On December 19, 2019 a
Complaint,Petition
was filed
involving a dispute between
Midland Funding Llc,
and
Joseph Bates Aka Joseph K Bates,
for Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff
in the District Court of Seneca County.
Preview
FILED: SENECA COUNTY CLERK 12/19/2019 10:04 AM INDEX NO. 20190415
.
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/19/2019
File # B303503
CONSUMER CREDIT TRANSACTION
SUPREME COURT OF THE STATE. OF NEW YORK
COUNTY OF SENECA
_________________________________
MIDLAND FUNDING LLC
Plaintiff , Index No..
-against- SUMMONS
JOSEPH BATES A/K/A JOSEPH K BATES
'
Plaintiff s Residence Address
350 CAMINO DE LA REINA, SUITE
100
SAN DIEGO CA 92108
Defendant(s).
The Basis of this venue
designated is:
Defendant's residence
________________________________-
Defendant's Residence Address:
55 CHURCH ST
WATERLOO, NY 131651118
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 within twenty (20) days after the
service of this summons exclusive of the days of service (or
within thirty (30) days after the service is complete if this
summons is not personally delivered to you within the State of
New York).
You are hereby notified that should you fail to appear or
answer, judgment will be taken against you by default for the
relief demanded in the complaint.
Dated: 12/12/19 PRESSLER, FELT & WARSHAW, LLP
Attorneys for Plaintiff
305 Broadway 9th Floor
New Y 10.007
(516) 22-79
[X] By
( Dam. Warshaw , Esq.
[ ] By:
Ian Z. Winograd Esq.
[ ] By:
Steven P.. Bann Esq.
[ ] By:
Craig-S. Stiller Esq.
1 of 3
FILED: SENECA COUNTY CLERK 12/19/2019 10:04 AM INDEX NO. 20190415
.
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/19/2019
File # ;B303503
OF OF NEW - COUNTY SENECA
SUPREME COURT THE STATE YORK OF
____________________ ____________
MIDLAND FUNDING LLC
Plaintiff(s) Index No.
-against- COMPLAINT
JOSEPH BATES A/K/A JOSEPH K BATES
Defendant(s)
__________________________________
Plaintiff by its attorney, Pressler, Felt & Warshaw, LLP
complaining of the Defendant(s) alleges upon information and
belief as follows:
FIRST CAUSE OF ACTION
1. Plaintiff, MIDLAND FUNDING LLC, is a limited liability
company formed under the laws of the State of Delaware and
having taken assignment of is owner of SYNCHRONY BANK
(AMAZON) account number ending in XXXXXXXXXXXX0373 .
2. JOSEPH BATES A/K/A JOSEPH K BATES resides within the
jurisdictional limits of this court.
3. Plaintiff alleges that JOSEPH BATES A/K/A JOSEPH K :BATES is
the responsible person for this account.
4. JOSEPH BATES A/K/A JOSEPH K BATES failed to repay the
balance owed on the account, which is in default.
5. The account was. assigned from the original creditor,
SYNCHRONY BANK (AMAZON) to MIDLAND FUNDING LLC, the present
assignee.
6. The date of last payment is on or about September 27, 2017.
7. Upon information and belief, the statute of limitations for
the cause of .action asserted herein is 4 years and
therefore has not expired.
8. There is now due and owing the plaintiff, as the assigne.e
of the account, from JOSEPH BATES A/K/A JOSEPH K BATES ,
the sum of $1,568.36.
2 of 3
FILED: SENECA COUNTY CLERK 12/19/2019 10:04 AM INDEX NO. 20190415
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/19/2019
WHEREFORE, Plaintiff demands judgment agà inst JOSEPH BATES A/K/A
.JOSEPH K BATES
disbursements'
for the sum of $1, 568.36 plus. costs and o.f this
action and for such further and other relief as the Court deems
just and proper.
Dated) 12/12/19 PRESSLER, FELT & WARSHAW, LLP
Attorneys for Plaintiff
305 .Broadway 9th Floor
New York, NY 10007
-
0516)
[X) By
id aMrdrshaw , Esq.
[ } By:
Ian Z. Winograd Esq..
[ ] By:
Steven P. -BÃ nn Esq.
[ } By;
Craig S. Stiller Esq..
THIS COMMONICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A
DEBT.. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
3 of 3
Document Filed Date
December 19, 2019
Case Filing Date
December 19, 2019
Category
Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff
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