Preview
FILED: OSWEGO COUNTY CLERK 10/16/2020 01:29 PM INDEX NO. EFC-2020-1260
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF OSWEGO
UHG I Index No.:
LLC,
Date Purchased
Plaintiff,
vs. SUMMONS
The basis ofthe venue designated is
The defendant residesin the
County of Oswego
PAUL VANDUSEN,
The transaction took place inthe
Defendant. county of Oswego
To the above-named Defendant:
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve
a copy of your answer, or, ifthe complaint is not served with this summons, to serve a notice of
appearance, on the Plaintiff's Attorney(s) at the address stated below within 20 days after the
service of this summons, exclusive of the day of service (or within 30 days after the service is
complete ifthis summons isnot personally delivered to you within the State of New York); and in
case of your failure to appear or answer, judgment will be taken against you by default for the
relief demanded in the complaint.
Dated: East Amherst, NY
C , 20 b y:
N CH LAW GROUP, LLP
He er A. ohnson, Esq.
and . Wrazen, Esq.
Attorneys for Plaintiff
5965 Transit Road, Suite 500
East Amherst, New York 14051
(833) 769-2757
MLG - 4340574
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FILED: OSWEGO COUNTY CLERK 10/16/2020 01:29 PM INDEX NO. EFC-2020-1260
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2020
10: PAUL VANDUSEN
240 TOAD HARBOR RD
WEST MONRQE, NY 13167
WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION WILL BE
USED FOR THAT.PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
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FILED: OSWEGO COUNTY CLERK 10/16/2020 01:29 PM INDEX NO. EFC-2020-1260
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF OSWEGO
UHG I LLC,
COMPLAINT
Plaintiff,
Index No.:
vs.
PAUL VANDUSEN,
Defendant.
Plaintiff, UHG I LLC, by its attorneys, Mandarich Law Group, LLP, complaiñiñg of the
Defendant, PAUL VANDUSEN, alleges the following:
1. Plaintiff is a foreign limited liability company organized and existing by virtue of
the laws of Delaware, with a principal place of business located at 6400 Sheridan Drive,
Williamsville, New York 14221.
2. Upon information and belief, Defendant PAUL VANDUSEN, was and is a natural
person residing at 240 TOAD HARBOR RD , County of Oswego, State of New York.
3. Plaintiff took by assignment and/or purchased, forvalue, allrights, title,and interest
of certain accounts, including the account identified below, which originated with WebBank
(serviced by Lending Club) (hereinafter the "Original Creditor").
4. Orignial Creditor issued a consumer loan account to the Defendant (original
account number ending in XXXXX4227) (herciñafter the "Account"), which is the subject of this
action.
5. Defendant entered into an agreement with the Original Creditor and made
purchases, received cash, merchandise, and/or credit on the Account.
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FILED: OSWEGO COUNTY CLERK 10/16/2020 01:29 PM INDEX NO. EFC-2020-1260
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2020
6. Defendant agreed but failed to make payments on said Account and $21,849.97 is
now due and owing to the Plaintiff from Defendant, which amount was demanded and remains
unpaid.
7. Defendant is in default and Plaintiff, as owner of the Account, is authorized to
proceed with this action.
8. Plaintiff has suffered damages in the amount of $21,849.97, together with the costs
and disbursements incurred in this action.
WHEREFORE, Plaintiff, UHG I LLC, respectfully requests judgment against the
Defendant, PAUL VANDUSEN, for the sum of $21,849.97, all costs and disbursements of this
action, with interest from the date of any judgment granted or ordered, and for such other and
further relief as this Court deems just and proper.
Dated: East Amherst, New York
, 20 b MANDARIC AW GROUP, LLP
Heather A. hns n, Esq.
Brandon . en, Esq.
Attorneys or Plaintiff
5965 Transit Road, Suite 500
East Amherst, New York 14051
(833) 769-2757
TO: PAUL VANDUSEN
240 TOAD HARBOR RD
WEST MONROE, NY 13167
WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT
COLLECTOR.
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Preview
FILED: OSWEGO COUNTY CLERK 10/16/2020 01:29 PM INDEX NO. EFC-2020-1260 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF OSWEGO UHG I Index No.: LLC, Date Purchased Plaintiff, vs. SUMMONS The basis ofthe venue designated is The defendant residesin the County of Oswego PAUL VANDUSEN, The transaction took place inthe Defendant. county of Oswego To the above-named Defendant: YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer, or, ifthe complaint is not served with this summons, to serve a notice of appearance, on the Plaintiff's Attorney(s) at the address stated below within 20 days after the service of this summons, exclusive of the day of service (or within 30 days after the service is complete ifthis summons isnot personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: East Amherst, NY C , 20 b y: N CH LAW GROUP, LLP He er A. ohnson, Esq. and . Wrazen, Esq. Attorneys for Plaintiff 5965 Transit Road, Suite 500 East Amherst, New York 14051 (833) 769-2757 MLG - 4340574 1 of 4 FILED: OSWEGO COUNTY CLERK 10/16/2020 01:29 PM INDEX NO. EFC-2020-1260 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2020 10: PAUL VANDUSEN 240 TOAD HARBOR RD WEST MONRQE, NY 13167 WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION WILL BE USED FOR THAT.PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. 2 of 4 FILED: OSWEGO COUNTY CLERK 10/16/2020 01:29 PM INDEX NO. EFC-2020-1260 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF OSWEGO UHG I LLC, COMPLAINT Plaintiff, Index No.: vs. PAUL VANDUSEN, Defendant. Plaintiff, UHG I LLC, by its attorneys, Mandarich Law Group, LLP, complaiñiñg of the Defendant, PAUL VANDUSEN, alleges the following: 1. Plaintiff is a foreign limited liability company organized and existing by virtue of the laws of Delaware, with a principal place of business located at 6400 Sheridan Drive, Williamsville, New York 14221. 2. Upon information and belief, Defendant PAUL VANDUSEN, was and is a natural person residing at 240 TOAD HARBOR RD , County of Oswego, State of New York. 3. Plaintiff took by assignment and/or purchased, forvalue, allrights, title,and interest of certain accounts, including the account identified below, which originated with WebBank (serviced by Lending Club) (hereinafter the "Original Creditor"). 4. Orignial Creditor issued a consumer loan account to the Defendant (original account number ending in XXXXX4227) (herciñafter the "Account"), which is the subject of this action. 5. Defendant entered into an agreement with the Original Creditor and made purchases, received cash, merchandise, and/or credit on the Account. 3 of 4 FILED: OSWEGO COUNTY CLERK 10/16/2020 01:29 PM INDEX NO. EFC-2020-1260 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/16/2020 6. Defendant agreed but failed to make payments on said Account and $21,849.97 is now due and owing to the Plaintiff from Defendant, which amount was demanded and remains unpaid. 7. Defendant is in default and Plaintiff, as owner of the Account, is authorized to proceed with this action. 8. Plaintiff has suffered damages in the amount of $21,849.97, together with the costs and disbursements incurred in this action. WHEREFORE, Plaintiff, UHG I LLC, respectfully requests judgment against the Defendant, PAUL VANDUSEN, for the sum of $21,849.97, all costs and disbursements of this action, with interest from the date of any judgment granted or ordered, and for such other and further relief as this Court deems just and proper. Dated: East Amherst, New York , 20 b MANDARIC AW GROUP, LLP Heather A. hns n, Esq. Brandon . en, Esq. Attorneys or Plaintiff 5965 Transit Road, Suite 500 East Amherst, New York 14051 (833) 769-2757 TO: PAUL VANDUSEN 240 TOAD HARBOR RD WEST MONROE, NY 13167 WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. 4 of 4