Preview
FILED: ST. LAWRENCE COUNTY CLERK 12/12/2018 04:22 PM INDEX NO. EFCV-2018-0154363
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/12/2018
Date Purchased:
SUPREME COURT OF THE STATE OF NEW YORK Index N9
COUNTY OF SAINT LAWRENCE X
Troy Capital LLC SUMMONS
Plaintiff, Plaintiff's Address:
-against- 2660 South Rainbow Blvd Ste D-
104
Karen Countryman Las Vegas NV 89146
Defendant(s). The basis of Venue is
CPLR Sec. 503(f)
Defendant resides in
County of: SAINT LAWRENCE
X Consumer Credit Transaction
Defendant(s) Address:
DEF.#1 -
417 County Route 7, Hammond NY 13646
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 on the Plaintiff's Attorney(s) within 20 days after the service of this
summons, exclusive of the day of service, or within 30 days after service is complete if this
summons is not personally delivered to you within the State of New York; and in the case of
your failure to appear or answer, judgment will be taken against you by default for the relief
demanded in the complaint.
We are attorneys attempting to collect a debt. Any information obtained will be used
for that purpose.
Dated: October 15, 2018
S.E ACCT. NO. 285664.001
Anthony S. Poulin U Stephanie R. Vetch
Stephen Einstein O Rafeena Khairullah
Joseph
Stephen
Attorneys
J. Cassotta
Einstein
for the
& Associates,
Plaintiff
Monique
P.C.
Aziza
M
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
*CCNB*
1 of 6
FILED: ST. LAWRENCE COUNTY CLERK 12/12/2018 04:22 PMINDEX NO. EFCV-2018-0154363
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/12/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SAINT LAWRENCE
Capital LLC VERIFIED COMPLAINT
Troy
Plaintiff,
-against-
Karen Countryman
Defendant(s).
Plaintiff, by its undersigned attorneys, complaining of the Defendant(s), respectfully
alleges that:
FIRST: Plaintiff is an active foreign entity conducting business in the state of NV. Upon
information and belief, at all times hereinafter mentioned, Defendant(s) resides in the
county in which this action is brought, or transacted business in person or through an
agent within the county in which this action is brought and the instant cause of action arose
out of said transaction.
SECOND: That the Defendant(s) executed an Agreement promising to repay
CHRYSLER CAPITAL all amounts financed, the unpaid principal balance of which as of
"THIRD"
4/30/2016 is set forth in paragraph below. Plaintiff purchased this account including
alloriginal documents for a valuable consideration and is stillthe holder thereof.
THIRD: That the amount due from Defendant(s) who is/are now in default is based
upon a sum certain as follows:
ACCOUNT NO: XXXXXXXXXXXXX1000
DATE OF AGREEMENT: 10/30/2013
BALANCE DUE.......................................... $8,405.92
2 of 6
FILED: ST. LAWRENCE COUNTY CLERK 12/12/2018 04:22 PM INDEX NO. EFCV-2018-0154363
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/12/2018
FOURTH: That as a result of the foregoing, Defendant(s) is/are indebted to the
Plaintiff in the amount of $8,405.92.
WHEREFORE, Plaintiff demands judgment against the Defendant(s) in the sum of
$8,405.92 together with the costs and disbursements of this action.
VERIFICATION: The undersigned, affirms under penalties of perjury, that he is a member of
the firm appearing as attorney of record for the plaintiff, has read this complaint and knows its
contents, and that the same is alleged upon information and belief and believes it to be true.
Affirmant says that the grounds of his belief are documents received from the Plaintiff and/or
pre-suit investigation. This verification is made by affirmant because plaintiff's place of
business is located outside the county where affirmant maintains his law practice. Affirmed
this 15th day of October, 2018.
tho y S. Poulin Stephanie R. Vetch
Stephen Einstein Rafeena Khairullah
Joseph J. Cassotta Monique Aziza
S.E Acet. No 285664.001
NV20
3 of 6
FILED: ST. LAWRENCE COUNTY CLERK 12/12/2018 04:22 PM INDEX NO. EFCV-2018-0154363
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/12/2018
Index No. Year
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SAINT LAWRENCE
Troy Capital LLC
Plaintiff
-against-
Karen Countryman
Defendant(s)
SUMMONS AND VERIFIED COMPLAINT
Sig at (Rule 130-1. 1-a)
en Esq.
ep Einstein,
nthony Poulin, Esq.
LAW OFFICE OF
STEPHEN EINSTEIN & ASSOCIATES, P.C.
for Plaintiff
Attorney(s)
Office and Post Office Address
39 Broadway, Suite 1250
New York, New York 10006
(212) 267-3550
Fax (212) 227-9656
Service of a of the within is hereby admitted.
copy
Dated,
for Plaintiff(s)
Attorney(s)
Sir: Please take notice
O NOTICE OF ENTRY:
That within is a true of a entered in the office of the clerk
(certified) copy duly
of the within named court on
NOTICE OF SETTLEMENT
That an order of which the within is a true copy of a
Settlement to the HON. Presented for one of the
judges
Of the within named court, at
On the __ day of 2010 at _ A.M
Dated,
4 of 6
FILED: ST. LAWRENCE COUNTY CLERK 12/12/2018 04:22 PM INDEX NO. EFCV-2018-0154363
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/12/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SAINT LAWRENCE Index No.
Troy Capital LLC
Plaintiff,
-against-
Karen Countryman
Defendant(s)
REDACTION COVER PAGE
C K ALL THAT APPLY:
The document filed contains no confidential personal information, as defined in 22 NYCRR 202..5(e).
The document filed is REDACTED in accordance with 22 NYCRR 202.5(e).
The document filed is UN-REDACTED in accordance with 22 NYCRR 202.5(e).
(a) The document filed contains SSN (as authorized by the order specified below).
(b) The decümcñt filed contains confidential personal information as defined under 22 NYCRR 202.5(e) (as
authorized by the order specified below).
This document was previously filed REDACTED.
Date:
This document was previously filed UN-REDACTED.
Date:
The document filed seeks a remedy under 22 NYCRR 202.5(e)(2).
The document filed seeks a remedy under 22 NYCRR 202.5(e)(3).
Additional information:
There is a previously filed order of the.Court ragarding this documcat:
O y**/ • no
Date of order:
Date order filed:
Other identifying information for such order:
The order of the Court is beingfiled with the redacted / un-redacted deca2:ca:: O yes / O no
Date of order:
Other identifying information for such order:
Signature of fil :
Print Name:
^ñthony S. Poulin Stephanie R. Vetch
Stephen Einstein Rafeena Khairullah
Joseph J. Cassotta Monique Aziza
Counsel appearing for: Troy Capital LLC
Filer is Unrepresented / Pro se: O yes / O no
Date: 10/15/2018
S.E. Acc. #285664.001
5 of 6
FILED: ST. LAWRENCE COUNTY CLERK 12/12/2018 04:22 PMINDEX NO. EFCV-2018-0154363
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/12/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SAINT LAWRENCE X
Troy Capital LLC
Plaintiff/Petitioner,
-against-
INDEX N9:
Karen Countryman
Defendant/Respondent.
X
NOTICE OF COMMENCEMENT OF ACTION
SUBJECT TO MANDATORY ELECTRONIC FILING
PLEASE TAKE NOTICE thatthe matter captioned above, which has been commenced by the filingof
the accompanying documents with the County Clerk via the New York State Courts Electronic Filing System
("NYSCEF"), is subject to mandatory electronic filing pursuant to Section 202.5-bb of the Uniform Rules for
the Trial Courts. This notice isbeing served as required by Subdivision (b) (3)of that Section.
Counsel and/or parties must either: 1)immediately record theirrepresentation within the e-filed matter
on the Consent/Represent page in NYSCEF; or 2) filethe Notice of Opt-Out form to claim one of the limited
exemptions from mandatory e-filing (see below). Failure to record representation may result in an inability to
receive electronic notice of any document filings.Claiming an exemption will require the exempt party to serve
and be served with hard copy documents.
Counsel and anrepresented parties who intend to participate in e-filing must first create a NYSCEF
account and obtain a user ID and password. For additional information about electronic filing,and to create a
NYSCEF accoynt, visit the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource
Center (phone: 646-386-3033; e-mail: efileénycourts.gov; mailing address: 60 Centre Street, New York, New
York 10007).
Exemptions from mandatory e-filing(Section 202.5-bb(e)) are limited to:
I) attorneys who certify in good faiththat they lack the computer hardware and/or scanner
and/or internet connection or that they lack (along with allemployees subject to their
direction) the operationa1 knowledge tocomply with e-filing requirements; and
parties who expect to represent themselves and who choose not to participate in e-
2)
filing.(Such parties are encouraged to visit www.nveourts.gov/courthelp/ or contact the
Help Center in the court where the action ispending
Dated: ..
th n S. Poulin Stephanie R. Vetch
O Shawn Clauther Rafeena Khairullah
Joseph J. Cassotta Monique Aziza
39 Broadway, Suite 1250
New York, N.Y, 10006
Stephen Einstein & Associates, P.C.
(212) 267-3550
www.stephencinstein.com
S.E acc. #285664.001
TO: Karen Countryman
417 County Route 7
Hammond NY 13646
6 of 6
Preview
FILED: ST. LAWRENCE COUNTY CLERK 12/12/2018 04:22 PM INDEX NO. EFCV-2018-0154363 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/12/2018 Date Purchased: SUPREME COURT OF THE STATE OF NEW YORK Index N9 COUNTY OF SAINT LAWRENCE X Troy Capital LLC SUMMONS Plaintiff, Plaintiff's Address: -against- 2660 South Rainbow Blvd Ste D- 104 Karen Countryman Las Vegas NV 89146 Defendant(s). The basis of Venue is CPLR Sec. 503(f) Defendant resides in County of: SAINT LAWRENCE X Consumer Credit Transaction Defendant(s) Address: DEF.#1 - 417 County Route 7, Hammond NY 13646 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 on the Plaintiff's Attorney(s) within 20 days after the service of this summons, exclusive of the day of service, or within 30 days after service is complete if this summons is not personally delivered to you within the State of New York; and in the case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. We are attorneys attempting to collect a debt. Any information obtained will be used for that purpose. Dated: October 15, 2018 S.E ACCT. NO. 285664.001 Anthony S. Poulin U Stephanie R. Vetch Stephen Einstein O Rafeena Khairullah Joseph Stephen Attorneys J. Cassotta Einstein for the & Associates, Plaintiff Monique P.C. Aziza M 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 *CCNB* 1 of 6 FILED: ST. LAWRENCE COUNTY CLERK 12/12/2018 04:22 PMINDEX NO. EFCV-2018-0154363 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/12/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SAINT LAWRENCE Capital LLC VERIFIED COMPLAINT Troy Plaintiff, -against- Karen Countryman Defendant(s). Plaintiff, by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges that: FIRST: Plaintiff is an active foreign entity conducting business in the state of NV. Upon information and belief, at all times hereinafter mentioned, Defendant(s) resides in the county in which this action is brought, or transacted business in person or through an agent within the county in which this action is brought and the instant cause of action arose out of said transaction. SECOND: That the Defendant(s) executed an Agreement promising to repay CHRYSLER CAPITAL all amounts financed, the unpaid principal balance of which as of "THIRD" 4/30/2016 is set forth in paragraph below. Plaintiff purchased this account including alloriginal documents for a valuable consideration and is stillthe holder thereof. THIRD: That the amount due from Defendant(s) who is/are now in default is based upon a sum certain as follows: ACCOUNT NO: XXXXXXXXXXXXX1000 DATE OF AGREEMENT: 10/30/2013 BALANCE DUE.......................................... $8,405.92 2 of 6 FILED: ST. LAWRENCE COUNTY CLERK 12/12/2018 04:22 PM INDEX NO. EFCV-2018-0154363 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/12/2018 FOURTH: That as a result of the foregoing, Defendant(s) is/are indebted to the Plaintiff in the amount of $8,405.92. WHEREFORE, Plaintiff demands judgment against the Defendant(s) in the sum of $8,405.92 together with the costs and disbursements of this action. VERIFICATION: The undersigned, affirms under penalties of perjury, that he is a member of the firm appearing as attorney of record for the plaintiff, has read this complaint and knows its contents, and that the same is alleged upon information and belief and believes it to be true. Affirmant says that the grounds of his belief are documents received from the Plaintiff and/or pre-suit investigation. This verification is made by affirmant because plaintiff's place of business is located outside the county where affirmant maintains his law practice. Affirmed this 15th day of October, 2018. tho y S. Poulin Stephanie R. Vetch Stephen Einstein Rafeena Khairullah Joseph J. Cassotta Monique Aziza S.E Acet. No 285664.001 NV20 3 of 6 FILED: ST. LAWRENCE COUNTY CLERK 12/12/2018 04:22 PM INDEX NO. EFCV-2018-0154363 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/12/2018 Index No. Year SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SAINT LAWRENCE Troy Capital LLC Plaintiff -against- Karen Countryman Defendant(s) SUMMONS AND VERIFIED COMPLAINT Sig at (Rule 130-1. 1-a) en Esq. ep Einstein, nthony Poulin, Esq. LAW OFFICE OF STEPHEN EINSTEIN & ASSOCIATES, P.C. for Plaintiff Attorney(s) Office and Post Office Address 39 Broadway, Suite 1250 New York, New York 10006 (212) 267-3550 Fax (212) 227-9656 Service of a of the within is hereby admitted. copy Dated, for Plaintiff(s) Attorney(s) Sir: Please take notice O NOTICE OF ENTRY: That within is a true of a entered in the office of the clerk (certified) copy duly of the within named court on NOTICE OF SETTLEMENT That an order of which the within is a true copy of a Settlement to the HON. Presented for one of the judges Of the within named court, at On the __ day of 2010 at _ A.M Dated, 4 of 6 FILED: ST. LAWRENCE COUNTY CLERK 12/12/2018 04:22 PM INDEX NO. EFCV-2018-0154363 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/12/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SAINT LAWRENCE Index No. Troy Capital LLC Plaintiff, -against- Karen Countryman Defendant(s) REDACTION COVER PAGE C K ALL THAT APPLY: The document filed contains no confidential personal information, as defined in 22 NYCRR 202..5(e). The document filed is REDACTED in accordance with 22 NYCRR 202.5(e). The document filed is UN-REDACTED in accordance with 22 NYCRR 202.5(e). (a) The document filed contains SSN (as authorized by the order specified below). (b) The decümcñt filed contains confidential personal information as defined under 22 NYCRR 202.5(e) (as authorized by the order specified below). This document was previously filed REDACTED. Date: This document was previously filed UN-REDACTED. Date: The document filed seeks a remedy under 22 NYCRR 202.5(e)(2). The document filed seeks a remedy under 22 NYCRR 202.5(e)(3). Additional information: There is a previously filed order of the.Court ragarding this documcat: O y**/ • no Date of order: Date order filed: Other identifying information for such order: The order of the Court is beingfiled with the redacted / un-redacted deca2:ca:: O yes / O no Date of order: Other identifying information for such order: Signature of fil : Print Name: ^ñthony S. Poulin Stephanie R. Vetch Stephen Einstein Rafeena Khairullah Joseph J. Cassotta Monique Aziza Counsel appearing for: Troy Capital LLC Filer is Unrepresented / Pro se: O yes / O no Date: 10/15/2018 S.E. Acc. #285664.001 5 of 6 FILED: ST. LAWRENCE COUNTY CLERK 12/12/2018 04:22 PMINDEX NO. EFCV-2018-0154363 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/12/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SAINT LAWRENCE X Troy Capital LLC Plaintiff/Petitioner, -against- INDEX N9: Karen Countryman Defendant/Respondent. X NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING PLEASE TAKE NOTICE thatthe matter captioned above, which has been commenced by the filingof the accompanying documents with the County Clerk via the New York State Courts Electronic Filing System ("NYSCEF"), is subject to mandatory electronic filing pursuant to Section 202.5-bb of the Uniform Rules for the Trial Courts. This notice isbeing served as required by Subdivision (b) (3)of that Section. Counsel and/or parties must either: 1)immediately record theirrepresentation within the e-filed matter on the Consent/Represent page in NYSCEF; or 2) filethe Notice of Opt-Out form to claim one of the limited exemptions from mandatory e-filing (see below). Failure to record representation may result in an inability to receive electronic notice of any document filings.Claiming an exemption will require the exempt party to serve and be served with hard copy documents. Counsel and anrepresented parties who intend to participate in e-filing must first create a NYSCEF account and obtain a user ID and password. For additional information about electronic filing,and to create a NYSCEF accoynt, visit the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone: 646-386-3033; e-mail: efileénycourts.gov; mailing address: 60 Centre Street, New York, New York 10007). Exemptions from mandatory e-filing(Section 202.5-bb(e)) are limited to: I) attorneys who certify in good faiththat they lack the computer hardware and/or scanner and/or internet connection or that they lack (along with allemployees subject to their direction) the operationa1 knowledge tocomply with e-filing requirements; and parties who expect to represent themselves and who choose not to participate in e- 2) filing.(Such parties are encouraged to visit www.nveourts.gov/courthelp/ or contact the Help Center in the court where the action ispending Dated: .. th n S. Poulin Stephanie R. Vetch O Shawn Clauther Rafeena Khairullah Joseph J. Cassotta Monique Aziza 39 Broadway, Suite 1250 New York, N.Y, 10006 Stephen Einstein & Associates, P.C. (212) 267-3550 www.stephencinstein.com S.E acc. #285664.001 TO: Karen Countryman 417 County Route 7 Hammond NY 13646 6 of 6