On April 18, 2022 a
Answer
was filed
involving a dispute between
The County Of Putnam,
and
for Special Proceedings - Other (Art 11 tax foreclosure)
in the District Court of Putnam County.
Preview
FILED:
To: Jeanne PUTNAM
Bruen COUNTYPage: 2 of 5CLERK2022-07-15
07/15/2022
13:34:46 GMT 02:51 PM
18008329150
INDEX NO. 500454/2022
From: Rural Law Center of New York, inc.
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 07/15/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF PUTNAM
IN THE MATTER OF FORECLOSURE OF TAX Index No. 500454/2022
LIENS BY PROCEEDING IN REM PURSUANT TO
ARTICLE ELEVEN OF THE REAL PROPERTY Consolidating Index No. 2302/2014
TAX LAW BY THE COUNTY OF PUTNAM and Index No. 2035/2015
AFFECTING PARCELS LOCATED IN THE TOWNS
OF CARMEL, KENT, PATTERSON, VERIFIED ANSWER
PHILLlPSTOWN, PUTNAM VALLEY AND
SOUTHEAST
Respondent JEANNE BRUEN, Pro Se, as and forher Verifted Answer with Affirmative
Defenses to Petitioner's Petition and Notice of Foreclosure respectfully alleges and shows to the
Court as follows:
1. Enters a general denial to allallegations contained in Petitioner's Petition and Notice of
Foreclosure.
AFFIRMATIVE DEFENSES
First Affirmative Defense
2. Petitioner's complaint fails to statea cause of action upon which reliefcan be granted.
Second Affirmative Defense
3. Petitioner has failed to mitigate itsdamages.
Third Affirmative Defense
4. Respondent has a defense based upon documentary evidence.
Fourth Affirmative Defense
5. Petitioner has not obtained personal jurisdiction over the Respondent.
Fifth Affirmative Defense
6. Petitioner's complaint violates the pleadings provision of the New York Real Property
Actions and Proceedings Law.
Sixth Affirmative Defense
7. Petitioner's complaint and causes of action are barred by the doctrine of estoppel.
1 of 3
FILED: PUTNAM
To: Jeanne Bruen COUNTYPage: 3 of 5CLERK2022-07-15
07/15/2022
13:34:46 GMT 02:51 PM
18008329150
INDEX NO. 500454/2022
From: Rural Law Center of New York, Inc.
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 07/15/2022
Seventh Affirmative Defense
8. Petitioner's cause of action may not be maintained because of payment.
WHEREFORE, Respondent, Jeanne Bruen, requests that this complaint be dismissed
in itsentirety and forsuch other and further reliefas to the Court may seem just and proper.
Dated: July /5~, 2022
Jeanne Bruen
CHL tYL A.ZASTENCHiK
Notary PuwicStateof New York
No. 01ZAG0984GG
Qualified
In Putnarg
Couniv
My Commission Expires 7
2 of 3
FILED:To: Jeanne PUTNAM
Bruen COUNTY CLERK 2022-07-15
Page: 4 of 5 07/15/2022
13:34:46 GMT 02:51 PM
18008329150 INDEX NO. 500454/2022
From: Rural Law Center of New York, Inc.
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 07/15/2022
VERIFICATION
STATE OF NEW YORK )
COUNTY OF PUTNAM ) :ss:
JEANNE BRUEN, being duly sworn, says that she is the Respondent in the above-named
proceeding and thatthe foregoing Answer istrue to her own knowledge, except as to matters
therein stated to be alleged on information and beliefand as to those matters she believes them to
be true.
canne ruen
Sworn to before me this day of
July, 2022.
CHERYL A.ZASTENCHiK
N Public Notary PuMic Stateof New York
ary
No. 01ZAGO984GG
in Putnam
Qualified County
- My Commission Expires
3 of 3
Document Filed Date
July 15, 2022
Case Filing Date
April 18, 2022
Category
Special Proceedings - Other (Art 11 tax foreclosure)
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Preview
FILED: To: Jeanne PUTNAM Bruen COUNTYPage: 2 of 5CLERK2022-07-15 07/15/2022 13:34:46 GMT 02:51 PM 18008329150 INDEX NO. 500454/2022 From: Rural Law Center of New York, inc. NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 07/15/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF PUTNAM IN THE MATTER OF FORECLOSURE OF TAX Index No. 500454/2022 LIENS BY PROCEEDING IN REM PURSUANT TO ARTICLE ELEVEN OF THE REAL PROPERTY Consolidating Index No. 2302/2014 TAX LAW BY THE COUNTY OF PUTNAM and Index No. 2035/2015 AFFECTING PARCELS LOCATED IN THE TOWNS OF CARMEL, KENT, PATTERSON, VERIFIED ANSWER PHILLlPSTOWN, PUTNAM VALLEY AND SOUTHEAST Respondent JEANNE BRUEN, Pro Se, as and forher Verifted Answer with Affirmative Defenses to Petitioner's Petition and Notice of Foreclosure respectfully alleges and shows to the Court as follows: 1. Enters a general denial to allallegations contained in Petitioner's Petition and Notice of Foreclosure. AFFIRMATIVE DEFENSES First Affirmative Defense 2. Petitioner's complaint fails to statea cause of action upon which reliefcan be granted. Second Affirmative Defense 3. Petitioner has failed to mitigate itsdamages. Third Affirmative Defense 4. Respondent has a defense based upon documentary evidence. Fourth Affirmative Defense 5. Petitioner has not obtained personal jurisdiction over the Respondent. Fifth Affirmative Defense 6. Petitioner's complaint violates the pleadings provision of the New York Real Property Actions and Proceedings Law. Sixth Affirmative Defense 7. Petitioner's complaint and causes of action are barred by the doctrine of estoppel. 1 of 3 FILED: PUTNAM To: Jeanne Bruen COUNTYPage: 3 of 5CLERK2022-07-15 07/15/2022 13:34:46 GMT 02:51 PM 18008329150 INDEX NO. 500454/2022 From: Rural Law Center of New York, Inc. NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 07/15/2022 Seventh Affirmative Defense 8. Petitioner's cause of action may not be maintained because of payment. WHEREFORE, Respondent, Jeanne Bruen, requests that this complaint be dismissed in itsentirety and forsuch other and further reliefas to the Court may seem just and proper. Dated: July /5~, 2022 Jeanne Bruen CHL tYL A.ZASTENCHiK Notary PuwicStateof New York No. 01ZAG0984GG Qualified In Putnarg Couniv My Commission Expires 7 2 of 3 FILED:To: Jeanne PUTNAM Bruen COUNTY CLERK 2022-07-15 Page: 4 of 5 07/15/2022 13:34:46 GMT 02:51 PM 18008329150 INDEX NO. 500454/2022 From: Rural Law Center of New York, Inc. NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 07/15/2022 VERIFICATION STATE OF NEW YORK ) COUNTY OF PUTNAM ) :ss: JEANNE BRUEN, being duly sworn, says that she is the Respondent in the above-named proceeding and thatthe foregoing Answer istrue to her own knowledge, except as to matters therein stated to be alleged on information and beliefand as to those matters she believes them to be true. canne ruen Sworn to before me this day of July, 2022. CHERYL A.ZASTENCHiK N Public Notary PuMic Stateof New York ary No. 01ZAGO984GG in Putnam Qualified County - My Commission Expires 3 of 3