Preview
FILED: CHAUTAUQUA COUNTY CLERK 12/31/2018 09:22 AM INDEX NO. EK12018001946
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/31/2018
STATE OF NEW YORK
COUNTY OF CHAUTAUQUA : CHAUTAUQ UA COUNTY SUPREME COURT
CONSUMER CREDIT TRANSACTION
GREATER WOODLAWN FEDERAL CREDIT UNION
S-3811 Lakeshore Road
Blasdell, NY 14219-,
Plaintiff, SUMMONS
vs.
Index No.
JOSHUA P PEREZ
307 East 6th Street, Apt. 4
Jamestown, NY 14701,
Defendant(s).
TO THE ABOVE-NAMED DEFENDANT(S):
You are hereby summoned and required to serve upon plaintiff's attomey 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 t Defendant(s) is the County of
Chautauqua.
DATED: December 26, 2018
Buffalo, New York
WILLIAM ILECKI
CHIARI & ILECKI, 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 willbe subject to
approval by the Court and applicable law. This communication is from a debt collector.
The debt ecilector is attempting to co!!ect a debt, and any information obtained will be used
for that purpose.
number-
Our file 20180172©
1 of 4
FILED: CHAUTAUQUA COUNTY CLERK 12/31/2018 09:22 AM INDEX NO. EK12018001946
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/31/2018
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 at the end of this notice. Note-
because of interest or other charges that may vary from day to day, the amount due on the
day you pay may be greater. Ifyou 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. This advice pertains to your dealings with
me as a debt co!!ector. Itdoes not affect your dealings with the court, and in particular it
does 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 of it,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 mail a
copy of such verification to you. 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 yoµr receipt of this summons. However, ifyou dispute the
debt or request the name and address of the original creditor within the thirty-day period
that begins with your receipt of this summons, and in the manner stated above, the law
requires us to cease efforts (through litigation or otherwise) to collect the debt until we mail
the requested information to you. 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.
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 4
FILED: CHAUTAUQUA COUNTY CLERK 12/31/2018 09:22 AM INDEX NO. EK12018001946
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/31/2018
STATE OF NEW YORK
COUNTY OF CHAUTAUQUA : CHAUTAUQUA COUNTY SUPREME COURT
CONSUMER CREÖÏT TRANSACTION
GREATER WOODLAWN FEDERAL CREDIT UNION,
Plaintiff, COMPLAINT
vs.
Index No.
JOSHUA P PEREZ,
Defendant(s). ASSIGNED JUDGE:
Hon.
Plaiñtiff, by Plaintiff's attorneys, CHIARI & ILECKl, 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 $4,886.00, together with interest at 1.99%
per annum from October 6, 2017, 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 February 26, 2015.
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 $4,886.00, together with interest at 1.99% per annum from
October 6, 2017 ($118.81 to date, plus any future interest due to date of
Judgment); plus reasonable attorney's fees to be requested in the amount of
3 of 4
FILED: CHAUTAUQUA COUNTY CLERK 12/31/2018 09:22 AM INDEX NO. EK12018001946
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/31/2018
$977.20; and
b. for the costs and disbursements of this action, and for such further relief
as this court deems proper.
DATED: December 26, 2018
Buffalo, New York
WILLIAM ILECKI
CHIARI & ILECKl, LLP
Attorney(s) for Plaintiff
1 DELAWARE ROAD, SUITE 110
BUFFALO, NY 14217
Phone: (716) 838-4300
Fax: (716) 204-9728
number-
Our file 20180172©
4 of 4
Preview
FILED: CHAUTAUQUA COUNTY CLERK 12/31/2018 09:22 AM INDEX NO. EK12018001946 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/31/2018 STATE OF NEW YORK COUNTY OF CHAUTAUQUA : CHAUTAUQ UA COUNTY SUPREME COURT CONSUMER CREDIT TRANSACTION GREATER WOODLAWN FEDERAL CREDIT UNION S-3811 Lakeshore Road Blasdell, NY 14219-, Plaintiff, SUMMONS vs. Index No. JOSHUA P PEREZ 307 East 6th Street, Apt. 4 Jamestown, NY 14701, Defendant(s). TO THE ABOVE-NAMED DEFENDANT(S): You are hereby summoned and required to serve upon plaintiff's attomey 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 t Defendant(s) is the County of Chautauqua. DATED: December 26, 2018 Buffalo, New York WILLIAM ILECKI CHIARI & ILECKI, 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 willbe subject to approval by the Court and applicable law. This communication is from a debt collector. The debt ecilector is attempting to co!!ect a debt, and any information obtained will be used for that purpose. number- Our file 20180172© 1 of 4 FILED: CHAUTAUQUA COUNTY CLERK 12/31/2018 09:22 AM INDEX NO. EK12018001946 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/31/2018 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 at the end of this notice. Note- because of interest or other charges that may vary from day to day, the amount due on the day you pay may be greater. Ifyou 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. This advice pertains to your dealings with me as a debt co!!ector. Itdoes not affect your dealings with the court, and in particular it does 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 of it,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 mail a copy of such verification to you. 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 yoµr receipt of this summons. However, ifyou dispute the debt or request the name and address of the original creditor within the thirty-day period that begins with your receipt of this summons, and in the manner stated above, the law requires us to cease efforts (through litigation or otherwise) to collect the debt until we mail the requested information to you. 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. 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 4 FILED: CHAUTAUQUA COUNTY CLERK 12/31/2018 09:22 AM INDEX NO. EK12018001946 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/31/2018 STATE OF NEW YORK COUNTY OF CHAUTAUQUA : CHAUTAUQUA COUNTY SUPREME COURT CONSUMER CREÖÏT TRANSACTION GREATER WOODLAWN FEDERAL CREDIT UNION, Plaintiff, COMPLAINT vs. Index No. JOSHUA P PEREZ, Defendant(s). ASSIGNED JUDGE: Hon. Plaiñtiff, by Plaintiff's attorneys, CHIARI & ILECKl, 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 $4,886.00, together with interest at 1.99% per annum from October 6, 2017, 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 February 26, 2015. 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 $4,886.00, together with interest at 1.99% per annum from October 6, 2017 ($118.81 to date, plus any future interest due to date of Judgment); plus reasonable attorney's fees to be requested in the amount of 3 of 4 FILED: CHAUTAUQUA COUNTY CLERK 12/31/2018 09:22 AM INDEX NO. EK12018001946 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/31/2018 $977.20; and b. for the costs and disbursements of this action, and for such further relief as this court deems proper. DATED: December 26, 2018 Buffalo, New York WILLIAM ILECKI CHIARI & ILECKl, LLP Attorney(s) for Plaintiff 1 DELAWARE ROAD, SUITE 110 BUFFALO, NY 14217 Phone: (716) 838-4300 Fax: (716) 204-9728 number- Our file 20180172© 4 of 4