On March 15, 2021 a
Complaint,Petition
was filed
involving a dispute between
Lvnv Funding Llc,
and
Robert Brooks,
for Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff
in the District Court of Columbia County.
Preview
FILED: COLUMBIA COUNTY CLERK 03/15/2021 12:39 PM INDEX NO. E012021016652
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/15/2021
SUPREME COURT OF THE STATE OF NEW YORK CONSUMER CREDIT TRANSACTION
COUNTY OF COLUMBIA Our File No. RC12314
Court Index No.
LVNV FUNDING LLC Date Purchased:
SUMMONS
Plaintiff Plaintiff's address:
-against-
55 Beattle Place, Suite 110
Robert Brooks Greenville, SC 29601
1111110Il1l|KI11110111101|l|lKI1111111
Defendant (s)
IlllKIIIIIIlllIllKIllIIIllll|IIIIlll|
1111K11111111111101l11ll1111111!l
l11111111011111
The basis 111111111111101111ll111
of venue is:
The defendant(s) reside in the State of New York, County of COLUMBIA
To the above named defendant (s):
PLEASE TAKE NOTICE THAT YOU ARE HEREBY SUMMONED
to answer the complaint of the Plaintiff herein and to serve a copy of your answer on the Plaintiff at the
address indicated below within 20 days after service of this Summons (not counting the date of service
itself), or within 30 days after service is complete ifthe Summons is not delivered personally to you within
the State of New York.
YOU ARE HEREBY NOTIFIED THAT should you fail to answer, a judgment will be entered against you by
default for the relief demanded in the complaint.
Dated: February 25, 2021
KIRSCIIENBAUM & PHILLIPS, P.C.
Attomfys- '
tiff
BY:
EPHANE PLANTIN
40 Dani treet, Suite 7
P.O. ox 9000
Farmingdale, NY 11735-9000
(516) 746-1144
Defendant (s) Address:
1905 State Route 66 Stop 16 Ghent NY 12075-2505
WE ARE DEBT COLLECTORS-THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
FILED 3/15/2021 1 of 2
FILED: COLUMBIA COUNTY CLERK 03/15/2021 12:39 PM INDEX NO. E012021016652
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/15/2021
SUPREME COURT OF THE STATE OF NEW YORK Our File No. RC12314
COUNTY OF COLUMBIA
LVNV FUNDING LLC Court Index No.
. . Plaintiff COMPLAINT
-against-
Robert Brooks ************6467
Defendant (s)
Plaintiff, by itsattorneys, complaining of the defendant(s), respectfully alleges:
1. Plaintiff is ajimitedjiability-company._Rlaintiff-is.licensed-as a debt collector by the New York City
Department of Consumer Affairs, license number 1326179.
2. That the defendant(s) resides in the county in which this action is brought.
3. On information and belief the causes of action asserted herein are not outside the applicable
statute of limitations. The date of default on this account was October 8, 2018.
FOR A FIRST CAUSE OF ACTION
4. The defendant(s) heretofore entered into a credit card agreement with the original creditor, Credit
One Bank, N.A..
5. Under the terms of the agreement the defendant(s) were authorized to, and did make, charges
purchases and/or obtained cash advances and were obligated to repay the same together with applicable
interest however, defendant(s) defaulted in making payments as they became due leaving a final balance
due and owing of $1,785.77 as of April 9, 2019. ..
. 6. . Plaintiffis the purchaser of this account where the original account number ended in
************6467 and is authorized to proceed with this action. The date on which the balance herein
became due was April 9, 2019 and the Chain of Title, with the date of each sale or assignment of the
account, is as follows:
Credit One Bank, N.A. April 30, 2019 [original creditor and date of sale/assignment]
MHC Receivables, LLC and FNBM, LLC May 14, 2019 [debt seller and date of sale/assignment]
Sherman Originator Ill LLC May 14, 2019 [debt seller and date of safe/assignment]
Sherman Originator LLC May 14, 2019 [debt selier and date of sale/assignment]
7. Defendant(s) is/are liable to plaintiff as a result of defendant(s) breach of agreement.
FOR A SECOND CAUSE OF ACTION
8. That heretofore, plaintiff, or the assignor, rendered to defendant(s) monthly, full,just and true
accounts of the indebtedness due and owing by defendant(s) as a result of the aforesaid transaction, which
is the sum set forth above, and said statements were delivered to defendant(s) without objection, resulting
in an account stated for the amount claimed above.
WHEREFORE, plaintiff demands judgment against the defendant(s) for the sum of $1,785.77 with
interest from April 9, 2019, togeth costs and disbursements.
2/25/21 KIRSCHENBAUM & PHILLIPS, P.C.
Attorneys for Plaintiff
STEPRA E PLANTIN
40 Daniei Street, Suite 7
P.O. Box 9000
Farmingdale, NY 11735-9000
(516) 746-1144
2 of 2
Document Filed Date
March 15, 2021
Case Filing Date
March 15, 2021
Category
Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff
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Preview
FILED: COLUMBIA COUNTY CLERK 03/15/2021 12:39 PM INDEX NO. E012021016652 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/15/2021 SUPREME COURT OF THE STATE OF NEW YORK CONSUMER CREDIT TRANSACTION COUNTY OF COLUMBIA Our File No. RC12314 Court Index No. LVNV FUNDING LLC Date Purchased: SUMMONS Plaintiff Plaintiff's address: -against- 55 Beattle Place, Suite 110 Robert Brooks Greenville, SC 29601 1111110Il1l|KI11110111101|l|lKI1111111 Defendant (s) IlllKIIIIIIlllIllKIllIIIllll|IIIIlll| 1111K11111111111101l11ll1111111!l l11111111011111 The basis 111111111111101111ll111 of venue is: The defendant(s) reside in the State of New York, County of COLUMBIA To the above named defendant (s): PLEASE TAKE NOTICE THAT YOU ARE HEREBY SUMMONED to answer the complaint of the Plaintiff herein and to serve a copy of your answer on the Plaintiff at the address indicated below within 20 days after service of this Summons (not counting the date of service itself), or within 30 days after service is complete ifthe Summons is not delivered personally to you within the State of New York. YOU ARE HEREBY NOTIFIED THAT should you fail to answer, a judgment will be entered against you by default for the relief demanded in the complaint. Dated: February 25, 2021 KIRSCIIENBAUM & PHILLIPS, P.C. Attomfys- ' tiff BY: EPHANE PLANTIN 40 Dani treet, Suite 7 P.O. ox 9000 Farmingdale, NY 11735-9000 (516) 746-1144 Defendant (s) Address: 1905 State Route 66 Stop 16 Ghent NY 12075-2505 WE ARE DEBT COLLECTORS-THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. FILED 3/15/2021 1 of 2 FILED: COLUMBIA COUNTY CLERK 03/15/2021 12:39 PM INDEX NO. E012021016652 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/15/2021 SUPREME COURT OF THE STATE OF NEW YORK Our File No. RC12314 COUNTY OF COLUMBIA LVNV FUNDING LLC Court Index No. . . Plaintiff COMPLAINT -against- Robert Brooks ************6467 Defendant (s) Plaintiff, by itsattorneys, complaining of the defendant(s), respectfully alleges: 1. Plaintiff is ajimitedjiability-company._Rlaintiff-is.licensed-as a debt collector by the New York City Department of Consumer Affairs, license number 1326179. 2. That the defendant(s) resides in the county in which this action is brought. 3. On information and belief the causes of action asserted herein are not outside the applicable statute of limitations. The date of default on this account was October 8, 2018. FOR A FIRST CAUSE OF ACTION 4. The defendant(s) heretofore entered into a credit card agreement with the original creditor, Credit One Bank, N.A.. 5. Under the terms of the agreement the defendant(s) were authorized to, and did make, charges purchases and/or obtained cash advances and were obligated to repay the same together with applicable interest however, defendant(s) defaulted in making payments as they became due leaving a final balance due and owing of $1,785.77 as of April 9, 2019. .. . 6. . Plaintiffis the purchaser of this account where the original account number ended in ************6467 and is authorized to proceed with this action. The date on which the balance herein became due was April 9, 2019 and the Chain of Title, with the date of each sale or assignment of the account, is as follows: Credit One Bank, N.A. April 30, 2019 [original creditor and date of sale/assignment] MHC Receivables, LLC and FNBM, LLC May 14, 2019 [debt seller and date of sale/assignment] Sherman Originator Ill LLC May 14, 2019 [debt seller and date of safe/assignment] Sherman Originator LLC May 14, 2019 [debt selier and date of sale/assignment] 7. Defendant(s) is/are liable to plaintiff as a result of defendant(s) breach of agreement. FOR A SECOND CAUSE OF ACTION 8. That heretofore, plaintiff, or the assignor, rendered to defendant(s) monthly, full,just and true accounts of the indebtedness due and owing by defendant(s) as a result of the aforesaid transaction, which is the sum set forth above, and said statements were delivered to defendant(s) without objection, resulting in an account stated for the amount claimed above. WHEREFORE, plaintiff demands judgment against the defendant(s) for the sum of $1,785.77 with interest from April 9, 2019, togeth costs and disbursements. 2/25/21 KIRSCHENBAUM & PHILLIPS, P.C. Attorneys for Plaintiff STEPRA E PLANTIN 40 Daniei Street, Suite 7 P.O. Box 9000 Farmingdale, NY 11735-9000 (516) 746-1144 2 of 2