`NYSCEF DOC. NO. 8
`
`INDEX NO. EF2022-2
`
`RECEIVED NYSCEF: 03/17/2022
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF MONTGOMERY
`
`Crown Asset Management, LLC
`
`INDEX NO. EF2022-2
`
`-against-
`
`Plaintiff,-
`
`Valerie M Butler
`
`Defendant(s),
`
`AFFIRMATION OF NON-EXPIRATION OF STATUTE OF LIMITATIONS
`
`The undersigned attorney, pursuant to CPLR 2106 and under the penalties of perjury, affirms as
`follows:
`
`1. I am counsel for Crown Asset Management, LLC, the plaintiff in the instant action.
`
`2. The cause(s) of action asserted herein accrued on 12/3/2019 in the state of Nebraska. The
`statute(s) of limitations for the cause(s) of action asserted herein is/are 4 years. Based on my
`reasonable inquiry, I believe that the applicable statute(s) of limitations for the cause(s) of action
`asserted herein has/have not expired.
`
`The above statements are true and correct to the best of my personal knowledge.
`
`Dated: March 2, 2022
`
` Joseph J. Cassotta
` Aksana Bondartseva
` Stephen Einstein
`Matter #: 409830.001
`
` Joseph G. Devine
` Stephanie R. Vetch
` Evridike Kollis
`
`S_J_SOL
`
`1 of 3
`
`
`
`FILED: MONTGOMERY COUNTY CLERK 03/17/2022 02:50 PM
`NYSCEF DOC. NO. 8
`
`INDEX NO. EF2022-2
`
`RECEIVED NYSCEF: 03/17/2022
`
`INDEX NO. EF2022-2
`
`AFFIRMATION
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF MONTGOMERY
`
`
`
`Crown Asset Management, LLC
`
`Plaintiff,
`
`
`vs.
`
`
`Valerie M Butler
`
`
`
`
`
`
`
`The undersigned attorney, pursuant to CPLR 2106 and under the penalties of perjury, affirms as
`follows:
`
`
`Defendant(s),
`
`
`
`1.
`
`I am an associate of the firm appearing as attorneys of record for the Plaintiff and am
`
`fully familiar with all of the statements submitted herein. I submit this Affirmation in support of
`the Plaintiff’s submission of a default judgment in favor of the Plaintiff and against the
`
`Defendant(s).
`This affidavit is made pursuant to the United States Soldiers and Sailor’s Relief Act of
`
`2.
`
`1940, as amended, 50 U.S.C.A. App. Secs. 501et. Seq. for the purpose of the entry of a judgment
`
`against Valerie M Butler , Defendant(s) in the above entitled action.
`
`3.
`
`I provided Department of Defense Manpower Data Center with the pertinent information,
`
`about the Defendant(s), such as date of birth and social security number which I know because
`
`this information was provided to us by the Plaintiff and we further verified this information in a
`credit report bearing Defendant’s(s’) name, date of birth and social security number. I requested a
`
`military investigation be conducted.
`
`4.
`
`Based upon the response I received from the Department of Defense Manpower Data
`
`Center dated 02/28/2022, I am convinced that the Defendant(s) is/are not in any branch of the
`
`United States military.
`
`
`
`Dated: March 2, 2022
`
`
`
`
`
`
`
`
`
` Joseph J. Cassotta
` Aksana Bondartseva
` Stephen Einstein
`S.E ACCT. NO. 409830
`
`
` Joseph G. Devine
`
` Stephanie R. Vetch
`
` Evridike Kollis
`
`S_J_NonMil
`
`
`
`2 of 3
`
`
`
`FILED: MONTGOMERY COUNTY CLERK 03/17/2022 02:50 PM
`NYSCEF DOC. NO. 8
`RECEIVED NYSCEF: 03/17/2022
`Resultsasof : Feb-22-202206:24:45AM
`of Defense
`Manpower
`Center
`Department
`Data
`
`INDEX NO. EF2022-2
`
`SCRA5.12
`
`Stanis
`
`Report
`
`Pursuant
`
`to Servicemembers
`
`Civil
`
`Relief
`
`Act
`
`SSN:
`
`XXX-XX-8471
`
`Birth
`
`Date:
`
`Last
`
`First
`
`Name:
`
`Name:
`
`Middle
`
`Status
`
`Name:
`
`As Of:
`
`1983
`
`BUTLER
`
`VALERIE
`M
`
`Feb-22-2022
`
`Certificate
`
`ID:
`
`RCJGWF9G21KJS8B
`
`ActiveDutyStartDate
`NA
`
`OnActiveDutyOnActiveDutyStatusDate
`Status
`ActiveDutyEndDate
`NA
`No
`Thisresponsereflectstheindividuals'activedutystatusbasedontheActiveDutyStatusDate
`
`ServiceComponent
`NA
`
`ActiveDutyStartDate
`NA
`
`LeftActiveDutyWithin367DaysofActiveDutyStatusDate
`Status
`ActiveDutyEndDate
`NA
`No
`Thisresponsereflectswheretheindividualleftactivedutystatuswithin367daysprecedingtheActiveDutyStatusDate
`
`ServiceComponent
`NA
`
`OrderNotificationStartDate
`NA
`
`TheMemberor His/HerUnitWasNotifiedofa FutureCall-UptoActiveDutyonActiveDutyStatusDate
`OrderNotificationEndDate
`Status
`NA
`No
`Thisresponsereflectswhethertheindividualor his/herunithasreceivedearlynotificationto reportforactiveduty
`
`ServiceComponent
`NA
`
`the above is the status of
`Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided,
`the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
`Coast Guard). This status includes information on a Servicemember
`for Active Duty.
`or his/her unit receiving notification of future orders to report
`
`Michael V. Sorrento, Director
`Department of Defense - Manpower Data Center
`400 Gigling Rd.
`Seaside, CA 93955
`
`3 of 3
`
`
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