FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`
`INDEX NO. 59394/2023
`
`CONSUMER CREDIT TRANSACTION
`
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF WESTCHESTER
`Cavalry SPV I, LLC
`
`
`
`
`-against-
`
`
`
`VINCENT GORMAN
`
`
`
`
`
`
`
`
`Plaintiff,
`
`
`
`Defendant(s).
`
`X
`
`
`
`X
`
`Date Purchased:
`
`
`
`Index №
`
`
`SUMMONS
`Plaintiff's Address:
`1 American Lane, Suite 220
`Greenwich CT 06131
`
`
`
`
`
`The Basis of Venue is:
`
`CPLR SEC. 503(f). Defendants
`residence is in the County of
`
`WESTCHESTER.
`
`
`DEF1- 21 MAPLE AVE APT 3A, HASTINGS ON HUDSON NY 10706-1424
`
`
`
`
`
`
`Defendant(s) Address:
`
`
`
`
`
`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 on the Plaintiff's Attorney(s) within 20 days after the service of this summons, exclusive of the day of
`service, or within 30 days after service is complete if this summons is not personally delivered to you within the
`State of New York; and in the case of your failure to appear or answer, judgment will be taken against you by
`default for the relief demanded in the complaint.
`
`
`
`
`Dated: March 29, 2023
`Matter # 487863
`
`
`
`
`
`
`We are attorneys attempting to collect a debt. Any information obtained will be used for that purpose.
`
`____________________________
` Stephen Einstein
` Urva S. Ahmed
` Anthony S. Poulin
` Joseph J. Cassotta
` Scott Morris
` Joseph G. Devine
` Chester Andrew Guala
`
`
`
`Tromberg, Morris & Poulin, PLLC.
`Attorneys for the Plaintiff
`39 Broadway, Suite 1250
`New York, N.Y. 10006
`(212) 267-3550
`
`*SM0000487863*
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`S_S_SUP-SUM
`
`1 of 16
`
`

`

`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`INDEX №:
`
`
`
`INDEX NO. 59394/2023
`
`Plaintiff,
`
`
`Defendant(s).
`
`COMPLAINT
`
`
`
`
`
`
`
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF WESTCHESTER
`
`Cavalry SPV I, LLC
`
`
`
`
`-against-
`
`
`
`
`VINCENT GORMAN
`
`
`
`
`
`
`
`
`
`Plaintiff, by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges that:
`
`1. Plaintiff is an active foreign entity conducting business in New York.
`
`2. Upon information and belief, the Defendant(s) resides or has an office in the venue in which this
`action is brought, or the Defendant(s) transacted business within the venue in which this action is brought,
`either in person or through an agent, and the instant cause of action arose out of said transaction.
`
`3. Based upon a reasonable inquiry, the Statute of Limitations for the cause of action asserted herein
`has not expired.
`
`
`AS AND FOR A FIRST CAUSE OF ACTION
`
`
`4. Upon information and belief the Defendant(s) hereto entered into a Revolving Credit Account
`Agreement (hereinafter "Account") with Synchrony Bank (hereinafter "Original Creditor"), the Original
`Creditor as defined by CPLR §105(g-1), bearing an account number on the most recent statement ending
`in #XXXXXXXXXXXX6207, as so evidenced in the statement attached hereto, wherein Defendant(s)
`agreed to pay Original Creditor all amounts charged to said Account.
`
`5. Upon information and belief, Defendant(s) incurred charges by use of the said Account and
`defaulted. As a result of the Defendant’s default the Original Creditor closed the Account and
`subsequently charged it off on 07/23/2021 in the amount of $4,785.19. Pursuant to CPLR §3016(j) a
`copy of the Charge-Off Statement is attached hereto as Exhibit A.
`
`6. Susequently, the Original Creditor sold/ assigned the Account, including all rights, title and interest
`in and to the outstanding balance owed by Defendant(s). Plaintiff, purchased and/or took by assignment
`the account herein on or about 05/17/2022. The complete chain of sale and assignment and dates sold
`and/or assigned are as follows:
`
`
`Assignor
`Transfer 1: Synchrony Bank
`
`
`
`
`
`
`Date of Transfer Amt. at Time of Transfer
`5/17/2022
`$4,785.19
`
`
`
`
`
`
`
`
`
`7. Upon information and belief the date of last payment on this account was 11/30/2020 in the amount
`of $105.00.
`
`
`S_S_COM-RTL
`
`2 of 16
`
`

`

`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`
`INDEX NO. 59394/2023
`
`8. The account balance printed on the most recent monthly statement recording a purchase transaction,
`last payment or balance transfer is attached hereto as Exhibit B.
`
`9. At this time, Defendant(s) owes $4,785.19 on the Account. This amount includes a charge-off
`balance of $4,785.19, post-charge-off interest of $0.00, post-charge-off fees and charges of $0.00, less any
`post-charge-off credits or payments made by or on behalf of the Defendant of $0.00; and that amount has
`not been paid despite due demand.
`
`
`WHEREFORE, Plaintiff demands judgment against Defendant(s) in the amount of $4,785.19, plus
`costs and disbursements.
`
`CERTIFICATION: Deponent is an attorney associated with Tromberg, Morris & Poulin, PLLC. Deponent
`certifies that, to the best of their knowledge, information and belief, formed after an inquiry reasonable
`under the circumstances, the presentation of the paper or the contentions therein are not frivolous as defined
`in section 130-1.1(c) of the Chief Administrative Judge, and as an initiating pleading, the matter was not
`obtained through illegal conduct, and the matter was not obtained in violation of Part 1200. Rule 4.5 of this
`Title. Affirmed this 29th day of March, 2023.
`
`
`Matter # 487863
`
`
`
`
`
`
`
`
`
`
`
`
`
`____________________________
` Stephen Einstein
` Urva S. Ahmed
` Anthony S. Poulin
` Joseph J. Cassotta
` Scott Morris
` Joseph G. Devine
` Chester Andrew Guala
`
`
`
`
`S_S_COM-RTL
`
`3 of 16
`
`

`

`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`
`INDEX NO. 59394/2023
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Matter #: 487863
`
`
`
`S_EXH-COSM
`
`EXHIBIT “A”
`(CHARGE-OFF/ LAST STATEMENT)
`
`
`
`
`
`
`
`4 of 16
`
`

`

`INDEX NO. 59394/2023
`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`
`Q PayPal
`
`Need
`
`to
`
`adjust
`
`a
`
`due
`
`date?
`
`Call
`
`this
`
`customer
`
`statement
`
`service
`
`at
`
`the
`
`phone
`
`number
`
`to
`
`determine
`
`if your
`
`account
`
`on
`
`is
`
`eligible
`
`and
`
`discuss
`
`available
`
`options.
`
`n-:
`mm
`
`VINCENT GORMAN
`Account Number
`
`6207
`
`Visit us at www.paypal.com
`PayPal Credit Services:
`1-866-437-2914
`
`Information
`Payment
`New Balance
`Amount Past Due
`Total Minimum Payment Due
`Payment Due Date
`
`$0.00
`$0.00
`$1,155.00
`07/25/2021
`
`Late Payment Warning:If we do not receive your Total
`Minimum Payment Due by the Payment Due Date listed
`above, you may have to pay a late fee up to $40.00.
`
`of Account Activity
`Summary
`Previous Balance
`- Other Credits
`+ Fees Charged
`New Balance
`
`Credit Limit
`Available Credit
`Cash Limit
`Available Cash
`Statement Closing Date
`Days in Billing Cycle
`
`$4,745.19
`$4,785.19
`$40.00
`$0.00
`
`$3,720.00
`$0.00
`$744.00
`$0.00
`07/23/2021
`30
`
`New York residents may contact the New York State
`Department of Financial Services by telephone or visit its
`website for free information on comparative credit card rates,
`fees and grace periods.
`NY State Dept of Financial Services:
`1-800-342-3736 http://www.dfs.ny.gov
`
`PayPal Extras Rewards Program
`Previous Reward Point Balance
`+ Points Earned This Period
`- Points Redeemed
`= Current Reward Point Balance
`
`Information
`Rewards
`Earn 3x points at gas stations & restaurants, 2x points
`at PayPal & eBay, and 1x point everywhere else
`Mastercard is accepted! Redeem for rewards starting
`at 800 Points. Points expire after 24 months.
`
`O
`O
`O
`O
`
`0
`
`3,000
`
`6,000
`
`9,000
`
`12,000+
`
`PAYMENT DUE BY 5 P.M. (ET) ON THE DUE DATE.
`NOTICE: We may convert your payment
`into an electronic debit. See reverse for details, Billing Rights Information and other
`information.
`important
`
`8640
`
`YBG
`
`1
`
`22
`1192
`Z XPAGE 1 of 3
`3
`210723
`1000 P603 01CW8640
`Detach and mail this portion with your check. Do not include any correspondence with your check.
`
`Total Minimum
`Payment Due
`$1,155.00
`
`Amount
`Past Due
`$0.00
`
`Account Number:
`Payment Due
`Overlimit
`Date
`Amount
`07/25/2021
`$0.00
`
`6207
`New Balance
`
`$0.00
`
`Payment Enclosed: Please use
`blue or black ink. Save a stamp,
`pay on-line at www.paypal.com
`
`New address or email? Print changes on back.
`
`VINCENT GORMAN
`21 MAPLE AVE
`HASTINGS ON HUDSON NY 10706-1424
`
`Make Payment to: PAYPAL CREDIT SVCS/SYNCB
`PO BOX 960080
`ORLANDO, FL 32896-0080
`
`5 of 16
`
`

`

`INDEX NO. 59394/2023
`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`
`Need
`
`an
`
`extra
`
`card?
`
`Call
`
`us
`
`at
`
`1-866-448-4367
`
`6 of 16
`
`

`

`INDEX NO. 59394/2023
`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`
`P PayPal
`
`Transaction
`Summary
`Tran Date Post Date
`07/23
`07/23
`07/23
`07/23
`
`Reference Number
`F1192006C00999990
`F1192006C00999990
`
`07/17
`
`07/17
`
`07/23
`07/23
`
`07/23
`07/23
`
`Description of Transaction or Credit
`CHARGE OFF ACCOUNT-PRINCIPALS
`CHARGE OFF ACCOUNT-INTEREST CHARGE
`FEES
`LATE FEE
`TOTAL FEES FOR THIS PERIOD
`INTEREST CHARGED
`INTEREST CHARGE ON PURCHASES
`INTEREST CHARGE ON CASH ADVANCES
`TOTAL INTEREST FOR THIS PERIOD
`
`Amount
`($3,535.01)
`($1,250.18)
`
`$40.00
`$40.00
`
`$0.00
`$0.00
`$0.00
`
`2021 Totals Year-to-Date
`Total Fees Charged in 2021
`Interest Charged in 2021
`Total
`Interest Paid in 2021
`
`Total
`
`$474.54
`
`$463.61
`
`$0.00
`
`Interest Charge Calculation
`Your Annual Percentage Rate (APR) is the annual
`Expiration
`Date
`N/A
`N/A
`
`Type of Balance
`Purchases
`Cash Advances
`(v) = Variable Rate
`
`interest rate on your account.
`
`Annual Percentage
`Rate
`19.99% (v)
`26.99% (v)
`
`Balance Subject to
`Interest Rate
`$0.00
`$0.00
`
`Interest Charge
`$0.00
`$0.00
`
`News and Information
`Cardholder
`The Annual Percentage Rate (APR) for Purchases will apply to Balance Transfers if they are made available to you and the
`Balance Transfers are not subject to a promotional APR.
`Did you know your Mastercard offers Mastercard ID Theft Protection. For more information about this benefit or to view the
`current benefits offered by Mastercard, please visit: www.mastercard.com/corecredit-GTB.
`Statement not provided to customer.
`You can pay your bill online or over the phone. We noticed you've been enjoying our easy paperless payment options, so we
`will no longer be including return envelopes. You can make things even easier by selecting the paperless statement option on
`your account online.
`
`I
`
`-
`
`8640
`
`YBG
`
`1
`
`3
`
`22
`
`210723
`
`Z X PAGE2 of 3
`7 of 16
`
`1192
`
`1000 P603 01CW8640
`
`

`

`INDEX NO. 59394/2023
`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`
`8640
`
`YBG
`
`1
`
`3
`
`22
`
`210723
`
`Z X PAGE3 of 3
`8 of 16
`
`1192
`
`1000 P603 OlCW8640
`
`

`

`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`
`INDEX NO. 59394/2023
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Matter #: 487863
`
`
`
`S_EXH-LPAM
`
`EXHIBIT “B”
`(LAST USE OF CARD STATEMENT/ BALANCE)
`
`
`
`
`
`
`
`9 of 16
`
`

`

`INDEX NO. 59394/2023
`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`Turn
`rewa
`monthly
`into
`RECEIVED NYSCEF: 04/11/2023
`NYSCEF DOC. NO. 1
`bills
`Earn points* when you set up automatic
`with your PayPal Extras Mastercard® for
`
`bill paymen
`recurring
`like:
`things
`
`to credit a proval. Automatic payments are treated as purchases and qualify for rewards. See your Rewards
`*Purchases subject
`Program Terms for more det
`**Mastercard may not be accepted by all service providers.
`
`VINCENT GORMAN
`Account Number
`
`6207
`
`Visit us at www.paypal.com
`PayPal Credit Services:
`1-866-300-6432
`
`Information
`Payment
`New Balance
`Total Minimum Payment Due
`Overlimit Amount
`Payment Due Date
`
`$3,847.04
`$106.00
`$127.04
`01/17/2021
`
`of Account Activity
`Summary
`Previous Balance
`- Payments
`+ Fees Charged
`+ Interest Charges
`New Balance
`
`Credit Limit
`Available Credit
`Cash Limit
`Available Cash
`Statement Closing Date
`Days in Billing Cycle
`
`$3,822.09
`$105.00
`$62.82
`$67.13
`$3,847.04
`
`$3,720.00
`OVERLIMIT
`$744.00
`OVERLIMIT
`12/24/2020
`30
`
`New York residents may contact the New York State
`Department of Financial Services by telephone or visit its
`website for free information on comparative credit card rates,
`fees and grace periods.
`NY State Dept of Financial Services:
`1-800-342-3736 http://www.dfs.ny.gov
`
`Late Payment Warning:If we do not receive your Total
`Minimum Payment Due by the Payment Due Date listed
`above, you may have to pay a late fee up to $40.00.
`Minimum Payment Warning:
`If you make only the minimum
`payment each period, you will pay more in interest and it will
`take you longer to pay off your balance. For example:
`If you make no
`You will pay off
`additional charges
`the balance
`using this card
`shown on this
`and each month
`in
`statement
`You pay ...
`about ...
`Only the minimum
`payment
`
`16 years
`
`$10,480.00
`
`And you will end
`up paying an
`estimated total
`
`$146.00
`
`3 years
`
`If you would like information about
`call 1-877-302-8775.
`services,
`
`$5,268.00
`(Savings=
`$5,212.00)
`credit counseling
`
`PAYMENT DUE BY 5 P.M. (ET) ON THE DUE DATE.
`into an electronic debit. See Statement Disclosures link on your eServices Statement
`Notice: We may convert your payment
`Page for details, Billing Rights and other important
`information.
`
`8640
`
`YBG
`
`1
`
`7
`
`22
`
`201224
`
`OPAGE1 of 3
`
`1192
`
`1000 P603 01CW8640
`
`-
`
`I
`
`Total Minimum
`Payment Due
`$106.00
`
`Payment
`Due Date
`01/17/2021
`
`Account Number:
`Overlimit
`Amount
`$127.04
`
`6207
`New Balance
`
`$3,847.04
`
`Save a stamp, pay on-line at
`www.paypal.com
`
`VINCENT GORMAN
`21 MAPLE AVE
`HASTINGS ON HUDSON NY 10706-1424
`
`Make Payment to: PAYPAL CREDIT SVCS/SYNCB
`PO BOX 960080
`ORLANDO, FL 32896-0080
`
`10 of 16
`
`

`

`INDEX NO. 59394/2023
`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`
`Need
`
`an
`
`extra
`
`card?
`
`Call
`
`us
`
`at
`
`1-866-448-4367
`
`11 of 16
`
`

`

`Q PayPat
`
`earn
`
`d
`
`s
`
`*
`
`.
`
`INDEX NO. 59394/2023
`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`to
`RECEIVED NYSCEF: 04/11/2023
`NYSCEF DOC. NO. 1
`les
`easy
`rewar
`
`0
`
`9
`
`Q-
`
`3 Points
`per $1 spent on gas and
`restaurant
`purchases
`
`2 Points
`per $1 spent on PayPal
`and eBay purchases
`
`1 Point
`per $1 spent on all other
`Mastercard® purchases
`
`*Purchases subject
`
`to credit approval. See your Rewards Program Terms for more details.
`
`PayPal Extras Rewards Program
`Previous Reward Point Balance
`+ Points Earned This Period
`- Points Redeemed
`= Current Reward Point Balance
`Month Reward Points to Expire
`Next Reward Points to Expire
`
`8,825
`O
`O
`8,825
`03/2021
`445
`
`Information
`Rewards
`Congratulations!
`You currently have 8,825 points.
`You can redeem your points at www.paypal.com for
`travel, and cash back as a credit
`gift cards, merchandise,
`into your PayPal balance.* Points expire after 24 months.
`*You need to have a PayPal Cash or PayPal Cash Plus
`to have a balance.
`If you do not have one of those
`account
`accounts, you can only transfer your Cash Rewards to your
`bank account or debit card linked to your PayPal account.
`
`0
`
`3,000
`
`6,000
`
`9,000
`
`12,000+
`
`Transaction
`Summary
`Tran Date Post Date
`11/30
`11/30
`
`Reference Number
`F119200NZ000BA
`
`12/24
`
`12/24
`
`12/24
`12/24
`
`12/24
`12/24
`
`Description of Transaction or Credit
`PAYMENT - THANK YOU
`FEES
`CARD SECURITY 1 800 815 4051
`TOTAL FEES FOR THIS PERIOD
`INTEREST CHARGED
`INTEREST CHARGE ON PURCHASES
`INTEREST CHARGE ON CASH ADVANCES
`TOTAL INTEREST FOR THIS PERIOD
`
`2020 Totals Year-to-Date
`Total Fees Charged in 2020
`Total
`Interest Charged in 2020
`Interest Paid in 2020
`
`Total
`
`$743.92
`
`$733.55
`
`$540.99
`
`Amount
`($105.00)
`
`$62.82
`$62.82
`
`$46.94
`$20.19
`$67.13
`
`Interest Charge Calculation
`Your Annual Percentage Rate (APR) is the annual
`Expiration
`Date
`N/A
`N/A
`
`Type of Balance
`Purchases
`Cash Advances
`(v) = Variable Rate
`
`interest rate on your account.
`
`Annual Percentage
`Rate
`19.99% (v)
`26.99% (v)
`
`Balance Subject to
`Interest Rate
`$2,856.95
`$910.10
`
`Interest Charge
`$46.94
`$20.19
`
`News and Information
`Cardholder
`Did you know your Mastercard offers Mastercard ID Theft Protection. For more information about this benefit or to view the
`current benefits offered by Mastercard, please visit: www.mastercard.com/corecredit-GTB.
`including employment and income information from others about you
`Synchrony Bank may continue to obtain information,
`(including requesting reports from consumer reporting agencies and other sources) to review, maintain or collect your account.
`
`--
`
`and Information
`Cardholder
`Benefits
`Looking for a more convenient due date? Call customer service at the phone number on your statement
`eligible and discuss available options.
`
`to determine if you are
`
`For information about your PayPal Extras Mastercard® rewards, call 1-866-300-6432 Monday- Sunday, 24U.
`
`8640
`
`YBG
`
`1
`
`7
`
`22
`
`201224
`
`OPAGE2 of 3
`12 of 16
`
`1192
`
`1000 P603 01CW8640
`
`

`

`INDEX NO. 59394/2023
`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`
`8640
`
`YBG
`
`1
`
`7
`
`22
`
`201224
`
`OPAGE3 of 3
`13 of 16
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`1192
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`1000 P603 01CW8640
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`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
` Index No.
`
`
`Year
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`
`INDEX NO. 59394/2023
`
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF WESTCHESTER
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`Cavalry SPV I, LLC
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`-against-
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`Plaintiff
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`VINCENT GORMAN
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`Defendant(s)
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`SUMMONS AND COMPLAINT
`
`Signature (Rule 130-1. 1-a)
`
`____________________________
` Stephen Einstein
` Urva S. Ahmed
` Anthony S. Poulin
` Joseph J. Cassotta
` Scott Morris
` Joseph G. Devine
` Chester Andrew Guala
`
`
`
`
`
`LAW OFFICE OF
`TROMBERG, MORRIS & POULIN, PLLC.
`Attorney(s) for Plaintiff
`Office and Post Office Address
`39 Broadway, Suite 1250
`New York, New York 10006
`(212) 267-3550
`Fax (212) 227-9656
`
`Service of a copy of the within ___________________ is hereby admitted.
`Dated,
`
`Attorney(s) for Plaintiff(s)
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`
`
`
`
`Sir: Please take notice
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`NOTICE OF ENTRY:
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`That within is a (certified) true copy of a duly entered in the office of the clerk
`of the within named court on
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`NOTICE OF SETTLEMENT
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`That an order __________________ of which the within is a true copy of a
`Settlement to the HON.
`___________________ Presented for one of the
`judges
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`Of the within named court, at
`On the ___ day of _____ 2023 at __ A.M
`Dated,
`
`S_S_SUP-BB
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`14 of 16
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`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`
`INDEX NO. 59394/2023
`
`Plaintiff,
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF WESTCHESTER
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`Cavalry SPV I, LLC
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`
`
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`-against-
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`
`
`VINCENT GORMAN
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`Defendant(s).
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`INDEX №:
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`NOTICE OF COMMENCEMENT OF ACTION
`SUBJECT TO MANDATORY ELECTRONIC FILING
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`PLEASE TAKE NOTICE that the matter captioned above has been commenced as an
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`electronically filed case in the New York State Courts Electronic Filing System (“NYSCEF”) as
`required by CPLR § 2111 and Uniform Rule § 202.5-bb (MANDATORY ELECTRONIC FILING).
`This notice is being served as required by that rule.
`
`
`NYSCEF is designed for the electronic filing of documents with the County Clerk and the
`court and for the electronic service of those documents, court documents, and court notices upon
`counsel and unrepresented litigants who have consented to electronic filing.
`
`Electronic filing offers significant benefits for attorneys and litigants, permitting papers to be
`filed with the County Clerk and the court and served on other parties simply, conveniently, and
`quickly. NYSCEF case documents are filed with the County Clerk and the court by filing on the
`NYSCEF Website, which can be done at any time of the day or night on any day of the week. The
`documents are served automatically on all consenting e-filers as soon as the document is uploaded to
`the website, which sends out an immediate email notification of the filing.
`
`The NYSCEF System charges no fees for filing, serving, or viewing the electronic case record,
`nor does it charge any fees to print any filed documents. Normal filing fees must be paid, but this can
`be done on-line.
`
`Parties represented by an attorney: An attorney representing a party who is served with this
`notice must either: 1) immediately record his or her representation within the e-filed matter on the
`NYSCEF site; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is
`pending. Exemptions from mandatory e-filing are limited to attorneys who certify in good faith that
`they lack the computer hardware and/or scanner and/or internet connection or that they lack (along
`with all employees subject to their direction) the operational knowledge to comply with e-filing
`requirements. [Section 202.5-bb(e)]
`
`Parties not represented by an attorney: Unrepresented litigants are exempt from efiling.
`They can serve and file documents in paper form and must be served with documents in paper
`form. However, an unrepresented litigant may participate in e-filing. For information on how to
`participate in e-filing, unrepresented litigants should contact the appropriate clerk in the court where
`the action was filed or visit www.nycourts.gov/efileunrepresented. Unrepresented litigants also are
`encouraged to visit www.nycourthelp.gov or contact the Help Center in the court where the action
`was filed. An unrepresented litigant who consents to e-filing may cease participation at any time.
`However, the other parties may continue to e-file their court documents in the case.
`
`
`S_S-EFI
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`15 of 16
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`FILED: WESTCHESTER COUNTY CLERK 04/11/2023 10:58 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 04/11/2023
`
`INDEX NO. 59394/2023
`
`
`
`
`____________________________
` Stephen Einstein
` Urva S. Ahmed
` Anthony S. Poulin
` Joseph J. Cassotta
` Scott Morris
` Joseph G. Devine
` Chester Andrew Guala
`
`
`
`Tromberg, Morris & Poulin, PLLC.
`39 Broadway, Suite 1250
`New York, N.Y. 10006
`(212) 267-3550
`www.tmppllc.com
`
`
`
`
`
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`
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`For additional information about electronic filing and to create a NYSCEF account, visit the
`NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone: 646-
`386-3033; e-mail: efile@nycourts.gov).
`
`Dated: March 29, 2023
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`TO:
`VINCENT GORMAN
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`21 MAPLE AVE APT 3A
`HASTINGS ON HUDSON NY 10706-1424
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`Matter # 487863
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`S_S-EFI
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`16 of 16
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