On September 08, 2021 a
Complaint,Petition
was filed
involving a dispute between
Ford Motor Credit Company Llc,
and
Sadie Clements,
for Other Matters - Consumer Credit (Non-Card) Transaction
in the District Court of Warren County.
Preview
FILED: WARREN COUNTY CLERK 09/08/2021 04:01 PM INDEX NO. EF2021-69444
NYSCEFSUPREME
DOC. NO.COURT
1 OF THE STATE OF NEW YORK Index No. RECEIVED NYSCEF: 09/08/2021
COUNTY OF WARREN Date Filed: ________________
----------------------------------------
FORD MOTOR CREDIT COMPANY LLC
SUMMONS (ORIGINAL)
Plaintiff
-against-
SADIE CLEMENTS The basis of venue is:
DEFENDANT'S RESIDENCE
Defendant(s) Plaintiff's Residence:
---------------------------------------- 1 AMERICAN RD #904
DEARBORN, MI 48126
CONSUMER CREDIT TRANSACTION County of WAYNE
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, or, if the complaint is not served with this summons
to serve a notice of appearance, on the Plaintiff's Attorney(s) within
TWENTY days after the service of this summons, exclusive of the day of
service (or within THIRTY 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
against you by default for the relief demanded herein.
Dated: Islandia, New York
SEPTEMBER 3, 2021 RUBIN & ROTHMAN, LLC
Attorneys for Plaintiff
1787 Veterans Highway
Islandia, N.Y. 11749
(631) 234-1500
DEFENDANT(S) ADDRESS:
SADIE CLEMENTS
657 LUZERNE RD QUEENSBURY, NY 12804-8085
WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
NYC DCA LIC. 2045512
Our File No. 1405295 Y 16 0- 0 V SLJ 000
000006116767
1 of 3
*000006116767*
FILED: WARREN COUNTY CLERK 09/08/2021 04:01 PM INDEX NO. EF2021-69444
NYSCEFSUPREME
DOC. NO.COURT
1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 09/08/2021
COUNTY OF WARREN Index No.
----------------------------------------
FORD MOTOR CREDIT COMPANY LLC
Plaintiff
-against- COMPLAINT (ORIGINAL)
SADIE CLEMENTS
Defendant(s)
----------------------------------------
Plaintiff, by its attorneys, complaining of the defendant(s), alleges:
1. Defendant(s) resides in the county in which this action is brought;
or transacted business in the county in which this action is brought
in person or through an agent, or this cause of action arose out of
said transaction. Plaintiff is not required to be licensed by the
NYC Dept of Consumer Affairs because its principal business is not the
collection of debts due to another nor is it a buyer of delinquent debt.
2. Plaintiff is a foreign corporation licensed to do business
in New York State.
3. Defendant(s) entered into an automobile lease with
NEMER FORD
in which defendant(s) agreed to pay monthly rental payments to the
dealership. The lease was subsequently assigned by the dealer to
CAB EAST LLC
(the "Titling Company") and given Acct No. ****************1742.
The account was not in default at the time of the assignment. Plaintiff
entered into a servicing agreement with the Titling Company that assigns
the account to plaintiff solely for the purpose of fulfilling the
servicer's duties under the agreement, including the commencement of
legal proceedings to enforce the account.
4. Defendant(s) later defaulted on the terms of the lease, with the
result that defendant(s) owe plaintiff $ 4,135.38.
WHEREFORE, plaintiff requests judgment against defendant(s) for the sum of
$ 4,135.38 and the costs and disbursements of this action.
RUBIN & ROTHMAN, LLC
SEPTEMBER 3, 2021 Attorneys for Plaintiff
1787 Veterans Highway
Islandia, NY 11749
(631) 234-1500
Deponent is an attorney associated with Rubin & Rothman, LLC. To the best
of deponent's knowledge, information and belief, formed after an inquiry
reasonable under the circumstances, the summons and complaint or the
contentions therein are not frivolous as defined in section 130-1.1(c)
of the Rules of the Chief Adm. and the matter was not obtained through
illegal conduct or in violation of 22 NYCRR 1200, Rule 4.5.
Dated: SEPTEMBER 3, 2021 ______________________
JACQUELINE TIERNEY
WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
NYC DCA LIC. 2045512
Our File No. 1405295 X 17 0- 0 V SLJ 000
000006116767
2 of 3
*000006116767*
FILED: WARREN COUNTY CLERK 09/08/2021 04:01 PM INDEX NO. EF2021-69444
NYSCEFSUPREME
DOC. NO.COURT
1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 09/08/2021
COUNTY OF WARREN
----------------------------------------
FORD MOTOR CREDIT COMPANY LLC
Plaintiff
-against- Index No.
SADIE CLEMENTS
Defendant(s)
----------------------------------------
NOTICE OF COMMENCEMENT OF ACTION
SUBJECT TO MANDATORY ELECTRONIC FILING
PLEASE TAKE NOTICE that the matter captioned above, which has been
commenced by filing of the accompanying documents with the County Clerk, is
subject to mandatory electronic filing pursuant to Section 202.5-bb of the
Uniform Rules for the Trial Courts. This notice is being served as
required by Subdivision (b)(3) of that Section.
The New York State Courts Electronic Filing System ("NYSCEF") is
designed for the electronic filing of documents with the County Clerk and
the court and for the electronic service of those documents, court docu-
ments, and court notices upon counsel and self-represented parties. Counsel
and/or parties who do not notify the court of a claimed exemption (see
below) as required by Section 202.5-bb(e) must immediately record their
representation within the e-filed matter on the Consent page in NYSCEF.
Failure to do so may result in an inability to receive electronic notice of
document filings.
Exemptions from mandatory e-filing are limited to: 1)attorneys who
certify in good faith that they lack the computer equipment and (along with
all employees) the requisite knowledge to comply; and 2) self-represented
parties who choose not to participate in e-filing. For additional informa-
tion about electronic filing, including access to Section 202.5-bb, consult
the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource
Center at 646-386-3033 or efile@courts.state.ny.us.
Dated: Islandia, New York
SEPTEMBER 3, 2021
____________________ RUBIN & ROTHMAN, LLC
JACQUELINE TIERNEY 1787 VETERANS HIGHWAY
RUBIN & ROTHMAN, LLC ISLANDIA, NY 11749
(631) 234-1500
NYDOCS@RUBINROTHMAN.COM
To: SADIE CLEMENTS
657 LUZERNE RD
QUEENSBURY, NY 12804-8085
WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
NYC DCA LIC. 2045512
Our File No. 1405295 X 18 0- 0 V SLJ 000
000006116767
3 of 3
*000006116767*
Document Filed Date
September 08, 2021
Case Filing Date
September 08, 2021
Category
Other Matters - Consumer Credit (Non-Card) Transaction
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: WARREN COUNTY CLERK 09/08/2021 04:01 PM INDEX NO. EF2021-69444 NYSCEFSUPREME DOC. NO.COURT 1 OF THE STATE OF NEW YORK Index No. RECEIVED NYSCEF: 09/08/2021 COUNTY OF WARREN Date Filed: ________________ ---------------------------------------- FORD MOTOR CREDIT COMPANY LLC SUMMONS (ORIGINAL) Plaintiff -against- SADIE CLEMENTS The basis of venue is: DEFENDANT'S RESIDENCE Defendant(s) Plaintiff's Residence: ---------------------------------------- 1 AMERICAN RD #904 DEARBORN, MI 48126 CONSUMER CREDIT TRANSACTION County of WAYNE 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, or, if the complaint is not served with this summons to serve a notice of appearance, on the Plaintiff's Attorney(s) within TWENTY days after the service of this summons, exclusive of the day of service (or within THIRTY 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 against you by default for the relief demanded herein. Dated: Islandia, New York SEPTEMBER 3, 2021 RUBIN & ROTHMAN, LLC Attorneys for Plaintiff 1787 Veterans Highway Islandia, N.Y. 11749 (631) 234-1500 DEFENDANT(S) ADDRESS: SADIE CLEMENTS 657 LUZERNE RD QUEENSBURY, NY 12804-8085 WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. NYC DCA LIC. 2045512 Our File No. 1405295 Y 16 0- 0 V SLJ 000 000006116767 1 of 3 *000006116767* FILED: WARREN COUNTY CLERK 09/08/2021 04:01 PM INDEX NO. EF2021-69444 NYSCEFSUPREME DOC. NO.COURT 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 09/08/2021 COUNTY OF WARREN Index No. ---------------------------------------- FORD MOTOR CREDIT COMPANY LLC Plaintiff -against- COMPLAINT (ORIGINAL) SADIE CLEMENTS Defendant(s) ---------------------------------------- Plaintiff, by its attorneys, complaining of the defendant(s), alleges: 1. Defendant(s) resides in the county in which this action is brought; or transacted business in the county in which this action is brought in person or through an agent, or this cause of action arose out of said transaction. Plaintiff is not required to be licensed by the NYC Dept of Consumer Affairs because its principal business is not the collection of debts due to another nor is it a buyer of delinquent debt. 2. Plaintiff is a foreign corporation licensed to do business in New York State. 3. Defendant(s) entered into an automobile lease with NEMER FORD in which defendant(s) agreed to pay monthly rental payments to the dealership. The lease was subsequently assigned by the dealer to CAB EAST LLC (the "Titling Company") and given Acct No. ****************1742. The account was not in default at the time of the assignment. Plaintiff entered into a servicing agreement with the Titling Company that assigns the account to plaintiff solely for the purpose of fulfilling the servicer's duties under the agreement, including the commencement of legal proceedings to enforce the account. 4. Defendant(s) later defaulted on the terms of the lease, with the result that defendant(s) owe plaintiff $ 4,135.38. WHEREFORE, plaintiff requests judgment against defendant(s) for the sum of $ 4,135.38 and the costs and disbursements of this action. RUBIN & ROTHMAN, LLC SEPTEMBER 3, 2021 Attorneys for Plaintiff 1787 Veterans Highway Islandia, NY 11749 (631) 234-1500 Deponent is an attorney associated with Rubin & Rothman, LLC. To the best of deponent's knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the summons and complaint or the contentions therein are not frivolous as defined in section 130-1.1(c) of the Rules of the Chief Adm. and the matter was not obtained through illegal conduct or in violation of 22 NYCRR 1200, Rule 4.5. Dated: SEPTEMBER 3, 2021 ______________________ JACQUELINE TIERNEY WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. NYC DCA LIC. 2045512 Our File No. 1405295 X 17 0- 0 V SLJ 000 000006116767 2 of 3 *000006116767* FILED: WARREN COUNTY CLERK 09/08/2021 04:01 PM INDEX NO. EF2021-69444 NYSCEFSUPREME DOC. NO.COURT 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 09/08/2021 COUNTY OF WARREN ---------------------------------------- FORD MOTOR CREDIT COMPANY LLC Plaintiff -against- Index No. SADIE CLEMENTS Defendant(s) ---------------------------------------- NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING PLEASE TAKE NOTICE that the matter captioned above, which has been commenced by filing of the accompanying documents with the County Clerk, is subject to mandatory electronic filing pursuant to Section 202.5-bb of the Uniform Rules for the Trial Courts. This notice is being served as required by Subdivision (b)(3) of that Section. The New York State Courts Electronic Filing System ("NYSCEF") is designed for the electronic filing of documents with the County Clerk and the court and for the electronic service of those documents, court docu- ments, and court notices upon counsel and self-represented parties. Counsel and/or parties who do not notify the court of a claimed exemption (see below) as required by Section 202.5-bb(e) must immediately record their representation within the e-filed matter on the Consent page in NYSCEF. Failure to do so may result in an inability to receive electronic notice of document filings. Exemptions from mandatory e-filing are limited to: 1)attorneys who certify in good faith that they lack the computer equipment and (along with all employees) the requisite knowledge to comply; and 2) self-represented parties who choose not to participate in e-filing. For additional informa- tion about electronic filing, including access to Section 202.5-bb, consult the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center at 646-386-3033 or efile@courts.state.ny.us. Dated: Islandia, New York SEPTEMBER 3, 2021 ____________________ RUBIN & ROTHMAN, LLC JACQUELINE TIERNEY 1787 VETERANS HIGHWAY RUBIN & ROTHMAN, LLC ISLANDIA, NY 11749 (631) 234-1500 NYDOCS@RUBINROTHMAN.COM To: SADIE CLEMENTS 657 LUZERNE RD QUEENSBURY, NY 12804-8085 WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. NYC DCA LIC. 2045512 Our File No. 1405295 X 18 0- 0 V SLJ 000 000006116767 3 of 3 *000006116767*