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  • Midland Funding Llc v. Joseph Bates AKA JOSEPH K BATESOther Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
  • Midland Funding Llc v. Joseph Bates AKA JOSEPH K BATESOther Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
  • Midland Funding Llc v. Joseph Bates AKA JOSEPH K BATESOther Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
						
                                

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 agàinst 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. -Bànn 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