Preview
FILED: TIOGA COUNTY CLERK 07/02/2024 02:04 PM INDEX NO. 2024-00063700
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/02/2024
STATE OF NEWYORK
SUPREMECOURT : COUNTYOF TIOGA
_____________________________________
VISIONS FEDERALCREDIT UNION
24 McKinley Avenue SUMMONS
Endicott, New York 13760,
INDEX NO:
Plaintiff
-against-
PAUL M. BALOG JR
255 Front Street
Owego, New York 13827,
Defendant.
_____________________________________
CONSUMERCREDIT TRANSACTION
TO THE ABOVE-NAMEDDEFENDANT:
YOU ARE HEREBYSUMMONED 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, if this Summons is personally delivered
to you within the State of New York, 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 and for
the relief demanded in the Complaint.
of residence
The County of Defendant is Tioga County, and
the county where the consumer credit transaction took place is
Tioga County.
The basis of the venue designate e county where the
Defendant resides.
Dated: May 20, 2024
Wi M. Thomas .
ASWAD & INGRAHAM, LLP
Attorneys for Plaintiff
Office and P. O. Address
46 Front Street
Binghamton, New York 13905
Telephone: (607) 722-3495
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FILED: TIOGA COUNTY CLERK 07/02/2024 02:04 PM INDEX NO. 2024-00063700
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/02/2024
STATE OF NEWYORK
SUPREMECOURT : COUNTYOF TIOGA
_____________________________________
VISIONS FEDERAL CREDIT UNION
24 McKinley Avenue COMPLAINT
Endicott, New York 13760,
INDEX NO:
Plaintiff,
-against-
PAUL M. BALOG JR
255 Front Street
Owego, New York 13827,
Defendant.
_____________________________________
The Plaintiff, by its attorneys, Aswad & Ingraham, LLP, for
its complaint herein, alleges:
1. That the Plaintiff was at all times hereinafter
mentioned and still is, a Federal Credit Union with a principal
place of business at 24 McKinley Avenue, in the Village of
Endicott, County of Broome and State of New York.
2. That upon information and belief, the Defendant resides
at: 255 Front Street, Owego, New York 13827.
3. That for the purpose of obtaining a line of credit and
other credit rights, the Defendant entered, and executed a
Credit Card Agreement with the Plaintiff which provided for a
credit line and an arrangement for payment of the debt to the
Plaintiff. That Agreement is identified as follows: Dated:
August 4, 2020; Approved Line of Credit: $3,000.00; Last four
digits of account number: 7100. A copy of said Agreement is
attached hereto.
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FILED: TIOGA COUNTY CLERK 07/02/2024 02:04 PM INDEX NO. 2024-00063700
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/02/2024
4. That the Defendant has defaulted on its obligation
under the Agreement to make the full payment due on August 28,
2023.
5. That the last payment made by Defendant to Plaintiff
on this obligation was received August 23, 2023, in the amount
of $100.00.
6. That due demand for payment has been made, the
necessary payments have not been made, and the entire amount
owing, with interest, is now in default and due and payable.
7. That attached hereto is the most recent statement of
account related to this obligation, which was provided to
Defendant on or about March 1, 2024. Also, attached is a copy
of the most recent monthly statement recording a purchase
transaction, last payment, or a balance transfer. The statement
shows an account balance of $2,966.76 as of August 31, 2023.
8. That the amount due is as follows: $2,994.81, which was
the amount owed at the time of charge off, plus interest in the
amount of $118.40 from January 30, 2024 the date of charge-off,
at the per annum rate of 13.0%, plus interest to the date of
judgment, plus attorney fees to be determined by the Court and
costs and disbursements in the approximate amount of $700.00.
the
WHEREFORE Plaintiff demands judgment against the
Defendant in the amount of $2,994.81, which was the amount owed
at the time of charge off, plus interest from January 30, 2024
at the per annum rate of 13.0%, plus attorney fees to be
2
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FILED: TIOGA COUNTY CLERK 07/02/2024 02:04 PM INDEX NO. 2024-00063700
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/02/2024
determined by the Court and costs and disbursements in the
approximate amount of $700.00, and for such other and further
relief as to the Court may seem just and proper.
Dated: May 20, 2024
William M. Thomas ˆsq.
ASWAD& INGRAHAM, LLP
Attorneys for Plaintiff
Office and P.O. Address
46 Front Street
Binghamton, New York 13905
Tele.: 607-722-3495
3
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FILED: TIOGA COUNTY CLERK 07/02/2024 02:04 PM INDEX NO. 2024-00063700
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VERIFICATION OF COMPLAINT
STATE OF NEWYORK )
COUNTYOF BROOME ) ss.:
CHRISTOPHERALFARANO being duly sworn, did depose and say that
he is the Vice President/Chief Lending Officer of Visions
Federal Credit Union, the Corporation named in the within
action; that deponent has read the foregoing Complaint and knows
the contents thereof; and that the same is true to deponent's
own knowledge, except as to the matters therein stated to be
alleged on information and belief, and as to those matters
deponent believes it to be true. This verification is made by
deponent because Visions Federal Credit Union is a Federal
Credit Union. Deponent is an officer thereof, to-wit, its Vice
President/Chief Lending Officer. The grounds of deponent's
belief as to all matters not stated upon deponent's knowledge
are from review of the Credit Union files.
C ristophe Alfarano
Sworn to b fore e this
Da day f , 2024
Notary Public
CAROLPARISOT
Nofary Public - State
of New
No. York
OIPA6075430
Won, ua led inFioga
'm Emires County
June 3, 20
4
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FILED: TIOGA COUNTY CLERK 07/02/2024 02:04 PM INDEX NO. 2024-00063700
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/02/2024
VISIONS
F E D E RA L CRE D I T U N I ON
24 McKinley Ave " Endicott, NY 13760-5491 " 800.242.2120 " Fax 607.754.9772
January 30th, 2024
PAULM BALOGJR
255 FRONTSTREET
NY 13827
OWEGO,
Dear Member:
Re: Notification of Charge Off on Member # XXXXXX7100
This is to advise you that on 01130/2024 we formally charged off a total of $ 2 , 994 . 81 as an
unreimbursed loss due to one of the following action(s) associated with your Visions membership:
L 9 0 VISA PLATINUM
The charged off amount shown may not reflect any subsequent payments or charge offs after that date.
If the total of your unreimbursed loss(es) is $250.00 or more you are subject to possible expulsion from
Visions. The credit union may exercise its right to terminate services as outlined in the policy printed on
the reverse.
Visions may hold a special member meeting to take action on your membership under this policy. If held,
the meeting will be the third Wednesday of June. A notice announcing the meeting will be posted in the
Visions'
second quarter edition of financial magazine, which is available to all members on record.
If you do not have any other open loans, are not a co-signer on another member's loan, and wish
to close your membership, please complete the section below and return it in the envelope provided. If
you would like to take other action or discuss this further, please contact:
Employee: WILLIAM HEWITT Member Solutions Department, 800.242.2120 ext. 10270
Member Name: PAULM BALOGJR Member Number: XXXXXX7100
El Ido not have any open loan(s) nor am I a co-signer on any open, outstanding loan(s) on
another member's account. Please close my account now, and send any remaining
balance to which I may be legally entitled via check to the address listed on my account.
Member Signature: Date:
Detach and return this portion in the pre-addressed envelope provided.
MemberSolutions Department, 800.242.2120 ext. 10270 CODate: 01/30/2024
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FILED: TIOGA COUNTY CLERK 07/02/2024 02:04 PM INDEX NO. 2024-00063700
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/02/2024
Keep Por Your Records 24 McKinley Avenue 324848
Check No Endicott, NewYork 13760-5491 CARDNUMBER
(800) 242-2120 ..-- -. .- --- - - .
Check Amt: visionsfou.org
F DERALCRRD1T UNION
Date:
AMOUNT
OFPAYMENT
ENCLOSED
If u use a bill syln serv1ce,
ase use cre t car number
CLOSINGDATE, NEW
BALANCE MINIMUMPAYMENT PAYMENT DUEDATE
arromittances. 08/31/23 $2,966.76 $132.00 09/28/23 -
MAKEcHECKSPAYABLE TO:
It h"IllllH ll'lull' bl"' ' " ']
PAULMBALOGJR Visions Federal Credit Union
POBOX375 POBox 630685
OWEGONY13827 OH45283-0885
Cincinnati
454306599002292712D0013200002966769
PLEASERETURNTHIS PORTIONTO ENSURE
PROPER
CREDIT
24 McKinley Avenue
-----..
Endicott, NewYork 13760-5491
"°""-""'""°° T²fc²1'²°
STATEMENT
OF ACCOUNT Page 1 of 6
Account NumbÈr: 100 . edit CerdÑumber: XXXXXXXXXXXX
2712
Stateme t Perfÿcl 08/0U ` throughi8/ I/23 Å count escription: ID 90 VISA PLATINUM .
Preylo 5 issil ce $ 999.86 TotalNewBalance $2,966 76
Payrnents ; . $100;00 Minimum Payment Due $132.00
Other redits 40110 Payment Due Date '09/28/23
Purchases +$14ü5 Late Payment Warning; If we do not receive your minimum payment
Cash Advances . +$0.00 within 14 days of the date listed above, you will be assessed a late
Fees and Other Debits . . +$20.00 fee of $20 00.
Interest Charged 4$31.95 Minimum PaymentWarning: If you make only the minimum payment
Neƒ Balance $2,966.76 each period, you will pay moUèin Interest and it will take you longer to
example-
pay off your balance For
'
pus $73.00 4 If yð0 make-ho 'Arld
r efid upwopilJ
Past Arnount */þlly/illphy off the
Cre(lit Litnit $3,000,00 adÆttonal charges Osin! bÆlahde shóuffo& payirig
Available Credit $33.24 thfs barst and eqch tbts state(n4fit irl infestJntated s
Statement Date 08/31/2023 m0nth fou pay about total of...
Days in billing cycle S1 Only the minimum 14 years $5,552.00
Que5cions? 53,672 00
Contact Center: 800.242.2120 $102,00 3 Years
(Savings ± $1,880 00)
Lost pr Stolen Credit Card: 833,224,5785. If you would like Information about credit counseling services,
To access Rewards: 888.211438Ï Please call 1-877-277-4032.
Website: www.visionsfcu.org Send billing inquines and correspondence to.
24 McKinley Ave., Endloott, NY13760
Post Tran Reference Description Aniount
08/12 08/12 Visa Late Fee 2ÖdÖ0
08/31 See Fee SummaryBelow
08/23 08/23 15ayment Transfer From Share 08 -100.00
08/27 08/27 Recurring Purchase Bill Payment #323926106361 14.95
Audibl#T36QLOAIVl0. Amzn com/bill NJ
FEE.SUMMARY
Notice: See reverse side for important information.
NEWYORKRE91DENTSMAYCONTAC1T TO OBTAINA COMPARATIVELISTING OFCREDIT
TEíENEWŽO.R STATE.BANKINGDEPARTMENT
CARDRATES,FEESANDGRACEPERIQDS NEW YORKnTATEBANKNG DEPARTMENT
800.618.8866
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FILED: TIOGA COUNTY CLERK 07/02/2024 02:04 PM INDEX NO. 2024-00063700
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/02/2024
VISIONS ~450:-
VISloNS Federal C redit Unlon
FEDERALCREDITUNION V 8 oflSfCU.0IQ Account Number 100
Statement Period: 08/01/2023 thru 08/31/2023
Page 3 of 6
Post Tran Reference Description Amount
Date Description Amount
08/12 Visa Late Fee $20.00
TOTALFEES FORTHIS PERIOD $20.00
INTERESTCHARGED
Interest Charged on Purchases $31.95
Interest Charged on Cash Advances $0.00
TOTALINTERESTFORTHIS PERIOD $31.95
YEARTODATETOTALS
Total Fees Year to Date $40.00
Total Charged This Year
Interest $124.59
Your Annual Percentage Rate (APR) is the annual on your account
interest rate
BaTenie Subjgct to
Type of Balan-ce Annual Percenta eBate (APR) Interest Ratp iriterest Cha gé _
Purchases 13 000% (v) $2,893.58 $31.95
Cash Advances 13.000% $0.00 $0,00
(v) Variable rate
Total available points balance = 29,868
Points next to expire on 12/31/2024 = 17,255
For the rnost current point balance, or to request a redernption, the
"Rewards"
select option from your online banking
account at visionsfou.o or call 888.211.8384.
Credit card security matters. In addition to your credit card's
built-in protections and fraud monitoring, you can help us defend
against fraudsters and theft with these security tips:
-Only makeonline purchases from trusted, secure sites (https)
-Monitor your card in digital banking for any suspicious transactions
-Save our Fraud Monitoring short code (23618) in your phone's contacts
-Slgn up for Visa Purchase Alerts
For quidance with these tips and more, visit visionsfcu,org/security.
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FILED: TIOGA COUNTY CLERK 07/02/2024 02:04 PM INDEX NO. 2024-00063700
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/02/2024
Keep For Your Records 24 McKinley Avenue 324848
Check No: Endicott, NewYork 13760-5491 CARDNUMBER
(800) 242-2120
Check Amt: . visionsfcu.org
E EFIAL CREDIT UNION
Date:
AMOUNTOFPAYMENTENCLOSED
If you use a bill ayin
lease use cre t car
service
number
CLOSINGDATE NEWBALANCE MINIMUMPAYMENT AŽMˆNTDUEDATE
or remittances. 02/29/24 $2,994.81 $572.00 03/28/24
MAKECHECKSPAYABLE
TO:
PAUL MBALOGJR Visions Federal Credit Union
POBOX375 POBox 630685
OWEGONY13827 Cincinnati OH45263-0685
45430654400229271200057200002994818
PLEASE RETURNTHIS PORTIONTOENSURE
PROPERCREDIT
_.__________ ________._____ ___________----------------------- ----------------------------------------------------------- ---
OVS Endicott, NewYork 13760-5491
~="" ca- ""'"- 242-2 20
OF ACCOUNT
STATEMENT Page 1 of 6
Account Number: '100 Credit Card Number: XXXXXXXXXXXX2712
Staternent Period: 02/01/24 through 02/29/24 Account Description: ID 90 C/OVISA PLATINUM
Payment Information
Previous Balance $2,994.81 Total NewBalance $2,994.81 I
Payments -$0.00 Minimum Payment Due $572.00
Other Credits -$0.00 Payment Due Date 03/28/24
Purchases +$0.00 Late Payment Warning: If we do not receive your minimumpayment
Cash Advances +$0.00 within 14 days of the date listed above, you will be assessed a late
Fees and Other Debits +$0.00 fee of $20.00.
Interest Charged +$0.00 Minimum Payment Warning: If you make only the minimumpayment
NewBalance $2,994.81 each period, you will pay more in interest and it will take you longer to
pay off your balance. For example:
Past Due Amount $483.00 , If you make no You will pay off the And you will
Credit Limit $0.00 additional charges using balance shown on end up paying
Available Credit $0.00 this card and.each this statement in an estimated
Statement Date 02/29/2024 month you pay... about... total of...
Days in cycle 29 Only the minimum 6 years $2,994.00
billing
Questions?
Contact Center: 800.242.2120 $85.00 3 Years
(Sav s = $0.00)
Lost or Stolen Credit Card: 833.224.5785 Ifyou would like information about credit counseling services
To access Rewards: 888.211.8384 please call 1-877-277-4932.
Website: www.visionsfou.org Send billing inquiries and conespondence to:
24 McKinley Ave., Endicott, NY13760
Post Tran Reference Description Amount
No transactions this period
FEE SUMMARY
TOTALFEESFORTHIS PERIOD $0.00
Notice: See reverse side for Important Information.
NEWYORKRESIDENTSMAYCONTACT THENEWYORK TOOBTAINA COMPARATIVE
STATEBANKING DEPARTMENT LISTING OFCREDIT
CARDRATES, FEES ANDGRACE
PERIODS.NEWYORKSTATEBANKINGDEPARTMENT800.518.8866
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FILED: TIOGA COUNTY CLERK 07/02/2024 02:04 PM INDEX NO. 2024-00063700
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O
VISIONS Federal Credit Union
SVT 24 McKinley A venue
Endicott, New York 13760-5491
enamÄuniom v sionsfeu.org Account Number '100
Statement Period: 02/01/2024 thru 02/29/2024
Page 3 of 6
Post Tran Reference Description Amount
INTERESTCHARGED
Interest Charged on Purchases $0.00
Interest Charged on Cash Advances $0.00
TOTALINTERESTFORTHIS PERIOD $0.00
YEARTODATETOTALS
Total Fees Year to Date $0.00
Total Interest Charged This Year $0.00
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Balance Subject to
Type of Balance Annual Percentage Rate (APR) Interest Rate Interest Charge
Purchases 0.000% $2,906.12 $0.00
Cash Advances 0.000% $0.00 $0.00
(v)
= Variable rate
Whether you're aiming for a short-term yield or long-term investment,
it's hard to beat great reliable rates. Thats why we offer a variety
of Share Certificates and other savings accounts with flexible terms
and competitive rates. Visit visionsfcu.org/rates to compare our rates
and start savin toda .
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FILED: TIOGA COUNTY CLERK 07/02/2024 02:04 PM INDEX NO. 2024-00063700
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/02/2024
VISIONS
F E D E RA L CRE D T U N ON I I
APPLICATION
24 McKinley Ave. " Endicott, NY 13760-5491
There are coslS aSsociated with the use of a credit card. Information about costs, rates and fees may be contained in disclosures provided with this
application or by calling us tolbfree or collect at 1-800-242-2120 or writing to us at the address stated on this application.
Check below to indicate the type of credit for which you are applyIng. Married Applicants rnay apply for a separate account.
Individual Credit: You must complete the Applicant section about yourself and the Other section about your spouse if
1. you live in or the property pledged as collateral is located in a community property state (AK, AZ, CA, ID, LA, NM, NV, TX, WA,
WI)
2. your spouse will use the account, or
3. you are relying on your spouse's income as a basis for repayment. If you are relying on income from alimony, child support, or separate
maintenance, complete the Other section to the extent possible about the person on whose payments you are relying.
Joint Credit: Each Applicant must Individually complete appropriate section below. If Co-Borrower is spouse of the Applicant, mark the Co-Applicant
box.
LOANLINERAccount/Loan: O individual O Joint Credit Card Account: ¡ Individual O Joint
(Including ATM/Debit card access to the account if available)
If this is an application for joint credit, Applicant and Co-Applicant each agree and acknowledge the intent to apply for joint credit (sign below):
Applicant Date Co-Applicant Date
Amount Requested $
Purpose/Collateral:
B Credit Limit Requested $ 3,000.00
If Authorized User, Name:
Visa Platinurn /
PAYMENT
PROTECTION Are you interested in having your loan protected? OYES NO
If you answer "yes", the credit union will disclose the cost to protect your IMan. The protection is voluntary and does not affect your loan approval. In
order for your loan to be covered, you will need to sign a separate applicatio7 that explains the terms and conditions.
APPLICANT OTHER OCO-APPLICANT ¤ SPOUSE O GUARANTOR ¡ OTHER
NAME NAME
PAULM BALOGJR
Acmi miT NUMBER SOCIALSECURITYNUMBER ACCOUNT
NUMBER SOCIALSECURITYNUMBER
7100
BIRTH DATE tran. AuuMted BIRTH DATE EMAIL ADDRESS
PAULMBALOG@GMAIL.COM
HUME
PUUNE CELL PHONE BUSINESSPHONE/EXT. HOME
PHONE CELL PHONE BUSINESSPHONE/EXT.
(610) 653-4118 (610) 653-4118 (607)751-2000 0-
nmum· · ---
:SE NUMBER/STATE AGESOFDEPENDENTS DRIVER'SLICENSENUMBER/STATE AGESOFDEPENDENTS
PRESENT (Streal - CIty- State-Zip)
ADDRESS
190FRONTSTREET2NDFLREAR
¡ OWN RENT PRESENT (Street - City -State - Zip)