On August 02, 2021 a
Party Statement
was filed
involving a dispute between
Midland Credit Management, Inc,
and
Denise Yost,
for Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff
in the District Court of Chemung County.
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FILED: CHEMUNG COUNTY CLERK 11/15/2021 03:34 PM INDEX NO. 2021-5811
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 11/15/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF CHEMUNG
INDEX NUMBER 2021-5811
Midland Credit Management, Inc FILE NO. C597340
PLAINTIFF, AFFIRMATION IN SUPPORT OF
-AGAINST- ENTRY OF JUDGMENT
DENISE YOST
" "!"
DEFENDANT. lullt::||:|::::: iii ¡:: E"Ilii1
IIIIIIIIIIIllilliiniiiii =n!::::::ns ses
Joseph Ranaldo, Esq., an attorney duly admitted to the practice of law in the State of New
York, hereby affirms the following to be true pursuant to CPLR § 2106 and under the penalties
of perjury states that:
1. I am an attorney employed by Selip & Stylianou, LLP, attorneys for the Plaintiff, and I am
fully familiar with the facts and circumstances herein.
2. I make this affirmation in additional support of Plaintiff s request for the entry of
judgment against DENISE YOST (hereinafter the "Defendant").
Additional Notice Pursüañt to CPLR § 3215(g)(3)
3. On September 13, 2021, as set forth in the affidavit of service previously filed with the
court, a copy of the summons was mailed in a separate post-paid envelopes in an official
depository of the U.S. Postal Service addressed to each defaulting defendant's last known
residence address as set forth below, by first class mail in an envelope bearing the legend
confidential"
"personal and and not indicating on the outside thereof that the
communication was from an attorney or concerns an alleged debt. More than 20 days have
elapsed and the same has not been returned as undeliverable by the U.S. Postal Service; if
same was returned, the copy of the summons was re-mailed to the defendant'(s) last known
residence.
DENISE YOST
552 OWEN HOLLOW RD BIG FLATS, NY 14814
1 of 2
FILED: CHEMUNG COUNTY CLERK 11/15/2021 03:34 PM INDEX NO. 2021-5811
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 11/15/2021
MILITARY STATUS
4. I provided Department of Defense, Defense Manpower Data Center, with the pertinent
information about the defendant, in particular the date of birth and/or social security
number, which I know because they were provided to me by the Plaintiff. I requested that
a military investigation be conducted for the purpose of entry of a judgment.
5. Based upon the response I received from the Department of Defense, Defense Manpower
Data Center, dated N6vember 8, 2021, I am convinced that the defendant is not in any
branch of the United States military.
WHEREFORE, Plaintiff respectfully requests the entry of a default judgment against the
Defendant(s).
I certify that, to the best of my knowledge, information, and belief, formed after an
inquiry reasonable under the circumstances, that the presentation of this judgment and all
papers or the contentions herein are not frivolous as defined in 22 NYCRR 130-
accompanying §
1-1(a).
Dated: November 8, 2021
Josepfi Ranaldo, Esq.
2 of 2
Document Filed Date
November 15, 2021
Case Filing Date
August 02, 2021
Category
Other Matters - Consumer Credit (Card) Debt Buyer Plaintiff
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FILED: CHEMUNG COUNTY CLERK 11/15/2021 03:34 PM INDEX NO. 2021-5811 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 11/15/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF CHEMUNG INDEX NUMBER 2021-5811 Midland Credit Management, Inc FILE NO. C597340 PLAINTIFF, AFFIRMATION IN SUPPORT OF -AGAINST- ENTRY OF JUDGMENT DENISE YOST " "!" DEFENDANT. lullt::||:|::::: iii ¡:: E"Ilii1 IIIIIIIIIIIllilliiniiiii =n!::::::ns ses Joseph Ranaldo, Esq., an attorney duly admitted to the practice of law in the State of New York, hereby affirms the following to be true pursuant to CPLR § 2106 and under the penalties of perjury states that: 1. I am an attorney employed by Selip & Stylianou, LLP, attorneys for the Plaintiff, and I am fully familiar with the facts and circumstances herein. 2. I make this affirmation in additional support of Plaintiff s request for the entry of judgment against DENISE YOST (hereinafter the "Defendant"). Additional Notice Pursüañt to CPLR § 3215(g)(3) 3. On September 13, 2021, as set forth in the affidavit of service previously filed with the court, a copy of the summons was mailed in a separate post-paid envelopes in an official depository of the U.S. Postal Service addressed to each defaulting defendant's last known residence address as set forth below, by first class mail in an envelope bearing the legend confidential" "personal and and not indicating on the outside thereof that the communication was from an attorney or concerns an alleged debt. More than 20 days have elapsed and the same has not been returned as undeliverable by the U.S. Postal Service; if same was returned, the copy of the summons was re-mailed to the defendant'(s) last known residence. DENISE YOST 552 OWEN HOLLOW RD BIG FLATS, NY 14814 1 of 2 FILED: CHEMUNG COUNTY CLERK 11/15/2021 03:34 PM INDEX NO. 2021-5811 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 11/15/2021 MILITARY STATUS 4. I provided Department of Defense, Defense Manpower Data Center, with the pertinent information about the defendant, in particular the date of birth and/or social security number, which I know because they were provided to me by the Plaintiff. I requested that a military investigation be conducted for the purpose of entry of a judgment. 5. Based upon the response I received from the Department of Defense, Defense Manpower Data Center, dated N6vember 8, 2021, I am convinced that the defendant is not in any branch of the United States military. WHEREFORE, Plaintiff respectfully requests the entry of a default judgment against the Defendant(s). I certify that, to the best of my knowledge, information, and belief, formed after an inquiry reasonable under the circumstances, that the presentation of this judgment and all papers or the contentions herein are not frivolous as defined in 22 NYCRR 130- accompanying § 1-1(a). Dated: November 8, 2021 Josepfi Ranaldo, Esq. 2 of 2