On March 18, 2021 a
Complaint,Petition
was filed
involving a dispute between
Jpmorgan Chase Bank, N.A.,
and
Crystal Cottrell,
for Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
in the District Court of Seneca County.
Preview
FILED: SENECA COUNTY CLERK 03/18/2021 12:27 PM INDEX NO. 20210120
NYSCEFSUPREME COURT
DOC. NO. 1 OF THE STATE OF NEW YORK Index No. RECEIVED NYSCEF: 03/18/2021
COUNTY OF SENECA Date Filed: ________________
----------------------------------------
JPMORGAN CHASE BANK, N.A.
SUMMONS (ORIGINAL)
Plaintiff
-against-
CRYSTAL COTTRELL The basis of venue is:
DEFENDANT'S RESIDENCE
Defendant(s) Plaintiff's Residence:
---------------------------------------- 201 N WALNUT ST
WILMINGTON, DE 19801
CONSUMER CREDIT TRANSACTION County of NEW CASTLE
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, or, if the complaint is not served with this summons
to serve a notice of appearance, on the Plaintiff's Attorney(s) within
TWENTY days after the service of this summons, exclusive of the day of
service (or within THIRTY 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
against you by default for the relief demanded herein.
Dated: Islandia, New York
MARCH 18, 2021 RUBIN & ROTHMAN, LLC
Attorneys for Plaintiff
1787 Veterans Highway
Islandia, N.Y. 11749
(631) 234-1500
DEFENDANT(S) ADDRESS:
CRYSTAL COTTRELL
447 STATE ROUTE 318 PHELPS, NY 14532-9314
WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
NYC DCA LIC. 2045512
Our File No. 1385063 Y 19 0- 0 V SZV 000
000005998992
1 of 3
*000005998992*
FILED: SENECA COUNTY CLERK 03/18/2021 12:27 PM INDEX NO. 20210120
NYSCEFSUPREME COURT
DOC. NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 03/18/2021
COUNTY OF SENECA Index No.
----------------------------------------
JPMORGAN CHASE BANK, N.A.
Plaintiff
-against- COMPLAINT (ORIGINAL)
CRYSTAL COTTRELL
Defendant(s)
----------------------------------------
Plaintiff, by its attorneys, complaining of the defendant(s), alleges:
AS AND FOR A FIRST CAUSE OF ACTION
1. Defendant(s) resides in the county in which this action is brought;
or transacted business in the county in which this action is brought
in person or through an agent, or this cause of action arose out of
said transaction. Plaintiff is not required to be licensed by the
NYC Dept of Consumer Affairs because it is the original creditor.
2. Plaintiff is a national banking association chartered under the laws
of the United States.
3. Defendant(s) used a credit card issued by plaintiff and agreed to
make payments for goods and services charged and/or cash advances
made upon such card.
4. Defendant(s) failed to make the payments due pursuant to such agreement,
and $ 5,041.65 is now due and owing to plaintiff from defendant(s).
WHEREFORE, plaintiff requests judgment against defendant(s) in the sum of
$ 5,041.65.
RUBIN & ROTHMAN, LLC
MARCH 18, 2021 Attorneys for Plaintiff
1787 Veterans Highway
Islandia, NY 11749
(631) 234-1500
Deponent is an attorney associated with Rubin & Rothman, LLC. To the best
of deponent's knowledge, information and belief, formed after an inquiry
reasonable under the circumstances, the summons and complaint or the
contentions therein are not frivolous as defined in section 130-1.1(c)
of the Rules of the Chief Adm. and the matter was not obtained through
illegal conduct or in violation of 22 NYCRR 1200, Rule 4.5.
Dated: MARCH 18, 2021 ______________________
JACQUELINE TIERNEY
WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
NYC DCA LIC. 2045512
Our File No. 1385063 X 20 0- 0 V SZV 000
000005998992
2 of 3
*000005998992*
FILED: SENECA COUNTY CLERK 03/18/2021 12:27 PM INDEX NO. 20210120
NYSCEFSUPREME COURT
DOC. NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 03/18/2021
COUNTY OF SENECA
----------------------------------------
JPMORGAN CHASE BANK, N.A.
Plaintiff
-against- Index No.
CRYSTAL COTTRELL
Defendant(s)
----------------------------------------
NOTICE OF COMMENCEMENT OF ACTION
SUBJECT TO MANDATORY ELECTRONIC FILING
PLEASE TAKE NOTICE that the matter captioned above, which has been
commenced by filing of the accompanying documents with the County Clerk, is
subject to mandatory electronic filing pursuant to Section 202.5-bb of the
Uniform Rules for the Trial Courts. This notice is being served as
required by Subdivision (b)(3) of that Section.
The New York State Courts Electronic Filing System ("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 docu-
ments, and court notices upon counsel and self-represented parties. Counsel
and/or parties who do not notify the court of a claimed exemption (see
below) as required by Section 202.5-bb(e) must immediately record their
representation within the e-filed matter on the Consent page in NYSCEF.
Failure to do so may result in an inability to receive electronic notice of
document filings.
Exemptions from mandatory e-filing are limited to: 1)attorneys who
certify in good faith that they lack the computer equipment and (along with
all employees) the requisite knowledge to comply; and 2) self-represented
parties who choose not to participate in e-filing. For additional informa-
tion about electronic filing, including access to Section 202.5-bb, consult
the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource
Center at 646-386-3033 or efile@courts.state.ny.us.
Dated: Islandia, New York
MARCH 18, 2021
____________________ RUBIN & ROTHMAN, LLC
JACQUELINE TIERNEY 1787 VETERANS HIGHWAY
RUBIN & ROTHMAN, LLC ISLANDIA, NY 11749
(631) 234-1500
NYDOCS@RUBINROTHMAN.COM
To: CRYSTAL COTTRELL
447 STATE ROUTE 318
PHELPS, NY 14532-9314
WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
NYC DCA LIC. 2045512
Our File No. 1385063 X 21 0- 0 V SZV 000
000005998992
3 of 3
*000005998992*
Document Filed Date
March 18, 2021
Case Filing Date
March 18, 2021
Category
Other Matters - Consumer Credit (Card) Original Creditor Plaintiff
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Preview
FILED: SENECA COUNTY CLERK 03/18/2021 12:27 PM INDEX NO. 20210120 NYSCEFSUPREME COURT DOC. NO. 1 OF THE STATE OF NEW YORK Index No. RECEIVED NYSCEF: 03/18/2021 COUNTY OF SENECA Date Filed: ________________ ---------------------------------------- JPMORGAN CHASE BANK, N.A. SUMMONS (ORIGINAL) Plaintiff -against- CRYSTAL COTTRELL The basis of venue is: DEFENDANT'S RESIDENCE Defendant(s) Plaintiff's Residence: ---------------------------------------- 201 N WALNUT ST WILMINGTON, DE 19801 CONSUMER CREDIT TRANSACTION County of NEW CASTLE 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, or, if the complaint is not served with this summons to serve a notice of appearance, on the Plaintiff's Attorney(s) within TWENTY days after the service of this summons, exclusive of the day of service (or within THIRTY 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 against you by default for the relief demanded herein. Dated: Islandia, New York MARCH 18, 2021 RUBIN & ROTHMAN, LLC Attorneys for Plaintiff 1787 Veterans Highway Islandia, N.Y. 11749 (631) 234-1500 DEFENDANT(S) ADDRESS: CRYSTAL COTTRELL 447 STATE ROUTE 318 PHELPS, NY 14532-9314 WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. NYC DCA LIC. 2045512 Our File No. 1385063 Y 19 0- 0 V SZV 000 000005998992 1 of 3 *000005998992* FILED: SENECA COUNTY CLERK 03/18/2021 12:27 PM INDEX NO. 20210120 NYSCEFSUPREME COURT DOC. NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 03/18/2021 COUNTY OF SENECA Index No. ---------------------------------------- JPMORGAN CHASE BANK, N.A. Plaintiff -against- COMPLAINT (ORIGINAL) CRYSTAL COTTRELL Defendant(s) ---------------------------------------- Plaintiff, by its attorneys, complaining of the defendant(s), alleges: AS AND FOR A FIRST CAUSE OF ACTION 1. Defendant(s) resides in the county in which this action is brought; or transacted business in the county in which this action is brought in person or through an agent, or this cause of action arose out of said transaction. Plaintiff is not required to be licensed by the NYC Dept of Consumer Affairs because it is the original creditor. 2. Plaintiff is a national banking association chartered under the laws of the United States. 3. Defendant(s) used a credit card issued by plaintiff and agreed to make payments for goods and services charged and/or cash advances made upon such card. 4. Defendant(s) failed to make the payments due pursuant to such agreement, and $ 5,041.65 is now due and owing to plaintiff from defendant(s). WHEREFORE, plaintiff requests judgment against defendant(s) in the sum of $ 5,041.65. RUBIN & ROTHMAN, LLC MARCH 18, 2021 Attorneys for Plaintiff 1787 Veterans Highway Islandia, NY 11749 (631) 234-1500 Deponent is an attorney associated with Rubin & Rothman, LLC. To the best of deponent's knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the summons and complaint or the contentions therein are not frivolous as defined in section 130-1.1(c) of the Rules of the Chief Adm. and the matter was not obtained through illegal conduct or in violation of 22 NYCRR 1200, Rule 4.5. Dated: MARCH 18, 2021 ______________________ JACQUELINE TIERNEY WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. NYC DCA LIC. 2045512 Our File No. 1385063 X 20 0- 0 V SZV 000 000005998992 2 of 3 *000005998992* FILED: SENECA COUNTY CLERK 03/18/2021 12:27 PM INDEX NO. 20210120 NYSCEFSUPREME COURT DOC. NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 03/18/2021 COUNTY OF SENECA ---------------------------------------- JPMORGAN CHASE BANK, N.A. Plaintiff -against- Index No. CRYSTAL COTTRELL Defendant(s) ---------------------------------------- NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING PLEASE TAKE NOTICE that the matter captioned above, which has been commenced by filing of the accompanying documents with the County Clerk, is subject to mandatory electronic filing pursuant to Section 202.5-bb of the Uniform Rules for the Trial Courts. This notice is being served as required by Subdivision (b)(3) of that Section. The New York State Courts Electronic Filing System ("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 docu- ments, and court notices upon counsel and self-represented parties. Counsel and/or parties who do not notify the court of a claimed exemption (see below) as required by Section 202.5-bb(e) must immediately record their representation within the e-filed matter on the Consent page in NYSCEF. Failure to do so may result in an inability to receive electronic notice of document filings. Exemptions from mandatory e-filing are limited to: 1)attorneys who certify in good faith that they lack the computer equipment and (along with all employees) the requisite knowledge to comply; and 2) self-represented parties who choose not to participate in e-filing. For additional informa- tion about electronic filing, including access to Section 202.5-bb, consult the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center at 646-386-3033 or efile@courts.state.ny.us. Dated: Islandia, New York MARCH 18, 2021 ____________________ RUBIN & ROTHMAN, LLC JACQUELINE TIERNEY 1787 VETERANS HIGHWAY RUBIN & ROTHMAN, LLC ISLANDIA, NY 11749 (631) 234-1500 NYDOCS@RUBINROTHMAN.COM To: CRYSTAL COTTRELL 447 STATE ROUTE 318 PHELPS, NY 14532-9314 WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. NYC DCA LIC. 2045512 Our File No. 1385063 X 21 0- 0 V SZV 000 000005998992 3 of 3 *000005998992*