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Our File No. 137843.001
Return Date: 07/16/2024
Docket Number:
FEC ICI CESIECAC CCCI IOC KH
Velocity Investments, L.L.C. SUPERIOR COURT.
DANBURY
JUDICIAL DISTRICT
Plaintiff
Vv
May 21, 2024
Jose Javiergarciapolanco
*
Defendant *
SISSIES ETI tofolok eee oI xO, ROO ICI ACA ACA ACR AAR A AR AR a
COMPLAINT
First Count: Breach of Contract
Defendant entered into a loan agreement with the original creditor or any other a: ignee that may
have or have had an interest in Defendant’s loan dunt or an interest in any obligation relating
to such account. Plaintiff, Velocity Investments, L.L.C. is now the owner and holder thereof,
Prior to the commencement of this action, Plaintiff purchased and/or was assigned the instrument
either directly from Upstart Network, Inc., or from a successor of Upstart Network, Inc.
Defendant made application to Cross River Bank for a loan.
In response to the Defendant's application, a loan was issued to Defendant under the account
ending in the number ***#8055,
Defendant promised to repay the monies loaned under the terms of the agreement.
Defendant failed to make payment and is in default of the terms of the loan, resulting in an
indebtedness on the account.
Defendant currently owes the sum of $9826.59 in addition to interest and costs of suit as allowed
by law.
Second Count: Account Stated
Defendant entered into a loan agreement with the original creditor or any other assignee
that may
have or have had an interest in Defendant’s loan account or an interest in any obligation relating
to such account. Plaintiff, Velocity Investments, L.L.C. is now the owner and holder thereof.
Prior to the commencement of this action, Plaintiff purchased and/or was assigned the instrument
either directly from Upstart Network, Inc., or from a successor of Upstart Network, Inc.
10 Defendant made application to Cross River Bank for a loan.
1 In response to the Defendant’s application, a loan was issued to Defendant under the account
ending in the number ****8055.
12. Heretofore, Defendant received monthly full and true accounts of the indebtedness owing by the
Defendant as a result of the loan agreement, which account statements were delivered to and
accepted without objection by the Defendant.
13. As no proper objection was made, the statements are presumed accurate, and constitute an
account stated which is prima facie evidence of the correctness of the account.
14, The final statement of account rendered detailed a total balance under the account stated cause of
action is $9826.59 as of 10/02/2022
WHEREFORE, Plaintiff prays for the following relief:
1 Money damages;
Interest;
Costs, disbursements, and interest at the maximum post judgment rate allowed by law,
A reasonable order of payments to be made by the said Defendant Jose Javicrgarciapolanco out of
any debts accruing by reason of the personal services of the Defendant Jose Javiergarciapolanco,
in accordance with statute made and provided
Such other and further relief as the Court may deem just and equitable.
Velocity Investments, L.L.C.
by its attorney,
—
Kyle Cohen
Juris No. 445386
Cohen & Cohen Law, LLC
540 East 180" Street, Suite 203
Bronx, New York 10457
CohenLawFirmLLC.com
(212) 564-1900
Contact@CohenLawFirmLLC.com
This is an attempt to collect a debt. Any information
obtained will be used for that purpose. This
communication is from a debt collector.
Our File No. 137843.001
Return Date: 07/16/2024
Docket Number:
FESS OI I ICISISII SI CIO IOI IK AA
Velocity Investments, L.L.C, SUPERIOR COURT
DANBURY
JUDICIAL DISTRICT
Plaintiff
v.
May 21, 2024
Jose Javiergarciapolanco
*
Defendant *
FEI COE SISISISIOCCICI
IIISCICICII
sod bk ese seak
STATEMENT OF AMOUNT IN DEMAND
The amount, legal interest or property in demand is:
[ ] FIFTEEN THOUSAND DOLLARS or more, exclusive of interest and custs.
[xX] TWO THOUSAND FIVE HUNDRED DOLLARS ($2,500.00) or more but less than
FIFTEEN THOUSAND DOLLARS ($15,000.00), exclusive of interest and costs.
Less than TWO THOUSAND FIVE HUNDRED DOLLARS, exclusive of interest and
costs.
Dated: May 21, 2024
Velocity Investments, L.L.C.
by its attorney,
so
LEae
2
Kyle Cohen
Juris No. 445386
Cohen & Cohen Law, LLC
540 Bast 180" Street, Suite 203
Rronx, New York 10457
CohenLawFirmLLC.com
(212) 564-1900
Contact(@CohenLawFirmLLC.com
This is an attempt to collect a debt. Any information
obtained will be used for that purpose. This
communication is from a debt collector.