Preview
FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024
CONSUMER CREDIT TRANSACTION
Date Purchased:
SUPREME COURT OF THE STATE OF NEW YORK Index №
COUNTY OF ULSTER X
Credit Corp Solutions Inc SUMMONS
Plaintiff, Plaintiff's Address:
-against- 180 West Election Road, S
Draper UT 84020
Masahiko Honge
Defendant(s).
The Basis of Venue is:
CPLR SEC. 503(f). Defendants
residence is in the County of
ULSTER.
X
Defendant(s) Address:
DEF1- 89 VINEYARD AVE FL 2, HIGHLAND NY 12528
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.
We are attorneys attempting to collect a debt. Any information obtained will be used for that purpose.
Dated: February 23, 2024
Matter # 512632 ____________________________
Stephen Einstein Scott Morris
Anthony S. Poulin Dianne Ramdeen
Elladia Lopez Joseph G. Devine
Chester Andrew Guala Gerard W. DeStefano
Richa Bhandari
Tromberg, Morris & Poulin, PLLC.
Attorneys for the Plaintiff
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
*SM0000512632*
S_S_SUP-SUM
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FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024
SUPREME COURT OF THE STATE OF NEW YORK INDEX №:
COUNTY OF ULSTER
Credit Corp Solutions Inc
Plaintiff,
-against-
COMPLAINT
Masahiko Honge
Defendant(s).
Plaintiff, by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges
that:
1. Plaintiff is an active foreign entity conducting business in the state of UT.
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 Citibank, N.A. (hereinafter "Original Creditor"), the Original
Creditor as defined by CPLR §105(q-1), bearing an account number on the most recent statement ending
in #XXXXXXXXXXXX3626, 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 02/09/2022 in the amount of $1,626.87. Pursuant to CPLR §3016(j) a
copy of the Charge-Off Statement is attached hereto.
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 03/17/2022. The complete chain of sale and assignment and dates sold
and/or assigned are as follows:
Assignor Date of Transfer Amt. at Time of Transfer
Transfer 1: Citibank, N.A. 03/17/2022 $1,626.87
7. Upon information and belief the date of last payment on this account was 07/14/2021 in the amount
of $89.75.
S_S_COM-RTL
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FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024
8. At this time, Defendant(s) owes $1,626.87 on the Account. This amount includes a charge-off
balance of $1,626.87, post-charge-off interest of $0.00, non-interest charges or fees accrued since charge-
off 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 sum of $1,626.87, 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 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 23rd day of February, 2024.
____________________________
Matter # 512632 Stephen Einstein Scott Morris
Anthony S. Poulin Dianne Ramdeen
Elladia Lopez Joseph G. Devine
Chester Andrew Guala Gerard W. DeStefano
Richa Bhandari
S_S_COM-RTL
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FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024
EXHIBIT “A”
(CHARGE-OFF/ LAST STATEMENT)
Matter #: 512632
S_EXH-COSM
4 of 12
FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024
® AmericanAirlines
CITI® AADVANTAGE® SELECT®
/ PLATINUM CARD C 11I AAdvantage i.
MASAHIKO HONGE www.citicards.com
Member Since 2006 Account number ending in: 3626 Customer Service 1-800-846-8444
Billing Period:01/12/22-02/09/22 Speech/hearing impaired: 711
BOX 6062 SIOUX FALLS, SD 57117
Account Summary
FEBRUARY STATEMENT
Previous balance $1,594.58
Minimum payment due: $1,626.87
Payments -$0.00
New balance as of O2/09/22: $1,626.87
Credits -$0.00
Payment due date: O2/09/22
See the last p.a e of this statement for important information about how to Purchases +$0.00
avoid paying InÎerest on purchases. Cash advances +$0.00
Fees +$0.00
Late Payment Interest +$32.29
Warning: If we do not receive your minimum payment by the
date listed above, you may have to pay a late fee of up to $37 and your APRs New balance $1,626.87
may be increased up to the Penalty APR of 27.24%.
Minimum Payment Warning: If you make only the minimum payment each Credit Limit
period, you will pay more in interest and it will take you longer to pay off your Revolving Credit limit $2,000
balance. For example: Includes $2,000 cash advance limit
If you make no additional You will pay off the And you will end up
charges using this card balance shown on this paying an estimated
and each month you pay... statement in about... total of...
Only the minimum payment 1 month(s) $1,627
For information about credit counseling services, call 1-877-337-8188.
For Payments, send check to: CITI CARDS, PO BOX 9001037, Louisville, KY, 40290-1037
Pay online www.citicards.com
Minimum payment due $1,626.87
Pay by phone 1-800-846-8444
New balance $1,626.87
Payment due date 02/09/22
Pay by mail Use this coupon
" Enclosea valid checkor money order payable
to CITICARDS.No cashor foreign currency.
Amount enclosed:
" Write the last four digits of your
accountnumberon your check.
Account number ending in 3626
000000 PW 34 A O
Please make check payable to CITI CARDS.
MASAHIKO HONGE CITI CARDS
PO BOX 778 PO BOX 9001037
WINDHAM NY 12496 Louisville, KY 40290-1037
5 of 12
FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024
www.citicards.com Customer Service 1-800-846-8444 Page 2 of 2
Speech/hearing impaired: 711
MASAHIKO HONGE
Account Summary
Trans. Post
date date Description Amount
.......................................................................................................................................................
Fees charged
Total fees charged in this billing period $0.00
Interest charged
Date Description Amount
......................................................................................................................................................
02/09 INTEREST CHARGED TO STANDARD PURCH $32.29
Total interest charged in this billing period $32.29
2022 totals year-to-date
Total fees charged in 2022 $0.00
.....................................................................................................................................................
Total interest charged in 2022 $68.25
Interest charge calculation Days in billing cycle: 29
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
.....................................................................................................................................................
Annual percentage Balance subject
Balance type rate (APR) to interest rate Interest charge
.....................................................................................................................................................
.P RCHASES
Standard Purch 25.24% (V) $1,610.11(D) $32.29
.....................................................................................................................................................
ADVANCES
Standard Adv 25.24% (V) $0.00 (D) $0.00
Your Annual Percentage Rate (APR) is the annual interest rate on your account. APRs followed
by (V) may vary. Balances followed by (D) are determined by the daily balance method
(including current transactions).
Account messages
Minimum Payment Due includes past due amounts. Your account may be with
a collection vendor and when you call our number, you may be referred to the
vendor. You may reach us at the toll-free number shown above
Monday-Thursday 8am to 6 pm or Friday 8am to 5pm, Central Time.
1-800-846-8444. TTY 1-855-371-0353.
©2021 Citibank, N.A.
Citi, Citi and Arc Design and other marks used herein are service marks of
Citigroup Inc. or its affiliates, used and registered throughout the world.
American Airlines, American Eagle, AAdvantage, AAdvantage Million Miler,
MileSAAver, Business Extra, Flagship, Admirals Club, Platinum Pro,
AAdvantage MileUp, AA Cargo, the Flight Symbol logo and the Tail Design are
marks of American Airlines, Inc.
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FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024
EXHIBIT “B”
(LAST USE OF CARD STATEMENT/ BALANCE)
Matter #: 512632
S_EXH-LPAM
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FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024
® AmericanAirlines
CITI® AADVANTAGE® SELECT®
/ PLATINUM CARD C 11I AAdvantage i.
MASAHIKO HONGE www.citicards.com
Member Since 2006 Account number ending in: 3626 Customer Service 1-800-846-8444
Billing Period:07/10/21-08/10/21 Speech/hearing impaired: 711
BOX 6062 SIOUX FALLS, SD 57117
Your account is past due $45.62. Please pay
AUGUST STATEMENT
at least the minimum payment due, which
Minimum payment due: $91.11
includes a past due amount.
New balance as of 08/10/21: $1,433.55
Payment due date: 09/07/21 Account Summary
See the la_stp_ageof this statement for important information about how to previous balance $1,491.81
avoid paying interest on purchases.
Payments -$89.75
Credits -$0.00
Late Payment Warning: If we do not receive your minimum payment by the Purchases +$0.00
date listed above, you may have to pay a late fee of up to $37 and your APRs Cash advances +$0.00
may be increased up to the Penalty APR of 27.24%. Fees +$0.00
Minimum Payment Warning: If you make only the minimum payment each Interest +$31.49
period, you will pay more in interest and it will take you longer to pay off your New balance $1,433.55
balance. For example:
If you make no additional You will pay off the And you will end up Credit Limit
charges using this card balance shown on this paying an estimated
and each month you pay... statement in about... total of... Revolving Credit limit $2,000
Includes $2,000 cash advance limit
Only the minimum payment 9 year(s) $3,174
For information about credit counseling services, call 1-877-337-8188.
For Payments, send check to: CITI CARDS, PO BOX 9001037, Louisville, KY, 40290-1037
Pay online www.citicards.com
Minimum payment due $91-11
Pay by phone 1-800-846-8444
New balance $1,433.55
Payment due date 09/07/21
Pay by mail Use this coupon
" Enclosea valid checkor money order payable
to CITiCARDS.No cashor foreign currency.
Amount enclosed:
" Write the last four digits of your
accountnumberon your check.
Account number ending in 3626
000000 PW 34 A O
Please make check payable to CITI CARDS.
MASAHIKO HONGE CITI CARDS
PO BOX 778 PO BOX 9001037
WINDHAM NY 12496 Louisville, KY 40290-1037
8 of 12
FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024
www.citicards.com Customer Service 1-800-846-8444 Page 2 of 2
Speech/hearing impaired: 711
MASAHIKO HONGE
Account Summary
Trans. Post
date date Description Amount
.......................................................................................................................................................
Payments, Credits and Adjustments
07/12 PAYMENT THANK YOU -$89.75
......................................................................................................................................................
Fees charged
Total fees charged in this billing period $0.00
Interest charged
Date Description Amount
......................................................................................................................................................
08/10 INTEREST CHARGED TO STANDARD PURCH $31.49
Total interest charged in this billing period $31.49
2021 totals year-to-date
Total fees charged in 2021 $0.00
.....................................................................................................................................................
Total interest charged in 2021 $260.58
Interest charge calculation Days in billing cycle:32
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
.....................................................................................................................................................
Annual percentage Balance subject
Balance type rate (APR) to interest rate Interest charge
.....................................................................................................................................................
.P RCHASES
Standard Purch 25.24% (V) $1,422.92 (D) $31.49
.....................................................................................................................................................
ADVANCES
Standard Adv 25.24% (V) $0.00 (D) $0.00
Your Annual Percentage Rate (APR) is the annual interest rate on your account. APRs followed
by (V) may vary. Balances followed by (D) are determined by the daily balance method
(including current transactions).
Account messages
Minimum Payment Due includes past due amounts. Your account may be with
a collection vendor and when you call our number, you may be referred to the
vendor. You may reach us at the toll-free number shown above
Monday-Thursday 8am to 6 pm or Friday 8am to 5pm, Central Time.
1-800-846-8444. TTY 1-855-371-0353.
©2021 Citibank, N.A.
Citi, Citi and Arc Design and other marks used herein are service marks of
Citigroup Inc. or its affiliates, used and registered throughout the world.
American Airlines, American Eagle, AAdvantage, AAdvantage Million Miler,
MileSAAver, Business Extra, Flagship, Admirals Club, Platinum Pro, AAdvatage
MileUp, AA Cargo, the Flight Symbol logo and the Tail Design are marks of
American Airlines, Inc.
9 of 12
FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611
NYSCEF DOC. NO. 1 Index No. Year RECEIVED NYSCEF: 03/04/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ULSTER
Credit Corp Solutions Inc
Plaintiff
-against-
Masahiko Honge
Defendant(s)
SUMMONS AND COMPLAINT
Signature (Rule 130-1. 1-a)
____________________________
Stephen Einstein Scott Morris
Anthony S. Poulin Dianne Ramdeen
Elladia Lopez Joseph G. Devine
Chester Andrew Guala Gerard W. DeStefano
Richa Bhandari
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)
Sir: Please take notice
NOTICE OF ENTRY:
That within is a (certified) true copy of a duly entered in the office of the clerk
of the within named court on
NOTICE OF SETTLEMENT
That an order __________________ of which the within is a true copy of a
Settlement to the HON. ___________________ Presented for one of the
judges
Of the within named court, at
On the ___ day of _____ 2024 at __ A.M
Dated,
S_S_SUP-BB
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FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024
SUPREME COURT OF THE STATE OF NEW YORK INDEX №:
COUNTY OF ULSTER
Credit Corp Solutions Inc
Plaintiff,
-against-
Masahiko Honge
Defendant(s).
NOTICE OF COMMENCEMENT OF ACTION
SUBJECT TO MANDATORY ELECTRONIC FILING
PLEASE TAKE NOTICE that the matter captioned above has been commenced as an
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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FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024
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: February 23, 2024
____________________________
Stephen Einstein Scott Morris
Anthony S. Poulin Dianne Ramdeen
Elladia Lopez Joseph G. Devine
Chester Andrew Guala Gerard W. DeStefano
Richa Bhandari
Tromberg, Morris & Poulin, PLLC.
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
www.tmppllc.com
TO: Masahiko Honge
89 Vineyard Ave Fl 2
Highland NY 12528
Matter # 512632
S_S-EFI
12 of 12
Preview
FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 CONSUMER CREDIT TRANSACTION Date Purchased: SUPREME COURT OF THE STATE OF NEW YORK Index № COUNTY OF ULSTER X Credit Corp Solutions Inc SUMMONS Plaintiff, Plaintiff's Address: -against- 180 West Election Road, S Draper UT 84020 Masahiko Honge Defendant(s). The Basis of Venue is: CPLR SEC. 503(f). Defendants residence is in the County of ULSTER. X Defendant(s) Address: DEF1- 89 VINEYARD AVE FL 2, HIGHLAND NY 12528 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. We are attorneys attempting to collect a debt. Any information obtained will be used for that purpose. Dated: February 23, 2024 Matter # 512632 ____________________________ Stephen Einstein Scott Morris Anthony S. Poulin Dianne Ramdeen Elladia Lopez Joseph G. Devine Chester Andrew Guala Gerard W. DeStefano Richa Bhandari Tromberg, Morris & Poulin, PLLC. Attorneys for the Plaintiff 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 *SM0000512632* S_S_SUP-SUM 1 of 12 FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 SUPREME COURT OF THE STATE OF NEW YORK INDEX №: COUNTY OF ULSTER Credit Corp Solutions Inc Plaintiff, -against- COMPLAINT Masahiko Honge Defendant(s). Plaintiff, by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges that: 1. Plaintiff is an active foreign entity conducting business in the state of UT. 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 Citibank, N.A. (hereinafter "Original Creditor"), the Original Creditor as defined by CPLR §105(q-1), bearing an account number on the most recent statement ending in #XXXXXXXXXXXX3626, 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 02/09/2022 in the amount of $1,626.87. Pursuant to CPLR §3016(j) a copy of the Charge-Off Statement is attached hereto. 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 03/17/2022. The complete chain of sale and assignment and dates sold and/or assigned are as follows: Assignor Date of Transfer Amt. at Time of Transfer Transfer 1: Citibank, N.A. 03/17/2022 $1,626.87 7. Upon information and belief the date of last payment on this account was 07/14/2021 in the amount of $89.75. S_S_COM-RTL 2 of 12 FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 8. At this time, Defendant(s) owes $1,626.87 on the Account. This amount includes a charge-off balance of $1,626.87, post-charge-off interest of $0.00, non-interest charges or fees accrued since charge- off 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 sum of $1,626.87, 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 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 23rd day of February, 2024. ____________________________ Matter # 512632 Stephen Einstein Scott Morris Anthony S. Poulin Dianne Ramdeen Elladia Lopez Joseph G. Devine Chester Andrew Guala Gerard W. DeStefano Richa Bhandari S_S_COM-RTL 3 of 12 FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 EXHIBIT “A” (CHARGE-OFF/ LAST STATEMENT) Matter #: 512632 S_EXH-COSM 4 of 12 FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 ® AmericanAirlines CITI® AADVANTAGE® SELECT® / PLATINUM CARD C 11I AAdvantage i. MASAHIKO HONGE www.citicards.com Member Since 2006 Account number ending in: 3626 Customer Service 1-800-846-8444 Billing Period:01/12/22-02/09/22 Speech/hearing impaired: 711 BOX 6062 SIOUX FALLS, SD 57117 Account Summary FEBRUARY STATEMENT Previous balance $1,594.58 Minimum payment due: $1,626.87 Payments -$0.00 New balance as of O2/09/22: $1,626.87 Credits -$0.00 Payment due date: O2/09/22 See the last p.a e of this statement for important information about how to Purchases +$0.00 avoid paying InÎerest on purchases. Cash advances +$0.00 Fees +$0.00 Late Payment Interest +$32.29 Warning: If we do not receive your minimum payment by the date listed above, you may have to pay a late fee of up to $37 and your APRs New balance $1,626.87 may be increased up to the Penalty APR of 27.24%. Minimum Payment Warning: If you make only the minimum payment each Credit Limit period, you will pay more in interest and it will take you longer to pay off your Revolving Credit limit $2,000 balance. For example: Includes $2,000 cash advance limit If you make no additional You will pay off the And you will end up charges using this card balance shown on this paying an estimated and each month you pay... statement in about... total of... Only the minimum payment 1 month(s) $1,627 For information about credit counseling services, call 1-877-337-8188. For Payments, send check to: CITI CARDS, PO BOX 9001037, Louisville, KY, 40290-1037 Pay online www.citicards.com Minimum payment due $1,626.87 Pay by phone 1-800-846-8444 New balance $1,626.87 Payment due date 02/09/22 Pay by mail Use this coupon " Enclosea valid checkor money order payable to CITICARDS.No cashor foreign currency. Amount enclosed: " Write the last four digits of your accountnumberon your check. Account number ending in 3626 000000 PW 34 A O Please make check payable to CITI CARDS. MASAHIKO HONGE CITI CARDS PO BOX 778 PO BOX 9001037 WINDHAM NY 12496 Louisville, KY 40290-1037 5 of 12 FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 www.citicards.com Customer Service 1-800-846-8444 Page 2 of 2 Speech/hearing impaired: 711 MASAHIKO HONGE Account Summary Trans. Post date date Description Amount ....................................................................................................................................................... Fees charged Total fees charged in this billing period $0.00 Interest charged Date Description Amount ...................................................................................................................................................... 02/09 INTEREST CHARGED TO STANDARD PURCH $32.29 Total interest charged in this billing period $32.29 2022 totals year-to-date Total fees charged in 2022 $0.00 ..................................................................................................................................................... Total interest charged in 2022 $68.25 Interest charge calculation Days in billing cycle: 29 Your Annual Percentage Rate (APR) is the annual interest rate on your account. ..................................................................................................................................................... Annual percentage Balance subject Balance type rate (APR) to interest rate Interest charge ..................................................................................................................................................... .P RCHASES Standard Purch 25.24% (V) $1,610.11(D) $32.29 ..................................................................................................................................................... ADVANCES Standard Adv 25.24% (V) $0.00 (D) $0.00 Your Annual Percentage Rate (APR) is the annual interest rate on your account. APRs followed by (V) may vary. Balances followed by (D) are determined by the daily balance method (including current transactions). Account messages Minimum Payment Due includes past due amounts. Your account may be with a collection vendor and when you call our number, you may be referred to the vendor. You may reach us at the toll-free number shown above Monday-Thursday 8am to 6 pm or Friday 8am to 5pm, Central Time. 1-800-846-8444. TTY 1-855-371-0353. ©2021 Citibank, N.A. Citi, Citi and Arc Design and other marks used herein are service marks of Citigroup Inc. or its affiliates, used and registered throughout the world. American Airlines, American Eagle, AAdvantage, AAdvantage Million Miler, MileSAAver, Business Extra, Flagship, Admirals Club, Platinum Pro, AAdvantage MileUp, AA Cargo, the Flight Symbol logo and the Tail Design are marks of American Airlines, Inc. 6 of 12 FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 EXHIBIT “B” (LAST USE OF CARD STATEMENT/ BALANCE) Matter #: 512632 S_EXH-LPAM 7 of 12 FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 ® AmericanAirlines CITI® AADVANTAGE® SELECT® / PLATINUM CARD C 11I AAdvantage i. MASAHIKO HONGE www.citicards.com Member Since 2006 Account number ending in: 3626 Customer Service 1-800-846-8444 Billing Period:07/10/21-08/10/21 Speech/hearing impaired: 711 BOX 6062 SIOUX FALLS, SD 57117 Your account is past due $45.62. Please pay AUGUST STATEMENT at least the minimum payment due, which Minimum payment due: $91.11 includes a past due amount. New balance as of 08/10/21: $1,433.55 Payment due date: 09/07/21 Account Summary See the la_stp_ageof this statement for important information about how to previous balance $1,491.81 avoid paying interest on purchases. Payments -$89.75 Credits -$0.00 Late Payment Warning: If we do not receive your minimum payment by the Purchases +$0.00 date listed above, you may have to pay a late fee of up to $37 and your APRs Cash advances +$0.00 may be increased up to the Penalty APR of 27.24%. Fees +$0.00 Minimum Payment Warning: If you make only the minimum payment each Interest +$31.49 period, you will pay more in interest and it will take you longer to pay off your New balance $1,433.55 balance. For example: If you make no additional You will pay off the And you will end up Credit Limit charges using this card balance shown on this paying an estimated and each month you pay... statement in about... total of... Revolving Credit limit $2,000 Includes $2,000 cash advance limit Only the minimum payment 9 year(s) $3,174 For information about credit counseling services, call 1-877-337-8188. For Payments, send check to: CITI CARDS, PO BOX 9001037, Louisville, KY, 40290-1037 Pay online www.citicards.com Minimum payment due $91-11 Pay by phone 1-800-846-8444 New balance $1,433.55 Payment due date 09/07/21 Pay by mail Use this coupon " Enclosea valid checkor money order payable to CITiCARDS.No cashor foreign currency. Amount enclosed: " Write the last four digits of your accountnumberon your check. Account number ending in 3626 000000 PW 34 A O Please make check payable to CITI CARDS. MASAHIKO HONGE CITI CARDS PO BOX 778 PO BOX 9001037 WINDHAM NY 12496 Louisville, KY 40290-1037 8 of 12 FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 www.citicards.com Customer Service 1-800-846-8444 Page 2 of 2 Speech/hearing impaired: 711 MASAHIKO HONGE Account Summary Trans. Post date date Description Amount ....................................................................................................................................................... Payments, Credits and Adjustments 07/12 PAYMENT THANK YOU -$89.75 ...................................................................................................................................................... Fees charged Total fees charged in this billing period $0.00 Interest charged Date Description Amount ...................................................................................................................................................... 08/10 INTEREST CHARGED TO STANDARD PURCH $31.49 Total interest charged in this billing period $31.49 2021 totals year-to-date Total fees charged in 2021 $0.00 ..................................................................................................................................................... Total interest charged in 2021 $260.58 Interest charge calculation Days in billing cycle:32 Your Annual Percentage Rate (APR) is the annual interest rate on your account. ..................................................................................................................................................... Annual percentage Balance subject Balance type rate (APR) to interest rate Interest charge ..................................................................................................................................................... .P RCHASES Standard Purch 25.24% (V) $1,422.92 (D) $31.49 ..................................................................................................................................................... ADVANCES Standard Adv 25.24% (V) $0.00 (D) $0.00 Your Annual Percentage Rate (APR) is the annual interest rate on your account. APRs followed by (V) may vary. Balances followed by (D) are determined by the daily balance method (including current transactions). Account messages Minimum Payment Due includes past due amounts. Your account may be with a collection vendor and when you call our number, you may be referred to the vendor. You may reach us at the toll-free number shown above Monday-Thursday 8am to 6 pm or Friday 8am to 5pm, Central Time. 1-800-846-8444. TTY 1-855-371-0353. ©2021 Citibank, N.A. Citi, Citi and Arc Design and other marks used herein are service marks of Citigroup Inc. or its affiliates, used and registered throughout the world. American Airlines, American Eagle, AAdvantage, AAdvantage Million Miler, MileSAAver, Business Extra, Flagship, Admirals Club, Platinum Pro, AAdvatage MileUp, AA Cargo, the Flight Symbol logo and the Tail Design are marks of American Airlines, Inc. 9 of 12 FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611 NYSCEF DOC. NO. 1 Index No. Year RECEIVED NYSCEF: 03/04/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ULSTER Credit Corp Solutions Inc Plaintiff -against- Masahiko Honge Defendant(s) SUMMONS AND COMPLAINT Signature (Rule 130-1. 1-a) ____________________________ Stephen Einstein Scott Morris Anthony S. Poulin Dianne Ramdeen Elladia Lopez Joseph G. Devine Chester Andrew Guala Gerard W. DeStefano Richa Bhandari 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) Sir: Please take notice NOTICE OF ENTRY: That within is a (certified) true copy of a duly entered in the office of the clerk of the within named court on NOTICE OF SETTLEMENT That an order __________________ of which the within is a true copy of a Settlement to the HON. ___________________ Presented for one of the judges Of the within named court, at On the ___ day of _____ 2024 at __ A.M Dated, S_S_SUP-BB 10 of 12 FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 SUPREME COURT OF THE STATE OF NEW YORK INDEX №: COUNTY OF ULSTER Credit Corp Solutions Inc Plaintiff, -against- Masahiko Honge Defendant(s). NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING PLEASE TAKE NOTICE that the matter captioned above has been commenced as an 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 11 of 12 FILED: ULSTER COUNTY CLERK 03/04/2024 10:25 PM INDEX NO. EF2024-611 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 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: February 23, 2024 ____________________________ Stephen Einstein Scott Morris Anthony S. Poulin Dianne Ramdeen Elladia Lopez Joseph G. Devine Chester Andrew Guala Gerard W. DeStefano Richa Bhandari Tromberg, Morris & Poulin, PLLC. 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 www.tmppllc.com TO: Masahiko Honge 89 Vineyard Ave Fl 2 Highland NY 12528 Matter # 512632 S_S-EFI 12 of 12