Preview
FILED: MONROE COUNTY CLERK 01/13/2021 11:25 AM INDEX NO. E2021000252
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/13/2021
MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT.
Receipt # 2599006
Book Page CIVIL
Return To: No. Pages: 5
TIMOTHY J. MURTHA
500 BI COUNTY BOULEVARD, SUITE 475 Instrument: EFILING INDEX NUMBER
Farmingdale, NY 11735
Control #: 202101131376
Index #: E2021000252
Date: 01/13/2021
ACCELERATED INVENTORY MANAGEMENT, LLC Time: 2:37:12 PM
FERGUSON-MCGILL, CHRISTINA
MCGILL, DAVID
State Fee Index Number $165.00
County Fee Index Number $26.00
State Fee Cultural Education $14.25
State Fee Records $4.75 Employee: MJ
Management
Total Fees Paid: $210.00
State of New York
MONROE COUNTY CLERK’S OFFICE
WARNING – THIS SHEET CONSTITUTES THE CLERKS
ENDORSEMENT, REQUIRED BY SECTION 317-a(5) &
SECTION 319 OF THE REAL PROPERTY LAW OF THE
STATE OF NEW YORK. DO NOT DETACH OR REMOVE.
JAMIE ROMEO
MONROE COUNTY CLERK
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INDEX NO. E2021000252
FILED: MONROE COUNTY CLERK 01/13/2021 11:25 AM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/13/2021
SUPREME COURT OF THE STATE OF NEW YORK Index Number:
COUNTY OF MONROE Our File No. OLI00039
---------------------------- ---------- X
Accelerated Inventory Management, LLC
SUMMONS
Consumer Credit Transaction
PLAINTIFF,
Plaintiff's Address
-AGAINST~ 5725 HWY 290 W SUITE 103
AUSTIN, TX 78735
CHRISTINA FERGUSON-MCGILL Defendant's Address
DAVID MCGILL CHRISTINA FERGUSON- DAVID MCGILL
DEFENDANT (S) MCGILL
______ X 140 CLEARBROOK DR 140 CLEARBROOK DR
The basis of the venue designated is: defendant(s) place of ROCHESTER, NY 14609 ROCHESTER NY 14609
residence: MONROE County
To the above named Defendant(s)
YOU ARE HEREBY SU_MMONED, and required to appear in this action in the SUPREME COURT OF THE STATE
OF NEW YORK of the County of MONROE, at the office of the clerk of the said Court at 545 Hall of Justice Rochester,
NY 14614 in the County of MONROE State of New York, by serving an answer to the annexed complaint upon plaintiff's
attorney at the address stated below, or if there is no attorney, upon the plaintiff at the address stated above, within the time
provided by law as noted below. Upon your failure to answer, judginsñt will be taken against you for the sum of
$15,002,34 together with the costs of this action.
DATED: Farmingdale, New York
12/30/2020
By:
Timothy J. Murtha
Roach & Murtha Attorneys at Law, P.C.
Attorneys for Plaintiff
500 Bi County Blvd Suite 475
Farmingdale, NY 11735
Telephone #: (516) 346-5400
NOTE: The Law or rules of court provide that:
(a) If this summons is served by its delivery to you, or (for a corporation) an agent antheri-ed to receive service,
perscñally within the County of MONROE State of New York, you must appear and answer within TWENTY
days after such service; or
(b) If this emeeñs is served to any person other than you personally
by delivery or (for a corporation) an agent
authorized to receive servicepersonally, or is served outside the county of MONROE or by publication, or by
any other means other than personal delivery to you, or (for a corporation) an agent authorized to receive service
persoñally, within the County of MONROE you are allowed THIRTY days after proof of service is filed with the
Clerk of this Court within which to appear and answer.
(c) You are required to file a copy of your answer togcthct with proof of service with the Clerk of the Court in
which the action is brought within TEN days of the service of the answer.
WE ARE DEBT COLLECTORS- THIS IS AN ATTEMPT TO COLLECT A DEBT AND
ANY INFORMATION WILL BE USED FOR THAT PURPOSE.
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INDEX NO. E2021000252
FILED: MONROE COUNTY CLERK 01/13/2021 11:25 AM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/13/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MONROE
____--
Accelerated Inventory Management, LLC,
VERIFIED COMPLAINT
Consumer Credit Transaction
PLER
Index No.:
-AGAINST-
CHRISTINA FERGUSON-MCGILL
DAVID MCGILL
DEFENDANT(S).
x
Plaintiff, by its attorneys, Roach & Murtha Attorneys at Law, P.C., hereby complains of the
Defendant(s) as follows:
1. Plaintiff is a national banking association organized pursuant to Federal Law.
2. That the Defendant(s) resides in the county in which this action is brought; or that the
Defendant(s) transacted business within the county in which this action is brought in person or
through an agent and that the instant cause of action arose out of said transaction.
FOR A FIRST CAUSE OF ACTION
3. That heretofore, the parties entered into a loan agreement.
4. Plaintiff duly performed all conditions on its part under the agreement.
5. Upon information and belief, Defendant(s) defaulted in payment and pursuant to the terms of
the agreement now owes a balance of $15,002.34, no part of which has been paid despite due
demand thereof.
F_OR A SECOND CAUSE OF ACTION
6. That heretofore, Plaintiff rendered to Defendañt(s) full, just and true accounts of the
indebtedness due and owing by Defendañt(s) as a result of the aforesaid transaction, which is the
sum set forth above, and said statenients were delivered to, received, accepted and retained by
Defendant(s) without objection, resulting in an account stated for the amount clairned above.
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INDEX NO. E2021000252
FILED: MONROE COUNTY CLERK 01/13/2021 11:25 AM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/13/2021
WHEREFORE, the Plaintiff, Accelerated Inventory Management, LLC, demands judgmeñt
against the defendant(s) CHRISTINA FERGUSON-MCGILL DAVID MCGILL on the First and
Second Cause of Action in the añicant of $15,002.34 less payments of $0.00, together with costs
and disbursements of the within action.
DATED: Farmingdale, New York
12/30/2020
By:
Timothy J. Murtha
Roach & Murtha Attorneys at Law, P.C.
Attorneys for Plaintiff
500 Bi County Blvd Suite 475
Farmingdale, NY 11735
Telephone #: (516) 346-5400
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INDEX NO. E2021000252
FILED: MONROE COUNTY CLERK 01/13/2021 11:25 AM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/13/2021
Attorneys for Plaintiff
STATE OF NEW YORK, COUNTY OF SUFFOLK
The undersigned, an attorney at law and the Plaintiffs attorney, affirms the following to be true
under the penalty of perjury: the foregoing complaint is true to my knowledge, except as to
matters stated to be on information and belief, and as to those, I believe them to be true. The
reason I am making this verification is I have all salient business records in my possession and
have reviewed the same and/or the plaintiff does not have offices in the county where I maintain
my office.
Attorney Signature:
Attorney Name (Print): Timothy Murtha
Sworn to before me this
12/30/2020
tary Public
LINDA A. CARBONETTO
Of New York
Notary Public, State
Qualified in Suffolk County
Reg. No. 01CA6055451
Comm. Expires February 26, 20
My
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Preview
FILED: MONROE COUNTY CLERK 01/13/2021 11:25 AM INDEX NO. E2021000252 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/13/2021 MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT. Receipt # 2599006 Book Page CIVIL Return To: No. Pages: 5 TIMOTHY J. MURTHA 500 BI COUNTY BOULEVARD, SUITE 475 Instrument: EFILING INDEX NUMBER Farmingdale, NY 11735 Control #: 202101131376 Index #: E2021000252 Date: 01/13/2021 ACCELERATED INVENTORY MANAGEMENT, LLC Time: 2:37:12 PM FERGUSON-MCGILL, CHRISTINA MCGILL, DAVID State Fee Index Number $165.00 County Fee Index Number $26.00 State Fee Cultural Education $14.25 State Fee Records $4.75 Employee: MJ Management Total Fees Paid: $210.00 State of New York MONROE COUNTY CLERK’S OFFICE WARNING – THIS SHEET CONSTITUTES THE CLERKS ENDORSEMENT, REQUIRED BY SECTION 317-a(5) & SECTION 319 OF THE REAL PROPERTY LAW OF THE STATE OF NEW YORK. DO NOT DETACH OR REMOVE. JAMIE ROMEO MONROE COUNTY CLERK 1 of 5 202101131376 01/13/2021 02:37:12 PM CIVIL 202101131376 INDEX NO. E2021000252 FILED: MONROE COUNTY CLERK 01/13/2021 11:25 AM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/13/2021 SUPREME COURT OF THE STATE OF NEW YORK Index Number: COUNTY OF MONROE Our File No. OLI00039 ---------------------------- ---------- X Accelerated Inventory Management, LLC SUMMONS Consumer Credit Transaction PLAINTIFF, Plaintiff's Address -AGAINST~ 5725 HWY 290 W SUITE 103 AUSTIN, TX 78735 CHRISTINA FERGUSON-MCGILL Defendant's Address DAVID MCGILL CHRISTINA FERGUSON- DAVID MCGILL DEFENDANT (S) MCGILL ______ X 140 CLEARBROOK DR 140 CLEARBROOK DR The basis of the venue designated is: defendant(s) place of ROCHESTER, NY 14609 ROCHESTER NY 14609 residence: MONROE County To the above named Defendant(s) YOU ARE HEREBY SU_MMONED, and required to appear in this action in the SUPREME COURT OF THE STATE OF NEW YORK of the County of MONROE, at the office of the clerk of the said Court at 545 Hall of Justice Rochester, NY 14614 in the County of MONROE State of New York, by serving an answer to the annexed complaint upon plaintiff's attorney at the address stated below, or if there is no attorney, upon the plaintiff at the address stated above, within the time provided by law as noted below. Upon your failure to answer, judginsñt will be taken against you for the sum of $15,002,34 together with the costs of this action. DATED: Farmingdale, New York 12/30/2020 By: Timothy J. Murtha Roach & Murtha Attorneys at Law, P.C. Attorneys for Plaintiff 500 Bi County Blvd Suite 475 Farmingdale, NY 11735 Telephone #: (516) 346-5400 NOTE: The Law or rules of court provide that: (a) If this summons is served by its delivery to you, or (for a corporation) an agent antheri-ed to receive service, perscñally within the County of MONROE State of New York, you must appear and answer within TWENTY days after such service; or (b) If this emeeñs is served to any person other than you personally by delivery or (for a corporation) an agent authorized to receive servicepersonally, or is served outside the county of MONROE or by publication, or by any other means other than personal delivery to you, or (for a corporation) an agent authorized to receive service persoñally, within the County of MONROE you are allowed THIRTY days after proof of service is filed with the Clerk of this Court within which to appear and answer. (c) You are required to file a copy of your answer togcthct with proof of service with the Clerk of the Court in which the action is brought within TEN days of the service of the answer. WE ARE DEBT COLLECTORS- THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION WILL BE USED FOR THAT PURPOSE. 2 of 5 202101131376 01/13/2021 02:37:12 PM CIVIL 202101131376 INDEX NO. E2021000252 FILED: MONROE COUNTY CLERK 01/13/2021 11:25 AM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/13/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MONROE ____-- Accelerated Inventory Management, LLC, VERIFIED COMPLAINT Consumer Credit Transaction PLER Index No.: -AGAINST- CHRISTINA FERGUSON-MCGILL DAVID MCGILL DEFENDANT(S). x Plaintiff, by its attorneys, Roach & Murtha Attorneys at Law, P.C., hereby complains of the Defendant(s) as follows: 1. Plaintiff is a national banking association organized pursuant to Federal Law. 2. That the Defendant(s) resides in the county in which this action is brought; or that the Defendant(s) transacted business within the county in which this action is brought in person or through an agent and that the instant cause of action arose out of said transaction. FOR A FIRST CAUSE OF ACTION 3. That heretofore, the parties entered into a loan agreement. 4. Plaintiff duly performed all conditions on its part under the agreement. 5. Upon information and belief, Defendant(s) defaulted in payment and pursuant to the terms of the agreement now owes a balance of $15,002.34, no part of which has been paid despite due demand thereof. F_OR A SECOND CAUSE OF ACTION 6. That heretofore, Plaintiff rendered to Defendañt(s) full, just and true accounts of the indebtedness due and owing by Defendañt(s) as a result of the aforesaid transaction, which is the sum set forth above, and said statenients were delivered to, received, accepted and retained by Defendant(s) without objection, resulting in an account stated for the amount clairned above. 3 of 5 202101131376 01/13/2021 02:37:12 PM CIVIL 202101131376 INDEX NO. E2021000252 FILED: MONROE COUNTY CLERK 01/13/2021 11:25 AM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/13/2021 WHEREFORE, the Plaintiff, Accelerated Inventory Management, LLC, demands judgmeñt against the defendant(s) CHRISTINA FERGUSON-MCGILL DAVID MCGILL on the First and Second Cause of Action in the añicant of $15,002.34 less payments of $0.00, together with costs and disbursements of the within action. DATED: Farmingdale, New York 12/30/2020 By: Timothy J. Murtha Roach & Murtha Attorneys at Law, P.C. Attorneys for Plaintiff 500 Bi County Blvd Suite 475 Farmingdale, NY 11735 Telephone #: (516) 346-5400 4 of 5 202101131376 01/13/2021 02:37:12 PM CIVIL 202101131376 INDEX NO. E2021000252 FILED: MONROE COUNTY CLERK 01/13/2021 11:25 AM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/13/2021 Attorneys for Plaintiff STATE OF NEW YORK, COUNTY OF SUFFOLK The undersigned, an attorney at law and the Plaintiffs attorney, affirms the following to be true under the penalty of perjury: the foregoing complaint is true to my knowledge, except as to matters stated to be on information and belief, and as to those, I believe them to be true. The reason I am making this verification is I have all salient business records in my possession and have reviewed the same and/or the plaintiff does not have offices in the county where I maintain my office. Attorney Signature: Attorney Name (Print): Timothy Murtha Sworn to before me this 12/30/2020 tary Public LINDA A. CARBONETTO Of New York Notary Public, State Qualified in Suffolk County Reg. No. 01CA6055451 Comm. Expires February 26, 20 My 5 of 5