Preview
FILED: CHAUTAUQUA COUNTY CLERK 08/26/2021 10:58 AM INDEX NO. EK12021001218
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/26/2021
STATE OF NEW YORK
COUNTY OF CHAUTAUQUA :CHAUTAUQUA COUNTY SUPREME COURT
CONSUMER CREDIT TRANSACTION
SOUTHERN CHAUTAUQUA FEDERAL CREDIT UNION
168 E Fairmount Ave
Lakewood, NY 14750-1942,
Plaintiff, SUMMONS
vs.
Index No.
YULISSA LEON A/K/A DEJESUS
610 Newland Ave Apt 2
Jamestown, NY 14701,
Defendant(s).
TO THE ABOVE-NAMED DEFENDANT(S):
You are hereby summoned and required to serve upon plaintiff's attorney an answer
to the complaint in this action within twenty days after the service of this summons,
exclusive of the day of service, or within thirty days after service is complete if this
summons is not personally delivered to you within the State of New York. In case of your
failure to answer, judgment will be taken against you by default for the relief demanded in
the complaint.
This action is brought in the County of Chautauqua, because of the place of
transaction in said County. The residence of the Defendant(s) is the County of
Chautauqua.
DATED: August 20, 2021
Buffalo, New York
WILLIAM ILECKI
ILECKI & OSTROWSKI, LLP
Attorney(s) for Plaintiff
1 DELAWARE ROAD, SUITE 110
BUFFALO, NY 14217
Phone: (716) 838-4300
Fax: (716) 204-9728
Any request for Judgment for the relief demanded in the Complaint will be subject to
approval by the Court and applicable law. This communication is from a debt collector. The
debt collector is attempting to collect a debt, and any information obtained will be used for
that purpose.
Our file number-
20190153©
1 of 5
FILED: CHAUTAUQUA COUNTY CLERK 08/26/2021 10:58 AM INDEX NO. EK12021001218
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/26/2021
Although we may have requested that you take certain action, you stillhave the right
to make a written request, within thirty days of your receipt of this notice, for more
information about the debt. Your rights are described herein.
This advice pertains to your dealings with me as a debt collector. Itdoes not affect
your dealings with the court, and in particular itdoes not change the time at which you must
answer the complaint. The summons is a command from the court, not from me, and you
must follow its instructions even ifyou dispute the validity or amount of the debt. The advice
in this portion of the document also does not affect my relations with the court. As a lawyer,
I may file papers in the suit according to the court's rules and the judge's instructions.
Unless you, within thirty days after receipt of this notice, dispute the validity of the debt, or
any portion thereof, the debt will be assumed to be valid by us.
Ifyou notify us in writing within the thirty-day period that the debt, or any portion
thereof, is disputed, we will obtain verification of the debt and a copy of such verification will
be mailed to you by us. Upon your written request within the thirty-day period, we will
provide you with the name and address of the original creditor, ifdifferent from the current
creditor. The law does not require us to wait until the end of the thirty-day period following
first contact with you before suing you to collect the debt. Even though the law provides
that your answer to the Complaint may be required to be served in some cases in less than
thirty days, no request will be made to the Court for a judgment until,at least, the expiration
of thirty days after your receipt of this notice. However, ifyou provide such written notice of
a dispute or request for creditor information as provided in this paragraph, and within the
thirty-day period that begins with your receipt of this notice, and in the manner stated
herein, we will cease efforts (through litigation or otherwise) to collect the debt until we mail
the information to you, as required by law. Nevertheless, this dispute or request may not
constitute an Answer under law. You should consult an attorney for advice concerning your
rights and obligations in this suit.
This communication is from a debt collector. The debt collector is attempting to
collect a debt, and any information obtained will be used for that purpose.
Note- because of interest or other charges that from to the
may vary day day,
amount due on the day you pay may be greater. If you pay the amount shown in the
Complaint, an adjustment may be necessary after we receive the payment, in which event
we will inform you. For further information, please contact this office.
2 of 5
FILED: CHAUTAUQUA COUNTY CLERK 08/26/2021 10:58 AM INDEX NO. EK12021001218
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/26/2021
STATE OF NEW YORK
COUNTY OF CHAUTAUQUA :CHAUTAUQUA COUNTY SUPREME COURT
CONSUMER CREDIT TRANSACTION
SOUTHERN CHAUTAUQUA FEDERAL CREDIT UNION,
Plaintiff, COMPLAINT
vs.
Index No.
YULISSA LEON A/K/A DEJESUS,
Defendant(s). ASSIGNED JUDGE:
Hon.
Plaintiff, by Plaintiff's attorneys, ILECKI & OSTROWSKI, LLP, complaining of the
Defendant(s), herein alleges:
FIRST CAUSE OF ACTION
FIRST COUNT
1. Plaintiff is a(n) federally chartered credit union.
2. Defendant(s) owe Plaintiff the sum of $4,955.60, together with interest at 9.00%
per annum from October 11, 2018, for money lent by Plaintiff to Defendant(s) for which
the Defendant(s) have failed to repay and remain liable pursuant to their agreement with
the Plaintiff on or about July 20, 2016.
attorneys'
3. Plaintiff has incurred legal expenses including fees by the default of
attorneys'
the Defendant(s), and is entitled to recover fees from the Defendant(s) as
provided by the aforementioned agreement.
WHEREFORE, Plaintiff demands judgment against Defendant(s) as follows:
a. for the sum of $4,955.60, together with interest at 9.00% per annum from
October 11, 2018 ($1,270.81 to date of Complaint, plus any future interest due to
date of Judgment); plus reasonable attorney's fees to be requested in the
3 of 5
FILED: CHAUTAUQUA COUNTY CLERK 08/26/2021 10:58 AM INDEX NO. EK12021001218
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/26/2021
amount of $1,238.90; and
b. for the costs and disbursements of this action, and for such further relief
as this court deems proper.
DATED: August 16, 2021
Buffalo, New York
WILLIAM ILECKI
ILECKI & OSTROWSKI, LLP
Attorney(s) for Plaintiff
1 DELAWARE ROAD, SUITE 110
BUFFALO, NY 14217
Phone: (716) 838-4300
Fax: (716) 204-9728
Our file number-
20190153©
4 of 5
FILED: CHAUTAUQUA COUNTY CLERK 08/26/2021 10:58 AM INDEX NO. EK12021001218
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/26/2021
STATE OF NEW YORK ) COUNTY OF Chautauqua ) ss:
Melissa Gniewecki, Co!!ections Manager for Plaintiff, being duly sworn, deposes
and states that I have read the foregoing Complaint and know the contents thereof; the
same is true to my own knowledge, except as to matters therein stated to be alleged on
information and belief and as to those matters I believe it to be true, based upon my
review of the file, records, and conversations with individuals with knowledge of this
matter.
Melissa Gniewecki
Sworn to before me this
August 16, 2021.
NOT RY PUBLIC
Our file number-
20190153©
MELISSA L JOHNSON
NOTARYPUBUC STATEOF NEW YORK
#01J006382941
Qualifiedin Chauteuqua County
My Commission ExpiresNov. 5,2022
5 of 5
Preview
FILED: CHAUTAUQUA COUNTY CLERK 08/26/2021 10:58 AM INDEX NO. EK12021001218 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/26/2021 STATE OF NEW YORK COUNTY OF CHAUTAUQUA :CHAUTAUQUA COUNTY SUPREME COURT CONSUMER CREDIT TRANSACTION SOUTHERN CHAUTAUQUA FEDERAL CREDIT UNION 168 E Fairmount Ave Lakewood, NY 14750-1942, Plaintiff, SUMMONS vs. Index No. YULISSA LEON A/K/A DEJESUS 610 Newland Ave Apt 2 Jamestown, NY 14701, Defendant(s). TO THE ABOVE-NAMED DEFENDANT(S): You are hereby summoned and required to serve upon plaintiff's attorney an answer to the complaint in this action within twenty days after the service of this summons, exclusive of the day of service, or within thirty days after service is complete if this summons is not personally delivered to you within the State of New York. In case of your failure to answer, judgment will be taken against you by default for the relief demanded in the complaint. This action is brought in the County of Chautauqua, because of the place of transaction in said County. The residence of the Defendant(s) is the County of Chautauqua. DATED: August 20, 2021 Buffalo, New York WILLIAM ILECKI ILECKI & OSTROWSKI, LLP Attorney(s) for Plaintiff 1 DELAWARE ROAD, SUITE 110 BUFFALO, NY 14217 Phone: (716) 838-4300 Fax: (716) 204-9728 Any request for Judgment for the relief demanded in the Complaint will be subject to approval by the Court and applicable law. This communication is from a debt collector. The debt collector is attempting to collect a debt, and any information obtained will be used for that purpose. Our file number- 20190153© 1 of 5 FILED: CHAUTAUQUA COUNTY CLERK 08/26/2021 10:58 AM INDEX NO. EK12021001218 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/26/2021 Although we may have requested that you take certain action, you stillhave the right to make a written request, within thirty days of your receipt of this notice, for more information about the debt. Your rights are described herein. This advice pertains to your dealings with me as a debt collector. Itdoes not affect your dealings with the court, and in particular itdoes not change the time at which you must answer the complaint. The summons is a command from the court, not from me, and you must follow its instructions even ifyou dispute the validity or amount of the debt. The advice in this portion of the document also does not affect my relations with the court. As a lawyer, I may file papers in the suit according to the court's rules and the judge's instructions. Unless you, within thirty days after receipt of this notice, dispute the validity of the debt, or any portion thereof, the debt will be assumed to be valid by us. Ifyou notify us in writing within the thirty-day period that the debt, or any portion thereof, is disputed, we will obtain verification of the debt and a copy of such verification will be mailed to you by us. Upon your written request within the thirty-day period, we will provide you with the name and address of the original creditor, ifdifferent from the current creditor. The law does not require us to wait until the end of the thirty-day period following first contact with you before suing you to collect the debt. Even though the law provides that your answer to the Complaint may be required to be served in some cases in less than thirty days, no request will be made to the Court for a judgment until,at least, the expiration of thirty days after your receipt of this notice. However, ifyou provide such written notice of a dispute or request for creditor information as provided in this paragraph, and within the thirty-day period that begins with your receipt of this notice, and in the manner stated herein, we will cease efforts (through litigation or otherwise) to collect the debt until we mail the information to you, as required by law. Nevertheless, this dispute or request may not constitute an Answer under law. You should consult an attorney for advice concerning your rights and obligations in this suit. This communication is from a debt collector. The debt collector is attempting to collect a debt, and any information obtained will be used for that purpose. Note- because of interest or other charges that from to the may vary day day, amount due on the day you pay may be greater. If you pay the amount shown in the Complaint, an adjustment may be necessary after we receive the payment, in which event we will inform you. For further information, please contact this office. 2 of 5 FILED: CHAUTAUQUA COUNTY CLERK 08/26/2021 10:58 AM INDEX NO. EK12021001218 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/26/2021 STATE OF NEW YORK COUNTY OF CHAUTAUQUA :CHAUTAUQUA COUNTY SUPREME COURT CONSUMER CREDIT TRANSACTION SOUTHERN CHAUTAUQUA FEDERAL CREDIT UNION, Plaintiff, COMPLAINT vs. Index No. YULISSA LEON A/K/A DEJESUS, Defendant(s). ASSIGNED JUDGE: Hon. Plaintiff, by Plaintiff's attorneys, ILECKI & OSTROWSKI, LLP, complaining of the Defendant(s), herein alleges: FIRST CAUSE OF ACTION FIRST COUNT 1. Plaintiff is a(n) federally chartered credit union. 2. Defendant(s) owe Plaintiff the sum of $4,955.60, together with interest at 9.00% per annum from October 11, 2018, for money lent by Plaintiff to Defendant(s) for which the Defendant(s) have failed to repay and remain liable pursuant to their agreement with the Plaintiff on or about July 20, 2016. attorneys' 3. Plaintiff has incurred legal expenses including fees by the default of attorneys' the Defendant(s), and is entitled to recover fees from the Defendant(s) as provided by the aforementioned agreement. WHEREFORE, Plaintiff demands judgment against Defendant(s) as follows: a. for the sum of $4,955.60, together with interest at 9.00% per annum from October 11, 2018 ($1,270.81 to date of Complaint, plus any future interest due to date of Judgment); plus reasonable attorney's fees to be requested in the 3 of 5 FILED: CHAUTAUQUA COUNTY CLERK 08/26/2021 10:58 AM INDEX NO. EK12021001218 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/26/2021 amount of $1,238.90; and b. for the costs and disbursements of this action, and for such further relief as this court deems proper. DATED: August 16, 2021 Buffalo, New York WILLIAM ILECKI ILECKI & OSTROWSKI, LLP Attorney(s) for Plaintiff 1 DELAWARE ROAD, SUITE 110 BUFFALO, NY 14217 Phone: (716) 838-4300 Fax: (716) 204-9728 Our file number- 20190153© 4 of 5 FILED: CHAUTAUQUA COUNTY CLERK 08/26/2021 10:58 AM INDEX NO. EK12021001218 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/26/2021 STATE OF NEW YORK ) COUNTY OF Chautauqua ) ss: Melissa Gniewecki, Co!!ections Manager for Plaintiff, being duly sworn, deposes and states that I have read the foregoing Complaint and know the contents thereof; the same is true to my own knowledge, except as to matters therein stated to be alleged on information and belief and as to those matters I believe it to be true, based upon my review of the file, records, and conversations with individuals with knowledge of this matter. Melissa Gniewecki Sworn to before me this August 16, 2021. NOT RY PUBLIC Our file number- 20190153© MELISSA L JOHNSON NOTARYPUBUC STATEOF NEW YORK #01J006382941 Qualifiedin Chauteuqua County My Commission ExpiresNov. 5,2022 5 of 5