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`VS :|ATNEW LONDON
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`Bendett&McHugh,P.C.,270FarmingtonAvenue,Suite151,Farmington,CT06032«TEL(860)677-2868«TDD/TYYPLEASEFIRSTDIAL711
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`DOCKET NO: KNL-CV-20-6044311-S
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`NATIONSTAR MORTGAGELLC D/B/A MR.
`COOPER
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`SUPERIOR COURT
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`J.D, OF NEW LONDON
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`ALFIERO,SR., JOSEPH M. A/K/A ALFIERO,
`JOSEPH M., ET AL
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`CawAnh
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`WV
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`\4 7020
`‘
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`PRELIMINARY STATEMENT OF MONETARY CLAIM
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`Pursuant to Practice Book Section 23-18(b), the Plaintiff hereby sets forth its preliminary
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`statement of its monetary claim by the contents of the affidavit of debt, executed on February 12,
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`2020, of which a copy is attached as Exhibit A (from which personalidentification information
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`has been redacted per P.B. §4-7 when applicable).
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`These amounts are preliminary and are subject to change, correction, modification,
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`addition, reduction, deletion or amplification at the time of the hearing on Plaintiff's Motion for
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`JudgmentofStrict Foreclosure. The omission of any item of debt or a statement of an item in an
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`amountthat is less than the total amount owed on the subject mortgage loan is not and is not
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`NOTICE: THE LAW FIRM OF BENDETT & MCHUGH,P.C. IS A DEBT
`COLLECTOR AND IS ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION
`WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
`RECEIVED A DISCHARGE IN BANKRUPTCY WHICH DISCHARGED THIS DEBT,
`THIS CORRESPONDENCEIS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
`ATTEMPT TO COLLECTA DEBT, BUT ONLY ENFORCEMENTOF A LIEN
`AGAINST PROPERTY.
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`intended to be a waiver of any such items or amounts. Litigation costs, expenses and attorney's
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`fees are not included even though claimed and claimable pursuant to the terms of the promissory
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`note and mortgage that form the basis for this action.
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`THE PLAINTIFF,
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`By
`Ben gbVerRIBRAY.c,
`Its Attorneys
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`Bendett&McHugh,P.C.,270FarmingtonAvenue,Suite151,Farmington,CT06032*TEL(860)677-2868»TDD/TYYPLEASEFIRSTDIAL711
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`EXHIBIT A
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` VdTWIG.LSHLd
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`ASVATdAALIGCLL¢8982-LL9(098)TAL+Z¢090LD‘uoWuIUULY‘TCTING‘onUOAYToIuTUUEYO42“Og“YNEy yepusg
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`DOCKET NO: KNL-CV-20-6044311-S
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`; SUPERIOR COURT
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`NATIONSTAR MORTGAGELLC D/B/A MR.
`COOPER
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`J.D. OF NEW LONDON
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`VS.
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`: AT NEW LONDON
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`ALFIERO, SR., JOSEPH M. A/K/A ALFIERO,
`JOSEPH M. ET AL
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`AFFIDAVIT OF DEBT
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`STATE OF TEXAS
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`COUNTY OF DENTON
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`Talya Harris
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`;
`‘
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`, being duly sworn according to law, depose andsay:
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`ts
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`1.
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`Lam authorizedto sign this affidavit as a(n)PocumentExecution Associate of
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`Nationstar Mortgage LLC d/b/a Mr. Cooper(Nationstar).
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`2.
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`Nationstar maintains records for the loan that is secured by the mortgage being
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`foreclosed in this action. As part of my job responsibilities for Nationstar, | am familiar with the
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`type of records maintained by Nationstar in connection with the loan.
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`3.
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`I have personal knowledge of the facts in this affidavit based upon a review of
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`Nationstar's business records, and the information in this affidavit is taken from Nationstar's
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`business records. I have personal knowledge of Nationstar's procedures for creating the records
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`maintained by Nationstar in connection with the loan. They are: (a) made at or near the time of
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`the occurrence of the matters recorded by persons with personal knowledge ofthe information in
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`the business record, or from information transmitted by persons with personal knowledge; (b)
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`made and kept in the usual and ordinary course of Nationstar's regularly conducted business
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`activities; and (c) created by Nationstar as regular practice.
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`AFFIDAVIT OF DEBT
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`Page 1 of 3
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`4.
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`Nationstar Mortgage LLC d/b/a Mr. Cooperdirectly or through an agent, currently
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`has possession of the promissory note. The promissory note has been duly indorsed.
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`Bs
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`I have reviewedthe portion ofNationstar's business recordsthat reflect the amounts
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`due on the loan. They show Joseph M. Alfiero, Sr. a/k/a Joseph M. Alfiero defaulted, and the
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`business records show amounts due on the loan through February 04, 2020 are due and unpaid.
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`The amounts total $258,875.28 and consist of the following:
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`Unpaid Principal Balance:
`$202,632.01
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`Deferred Balance/Streamline Mods
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`Interest Total
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`from 05/01/2019 to 02/04/2020 @ 4.000%
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`Per diem at $22.21
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`$45,548.49
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`$6,145.58
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`Pre-acceleration Late Charges
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`Property Tax Advances
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`Hazard Insurance Advances
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`$0.00
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`$4,265.84
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`$249.51
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`MIP/PMI
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`Total Property Inspection Fees
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`Prior Foreclosure Fees
`$0.00 |
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`Other
`$0.00
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`$33.85
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`$0.00
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`Payment Advance- Principal/Interest/Escrow
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`Total:
`$258,875.28
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`AFFIDAVIT OF DEBT
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`Page 2 of 3
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`6.
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`It
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`is requested that this court take judicial notice that there are no setoffs or
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`counterclaims applicable to this loan.
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`Printed Name:
`_‘Talya Harris
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`Title:_Document Execution Associate
`Date:
`02/12/2020
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`Sworn to and subscribed before me on the day of_February12 , 2020 by
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`Talya Harris
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`|
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`(NOTARY SEAL)
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`Signature of Notary Public
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`am
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`i
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`Sores,
`APRIL HAWKINS
`Shi reeNotary Publié, State of Texas
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`ah!
`SoesaS Comm.Expires 06-25-2099)
`= ete oe
`A Notary iD 129470703
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`ay ag ma rnin,
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`AFFIDAVIT OF DEBT
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`Page 3 of 3
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`CERTIFICATION
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`I hereby certify that a copy of the above was mailed or electronically delivered on
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`\4 ‘ 20’ to all counsel and pro se parties of record and that written consent
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`for electronic/delivery was received from all counsel and prose parties of record who were
`electronically served, as follows:
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`NONE OF RECORD
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`Michelle L, Bibeau
`Commissioner of the Superior Court
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`Bendett&McHugh,P.C.,FarmingtonAvenue,Suite151,270Farmington,CT06032+TEL(860)677-2868»TDDFTYYPLEASEFIRSTDIAL711
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