Preview
ESX-L-004111-24 06/17/2024 3:00:28 AM Pg 1 of 5 Trans ID: LCV20241509135
Tromberg, Morris & Partners, PLLC
Dianne Rhonda Ramdeen, BAR ID# 325762022
Anthony Poulin, BAR ID# 006222008
Joseph Devine, BAR ID# 031072011
39 Broadway, Suite 1250
New York, NY 10006
(800)280-6205
Attorneys for Plaintiff,
Credit Corp Solutions Inc
-------------------------------------------X
: Superior Court of New Jersey
Credit Corp Solutions Inc as Assignee of First Electronic Bank : Law Division
Plaintiff, : Essex County
-against- :
Peter Louzek :
Defendant(s). : Civil Action
: SUMMONS
:
:
-------------------------------------------X
From the State of New Jersey
To the Defendant Named Above: Peter Louzek
The plaintiff, named above, has filed a lawsuit against you in the Superior Court of New Jersey. The
complaint attached to this summons states the basis for this lawsuit. If you dispute this complaint, you or your
attorney must file a written answer or motion and proof of service with the deputy clerk of the Superior Court in the
county listed above within 35 days from the date you received this summons, not counting the date you received it.
(The address of each deputy clerk of the Superior Court is available in the Civil Division Management Office in the
county listed above and online at http://www.njcourts.gov/forms/10153_deptyclerklawref.pdf.) If the complaint is
one in foreclosure, then you must file your written answer or motion and proof of service with the Clerk of the
Superior Court, Hughes Justice Complex, P.O. Box 971, Trenton, NJ 08625-0971. A filing fee payable to the
Treasurer, State of New Jersey and a completed Case Information Statement (available from the deputy clerk of the
Superior Court) must accompany your answer or motion when it is filed. You must also send a copy of your answer
above. A telephone call will not protect your rights; you must file and serve a written answer or motion (with fee of
$175.00 and completed Case Information Statement) if you want the court to hear your defense.
If you do not file and serve a written answer or motion within 35 days, the court may enter a judgment
against you for the relief plaintiff demands, plus interest and costs of suit. If judgment is entered against you, the
Sheriff may seize your money, wages or property to pay all or part of the judgment.
If you cannot afford an attorney, you may call the Legal Services office in the county where you live or the
Legal Services of New Jersey Hotline at 1-888-LSNJ-LAW (1-888576-5529). A list of these offices is provided. If
you do not have an attorney and are not eligible for free legal assistance, you may obtain a referral to an attorney by
calling one of the Lawyer Referral Services. A directory with contact information for local Legal Services Office
and Lawyer Referral Services is available in the Civil Division Management Office in the county listed above and
online at http://www.njcourts.gov/forms/10153_deptyclerklawref.pdf .
Dated: 10th day of June, 2024
___________________________________
Clerk of the Superior Court
Name of Defendant to be Served: Peter Louzek
Address of Defendant to be Served: DEF.#1 - 20 Speir Dr, South Orange NJ 07079
ESX-L-004111-24 06/17/2024 3:00:28 AM Pg 2 of 5 Trans ID: LCV20241509135
Tromberg, Morris & Partners, PLLC
Dianne Rhonda Ramdeen, BAR ID# 325762022
Anthony Poulin, BAR ID# 006222008
Joseph Devine, BAR ID# 031072011
39 Broadway, Suite 1250
New York, NY 10006
(800)280-6205
Attorneys for Plaintiff,
Credit Corp Solutions Inc
-------------------------------------------X
: Superior Court of New Jersey
Credit Corp Solutions Inc as Assignee of First : Law Division
Electronic Bank : Essex County
Plaintiff, :
-against-
:
Peter Louzek : Civil Action
Defendant(s). : COMPLAINT
:
:
-------------------------------------------X
Plaintiff Credit Corp Solutions Inc as Assignee of First Electronic Bank
its attorneys, Tromberg, Morris & Partners, PLLC as and for its complaint against defendant(s)
Peter Louzek
THE PARTIES
1. At all times hereinafter mentioned, Plaintiff was and still is active domestic entity
conducting business in the state of UT.
2. Upon information and belief, Defendant(s) reside(s) at 20 Speir Dr, South Orange
NJ 07079 .
AS AND FOR A FIRST CAUSE OF ACTION
(Breach of Contract)
3. That the Defendant(s) hereto executed an Agreement promising to repay First
-2-
ESX-L-004111-24 06/17/2024 3:00:28 AM Pg 3 of 5 Trans ID: LCV20241509135
Electronic Bank all amounts financed , the unpaid principal balance of which as of 2/26/2022 is set
forth in paragraph "4." below. Plaintiff is the holder and owner of said account having acquired
same for a good and valuable consideration.
4. That the amount due from the Defendant(s) who is/are now in default is based
upon a sum certain as follows:
Account XXXXXXXX1548
Date of Agreement: 06/28/2021
Balance Due: $31,196.48
5. As a result of the foregoing, Defendant(s) is/are indebted to Plaintiff in the
amount of $31,196.48.
6. Plaintiff mailed statements to the Defendant(s) advising of said balance due and
demanding payment. No payment has been forthcoming.
7.
constitutes a breach of contract between Defendant(s) and Plaintiff for which Defendant(s) is
(are) liable. Accordingly, $31,196.48 plus costs and disbursements of this action is now due and
owing by Defendant(s) to Plaintiff.
AS AND FOR A SECOND CAUSE OF ACTION
(Unjust Enrichment)
8. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
through 7 as though fully set forth herein.
9. Defendant(s) used the credit extended by Plaintiff. Defendant(s) received the
benefit of using said credit to make desired purchases without paying the reasonable value for
same.
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ESX-L-004111-24 06/17/2024 3:00:28 AM Pg 4 of 5 Trans ID: LCV20241509135
10. Defendant(s) has been unjustly enriched by using the Account to make desired
purchases without paying the reasonable value for same and, accordingly, the outstanding
amount of $31,196.48 is immediately due and owing by Defendant(s) to Plaintiff.
AS AND FOR A THIRD CAUSE OF ACTION
(Account Stated)
11. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
through 10 as though fully set forth herein.
12. Plaintiff rendered to Defendant(s) monthly, full and true accounts of the
indebtedness owing by the Defendant(s) resulting from Defendant(s) use of the Account, in an
amount as set forth hereinabove.
13. Defendant received, accepted and retained the Account statements from Plaintiff
and made no timely objection of same to Plaintiff.
14. Accordingly, an account has been stated in favor of Plaintiff and against
Defendant(s) in the amount of $31,196.48, no part of which has been paid despite due demand
therefore.
WHEREFORE, Plaintiff demands judgment against Defendant(s) in the sum of
$31,196.48
and further relief as this Court may deem just and proper.
I certify that, confidential personal identifiers have been redacted from documents now
submitted to the court, and will be redacted from all documents submitted in the future in
accordance with Rule 1:38-7(b).
I certify that the matter in controversy is not the subject of any other action or arbitration
-4-
ESX-L-004111-24 06/17/2024 3:00:28 AM Pg 5 of 5 Trans ID: LCV20241509135
proceeding, now or contemplated, and that no other parties should be joined in this action.
R.4:5-1.
Dated: 10th day of June, 2024
Tromberg, Morris & Partners, PLLC
By: ___________________________
Dianne Rhonda Ramdeen, Esq., BAR ID# 325762022
Anthony Poulin, Esq., BAR ID# 006222008
Joseph Devine, Esq., BAR ID# 031072011
Attorneys for Plaintiff,
517985
-5-
Preview
ESX-L-004111-24 06/17/2024 3:00:28 AM Pg 1 of 5 Trans ID: LCV20241509135 Tromberg, Morris & Partners, PLLC Dianne Rhonda Ramdeen, BAR ID# 325762022 Anthony Poulin, BAR ID# 006222008 Joseph Devine, BAR ID# 031072011 39 Broadway, Suite 1250 New York, NY 10006 (800)280-6205 Attorneys for Plaintiff, Credit Corp Solutions Inc -------------------------------------------X : Superior Court of New Jersey Credit Corp Solutions Inc as Assignee of First Electronic Bank : Law Division Plaintiff, : Essex County -against- : Peter Louzek : Defendant(s). : Civil Action : SUMMONS : : -------------------------------------------X From the State of New Jersey To the Defendant Named Above: Peter Louzek The plaintiff, named above, has filed a lawsuit against you in the Superior Court of New Jersey. The complaint attached to this summons states the basis for this lawsuit. If you dispute this complaint, you or your attorney must file a written answer or motion and proof of service with the deputy clerk of the Superior Court in the county listed above within 35 days from the date you received this summons, not counting the date you received it. (The address of each deputy clerk of the Superior Court is available in the Civil Division Management Office in the county listed above and online at http://www.njcourts.gov/forms/10153_deptyclerklawref.pdf.) If the complaint is one in foreclosure, then you must file your written answer or motion and proof of service with the Clerk of the Superior Court, Hughes Justice Complex, P.O. Box 971, Trenton, NJ 08625-0971. A filing fee payable to the Treasurer, State of New Jersey and a completed Case Information Statement (available from the deputy clerk of the Superior Court) must accompany your answer or motion when it is filed. You must also send a copy of your answer above. A telephone call will not protect your rights; you must file and serve a written answer or motion (with fee of $175.00 and completed Case Information Statement) if you want the court to hear your defense. If you do not file and serve a written answer or motion within 35 days, the court may enter a judgment against you for the relief plaintiff demands, plus interest and costs of suit. If judgment is entered against you, the Sheriff may seize your money, wages or property to pay all or part of the judgment. If you cannot afford an attorney, you may call the Legal Services office in the county where you live or the Legal Services of New Jersey Hotline at 1-888-LSNJ-LAW (1-888576-5529). A list of these offices is provided. If you do not have an attorney and are not eligible for free legal assistance, you may obtain a referral to an attorney by calling one of the Lawyer Referral Services. A directory with contact information for local Legal Services Office and Lawyer Referral Services is available in the Civil Division Management Office in the county listed above and online at http://www.njcourts.gov/forms/10153_deptyclerklawref.pdf . Dated: 10th day of June, 2024 ___________________________________ Clerk of the Superior Court Name of Defendant to be Served: Peter Louzek Address of Defendant to be Served: DEF.#1 - 20 Speir Dr, South Orange NJ 07079 ESX-L-004111-24 06/17/2024 3:00:28 AM Pg 2 of 5 Trans ID: LCV20241509135 Tromberg, Morris & Partners, PLLC Dianne Rhonda Ramdeen, BAR ID# 325762022 Anthony Poulin, BAR ID# 006222008 Joseph Devine, BAR ID# 031072011 39 Broadway, Suite 1250 New York, NY 10006 (800)280-6205 Attorneys for Plaintiff, Credit Corp Solutions Inc -------------------------------------------X : Superior Court of New Jersey Credit Corp Solutions Inc as Assignee of First : Law Division Electronic Bank : Essex County Plaintiff, : -against- : Peter Louzek : Civil Action Defendant(s). : COMPLAINT : : -------------------------------------------X Plaintiff Credit Corp Solutions Inc as Assignee of First Electronic Bank its attorneys, Tromberg, Morris & Partners, PLLC as and for its complaint against defendant(s) Peter Louzek THE PARTIES 1. At all times hereinafter mentioned, Plaintiff was and still is active domestic entity conducting business in the state of UT. 2. Upon information and belief, Defendant(s) reside(s) at 20 Speir Dr, South Orange NJ 07079 . AS AND FOR A FIRST CAUSE OF ACTION (Breach of Contract) 3. That the Defendant(s) hereto executed an Agreement promising to repay First -2- ESX-L-004111-24 06/17/2024 3:00:28 AM Pg 3 of 5 Trans ID: LCV20241509135 Electronic Bank all amounts financed , the unpaid principal balance of which as of 2/26/2022 is set forth in paragraph "4." below. Plaintiff is the holder and owner of said account having acquired same for a good and valuable consideration. 4. That the amount due from the Defendant(s) who is/are now in default is based upon a sum certain as follows: Account XXXXXXXX1548 Date of Agreement: 06/28/2021 Balance Due: $31,196.48 5. As a result of the foregoing, Defendant(s) is/are indebted to Plaintiff in the amount of $31,196.48. 6. Plaintiff mailed statements to the Defendant(s) advising of said balance due and demanding payment. No payment has been forthcoming. 7. constitutes a breach of contract between Defendant(s) and Plaintiff for which Defendant(s) is (are) liable. Accordingly, $31,196.48 plus costs and disbursements of this action is now due and owing by Defendant(s) to Plaintiff. AS AND FOR A SECOND CAUSE OF ACTION (Unjust Enrichment) 8. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1 through 7 as though fully set forth herein. 9. Defendant(s) used the credit extended by Plaintiff. Defendant(s) received the benefit of using said credit to make desired purchases without paying the reasonable value for same. -3- ESX-L-004111-24 06/17/2024 3:00:28 AM Pg 4 of 5 Trans ID: LCV20241509135 10. Defendant(s) has been unjustly enriched by using the Account to make desired purchases without paying the reasonable value for same and, accordingly, the outstanding amount of $31,196.48 is immediately due and owing by Defendant(s) to Plaintiff. AS AND FOR A THIRD CAUSE OF ACTION (Account Stated) 11. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1 through 10 as though fully set forth herein. 12. Plaintiff rendered to Defendant(s) monthly, full and true accounts of the indebtedness owing by the Defendant(s) resulting from Defendant(s) use of the Account, in an amount as set forth hereinabove. 13. Defendant received, accepted and retained the Account statements from Plaintiff and made no timely objection of same to Plaintiff. 14. Accordingly, an account has been stated in favor of Plaintiff and against Defendant(s) in the amount of $31,196.48, no part of which has been paid despite due demand therefore. WHEREFORE, Plaintiff demands judgment against Defendant(s) in the sum of $31,196.48 and further relief as this Court may deem just and proper. I certify that, confidential personal identifiers have been redacted from documents now submitted to the court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b). I certify that the matter in controversy is not the subject of any other action or arbitration -4- ESX-L-004111-24 06/17/2024 3:00:28 AM Pg 5 of 5 Trans ID: LCV20241509135 proceeding, now or contemplated, and that no other parties should be joined in this action. R.4:5-1. Dated: 10th day of June, 2024 Tromberg, Morris & Partners, PLLC By: ___________________________ Dianne Rhonda Ramdeen, Esq., BAR ID# 325762022 Anthony Poulin, Esq., BAR ID# 006222008 Joseph Devine, Esq., BAR ID# 031072011 Attorneys for Plaintiff, 517985 -5-