Preview
FILED: COLUMBIA COUNTY CLERK 10/01/2021 07:37 AM INDEX NO. E012021017313
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2021
CONSUMER CREDIT TRANSACTION
STATE OF NEW YORK
SUPREME COURT COUNTY OF COLUMBIA
CREDIT ACCEPTANCE CORPORATION
INDEX NO.:
25505 West Twelve Mile Road
DATE PURCHASED:
Southfield, Michigan 48034
SUMMONS
Plaintiff,
-vs-
Plaintiff(s) designate(s)
Columbia County
CHRISTOPHER M. GREENE
as the place of trial.
49 Eichybush Road
Kinderhook, New York 12106-2401
The basis of venue is:
DEFENDANT'S LOCATION
Defendant,
To the above-named Defendant:
YOU ARE HEREBY SUMMONED and required to appear in the Supreme Court of the County of
Columbia located at 401 Union Street, City of Hudson, State of New York, by serving an answer to the annexed
Verified Complaint upon Plaintiff's attorney(s) at the address stated below, or if there is no attorney, upon the
Plaintiff at the address stated above, within the time provid by la noted below. Upon your failure to so
answer, judgment will be taken against you for the relief an in the complaint, together with the costs and
disbursements of this action.
Date: September 29, 2021
O seph M. Shur, Esq.
Shelly L. Baldwin, Esq.
Relin, Goldstein & Crane, LLP
Attorney(s) for Plaintiff
Office and Post Office Address:
28 East Main Street, Suite 1800
Rochester, New York 14614
(585) 325-6202
NOTE: The law provides that:
1) If this summons is served by its delivery to you personally within the County of Columbia, you must
answer within twenty (20) days after such service; or
2) If this summons is served by delivery to any person other than you personally, or is served outside the
County of Columbia, or by publication, or by any means other than personal delivery to you within the
County of Columbia, you are allowed thirty (30) days after service is complete within which to answer.
*
You need not physically go to the court to serve an answer.
THIS IS AN ATTEMPT TO COLLECT A DEBT BY A DEBT COLLECTOR, ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.
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FILED: COLUMBIA COUNTY CLERK 10/01/2021 07:37 AM INDEX NO. E012021017313
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2021
STATE OF NEW YORK
SUPREME COURT COUNTY OF COLUMBIA
CREDIT ACCEPTANCE CORPORATION,
25505 West Twelve Mile Road
Southfield, Michigan 48034
Plaintiff,
-vs- VERIFIED COMPLAINT
CHRISTOPHER M. GREENE
49 Eichybush Road
Kinderhook, New York 12106-2401
Defendant.
The Plaintiff herein, by RELIN, GOLDSTEIN & CRANE, LLP, its attorneys, complains of the
above-named Defendant, and for its cause(s) of action, alleges:
FIRST: That the Plaintiff is a corporation licensed to transact business in the State of New York, having a
principal place of business located in the county of Oakland, State of Michigan.
SECOND: Upon information and belief, that the Defendant is a resident of the county of Columbia, State
of New York.
AS AND FOR A FIRST CAUSE OF ACTION:
THIRD: Dealer entered in to a Retail Installment Contract (the "Contract") with the Defendant for good
and valuable consideration. That attached hereto is a true copy of said Contract, marked Exhibit "A".
FOURTH: Plaintiff accepted assignment of the Contract.
FIFTH: That within four years last past, the Defendant herein defaulted on his/her obligations under the
Contract, and there remains due and owing the sum of $13,070.07.
SIXTH: That the Plaintiff has complied with all conditions precedent to the aforesaid Contract.
SEVENTH: That demand for payment has been made upon the Defendant and the Defendant has failed to
pay.
AS AND FOR A SECOND CAUSE OF ACTION:
"FIRST" "SEVENTH"
EIGHTH: The Plaintiff repeats and re-alleges paragraphs through of this complaint,
as though fully hereinafter set forth.
NINTH: True and correct statements of account were sent by Plaintiff to the Defendant.
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FILED: COLUMBIA COUNTY CLERK 10/01/2021 07:37 AM INDEX NO. E012021017313
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2021
TENTH: The Defendant retained such statements of account with out objection.
WHEREFORE, Plaintiff demands judgment:
A) On Plaintiff's first cause of action, adjudging and decreeing the amounts due to the Plaintiff;
B) On Plaintiff's second cause of action, in the sum of $13,070.07, with interest in the amount of 9% from
January 24, 2020 on the sum of $13,070.07,
C) Together with the costs and disbursements of tion.
Date: September 29, 2021
.
O J eph M. Shur, Esq.
Shelly L. Baldwin, Esq.
Relin, Goldstein & Crane, LLP
Attorney(s) for Plaintiff
Office and Post Office Address:
28 East Main Street, Suite 1800
Rochester, New York 14614
(585) 325-6202
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FILED: COLUMBIA COUNTY CLERK 10/01/2021 07:37 AM INDEX NO. E012021017313
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2021
ATTORNEY'S VERIFICATION BY AFFIRMATION
STATE OF NEW YORK
COUNTY OF MONROE) SS:
I,the undersigned, am an attorney admitted to practice in the courts of the State of New York and that: I
am the attorney of record or of counsel with the attorney(s) of record for the Plaintiff.
I have read the annexed Complaint and know the contents thereof and the same are true to my knowledge,
except those matters therein which are stated to be alleged on information and belief, and as to those matters, I
believe them to be true. My belief, as to those matters therein not stated upon knowledge, is based upon the
following: correspondence, memoranda and statements of account in deponent's possession.
The reason I make this affirmation instead of Plaintiff is because an officer of Plaintiff is not within the
County of Monroe and deponent is one of the attorneys for said corporation.
I affirm that the foregoing statements are true under e alties of .
Date: September 29, 2021
O oseph M. Shur, Esq.
Shelly L. Baldwin, Esq.
Relin, Goldstein & Crane, LLP
Attorney(s) for Plaintiff
Office and Post Office Address:
28 East Main Street, Suite 1800
Rochester, New York 14614
(585) 325-6202
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Preview
FILED: COLUMBIA COUNTY CLERK 10/01/2021 07:37 AM INDEX NO. E012021017313 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2021 CONSUMER CREDIT TRANSACTION STATE OF NEW YORK SUPREME COURT COUNTY OF COLUMBIA CREDIT ACCEPTANCE CORPORATION INDEX NO.: 25505 West Twelve Mile Road DATE PURCHASED: Southfield, Michigan 48034 SUMMONS Plaintiff, -vs- Plaintiff(s) designate(s) Columbia County CHRISTOPHER M. GREENE as the place of trial. 49 Eichybush Road Kinderhook, New York 12106-2401 The basis of venue is: DEFENDANT'S LOCATION Defendant, To the above-named Defendant: YOU ARE HEREBY SUMMONED and required to appear in the Supreme Court of the County of Columbia located at 401 Union Street, City of Hudson, State of New York, by serving an answer to the annexed Verified Complaint upon Plaintiff's attorney(s) at the address stated below, or if there is no attorney, upon the Plaintiff at the address stated above, within the time provid by la noted below. Upon your failure to so answer, judgment will be taken against you for the relief an in the complaint, together with the costs and disbursements of this action. Date: September 29, 2021 O seph M. Shur, Esq. Shelly L. Baldwin, Esq. Relin, Goldstein & Crane, LLP Attorney(s) for Plaintiff Office and Post Office Address: 28 East Main Street, Suite 1800 Rochester, New York 14614 (585) 325-6202 NOTE: The law provides that: 1) If this summons is served by its delivery to you personally within the County of Columbia, you must answer within twenty (20) days after such service; or 2) If this summons is served by delivery to any person other than you personally, or is served outside the County of Columbia, or by publication, or by any means other than personal delivery to you within the County of Columbia, you are allowed thirty (30) days after service is complete within which to answer. * You need not physically go to the court to serve an answer. THIS IS AN ATTEMPT TO COLLECT A DEBT BY A DEBT COLLECTOR, ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1 of 4 FILED: COLUMBIA COUNTY CLERK 10/01/2021 07:37 AM INDEX NO. E012021017313 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2021 STATE OF NEW YORK SUPREME COURT COUNTY OF COLUMBIA CREDIT ACCEPTANCE CORPORATION, 25505 West Twelve Mile Road Southfield, Michigan 48034 Plaintiff, -vs- VERIFIED COMPLAINT CHRISTOPHER M. GREENE 49 Eichybush Road Kinderhook, New York 12106-2401 Defendant. The Plaintiff herein, by RELIN, GOLDSTEIN & CRANE, LLP, its attorneys, complains of the above-named Defendant, and for its cause(s) of action, alleges: FIRST: That the Plaintiff is a corporation licensed to transact business in the State of New York, having a principal place of business located in the county of Oakland, State of Michigan. SECOND: Upon information and belief, that the Defendant is a resident of the county of Columbia, State of New York. AS AND FOR A FIRST CAUSE OF ACTION: THIRD: Dealer entered in to a Retail Installment Contract (the "Contract") with the Defendant for good and valuable consideration. That attached hereto is a true copy of said Contract, marked Exhibit "A". FOURTH: Plaintiff accepted assignment of the Contract. FIFTH: That within four years last past, the Defendant herein defaulted on his/her obligations under the Contract, and there remains due and owing the sum of $13,070.07. SIXTH: That the Plaintiff has complied with all conditions precedent to the aforesaid Contract. SEVENTH: That demand for payment has been made upon the Defendant and the Defendant has failed to pay. AS AND FOR A SECOND CAUSE OF ACTION: "FIRST" "SEVENTH" EIGHTH: The Plaintiff repeats and re-alleges paragraphs through of this complaint, as though fully hereinafter set forth. NINTH: True and correct statements of account were sent by Plaintiff to the Defendant. 2 of 4 FILED: COLUMBIA COUNTY CLERK 10/01/2021 07:37 AM INDEX NO. E012021017313 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2021 TENTH: The Defendant retained such statements of account with out objection. WHEREFORE, Plaintiff demands judgment: A) On Plaintiff's first cause of action, adjudging and decreeing the amounts due to the Plaintiff; B) On Plaintiff's second cause of action, in the sum of $13,070.07, with interest in the amount of 9% from January 24, 2020 on the sum of $13,070.07, C) Together with the costs and disbursements of tion. Date: September 29, 2021 . O J eph M. Shur, Esq. Shelly L. Baldwin, Esq. Relin, Goldstein & Crane, LLP Attorney(s) for Plaintiff Office and Post Office Address: 28 East Main Street, Suite 1800 Rochester, New York 14614 (585) 325-6202 3 of 4 FILED: COLUMBIA COUNTY CLERK 10/01/2021 07:37 AM INDEX NO. E012021017313 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/01/2021 ATTORNEY'S VERIFICATION BY AFFIRMATION STATE OF NEW YORK COUNTY OF MONROE) SS: I,the undersigned, am an attorney admitted to practice in the courts of the State of New York and that: I am the attorney of record or of counsel with the attorney(s) of record for the Plaintiff. I have read the annexed Complaint and know the contents thereof and the same are true to my knowledge, except those matters therein which are stated to be alleged on information and belief, and as to those matters, I believe them to be true. My belief, as to those matters therein not stated upon knowledge, is based upon the following: correspondence, memoranda and statements of account in deponent's possession. The reason I make this affirmation instead of Plaintiff is because an officer of Plaintiff is not within the County of Monroe and deponent is one of the attorneys for said corporation. I affirm that the foregoing statements are true under e alties of . Date: September 29, 2021 O oseph M. Shur, Esq. Shelly L. Baldwin, Esq. Relin, Goldstein & Crane, LLP Attorney(s) for Plaintiff Office and Post Office Address: 28 East Main Street, Suite 1800 Rochester, New York 14614 (585) 325-6202 4 of 4