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DOCKET NO.: AAN-CV-18-6027492-S
`
`: SUPERIOR COURT
`
`NEW PENN FINANCIAL, LLC D/B/A SHELLPOINT
`MORTGAGESERVICING
`
`: JUDICIAL DISTRICT OF
`: ANSONIA/MILFORD
`
`V.
`
`> AT MILFORD
`
`ESTATE OF CHARLES R ZUCHINSKYC/O ITS FIDUCIARY : OCTOBER 22, 2019
`LAURIE A ZUCHINSKY, ET AL.
`
`MOTION TO CITE IN PARTY DEFENDANT
`
`Pursuant to Sections 9-18 and 9-22 of the Rules of Practice, the Plaintiff moves to cite in Brian P
`
`Zuchinskyas a party defendant in this action. The said party claims aninterest in this matter by virtue of
`
`holding an interest the property located at, and knownas 330 Savin Ave, West Haven, CT, whichis the
`
`subject of this action.
`
`The Plaintiff, New Penn Financial, LLC d/b/a Shellpoint Mortgage Servicing, commencedthis
`
`underlying foreclosure action with a Complaint, dated March 6, 2018, bearing a Return Date of
`
`April 24, 2018. On or about April 8, 2019 the Plaintiff filed a Motion to Cite Brian P Zuchinsky, heir of
`
`the deceased ownerof the Property, Charles R Zuchinsky, which was granted by the court on May 21,
`
`2019.
`
`On May31, 2019, State Marshal John T Fiorillo made a service to CT Secretary of State at 30
`
`Trinity Street, Hartford, CT and via Certified Mail to 707 Medina Ct, Saint Augustine, FL 32086.
`
`File: 016959F01
`
`

`

`Asof today, State Marshal John T Fiorillo did not receive a confirmationof receipt of said
`
`service, and USPS Tracking History states that the item is out for delivery in Florida since June 7, 2019.
`
`It is likely that said proofof delivery is lost in transition.
`
`Our most recent research confirmed that Defendant Brian P. Zuchinskystill resides at 707
`
`Medina Ct, Saint Augustine, FL 32086 and service should be madeat that address.
`
`SlyWN
`
`
`
`McCalla Raymer Leibert Pierce, LLC
`50 Weston Street
`Hartford, CT 06120
`860-808-0606
`Its Attorneys
`Juris No. 101589
`
`Emily t. McConnell
`
`ORAL ARGUMENT REQUESTED
`TESTIMONY NOT REQUIRED
`
`File: 016959F01
`
`

`

`The foregoing motion having been presented to the Court, and it appearing that the same should
`
`ORDER
`
`be granted,it is hereby:
`
`ORDERED,that on or before
`
`, the Plaintiff summonssaid Brian P
`
`Zuchinsky of 707 Medina Ct, Saint Augustine, FL 32086 to appear as a defendant in this action on or
`
`before the second day following
`
`, 2019 by causing some properofficer to serve on
`
`it, a true andattested copy of this order, a true and attested copy of the complaint in this action, and a
`
`Summons-Civil Form, and due return make.
`
`GRANTED/DENIED
`
`BY THE COURT
`
`
`
`Judge/Clerk
`
`File: 016959F01
`
`

`

`CERTIFICATION
`
`I hereby certify that a copy of the above was mailed or electronically delivered on October 22,
`
`2019 to all counsel and self-represented parties of record and that written consent for electronic delivery
`
`wasreceived from all counsel and self-represented parties of record who wereelectronically served:
`
`Law Office of Earle Giovanniello
`office@eglaw1.com
`
`Marinosci Law Group, PC
`jsimbaqueva@mlg-defaultlaw.com
`
` Attorney for the Plaintiff
`
`PURSUANTTO FEDERAL LAW,THIS LAW FIRM IS A DEBT
`COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY
`INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
`HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A
`BANKRUPTCY DISCHARGEOF THIS DEBT, THIS COMMUNICATIONIS
`NOT AN ATTEMPT TO COLLECT THE DEBT AGAINST YOU
`PERSONALLY, BUT IS NOTICE OF A POSSIBLE ENFORCEMENT OF THE
`LIEN AGAINST THE COLLATERAL PROPERTY.
`
`File: 016959F01
`
`

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