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  • Midland Funding Llc v. Michelle Aka Foster A/K/A MICHELLE L PASCHALL, Michelle L Aka Paschall Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
  • Midland Funding Llc v. Michelle Aka Foster A/K/A MICHELLE L PASCHALL, Michelle L Aka Paschall Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
  • Midland Funding Llc v. Michelle Aka Foster A/K/A MICHELLE L PASCHALL, Michelle L Aka Paschall Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff document preview
						
                                

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FILED: OSWEGO COUNTY CLERK 07/24/2018 11:22 AM INDEX NO. EFC-2018-1227 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/24/2018 File # F131319 CONSUMER CRED I T TRANSACTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF OSWEGO ___________----------____________ MIDLAND FUNDING LLC Plaintiff, Index No. -against- SUMMONS MICHELLE FOSTER A/K/A MICHELLE L PASCHALL Plaintiff's Residence Address 2365 NORTHSIDE DR STE 300. SAN DIEGO CA 92108 Defendant(s). The Basis of this venue designated is: Defendant's residence __________________.___________.____ Defendant's Residence Address: 23 CASTER RD SANDY CREEK, NY 131452189 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 within twenty (20) days after the service of this summons exclusive of the days of service (or within thirty (30) days after the service is complete if this summons is not personally delivered to you within the State of New York). You are hereby notified that should you fail to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: 07/19/18 PRESSLER, FELT & WARSHAW, LLP Attorneys for Plaintiff 305 Broa way 9th Floor New Y , 10 7 (516 222-7929 (X] y: Craig . tiller , E q. [ ) By: Ian Z. Winog rac E sq. [ ] By: David B. Warshaw Esq. 1 of 3 FILED: OSWEGO COUNTY CLERK 07/24/2018 11:22 AM INDEX NO. EFC-2018-1227 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/24/2018 File 4 F131319 - COUNTY OSWEGO SUPREME COURT OF THE STATE OF NEW YORK OF __________________________________ MIDLAND FUNDING LLC Plaintiff(s) Index No. -against- COMPLAINT MICHELLE FOSTER A/K/A MICHELLE L PASCHALL Defendant(s) __________________________________ Plaintiff by its attorneys, Pressler, Felt & Warshaw, LLP complaining of the defendant(s) alleges upon information and belief as follows: FIRST CAUSE OF ACTION 1. Plaintiff, MIDLAND FUNDING LLC, is a limited liability company formed under the laws of the state of Delaware and having taken assignment of is owner of COMENITY CAPITAL BANK (DENTALFIRST FINANCING) account number ending in XXXXXXXXXXXX9431 . 2. MICHELLE FOSTER A/K/A MICHELLE L PASCHALL resides within the jurisdictional limits of this court. 3. Plaintiff alleges that MICHELLE FOSTER A/K/A .A/K/A MICHELLE L PASCHALL , whose social security number ends in 099, is the responsible person for this account. 4. MICHELLE FOSTER A/K/A MICHELLE L PASCHALL failed to repay the balance owed on the account, which is in default. 5. The account was assigned from the original creditor COMENITY CAPITAL BANK (DENTALFIRST FINANCING) to MIDLAND FUNDING LLC, the present assignee. 6. The cause of action asserted herein accrued on or about March 20, 2017, the governing law being the state of Utah. 7. The date of default is on or about March 20, 2017. 8. Upon information and belief, the statute of limitations for the cause of action asserted herein is 4 years and therefore has not expired. 9. There is now due and owing the plaintiff, as the assignee of the account, from MICHELLE FOSTER A/K/A MICHELLE L PASCHALL , the sum of $999.78. 2 of 3 FILED: OSWEGO COUNTY CLERK 07/24/2018 11:22 AM INDEX NO. EFC-2018-1227 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/24/2018 WHEREFORE, Plaintiff demands judgment against MICHELLE FOSTER A/K/A MICHELLE L PASCHALL for the sum of $999.78 plus post judgment interest, costs and disbursements of this action and for such further and other relief as the Court deems just and proper. Dated: 07/19/18 PRESSLER, FELT & WARSHAW, i LLP Attorneys for Plaintiff 305 Broadway 9th Floor New York, NY 10007 (516)222- {X] By: Cr ig S. S lie , sq. ( ] By: Ian Z. Winograd Esq. { ) By: David B. Warshaw Esq. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 3 of 3