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FILED: CLINTON COUNTY CLERK 08/06/2021 12:26 PM INDEX NO. 2021-00021402
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/06/2021
CONSUMER CREDIT TRANSACTION
SUPREME COURT
COUNTY OF CLINTON STATE OF NEW YORK
GOLDMAN SACHS BANK USA, Index No.
Plaintiff
- vs. - S U M M O N S
SONYA DUBREY, The basis of the venue designated is
Defendant's residence.
262 CHAZY LAKE RD
SARANAC, NY 12981 Plaintiff's address:
Defendant(s) 200 West Street
New York, NY 10282
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 attorneys for plaintiff within 20 days after the service of the
Summons, exclusive of the days of service (or within 30 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 agaimt you by default for the relief
demanded herein. The basis of venue is the Defendant(s) residence.
DATED: O 6
[ ] J N P. VERHAGEN, ESQ.
[ ARRY T.POWELL, ESQ.
[ ]JOSEPH JAKAS, ESQ.
[ ]ELIZABETH CLARKE, ESQ.
[ ] JOSEPH M. JACKLING, ESQ.
[ ] STEPHANIE MAIDA, ESQ.
ZWICKER & ASSOCIATES, P.C.
A Law Firm Engaged in Debt Collection
100 CORPORATE WOODS, SUITE 230
ROCHESTER, NY 14623
(585)427-0482
ZANYLITIGATION@ZWICKERPC.COM
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FILED: CLINTON COUNTY CLERK 08/06/2021 12:26 PM INDEX NO. 2021-00021402
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/06/2021
SUPREME COURT
COUNTY OF CLINTON STATE OF NEW YORK
GOLDMAN SACHS BANK USA, Index No.
Plaintiff,
vs. COMPLAINT
SONYA DUBREY,
Defendant(s).
Plaintiff, GOLDMAN SACHS BANK USA, by and through its attorneys, Zwicker &
Associates, P.C., for its Complaint against SONYA DUBREY ("Defendant(s)"), states as
follows:
1. Plaintiff is a New York State-chartered bank and member of the FDIC.
2. Defendant(s) reside(s) and/or maintain(s) an address and/or domicile sufficient to allow
this Court to maintain jurisdiction and venue of Plaintiff's claims.
3. The priñcipal damage amount sought by Plaintiff in this Complaint is within this Court's
monetary jurisdictional limit.
4. Defendant(s) entered into a loan agreeñ1eñt (hereafter referred to as "Agreement"). True
and exact copies of the loan documents are attached hereto and marked Exhibit A.
5. Funds were disbursed pursuant to the terms of the Agreement or as requested by
Defendant(s).
6. The loan is identified with account number ending in 5809.
7. Defêñdant(s) defaulted on the terms of the Agreement when Defendant(s) failed to make
payments pursuant to the terms of the Agreement.
8. As a result of the default by Defeñdant(s), Plaintiff has accelerated the fullbalance due
and pursuant to the terms of the Agreement
owing
9. Demand was made upon Defendant(s).
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FILED: CLINTON COUNTY CLERK 08/06/2021 12:26 PM INDEX NO. 2021-00021402
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/06/2021
10. As of today's date, Defendant(s) has/have failed to pay Plaintiff pu1suant to the terms of
the Agreement.
11. As Defendant(s) have materially breached the terms of the Agreement, the balance due
and owing to Plaintiff after deducting alljust and lawful offsets, payment, and credits is the
sum of $14,275.77. Account statement records or balance history records sub imtiating the
balance due are attached hereto and marked Exhibit B.
RELIEF REQUESTED
WHEREFORE, Plaintiff requests this Honorable Court to enter a Judgmeñt awarding the
following:
a) The balance due and owing of $14,275.77.
Respectfully submitted,
Zwicker & Associ , . .
By: -
---,
[ ]J N P. VERHAGEN, ESQ., #4296208
[ ARRY T. POWELL, ESQ., #4544177
[ ]JOSEPH JAKAS, ESQ., #5154521
[ ]ELIZABETH CLARKE, ESQ., #5046719
[ ]JOSEPH M. JACKLING, ESQ., #5820584
[ ]STEPHANIE MAIDA, ESQ., #5761846
ZWICKER & ASSOCIATES, P.C.
A Law Firm Engaged in Debt Collection
100 CORPORATE WOODS, SUITE 230
ROCHESTER, NY 14623
(585)427-0482
ZANYLITIGATION@ZWICKERPC.COM
Attorney for Plaintiff
Dated: a $
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