FILED: ULSTER COUNTY CLERK 03/03/2025 12:18 PM
`SUPREMECOURTOFTHESTATEOFNEWYORK
`NYSCEF DOC. NO. 29
`COUNTYOFULSTER
`HSBCBank USA, National Association
`Verified Reply to
`Plaintiff's
`as Trustee
`Corporation, Home Defendant's Answer, Affirmative
`For Wells Fargo Asset Securities
`Defenses and Potential Counterclaims
`Equity Asset-Backed Certificates,
`Series 2007-1
`
`INDEX NO. EF2024-2934
`
`RECEIVED NYSCEF: 03/03/2025
`
`-against-
`
`'
`
`Index Number: EF2024-2934
`
`Dana Marie
`John
`Smith, Workers
`T.
`Smith,
`Compensation Board of the State of New York, New
`York State Department
`of Taxation and Finance,
`Northern Dutchess Hospital
`and
`Valley
`Hospital,
`Vassar Brothers
`Healthalliance
`Hospital
`Hospital,
`Broadway Campus, Credit Acceptance Corporation,
`the State of New York, and "JOHN
`The People of
`DOE#1,"
`through "JOHNDOE#12,"
`the last
`twelve
`names being fictitious
`and unknown to plaintiff,
`the
`persons
`or
`intended
`the
`being
`parties
`tenants,
`occupants, persons or corporations,
`if any, having or
`lien upon the premises
`an interest
`in or
`claiming
`being foreclosed
`herein,
`
`Defendant(s).
`
`Plaintiff HSBCBank USA, National Association
`as Trustee For Wells Fargo Asset Securities
`Corporation, HomeEquity Asset-Backed Certificates,
`Sheldon May & Associates,
`Defenses and Potential Counterclaims (the "Answer"),
`
`Series 2007-1 ("Plaintiff")
`
`by its attorneys
`
`P.C., as and for
`
`its Verified Reply to the Defendant's Answer,
`
`Affirmative
`
`hereby states, upon
`
`information
`
`and belief,
`
`as follows:
`
`ASANDTODEFENDANT'SRESPONSE
`TOPLAINTIFF'S COMPLAINT
`Defendant's Answer contains
`
`a general denial
`
`of the allegations
`
`in the Complaint and/or
`
`1.
`
`legal
`
`conclusions
`
`to which no response is required;
`
`however,
`
`to the extent a response is deemed
`
`required,
`
`Plaintiff
`
`denies
`
`the
`
`allegations
`
`contained
`
`in the Answer, and respectfully
`
`refers
`
`all
`
`questions of law to the Court.
`
`ASANDTODEFENDANT'S
`AFFIRMATIVE DEFENSES
`
`2.
`
`Defendant's Answer contains
`
`affirmative
`
`defenses to Plaintiff's
`
`Complaint and/or
`
`legal
`
`conclusions
`
`to which no response is
`
`required;
`
`however,
`
`to the extent
`
`a response is
`
`required,
`
`1 of 10
`
`

`

`FILED: ULSTER COUNTY CLERK 03/03/2025 12:18 PM
`NYSCEF DOC. NO. 29
`
`Plaintiff
`
`denies the allegations
`
`contained
`
`in the Answer, and respectfully
`
`INDEX NO. EF2024-2934
`
`RECEIVED NYSCEF: 03/03/2025
`all questions of
`
`refers
`
`law to the Court.
`
`3.
`
`4.
`
`5.
`
`6.
`
`Plaintiff
`
`denies the allegations
`
`contained
`
`in the Defendant's First Affirmative
`
`Defense.
`
`Plaintiff
`
`denies the allegations
`
`contained
`
`in the Defendant's Second Affirmative
`
`Defense.
`
`Plaintiff
`
`denies the allegations
`
`contained
`
`in the Defendant's Third Affirmative
`
`Defense.
`
`Plaintiff
`
`denies, upon the ground that
`
`they lack knowledge or information
`
`sufficient
`
`to
`
`form a belief
`
`as to the truth
`
`thereof of each and every allegation
`
`contained
`
`in Defendant's Fourth
`
`Affirmative
`
`Defense.
`
`7.
`
`8.
`
`9.
`
`Plaintiff
`
`denies the allegations
`
`contained
`
`in the Defendant's Fifth Affirmative
`
`Defense.
`
`Plaintiff
`
`denies the allegations
`
`contained
`
`in the Defendant's Sixth Affirmative
`
`Defense.
`
`Plaintiff
`
`denies the allegations
`
`contained
`
`in the Defendant's Seventh Affirmative
`
`Defense.
`
`10.
`
`Plaintiff
`
`denies the allegations
`
`contained
`
`in the Defendant's Eighth Affirmative
`
`Defense.
`
`11.
`
`Plaintiff
`
`denies, upon the ground that
`
`they lack knowledge or infonnation
`
`sufficient
`
`to
`
`form a belief
`
`as to the truth
`
`thereof of each and every allegation
`
`contained
`
`in Defendant's Ninth
`
`Affirmative
`
`Defense.
`
`12.
`
`13.
`
`Plaintiff
`
`denies the allegations
`
`contained
`
`in the Defendant's Tenth Affirmative
`
`Defense.
`
`Plaintiff
`
`denies, upon the ground that
`
`they lack knowledge or information
`
`sufficient
`
`to
`
`form a belief
`
`as to the truth
`
`thereof of each and every
`
`allegation
`
`contained
`
`in Defendant's
`
`Eleventh Affirmative
`
`Defense.
`
`14.
`
`Plaintiff
`
`denies, upon the ground that
`
`they lack knowledge or information
`
`sufficient
`
`to
`
`form a belief
`
`as to the truth
`
`thereof
`
`of each and every
`
`allegation
`
`contained
`
`in Defendant's
`
`Twelfth Affirmative
`
`Defense.
`
`15.
`
`Plaintiff
`
`denies, upon the ground that
`
`they lack knowledge or information
`
`sufficient
`
`to
`
`form a belief
`
`as to the truth
`
`thereof of each and every
`
`allegation
`
`contained
`
`in Defendant's
`
`Thirteenth
`
`Affirmative
`
`Defense.
`
`2 of 10
`
`

`

`FILED: ULSTER COUNTY CLERK 03/03/2025 12:18 PM
`NYSCEF DOC. NO. 29
`REPLIESTOBORROWERS'
`COUNTERCLAIMS
`
`INDEX NO. EF2024-2934
`
`RECEIVED NYSCEF: 03/03/2025
`
`1.
`
`Plaintiff
`
`denies, upon the ground that
`
`they lack knowledge or information
`
`sufficient
`
`to
`
`form a belief
`
`as to the truth
`
`thereof of each and every allegation
`
`contained
`
`in Defendant's First
`
`Counterclaim.
`
`2.
`
`Plaintiff
`
`denies the allegations
`
`contained
`
`in Defendant's Second Counterclaim.
`
`PLAINTIFFS$
`AFFIRMATIVE DEFENSES
`
`3.
`
`4.
`
`The plaintiff
`
`incorporates
`
`all
`
`the allegations
`
`of its Complaint as if
`
`fully
`
`set
`
`forth
`
`herein.
`
`Plaintiff
`
`is the owner and holder of the subject
`
`note, mortgage and loan modification
`
`agreement (if applicable)
`
`being foreclosed upon in this action pursuant
`
`to all
`
`relevant Uniform
`
`Commercial Code provisions.
`
`5.
`
`6.
`
`Plaintiff
`
`is a holder
`
`is due course.
`
`The defendant's
`
`counterclaims
`
`fail
`
`to state a cause of action upon which relief maybe
`
`granted as against
`
`the Plaintiff.
`
`7.
`
`8.
`
`Plaintiff
`
`has a defense founded upon the documentary evidence.
`
`Defendant's Counterclaims are barred,
`
`in whole or in part, by the doctrines
`
`of collateral
`
`estoppel and/or
`
`res judicata.
`
`9.
`
`10.
`
`Defendant's Counterclaims are barred by the applicable
`in whole or in part, by his/her own breaches of the
`
`Defendant's Counterclaims are barred,
`
`statutes of limitations.
`
`terms and conditions
`
`of the subject
`
`note and mortgage,
`
`and/or his/her
`
`failure
`
`to comply with the
`
`terms and conditions
`
`of the agreements which form the basis of his/her Counterclaims.
`
`11.
`
`Defendant's Counterclaims
`
`are barred,
`
`in whole or in part, due to his/her
`
`failure
`
`to
`
`perform his/her
`
`obligations
`
`under the applicable
`
`agreements at
`
`issue in this action.
`
`12.
`
`Plaintiff
`
`has complied with all
`
`laws,
`
`statutes and regulations
`
`applicable
`
`to the claims
`
`as
`
`alleged in Defendant's Counterclaims.
`
`3 of 10
`
`

`

`FILED: ULSTER COUNTY CLERK 03/03/2025 12:18 PM
`NYSCEF DOC. NO. 29
`To the extent Defendant seeks or may seek equitable
`13.
`
`or injunctive
`
`INDEX NO. EF2024-2934
`
`RECEIVED NYSCEF: 03/03/2025
`claims
`his/her
`relief,
`
`are barred or limited,
`
`in whole or
`
`in part, by the existence of an adequate remedy at
`
`law.
`
`14.
`
`15.
`
`Plaintiff
`
`is not
`
`liable
`
`for
`
`the alleged acts committed by its assignors.
`
`Defendants'
`
`claims and damages, which Plaintiff
`
`expressly
`
`denies,
`
`are barred in whole or
`
`in part by the doctrines of waiver,
`Defendant's claims and damages, which are expressly denied, are barred by his/her own
`
`laches and estoppel.
`
`16,
`
`errors,
`
`17.
`
`fraudulent
`
`and/or deceptive
`
`omissions,
`Defendant's claims and damages, which are expressly denied, are due to his own
`
`conduct
`
`affirmative,
`
`wrongful,
`
`improper,
`
`unreasonable,
`
`fraudulent,
`
`illegal
`
`and inequitable
`
`conduct,
`
`breaches of duty,
`Defendants'
`
`18.
`
`lack of diligence,
`
`poor judgment, misconduct or omissions.
`
`claims and damages, which Plaintiff
`
`expressly
`
`denies,
`
`are barred by the
`
`doctrine of unclean hands.
`
`19.
`
`Defendants claims and damages, which are expressly denied, are barred by the doctrines
`
`of ratification,
`
`novation,
`
`agreement, mutual assent,
`
`voluntary
`
`payment, accord and satisfaction,
`
`assent, acquiescence
`
`and/or
`
`consent.
`
`20.
`
`Defendants claims and damages, which are expressly denied, are the result,
`
`in whole or
`
`in part,
`
`from intervening,
`
`superseding,
`
`affirmative,
`
`wrongful,
`
`improper,
`
`unreasonable,
`
`fraudulent,
`
`illegal
`
`and inequitable
`
`conduct, breaches of duty,
`
`lack of diligence,
`
`poor judgment,
`
`misconduct or omissions by other parties,
`
`persons or entities
`
`not under Plaintiff
`
`s control.
`
`21.
`
`Principles
`
`of equity warrant denial of the relief
`
`requested by Defendant
`
`in his
`
`Counterclaims.
`
`22.
`
`Defendant has not suffered
`
`any injury
`
`in fact or damages attributable
`
`to Plaintiffs
`
`alleged
`
`conduct.
`
`23.
`
`Defendants Counterclaims are barred,
`
`in whole or
`
`in part, because he has not suffered
`
`actual,
`
`cognizable
`
`injury
`
`as a result of Plaintiffs
`
`alleged conduct.
`
`4 of 10
`
`

`

`FILED: ULSTER COUNTY CLERK 03/03/2025 12:18 PM
`NYSCEF DOC. NO. 29
`RECEIVED NYSCEF: 03/03/2025
`Defendants Counterclaims are bared,
`in whole or in part, because the injury(ies)
`alleged
`24.
`
`INDEX NO. EF2024-2934
`
`is(are)
`
`not
`
`the type addressed by the laws under which Defendant purports
`
`to bring his/her
`
`claims
`
`against Plaintiff.
`
`25.
`
`Defendants claims and damages, which are expressly
`
`denied, are barred,
`
`in whole or in
`
`part, because their
`
`alleged injuries/damages,
`
`if any, which are expressly
`
`denied, are too
`
`speculative,
`
`uncertain,
`
`derivative,
`
`indirect
`
`and/or
`
`remote.
`
`26.
`
`Defendant has failed
`
`to mitigate
`
`his alleged damages.
`
`27.
`
`Defendants Counterclaims are barred,
`predecessors' and assignors')
`
`in whole or in part, by Plaintiffs
`
`(and/or
`
`its
`
`compliance with, and otherwise
`
`lack of violation
`
`of, all
`
`laws,
`
`statutes and regulations
`
`applicable
`
`to the claims alleged in Defendants Counterclaims
`
`28.
`
`At all
`
`relevant
`
`times, Plaintiff
`
`s alleged conduct was in good faith and complied with the
`
`rules and regulations
`
`of, and the statutes
`
`administered
`
`by the official
`
`department,
`
`division,
`
`commission and/or agency of the United States as such rules,
`
`regulations
`
`or statutes
`
`are
`
`interpreted
`
`by such department,
`
`division,
`
`commission or agency or the courts.
`
`29.
`
`Defendant will be unjustly
`
`enriched
`
`if he/she is granted the relief
`
`sough in his
`
`Counterclaims.
`
`30.
`
`31.
`
`Defendant has failed
`
`to allege
`
`fraud or misrepresentation
`
`with the requisite
`
`particularity.
`
`Defendant has failed
`
`to allege
`
`fraudulent
`
`intent on the part of Plaintiff
`
`or Defendants
`
`own detrimental
`
`reliance.
`
`32.
`
`Defendant has failed
`
`to plead his claims with requisite
`
`particularity
`
`or state in detail
`
`the
`
`alleged wrongs upon which Defendants Counterclaims are based.
`
`33.
`
`Defendant has failed
`
`to allege
`
`the manner in which Plaintiffs
`
`alleged conduct was illegal
`
`and/or deceptive.
`
`Defendant's Counterclaims
`34.
`predecessors' and assignors')
`
`are barred,
`
`in whole or in part, by Plaintiffs
`
`(and/or
`
`its
`
`compliance with,
`
`and otherwise
`
`lack of violation
`
`of, all applicable
`
`5 of 10
`
`

`

`FILED: ULSTER COUNTY CLERK 03/03/2025 12:18 PM
`RECEIVED NYSCEF: 03/03/2025
`NYSCEF DOC. NO. 29
`of the Fair Credit Reporting Act, and Plaintiff
`pleads each and every defense
`provisions
`
`INDEX NO. EF2024-2934
`
`permitted
`
`by statute.
`
`35.
`
`Plaintiff
`
`maintains
`
`an absolute defense to Defendant's Counterclaims based upon
`
`documentary evidence.
`
`36.
`
`Defendant's Counterclaims and defenses are barred by the terms of the subject note,
`
`mortgage and/or
`
`loan modification
`
`agreement.
`
`37.
`
`Plaintiff
`
`reserves the right
`
`to assert and rely upon such other and further
`
`defenses to
`
`Defendants Counterclaims as maybe supported by the facts
`
`to be determined by full and
`
`complete discovery.
`
`Defendants'
`
`38.
`
`claims and damages, which Plaintiff
`
`expressly
`
`denies,
`
`are barred by the
`
`doctrines
`
`of ratification,
`
`novation,
`
`agreement, mutual assent,
`
`voluntary
`
`payment, accord and
`
`satisfaction,
`
`assent, acquiescence
`
`and/or
`
`consent.
`
`39.
`
`Defendant has not suffered any injury
`
`in fact or damagesattributable
`
`to Plaintiff's
`
`alleged
`
`conduct.
`
`40.
`
`Defendants' Counterclaims are barred,
`
`in whole or in part, because his alleged injuries
`
`are not
`
`the type addressed by the laws under which Defendant purports
`
`to bring his claims
`
`against Plaintiff.
`
`41.
`
`Defendants'
`
`claims and damages, which Plaintiff
`
`expressly
`
`denies,
`
`are barred,
`
`in whole
`
`or in part, because his/her
`
`alleged injuries/damages,
`
`if any, which Plaintiff
`
`expressly
`
`denies,
`
`are
`
`too speculative,
`
`uncertain,
`
`derivative,
`
`indirect
`
`and/or
`
`remote.
`
`42.
`
`43.
`
`Defendant has failed
`
`to mitigate
`
`his/her
`
`damages.
`
`Defendants'
`
`Counterclaims
`
`are barred,
`
`in whole or in part, by Plaintiff's
`
`(and/or
`
`its
`
`predecessor's
`
`and assignor's)
`
`statutes and regulations
`
`applicable
`
`compliance with, and otherwise
`to the claims alleged in Defendants'
`
`lack of violation
`
`of, all
`
`laws,
`
`Counterclaims.
`
`44.
`
`Defendants' Counterclaims are barred,
`
`in whole or in part, by Plaintiff's
`
`(and/or
`
`its
`
`predecessor's
`
`and assignor's)
`
`compliance with, and otherwise
`
`lack of violation
`
`of, all applicable
`
`6 of 10
`
`

`

`FILED: ULSTER COUNTY CLERK 03/03/2025 12:18 PM
`NYSCEF DOC. NO. 29
`of the Truth in Lending Act and Regulation
`Z, and Plaintiff
`provisions
`
`INDEX NO. EF2024-2934
`
`RECEIVED NYSCEF: 03/03/2025
`pleads each and every
`
`defense permitted
`
`by statute.
`
`45.
`
`At all
`
`relevant
`
`times, Plaintiff's
`
`alleged conduct was in good faith and complied with the
`
`rules and regulations
`
`of, and the statutes
`
`administrated
`
`by the official
`
`department,
`
`division,
`
`commission and/or agency of the United States as such rules,
`
`regulations
`
`or statutes
`
`are
`
`interpreted
`
`by such department,
`
`division,
`
`commission or agency or the courts.
`
`46.
`
`Defendant's claims and defenses are barred by the doctrine of unjust enrichment.
`
`47.
`
`Plaintiff
`
`to assert and rely upon such other and further
`reserves the right
`Defendants' Counterclaims as maybe supported by the facts
`
`defenses to
`
`to be determined by full and
`
`complete discovery.
`
`48.
`
`Plaintiff
`
`is not
`
`liable
`
`for any alleged wrongdoing committed by such nonparty loan
`
`servicers, mortgage brokers or real estate brokers and, as such, all necessary parties
`
`have not
`
`been joined
`
`in this action.
`
`49.
`
`50.
`
`That the Plaintiff
`
`asserts
`
`all affirmative
`
`defenses available
`
`pursuant
`
`to CPLR§3018(b).
`
`Plaintiff
`
`is not
`
`liable,
`
`vicariously
`
`or otherwise,
`
`for
`
`the alleged fraudulent
`
`acts of any of
`
`the defendants
`
`in this action, nor are the alleged acts and/or knowledge of any of the defendants
`
`imputable
`
`to the plaintiff.
`
`51.
`
`To the extent
`
`the Defendant's counterclaims may be seeking relief
`
`against
`
`the plaintiff
`
`based on fraud or other wrongful conduct,
`required under CPLR3016(b).
`
`particularity
`
`the Defendant has failed
`
`to plead such claims with the
`
`52.
`
`Whatever damages were sustained at
`
`the times and places alleged in the Defendant's
`
`counterclaims were not caused by any fraudulent
`
`or tortious
`
`conduct on the part of the plaintiff,
`
`but were caused solely by the fraudulent
`somethird party or parties
`
`conduct, negligence
`
`or carelessness
`
`of the Defendant or
`
`over whom, or conduct over which,
`
`the plaintiff was not obligated
`
`to
`
`exercise
`
`any control or supervision.
`
`7 of 10
`
`

`

`FILED: ULSTER COUNTY CLERK 03/03/2025 12:18 PM
`NYSCEF DOC. NO. 29
`Defendant's counterclaims
`53.
`
`are barred by estoppel,
`
`waiver,
`
`ratification,
`
`INDEX NO. EF2024-2934
`
`RECEIVED NYSCEF: 03/03/2025
`consent,
`laches,
`
`accord and satisfaction,
`assumption of risk, unjust enrichment,
`payment,
`release,
`and by the Defendant's own culpable conduct.
`
`unclean hands
`
`54.
`
`55.
`
`56.
`
`Defendant
`
`lacks standing and/or capacity
`
`to assert one or more of her counterclaims.
`
`Defendant's counterclaims
`
`are premature.
`
`Defendant's execution of the note and mortgage evidences Defendant's knowledge,
`
`understanding
`
`and agreement to be bound in accordance with its content.
`
`57.
`
`Thus, if Defendant has sustained any damages, such damages were not
`
`the proximate
`
`result of any conduct on the part of Plaintiff,
`
`but
`
`rather a result of Defendant's
`
`own carelessness,
`
`negligence,
`
`disregard of his/her
`
`contractual
`
`obligations
`
`to Plaintiff,
`
`and failure
`
`to act
`
`in his/her
`
`best
`
`interests
`
`or otherwise
`
`58.
`
`Defendant's damages claims
`
`abide by the terms of the note and mortgage.
`of TILA and RESPAare barred by the
`
`stating
`
`violations
`
`applicable one-year statute of limitations.
`
`59.
`
`The counterclaims
`
`are barred in whole, or in part, by the equitable
`
`doctrines of estoppel,
`
`ladies, waiver and unclean hands.
`
`WHEREFORE,Plaintiff
`(a) That Borrowers'
`requests the following:
`respectfully
`(b) That Borrowers' Affirmative
`Counterclaims be dismissed with prejudice;
`Defenses be
`dismissed with prejudice;
`(c) That Plaintiff
`be awarded fees and costs; and (d) That Plaintiff
`in the mortgaged premises as maybe just and equitable.
`such other and further
`relief
`
`have
`
`Dated: March 3, 2025
`Centre, NewYork
`Rockville
`
`Yours, etcT7
`Sheldon)ffy & Asso infes, PA
`
`,
`
`By: Jordan Slavens, Esq
`Attorney for Plaintiff
`255 Merrick Road
`Centre, NewYork 11570
`(516) 763-3200
`
`Rockville
`
`8 of 10
`
`

`

`FILED: ULSTER COUNTY CLERK 03/03/2025 12:18 PM
`NYSCEF DOC. NO. 29
`VERIFICATION
`
`INDEX NO. EF2024-2934
`
`RECEIVED NYSCEF: 03/03/2025
`
`STATEOFNEWYORK )
`COUNTYOFNASSAU
`
`)
`
`) ss:
`
`Jordan Slavens,
`
`the undersigned,
`
`an attorney
`
`duly admitted
`
`to practice
`
`before the Courts
`
`respectfully
`
`of this State,
`shows:
`That he is a member of the law firm of Sheldon May& Associates,
`in the above entitled
`record for
`the plaintiff
`
`action.
`
`P.C.,
`
`the attorney
`
`of
`
`Verified Reply and knows the contents thereof,
`That he has read the foregoing
`same is true to affiant's ownknowledge, except as to those matters therein
`
`stated
`
`and the
`
`to be alleged
`
`upon information
`
`and belief,
`
`and as to those matters believes
`
`them to be true.
`
`The grounds of affiant's
`
`belief
`
`as to all matters not stated upon affiant's
`
`knowledge are
`
`based upon the records of plaintiff
`
`in affiant's
`
`possession.
`
`The reason that
`
`this verification
`
`is madeby the undersigned and not by the Plaintiff
`
`is
`
`because Plaintiff
`
`is domiciled
`
`outside Nassau County;
`
`that being the County in which your
`
`affiant maintains
`
`an office
`
`for
`
`the practice
`
`of law.
`
`The undersigned
`
`affirms
`
`that
`
`the foregoing
`
`statements
`
`are true under penalty of perjury.
`
`Dated: March 3, 2025
`Centre, NewYork
`Rockville
`
`ü6rdan Slavens, Esq.
`
`9 of 10
`
`

`

`FILED: ULSTER COUNTY CLERK 03/03/2025 12:18 PM
`RECEIVED NYSCEF: 03/03/2025
`NYSCEF DOC. NO. 29
`SUPREMECOURT
`STATEOFNEWYORK, COUNTYOFULSTER
`Index NumberEF2024-2934
`HSBCBank USA, National Association
`Corporation, HomeEquity
`as Trustee For Wells Fargo Asset Securities
`Asset-Backed Certificates,
`Series 2007-1
`Plaintiff(s),
`
`INDEX NO. EF2024-2934
`
`-against-
`
`John T. Smith, Dana Marie Smith, Workers Compensation Board of
`the State of New York, New York State
`Department
`of Taxation and Finance, Valley Hospital,
`Northern Dutchess Hospital and Vassar Brothers Hospital,
`Healthalliance Hospital Broadway Campus, Credit Acceptance Corporation, The People of the State of NewYork,
`and "JOHNDOE#1,"
`through "JOHN DOE#12,"
`twelve names being fictitious
`and unknown to plaintiff,
`the last
`the persons or parties
`intended being the tenants,
`occupants, persons or corporations,
`if any, having or claiming an
`lien upon the premises being foreclosed herein,
`interest
`in or
`Defendant(s).
`Verified Reply to Affinnative Defenses and Counterclaims
`Sheldon May& Associates,
`P.C.
`Attorneys
`for Plaintiff
`Office and Post Office Address
`255 Merrick Road
`Centre, NewYork 11570
`Telephone Number
`(516) 763 - 3200
`
`Rockville
`
`To:
`
`Signatu efursya
`
`o ule
`
`3
`
`fint Name: Jordan Slavens, Esq.
`
`Service of a copy of the
`within
`is hereby admitted.
`
`Dated:
`
`Attorney(s)
`for:
`PLEASETAKENOTICE:
`o NOTICEOFENTRY
`is a (certified)
`true copy of a
`that
`the within
`named court on
`,200
`«NOTICEOFSETTLEMENT
`of which the within
`that an order
`is a true copy will be presented
`one of the judges of the within named court,
`on
`200
`at
`
`Duly entered in the office of the clerk of the within
`
`for settlement
`.M.
`at
`
`to the Honorable
`
`Dated:
`
`Yours, etc.
`Sheldon May &Associates,
`P.C.
`255 Merrick Road
`Centre, NewYork 11570
`(516) 763 - 3200
`
`Rockville
`
`10 of 10
`
`