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FILED: CLINTON COUNTY CLERK 08/11/2021 05:33 PM INDEX NO. 2021-00021424
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/11/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF CLINTON
_____________________________________ ______ Plaintiff designates CLINTON as
County
SYNCHRONY BANK the place of trial;the defendant resides in
CLINTON County
PLAINTIFF,
INDEX NUMBER:
-AGAINST. PURCHASE DATE:
S&S FILE NO. G1743175
JENNIFER GARROW
DEFENDANT. SUMMONS
Plaintiffs address: 170 ELECTION RD
SUITE 125, DRAPER, UT 84020
The Basis of the Venue isDefendant's
Residence
CONSUMER CREDIT TRANSACTION
TO THE ABOVE NAMED DEFENDANT(S):
YOU ARE HEREBY SUMMONED to answer the coniplaiiit in this action and
to serve a copy of your answer, or, ifthe coniplaint is not served with this summons, to serve a
notice of appearance, on the plaintiffs attorney within 20 days afterthe service of this summons,
exclusive of the day of service (orwithin 30 days after the service iscomplete 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: August 10, 2021
Selip & Stylianou, LLP
Attorneys forplaintiff
P.O. Box 9004, 199 Crossways Park Dr., Woodbury, NY 11797-9004
(516) 364-6006 ext. 8991; (866) 848-8975 ext. 8991; TTY/TRS: (516) 422-8500
Refer to S&S File No. G1743175
Defendant to be served: JENNIFER GARROW, 2 TWIN POND LAKE RD, PERU, NY 12972
This c:----------½an is from a debt collector and is an attempt to collect a debt. Any
informatism obtained will be used for that purpose.
By:
MARGA ET LESZKIEWICZ ESQ.
IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII
IIllIIIII|!!!!!|||!!!!!!!!iiiiill!!!!!!!!!!!!!!!!IIIIIIIIIIIIIIIIIlliiiiiiiiiiiE:IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII
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FILED: CLINTON COUNTY CLERK 08/11/2021 05:33 PM INDEX NO. 2021-00021424
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/11/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF CLINTON
SYNCHRONY BANK
PLAINTIFF, INDEX NUMBER:
-AGAINST- S&S FILE NO. G1743175
JENNIFER GARROW COMPLAINT
DEFENDANT.
Plaintiff,by itsattorneys, coiiiplaiilliigof the Defendant(s), respectfully alleges that:
1. Plaintiffisa nationalbanking association organized pursuant to federallaw.
2. Upon information and belief,the Defendant(s) residesor has an office in thecounty in which
thisaction is brought,or theDefendant(s) transacted business within the county in which thisaction is
brought, eitherinperson or through an agent and the instantcause of action arose out ofsaid transaction.
3. Based upon a reasonable inquiry,the Statute of Limitations forthe causes of actionasserted
hereinhas not expired.
FACTS
4. A Sam's Club MC-branded credit account, account no. ending in 8963 (hereafter the
"Account"), was opened in Defendant'sname, subject to theterms and conditions provided, or made
availablein electronicformat, to theDefendant (the "Agreement").
5. Defendant used the Account and incurred a balance.
6. Defendant breached the terms of theAgreement by failing to make the agreed-upon payments
when due.
7. Demand forpayment of theAccount was made on Defendant, but Defendant failedto make
allthe requiredpayments. The balance currently due and owing is$3,250.42.
AS AND FOR A FIRST CAUSE OF ACTION
8. Plaintiff
repeats and realleges each and every allegationcontained inthe foregoing paragiaplis
as ifmore fully setfor herein.
9. As a resultof Defendant's breach of theAgreement, and aftercrediting Defendant for all
payments and credits,there is now due and owing by Defendant to Plaintiffthe sum of$3,250.42.
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FILED: CLINTON COUNTY CLERK 08/11/2021 05:33 PM INDEX NO. 2021-00021424
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/11/2021
WHEREFORE, Plaintiffdemands judgment against Defendant(s) inthe amount of $3,250.42 together
with costs and disbursements.
The undersigned attorney hereby certifies
that,to thebest of his/herknowledge, information, and belief,
formed afteran inquiry reasonable under the circumstances, the presentation of thewithin complaint and
the contentions therein are not frivolousas defined in part130-1.1(c) of therules of theChief
Administrator.
Dated: AUGUST 10, 2021
YOUR ,
By:
MARGA LESZKIEWICZ 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. G1743175
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Preview
FILED: CLINTON COUNTY CLERK 08/11/2021 05:33 PM INDEX NO. 2021-00021424 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/11/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF CLINTON _____________________________________ ______ Plaintiff designates CLINTON as County SYNCHRONY BANK the place of trial;the defendant resides in CLINTON County PLAINTIFF, INDEX NUMBER: -AGAINST. PURCHASE DATE: S&S FILE NO. G1743175 JENNIFER GARROW DEFENDANT. SUMMONS Plaintiffs address: 170 ELECTION RD SUITE 125, DRAPER, UT 84020 The Basis of the Venue isDefendant's Residence CONSUMER CREDIT TRANSACTION TO THE ABOVE NAMED DEFENDANT(S): YOU ARE HEREBY SUMMONED to answer the coniplaiiit in this action and to serve a copy of your answer, or, ifthe coniplaint is not served with this summons, to serve a notice of appearance, on the plaintiffs attorney within 20 days afterthe service of this summons, exclusive of the day of service (orwithin 30 days after the service iscomplete 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: August 10, 2021 Selip & Stylianou, LLP Attorneys forplaintiff P.O. Box 9004, 199 Crossways Park Dr., Woodbury, NY 11797-9004 (516) 364-6006 ext. 8991; (866) 848-8975 ext. 8991; TTY/TRS: (516) 422-8500 Refer to S&S File No. G1743175 Defendant to be served: JENNIFER GARROW, 2 TWIN POND LAKE RD, PERU, NY 12972 This c:----------½an is from a debt collector and is an attempt to collect a debt. Any informatism obtained will be used for that purpose. By: MARGA ET LESZKIEWICZ ESQ. IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII IIllIIIII|!!!!!|||!!!!!!!!iiiiill!!!!!!!!!!!!!!!!IIIIIIIIIIIIIIIIIlliiiiiiiiiiiE:IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII 1 of 3 FILED: CLINTON COUNTY CLERK 08/11/2021 05:33 PM INDEX NO. 2021-00021424 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/11/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF CLINTON SYNCHRONY BANK PLAINTIFF, INDEX NUMBER: -AGAINST- S&S FILE NO. G1743175 JENNIFER GARROW COMPLAINT DEFENDANT. Plaintiff,by itsattorneys, coiiiplaiilliigof the Defendant(s), respectfully alleges that: 1. Plaintiffisa nationalbanking association organized pursuant to federallaw. 2. Upon information and belief,the Defendant(s) residesor has an office in thecounty in which thisaction is brought,or theDefendant(s) transacted business within the county in which thisaction is brought, eitherinperson or through an agent and the instantcause of action arose out ofsaid transaction. 3. Based upon a reasonable inquiry,the Statute of Limitations forthe causes of actionasserted hereinhas not expired. FACTS 4. A Sam's Club MC-branded credit account, account no. ending in 8963 (hereafter the "Account"), was opened in Defendant'sname, subject to theterms and conditions provided, or made availablein electronicformat, to theDefendant (the "Agreement"). 5. Defendant used the Account and incurred a balance. 6. Defendant breached the terms of theAgreement by failing to make the agreed-upon payments when due. 7. Demand forpayment of theAccount was made on Defendant, but Defendant failedto make allthe requiredpayments. The balance currently due and owing is$3,250.42. AS AND FOR A FIRST CAUSE OF ACTION 8. Plaintiff repeats and realleges each and every allegationcontained inthe foregoing paragiaplis as ifmore fully setfor herein. 9. As a resultof Defendant's breach of theAgreement, and aftercrediting Defendant for all payments and credits,there is now due and owing by Defendant to Plaintiffthe sum of$3,250.42. 2 of 3 FILED: CLINTON COUNTY CLERK 08/11/2021 05:33 PM INDEX NO. 2021-00021424 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/11/2021 WHEREFORE, Plaintiffdemands judgment against Defendant(s) inthe amount of $3,250.42 together with costs and disbursements. The undersigned attorney hereby certifies that,to thebest of his/herknowledge, information, and belief, formed afteran inquiry reasonable under the circumstances, the presentation of thewithin complaint and the contentions therein are not frivolousas defined in part130-1.1(c) of therules of theChief Administrator. Dated: AUGUST 10, 2021 YOUR , By: MARGA LESZKIEWICZ 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. G1743175 3 of 3