On September 02, 2021 a
Complaint,Petition
was filed
involving a dispute between
Jefferson Capital Systems, Llc,
and
Clara E Caruso,
for Other Matters - Consumer Credit (Non-Card) Transaction
in the District Court of Dutchess County.
Preview
FILED: DUTCHESS COUNTY CLERK 09/02/2021 11:32 AM INDEX NO. 2021-53780
SUPREME
NYSCEF DOC. COURT
NO. 1 OF THE STATE OF NEW YORK INDEX # RECEIVED NYSCEF: R
09/02/2021 R
COUNTY OF DUTCHESS SUMMONS
------------------------------------------------
JEFFERSON CAPITAL SYSTEMS, LLC PLAINTIFF'S ADDRESS
PLAINTIFF, 16 MCLELAND RD
ST CLOUD MN 56303
- AGAINST - X
DEFENDANT'S ADDRESSES
CLARA E CARUSO 27 CROSSWAY RD # 2
DEFENDANT(S). BEACON NY 12508-1101
------------------------------------------------
CONSUMER CREDIT TRANSACTION
THE BASIS OF THE VENUE IS:
A DEFENDANT RESIDES IN THE COUNTY OF DUTCHESS
THE TRANSACTION TOOK PLACE IN THE COUNTY OF DUTCHESS
TO THE ABOVE NAMED DEFENDANT(S): CLARA E CARUSO
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 DAY 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).
UPON YOUR FAILURE TO ANSWER, JUDGMENT WILL BE TAKEN AGAINST YOU FOR THE
RELIEF DEMANDED IN THE COMPLAINT, TOGETHER WITH THE DISBURSEMENTS OF
THIS ACTION.
DATED THE 17 DAY OF AUGUST , 2021
FORSTER & GARBUS LLP
FILE NO. ATTORNEY(S) FOR PLAINTIFF
FZEC959493 60 MOTOR PARKWAY
ORIG CRED: CITIZENS BANK, N.A. COMMACK, NY 11725
ORIG ACCT# END IN: 4050 (631) 393-9400
NOTE: THE LAW PROVIDES THAT:
(A) IF THIS SUMMONS IS SERVED BY ITS DELIVERY TO YOU PERSONALLY WITHIN
THE COUNTY OF DUTCHESS YOU MUST APPEAR AND ANSWER WITHIN 20 DAYS AFTER
SUCH SERVICE: OR
(B) IF THIS SUMMONS IS SERVED BY DELIVERY TO ANY PERSON OTHER THAN YOU
PERSONALLY, OR IS SERVED OUTSIDE THE COUNTY OF DUTCHESS , OR BY PUBLI-
CATION, OR BY ANY MEANS OTHER THAN PERSONAL DELIVERY TO YOU WITHIN THE
COUNTY OF DUTCHESS YOU ARE ALLOWED 30 DAYS AFTER SERVICE IS COMPLETE
WITHIN WHICH TO APPEAR AND ANSWER.
1 of 2
FILED: DUTCHESS COUNTY CLERK 09/02/2021 11:32 AM INDEX NO. 2021-53780
SUPREME
NYSCEF DOC. COURT
NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 09/02/2021
COUNTY OF DUTCHESS FORMAL COMPLAINT
------------------------------------------------
JEFFERSON CAPITAL SYSTEMS, LLC
PLAINTIFF,
- AGAINST -
CLARA E CARUSO
DEFENDANT(S).
------------------------------------------------
PLAINTIFF, BY ITS ATTORNEY(S), COMPLAINING OF THE DEFENDANT(S), UPON
INFORMATION AND BELIEF, ALLEGES:
1. THAT THE DEFENDANT(S) RESIDES IN THE COUNTY IN WHICH THIS ACTION IS
BROUGHT; OR THAT THE DEFENDANT(S) TRANSACTED BUSINESS WITHIN THE COUNTY
IN WHICH THIS ACTION IS BROUGHT IN PERSON OR THROUGH HIS AGENT AND THAT
THE INSTANT CAUSE OF ACTION AROSE OUT OF SAID TRANSACTION
2. ON INFORMATION AND BELIEF THE DEFENDANT
IN PERSON OR THROUGH AN AGENT TOOK OUT A LOAN.
PLAINTIFF PURCHASED THIS ACCOUNT FOR VALUE;
NOTIFIED THE DEFENDANT.
3. THERE REMAINS AN AGREED BALANCE ON SAID ACCOUNT OF $ 31,280.43 ,
DUE AND OWING, NO PART OF SAID SUM HAS BEEN PAID ALTHOUGH DULY DEMANDED.
4. DEFENDANT(S) IS IN DEFAULT AND DEMAND FOR PAYMENT HAS BEEN MADE.
CHAIN OF TITLE:
JEFFERSON CAPITAL SYSTEMS, LLC who purchased this account from CITIZENS BANK NA
on 01/25/2021.
THERE IS NOW DUE PLAINTIFF FROM DEFENDANT(S) THE AMOUNT SET FORTH IN
THE COMPLAINT, NO PART OF WHICH HAS BEEN PAID, ALTHOUGH DULY DEMANDED.
WHEREFORE, PLAINTIFF DEMANDS JUDGMENT AGAINST DEFENDANT(S) FOR THE SUM OF
31,280.43
TOGETHER WITH THE DISBURSEMENTS OF THIS ACTION
WE ARE DEBT COLLECTORS; ANY FORSTER & GARBUS LLP
INFORMATION OBTAINED WILL BE USED ATTORNEY(S) FOR PLAINTIFF
IN ATTEMPTING TO COLLECT THIS DEBT. 60 MOTOR PARKWAY
COMMACK, NY 11725
DATED: THE 17 DAY OF AUGUST , 2021
_____________________________________________________
TESS E. GUNTHER ANNETTE T. ALTMAN MICHAEL FLORIO
PURSUANT TO PART 130-1.1-a OF THE RULES OF THE
CHIEF ADMINISTRATOR THIS SIGNATURE APPLIES
TO THE ATTACHED SUMMONS AND COMPLAINT
FZEC959493 2 of 2
Document Filed Date
September 02, 2021
Case Filing Date
September 02, 2021
Category
Other Matters - Consumer Credit (Non-Card) Transaction
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: DUTCHESS COUNTY CLERK 09/02/2021 11:32 AM INDEX NO. 2021-53780 SUPREME NYSCEF DOC. COURT NO. 1 OF THE STATE OF NEW YORK INDEX # RECEIVED NYSCEF: R 09/02/2021 R COUNTY OF DUTCHESS SUMMONS ------------------------------------------------ JEFFERSON CAPITAL SYSTEMS, LLC PLAINTIFF'S ADDRESS PLAINTIFF, 16 MCLELAND RD ST CLOUD MN 56303 - AGAINST - X DEFENDANT'S ADDRESSES CLARA E CARUSO 27 CROSSWAY RD # 2 DEFENDANT(S). BEACON NY 12508-1101 ------------------------------------------------ CONSUMER CREDIT TRANSACTION THE BASIS OF THE VENUE IS: A DEFENDANT RESIDES IN THE COUNTY OF DUTCHESS THE TRANSACTION TOOK PLACE IN THE COUNTY OF DUTCHESS TO THE ABOVE NAMED DEFENDANT(S): CLARA E CARUSO 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 DAY 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). UPON YOUR FAILURE TO ANSWER, JUDGMENT WILL BE TAKEN AGAINST YOU FOR THE RELIEF DEMANDED IN THE COMPLAINT, TOGETHER WITH THE DISBURSEMENTS OF THIS ACTION. DATED THE 17 DAY OF AUGUST , 2021 FORSTER & GARBUS LLP FILE NO. ATTORNEY(S) FOR PLAINTIFF FZEC959493 60 MOTOR PARKWAY ORIG CRED: CITIZENS BANK, N.A. COMMACK, NY 11725 ORIG ACCT# END IN: 4050 (631) 393-9400 NOTE: THE LAW PROVIDES THAT: (A) IF THIS SUMMONS IS SERVED BY ITS DELIVERY TO YOU PERSONALLY WITHIN THE COUNTY OF DUTCHESS YOU MUST APPEAR AND ANSWER WITHIN 20 DAYS AFTER SUCH SERVICE: OR (B) IF THIS SUMMONS IS SERVED BY DELIVERY TO ANY PERSON OTHER THAN YOU PERSONALLY, OR IS SERVED OUTSIDE THE COUNTY OF DUTCHESS , OR BY PUBLI- CATION, OR BY ANY MEANS OTHER THAN PERSONAL DELIVERY TO YOU WITHIN THE COUNTY OF DUTCHESS YOU ARE ALLOWED 30 DAYS AFTER SERVICE IS COMPLETE WITHIN WHICH TO APPEAR AND ANSWER. 1 of 2 FILED: DUTCHESS COUNTY CLERK 09/02/2021 11:32 AM INDEX NO. 2021-53780 SUPREME NYSCEF DOC. COURT NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 09/02/2021 COUNTY OF DUTCHESS FORMAL COMPLAINT ------------------------------------------------ JEFFERSON CAPITAL SYSTEMS, LLC PLAINTIFF, - AGAINST - CLARA E CARUSO DEFENDANT(S). ------------------------------------------------ PLAINTIFF, BY ITS ATTORNEY(S), COMPLAINING OF THE DEFENDANT(S), UPON INFORMATION AND BELIEF, ALLEGES: 1. THAT THE DEFENDANT(S) RESIDES IN THE COUNTY IN WHICH THIS ACTION IS BROUGHT; OR THAT THE DEFENDANT(S) TRANSACTED BUSINESS WITHIN THE COUNTY IN WHICH THIS ACTION IS BROUGHT IN PERSON OR THROUGH HIS AGENT AND THAT THE INSTANT CAUSE OF ACTION AROSE OUT OF SAID TRANSACTION 2. ON INFORMATION AND BELIEF THE DEFENDANT IN PERSON OR THROUGH AN AGENT TOOK OUT A LOAN. PLAINTIFF PURCHASED THIS ACCOUNT FOR VALUE; NOTIFIED THE DEFENDANT. 3. THERE REMAINS AN AGREED BALANCE ON SAID ACCOUNT OF $ 31,280.43 , DUE AND OWING, NO PART OF SAID SUM HAS BEEN PAID ALTHOUGH DULY DEMANDED. 4. DEFENDANT(S) IS IN DEFAULT AND DEMAND FOR PAYMENT HAS BEEN MADE. CHAIN OF TITLE: JEFFERSON CAPITAL SYSTEMS, LLC who purchased this account from CITIZENS BANK NA on 01/25/2021. THERE IS NOW DUE PLAINTIFF FROM DEFENDANT(S) THE AMOUNT SET FORTH IN THE COMPLAINT, NO PART OF WHICH HAS BEEN PAID, ALTHOUGH DULY DEMANDED. WHEREFORE, PLAINTIFF DEMANDS JUDGMENT AGAINST DEFENDANT(S) FOR THE SUM OF 31,280.43 TOGETHER WITH THE DISBURSEMENTS OF THIS ACTION WE ARE DEBT COLLECTORS; ANY FORSTER & GARBUS LLP INFORMATION OBTAINED WILL BE USED ATTORNEY(S) FOR PLAINTIFF IN ATTEMPTING TO COLLECT THIS DEBT. 60 MOTOR PARKWAY COMMACK, NY 11725 DATED: THE 17 DAY OF AUGUST , 2021 _____________________________________________________ TESS E. GUNTHER ANNETTE T. ALTMAN MICHAEL FLORIO PURSUANT TO PART 130-1.1-a OF THE RULES OF THE CHIEF ADMINISTRATOR THIS SIGNATURE APPLIES TO THE ATTACHED SUMMONS AND COMPLAINT FZEC959493 2 of 2