Preview
FILED: WARREN COUNTY CLERK 08/06/2021 02:03 PM INDEX NO. EF2021-69337
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/06/2021
CONSUMER CREDIT TRANSACTION
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WARREN
ROCK CREEK CAPITAL, LLC as assignee Purchased:
of SALLIE MAE BANK,
Index No.
Plaintiff,
-against- SUMMONS
VANESSA L. DINATALE, Basis of venue is the
residence of Defendant
Defendant.
To the above named Defendant:
YOU ARE HEREBY SUMMONED and required to serve upon
plaintiff’s attorney an answer to the complaint in this action
within twenty days after the service of this summons, exclusive
of the day of service, or within thirty days after service is
complete if this summons is not personally delivered to you
within the State of New York. In case of your failure to answer,
judgment will be taken against you by default for the relief
demanded in the complaint.
Defendant's address: 60 Hudson Avenue Glens Falls NY 12081
Dated: August 5, 2021 /s/ Dolores Iannarone-Rainieri
Dolores Iannarone-Rainieri, Esq.
Portnoy Schneck, L.L.C.
3705 Quakerbridge Rd, Ste 116
Hamilton, NJ 08619
Phone: 609/514-8668
Attorney for Plaintiff
File No. J2100133
NOTE: The law provides that:
1. If this summons is served by its delivery to you personally,
you must appear and answer within TWENTY (20) days after such
service; or
2. If this summons is served by its delivery to any person
other than you personally, or by publication, or by any means
other than personal delivery to you, you are allowed THIRTY (30)
days after the proof of service thereof is filed with the Clerk
of the this Court within which to appear and answer.
Disclosure
This communication is from a debt collector and is an attempt to
collect a debt. Any information obtained will be used for that
purpose.
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FILED: WARREN COUNTY CLERK 08/06/2021 02:03 PM INDEX NO. EF2021-69337
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/06/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WARREN
ROCK CREEK CAPITAL, LLC as assignee Index No.
of SALLIE MAE BANK,
Plaintiff, COMPLAINT
-against-
VANESSA L. DINATALE,
Defendant.
Plaintiff, by and through its attorneys, Portnoy Schneck,
L.L.C. complaining of the Defendant alleges:
1. Plaintiff Rock Creek Capital, LLC as assignee of SALLIE
MAE BANK, located at 4500 Mercantile Plaza, Suite 300, Fort
Worth, Texas 76137.
2. Defendant Vanessa L. Dinatale, is an individual residing
at 60 Hudson Avenue, Glens Falls NY 12081.
3. Defendant executed a promissory note for educational
expenses. Pursuant to the promissory note Defendant was required
to make monthly payments until the balance was paid in full.
4. The loan was issued to Defendant by Sallie Mae Bank.
5. On or about June 18, 2020 the promissory note was
transferred, sold and assigned to Rock Creek Capital, LLC.
6. Pursuant to the promissory note, Defendant made certain
payments and beginning on July 16, 2019 and continuing
thereafter, failed to make the payments as required.
7. Payment has been duly demanded and has not been made.
8. Plaintiff has fully performed or otherwise complied with
all promises, conditions and terms of the promissory note.
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FILED: WARREN COUNTY CLERK 08/06/2021 02:03 PM INDEX NO. EF2021-69337
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/06/2021
9. Defendant is in default of the loan agreement by failing
to make payments when due, making the Defendant presently liable
for the full outstanding balance of $7,881.24. Said sum includes
principal in the amount of $6,627.22, interest at the rate of
7.500% from January 28, 2014 to November 30, 2019 of $233.28,
post-write off interest at the rate of 7.25% of $851.50 and
continuing to accrue. After giving credit for all payments
received, there remains an outstanding balance of $7,712.00.
WHEREFORE, Plaintiff requests Judgment against Defendant for
the sum of $7,712.00, said sum includes principal in the amount
of $6,627.22, interest at the rate of 7.500% from January 28,
2014 to November 30, 2019 of $233.28, post-write off interest at
the rate of 7.25% of $851.50 and continuing to accrue, plus the
costs and disbursements of this action.
Dated: August 5, 2021 /s/ Dolores Iannarone-Rainieri
Dolores Iannarone-Rainieri, Esq.
Portnoy Schneck, L.L.C.
3705 Quakerbridge Rd, Ste 116
Hamilton, NJ 08619
Phone: 609/514-8668
Attorney for Plaintiff
File No. J2100133
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