Preview
FILED: WASHINGTON COUNTY CLERK 07/07/2020 02:55 PM INDEX NO. EC2020-31784
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/07/2020
File # Kl24952
CONSUMER CREDIT TRANSACTION
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WASHINGTON
_________________________________
MIDLAND CREDIT MANAGEMENT, INC.
Plaintiff, Index No.
-against- SUMMONS
LAURA KAMBURELIS A/K/A LAURA L
KAMBURELIS
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:
3 LAWRENCE ST
GRANVILLE, NY 128321503
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: 06/30/2020 PRESSLER, FELT & WARSHAW, LLP
Attorneys for Plaintiff
305 Broadway Suite 802
New York, NY 10007
(516)22 9 9
[X] By:
Cr . tiller , Esq.
[ ] By:
Ian Z. Winograd Esq.
[ ] By:
David B. Warshaw Esq.
[ ] By:
Steven P. Bann Esq.
[ ] By:
Howard Schachter Esq.
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FILED: WASHINGTON COUNTY CLERK 07/07/2020 02:55 PM INDEX NO. EC2020-31784
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/07/2020
File # Kl24952
SUPREME COURT OF THE STATE OF NEW YORK - COUNTY OF WASHINGTON
__________________________________
MIDLAND CREDIT MANAGEMENT, INC.
Plaintiff(s) Index No.
-against- COMPLAINT
LAURA KAMBURELIS A/K/A LAURA L
KAMBURELIS
Defendant(s)
__________________________________
Plaintiff by its attorney, Pressler, Felt & Warshaw, LLP
complaining of the Defendant(s) alleges upon information and
belief as follows:
FACTS COMMON TO ALL COUNTS
1. Plaintiff, MIDLAND CREDIT MANAGEMENT, INC., is a limited
liability company formed under the laws of the state of Delaware
and is authorized to do business in the State of New York.
2. Plaintiff alleges that LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS
is the responsible person for the accounts sued upon herein.
3. LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS resides within the
jurisdictional limits of this court.
FIRST CAUSE OF ACTION
4. Plaintiff repeats, realleges and reiterates each and every
allegation contained in Facts Common to All Counts as if set forth
at length herein.
5. Plaintiff is the the assignee and the current owner of SYNCHRONY
BANK (GAP), account number ending in 4974. This debt was assigned
from the original creditor SYNCHRONY BANK (GAP) to MIDLAND CREDIT
MANAGEMENT, the present assignee, Plaintiff.
6. Plaintiff alleges that the Defendant LAURA KAMBURELIS A/K/A
LAURA L KAMBURELIS is the person who incurred the debt on account
number ending in 4974.
7. LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS failed to repay the
balance owed on the account number ending in 4974, which is in
default.
8. The date of last payment is on or about October 30, 2018.
9. Upon information and belief, the statute of limitations for this
account is 4 years and, therefore, has not expired.
10. There is now due and owing the Plaintiff, as the assignee of
the account number ending in 4974 from the Defendant, LAURA
KAMBURELIS A/K/A LAURA L KAMBURELIS , the sum of $2,250.81.
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FILED: WASHINGTON COUNTY CLERK 07/07/2020 02:55 PM INDEX NO. EC2020-31784
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/07/2020
SECOND CAUSE OF ACTION
11. Plaintiff repeats, realleges and reiterates each and every
allegation contained in Facts Common to All Counts as if set forth
at length herein.
12. Plaintiff is the the assignee and the current owner of
SYNCHRONY BANK (TJX), account number ending in 5796. This debt was
assigned from the original creditor SYNCHRONY BANK (TJX) to MIDLAND
CREDIT MANAGEMENT, the present assignee, Plaintiff.
13. Plaintiff alleges that the Defendant LAURA KAMBURELIS A/K/A
LAURA L KAMBURELIS is the person who incurred the debt on account
number ending in 5796.
14. LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS failed to repay the
balance owed on the account number ending in 5796, which is in
default.
15. The date of last payment is on or about October 23, 2018.
16. Upon information and belief, the statute of limitations for
this account is 4 years and, therefore, has not expired.
17. There is now due and owing the Plaintiff, as the assignee of
the account number ending in 5796 from the Defendant, LAURA
KAMBURELIS A/K/A LAURA L KAMBURELIS , the sum of $867.50.
WHEREFORE, Plaintiff demands judgment against LAURA KAMBURELIS
A/K/A LAURA L KAMBURELIS in the first cause of action for the sum
of $2,250.81 and in the second cause of action for the sum of
$867.50 for a total of $3,118.31 plus costs and disbursements and
for such further and other relief as the Court deems just and
proper.
Dated: 06/30/2020 PRESSLER, FELT & WARSHAW, LLP
Attorneys for Plaintiff
305 Broadway Suite 802
New York, NY 10007
(516)22 9 9
[X] By:
Cr . tiller , Esq.
[ ] By:
Ian Z. Winograd Esq.
[ ] By:
David B. Warshaw Esq.
[ ] By:
Steven P. Bann Esq.
[ ] By:
Howard Schachter Esq.
THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A
DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
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Preview
FILED: WASHINGTON COUNTY CLERK 07/07/2020 02:55 PM INDEX NO. EC2020-31784 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/07/2020 File # Kl24952 CONSUMER CREDIT TRANSACTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF WASHINGTON _________________________________ MIDLAND CREDIT MANAGEMENT, INC. Plaintiff, Index No. -against- SUMMONS LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS 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: 3 LAWRENCE ST GRANVILLE, NY 128321503 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: 06/30/2020 PRESSLER, FELT & WARSHAW, LLP Attorneys for Plaintiff 305 Broadway Suite 802 New York, NY 10007 (516)22 9 9 [X] By: Cr . tiller , Esq. [ ] By: Ian Z. Winograd Esq. [ ] By: David B. Warshaw Esq. [ ] By: Steven P. Bann Esq. [ ] By: Howard Schachter Esq. 1 of 3 FILED: WASHINGTON COUNTY CLERK 07/07/2020 02:55 PM INDEX NO. EC2020-31784 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/07/2020 File # Kl24952 SUPREME COURT OF THE STATE OF NEW YORK - COUNTY OF WASHINGTON __________________________________ MIDLAND CREDIT MANAGEMENT, INC. Plaintiff(s) Index No. -against- COMPLAINT LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS Defendant(s) __________________________________ Plaintiff by its attorney, Pressler, Felt & Warshaw, LLP complaining of the Defendant(s) alleges upon information and belief as follows: FACTS COMMON TO ALL COUNTS 1. Plaintiff, MIDLAND CREDIT MANAGEMENT, INC., is a limited liability company formed under the laws of the state of Delaware and is authorized to do business in the State of New York. 2. Plaintiff alleges that LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS is the responsible person for the accounts sued upon herein. 3. LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS resides within the jurisdictional limits of this court. FIRST CAUSE OF ACTION 4. Plaintiff repeats, realleges and reiterates each and every allegation contained in Facts Common to All Counts as if set forth at length herein. 5. Plaintiff is the the assignee and the current owner of SYNCHRONY BANK (GAP), account number ending in 4974. This debt was assigned from the original creditor SYNCHRONY BANK (GAP) to MIDLAND CREDIT MANAGEMENT, the present assignee, Plaintiff. 6. Plaintiff alleges that the Defendant LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS is the person who incurred the debt on account number ending in 4974. 7. LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS failed to repay the balance owed on the account number ending in 4974, which is in default. 8. The date of last payment is on or about October 30, 2018. 9. Upon information and belief, the statute of limitations for this account is 4 years and, therefore, has not expired. 10. There is now due and owing the Plaintiff, as the assignee of the account number ending in 4974 from the Defendant, LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS , the sum of $2,250.81. 2 of 3 FILED: WASHINGTON COUNTY CLERK 07/07/2020 02:55 PM INDEX NO. EC2020-31784 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/07/2020 SECOND CAUSE OF ACTION 11. Plaintiff repeats, realleges and reiterates each and every allegation contained in Facts Common to All Counts as if set forth at length herein. 12. Plaintiff is the the assignee and the current owner of SYNCHRONY BANK (TJX), account number ending in 5796. This debt was assigned from the original creditor SYNCHRONY BANK (TJX) to MIDLAND CREDIT MANAGEMENT, the present assignee, Plaintiff. 13. Plaintiff alleges that the Defendant LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS is the person who incurred the debt on account number ending in 5796. 14. LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS failed to repay the balance owed on the account number ending in 5796, which is in default. 15. The date of last payment is on or about October 23, 2018. 16. Upon information and belief, the statute of limitations for this account is 4 years and, therefore, has not expired. 17. There is now due and owing the Plaintiff, as the assignee of the account number ending in 5796 from the Defendant, LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS , the sum of $867.50. WHEREFORE, Plaintiff demands judgment against LAURA KAMBURELIS A/K/A LAURA L KAMBURELIS in the first cause of action for the sum of $2,250.81 and in the second cause of action for the sum of $867.50 for a total of $3,118.31 plus costs and disbursements and for such further and other relief as the Court deems just and proper. Dated: 06/30/2020 PRESSLER, FELT & WARSHAW, LLP Attorneys for Plaintiff 305 Broadway Suite 802 New York, NY 10007 (516)22 9 9 [X] By: Cr . tiller , Esq. [ ] By: Ian Z. Winograd Esq. [ ] By: David B. Warshaw Esq. [ ] By: Steven P. Bann Esq. [ ] By: Howard Schachter Esq. THIS COMMUNICATION 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