Preview
FILED: ST. LAWRENCE COUNTY CLERK 12/27/2019 09:04 AM INDEX NO. EFCV-19-157224
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/27/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ST LAWRENCE
____________________ _______________________ Plaintiff designates ST LAWRENCE
DISCOVER BANK County as the place of trial;the defendant
resides in ST LAWRENCE County
PLAINTIFF,
INDEX NUMBER:
-AGAINST. PURCHASE DATE:
S&S FILE NO. D159611
MARC J PEARSON
DEFENDANT. SUMMONS
Plaintiff s address: C/O DISCOVER
PRODUCTS INC.
6500 NEW ALBANY ROAD, NEW
ALBANY, OH 43054
The Basis of the Venue isDefendant's
Residence
CONSUMER CREDIT TRANSACTION
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, or, ifthe complaint isnot served with this summons, to serve a
notice of appearance, on the plaintiff s attorney within 20 days after the service of this summons
exclusive of the day of service (or within 30 days afterthe service is complete ifthis summons is
not personally delivered to you within the stateof New York); and in case of your failureto
appear or answer, judgment will be taken against you by default for the relief demanded in the
complaint, together with the costs of this action.
Dated: December 23, 2019
Selip & Stylianou, LLP
Attorneys forplaintiff
P.O. Box 9004, 199 Crossways Park Dr., Woodbury, NY 11797-9004
(516) 364-6006; (866) 848-8975 ext. 8991; Refer to S&S File No. D159611
Defendant to be served: MARC J PEARSON, 325 OLD ROUTE 11, CANTON, NY 13617
This communication is from a debt collector and is an attempt to collect a debt. Any
information nbtained will be used for that purpose.
JOS H DOW.
IIIIIIIIIIIIIIIIII!!!!;:::::2!!IIIIIIII
IIIIIIIII;;; IIIIIIIIIIIIIIIIIII!!!iillill!!!!!!!!iillIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII
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FILED: ST. LAWRENCE COUNTY CLERK 12/27/2019 09:04 AM INDEX NO. EFCV-19-157224
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/27/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ST LAWRENCE
____________________ _____________________________
DISCOVER BANK
PLAINTIFF, INDEX NUMBER:
-AGAINST- S&S FILE NO. D159611
MARC J PEARSON COMPLAINT
DEFENDANT.
____________________ _____________________________
Plaintiff,by itsattorneys, complaining of the Defendant(s), respectfully alleges that:
1. Plaintiff is a state chartered bank insured by the FDIC.
2. Upon information and belief, the Defendant(s) resides or has an office in the
county in which this action is brought, or the Defendant(s) transacted business within the
county 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. Plaintiff is authorized to bring the lawsuit pursuant to New York State
Banking Law §200(4).
4. Based upon a reasonable inquiry, the Statute of Limitations for the causes of
action asserted herein has not expired.
FACTS
5. A credit account, account no. ending in 7879 (hereafter the "Account"), was
opened in Defendant's name, subject to the terms and conditions provided, or made
available in electronic format, to the Defendant (the "Agreement").
6. Defendant used the Account and incurred a balance.
7. Defendant breached the terms of the Agreement to make the agreed-
by failing
upon payments when due.
8. Demand for payment of the Account was made on Defendant, but Defendant
failed to make all the required payments. The balance currently due and owing is
$9,786.04.
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FILED: ST. LAWRENCE COUNTY CLERK 12/27/2019 09:04 AM INDEX NO. EFCV-19-157224
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/27/2019
AS AND FOR A FIRST CAUSE OF ACTION
9. Plaintiff repeats and realleges each and every allegation contained in the
foregoing paragraphs as if more fully set for herein.
10. As a result of Defendant's breach of the Agreement, and after crediting
Defendant for all payments and credits, there is now due and owing by Defendant to
Plaintiff the sum of $9,786.04, no part of which has been paid despite due demand
therefor.
WHEREFORE, Plaintiff demands judgment against Defendant(s) in the amount of
$9,786.04 together with disbursements, with post-judgment interest to accrue thereon as
authorized by law.
The undersigned attorney hereby certifies that, to the best of his/her knowledge,
information, and belief, formed after an inquiry reasonable under the circumstances, the
presentation of the within complaint and the contentions therein are not frivolous as
defined in part 130-1.1(c) of the rules of the Chief Administrator.
Dated: DECEMBER 23, 2019
YOU TC.
By:
-
JOSEÈH1 A 1 O ESQ.
Selip & Stylianou, LLP, Attorneys for Plaintiff
199 Crossways Park Drive, Woodbury, NY 11797-9004
(516) 686-8991; (866) 848-8975 ext.8991;
S&S File No. D159611
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Preview
FILED: ST. LAWRENCE COUNTY CLERK 12/27/2019 09:04 AM INDEX NO. EFCV-19-157224 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/27/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ST LAWRENCE ____________________ _______________________ Plaintiff designates ST LAWRENCE DISCOVER BANK County as the place of trial;the defendant resides in ST LAWRENCE County PLAINTIFF, INDEX NUMBER: -AGAINST. PURCHASE DATE: S&S FILE NO. D159611 MARC J PEARSON DEFENDANT. SUMMONS Plaintiff s address: C/O DISCOVER PRODUCTS INC. 6500 NEW ALBANY ROAD, NEW ALBANY, OH 43054 The Basis of the Venue isDefendant's Residence CONSUMER CREDIT TRANSACTION 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, or, ifthe complaint isnot served with this summons, to serve a notice of appearance, on the plaintiff s attorney within 20 days after the service of this summons exclusive of the day of service (or within 30 days afterthe service is complete ifthis summons is not personally delivered to you within the stateof New York); and in case of your failureto appear or answer, judgment will be taken against you by default for the relief demanded in the complaint, together with the costs of this action. Dated: December 23, 2019 Selip & Stylianou, LLP Attorneys forplaintiff P.O. Box 9004, 199 Crossways Park Dr., Woodbury, NY 11797-9004 (516) 364-6006; (866) 848-8975 ext. 8991; Refer to S&S File No. D159611 Defendant to be served: MARC J PEARSON, 325 OLD ROUTE 11, CANTON, NY 13617 This communication is from a debt collector and is an attempt to collect a debt. Any information nbtained will be used for that purpose. JOS H DOW. IIIIIIIIIIIIIIIIII!!!!;:::::2!!IIIIIIII IIIIIIIII;;; IIIIIIIIIIIIIIIIIII!!!iillill!!!!!!!!iillIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII 1 of 3 FILED: ST. LAWRENCE COUNTY CLERK 12/27/2019 09:04 AM INDEX NO. EFCV-19-157224 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/27/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ST LAWRENCE ____________________ _____________________________ DISCOVER BANK PLAINTIFF, INDEX NUMBER: -AGAINST- S&S FILE NO. D159611 MARC J PEARSON COMPLAINT DEFENDANT. ____________________ _____________________________ Plaintiff,by itsattorneys, complaining of the Defendant(s), respectfully alleges that: 1. Plaintiff is a state chartered bank insured by the FDIC. 2. Upon information and belief, the Defendant(s) resides or has an office in the county in which this action is brought, or the Defendant(s) transacted business within the county 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. Plaintiff is authorized to bring the lawsuit pursuant to New York State Banking Law §200(4). 4. Based upon a reasonable inquiry, the Statute of Limitations for the causes of action asserted herein has not expired. FACTS 5. A credit account, account no. ending in 7879 (hereafter the "Account"), was opened in Defendant's name, subject to the terms and conditions provided, or made available in electronic format, to the Defendant (the "Agreement"). 6. Defendant used the Account and incurred a balance. 7. Defendant breached the terms of the Agreement to make the agreed- by failing upon payments when due. 8. Demand for payment of the Account was made on Defendant, but Defendant failed to make all the required payments. The balance currently due and owing is $9,786.04. 2 of 3 FILED: ST. LAWRENCE COUNTY CLERK 12/27/2019 09:04 AM INDEX NO. EFCV-19-157224 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/27/2019 AS AND FOR A FIRST CAUSE OF ACTION 9. Plaintiff repeats and realleges each and every allegation contained in the foregoing paragraphs as if more fully set for herein. 10. As a result of Defendant's breach of the Agreement, and after crediting Defendant for all payments and credits, there is now due and owing by Defendant to Plaintiff the sum of $9,786.04, no part of which has been paid despite due demand therefor. WHEREFORE, Plaintiff demands judgment against Defendant(s) in the amount of $9,786.04 together with disbursements, with post-judgment interest to accrue thereon as authorized by law. The undersigned attorney hereby certifies that, to the best of his/her knowledge, information, and belief, formed after an inquiry reasonable under the circumstances, the presentation of the within complaint and the contentions therein are not frivolous as defined in part 130-1.1(c) of the rules of the Chief Administrator. Dated: DECEMBER 23, 2019 YOU TC. By: - JOSEÈH1 A 1 O ESQ. Selip & Stylianou, LLP, Attorneys for Plaintiff 199 Crossways Park Drive, Woodbury, NY 11797-9004 (516) 686-8991; (866) 848-8975 ext.8991; S&S File No. D159611 3 of 3