Preview
FILED: LIVINGSTON COUNTY CLERK 05/31/2019 12:03 PM INDEX NO. 000472-2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2019
Mary F. Strickland , County Cl
Livingston County Government Ce
6 Court Street, Room 201
fl A ÏÏ Geneseo, New York 14454
182'
243-7010 ~ Fax 243-792
(585) (585)
Livingston County Clerk Recording P
Received From: Return To:
KEITH H. ROTHMAN KEITH H. ROTHMAN
1787 VETERANS HWY 1787 VETERANS HWY
ISLANDIA, NY 11749 ISLANDIA, NY 11749
Document Type: CIVIL ACTION -
MISC Document Desc: SUMMO
Plaintiff Defendant
CITIBANK, N.A. BENNETT TANNYA K
Recorded Information:
State of New York
Index #: 000472-2019
County of Liviñgstoñ
EFiling through NYSCE
Livingston
This sheet condHL s the Clerk's endemement required by section 319 of the Real Property Law
1 of 4
Index#:000472-2019
INDEX NO. 000472-2019
FILED: LIVINGSTON COUNTY CLERK 05/31/2019 12:03 PM
NYSCEF SUPREME
DOC. NO.COURT
1 OF THE STATE OF NEW YORK Index No. RECEIVED NYSCEF: 05/31/2019
COUNTY OF LIVINGSTON Date Filed:
________________________________________
CITIBANK, N.A.
SUMMONS (ORIGINAL)
Plaintiff
-against-
TANNYA K BENNETT The basis of venue is:
DEFENDANT'S RESIDENCE
Defendant(s) Plaintiff's Residence:
________________________________________ 701 EAST 60TH ST NORTH
SIOUX FALLS, SD 57117
CONSUMER CREDIT TRANSACTION County of MINNEHAHA
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
MAY 29, 2019 RUBIN & ROTHMAN, LLC
Attorneys for Plaintiff
1787 Veterans Highway
Islandia, N.Y. 11749
(631) 234-1500
DEFENDANT(S) ADDRESS:
TANNYA K BENNETT
1979 POLE BRIDGE RD AVON, NY 14414-9721
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. 1293358 Y 46 0- 0 U SZM 000
000005513648
2 of 4
Index#:000472-2019
INDEX NO. 000472-2019
FILED: LIVINGSTON COUNTY CLERK 05/31/2019 12:03 PM
NYSCEF SUPREME
DOC. NO.COURT
1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 05/31/2019
COUNTY OF LIVINGSTON Index No.
________________________________________
CITIBANK, N.A.
Plaintiff
-against- COMPLAINT (ORIGINAL)
TANNYA K BENNETT
Defendant(s)
________________________________________
Plaintiff, by its attorneys, complaining of the defendant(s), alleges:
AS AND FOR A FIRST CAUSE OF ACTION
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 it is the original creditor.
2. Plaintiff is a national bank located in South Dakota.
3. Defendant(s) used a credit card issued by plaintiff and agreed to
make payments for goods and services charged and/or cash advances
made upon such card.
4. Defendant(s) failed to make the payments due pursuant to such agreement,
and $ 8,223.04 is now due and owing to plaintiff from defendant(s),
WHEREFORE, plaintiff requests judgment against defendant(s) in the sum of
$ 8,223.04 and the costs and disbursements of this action.
RUBIN & ROTHMAN, LLC
MAY 29, 2019 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 ot btained through
illegal conduct or in violation of 22 NYCRR 1200. - (DR -1 1).
Dated: MAY 29, 2019 /S/
ADRIENNE CERVENKA
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. 1293358 X 47 0- 0 U SZM 000
000005513648
3 of 4
Index#:000472-2019
INDEX NO. 000472-2019
FILED: LIVINGSTON COUNTY CLERK 05/31/2019 12:03 PM
NYSCEF SUPREME
DOC. NO.COURT
1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 05/31/2019
COUNTY OF LIVINGSTON
________________________________________
CITIBANK, N.A.
Plaintiff
-against- Index No.
TANNYA K BENNETT
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 court docu-
documents,
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.
Date : slandia, New York
MAY 29, 2019
/s/ RUBIN & ROTHMAN, LLC
ADRIENNE CERVENKA 1787 VETERANS HIGHWAY
RUBIN & ROTHMAN, LLC ISLANDIA, NY 11749
(631) 234-1500
NYDOCS@RUBINROTHMAN.COM
To: TANNYA K BENNETT
1979 POLE BRIDGE RD
AVON, NY 14414-9721
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. 1293358 X 48 0- 0 U SZM 000
000005513648
4 of 4
Preview
FILED: LIVINGSTON COUNTY CLERK 05/31/2019 12:03 PM INDEX NO. 000472-2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2019 Mary F. Strickland , County Cl Livingston County Government Ce 6 Court Street, Room 201 fl A ÏÏ Geneseo, New York 14454 182' 243-7010 ~ Fax 243-792 (585) (585) Livingston County Clerk Recording P Received From: Return To: KEITH H. ROTHMAN KEITH H. ROTHMAN 1787 VETERANS HWY 1787 VETERANS HWY ISLANDIA, NY 11749 ISLANDIA, NY 11749 Document Type: CIVIL ACTION - MISC Document Desc: SUMMO Plaintiff Defendant CITIBANK, N.A. BENNETT TANNYA K Recorded Information: State of New York Index #: 000472-2019 County of Liviñgstoñ EFiling through NYSCE Livingston This sheet condHL s the Clerk's endemement required by section 319 of the Real Property Law 1 of 4 Index#:000472-2019 INDEX NO. 000472-2019 FILED: LIVINGSTON COUNTY CLERK 05/31/2019 12:03 PM NYSCEF SUPREME DOC. NO.COURT 1 OF THE STATE OF NEW YORK Index No. RECEIVED NYSCEF: 05/31/2019 COUNTY OF LIVINGSTON Date Filed: ________________________________________ CITIBANK, N.A. SUMMONS (ORIGINAL) Plaintiff -against- TANNYA K BENNETT The basis of venue is: DEFENDANT'S RESIDENCE Defendant(s) Plaintiff's Residence: ________________________________________ 701 EAST 60TH ST NORTH SIOUX FALLS, SD 57117 CONSUMER CREDIT TRANSACTION County of MINNEHAHA 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 MAY 29, 2019 RUBIN & ROTHMAN, LLC Attorneys for Plaintiff 1787 Veterans Highway Islandia, N.Y. 11749 (631) 234-1500 DEFENDANT(S) ADDRESS: TANNYA K BENNETT 1979 POLE BRIDGE RD AVON, NY 14414-9721 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. 1293358 Y 46 0- 0 U SZM 000 000005513648 2 of 4 Index#:000472-2019 INDEX NO. 000472-2019 FILED: LIVINGSTON COUNTY CLERK 05/31/2019 12:03 PM NYSCEF SUPREME DOC. NO.COURT 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 05/31/2019 COUNTY OF LIVINGSTON Index No. ________________________________________ CITIBANK, N.A. Plaintiff -against- COMPLAINT (ORIGINAL) TANNYA K BENNETT Defendant(s) ________________________________________ Plaintiff, by its attorneys, complaining of the defendant(s), alleges: AS AND FOR A FIRST CAUSE OF ACTION 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 it is the original creditor. 2. Plaintiff is a national bank located in South Dakota. 3. Defendant(s) used a credit card issued by plaintiff and agreed to make payments for goods and services charged and/or cash advances made upon such card. 4. Defendant(s) failed to make the payments due pursuant to such agreement, and $ 8,223.04 is now due and owing to plaintiff from defendant(s), WHEREFORE, plaintiff requests judgment against defendant(s) in the sum of $ 8,223.04 and the costs and disbursements of this action. RUBIN & ROTHMAN, LLC MAY 29, 2019 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 ot btained through illegal conduct or in violation of 22 NYCRR 1200. - (DR -1 1). Dated: MAY 29, 2019 /S/ ADRIENNE CERVENKA 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. 1293358 X 47 0- 0 U SZM 000 000005513648 3 of 4 Index#:000472-2019 INDEX NO. 000472-2019 FILED: LIVINGSTON COUNTY CLERK 05/31/2019 12:03 PM NYSCEF SUPREME DOC. NO.COURT 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 05/31/2019 COUNTY OF LIVINGSTON ________________________________________ CITIBANK, N.A. Plaintiff -against- Index No. TANNYA K BENNETT 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 court docu- documents, 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. Date : slandia, New York MAY 29, 2019 /s/ RUBIN & ROTHMAN, LLC ADRIENNE CERVENKA 1787 VETERANS HIGHWAY RUBIN & ROTHMAN, LLC ISLANDIA, NY 11749 (631) 234-1500 NYDOCS@RUBINROTHMAN.COM To: TANNYA K BENNETT 1979 POLE BRIDGE RD AVON, NY 14414-9721 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. 1293358 X 48 0- 0 U SZM 000 000005513648 4 of 4