Preview
FILED: NIAGARA COUNTY CLERK 02/02/2021 01:31 PM INDEX NO. E174114/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/02/2021
CONSUMER CREDIT TRANSACTION
Date Purchased:
SUPREME COURT OF THE STATE OF NEW YORK Index №
COUNTY OF NIAGARA X
LVNV Funding LLC SUMMONS
Plaintiff, Plaintiff's Address:
-against- 6801 S. Cimarron Road, Suite 424-J
Las Vegas NV 89113
Seanna Bradley
Defendant(s).
The Basis of Venue is:
CPLR SEC. 503(f). Defendants
residence is in the County of
NIAGARA.
X
Defendant(s) Address:
DEF.#1 - 1712 PALISTER AVE, BARKER NY 14012-9693
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: January 12, 2021
Matter # 399770 ____________________________
Evridike Kollis Stephanie R. Vetch
Aksana Bondartseva Joseph J. Cassotta
Alex Pesochin Anthony Poulin
Stephen Einstein Krista Rose
Scott Morris
Tromberg, Morris & Poulin, PLLC f/k/a Stephen Einstein &
Associates, P.C.
Attorneys for the Plaintiff
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
*SM0000399770*
S_S_SUP-SUM
1 of 5
FILED: NIAGARA COUNTY CLERK 02/02/2021 01:31 PM INDEX NO. E174114/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/02/2021
SUPREME COURT OF THE STATE OF NEW YORK INDEX №:
COUNTY OF NIAGARA
LVNV Funding LLC
Plaintiff,
-against-
COMPLAINT
Seanna Bradley
Defendant(s).
Plaintiff, by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges that:
1. Plaintiff is an active foreign entity conducting business in the state of NV.
2. Upon information and belief, Defendant(s) reside or is employed in of the State of New York, County
of NIAGARA; or that the Defendant(s) transacted business with within the jurisdiction and venue where this
action is brought in person or through an agent and that the instant cause of action arose out of said
transaction.
AS AND FOR A FIRST CAUSE OF ACTION
3. Upon information and belief the Defendant(s) hereto entered into a Retail Charge Account
Agreement with Plaintiff‘s predecessor in interest, Credit One Bank, N.A., bearing account #
XXXXXXXXXXXX8600 wherein Defendant(s) agreed to pay Credit One Bank, N.A. all amounts
charged to said account by the authorized use thereof.
4. Upon information and belief, the agreement containing the terms and conditions governing the use
of the credit account, including terms of payment were delivered to the Defendant(s).
5. Plaintiff, as purchaser and assignee of the account herein, owns and retains all beneficial rights and
interests therein and Plaintiff has complete authority to settle, adjust, compromise and satisfy the same
and that the assignor has no further interest in said account for any purpose.
6. Upon information and belief this obligation originated with Credit One Bank, N.A. with a chain of
title as follows:
CREDIT ONE BANK, N.A.
MHC RECEIVABLES, LLC AND FNBM, LLC
SHERMAN ORIGINATOR III LLC
SHERMAN ORIGINATOR LLC
LVNV FUNDING LLC
7. Upon information and belief, Defendant(s) incurred charges by use of the said charge account, less
and credits, in the sum of $1,214.12, no part of which has been paid although duly demanded.
8. Upon information and belief the the date of default on this account was 9/20/2018 and the cause of
action asserted herein is not outside the applicable statute of limitations for enforcing the debt.
WHEREFORE, Plaintiff demands judgment against Defendant(s) in the sum of $1,214.12, plus costs
and disbursements.
CERTIFICATION: Deponent is an attorney associated with Tromberg, Morris & Poulin, PLLC f/k/a Stephen
Einstein & Associates, P.C. Deponent certifies that, to the best of their knowledge, information and belief,
formed after an inquiry reasonable under the circumstances, the presentation of the paper or the
contentions therein are not frivolous as defined in section 130-1.1(c) of the Chief Administrative Judge,
and an initiating pleading, the matter was not obtained through illegal conduct, and the matter was not
obtained in violation of Part 1200. Rule 4.5 of this Title. Affirmed this 12th day of January, 2021.
____________________________
Matter # 399770 Evridike Kollis Stephanie R. Vetch
Aksana Bondartseva Joseph J. Cassotta
Alex Pesochin Anthony Poulin
Stephen Einstein Krista Rose
Scott Morris
S_S_COM-RTL
2 of 5
FILED: NIAGARA COUNTY CLERK 02/02/2021 01:31 PM INDEX NO. E174114/2021
NYSCEF DOC. NO. 1 Index No. Year RECEIVED NYSCEF: 02/02/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NIAGARA
LVNV Funding LLC
Plaintiff
-against-
Seanna Bradley
Defendant(s)
SUMMONS AND VERIFIED COMPLAINT
Signature (Rule 130-1. 1-a)
____________________________
Evridike Kollis Stephanie R. Vetch
Aksana Bondartseva Joseph J. Cassotta
Alex Pesochin Anthony Poulin
Stephen Einstein Krista Rose
Scott Morris
LAW OFFICE OF
TROMBERG, MORRIS & POULIN, PLLC F/K/A STEPHEN EINSTEIN & ASSOCIATES,
P.C.
Attorney(s) for Plaintiff
Office and Post Office Address
39 Broadway, Suite 1250
New York, New York 10006
(212) 267-3550
Fax (212) 227-9656
Service of a copy of the within ___________________ is hereby admitted.
Dated,
Attorney(s) for Plaintiff(s)
Sir: Please take notice
NOTICE OF ENTRY:
That within is a (certified) true copy of a duly entered in the office of the clerk
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 _____ 2021 at __ A.M
Dated,
S_S_SUP-BB
3 of 5
FILED: NIAGARA COUNTY CLERK 02/02/2021 01:31 PM INDEX NO. E174114/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/02/2021
SUPREME COURT OF THE STATE OF NEW YORK INDEX №:
COUNTY OF NIAGARA
LVNV Funding LLC
Plaintiff,
-against-
Seanna Bradley
Defendant(s).
NOTICE OF COMMENCEMENT OF ACTION
SUBJECT TO MANDATORY ELECTRONIC FILING
PLEASE TAKE NOTICE that the matter captioned above has been commenced as an
electronically filed case in the New York State Courts Electronic Filing System (“NYSCEF”) as
required by CPLR § 2111 and Uniform Rule § 202.5-bb (MANDATORY ELECTRONIC FILING).
This notice is being served as required by that rule.
NYSCEF is designed for the electronic filing of documents with the County Clerk and the
court and for the electronic service of those documents, court documents, and court notices upon
counsel and unrepresented litigants who have consented to electronic filing.
Electronic filing offers significant benefits for attorneys and litigants, permitting papers to
be filed with the County Clerk and the court and served on other parties simply, conveniently, and
quickly. NYSCEF case documents are filed with the County Clerk and the court by filing on the
NYSCEF Website, which can be done at any time of the day or night on any day of the week. The
documents are served automatically on all consenting e-filers as soon as the document is uploaded
to the website, which sends out an immediate email notification of the filing.
The NYSCEF System charges no fees for filing, serving, or viewing the electronic case
record, nor does it charge any fees to print any filed documents. Normal filing fees must be paid,
but this can be done on-line.
Parties represented by an attorney: An attorney representing a party who is served with
this notice must either: 1) immediately record his or her representation within the e-filed matter on
the NYSCEF site; or 2) file the Notice of Opt-Out form with the clerk of the court where this action
is pending. Exemptions from mandatory e-filing are limited to attorneys who certify in good faith
that they lack the computer hardware and/or scanner and/or internet connection or that they lack
(along with all employees subject to their direction) the operational knowledge to comply with e-
filing requirements. [Section 202.5-bb(e)]
Parties not represented by an attorney: Unrepresented litigants are exempt from
efiling. They can serve and file documents in paper form and must be served with documents
in paper form. However, an unrepresented litigant may participate in e-filing. For information on
how to participate in e-filing, unrepresented litigants should contact the appropriate clerk in the
court where the action was filed or visit www.nycourts.gov/efileunrepresented. Unrepresented
litigants also are encouraged to visit www.nycourthelp.gov or contact the Help Center in the court
where the action was filed. An unrepresented litigant who consents to e-filing may cease
participation at any time. However, the other parties may continue to e-file their court documents in
the case.
S_S-EFI
4 of 5
FILED: NIAGARA COUNTY CLERK 02/02/2021 01:31 PM INDEX NO. E174114/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/02/2021
For additional information about electronic filing and to create a NYSCEF account, visit the
NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone: 646 -
386-3033; e-mail: efile@nycourts.gov).
Dated: January 12, 2021
____________________________
Evridike Kollis Stephanie R. Vetch
Aksana Bondartseva Joseph J. Cassotta
Alex Pesochin Anthony Poulin
Stephen Einstein Krista Rose
Scott Morris
39 Broadway, Suite 1250
New York, N.Y. 10006
Tromberg, Morris & Poulin, PLLC f/k/a Stephen Einstein &
Associates, P.C.
(212) 267-3550
www.tmppllc.com
TO: Seanna Bradley
1712 PALISTER AVE
BARKER NY 14012-9693
Matter # 399770
S_S-EFI
5 of 5
Preview
FILED: NIAGARA COUNTY CLERK 02/02/2021 01:31 PM INDEX NO. E174114/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/02/2021 CONSUMER CREDIT TRANSACTION Date Purchased: SUPREME COURT OF THE STATE OF NEW YORK Index № COUNTY OF NIAGARA X LVNV Funding LLC SUMMONS Plaintiff, Plaintiff's Address: -against- 6801 S. Cimarron Road, Suite 424-J Las Vegas NV 89113 Seanna Bradley Defendant(s). The Basis of Venue is: CPLR SEC. 503(f). Defendants residence is in the County of NIAGARA. X Defendant(s) Address: DEF.#1 - 1712 PALISTER AVE, BARKER NY 14012-9693 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: January 12, 2021 Matter # 399770 ____________________________ Evridike Kollis Stephanie R. Vetch Aksana Bondartseva Joseph J. Cassotta Alex Pesochin Anthony Poulin Stephen Einstein Krista Rose Scott Morris Tromberg, Morris & Poulin, PLLC f/k/a Stephen Einstein & Associates, P.C. Attorneys for the Plaintiff 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 *SM0000399770* S_S_SUP-SUM 1 of 5 FILED: NIAGARA COUNTY CLERK 02/02/2021 01:31 PM INDEX NO. E174114/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/02/2021 SUPREME COURT OF THE STATE OF NEW YORK INDEX №: COUNTY OF NIAGARA LVNV Funding LLC Plaintiff, -against- COMPLAINT Seanna Bradley Defendant(s). Plaintiff, by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges that: 1. Plaintiff is an active foreign entity conducting business in the state of NV. 2. Upon information and belief, Defendant(s) reside or is employed in of the State of New York, County of NIAGARA; or that the Defendant(s) transacted business with within the jurisdiction and venue where this action is brought in person or through an agent and that the instant cause of action arose out of said transaction. AS AND FOR A FIRST CAUSE OF ACTION 3. Upon information and belief the Defendant(s) hereto entered into a Retail Charge Account Agreement with Plaintiff‘s predecessor in interest, Credit One Bank, N.A., bearing account # XXXXXXXXXXXX8600 wherein Defendant(s) agreed to pay Credit One Bank, N.A. all amounts charged to said account by the authorized use thereof. 4. Upon information and belief, the agreement containing the terms and conditions governing the use of the credit account, including terms of payment were delivered to the Defendant(s). 5. Plaintiff, as purchaser and assignee of the account herein, owns and retains all beneficial rights and interests therein and Plaintiff has complete authority to settle, adjust, compromise and satisfy the same and that the assignor has no further interest in said account for any purpose. 6. Upon information and belief this obligation originated with Credit One Bank, N.A. with a chain of title as follows: CREDIT ONE BANK, N.A. MHC RECEIVABLES, LLC AND FNBM, LLC SHERMAN ORIGINATOR III LLC SHERMAN ORIGINATOR LLC LVNV FUNDING LLC 7. Upon information and belief, Defendant(s) incurred charges by use of the said charge account, less and credits, in the sum of $1,214.12, no part of which has been paid although duly demanded. 8. Upon information and belief the the date of default on this account was 9/20/2018 and the cause of action asserted herein is not outside the applicable statute of limitations for enforcing the debt. WHEREFORE, Plaintiff demands judgment against Defendant(s) in the sum of $1,214.12, plus costs and disbursements. CERTIFICATION: Deponent is an attorney associated with Tromberg, Morris & Poulin, PLLC f/k/a Stephen Einstein & Associates, P.C. Deponent certifies that, to the best of their knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the presentation of the paper or the contentions therein are not frivolous as defined in section 130-1.1(c) of the Chief Administrative Judge, and an initiating pleading, the matter was not obtained through illegal conduct, and the matter was not obtained in violation of Part 1200. Rule 4.5 of this Title. Affirmed this 12th day of January, 2021. ____________________________ Matter # 399770 Evridike Kollis Stephanie R. Vetch Aksana Bondartseva Joseph J. Cassotta Alex Pesochin Anthony Poulin Stephen Einstein Krista Rose Scott Morris S_S_COM-RTL 2 of 5 FILED: NIAGARA COUNTY CLERK 02/02/2021 01:31 PM INDEX NO. E174114/2021 NYSCEF DOC. NO. 1 Index No. Year RECEIVED NYSCEF: 02/02/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NIAGARA LVNV Funding LLC Plaintiff -against- Seanna Bradley Defendant(s) SUMMONS AND VERIFIED COMPLAINT Signature (Rule 130-1. 1-a) ____________________________ Evridike Kollis Stephanie R. Vetch Aksana Bondartseva Joseph J. Cassotta Alex Pesochin Anthony Poulin Stephen Einstein Krista Rose Scott Morris LAW OFFICE OF TROMBERG, MORRIS & POULIN, PLLC F/K/A STEPHEN EINSTEIN & ASSOCIATES, P.C. Attorney(s) for Plaintiff Office and Post Office Address 39 Broadway, Suite 1250 New York, New York 10006 (212) 267-3550 Fax (212) 227-9656 Service of a copy of the within ___________________ is hereby admitted. Dated, Attorney(s) for Plaintiff(s) Sir: Please take notice NOTICE OF ENTRY: That within is a (certified) true copy of a duly entered in the office of the clerk 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 _____ 2021 at __ A.M Dated, S_S_SUP-BB 3 of 5 FILED: NIAGARA COUNTY CLERK 02/02/2021 01:31 PM INDEX NO. E174114/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/02/2021 SUPREME COURT OF THE STATE OF NEW YORK INDEX №: COUNTY OF NIAGARA LVNV Funding LLC Plaintiff, -against- Seanna Bradley Defendant(s). NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING PLEASE TAKE NOTICE that the matter captioned above has been commenced as an electronically filed case in the New York State Courts Electronic Filing System (“NYSCEF”) as required by CPLR § 2111 and Uniform Rule § 202.5-bb (MANDATORY ELECTRONIC FILING). This notice is being served as required by that rule. NYSCEF is designed for the electronic filing of documents with the County Clerk and the court and for the electronic service of those documents, court documents, and court notices upon counsel and unrepresented litigants who have consented to electronic filing. Electronic filing offers significant benefits for attorneys and litigants, permitting papers to be filed with the County Clerk and the court and served on other parties simply, conveniently, and quickly. NYSCEF case documents are filed with the County Clerk and the court by filing on the NYSCEF Website, which can be done at any time of the day or night on any day of the week. The documents are served automatically on all consenting e-filers as soon as the document is uploaded to the website, which sends out an immediate email notification of the filing. The NYSCEF System charges no fees for filing, serving, or viewing the electronic case record, nor does it charge any fees to print any filed documents. Normal filing fees must be paid, but this can be done on-line. Parties represented by an attorney: An attorney representing a party who is served with this notice must either: 1) immediately record his or her representation within the e-filed matter on the NYSCEF site; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is pending. Exemptions from mandatory e-filing are limited to attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or internet connection or that they lack (along with all employees subject to their direction) the operational knowledge to comply with e- filing requirements. [Section 202.5-bb(e)] Parties not represented by an attorney: Unrepresented litigants are exempt from efiling. They can serve and file documents in paper form and must be served with documents in paper form. However, an unrepresented litigant may participate in e-filing. For information on how to participate in e-filing, unrepresented litigants should contact the appropriate clerk in the court where the action was filed or visit www.nycourts.gov/efileunrepresented. Unrepresented litigants also are encouraged to visit www.nycourthelp.gov or contact the Help Center in the court where the action was filed. An unrepresented litigant who consents to e-filing may cease participation at any time. However, the other parties may continue to e-file their court documents in the case. S_S-EFI 4 of 5 FILED: NIAGARA COUNTY CLERK 02/02/2021 01:31 PM INDEX NO. E174114/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/02/2021 For additional information about electronic filing and to create a NYSCEF account, visit the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone: 646 - 386-3033; e-mail: efile@nycourts.gov). Dated: January 12, 2021 ____________________________ Evridike Kollis Stephanie R. Vetch Aksana Bondartseva Joseph J. Cassotta Alex Pesochin Anthony Poulin Stephen Einstein Krista Rose Scott Morris 39 Broadway, Suite 1250 New York, N.Y. 10006 Tromberg, Morris & Poulin, PLLC f/k/a Stephen Einstein & Associates, P.C. (212) 267-3550 www.tmppllc.com TO: Seanna Bradley 1712 PALISTER AVE BARKER NY 14012-9693 Matter # 399770 S_S-EFI 5 of 5