On September 02, 2021 a
Complaint,Petition
was filed
involving a dispute between
Jefferson Capital Systems, Llc,
and
Thomas J Baylor,
for Other Matters - Consumer Credit (Non-Card) Transaction
in the District Court of Orange County.
Preview
FILED: ORANGE COUNTY CLERK 09/02/2021 12:14 PM INDEX NO. EF006211-2021
SUPREME
NYSCEF DOC. COURT
NO. 1 OF THE STATE OF NEW YORK INDEX # RECEIVED NYSCEF: R
09/02/2021 R
COUNTY OF ORANGE SUMMONS
JEFFERSON CAPITAL SYSTEMS, LLC PLAINTIFF'S ADDRESS
PLAINTIFF, 16 MCLELAND RD
ST CLOUD MN 56303
- AGAINST - X El
DEFENDANT'S ADDRESSES 5|
THOMAS J BAYLOR 15 GILLIAN CT iiii
DEFENDANT(S). MONROE NY 10950-0000
CONSUMER CREDIT TRANSACTION
THE BASIS OF THE VENUE IS:
A DEFENDANT RESIDES IN THE COUNTY OF ORANGE
THE TRANSACTION TOOK PLACE IN THE COUNTY OF ORANGE
TO THE ABOVE NAMED DEFENDANT(S): THOMAS J BAYLOR
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
FZLB1041234 60 MOTOR PARKWAY
ORIG CRED: SANTANDER CONSUMER USA COMMACK, NY 11725
ORIG ACCT# END IN: 1000 (631) 393-9400
NOTE: THE LAW PROVIDES THAT:
(A) IF THIS SUMMONS IS SERVED BY ITS DELIVERY TO YOU PERSONALLY WITHIN
THE COUNTY OF ORANGE 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
OR IS SERVED OUTSIDE THE COUNTY OF ORANGE OR BY PUBLI-
PERSONALLY, ,
CATION, OR BY ANY MEANS OTHER THAN PERSONAL DELIVERY TO YOU WITHIN THE
COUNTY OF ORANGE YOU ARE ALLOWED 30 DAYS AFTER SERVICE IS COMPLETE
WITHIN WHICH TO APPEAR AND ANSWER.
Filedin Orange County 09/02/2021 12:14:41 PM $0.00 Bk: 1 of
5146 2 Pg: 1075 Index: # EF006211-2021 Clerk:DK
FILED: ORANGE COUNTY CLERK 09/02/2021 12:14 PM INDEX NO. EF006211-2021
SUPREME
NYSCEF DOC. COURT
NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 09/02/2021
COUNTY OF ORANGE FORMAL COMPLAINT
________________________________________________
GErrEMSON CAPITAL SYSTEMS, LLC
PLAINTIFF,
- AGAINST -
THOMAS J BAYLOR
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. DEFENDANT(S), FOR VALUE, ENTERED A WRITTEN RETAIL INSTALLMENT CONTRACT OR
CLOSED END MOTOR VEHICLE LEASE AGREEMENT, NOW OWNED BY PLAINTIFF.
3. DEFENDANT(S) FAILED TO MAKE THE MONTHLY PAYMENTS AND ALL SUMS DUE HAVE BEEN
DECLARED DUE AND PAYABLE.
4. THERE REMAINS AN AGREED BALANCE ON SAID ACCOUNT OF $ 7,977.97 DUE AND
UNPAID ALTHOUGH DULY DEMANDED.
5. DEFENDANT(S) IS IN DEFAULT AND DEMAND FOR PAYMENT HAS BEEN MADE.
CHAIN OF TITLE:
JEFFERSON CAPITAL SYSTEMS, LLC who purchased this account from SANTANDER
CONSUMER USA on 08/28/2019.
2ND CAUSE/ACTION:PLAINTIFF STATED AN ACCOUNT TO DEFENDANT WITHOUT OBJECTION
THAT 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
7,977.97
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 GUNTHER ETTET. ALTMAN MICHAELFLORIO
PURSUANTTOPART130-1.1-aOF THERULESOFTHE
CHIEFADMINISTRATORTHISSIGNATUREAPPLIES
TOTHEATTACHEDSUMMONSANDCOMPLAINT
FZLB1041234 2 of 2
Document Filed Date
September 02, 2021
Case Filing Date
September 02, 2021
Category
Other Matters - Consumer Credit (Non-Card) Transaction
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Preview
FILED: ORANGE COUNTY CLERK 09/02/2021 12:14 PM INDEX NO. EF006211-2021 SUPREME NYSCEF DOC. COURT NO. 1 OF THE STATE OF NEW YORK INDEX # RECEIVED NYSCEF: R 09/02/2021 R COUNTY OF ORANGE SUMMONS JEFFERSON CAPITAL SYSTEMS, LLC PLAINTIFF'S ADDRESS PLAINTIFF, 16 MCLELAND RD ST CLOUD MN 56303 - AGAINST - X El DEFENDANT'S ADDRESSES 5| THOMAS J BAYLOR 15 GILLIAN CT iiii DEFENDANT(S). MONROE NY 10950-0000 CONSUMER CREDIT TRANSACTION THE BASIS OF THE VENUE IS: A DEFENDANT RESIDES IN THE COUNTY OF ORANGE THE TRANSACTION TOOK PLACE IN THE COUNTY OF ORANGE TO THE ABOVE NAMED DEFENDANT(S): THOMAS J BAYLOR 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 FZLB1041234 60 MOTOR PARKWAY ORIG CRED: SANTANDER CONSUMER USA COMMACK, NY 11725 ORIG ACCT# END IN: 1000 (631) 393-9400 NOTE: THE LAW PROVIDES THAT: (A) IF THIS SUMMONS IS SERVED BY ITS DELIVERY TO YOU PERSONALLY WITHIN THE COUNTY OF ORANGE 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 OR IS SERVED OUTSIDE THE COUNTY OF ORANGE OR BY PUBLI- PERSONALLY, , CATION, OR BY ANY MEANS OTHER THAN PERSONAL DELIVERY TO YOU WITHIN THE COUNTY OF ORANGE YOU ARE ALLOWED 30 DAYS AFTER SERVICE IS COMPLETE WITHIN WHICH TO APPEAR AND ANSWER. Filedin Orange County 09/02/2021 12:14:41 PM $0.00 Bk: 1 of 5146 2 Pg: 1075 Index: # EF006211-2021 Clerk:DK FILED: ORANGE COUNTY CLERK 09/02/2021 12:14 PM INDEX NO. EF006211-2021 SUPREME NYSCEF DOC. COURT NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 09/02/2021 COUNTY OF ORANGE FORMAL COMPLAINT ________________________________________________ GErrEMSON CAPITAL SYSTEMS, LLC PLAINTIFF, - AGAINST - THOMAS J BAYLOR 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. DEFENDANT(S), FOR VALUE, ENTERED A WRITTEN RETAIL INSTALLMENT CONTRACT OR CLOSED END MOTOR VEHICLE LEASE AGREEMENT, NOW OWNED BY PLAINTIFF. 3. DEFENDANT(S) FAILED TO MAKE THE MONTHLY PAYMENTS AND ALL SUMS DUE HAVE BEEN DECLARED DUE AND PAYABLE. 4. THERE REMAINS AN AGREED BALANCE ON SAID ACCOUNT OF $ 7,977.97 DUE AND UNPAID ALTHOUGH DULY DEMANDED. 5. DEFENDANT(S) IS IN DEFAULT AND DEMAND FOR PAYMENT HAS BEEN MADE. CHAIN OF TITLE: JEFFERSON CAPITAL SYSTEMS, LLC who purchased this account from SANTANDER CONSUMER USA on 08/28/2019. 2ND CAUSE/ACTION:PLAINTIFF STATED AN ACCOUNT TO DEFENDANT WITHOUT OBJECTION THAT 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 7,977.97 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 GUNTHER ETTET. ALTMAN MICHAELFLORIO PURSUANTTOPART130-1.1-aOF THERULESOFTHE CHIEFADMINISTRATORTHISSIGNATUREAPPLIES TOTHEATTACHEDSUMMONSANDCOMPLAINT FZLB1041234 2 of 2