FILED: SCHENECTADY COUNTY CLERK 09/29/2023 04:36 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 09/29/2023
`
`INDEX NO. 2023-1685
`
`1 of 5
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` SUPREME COURT OF THE STATE OF NEW YORK Index No.
` COUNTY OF SCHENECTADY Date Filed: ________________
` ----------------------------------------
` JPMORGAN CHASE BANK, N.A.
`
` SUMMONS (ORIGINAL)
` Plaintiff
` -against-
`
` MATTHEW J BOEHMER The basis of venue is:
`
` DEFENDANT'S RESIDENCE
`
` Defendant(s) Plaintiff's Residence:
` ---------------------------------------- 201 N WALNUT ST
` WILMINGTON, DE 19801
` CONSUMER CREDIT TRANSACTION County of NEW CASTLE
`
` 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, or, if the complaint is not served with this summons
` to serve a notice of appearance, on the Plaintiff's Attorney(s) within
` TWENTY days after the service of this summons, exclusive of the day of
` service (or within THIRTY 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 herein.
`
` Dated: Islandia, New York
` RUBIN & ROTHMAN, LLC
` SEPTEMBER 29, 2023 Attorneys for Plaintiff
` By: _____________________
` JARED DOCKSWELL
` 1787 Veterans Highway
` Islandia, NY 11749
` (631) 234-1500
`
` DEFENDANT(S) ADDRESS:
`
` MATTHEW J BOEHMER
` 2116 DEAN ST SCHENECTADY, NY 12309-4010
`
` WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
` USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
` NYC DCA LIC. 2110651
` Our File No 1519733 Y 126 0- 0 V SZV 000
`
`000006662658
`
`

`

`FILED: SCHENECTADY COUNTY CLERK 09/29/2023 04:36 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 09/29/2023
`
`INDEX NO. 2023-1685
`
`2 of 5
`
` SUPREME COURT OF THE STATE OF NEW YORK
` COUNTY OF SCHENECTADY Index No.
` ----------------------------------------
` JPMORGAN CHASE BANK, N.A.
`
` Plaintiff
` -against- COMPLAINT (ORIGINAL)
` MATTHEW J BOEHMER
`
` Defendant(s)
` ----------------------------------------
` Plaintiff, by its attorneys, complaining of Defendant(s), alleges:
`
` AS AND FOR A FIRST CAUSE OF ACTION
`
` 1. Defendant(s) resides in the county in which this action is brought;
` or transacted business in the county in which this action is brought
` in person or through an agent, or this cause of action arose out of
` said transaction. Plaintiff is not required to be licensed by the
` NYC Dept of Consumer Affairs because it is the original creditor.
`
` 2. Plaintiff is a national banking association chartered under the laws
` of the United States.
`
` 3. Defendant(s) maintained a revolving credit account with Plaintiff and
` agreed to make payments for goods and services charged, balance
` transfers, and/or cash advances made upon such card.
`
` 4. Defendant(s) later defaulted on the terms of the agreement.
`
` 5. The last payment in good and collectable funds was received
` on or about 7/22/22 in the amount of $ 654.00.
`
` 6. The last four digits of the account number printed on the most recent
` monthly statement recording a purchase transaction, last payment or
` balance transfer are 9585
`
` 7. The account balance printed on the most recent monthly statement
` recording a purchase transaction, last payment or balance transfer is
` $ 4,072.62.
`
` 8. Plaintiff is the entity that owned the consumer credit account at
` the date of default giving rise to the cause of action and is the
` original creditor as defined by CPLR 105(q-1).
`
`

`

`FILED: SCHENECTADY COUNTY CLERK 09/29/2023 04:36 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 09/29/2023
`
`INDEX NO. 2023-1685
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`3 of 5
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` 9. Defendant(s) failed to make the payments due pursuant to the credit
` account and $ 4,844.76 is now due and owing to Plaintiff from
` Defendant. This amount includes a charge-off balance of $ 4,844.76,
` post charge-off interest of $ .00, post charge-off non-interest
` charges or fees and/or other balance adjustment of $ .00, less
` post charge-off payments, balance adjustments and/or credits made on
` the debt of $ .00.
`
` 10. A copy of the charge-off statement issued for the account at issue
` is attached hereto.
`
` WHEREFORE, Plaintiff requests judgment against Defendant(s) in the sum of
` $ 4,844.76.
`
` RUBIN & ROTHMAN, LLC
` SEPTEMBER 29, 2023 Attorneys for Plaintiff
` 1787 Veterans Highway
` Islandia, NY 11749
` (631) 234-1500
` Deponent is an attorney associated with Rubin & Rothman, LLC. To the best
` of deponent's knowledge, information and belief, formed after an inquiry
` reasonable under the circumstances, the summons and complaint or the
` contentions therein are not frivolous as defined in section 130-1.1(c)
` of the Rules of the Chief Adm. and the matter was not obtained through
` illegal conduct or in violation of 22 NYCRR 1200, Rule 4.5.
`
` Dated: SEPTEMBER 29, 2023 ______________________
` JARED DOCKSWELL
`
` WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
` USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
` NYC DCA LIC. 2110651
`
` Our File No 1519733 X 128 0- 0 V SZV 000 OUR FILE NO 1519733 X 128 0- 0 V SZV 000
`
`
`
`000006662658000006662658
`
`

`

`FILED: SCHENECTADY COUNTY CLERK 09/29/2023 04:36 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 09/29/2023
`
`INDEX NO. 2023-1685
`
`4 of 5
`
` SUPREME COURT OF THE STATE OF NEW YORK
` COUNTY OF SCHENECTADY
` ----------------------------------------
` JPMORGAN CHASE BANK, N.A.
`
` Plaintiff
` -against- Index No.
` MATTHEW J BOEHMER
`
` Defendant(s)
` ----------------------------------------
` NOTICE OF ELECTRONIC FILING
` (Mandatory Case)
` (Uniform Rule § 202.5-bb)
`
` You have received this Notice because:
`
` 1) The Plaintiff/Petitioner, whose name is listed above, has filed this
` case using the New York State Courts E-filing system ("NYSCEF"), and
`
` 2) You are a Defendant/Respondent (a party) in this case.
`
` If you are represented by an attorney:
`
` Give this Notice to your attorney. (Attorneys: see "Information for
` Attorneys" pg. 2).
`
` If you are not represented by an attorney:
`
` You will be served with all documents in paper and you must serve and file
` your documents in paper, unless you choose to participate in e-filing.
`
` If you choose to participate in e-filing, you must have access to a
` computer and a scanner or other device to convert documents into electronic
` format, a connection to the internet, and an e-mail address to receive
` service of documents.
`
` The benefits of participating in e-filing include:
`
` Serving and filing your documents electronically.
` Free access to view and print your e-filed documents.
` Limiting your number of trips to the courthouse.
` Paying any court fees on-line (credit card needed).
`
` Our file no.: 1519733 Page 1 of 2 9/29/23 EFM-1
`
`

`

`FILED: SCHENECTADY COUNTY CLERK 09/29/2023 04:36 PM
`NYSCEF DOC. NO. 1
`RECEIVED NYSCEF: 09/29/2023
`
`INDEX NO. 2023-1685
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`
` To register for e-filing or for more information about how e-filing works:
` Visit: www.nycourts.gov/efile-unrepresented or
` Contact the Clerk's Office or Help Center at the court where the case was
` filed. Court contact information can be found at www.nycourts.gov
`
` To find legal information to help you represent yourself visit www.nycourt.
` gov
`
` Information for Attorneys
` (E-filing is Mandatory for Attorneys)
`
` 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 www.nycourts.gov/efile; or
`
` 2) file the Notice of Opt-Out form with the clerk of the court where this
` action is pending and serve on all parties. 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 knowledge to operate such equipment. [Section 202.5-bb(e)].
`
` 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: nyscef@nycourts.gov).
`
` Dated: Islandia, New York
` SEPTEMBER 29, 2023
`
` ____________________ RUBIN & ROTHMAN, LLC
` JARED DOCKSWELL 1787 VETERANS HIGHWAY
` RUBIN & ROTHMAN, LLC ISLANDIA, NY 11749
` (631) 234-1500
` NYDOCS@RUBINROTHMAN.COM
` To: MATTHEW J BOEHMER
` 2116 DEAN ST
` SCHENECTADY, NY 12309-4010
` Index no.: Page 2 of 2 9/29/23 EFM-1
`
` WE ARE ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
` USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
` NYC DCA LIC. 2110651
` Our File No 1519733 X 130 0- 0 V SZV 000
`
`000006662658
`
`