MEMORANDUM OF LAW IN REPLY (Motion #001) - Laverne Leonard v. E Trade Bank, National City Bank N/K/A Pnc Financial Services Group, E Trade Financial Corporation

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On February 16, 2018 a real property - other (rpapl1501(4)-remove lien) case was filed by Laverne Leonard, represented by Lanin, Scott L, against E Trade Bank, E Trade Financial Corporation, and National City Bank N K A Pnc Financial Services Group, represented by Lax, Barry Richard, in the jurisdiction of New York County. Judge Robert D Kalish presiding.

                        
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                             FILED:         NEW     YORK       COUNTY        CLERK        04/24/2018             10:34        PM                 INDEX    NO.   151492/2018
   NYSCEF     DOC.   NO.   29                                                                                 RECEIVED      NYSCEF:     04/24/2018




                  SUPREME        COURT      OF   THE   STATE     OF  NEW     YORK
                  COUNTY       OF   NEW     YORK
                  -----------------------------------------------------------------------X
                  LAVERNE        LEONARD,
                                                                                                   Index   No.  151492/2018

                                                      Plaintiff,


                           -against-



                  NATIONAL        CITY    BANK     n/lda,
                  PNC    FINANCIAL        SERVICES      GROUP,      and
                  E*TRADE       FINANCIAL        CORPORATION,


            …