Preview
FILED: MADISON COUNTY CLERK 04/23/2021 08:27 AM INDEX NO. EF2021-1365
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2021
CONSUMER CREDIT TRANSACTION
Date Purchased:
SUPREME COURT OF THE STATE OF NEW YORK Index Ne
COUNTY OF MADISON X
MIDLAND CREDIT MANAGEMENT, INC. SUMMONS
Plaintiff, Plaintiffs Address:
-against- 350 Camino De La Suite 100
Reina,
San Diego CA 92108
Sean Dillon
Defendant(s).
The Basis of Venue is:
CPLR SEC. 503(f). Defendants
residence is in the County of
MADISON.
X
Defendant(s) Address:
DEF.#1 - 2712 Evans Rd Eaton NY 13334-1804
2712,
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 Plaintiffs 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 smmmons 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.
3'
Dated: April 12, 2021 Cuuáop
Matter # 414085
O Evridike Kollis E Stephanie R. Vetch
O Aksana Bondartseva |_ Joseph J. Cassotta
O Alex Pesochin |_ Anthony Poulin
Stephen Einstein |_ Krista Rose
Scott Morris
Tromberg, Morris & Poulin, PLLC
Attomeys for the Plaintiff
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
S_S_SUP-SUM
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FILED: MADISON COUNTY CLERK 04/23/2021 08:27 AM INDEX NO. EF2021-1365
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2021
SUPREME COURT OF THE STATE OF NEW YORK INDEX Ne:
COUNTY OF MADISON
MIDLAND CREDIT MANAGEMENT, INC.
Plaintiff,
-against-
COMPLAINT
Sean Dillon
Defendant(s).
Plaintiff,by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges that:
1. Plaintiffisan active foreign entity conducting business in the stateof CA.
2. Upon information and belief,Defendant(s) reside or isemployed in of the State of New York, County
of MADISON; 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 #
XXXXXXXXXXXX0972 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 conhining the terms and conditions governing the use
of the credit account, including terms of payment were delivered tothe Defendant(s).
5. Plaintiff,as purchaser and assignee of the account herein, owns and retains allbeneficial 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 beliefthis obligation originated with CREDIT ONE BANK, N.A. with a
chain of titleas follows:
CREDIT ONE BANK, N.A.
MHC RECEIVABLES, LLC
SHERMAN ORIGINATOR IIILLC
MIDLAND CREDIT MANAGEMENT, INC.
7. Upon information and belief,Defendant(s) incurred charges by use of the said charge account, less
and credits,in the sum of $841.35, no part of which has been paid although duly demanded.
8. Upon information and belief the the date of default on this account was 7/15/2019 and the cause of
action asserted herein isnot outside the applicable statute of limitations for enforcing the debt.
WHEREFORE, Plaintiff demañds judgment against Defendant(s) in the sum of $841.35, plus costs
and disbursements.
CERTIFICATION: Deponent is an attorney associated with Tromberg, Morris & Poulin, PLLC 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 ofApril, 2021.
Matter # 414085 O Evridike Kollis O Stephanie R. Vetch
O Aksana Bondartseva O Joseph J.Cassotta
Alex Pesochin Anthony Poulin
Stephen Einstein Krista Rose
Scott Morris O
S S COM-RTL
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FILED: MADISON COUNTY CLERK 04/23/2021 08:27 AM INDEX NO. EF2021-1365
NYSCEF DOC. NO. 1 IndexNo. Year RECEIVED NYSCEF: 04/23/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MADISON
MIDLAND CREDIT MANAGEMENT, INC.
Plaintiff
-against-
Sean Dillon
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
3Stephen Einstein Krista Rose
Scott Morris
LAW OFFICE OF
TROMBERG, MORRIS & POULIN, PLLC
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 of the within is hereby admitted.
copy
Dated,
Attorney(s) for Plaintiff(s)
Sir: Please take notice
O NOTICE OF ENTRY:
That within is a true of a entered in the office of the clerk
(certified) copy duly
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 3
Preview
FILED: MADISON COUNTY CLERK 04/23/2021 08:27 AM INDEX NO. EF2021-1365 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2021 CONSUMER CREDIT TRANSACTION Date Purchased: SUPREME COURT OF THE STATE OF NEW YORK Index Ne COUNTY OF MADISON X MIDLAND CREDIT MANAGEMENT, INC. SUMMONS Plaintiff, Plaintiffs Address: -against- 350 Camino De La Suite 100 Reina, San Diego CA 92108 Sean Dillon Defendant(s). The Basis of Venue is: CPLR SEC. 503(f). Defendants residence is in the County of MADISON. X Defendant(s) Address: DEF.#1 - 2712 Evans Rd Eaton NY 13334-1804 2712, 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 Plaintiffs 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 smmmons 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. 3' Dated: April 12, 2021 Cuuáop Matter # 414085 O Evridike Kollis E Stephanie R. Vetch O Aksana Bondartseva |_ Joseph J. Cassotta O Alex Pesochin |_ Anthony Poulin Stephen Einstein |_ Krista Rose Scott Morris Tromberg, Morris & Poulin, PLLC Attomeys for the Plaintiff 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 S_S_SUP-SUM 1 of 3 FILED: MADISON COUNTY CLERK 04/23/2021 08:27 AM INDEX NO. EF2021-1365 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/23/2021 SUPREME COURT OF THE STATE OF NEW YORK INDEX Ne: COUNTY OF MADISON MIDLAND CREDIT MANAGEMENT, INC. Plaintiff, -against- COMPLAINT Sean Dillon Defendant(s). Plaintiff,by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges that: 1. Plaintiffisan active foreign entity conducting business in the stateof CA. 2. Upon information and belief,Defendant(s) reside or isemployed in of the State of New York, County of MADISON; 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 # XXXXXXXXXXXX0972 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 conhining the terms and conditions governing the use of the credit account, including terms of payment were delivered tothe Defendant(s). 5. Plaintiff,as purchaser and assignee of the account herein, owns and retains allbeneficial 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 beliefthis obligation originated with CREDIT ONE BANK, N.A. with a chain of titleas follows: CREDIT ONE BANK, N.A. MHC RECEIVABLES, LLC SHERMAN ORIGINATOR IIILLC MIDLAND CREDIT MANAGEMENT, INC. 7. Upon information and belief,Defendant(s) incurred charges by use of the said charge account, less and credits,in the sum of $841.35, no part of which has been paid although duly demanded. 8. Upon information and belief the the date of default on this account was 7/15/2019 and the cause of action asserted herein isnot outside the applicable statute of limitations for enforcing the debt. WHEREFORE, Plaintiff demañds judgment against Defendant(s) in the sum of $841.35, plus costs and disbursements. CERTIFICATION: Deponent is an attorney associated with Tromberg, Morris & Poulin, PLLC 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 ofApril, 2021. Matter # 414085 O Evridike Kollis O Stephanie R. Vetch O Aksana Bondartseva O Joseph J.Cassotta Alex Pesochin Anthony Poulin Stephen Einstein Krista Rose Scott Morris O S S COM-RTL 2 of 3 FILED: MADISON COUNTY CLERK 04/23/2021 08:27 AM INDEX NO. EF2021-1365 NYSCEF DOC. NO. 1 IndexNo. Year RECEIVED NYSCEF: 04/23/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MADISON MIDLAND CREDIT MANAGEMENT, INC. Plaintiff -against- Sean Dillon 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 3Stephen Einstein Krista Rose Scott Morris LAW OFFICE OF TROMBERG, MORRIS & POULIN, PLLC 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 of the within is hereby admitted. copy Dated, Attorney(s) for Plaintiff(s) Sir: Please take notice O NOTICE OF ENTRY: That within is a true of a entered in the office of the clerk (certified) copy duly 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 3