Preview
FILED: BROOME COUNTY CLERK 06/04/2021 03:35 AM INDEX NO. EFCA2021001370
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/04/2021
CONSUMER CREDIT TRANSACTION
Date Purchased:
SUPREME COURT OF THE STATE OF NEW YORK Index N9
COUNTY OF BROOME X
Second Round Sub, LLC SUMMONS
Plaintiff, Plaintiff s Address:
-against- 1701 Directors Blvd. Ste. 900
Austin TX 78744
Lashawn L Peterson
Defendant(s).
The Basis of Venue is:
CPLR SEC. 503(f). Defendants
residence is in the County of
BROOME.
X
Defendant(s) Address:
DEF.#1 - 1038 Jfk Blvd Apt Endwell NY 13760
2,
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 Plaintiff s Attorney(s) within 20 days after the service of this summons, exclusive of the d ay of
service, or within 30 days after service iscomplete if thissummons 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.
Dated: April 15, 2021
Matter # 415659
O Evridike Kollis O Stephanie R. Vetch
O Ak.sana Bondartseva O Joseph J. Cassotta
O Alex Pesochin O Anthony Poulin
Stephen Einstein O Krista Rose
O Scott Morris O
Tromberg, Morris & Poulin, PLLC
Attorneys for the Plaintiff
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
S_S_SUP-SUM
1 of 3
FILED: BROOME COUNTY CLERK 06/04/2021 03:35 AM INDEX NO. EFCA2021001370
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/04/2021
SUPREME COURT OF THE STATE OF NEWYORK INDEX N9:
COUNTY OF BROOME
SecondRound Sub, LLC
Plaintiff,
-against-
COMPLAINT
Lashawn L Peterson
Defendant(s).
Plaintiff, by itsundersigned attorneys, complaining of the Defendant(s), respectfully alleges that:
1. Plaintiff isan activefomign entityconducting business in the stateof TX.
2. Upon infonnation and belief, Defendant(s) reside oris employed in of the StateofNew York, County
of BROOME; or that the Defendant(s) transacted business with within thejurisdiction 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
Plaintiff'
3. The Defendant(s)hereto entered intoa Credit Agreement with s predeces sor in interest,
Comenity Capital Bank, bearing account #XXXXXXXXXXXXXX5485 who charged off the debt on
09/30/2019.
4. Upon infonnation and belief, Plaintiff'spredecessor in interest duly performed allconditions on its
part under the agreement.
5. The Plaintiff themafter took by assignment allthe rights,titleand interest to receive the monie s
due pursuant to and in accordance with the said agreement and is the legal assignee of the original
creditor.
6. Upon information and belief,Plaintiff advised Defendant, in writing, of said balance due and
demanding payment. No payment has been forthcoming.
7.Defendant(s) defaulted in payment and pursuant to the terms of the agreement now owe a balance
of $1,846.85 as of 9/30/2019, no partof which has been paid despite due demand therefore.
AS AND FOR A SECOND CAUSE OF ACTION
8. That heretofore, upon information and belief, Plaintiff's predecessor in interest rendered to
Defendant(s) monthly, full and truthaccounts of the indebtedness owing by the Defendant(s) as a resultof
the above Agreement, in an amount as hereinabove set forth,which account statements were delivered to
and accepted without objection by the Defendant(s) resulting in an account stated in the sum of $1,846.85
as of 9/30/2019, no part of which has been paid despite due demand therefore.
WHEREFORE, Plaintiff demands judgment against Defendant(s) in the sum of $1,846.85, plus co sts
and disbursements.
CERTIFICATION: Deponent isan attomey associated with Tromberg, Morris & Poulin, PLLC Deponent
certifies that, to the bestoftheir 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 initiatingpleading, the matter was
not obtained through illegal conduct, and the matter was not obtained inviolation of Part 1200. Rule 4.5
of this Title. Affirmed this 15th day ofApril, 2021.
Matter # 415659 vridike Kollis O Stephanie R. Vetch
Aksana Bondartseva O Joseph J. Cassotta
Alex Pesochin O Anthony Poulin
2 Stephen Einstein O Krista Rose
O Scott Morris O
S S COM-RTL
2 of 3
FILED: BROOME COUNTY CLERK 06/04/2021 03:35 AM INDEX NO. EFCA2021001370
NYSCEF DOC. NO. 1 Index No. Year RECEIVED NYSCEF: 06/04/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BROOME
Second Round Sub, LLC
Plaintiff
-against-
Lashawn L Peterson
Defendant(s)
SUMMONS AND VERIFIED COMPLAINT
Signature (Rule 130-1. 1-a)
O Evridike Kollis Stephanie R. Vetch
U Aksana Bondartseva Joseph J. Cassotta
U Alex Pesochin Anthony Poulin
Stephen 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
NOTICE OF ENTRY:
That within is a true of a entered in the office of the clerk
(certified) copy duly
of the within named courton
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: BROOME COUNTY CLERK 06/04/2021 03:35 AM INDEX NO. EFCA2021001370 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/04/2021 CONSUMER CREDIT TRANSACTION Date Purchased: SUPREME COURT OF THE STATE OF NEW YORK Index N9 COUNTY OF BROOME X Second Round Sub, LLC SUMMONS Plaintiff, Plaintiff s Address: -against- 1701 Directors Blvd. Ste. 900 Austin TX 78744 Lashawn L Peterson Defendant(s). The Basis of Venue is: CPLR SEC. 503(f). Defendants residence is in the County of BROOME. X Defendant(s) Address: DEF.#1 - 1038 Jfk Blvd Apt Endwell NY 13760 2, 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 Plaintiff s Attorney(s) within 20 days after the service of this summons, exclusive of the d ay of service, or within 30 days after service iscomplete if thissummons 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. Dated: April 15, 2021 Matter # 415659 O Evridike Kollis O Stephanie R. Vetch O Ak.sana Bondartseva O Joseph J. Cassotta O Alex Pesochin O Anthony Poulin Stephen Einstein O Krista Rose O Scott Morris O Tromberg, Morris & Poulin, PLLC Attorneys for the Plaintiff 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 S_S_SUP-SUM 1 of 3 FILED: BROOME COUNTY CLERK 06/04/2021 03:35 AM INDEX NO. EFCA2021001370 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/04/2021 SUPREME COURT OF THE STATE OF NEWYORK INDEX N9: COUNTY OF BROOME SecondRound Sub, LLC Plaintiff, -against- COMPLAINT Lashawn L Peterson Defendant(s). Plaintiff, by itsundersigned attorneys, complaining of the Defendant(s), respectfully alleges that: 1. Plaintiff isan activefomign entityconducting business in the stateof TX. 2. Upon infonnation and belief, Defendant(s) reside oris employed in of the StateofNew York, County of BROOME; or that the Defendant(s) transacted business with within thejurisdiction 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 Plaintiff' 3. The Defendant(s)hereto entered intoa Credit Agreement with s predeces sor in interest, Comenity Capital Bank, bearing account #XXXXXXXXXXXXXX5485 who charged off the debt on 09/30/2019. 4. Upon infonnation and belief, Plaintiff'spredecessor in interest duly performed allconditions on its part under the agreement. 5. The Plaintiff themafter took by assignment allthe rights,titleand interest to receive the monie s due pursuant to and in accordance with the said agreement and is the legal assignee of the original creditor. 6. Upon information and belief,Plaintiff advised Defendant, in writing, of said balance due and demanding payment. No payment has been forthcoming. 7.Defendant(s) defaulted in payment and pursuant to the terms of the agreement now owe a balance of $1,846.85 as of 9/30/2019, no partof which has been paid despite due demand therefore. AS AND FOR A SECOND CAUSE OF ACTION 8. That heretofore, upon information and belief, Plaintiff's predecessor in interest rendered to Defendant(s) monthly, full and truthaccounts of the indebtedness owing by the Defendant(s) as a resultof the above Agreement, in an amount as hereinabove set forth,which account statements were delivered to and accepted without objection by the Defendant(s) resulting in an account stated in the sum of $1,846.85 as of 9/30/2019, no part of which has been paid despite due demand therefore. WHEREFORE, Plaintiff demands judgment against Defendant(s) in the sum of $1,846.85, plus co sts and disbursements. CERTIFICATION: Deponent isan attomey associated with Tromberg, Morris & Poulin, PLLC Deponent certifies that, to the bestoftheir 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 initiatingpleading, the matter was not obtained through illegal conduct, and the matter was not obtained inviolation of Part 1200. Rule 4.5 of this Title. Affirmed this 15th day ofApril, 2021. Matter # 415659 vridike Kollis O Stephanie R. Vetch Aksana Bondartseva O Joseph J. Cassotta Alex Pesochin O Anthony Poulin 2 Stephen Einstein O Krista Rose O Scott Morris O S S COM-RTL 2 of 3 FILED: BROOME COUNTY CLERK 06/04/2021 03:35 AM INDEX NO. EFCA2021001370 NYSCEF DOC. NO. 1 Index No. Year RECEIVED NYSCEF: 06/04/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BROOME Second Round Sub, LLC Plaintiff -against- Lashawn L Peterson Defendant(s) SUMMONS AND VERIFIED COMPLAINT Signature (Rule 130-1. 1-a) O Evridike Kollis Stephanie R. Vetch U Aksana Bondartseva Joseph J. Cassotta U Alex Pesochin Anthony Poulin Stephen 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 NOTICE OF ENTRY: That within is a true of a entered in the office of the clerk (certified) copy duly of the within named courton 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