Order to Show Cause: Federal National Mortgage Association ("FANNIE MAE"), A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE UNITED STATES OF AMERICA v. Glen Wakeford, Ellen Grace Wakefield, Lora H Hover As Trustee Of The Jacob F Hoffman & Nettie Hoffman Trust, John Doe
On December 15, 2017 a
Order to Show Cause
was filed
involving a dispute between
Federal National Mortgage Association,
and
Ellen Grace Wakefield,
Glen Wakeford,
John Doe,
Lora H Hover As Trustee Of The Jacob F Hoffman & Nettie Hoffman Trust,
for Real Property - Mortgage Foreclosure - Residential
in the District Court of Westchester County.
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FILED: WESTCHESTER COUNTY CLERK 10/04/2018 04:49 PM INDEX NO. 70537/2017
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 10/04/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WESTCHESTER
________________________________________X
FEDERAL NATIONAL MORTGAGE
ASSOCIATION,
Plaintiff, Index No. 70537/2017
vs
GLEN WAKEFORD AND ELLEN GRACE AFFIRMATION IN SUPPORT OF
WAKEFORD, ORDER TO SHOW CAUSE
Defendants.
________________________________________X
NATASHA MERUELO, Esq. makes the following Affirmation in Reply to Plaintiff’s
Opposition to Defendant’s Motion seeking an Order Dismissing the case pursuant to CPLR
3211(a)(7) and 3211(a)(10):
1. Federal National Mortgage Association (“Plaintiff”) commenced this foreclosure
action on December 15, 2017 by the filing of a summons and complaint. A true and
correct copy of the Summons and Complaint is attached as Ex. A.
2. Defendant’s Answer with Affirmative Defenses, and Counter-Claims is attached as
Ex. B.
3. Plaintiff’s Opposition to Defendant’s Motion to Dismiss is attached as Ex. C.
4. A true and correct copy of the quiet title complaint filed on behalf of the Plaintiff on
August 28, 2018 reflecting a different party as the Noteholder is attached as Ex. D.
5. A true and correct copy of Plaintiff’s Affirmation in Support of Motion for
Discontinuance of Action and Cancellation of Notice of Pendency is attached as Ex.
E.
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FILED: WESTCHESTER COUNTY CLERK 10/04/2018 04:49 PM INDEX NO. 70537/2017
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 10/04/2018
6. The stipulation dated April 27, 2018, whereby Plaintiff discontinued the action only
as to Defendant, Lora H. Hover as Trustee of the Jacob F. Hoffman and Nettie
Hoffman Trust. A true and correct copy of the stipulation of discontinuance filed with
the Court is attached as Ex. F.
7. A memorandum of law in further support is being filed with this Affirmation.
Dated: October 4, 2018
White Plains, NY
!
________________________
Natasha Meruelo, Esq.
Attorney for Defendant, Glen Wakeford
99 Church Street, 4th Floor, Suite 401
White Plains, NY 10601
t: (914) 517-7565
f: (914) 613-0875
meruelolaw@gmail.com
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FILED: WESTCHESTER COUNTY CLERK 10/04/2018 04:49 PM INDEX NO. 70537/2017 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 10/04/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF WESTCHESTER ________________________________________X FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff, Index No. 70537/2017 vs GLEN WAKEFORD AND ELLEN GRACE AFFIRMATION IN SUPPORT OF WAKEFORD, ORDER TO SHOW CAUSE Defendants. ________________________________________X NATASHA MERUELO, Esq. makes the following Affirmation in Reply to Plaintiff’s Opposition to Defendant’s Motion seeking an Order Dismissing the case pursuant to CPLR 3211(a)(7) and 3211(a)(10): 1. Federal National Mortgage Association (“Plaintiff”) commenced this foreclosure action on December 15, 2017 by the filing of a summons and complaint. A true and correct copy of the Summons and Complaint is attached as Ex. A. 2. Defendant’s Answer with Affirmative Defenses, and Counter-Claims is attached as Ex. B. 3. Plaintiff’s Opposition to Defendant’s Motion to Dismiss is attached as Ex. C. 4. A true and correct copy of the quiet title complaint filed on behalf of the Plaintiff on August 28, 2018 reflecting a different party as the Noteholder is attached as Ex. D. 5. A true and correct copy of Plaintiff’s Affirmation in Support of Motion for Discontinuance of Action and Cancellation of Notice of Pendency is attached as Ex. E. 1 of 2 FILED: WESTCHESTER COUNTY CLERK 10/04/2018 04:49 PM INDEX NO. 70537/2017 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 10/04/2018 6. The stipulation dated April 27, 2018, whereby Plaintiff discontinued the action only as to Defendant, Lora H. Hover as Trustee of the Jacob F. Hoffman and Nettie Hoffman Trust. A true and correct copy of the stipulation of discontinuance filed with the Court is attached as Ex. F. 7. A memorandum of law in further support is being filed with this Affirmation. Dated: October 4, 2018 White Plains, NY ! ________________________ Natasha Meruelo, Esq. Attorney for Defendant, Glen Wakeford 99 Church Street, 4th Floor, Suite 401 White Plains, NY 10601 t: (914) 517-7565 f: (914) 613-0875 meruelolaw@gmail.com 2 of 2