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SUPREME COURT OF THE STATE OF NEW YORK CONSUMER CREDIT TRANSACTION
COUNTY OF NEW YORK Our File No. MB05134
Court Index No.
HSBC BANK USA, NATIONAL Date Purchased:
ASSOCIATION
SUMMONS
Plaintiff Plaintiff's address:
-against- ae ASN One oo 3 SOUTH
FFALO, NY 142
YEE MAU CHEUNG ina a
COTTON WORKS USA, INC.
Defendant(s) MINN
{QA
{NNN
Defendant resides in the State of New York, County of NEW YORK
To the above named defendant (s):
The basis of venue is:
YOU ARE HEREBY SUMMONED
to answer the complaint in this action and to serve a copy of your answer on Plaintiff's Attorneys within the
time provided by law as noted below. Upon failure to answer, judgment will be taken against you for the
relief demanded in the complaint, together with the costs of this action.
Dated: May 22, 2009
ELLIOT PHILLIPS
3000 Hempstead Turnpike, Fourth Floor
Levittown, New York 11756
(516) 746-1144
NOTE: The Law or rules of court provide that:
(a) If this summons is served by its delivery to you personally within the State of New York, you must
answer within 20 days after such service; or
(b) If this summons is served by delivery to any person other than you personally, or is served
outside the State of New York, or by publication, or by any means other than personal delivery to you within
the State of New York, you are allowed 30 days after service is complete within which to answer.
Defendant (s) Address:
12 MONROE ST APT APT 10F NEW YORK NY 10002-7683
400 SOUTH 2ND ST 3RD FL BROOKLYN NY 11211
WE ARE DEBT COLLECTORS-THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.SUPREME COURT OF THE STATE OF NEW YORK Our File No. MB05134
COUNTY OF NEW YORK
HSBC BANK USA, NATIONAL Court Index No.
ASSOCIATION
Plaintiff
-against- COMPLAINT
YEE MAU CHEUNG
COTTON WORKS USA, INC.
Defendant (s) L9703003065
Plaintiff, by its attorneys, complaining of the defendant(s), respectfully alleges:
1. Plaintiff is a corporation organized under the laws of the United States of America. Under present
rules plaintiff is not required to be licensed as a debt collector by the New York City Department of
Consumer Affairs.
2. That the defendant(s) resides in the county in which this action is brought; or that the defendant(s)
transacted business within the county in which this action is brought in person or through an agent and that
the instant cause of action arose out of said transaction.
3. Upon information and belief the corporate defendant is a New York Corporation.
4. That the individual defendants are guarantors of the obligations of the corporate defendant to the
plaintiff.
FOR A FIRST CAUSE OF ACTION
5. That heretofore the plaintiff and the corporate defendant entered into an agreement under the
terms of which the corporate defendant was authorized to, and did, issue checks for amounts in excess of
the balance in its account, and was obligated to reimburse plaintiff for the amount thereof together with
applicable interest.
6. Upon information and belief, the corporate defendant, defaulted in making the payments due
therein and presently owes a balance of $104,406.14, together with an attorney's fee of $20,881.23, as
provided in said agreement, making a total of $125,287.37.
FOR A SECOND CAUSE OF ACTION
7. That heretofore, plaintiff rendered to the corporate defendant, monthly, full, just and true accounts
of the indebtedness due and owing by the corporate defendant as a result of the aforesaid transaction,
which is the sum set forth above, and said statements were delivered to, received, accepted and retained
the corporate defendant without objection, resulting in an account stated for the amount claimed above.
WHEREFORE, plaintiff demands judgement against the defendant(s) for the sum of $125,287.37 with
interest on $104,406.14 from SeptemberZ9, 2006, together with costs and disbursements.
May 22, 2009 KIRSCHENBAUM & PHILLIPS, P.C.
Attorneys for Plaintiff
3000 Hempstead Turnpike, Fourth Floor
Levittown, New York 11756
(516) 746-1144
LLIOT PHILLIPS
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SUPREME COURT OF THE STATE OF NEW YORK CONSUMER CREDIT TRANSACTION COUNTY OF NEW YORK Our File No. MB05134 Court Index No. HSBC BANK USA, NATIONAL Date Purchased: ASSOCIATION SUMMONS Plaintiff Plaintiff's address: -against- ae ASN One oo 3 SOUTH FFALO, NY 142 YEE MAU CHEUNG ina a COTTON WORKS USA, INC. Defendant(s) MINN {QA {NNN Defendant resides in the State of New York, County of NEW YORK To the above named defendant (s): The basis of venue is: YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer on Plaintiff's Attorneys within the time provided by law as noted below. Upon failure to answer, judgment will be taken against you for the relief demanded in the complaint, together with the costs of this action. Dated: May 22, 2009 ELLIOT PHILLIPS 3000 Hempstead Turnpike, Fourth Floor Levittown, New York 11756 (516) 746-1144 NOTE: The Law or rules of court provide that: (a) If this summons is served by its delivery to you personally within the State of New York, you must answer within 20 days after such service; or (b) If this summons is served by delivery to any person other than you personally, or is served outside the State of New York, or by publication, or by any means other than personal delivery to you within the State of New York, you are allowed 30 days after service is complete within which to answer. Defendant (s) Address: 12 MONROE ST APT APT 10F NEW YORK NY 10002-7683 400 SOUTH 2ND ST 3RD FL BROOKLYN NY 11211 WE ARE DEBT COLLECTORS-THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.SUPREME COURT OF THE STATE OF NEW YORK Our File No. MB05134 COUNTY OF NEW YORK HSBC BANK USA, NATIONAL Court Index No. ASSOCIATION Plaintiff -against- COMPLAINT YEE MAU CHEUNG COTTON WORKS USA, INC. Defendant (s) L9703003065 Plaintiff, by its attorneys, complaining of the defendant(s), respectfully alleges: 1. Plaintiff is a corporation organized under the laws of the United States of America. Under present rules plaintiff is not required to be licensed as a debt collector by the New York City Department of Consumer Affairs. 2. That the defendant(s) resides in the county in which this action is brought; or that the defendant(s) transacted business within the county in which this action is brought in person or through an agent and that the instant cause of action arose out of said transaction. 3. Upon information and belief the corporate defendant is a New York Corporation. 4. That the individual defendants are guarantors of the obligations of the corporate defendant to the plaintiff. FOR A FIRST CAUSE OF ACTION 5. That heretofore the plaintiff and the corporate defendant entered into an agreement under the terms of which the corporate defendant was authorized to, and did, issue checks for amounts in excess of the balance in its account, and was obligated to reimburse plaintiff for the amount thereof together with applicable interest. 6. Upon information and belief, the corporate defendant, defaulted in making the payments due therein and presently owes a balance of $104,406.14, together with an attorney's fee of $20,881.23, as provided in said agreement, making a total of $125,287.37. FOR A SECOND CAUSE OF ACTION 7. That heretofore, plaintiff rendered to the corporate defendant, monthly, full, just and true accounts of the indebtedness due and owing by the corporate defendant as a result of the aforesaid transaction, which is the sum set forth above, and said statements were delivered to, received, accepted and retained the corporate defendant without objection, resulting in an account stated for the amount claimed above. WHEREFORE, plaintiff demands judgement against the defendant(s) for the sum of $125,287.37 with interest on $104,406.14 from SeptemberZ9, 2006, together with costs and disbursements. May 22, 2009 KIRSCHENBAUM & PHILLIPS, P.C. Attorneys for Plaintiff 3000 Hempstead Turnpike, Fourth Floor Levittown, New York 11756 (516) 746-1144 LLIOT PHILLIPS