Preview
FILED: LIVINGSTON COUNTY CLERK 01/22/2021 02:19 PM INDEX NO. 000045-2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/22/2021
Andrea K. Bailey, Acting County Clerk
Livingston County Government Center
6 Court Street, Room 201
Geneseo, New York 14454
(585) 243-7010 ~ Fax (585) 243-7928
Livingston County Clerk Recording Page
Received From: Return To:
ELIZABETH EMILY DEERY ELIZABETH EMILY DEERY
100 CORPORATE WOODS 100 CORPORATE WOODS
SUITE 230 SUITE 230
ROCHESTER, NY 14623 ROCHESTER, NY 14623
Document Type: CIVIL ACTION - MISC Document Desc: SUMMONS + COMPLAINT
Plaintiff Defendant
AMERICAN EXPRESS NATIONAL BANK BRADSHAW ROBERT
AKA ROBERT A BRADSHAW
Recorded Information:
State of New York
Index #: 000045-2021 County of Livingston
EFiling through NYSCEF
Acting Livingston County Clerk
This sheet constitutes the Clerk’s endorsement required by section 319 of the Real Property Law of the State of New York
AKB
Do Not1 ofDetach
4
FILED: LIVINGSTON COUNTY CLERK 01/22/2021 02:19 PM INDEX
Index NO.
# 000045-2021
: 000045-2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/22/2021
CONSUMER CREDIT TRANSACTION
SUPREME COURT
COUNTY OF LIVINGSTON STATE OF NEW YORK
AMERICAN EXPRESS NATIONAL BANK, Index No.
Plaintiff
- -
vs. S U M M O N S
ROBERT BRADSHAW AKA ROBERT A The basis of the venue designated is
BRADSHAW, Defendant's residence.
2820 NUNDA MOUNT MORRIS Plaintiff's address:
TL RD 115 W. Towne Ridge Parkway
NUNDA, NY 14517
Sandy, UT 84070
Defendant(s)
__
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 attorneys for plaintiff within 20 days after the service of the
Summons, exclusive of the days of service (or within 30 days after the service is complete if this
summons is not personally delivered to you within the State of New York); and in case of your
failure to appear or answer, judgment will be taken agaiñst you by default for the relief
demanded herein. The basis of venue is the Defendant(s) residence.
DATED: Ï
[ ]JAWN P. VERHAGEN, E
[ ]LARRY T. POWELL, ES
LIZABETH DEERY, ESQ.
[ ]JOSEPH JAKAS, ESQ.
[ ]ELIZABETH CLARKE, ESQ.
ZWICKER & ASSOCIATES, P.C.
A Law Firm Engaged in Debt Collection
100 CORPORATE WOODS, SUITE 230
ROCHESTER, NY 14623
(585)427-0482
2 of 4
Index NO.
INDEX #:000045-2021
000045-2021
FILED: LIVINGSTON COUNTY CLERK 01/22/2021 02:19 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/22/2021
SUPREME COURT
COUNTY OF LIVINGSTON STATE OF NEW YORK
AMERICAN EXPRESS NATIONAL BANK, Index No.
Plaintiff,
vs. COMPLAINT
ROBERT BRADSHAW AKA ROBERT A
BRADSHAW,
Defendant(s).
Plaintiff, AMERICAN EXPRESS NATIONAL BANK, by and through its attorneys,
Zwicker & Associates, P.C., for its Complaint against ROBERT BRADSHAW AKA ROBERT A
BRADSHAW ("Defendant(s)"), states as follows:
1. Plaintiff is a National Bank located in Utah.
2. Defeiideit(s) reside(s) and/or maintain(s) an address and/or domicile sufficient to allow this
Court to maintain jurisdiction and venue of Plaintiff's claims.
3. The principal damage amount sought by Plaintiff in this Complaiñt is within this Court's
monetary jurisdictional limit.
4. Defendant(s) entered into a loan agreement (hereafter referred to as "Agreement"). True and
exact copies of the loan documents are attached hereto and marked Exhibit A.
5. Funds were disbursed pursuant to the terms of the Agreement or as requested by
Defendant(s).
6. The loan is identified with account number ending in 1009.
7. Defendant(s) defaulted on the terms of the Agreement when Defendant(s) failed to make
payments pursuant to the terms of the Agreement.
8. As a result of the default by Defendant(s), Plaintiff has accelerated the full balañce due and
owing pursuant to the terms of the Agreement.
9. Demand was made upon Defendant(s).
10. As of today's date, Defendant(s) has/have failed to pay Plaintiff pursuant to the terms of the
Agreement.
11. As Defendant(s) have materially breached the terms of the Agreement, the balance due and
owing to Plaintiff after deducting alljust and lawful offsets, payment, and credits is the sum of
$11,061.00. Account statemcñt records or balance history records substantiating the balance due
are attached hereto and marked Exhibit B.
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FILED: LIVINGSTON COUNTY CLERK 01/22/2021 02:19 PM INDEXIndex NO.
#: 000045-2021
000045-2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/22/2021
RELIEF REQUESTED
WHEREFORE, Plaintiff requests thisHonorable Court to enter a Judgment awarding the
following:
a) The balance due and owing of $11,061.00,
b) Court costs to the extent permitted by applicable law.
Respectfully submitted,
Zwicker & Associates, P.C.
By:
[ ]JAŠ0N P. VERHA"GEN, ESQ., 429 08
]LARRY T. POWELL, ESQ., # 54417
IZABETH DEERY, ESQ., # 91
OSEPH JAKAS, ESQ., #5154521
[ ]ELIZABETH CLARKE, ESQ., #5046719
ZWICKER & ASSOCIATES, P.C.
A Law Firm Engaged in Debt Collection
100 CORPORATE WOODS, SUITE 230
ROCHESTER, NY 14623
(585)427-0482
Attorney for Plaintiff
Dated:
4 of 4
Preview
FILED: LIVINGSTON COUNTY CLERK 01/22/2021 02:19 PM INDEX NO. 000045-2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/22/2021 Andrea K. Bailey, Acting County Clerk Livingston County Government Center 6 Court Street, Room 201 Geneseo, New York 14454 (585) 243-7010 ~ Fax (585) 243-7928 Livingston County Clerk Recording Page Received From: Return To: ELIZABETH EMILY DEERY ELIZABETH EMILY DEERY 100 CORPORATE WOODS 100 CORPORATE WOODS SUITE 230 SUITE 230 ROCHESTER, NY 14623 ROCHESTER, NY 14623 Document Type: CIVIL ACTION - MISC Document Desc: SUMMONS + COMPLAINT Plaintiff Defendant AMERICAN EXPRESS NATIONAL BANK BRADSHAW ROBERT AKA ROBERT A BRADSHAW Recorded Information: State of New York Index #: 000045-2021 County of Livingston EFiling through NYSCEF Acting Livingston County Clerk This sheet constitutes the Clerk’s endorsement required by section 319 of the Real Property Law of the State of New York AKB Do Not1 ofDetach 4 FILED: LIVINGSTON COUNTY CLERK 01/22/2021 02:19 PM INDEX Index NO. # 000045-2021 : 000045-2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/22/2021 CONSUMER CREDIT TRANSACTION SUPREME COURT COUNTY OF LIVINGSTON STATE OF NEW YORK AMERICAN EXPRESS NATIONAL BANK, Index No. Plaintiff - - vs. S U M M O N S ROBERT BRADSHAW AKA ROBERT A The basis of the venue designated is BRADSHAW, Defendant's residence. 2820 NUNDA MOUNT MORRIS Plaintiff's address: TL RD 115 W. Towne Ridge Parkway NUNDA, NY 14517 Sandy, UT 84070 Defendant(s) __ 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 attorneys for plaintiff within 20 days after the service of the Summons, exclusive of the days of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken agaiñst you by default for the relief demanded herein. The basis of venue is the Defendant(s) residence. DATED: Ï [ ]JAWN P. VERHAGEN, E [ ]LARRY T. POWELL, ES LIZABETH DEERY, ESQ. [ ]JOSEPH JAKAS, ESQ. [ ]ELIZABETH CLARKE, ESQ. ZWICKER & ASSOCIATES, P.C. A Law Firm Engaged in Debt Collection 100 CORPORATE WOODS, SUITE 230 ROCHESTER, NY 14623 (585)427-0482 2 of 4 Index NO. INDEX #:000045-2021 000045-2021 FILED: LIVINGSTON COUNTY CLERK 01/22/2021 02:19 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/22/2021 SUPREME COURT COUNTY OF LIVINGSTON STATE OF NEW YORK AMERICAN EXPRESS NATIONAL BANK, Index No. Plaintiff, vs. COMPLAINT ROBERT BRADSHAW AKA ROBERT A BRADSHAW, Defendant(s). Plaintiff, AMERICAN EXPRESS NATIONAL BANK, by and through its attorneys, Zwicker & Associates, P.C., for its Complaint against ROBERT BRADSHAW AKA ROBERT A BRADSHAW ("Defendant(s)"), states as follows: 1. Plaintiff is a National Bank located in Utah. 2. Defeiideit(s) reside(s) and/or maintain(s) an address and/or domicile sufficient to allow this Court to maintain jurisdiction and venue of Plaintiff's claims. 3. The principal damage amount sought by Plaintiff in this Complaiñt is within this Court's monetary jurisdictional limit. 4. Defendant(s) entered into a loan agreement (hereafter referred to as "Agreement"). True and exact copies of the loan documents are attached hereto and marked Exhibit A. 5. Funds were disbursed pursuant to the terms of the Agreement or as requested by Defendant(s). 6. The loan is identified with account number ending in 1009. 7. Defendant(s) defaulted on the terms of the Agreement when Defendant(s) failed to make payments pursuant to the terms of the Agreement. 8. As a result of the default by Defendant(s), Plaintiff has accelerated the full balañce due and owing pursuant to the terms of the Agreement. 9. Demand was made upon Defendant(s). 10. As of today's date, Defendant(s) has/have failed to pay Plaintiff pursuant to the terms of the Agreement. 11. As Defendant(s) have materially breached the terms of the Agreement, the balance due and owing to Plaintiff after deducting alljust and lawful offsets, payment, and credits is the sum of $11,061.00. Account statemcñt records or balance history records substantiating the balance due are attached hereto and marked Exhibit B. 3 of 4 FILED: LIVINGSTON COUNTY CLERK 01/22/2021 02:19 PM INDEXIndex NO. #: 000045-2021 000045-2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/22/2021 RELIEF REQUESTED WHEREFORE, Plaintiff requests thisHonorable Court to enter a Judgment awarding the following: a) The balance due and owing of $11,061.00, b) Court costs to the extent permitted by applicable law. Respectfully submitted, Zwicker & Associates, P.C. By: [ ]JAŠ0N P. VERHA"GEN, ESQ., 429 08 ]LARRY T. POWELL, ESQ., # 54417 IZABETH DEERY, ESQ., # 91 OSEPH JAKAS, ESQ., #5154521 [ ]ELIZABETH CLARKE, ESQ., #5046719 ZWICKER & ASSOCIATES, P.C. A Law Firm Engaged in Debt Collection 100 CORPORATE WOODS, SUITE 230 ROCHESTER, NY 14623 (585)427-0482 Attorney for Plaintiff Dated: 4 of 4