaint or the
contentions therein are not frivolous as defined in section 130-1.1(c)
of the Rules of the Chief Adm. and the matter was not obtained through
illegal conduct or in violation of 22 NYCRR 1200, Rule 4.5.
Dated: OCTOBER 19, 2020
CHRISTOPHER J.AHERN
WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBPATNED WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
NYC DCA LIC. 2045512
Our File No. 1362220 X 11 0- 0 V SLJ 000
000005915319
2 of 3
FILED: ESSEX COUNTY CLERK 10/20/2020 10:48 AM INDEX NO. CV20-0418
NYSCEF SUPREME COURT
DOC. NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 10/20/2020
COUNTY OF ESSEX
________________________________________
FORD MOTOR CREDIT COMPANY LLC
Plaintiff
-against- Index No.
KIM R HINDS
KRISANNE B HINDS
Defendant(s)
________________________________________
NOTICE OF COMMENCEMENT OF ACTION
SUBJECT TO MANDATORY ELECTRONIC FILING
PLEASE TAKE NOTICE that the matter captioned above, which has been
commenced by filing of the accompanying documents with the County Clerk, 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.
The New York State Courts Electronic Filing System ("NYSCEF") is
designed for the electronic filing of documents with the County Clerk and
the court and for the electronic service of those court docu-
documents,
ments, and court notices upon counsel and self-represented parties. Counsel
and/or parties who do not notify the court of a claimed exemption (see
below) as required by Section 202.5-bb(e) must immediately record their
representation within the e-filed matter on the Consent page in NYSCEF.
Failure to do so may result in an inability to receive electronic notice of
document filings.
Exemptions from mandatory e-filing are limited to: 1)attorneys who
certify in good faith that they lack the computer equipment and (along with
all employees) the requisite knowledge to comply; and 2) self-represented
parties who choose not to participate in e-filing. For additional informa-
tion about electronic filing, including access to Section 202.5-bb, consult
the YSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource
Center at 646-386-3033 or efile@courts.state.ny.us.
Dated: Islandia, New York
OCTOBER 19, 2020
RUBIN & ROTHMAN, LLC
CHRIST PHER J.AHERN 1787 VETERANS HIGHWÃY
RUBIN & ROTHMAN, LLC ISLANDIA, NY 11749
(631) 234-1500
NYDOCS@RUBINROTHMAN.COM
To: KIM R HINDS
341 MIDDLE RD
CROWN POINT, NY 12928-2207
To: KRISANNE B HINDS
420 RUSSELL ST
CROWN POINT, NY 12928-2516
WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBPATNED WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
NYC DCA LIC. 2045512
Our File No. 1362220 X 12 0- 0 V SLJ 000
000005915319
3 of 3
Document Filed Date
October 20, 2020
Case Filing Date
October 20, 2020
Category
Other Matters - Consumer Credit (Non-Card) Transaction
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: ESSEX COUNTY CLERK 10/20/2020 10:48 AM INDEX NO. CV20-0418 NYSCEF SUPREME COURT DOC. NO. 1 OF THE STATE OF NEW YORK Index No. RECEIVED NYSCEF: 10/20/2020 COUNTY OF ESSEX Date Filed: ________________________________________ FORD MOTOR CREDIT COMPANY LLC SUMMONS (ORIGINAL) Plaintiff -against- KIM R HINDS The basis of venue is: KRISANNE B HINDS DEFENDANT'S RESIDENCE Defendant(s) Plaintiff's Residence: ---------------------------------------- 1 AMERICAN RD #904 DEARBORN, MI 48126 CONSUMER CREDIT TRANSACTION County of WAYNE 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, or, if the complaint is not served with this summons to serve a notice of appearance, on the Plaintiff's Attorney(s) within TWENTY days after the service of this summañs, exclusive of the day of service (or within THIRTY days after 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, judgmeñt will be taken against you by default for the relief demanded herein. Dated: Islandia, New York OCTOBER 19, 2020 RUBIN & ROTHMAN, LLC Attorneys for Plaintiff 1787 Veterans Highway Islandia, N.Y. 11749 (631) 234-1500 DEFENDANT(S) ADDRESS: KIM R HINDS 341 MIDDLE RD CROWN POINT, NY 12928-2207 KRISANNE B HINDS 420 RUSSELL ST CROWN POINT, NY 12928-2516 WE ARE ATTEMPTING TO COLLECT A DEBT. ANY ImrummATION OBP A TNED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. NYC DCA LIC. 2045512 Our File No. 1362220 Y 10 0- 0 V SLJ 000 000005915319 1 of 3 FILED: ESSEX COUNTY CLERK 10/20/2020 10:48 AM INDEX NO. CV20-0418 NYSCEF SUPREME COURT DOC. NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 10/20/2020 COUNTY OF ESSEX Index No. ________________________________________ FORD MOTOR CREDIT COMPANY LLC Plaintiff -against- COMPLAINT (ORIGINAL) KIM R HINDS KRISANNE B HINDS Defendant(s) ________________________________________ Plaintiff, by its attorneys, complaining of the defendant(s), alleges: 1. Defendant(s) resides in the county in which this action is brought; or transacted business in the county in which this action is brought in person or through an agent, or this cause of action arose out of said transaction. Plaintiff is not required to be licensed by the NYC Dept of Consumer Affairs because its principal business is not the collection of debts due to another nor is it a buyer of delinquent debt. 2. Plaintiff is a foreign corporation licensed to do business in New York State. 3. Defendant(s) entered into an automobile lease with EGGLEFIELD BROS, INC. in which defendant(s) agreed to pay monthly rental payments to the dealership. The lease was subsequently assigned by the dealer to CAB EAST LLC (the "Titling Company") and given Acet No. ****************8565. The account was not in default at the time of the assignment. Plaintiff entered into a servicing agreement with the Titling Company that assigns the anonunt to plaintiff solely for the purpose of fulfilling the servicer's duties under the agreement, including the commencement of legal proceedings to enforce the account. 4. Defendant(s) later defaulted on the terms of the lease, with the result that defendant(s) owe plaintiff $ 3,077.45. WHEREFORE, plaintiff requests judgment against defendant(s) for the sum of $ 3,077.45 and the costs and disbursements of this action. RUBIN & ROTHMAN, LLC OCTOBER 19, 2020 Attorneys for Plaintiff 1787 Veterans Highway Islandia, NY 11749 (631) 234-1500 DepGñGnt is an attorney associated with Rubin & Rothman, LLC. To the best of deponent's knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the summons and complaint or the contentions therein are not frivolous as defined in section 130-1.1(c) of the Rules of the Chief Adm. and the matter was not obtained through illegal conduct or in violation of 22 NYCRR 1200, Rule 4.5. Dated: OCTOBER 19, 2020 CHRISTOPHER J.AHERN WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBPATNED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. NYC DCA LIC. 2045512 Our File No. 1362220 X 11 0- 0 V SLJ 000 000005915319 2 of 3 FILED: ESSEX COUNTY CLERK 10/20/2020 10:48 AM INDEX NO. CV20-0418 NYSCEF SUPREME COURT DOC. NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 10/20/2020 COUNTY OF ESSEX ________________________________________ FORD MOTOR CREDIT COMPANY LLC Plaintiff -against- Index No. KIM R HINDS KRISANNE B HINDS Defendant(s) ________________________________________ NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING PLEASE TAKE NOTICE that the matter captioned above, which has been commenced by filing of the accompanying documents with the County Clerk, 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. The New York State Courts Electronic Filing System ("NYSCEF") is designed for the electronic filing of documents with the County Clerk and the court and for the electronic service of those court docu- documents, ments, and court notices upon counsel and self-represented parties. Counsel and/or parties who do not notify the court of a claimed exemption (see below) as required by Section 202.5-bb(e) must immediately record their representation within the e-filed matter on the Consent page in NYSCEF. Failure to do so may result in an inability to receive electronic notice of document filings. Exemptions from mandatory e-filing are limited to: 1)attorneys who certify in good faith that they lack the computer equipment and (along with all employees) the requisite knowledge to comply; and 2) self-represented parties who choose not to participate in e-filing. For additional informa- tion about electronic filing, including access to Section 202.5-bb, consult the YSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center at 646-386-3033 or efile@courts.state.ny.us. Dated: Islandia, New York OCTOBER 19, 2020 RUBIN & ROTHMAN, LLC CHRIST PHER J.AHERN 1787 VETERANS HIGHWÃY RUBIN & ROTHMAN, LLC ISLANDIA, NY 11749 (631) 234-1500 NYDOCS@RUBINROTHMAN.COM To: KIM R HINDS 341 MIDDLE RD CROWN POINT, NY 12928-2207 To: KRISANNE B HINDS 420 RUSSELL ST CROWN POINT, NY 12928-2516 WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBPATNED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. NYC DCA LIC. 2045512 Our File No. 1362220 X 12 0- 0 V SLJ 000 000005915319 3 of 3