Preview
FILED: FRANKLIN COUNTY CLERK 12/11/2020 06:01 PM INDEX NO. E2020-693
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2020
CONSUMER CREDIT TRANSACTION
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF FRANKLIN
Midland Credit inc. Index No.:
Management,
Date Purchased
Plaintiff,
vs. SUMMONS
The basis ofthe venue designated is
The defendant residesin the
x of Franklin
County
Sheri Harr.
The transactiontook place in the
Defendant. County of Franklin
To the above-named Defendant:
YOU ARE HEREBY SUMMONED to answer the complaint in thisaction and to serve
a copy of your answer, or, ifthe complaird is not served with this summons, to serve a notice of
appearance, on the Plaintiff's Attorney(s) at the address stated below within 20 days aAer the
service of this summons, exclusive of the day of service (or within 30 days after the service is
complete ifthis summons isnot personally delivered to you within the State of New York); and in
case of your failure to appear or answer, judgment will be taken against you by default for the
relief demanded in the complaint.
Dated: East Amb
. 20 By:
MAN R LAWOROUP,LLP
Heather A. whñsen, Esq.
Brandon . Wrazen, Esq.
Attorneys for Plainnf
5%5 Transit Road, Suite 500
East Amherst, New York 14051
(833) 769-2757
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FILED: FRANKLIN COUNTY CLERK 12/11/2020 06:01 PM INDEX NO. E2020-693
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2020
TO: Sheri Harr
729 S WOODS RD
BRUSHTON, NY 12916-4016
WE ARE ATTEMPTING TO COLLECTA DEBT ANDANY INFORMATION W1LL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROMA DEBT COLLECTOR.
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FILED: FRANKLIN COUNTY CLERK 12/11/2020 06:01 PM INDEX NO. E2020-693
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2020
CONSUMER CREDIT TRANSACTION
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF FRANKLIN
Midland Credit Menãgement, Inc,
COMPLAINT
Plaintiff,
vs-
Index No.:
Sheri Harr,
Defendant.
Plaintiff, Midland Credit Management, Inc, by itsattorneys, Mandarich Law Group, LLP,
comp-5 eg of the Defendant, Sheri Harr, alleges the following:
1. Plaintiff is a foreign limited liability company ciganized and existing by virtue of the laws
of Delaware, with a principal place of business located at 2365 Northside Drive, 3rd Floor, San
Diego, California 92108.
2. Upon information and belief, Defendant Sheri Harr, was and is a saturâI person residing at
729 S WOODS RD , County of Franklin, State of New York.
3. Plaintiff took by assignment and/or purchased, for value, all rights, title, and interest of
certain accounts, including the account identified below. which originated with CREDIT ONE
BANK, N.A. (hereinailer the "Original Creditor"). The chain of title is as follows:
CREDIT ONE BANK, N.A.
MHC RECEIVABLES, LLC
SHERMAN ORIGINATOR IIILLC
MIDLAND CREDIT MANAGEMENT, INC
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FILED: FRANKLIN COUNTY CLERK 12/11/2020 06:01 PM INDEX NO. E2020-693
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2020
4. Original Creditor issued a consumer credit card account to the Defendant (original account
number ending in XXXXXXXXXXXX7165) herein aAer the "Account", which is the subject of
this action.
5. Defendant entered into an agreement with the Original Creditor and made purchases,
received cash, merchandise, and/or credit on the Account.
6. Defendant agreed to but failed to make payments on said Account and $1,189.63 is now
due and owing to the Plaintiff from Defendant, which amount has been de-saded and remains
unpaid. The date of the last payment on the account is:03/21/2019.
7. Defendant is in default and Plaintiff, as owner of the Account, is authorized to proceed
with this action.
8. Plaintiff has suffered damages in the amount of $1,189.63, together with the costs and
disbursements incurred in thisaction.
9. The causes of action asserted herein are not outside of the applicable statute of limitations
for enforcing the debt.
WHEREFORE, Plaintiff. Midland Credit Management, Inc, respectfully requests
judgment against the Defendant, Sheri Harr, for the sum of $1,189.63, all costs and
disbursements of this action, with interest from the date of any judgment granted or ordered, and
for such other and further relief as this Court deems just and proper.
Dated: East A erst,New ork
By:
, 20
MAN I LAW OROUP, LLP
Heather A Johnson, Esq.
Brandon M. Wrazen. Esq.
Attorneys for Plaintt)f
5965 Transit Road, Suite 500
East Amherst, New York 14051
MLG - 4363469
(833) 769-2757
4 of 5
FILED: FRANKLIN COUNTY CLERK 12/11/2020 06:01 PM INDEX NO. E2020-693
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2020
TO: Sheri Harr
729 S WOODS RD
BRUSHTON, NY 12916-4016
WEARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROMA DEBT
COLLECTOR.
5 of 5
Preview
FILED: FRANKLIN COUNTY CLERK 12/11/2020 06:01 PM INDEX NO. E2020-693 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2020 CONSUMER CREDIT TRANSACTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF FRANKLIN Midland Credit inc. Index No.: Management, Date Purchased Plaintiff, vs. SUMMONS The basis ofthe venue designated is The defendant residesin the x of Franklin County Sheri Harr. The transactiontook place in the Defendant. County of Franklin To the above-named Defendant: YOU ARE HEREBY SUMMONED to answer the complaint in thisaction and to serve a copy of your answer, or, ifthe complaird is not served with this summons, to serve a notice of appearance, on the Plaintiff's Attorney(s) at the address stated below within 20 days aAer the service of this summons, exclusive of the day of service (or within 30 days after the service is complete ifthis summons isnot personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: East Amb . 20 By: MAN R LAWOROUP,LLP Heather A. whñsen, Esq. Brandon . Wrazen, Esq. Attorneys for Plainnf 5%5 Transit Road, Suite 500 East Amherst, New York 14051 (833) 769-2757 1 of 5 FILED: FRANKLIN COUNTY CLERK 12/11/2020 06:01 PM INDEX NO. E2020-693 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2020 TO: Sheri Harr 729 S WOODS RD BRUSHTON, NY 12916-4016 WE ARE ATTEMPTING TO COLLECTA DEBT ANDANY INFORMATION W1LL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROMA DEBT COLLECTOR. 2 of 5 FILED: FRANKLIN COUNTY CLERK 12/11/2020 06:01 PM INDEX NO. E2020-693 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2020 CONSUMER CREDIT TRANSACTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF FRANKLIN Midland Credit Menãgement, Inc, COMPLAINT Plaintiff, vs- Index No.: Sheri Harr, Defendant. Plaintiff, Midland Credit Management, Inc, by itsattorneys, Mandarich Law Group, LLP, comp-5 eg of the Defendant, Sheri Harr, alleges the following: 1. Plaintiff is a foreign limited liability company ciganized and existing by virtue of the laws of Delaware, with a principal place of business located at 2365 Northside Drive, 3rd Floor, San Diego, California 92108. 2. Upon information and belief, Defendant Sheri Harr, was and is a saturâI person residing at 729 S WOODS RD , County of Franklin, State of New York. 3. Plaintiff took by assignment and/or purchased, for value, all rights, title, and interest of certain accounts, including the account identified below. which originated with CREDIT ONE BANK, N.A. (hereinailer the "Original Creditor"). The chain of title is as follows: CREDIT ONE BANK, N.A. MHC RECEIVABLES, LLC SHERMAN ORIGINATOR IIILLC MIDLAND CREDIT MANAGEMENT, INC 3 of 5 FILED: FRANKLIN COUNTY CLERK 12/11/2020 06:01 PM INDEX NO. E2020-693 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2020 4. Original Creditor issued a consumer credit card account to the Defendant (original account number ending in XXXXXXXXXXXX7165) herein aAer the "Account", which is the subject of this action. 5. Defendant entered into an agreement with the Original Creditor and made purchases, received cash, merchandise, and/or credit on the Account. 6. Defendant agreed to but failed to make payments on said Account and $1,189.63 is now due and owing to the Plaintiff from Defendant, which amount has been de-saded and remains unpaid. The date of the last payment on the account is:03/21/2019. 7. Defendant is in default and Plaintiff, as owner of the Account, is authorized to proceed with this action. 8. Plaintiff has suffered damages in the amount of $1,189.63, together with the costs and disbursements incurred in thisaction. 9. The causes of action asserted herein are not outside of the applicable statute of limitations for enforcing the debt. WHEREFORE, Plaintiff. Midland Credit Management, Inc, respectfully requests judgment against the Defendant, Sheri Harr, for the sum of $1,189.63, all costs and disbursements of this action, with interest from the date of any judgment granted or ordered, and for such other and further relief as this Court deems just and proper. Dated: East A erst,New ork By: , 20 MAN I LAW OROUP, LLP Heather A Johnson, Esq. Brandon M. Wrazen. Esq. Attorneys for Plaintt)f 5965 Transit Road, Suite 500 East Amherst, New York 14051 MLG - 4363469 (833) 769-2757 4 of 5 FILED: FRANKLIN COUNTY CLERK 12/11/2020 06:01 PM INDEX NO. E2020-693 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/11/2020 TO: Sheri Harr 729 S WOODS RD BRUSHTON, NY 12916-4016 WEARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROMA DEBT COLLECTOR. 5 of 5