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  • Cavalry SPV I, LLC, as assignee of Citibank, N.A./AAdvantage vs. McGovern, Janine K Other Contract Action document preview
  • Cavalry SPV I, LLC, as assignee of Citibank, N.A./AAdvantage vs. McGovern, Janine K Other Contract Action document preview
						
                                

Preview

’ i6.0 1 COMMONWEALTH OF MASSACHUSETTS NORFOLK, ss. 29\9 DEC 9 ANI Wi NORFOLK SUPERIOR COURT eRK OF THE COURTS - DOCKET NO. 1682Cv01539 SLERK OF THE ey” ot rtobrnnnendi eile QoL, CAVALRY SPV I, LLC, as assignee of Citibank, N.A./AAdvantage, Plaintiff, ve JANINE K. MCGOVERN, \e ey es K ON Defendant Jpppiosieisioloiooisofsoisioiaiooloieaioioioioioioloooioiotok PLAINTIFF’S MOTION FOR THE ISSUANCE OF AN EXECUTION AFTER ONE (1) YEAR NOW COMES the Plaintiff, CAVALRY SPV I, LLC, as assignee of Citibank, N.A./AAdvantage, and respectfully requests that this Honorable Court issue an Execution on the Judgment entered in favor of the Plaintiff and against the Defendant, JANINE K. MCGOVERN (hereinafter the “Defendant”). As grounds therefor, the Plaintiff states the following: 1. Judgment entered in favor of the Plaintiff and against the Defendant on June 7, 2018. 2. Plaintiff however, failed to request the issuance of an Execution on Money Judgment from this Honorable Court. Further, more than one (1) year has passed since the Judgment was entered. 3. The Defendant has not made any payments towards the Judgment. The defendant owes the Judgment amount of $60,609.97, plus interest. 4. Therefore, as more than one year has passed and Execution never issued, Plaintiff requests this Honorable Court to issue an Execution so that Plaintiff may continue with its post-Judgment collections activities, as the Judgment balance has yet to be satisfied in full. WHEREFORE, the Plaintiff respectfully requests that this Honorable Court issue an Execution on the Judgment entered in favor of the Plaintiff and against the Defendant, and enter such further relief as this Honorable Court should deem just and proper.