On January 26, 2021 a
Answer
was filed
involving a dispute between
Cavalry Spv I Llc,
and
Karen Troendle,
for Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff
in the District Court of Madison County.
Preview
FILED: MADISON COUNTY CLERK 02/26/2021 09:26 PM INDEX NO. EF2021-1064
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 02/26/2021
IN THE SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MADISON
______________________________________________ __---------X
Cavalry SPV I, LLC,
Plaintiff Index No. EF2021-1064
VERIFIED ANSWER
v. OF DEFENDANT
TO PLAINTIFF'S COMPLAINT
Karen Troendle,
Defendant
_____--
---------------------------------------------------X
Now comes the Defendant, Karen Treendle, and through coüñsel, and for the Answer
by
to Plaintiff's Complaint states as follows:
FIRST DEFENSE
1. Defendant denies each and allegation contained in Plaintiff's Complaint.
every
SECOND DEFENSE
2. Defendant repeats, reiterates, and re-alleges the deñials contained in paragraph 1 as
if fully rewritten herein.
3. Defendant denies the alleged amount claimed as total damages, due to incorrect and
improper addition of late fees, interest or other misce!!añeous charges.
AFFIRMATIVE DEFENSE
4. Upon information and belief, Plaintiff has failed to state a claim upon which relief
can be granted.
5. Plaintiff does not have standing to bring this claim.
6. The alleged assig-ent is not binding on Defendant.
7. Defendant gives notice to reserve the right to rely upon such other
hereby
defenses as may become available and amend this Answer accordingly.
during discovery
based on the Defcñdëñt prays the Court to dismiss this action
WHEREFORE, foregoing,
against her, and for such other relief as the Court deems just and proper.
1 of 4
FILED: MADISON COUNTY CLERK 02/26/2021 09:26 PM INDEX NO. EF2021-1064
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 02/26/2021
Respectfully submitted,
RODIER LAW OFFICES, INC.
lan-Itfodier (2753861)
(Mailing Address:)
2295 E Livingston Ave
Columbus, OH 43209
Telephone: (614) 224-7754
Facsimile: (614) 224-7760
Attorneys for Defendant
(Satellite Office Address:)
12th
1501 Broadway Flf
New York, NY 10036
2 of 4
FILED: MADISON COUNTY CLERK 02/26/2021 09:26 PM INDEX NO. EF2021-1064
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 02/26/2021
VERIFICATION
1, lan H. Rodier, Attorney at Law, being duly sworn, state that:
1. My principal place of business is located at 2295 East Livingston Avenue, Columbus,
Ohio 43209.
2. I have been retained by Defendant Karen Troendle whose residence is located at 7991
Black Creek Road, Chittenango, NY 13037.
3. The within Answer is true to the best of my knowledge, except as to those matters alleged
upon information and belief, which I believe to be true.
Ian dier (2753861)
'
Swom to before me this day of , 20 .
Bryan R. Stafford
Public
Attomey At Law
* Notary Public, Stateof Ohio
My commission has no expiration date
Sec.147.03R.C.
3
3 of 4
FILED: MADISON COUNTY CLERK 02/26/2021 09:26 PM INDEX NO. EF2021-1064
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 02/26/2021
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Answer was sent by court's ECF system on
February $8, 2021 to the following:
Tromberg Morris & Poulin PLLC
39 Broadway
Ste 1250
New York, NY 10006
Phone: (212) 267-3550
Facsimile: (212) 227-9656
Attorney for PlaintifJ
lan H odier'(2753861)
RODIER LAW OFFICES
4
4 of 4
Document Filed Date
February 26, 2021
Case Filing Date
January 26, 2021
Category
Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: MADISON COUNTY CLERK 02/26/2021 09:26 PM INDEX NO. EF2021-1064 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 02/26/2021 IN THE SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MADISON ______________________________________________ __---------X Cavalry SPV I, LLC, Plaintiff Index No. EF2021-1064 VERIFIED ANSWER v. OF DEFENDANT TO PLAINTIFF'S COMPLAINT Karen Troendle, Defendant _____-- ---------------------------------------------------X Now comes the Defendant, Karen Treendle, and through coüñsel, and for the Answer by to Plaintiff's Complaint states as follows: FIRST DEFENSE 1. Defendant denies each and allegation contained in Plaintiff's Complaint. every SECOND DEFENSE 2. Defendant repeats, reiterates, and re-alleges the deñials contained in paragraph 1 as if fully rewritten herein. 3. Defendant denies the alleged amount claimed as total damages, due to incorrect and improper addition of late fees, interest or other misce!!añeous charges. AFFIRMATIVE DEFENSE 4. Upon information and belief, Plaintiff has failed to state a claim upon which relief can be granted. 5. Plaintiff does not have standing to bring this claim. 6. The alleged assig-ent is not binding on Defendant. 7. Defendant gives notice to reserve the right to rely upon such other hereby defenses as may become available and amend this Answer accordingly. during discovery based on the Defcñdëñt prays the Court to dismiss this action WHEREFORE, foregoing, against her, and for such other relief as the Court deems just and proper. 1 of 4 FILED: MADISON COUNTY CLERK 02/26/2021 09:26 PM INDEX NO. EF2021-1064 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 02/26/2021 Respectfully submitted, RODIER LAW OFFICES, INC. lan-Itfodier (2753861) (Mailing Address:) 2295 E Livingston Ave Columbus, OH 43209 Telephone: (614) 224-7754 Facsimile: (614) 224-7760 Attorneys for Defendant (Satellite Office Address:) 12th 1501 Broadway Flf New York, NY 10036 2 of 4 FILED: MADISON COUNTY CLERK 02/26/2021 09:26 PM INDEX NO. EF2021-1064 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 02/26/2021 VERIFICATION 1, lan H. Rodier, Attorney at Law, being duly sworn, state that: 1. My principal place of business is located at 2295 East Livingston Avenue, Columbus, Ohio 43209. 2. I have been retained by Defendant Karen Troendle whose residence is located at 7991 Black Creek Road, Chittenango, NY 13037. 3. The within Answer is true to the best of my knowledge, except as to those matters alleged upon information and belief, which I believe to be true. Ian dier (2753861) ' Swom to before me this day of , 20 . Bryan R. Stafford Public Attomey At Law * Notary Public, Stateof Ohio My commission has no expiration date Sec.147.03R.C. 3 3 of 4 FILED: MADISON COUNTY CLERK 02/26/2021 09:26 PM INDEX NO. EF2021-1064 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 02/26/2021 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Answer was sent by court's ECF system on February $8, 2021 to the following: Tromberg Morris & Poulin PLLC 39 Broadway Ste 1250 New York, NY 10006 Phone: (212) 267-3550 Facsimile: (212) 227-9656 Attorney for PlaintifJ lan H odier'(2753861) RODIER LAW OFFICES 4 4 of 4