Preview
FILED: ROCKLAND COUNTY CLERK 08/18/2021 05:12 PM INDEX NO. 034907/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/18/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ROCKLAND
____________________ _______________________ Plaintiff designates ROCKLAND County
CAPITAL ONE BANK (USA), N.A. as the place of trial; the defendant resides
in ROCKLAND County
PLAINTIFF,
INDEX NUMBER:
-AGAINST. PURCHASE DATE:
S&S FILE NO. N465959
ALEXANDER VOULGARIS
DEFENDANT. SUMMONS
_______________________ Plaintiffs address: 4851 COX ROAD, GLEN
ALLEN, VA 23060
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 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 17, 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. N465959
Defendant to be served: ALEXANDER VOULGARIS, 335 BLAUVELT RD, BLAUVELT, NY
10913
This ccen ___±atisii is from a debt collector and is an attempt to collect a debt. Any
information 6ttaliied will be used for that purp6se.
By:
..-==-··....q JOSEP RANALDO ESQ.
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FILED: ROCKLAND COUNTY CLERK 08/18/2021 05:12 PM INDEX NO. 034907/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/18/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ROCKLAND
CAPITAL ONE BANK (USA), N.A.
PLAINTIFF, INDEX NUMBER:
-AGAINST- S&S FILE NO. N465959
ALEXANDER VOULGARIS COMPLAINT
DEFENDANT.
Plaintiff,by itsattorneys, complaining of 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.
4. Upon information and belief based upon information received from the United States
Department of Defense, Manpower Defense Data Center (a copy of which isattached),the Defendant isnot
an activemember of any branch of theUnited States Military.
FACTS
5. A creditaccount, account no. ending in 5006 (hereafter the "Account"), was opened in
Defendant's name, subjectto theterms and conditions provided, or made available in electronicformat, to
the Defendant (the "Agreement").
6. Defendant used the Account and incurred a balance.
7. Defendant breached the terms of theAgreement by failing to make the agreed-upon payments
when due, and as a result
Plaintiffclosed the Account. At the time the Plaintiffclosed the Account, the
balance due and owing was $3,642.76, as reflectedin theattached statement.
8. Demand forpayment of theAccount was made on Defendant, but Defendant failedto make
allthe requiredpayments. The balance currently due and owing is$3,642.76.
AS AND FOR A FIRST CAUSE OF ACTION
9. Plaintiff
repeats and realleges each and every allegationcontained inthe foregoing paragraphs
as ifmore fully setforthherein.
10. That upon information and belief,Plaintiffrendered to Defendant a fulland true account of
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FILED: ROCKLAND COUNTY CLERK 08/18/2021 05:12 PM INDEX NO. 034907/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/18/2021
the indebtedness owing by the Defendant of
as a result nonpayment of theAccount, which
statement (a copy of which isattached) was delivered to and accepted without objection by the Defendant,
resultingin an account statedin the sum of $3,642.76, no part ofwhich has been paid despite due demand
therefor.
11. After creditingDefendant for allpayments and credits,there is now due and owing by
Defendant to Plaintiff
the sum of$3,642.76, no part ofwhich has been paid despite due demand therefor.
AS AND FOR A SECOND CAUSE OF ACTION
12. Plaintiff
repeats and realleges each and every allegationcontained inthe foregoing paragraphs
as ifmore fully setfor herein.
13. 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$3,642.76, no part
of which has been paid despite due demand therefor.
WHEREFORE, Plaintiffdemands judgment against Defendant(s) inthe amount of $3,642.76 together
with disbursements. Plaintiffexpressly disclaims any right to attorneyfees thatitmay have.
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 contentionstherein are not frivolousas defined in part130-1.1(c) of therules of theChief
Administrator.
Dated: AUGUST 17, 2021
YOURS T .
By
JOSEPIttANALDO 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. N465959
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FILED: ROCKLAND COUNTY CLERK 08/18/2021 05:12 PM INDEX NO. 034907/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/18/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ROCKLAND
_________________________________________________
CAPITAL ONE BANK (USA), N.A.
PLAINTIFF,
-AGAINST-
INDEX NUMBER:
ALEXANDER VOULGARIS S&S FILE NO. N465959
DEFENDANT.
_________________________________________________
NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING
PLEASE TAKE NOTICE that the matter captioned above, which has been commenced by the filing
of the accompanying documents with the County Clerk via the New York State Courts Electronic Filing
System ("NYSCEF"), is subject to mandatory electronic filing pursuant to Section 202.5-bb of the
Uniform Rules for the Trial Courts. This notice is being served as required by Subdivision (b) (3) of that
Section.
Counsel and/or parties must either: 1) immediately record their representation within the e-filed
matter on the Consent/Represent page in NYSCEF; or 2) file the Notice of Opt-Out form to claim one of
the limited exemptions from mandatory e-filing (see below). Failure to record representation may result
in an inability to receive electronic notice of any document filings. Claiming an exemption will require
the exempt party to serve and be served with hard copy documents.
Counsel and unrepresented parties who intend to participate in e-filing must first create a NYSCEF
account and obtain a userID and password. For additional information about electronic filing, and to
create a NYSCEF account, visit the NYSCEF website at www.nycourts.gov/efile or contact the
NYSCEF Resource Center (phone: 646-386-3033; e-mail: efile@nycourts.gov; mailing address: 60
Centre Street, New York, New York 10007).
Exemptions from mandatory e-filing (Section 202.5-bb(e)) are limited to:
1) attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or
internet connection or that they lack (along with all employees subject to their direction) the operational
knowledge to comply with e-filing requirements; and
2) parties who expect to represent themselves and who choose not to participate in e-filing. (Such
parties are encouraged to visit www.nycourthelp.gov or contact the Help Center in the court where the
action is pending.)
Dated: August 17, 2021
Selit & Stylianou, ÊLP
By: JOSEPH RANALDO ESQ., Attorney for Plaintiff
P.O. Box 9004, 199 Crossways Park Drive, Woodbury, NY 11797-9004
(516) 686-8991; (800) 293-6006 ext. 8991;
To: ALEXANDER VOULGARIS, 335 BLAUVELT RD, BLAUVELT, NY 10913
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Preview
FILED: ROCKLAND COUNTY CLERK 08/18/2021 05:12 PM INDEX NO. 034907/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/18/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND ____________________ _______________________ Plaintiff designates ROCKLAND County CAPITAL ONE BANK (USA), N.A. as the place of trial; the defendant resides in ROCKLAND County PLAINTIFF, INDEX NUMBER: -AGAINST. PURCHASE DATE: S&S FILE NO. N465959 ALEXANDER VOULGARIS DEFENDANT. SUMMONS _______________________ Plaintiffs address: 4851 COX ROAD, GLEN ALLEN, VA 23060 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 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 17, 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. N465959 Defendant to be served: ALEXANDER VOULGARIS, 335 BLAUVELT RD, BLAUVELT, NY 10913 This ccen ___±atisii is from a debt collector and is an attempt to collect a debt. Any information 6ttaliied will be used for that purp6se. By: ..-==-··....q JOSEP RANALDO ESQ. 1 of 4 FILED: ROCKLAND COUNTY CLERK 08/18/2021 05:12 PM INDEX NO. 034907/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/18/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND CAPITAL ONE BANK (USA), N.A. PLAINTIFF, INDEX NUMBER: -AGAINST- S&S FILE NO. N465959 ALEXANDER VOULGARIS COMPLAINT DEFENDANT. Plaintiff,by itsattorneys, complaining of 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. 4. Upon information and belief based upon information received from the United States Department of Defense, Manpower Defense Data Center (a copy of which isattached),the Defendant isnot an activemember of any branch of theUnited States Military. FACTS 5. A creditaccount, account no. ending in 5006 (hereafter the "Account"), was opened in Defendant's name, subjectto theterms and conditions provided, or made available in electronicformat, to the Defendant (the "Agreement"). 6. Defendant used the Account and incurred a balance. 7. Defendant breached the terms of theAgreement by failing to make the agreed-upon payments when due, and as a result Plaintiffclosed the Account. At the time the Plaintiffclosed the Account, the balance due and owing was $3,642.76, as reflectedin theattached statement. 8. Demand forpayment of theAccount was made on Defendant, but Defendant failedto make allthe requiredpayments. The balance currently due and owing is$3,642.76. AS AND FOR A FIRST CAUSE OF ACTION 9. Plaintiff repeats and realleges each and every allegationcontained inthe foregoing paragraphs as ifmore fully setforthherein. 10. That upon information and belief,Plaintiffrendered to Defendant a fulland true account of 2 of 4 FILED: ROCKLAND COUNTY CLERK 08/18/2021 05:12 PM INDEX NO. 034907/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/18/2021 the indebtedness owing by the Defendant of as a result nonpayment of theAccount, which statement (a copy of which isattached) was delivered to and accepted without objection by the Defendant, resultingin an account statedin the sum of $3,642.76, no part ofwhich has been paid despite due demand therefor. 11. After creditingDefendant for allpayments and credits,there is now due and owing by Defendant to Plaintiff the sum of$3,642.76, no part ofwhich has been paid despite due demand therefor. AS AND FOR A SECOND CAUSE OF ACTION 12. Plaintiff repeats and realleges each and every allegationcontained inthe foregoing paragraphs as ifmore fully setfor herein. 13. 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$3,642.76, no part of which has been paid despite due demand therefor. WHEREFORE, Plaintiffdemands judgment against Defendant(s) inthe amount of $3,642.76 together with disbursements. Plaintiffexpressly disclaims any right to attorneyfees thatitmay have. 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 contentionstherein are not frivolousas defined in part130-1.1(c) of therules of theChief Administrator. Dated: AUGUST 17, 2021 YOURS T . By JOSEPIttANALDO 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. N465959 3 of 4 FILED: ROCKLAND COUNTY CLERK 08/18/2021 05:12 PM INDEX NO. 034907/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/18/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND _________________________________________________ CAPITAL ONE BANK (USA), N.A. PLAINTIFF, -AGAINST- INDEX NUMBER: ALEXANDER VOULGARIS S&S FILE NO. N465959 DEFENDANT. _________________________________________________ NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING PLEASE TAKE NOTICE that the matter captioned above, which has been commenced by the filing of the accompanying documents with the County Clerk via the New York State Courts Electronic Filing System ("NYSCEF"), is subject to mandatory electronic filing pursuant to Section 202.5-bb of the Uniform Rules for the Trial Courts. This notice is being served as required by Subdivision (b) (3) of that Section. Counsel and/or parties must either: 1) immediately record their representation within the e-filed matter on the Consent/Represent page in NYSCEF; or 2) file the Notice of Opt-Out form to claim one of the limited exemptions from mandatory e-filing (see below). Failure to record representation may result in an inability to receive electronic notice of any document filings. Claiming an exemption will require the exempt party to serve and be served with hard copy documents. Counsel and unrepresented parties who intend to participate in e-filing must first create a NYSCEF account and obtain a userID and password. For additional information about electronic filing, and to create a NYSCEF account, visit the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone: 646-386-3033; e-mail: efile@nycourts.gov; mailing address: 60 Centre Street, New York, New York 10007). Exemptions from mandatory e-filing (Section 202.5-bb(e)) are limited to: 1) attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or internet connection or that they lack (along with all employees subject to their direction) the operational knowledge to comply with e-filing requirements; and 2) parties who expect to represent themselves and who choose not to participate in e-filing. (Such parties are encouraged to visit www.nycourthelp.gov or contact the Help Center in the court where the action is pending.) Dated: August 17, 2021 Selit & Stylianou, ÊLP By: JOSEPH RANALDO ESQ., Attorney for Plaintiff P.O. Box 9004, 199 Crossways Park Drive, Woodbury, NY 11797-9004 (516) 686-8991; (800) 293-6006 ext. 8991; To: ALEXANDER VOULGARIS, 335 BLAUVELT RD, BLAUVELT, NY 10913 4 of 4