Does anyone have a good example I could use?
Thanks to everyone's awesome advice and lots of googling and reading the CPLR, I think I've glued together my case.
I'll be using 2 credit reports which I was very fortunate to have from years...ago that clearly state "Last Activity" to be calcualted as outside the SOL. In addition to the non-proper service that I'll be raising with the judge.
I'm also sending a request for documents to the plaintiff for actual proof of the validity of this debt.
I think I have all my ducks lined up for a summary judgment in my favor.
Thanks again everyone for their sincere intentions in trying to help me out!
Cheers from NY!