Preview
FILED: NEW YORK COUNTY CLERK 05/08/2024 06:19 PM INDEX NO. 154266/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/08/2024
CONSUMER CREDIT TRANSACTION
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
Midland Credit Management, Inc, Index No.:
Plaintiff, Date Purchased
vs. SUMMONS
The basis of the venue designated is
The defendant resides in the
SANJAY SEEPERSAUD, County of New York
Defendant. The transaction took place in the
County of New York
To the above-named Defendant:
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) at the address stated below 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); and in
case of your failure to appear or answer, judgment will be taken against you by default for the
relief demanded in the complaint.
Dated: Williamsville NY /
/ C) , 20 By:
MA I I AW GROUP, LLP
Ieath A. Johnson, Esq.
Mari Purpura, Esq.
Atto eys for Plaintiff
600 Essjay Rd., Suite 200
Williamsville, NY 14221
(833) 769-2757
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FILED: NEW YORK COUNTY CLERK 05/08/2024 06:19 PM INDEX NO. 154266/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/08/2024
TO: SANJAY SEEPERSAUD
400 FORT WASHINGTON AVE
APT 1D
NEW YORK, NY 10033
WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT
COLLECTOR.
PLAINTIFF'S COUNSEL'S NYCDCA LICENSE NUMBER: 2079588-DCA
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FILED: NEW YORK COUNTY CLERK 05/08/2024 06:19 PM INDEX NO. 154266/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/08/2024
CONSUMER CREDIT TRANSACTION
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
Midland Credit Management, Inc,
COMPLAINT
Plaintiff,
vs.
Index No.:
SANJAY SEEPERSAUD,
Defendant.
Plaintiff, Midland Credit Management, Inc, by its attorneys, Mandarich Law Group, LLP,
complaining of the Defendant, SANJAY SEEPERSAUD, alleges the following:
1. Plaintiff is a foreign limited liability company organized and existing by virtue of the laws
of Delaware, with a principal place of business located at 350 Camino De La Reina, Suite 100,
San Diego, Califomia and licensed with the New York City Department of Consumer Affairs,
license number 1140603-DCA
2. Upon information and belief, Defendant SANJAY SEEPERSAUD, was and is a natural
person residing at 400 FORT WASHINGTON AVE APT 1D , County ofNew York, State of New
York.
3. Plaintiff took by assignment and/or purchased, for value, all rights, title, and interest of
certain accounts, including the account identified below, which originated with SYNCHRONY
BANK (hereinafter the "Original Creditor").
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FILED: NEW YORK COUNTY CLERK 05/08/2024 06:19 PM INDEX NO. 154266/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/08/2024
4. The chain of title is as follows:
Date of Assignor: Assignee: Account Balance at
Assignment Transfer:
(On or About):
2/24/2023 SYNCHRONY BANK Midland Credit $4,439.16
Management, Inc
5. The Original Creditor issued a consumer credit card account to the Defendant bearing an
account number ending in XXXXXXXXXXXX8267 as printed on the most recent account
statement recording a purchase transaction, payment or balance transfer (hereinafter the
"Account"), which Account is the subject of this action.
6. Defendant entered into an agreement with the Original Creditor and made purchases,
received cash, merchandise, and/or credit on the Account.
7. A copy of the Charge-Off statement for the Account is attached hereto.
8. An itemization of the Account is as follows:
Total due at charge-off: $4,439.16
Total interest accrued since charge-off: $0.00
Total non-interest charges/fees accrued since charge-off: $0.00
Total amount of payments and/or credits since charge-off: $392.00
9. The last payment on the account was made on: 08/26/2021 in the amount of $196.00.
10. The Account balance printed on the most recent Account statement provided by the
Original Creditor recording a purchase, transaction, last payment or balance transfer was
$3,651.92.
11. Defendant agreed to but failed to make payments on said Account and $4,032.95 is now
due and owing to the Plaintiff from Defendant, which amount has been demanded and remains
unpaid.
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FILED: NEW YORK COUNTY CLERK 05/08/2024 06:19 PM INDEX NO. 154266/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/08/2024
12. Defendant is in default and Plaintiff, as owner of the Account, is authorized to proceed
with this action.
13. Plaintiff has suffered damages in the amount of $4,032.95, together with the costs and
disbursements incurred in this action.
14. The causes of action asserted herein are not outside of the applicable statute of limitations
for enforcing the debt.
WHEREFORE, Plaintiff, Midland Credit Management, Inc, respectfully requests judgment
against the Defendant, SANJAY SEEPERSAUD, for the sum of $4,032.95, all costs and
disbursements of this action, with interest from the date of any judgment granted or ordered, and for
such other and further relief as this Court dee s/j'ust and proper.
Dated: Williams ile, New York
, 20 By:
MANI ICH LAW GROUP, LLP
Heat er . Johnson, Esq.
Mari n Purpura, Esq.
Attor ys for Plaintiff
600 Essjay Rd., Suite 200
Williamsville, NY 14221
(833) 769-2757
MLG-4836291
TO: SANJAY SEEPERSAUD
400 FORT WASHINGTON AVE APT
ID
NEW YORK, NY 10033
WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT
COLLECTOR.
PLAINTIFF'S COUNSEL'S NYCDCA LICENSE NUMBER: 2079588-DCA
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Preview
FILED: NEW YORK COUNTY CLERK 05/08/2024 06:19 PM INDEX NO. 154266/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/08/2024 CONSUMER CREDIT TRANSACTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Midland Credit Management, Inc, Index No.: Plaintiff, Date Purchased vs. SUMMONS The basis of the venue designated is The defendant resides in the SANJAY SEEPERSAUD, County of New York Defendant. The transaction took place in the County of New York To the above-named Defendant: 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) at the address stated below 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); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: Williamsville NY / / C) , 20 By: MA I I AW GROUP, LLP Ieath A. Johnson, Esq. Mari Purpura, Esq. Atto eys for Plaintiff 600 Essjay Rd., Suite 200 Williamsville, NY 14221 (833) 769-2757 1 of 5 FILED: NEW YORK COUNTY CLERK 05/08/2024 06:19 PM INDEX NO. 154266/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/08/2024 TO: SANJAY SEEPERSAUD 400 FORT WASHINGTON AVE APT 1D NEW YORK, NY 10033 WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. PLAINTIFF'S COUNSEL'S NYCDCA LICENSE NUMBER: 2079588-DCA 2 of 5 FILED: NEW YORK COUNTY CLERK 05/08/2024 06:19 PM INDEX NO. 154266/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/08/2024 CONSUMER CREDIT TRANSACTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Midland Credit Management, Inc, COMPLAINT Plaintiff, vs. Index No.: SANJAY SEEPERSAUD, Defendant. Plaintiff, Midland Credit Management, Inc, by its attorneys, Mandarich Law Group, LLP, complaining of the Defendant, SANJAY SEEPERSAUD, alleges the following: 1. Plaintiff is a foreign limited liability company organized and existing by virtue of the laws of Delaware, with a principal place of business located at 350 Camino De La Reina, Suite 100, San Diego, Califomia and licensed with the New York City Department of Consumer Affairs, license number 1140603-DCA 2. Upon information and belief, Defendant SANJAY SEEPERSAUD, was and is a natural person residing at 400 FORT WASHINGTON AVE APT 1D , County ofNew York, State of New York. 3. Plaintiff took by assignment and/or purchased, for value, all rights, title, and interest of certain accounts, including the account identified below, which originated with SYNCHRONY BANK (hereinafter the "Original Creditor"). 3 of 5 FILED: NEW YORK COUNTY CLERK 05/08/2024 06:19 PM INDEX NO. 154266/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/08/2024 4. The chain of title is as follows: Date of Assignor: Assignee: Account Balance at Assignment Transfer: (On or About): 2/24/2023 SYNCHRONY BANK Midland Credit $4,439.16 Management, Inc 5. The Original Creditor issued a consumer credit card account to the Defendant bearing an account number ending in XXXXXXXXXXXX8267 as printed on the most recent account statement recording a purchase transaction, payment or balance transfer (hereinafter the "Account"), which Account is the subject of this action. 6. Defendant entered into an agreement with the Original Creditor and made purchases, received cash, merchandise, and/or credit on the Account. 7. A copy of the Charge-Off statement for the Account is attached hereto. 8. An itemization of the Account is as follows: Total due at charge-off: $4,439.16 Total interest accrued since charge-off: $0.00 Total non-interest charges/fees accrued since charge-off: $0.00 Total amount of payments and/or credits since charge-off: $392.00 9. The last payment on the account was made on: 08/26/2021 in the amount of $196.00. 10. The Account balance printed on the most recent Account statement provided by the Original Creditor recording a purchase, transaction, last payment or balance transfer was $3,651.92. 11. Defendant agreed to but failed to make payments on said Account and $4,032.95 is now due and owing to the Plaintiff from Defendant, which amount has been demanded and remains unpaid. 4 of 5 FILED: NEW YORK COUNTY CLERK 05/08/2024 06:19 PM INDEX NO. 154266/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/08/2024 12. Defendant is in default and Plaintiff, as owner of the Account, is authorized to proceed with this action. 13. Plaintiff has suffered damages in the amount of $4,032.95, together with the costs and disbursements incurred in this action. 14. The causes of action asserted herein are not outside of the applicable statute of limitations for enforcing the debt. WHEREFORE, Plaintiff, Midland Credit Management, Inc, respectfully requests judgment against the Defendant, SANJAY SEEPERSAUD, for the sum of $4,032.95, all costs and disbursements of this action, with interest from the date of any judgment granted or ordered, and for such other and further relief as this Court dee s/j'ust and proper. Dated: Williams ile, New York , 20 By: MANI ICH LAW GROUP, LLP Heat er . Johnson, Esq. Mari n Purpura, Esq. Attor ys for Plaintiff 600 Essjay Rd., Suite 200 Williamsville, NY 14221 (833) 769-2757 MLG-4836291 TO: SANJAY SEEPERSAUD 400 FORT WASHINGTON AVE APT ID NEW YORK, NY 10033 WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. PLAINTIFF'S COUNSEL'S NYCDCA LICENSE NUMBER: 2079588-DCA 5 of 5