Preview
FILED: ALBANY COUNTY CLERK 09/20/2022 05:15 PM INDEX NO. 907054-22
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/20/2022
STATE OF NEW YORK
ALBANY COUNTY SUPREME COURT
COUNTY OF WESTCHESTER
Present: Hon.
Justice of the Supreme Court Index/Docket No. INDEX
CPLR Article 78 Proceeding
-In the Matter of the Application of-
VERIFIED PETITION
DEBORAH VERONICA GREY (Maiden
TO OBTAIN
Name: MASSARO) VITAL RECORDS
Petitioner UNDER
- Against - PUBLIC HEALTH LAW
§§4173 - 4174
Mary T. Bassett, M.D. M.P.N.,
AND
the Commissioner,
New York State Department of Health
COMPLAINT FOR DECLARATORY
Corning Tower
RELIEF (OATS)
Empire State Plaza
Albany, NY 12237
Respondent
NUMBER
TO THE COURT:
PARTIES TO THIS ACTION AND STANDING
Petitioner, Deborah Veronica Grey (Maiden Name: Massaro), through this verified
petition, respectfully shows to this Court as follows:
1) Petitioner resides at 5352 Venus Terrace, Port Charlotte, Florida, 33981.
Attached as Exhibit A isa copy of Petitioner's Driver's License and Exhibit B is a copy of
Petitioner's U.S. Passport.
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2) The Respondent is the Commissioner of the New York State Department of
Health, having itsprincipal office at Corning Tower, Empire State Plaza, Albany, New York,
12237, which principal office is located in the County of Albany, State of New York.
Respondent's office is solely responsible for the issuance, creation, amendment and
production of vital records for the State of New York, the subject matter of this proceeding.
3) Petitioner attests that she is the granddaughter of Domenico Massaro.
4) Petitioner attests that she is the daughter of Fiorentino Massaro (aka
Ferondino Massaro, Fiore Massaro, Fiore D. Massaro, Fiore Dominick Massaro, Frank
Massaro and Frank Massaro, Sr.); who is the son of Domenico Massaro (aka Dominick
Massaro) and Maria Massaro (aka Maria Della Peruta, Peruto, Pruto) by birth. Attached as
Exhibit V isa copy of Petitioner's birth certificate.
5) Petitioner intends to apply to the Republic of Italy for recognition of Italian
origin and citizenship through the civil law doctrine of jure sanguinis (the "IS Procedure")
as the lineal descendant of her grandfather, Domenico Massaro, born July 2, 1899, in Italy
(Commune di Moiano, Provincia di Benevento, Campania) through her father, Fiorentino
(Fiore) Massaro, born on September 19, 1925, in White Plains, New York.
To prove Petitioner's legal entitlement to Italian citizenship under the JS Procedure,
Petitioner must include in her submission to the Republic of Italy long-form, certified
signed and sealed copies of the birth certificate for her father, Fiorentino Massaro.
Attached as Exhibit C is a copy of the applicable JS Procedure rules from the website for the
Consulate General of Italy, Citizenship Office, 4000 Ponce de Leon Boulevard, Suite 590,
Coral Gables, FL 33146 (https://consmiami.esteri.it/consolato miami/en/) ("Miami
Consulate"). with Italian Consulate directives, documentary evidence is
Complying
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requested to be presented to the Miami Consulate in June 2023 that will demonstrate
Petitioner's right of Italian citizenship through her paternal line. Documents submitted
must comply with the directives as promulgated under the of the Italian
authority
Consulate:
These rules state the requirements for Petitioner's application for recognition and
dual citizenship to the Republic of Italy to include that all certificates must be presented in
form' form' copy'
the original or in an authenticated copy, i.e.'long or 'full or 'book
indicating the city of birth (certifications or extracts will not be accepted). Certificates
Country"
showing only the "County / State / of birth cannot be accepted. These forms
must be obtained from the registrars of the state (not the City or County) where the birth
took place.
copy" form" "
" All certificates must be in original or a "certified a.k.a. or full
"long
form" copy" ("certifications" "abstracts"
or "book or will not be accepted). Such forms
can be obtained from the Vital Records Office of the State in which the
birth/marriage/death took place. You must request the Office of Vital Records to
indicate in the certificate the city of birth.
"Country/State/County"
Certificates reporting only the of birth cannot be accepted.
" Double-check allforeigner documents word by word to make sure that there are n_o
discrepancies or mismatches in names, last names, dates and places of birth. If there
are major discrepancies in such fields, you must have those certificates amended
through an official "affidavit to amend a record", to be obtained from the Vital Records
Office that issued the document or through a competent Court Order.
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PETITIONER'S FATHER'S BIRTH CERTIFICATE.
6). PHL § 4173(2) states that the Commissioner of Public Health may issue
only
to Petitioner birth certificates for her father, Fiorentino Massaro, order of this Court, as
by
Petitioner's father is deceased. Attached as Exhibit K isa copy of father's death certificate.
7). For purposes of Petitioner's application for recognition of Italian origin and
Italian citizenship under the JS Procedure, per the aforementioned rules, Petitioner must obtain
and present to the Miami Consulate two (2) certified extended long form copies of (a) the New
York State (not City or County) birth record, signed with seal affixed, for Petitioner's father,
born in White Plains, New York, on September 19, 1925. Attached as Exhibit D is a copy of
father's birth certificate.
6) In addition, the certification procedure requires that all vital records (Birth, Death
and Marriage/Exhibits D, K,G) of Petitioner and ascendants, must have the same name, initials
and be presented to the Miami Consulate.
Orders"
7) Petitioner further requires Declaratory Relief via "One and the Same
indicating the following per the attached Complaint for Declaratory Relief:
a) Petitioner's father, Fiore Massaro, is one and the same as Fiorentino
Massaro per attached copies of Exhibits D - K. Fiorentino Massaro (Exhibit D-Birth Certificate,
Exhibit E-1942 Application for Social Ferondino Massaro (Exhibit H - 1930
Security Card);
Census); Fiore Dominick Massaro (Exhibit I-Registration Draft Card); Fiore Massaro (Exhibit G
- 1947 Marriage Certificate, Exhibit J - 1962 Death Certificate of wife); Fiore D. Massaro
(Exhibit V - 1951 Birth Certificate of Frank Massaro (Exhibit F-2009 Death per
daughter);
Social and Frank Sr. (Exhibits K - 2009 Death Certificate).
Security Register); Massaro,
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b) Petitioner's grandfather, Domenico Massaro, is one and the same as
Dominick Massaro per attached copies of the following Exhibits: Domenico Massaro (Exhibit N
- - N1
Birth Certificate); Domenico Massaro (Exhibit D 1925 son's birth certificate and Exhibit
N2 - -
and Ship manifesto from 1913 arriving from Italy); Domenic Massaro (Exhibit H 1930
Domenico Massaro (Exhibit P - Marriage Dominick Massaro Exhibit G
Census); Certificate); (
- 1947 son's marriage Domenico Massaro -
certificate; (Exhibit P 1920 Marriage certificate);
and Dominick Massaro (Exhibit O - Death certificate).
c) Petitioner's grandmother, Maria Massaro, is one and the same as Marie
Massaro, Maria Della Peruta, Maria Peruta, Maria Peruto, and Maria Pruto per the attached
- S2 -
copies of the following Exhibits: Maria Della Peruto (Exhibit S Birth Certificate, Exhibit
1920 manifest of arrival in Maria Peruta (Exhibit P - 1920 Marriage
Ship USA); Certificate,
Exhibit O- husband's death Maria Peruto (Exhibit D - 1925 son's birth
certificate); certificate);
Marie Massaro (Exhibit H - 1930 and Maria Massaro (Exhibit T - death certificate).
Census);
d) Petitioner's mother, Milagro Ventura, is one and the same as Milagro
Ventura Llorens and Milagro Massaro per copies of the following Exhibits: Milagro Ventura
Llorens (Exhibit L- Birth Certificate); Milagro Ventura (Exhibit G -marriage certificate);
Milagro Massaro (J - Death and Milagro Ventura (Exhibits V- Petitioner's birth
Certificate);
certificate).
e) Petitioner, Deborah Veronica Grey, is one and the same as Deborah
Massaro, Deborah Veronica Massaro, Deborah V. Massaro, Deborah Veronica Grey, Deborah V.
Grey, Deborah V Calo per copies of the following Exhibits: Deborah Massaro (Exhibit V-birth
Deborah Veronica Massaro (Exhibit X - 1973 marriage certificate to Michael
certificate); Calo);
Y- 1977 divorce from Michael Deborah Veronica Massaro -
Deborah V. Calo (Exhibit Calo);
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(Exhibit Z - 1981 marriage certificate to -
Darryl C. Grey); Deborah Veronica Grey (Exhibit aa
1997 Divorce certificate).
8) In support of the request for correction, the Petitioner attaches hereto as Exhibits,
copies of all relevant documents showing Petitioner's right to win this case. These documents
are:
Exhibits Person Document Type Proof of
A Petitioner Driver License Petitioner Name
B Petitioner Passport Petitioner Name
C Petitioner J.S. Procedural Rules Italian Consulate
requirements
D Petitioner's Birth Certificate issued Birth name & Name of
Father by City parents
E Petitioner's Social Security Social Security #
Father Application 1942 and
121-16-1995
letter from SS
F Petitioner's Social Security Death Social Security #
Father Register 2009
121-16-1995
G Petitioner's Marriage Certificate Name
Father
H Petitioner's 1930 Census Names and
Grandfather, Proof GF did not naturalize
Grandmother,
Names of children
Father
H1 Petitioner's 1920 Census Name
Grandfather
H2 Petitioner's 1925 Census Names
Grandfather, Names of children
Grandmother
H3 Petitioner's 1940 Census Names
Grandmother, Names of children
Father
I Petitioner's Draft Card Name
Father
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J Petitioner's Death Certificate of Name
Father Wife
K Petitioner's Death Certificate Name
Father
L Petitioner's Birth Certificate Name
Mother
M Petitioner's Ship Manifest from Name
Grandfather 1913 arriving in USA
N Petitioner's Birth Certificate Name & Date of Birth
Grandfather
O Petitioner's Death Certificate Name
Grandfather
P Petitioner's Marriage Certificate Name
Grandfather
Q Petitioner's USCIS Gen 10180297 No Naturalization
Grandfather
R Petitioner's Westchester County No Naturalization
Grandfather Archives
S Petitioner's Birth Certificate Name & Date of Birth
Grandmother
S2
S1 and Petitioner's Ship Manifesto Name
Grandmother
Arrival in USA
Petitioner'
T Death Certificate Name
Grandmother
U Petitioner's Certificate Naturalization
Grandmother
V Petitioner Birth Certificate Name
W Petitioner Baptismal Certificate Name
X Petitioner Marriage #1 Certificate Name
Y Petitioner Divorce #1 Certificate Name
Z Petitioner Marriage #2 Certificate Name
Z1 Petitioner Divorce #2 Certificate Name
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REPRESENTATIONS TO COURT
9) Petitioner represents to this Court and to Respondent that she will use all
New York State vital records delivered to her pursuant to this solely to
proceeding satisfy
the legal and factual requirements for the JS Procedure.
10) Petitioner has not made a prior application for the relief sought.
11) Petitioner represents that she will discharge allstatutory fees payable under
the PHL for the creation, issuance, production and release of each of the requisite records.
WHEREFORE, your deponent prays and respectfully petitions that this court grants
petitioner's application within fifteen (15) days of service of the Court Order upon the
respondent as follows:
1. pursuant to PHL §§4173 through 4174, subject to payment by Petitioner of
applicable fees and completion of applicable documentation, to create or issue, produce
and deliver to Petitioner two (2) long-form, certified signed and sealed copies of the (a)
birth certificate for Petitioner's father, Fiorentino Massaro and two (2) One and the Same
Orders for Fiorentino (Fiore, Fiore D, Fiore Domenic, Frank, Frank Sr.) Massaro. For this
legal and proper purpose, the issuance of a certified transcript of such records in place of a
certified copy thereof shall not be sufficient (PHL §4174(1)(0]; and
2. One and the same Orders per the attached Complaint for Declaratory Relief
of all other parties in the aforementioned Petition; and
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3. such other and further relief as the Court may determine to be just, proper
and equitable in this matter.
Birth Certificate of: FIORENTINO MASSARO (one and the same as Ferondino
Date of Birth: Massaro, Fiore Massaro, Fiore D. Massaro, Fiore
Dominick Massaro, Frank Massaro, Frank Massaro Sr.)
Place of Birth
09/19/1925
Father:
WHITE PLAINS, New York
Full Maiden Name of Mother:
DOMENICO MASSARO
MARIA DELLA PERUTA
Name: DEBORAH V. (MASSARO) GREY
Address: 5352 VENUS TERRACE
PORT CHARLOTTE, FL 33981
Telephone: +1 (727) 686-3157
Deborah V. (Massaro) Grey
STATE OF FLORIDA
COUNTY OF CHARLOTTE
The foregoing instrument was acknowledged before me this _1D. day of 9pt 2022,
by Deborah V. Grey.
Known ___ OR Production Identification
Personally
Type of Identification Produced FL DL
f rida Signatur Notary Public-State of
Notary
Spies OW12 025
Florida My Commissbn
Commission No. HH 90040
(NOTARY Name o Notary Typed, Printed, or
SEAL)
Stamped
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Preview
FILED: ALBANY COUNTY CLERK 09/20/2022 05:15 PM INDEX NO. 907054-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/20/2022 STATE OF NEW YORK ALBANY COUNTY SUPREME COURT COUNTY OF WESTCHESTER Present: Hon. Justice of the Supreme Court Index/Docket No. INDEX CPLR Article 78 Proceeding -In the Matter of the Application of- VERIFIED PETITION DEBORAH VERONICA GREY (Maiden TO OBTAIN Name: MASSARO) VITAL RECORDS Petitioner UNDER - Against - PUBLIC HEALTH LAW §§4173 - 4174 Mary T. Bassett, M.D. M.P.N., AND the Commissioner, New York State Department of Health COMPLAINT FOR DECLARATORY Corning Tower RELIEF (OATS) Empire State Plaza Albany, NY 12237 Respondent NUMBER TO THE COURT: PARTIES TO THIS ACTION AND STANDING Petitioner, Deborah Veronica Grey (Maiden Name: Massaro), through this verified petition, respectfully shows to this Court as follows: 1) Petitioner resides at 5352 Venus Terrace, Port Charlotte, Florida, 33981. Attached as Exhibit A isa copy of Petitioner's Driver's License and Exhibit B is a copy of Petitioner's U.S. Passport. 1 1 of 9 FILED: ALBANY COUNTY CLERK 09/20/2022 05:15 PM INDEX NO. 907054-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/20/2022 2) The Respondent is the Commissioner of the New York State Department of Health, having itsprincipal office at Corning Tower, Empire State Plaza, Albany, New York, 12237, which principal office is located in the County of Albany, State of New York. Respondent's office is solely responsible for the issuance, creation, amendment and production of vital records for the State of New York, the subject matter of this proceeding. 3) Petitioner attests that she is the granddaughter of Domenico Massaro. 4) Petitioner attests that she is the daughter of Fiorentino Massaro (aka Ferondino Massaro, Fiore Massaro, Fiore D. Massaro, Fiore Dominick Massaro, Frank Massaro and Frank Massaro, Sr.); who is the son of Domenico Massaro (aka Dominick Massaro) and Maria Massaro (aka Maria Della Peruta, Peruto, Pruto) by birth. Attached as Exhibit V isa copy of Petitioner's birth certificate. 5) Petitioner intends to apply to the Republic of Italy for recognition of Italian origin and citizenship through the civil law doctrine of jure sanguinis (the "IS Procedure") as the lineal descendant of her grandfather, Domenico Massaro, born July 2, 1899, in Italy (Commune di Moiano, Provincia di Benevento, Campania) through her father, Fiorentino (Fiore) Massaro, born on September 19, 1925, in White Plains, New York. To prove Petitioner's legal entitlement to Italian citizenship under the JS Procedure, Petitioner must include in her submission to the Republic of Italy long-form, certified signed and sealed copies of the birth certificate for her father, Fiorentino Massaro. Attached as Exhibit C is a copy of the applicable JS Procedure rules from the website for the Consulate General of Italy, Citizenship Office, 4000 Ponce de Leon Boulevard, Suite 590, Coral Gables, FL 33146 (https://consmiami.esteri.it/consolato miami/en/) ("Miami Consulate"). with Italian Consulate directives, documentary evidence is Complying 2 2 of 9 FILED: ALBANY COUNTY CLERK 09/20/2022 05:15 PM INDEX NO. 907054-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/20/2022 requested to be presented to the Miami Consulate in June 2023 that will demonstrate Petitioner's right of Italian citizenship through her paternal line. Documents submitted must comply with the directives as promulgated under the of the Italian authority Consulate: These rules state the requirements for Petitioner's application for recognition and dual citizenship to the Republic of Italy to include that all certificates must be presented in form' form' copy' the original or in an authenticated copy, i.e.'long or 'full or 'book indicating the city of birth (certifications or extracts will not be accepted). Certificates Country" showing only the "County / State / of birth cannot be accepted. These forms must be obtained from the registrars of the state (not the City or County) where the birth took place. copy" form" " " All certificates must be in original or a "certified a.k.a. or full "long form" copy" ("certifications" "abstracts" or "book or will not be accepted). Such forms can be obtained from the Vital Records Office of the State in which the birth/marriage/death took place. You must request the Office of Vital Records to indicate in the certificate the city of birth. "Country/State/County" Certificates reporting only the of birth cannot be accepted. " Double-check allforeigner documents word by word to make sure that there are n_o discrepancies or mismatches in names, last names, dates and places of birth. If there are major discrepancies in such fields, you must have those certificates amended through an official "affidavit to amend a record", to be obtained from the Vital Records Office that issued the document or through a competent Court Order. 3 3 of 9 FILED: ALBANY COUNTY CLERK 09/20/2022 05:15 PM INDEX NO. 907054-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/20/2022 PETITIONER'S FATHER'S BIRTH CERTIFICATE. 6). PHL § 4173(2) states that the Commissioner of Public Health may issue only to Petitioner birth certificates for her father, Fiorentino Massaro, order of this Court, as by Petitioner's father is deceased. Attached as Exhibit K isa copy of father's death certificate. 7). For purposes of Petitioner's application for recognition of Italian origin and Italian citizenship under the JS Procedure, per the aforementioned rules, Petitioner must obtain and present to the Miami Consulate two (2) certified extended long form copies of (a) the New York State (not City or County) birth record, signed with seal affixed, for Petitioner's father, born in White Plains, New York, on September 19, 1925. Attached as Exhibit D is a copy of father's birth certificate. 6) In addition, the certification procedure requires that all vital records (Birth, Death and Marriage/Exhibits D, K,G) of Petitioner and ascendants, must have the same name, initials and be presented to the Miami Consulate. Orders" 7) Petitioner further requires Declaratory Relief via "One and the Same indicating the following per the attached Complaint for Declaratory Relief: a) Petitioner's father, Fiore Massaro, is one and the same as Fiorentino Massaro per attached copies of Exhibits D - K. Fiorentino Massaro (Exhibit D-Birth Certificate, Exhibit E-1942 Application for Social Ferondino Massaro (Exhibit H - 1930 Security Card); Census); Fiore Dominick Massaro (Exhibit I-Registration Draft Card); Fiore Massaro (Exhibit G - 1947 Marriage Certificate, Exhibit J - 1962 Death Certificate of wife); Fiore D. Massaro (Exhibit V - 1951 Birth Certificate of Frank Massaro (Exhibit F-2009 Death per daughter); Social and Frank Sr. (Exhibits K - 2009 Death Certificate). Security Register); Massaro, 4 4 of 9 FILED: ALBANY COUNTY CLERK 09/20/2022 05:15 PM INDEX NO. 907054-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/20/2022 b) Petitioner's grandfather, Domenico Massaro, is one and the same as Dominick Massaro per attached copies of the following Exhibits: Domenico Massaro (Exhibit N - - N1 Birth Certificate); Domenico Massaro (Exhibit D 1925 son's birth certificate and Exhibit N2 - - and Ship manifesto from 1913 arriving from Italy); Domenic Massaro (Exhibit H 1930 Domenico Massaro (Exhibit P - Marriage Dominick Massaro Exhibit G Census); Certificate); ( - 1947 son's marriage Domenico Massaro - certificate; (Exhibit P 1920 Marriage certificate); and Dominick Massaro (Exhibit O - Death certificate). c) Petitioner's grandmother, Maria Massaro, is one and the same as Marie Massaro, Maria Della Peruta, Maria Peruta, Maria Peruto, and Maria Pruto per the attached - S2 - copies of the following Exhibits: Maria Della Peruto (Exhibit S Birth Certificate, Exhibit 1920 manifest of arrival in Maria Peruta (Exhibit P - 1920 Marriage Ship USA); Certificate, Exhibit O- husband's death Maria Peruto (Exhibit D - 1925 son's birth certificate); certificate); Marie Massaro (Exhibit H - 1930 and Maria Massaro (Exhibit T - death certificate). Census); d) Petitioner's mother, Milagro Ventura, is one and the same as Milagro Ventura Llorens and Milagro Massaro per copies of the following Exhibits: Milagro Ventura Llorens (Exhibit L- Birth Certificate); Milagro Ventura (Exhibit G -marriage certificate); Milagro Massaro (J - Death and Milagro Ventura (Exhibits V- Petitioner's birth Certificate); certificate). e) Petitioner, Deborah Veronica Grey, is one and the same as Deborah Massaro, Deborah Veronica Massaro, Deborah V. Massaro, Deborah Veronica Grey, Deborah V. Grey, Deborah V Calo per copies of the following Exhibits: Deborah Massaro (Exhibit V-birth Deborah Veronica Massaro (Exhibit X - 1973 marriage certificate to Michael certificate); Calo); Y- 1977 divorce from Michael Deborah Veronica Massaro - Deborah V. Calo (Exhibit Calo); 5 5 of 9 FILED: ALBANY COUNTY CLERK 09/20/2022 05:15 PM INDEX NO. 907054-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/20/2022 (Exhibit Z - 1981 marriage certificate to - Darryl C. Grey); Deborah Veronica Grey (Exhibit aa 1997 Divorce certificate). 8) In support of the request for correction, the Petitioner attaches hereto as Exhibits, copies of all relevant documents showing Petitioner's right to win this case. These documents are: Exhibits Person Document Type Proof of A Petitioner Driver License Petitioner Name B Petitioner Passport Petitioner Name C Petitioner J.S. Procedural Rules Italian Consulate requirements D Petitioner's Birth Certificate issued Birth name & Name of Father by City parents E Petitioner's Social Security Social Security # Father Application 1942 and 121-16-1995 letter from SS F Petitioner's Social Security Death Social Security # Father Register 2009 121-16-1995 G Petitioner's Marriage Certificate Name Father H Petitioner's 1930 Census Names and Grandfather, Proof GF did not naturalize Grandmother, Names of children Father H1 Petitioner's 1920 Census Name Grandfather H2 Petitioner's 1925 Census Names Grandfather, Names of children Grandmother H3 Petitioner's 1940 Census Names Grandmother, Names of children Father I Petitioner's Draft Card Name Father 6 6 of 9 FILED: ALBANY COUNTY CLERK 09/20/2022 05:15 PM INDEX NO. 907054-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/20/2022 J Petitioner's Death Certificate of Name Father Wife K Petitioner's Death Certificate Name Father L Petitioner's Birth Certificate Name Mother M Petitioner's Ship Manifest from Name Grandfather 1913 arriving in USA N Petitioner's Birth Certificate Name & Date of Birth Grandfather O Petitioner's Death Certificate Name Grandfather P Petitioner's Marriage Certificate Name Grandfather Q Petitioner's USCIS Gen 10180297 No Naturalization Grandfather R Petitioner's Westchester County No Naturalization Grandfather Archives S Petitioner's Birth Certificate Name & Date of Birth Grandmother S2 S1 and Petitioner's Ship Manifesto Name Grandmother Arrival in USA Petitioner' T Death Certificate Name Grandmother U Petitioner's Certificate Naturalization Grandmother V Petitioner Birth Certificate Name W Petitioner Baptismal Certificate Name X Petitioner Marriage #1 Certificate Name Y Petitioner Divorce #1 Certificate Name Z Petitioner Marriage #2 Certificate Name Z1 Petitioner Divorce #2 Certificate Name 7 7 of 9 FILED: ALBANY COUNTY CLERK 09/20/2022 05:15 PM INDEX NO. 907054-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/20/2022 REPRESENTATIONS TO COURT 9) Petitioner represents to this Court and to Respondent that she will use all New York State vital records delivered to her pursuant to this solely to proceeding satisfy the legal and factual requirements for the JS Procedure. 10) Petitioner has not made a prior application for the relief sought. 11) Petitioner represents that she will discharge allstatutory fees payable under the PHL for the creation, issuance, production and release of each of the requisite records. WHEREFORE, your deponent prays and respectfully petitions that this court grants petitioner's application within fifteen (15) days of service of the Court Order upon the respondent as follows: 1. pursuant to PHL §§4173 through 4174, subject to payment by Petitioner of applicable fees and completion of applicable documentation, to create or issue, produce and deliver to Petitioner two (2) long-form, certified signed and sealed copies of the (a) birth certificate for Petitioner's father, Fiorentino Massaro and two (2) One and the Same Orders for Fiorentino (Fiore, Fiore D, Fiore Domenic, Frank, Frank Sr.) Massaro. For this legal and proper purpose, the issuance of a certified transcript of such records in place of a certified copy thereof shall not be sufficient (PHL §4174(1)(0]; and 2. One and the same Orders per the attached Complaint for Declaratory Relief of all other parties in the aforementioned Petition; and 8 8 of 9 FILED: ALBANY COUNTY CLERK 09/20/2022 05:15 PM INDEX NO. 907054-22 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/20/2022 3. such other and further relief as the Court may determine to be just, proper and equitable in this matter. Birth Certificate of: FIORENTINO MASSARO (one and the same as Ferondino Date of Birth: Massaro, Fiore Massaro, Fiore D. Massaro, Fiore Dominick Massaro, Frank Massaro, Frank Massaro Sr.) Place of Birth 09/19/1925 Father: WHITE PLAINS, New York Full Maiden Name of Mother: DOMENICO MASSARO MARIA DELLA PERUTA Name: DEBORAH V. (MASSARO) GREY Address: 5352 VENUS TERRACE PORT CHARLOTTE, FL 33981 Telephone: +1 (727) 686-3157 Deborah V. (Massaro) Grey STATE OF FLORIDA COUNTY OF CHARLOTTE The foregoing instrument was acknowledged before me this _1D. day of 9pt 2022, by Deborah V. Grey. Known ___ OR Production Identification Personally Type of Identification Produced FL DL f rida Signatur Notary Public-State of Notary Spies OW12 025 Florida My Commissbn Commission No. HH 90040 (NOTARY Name o Notary Typed, Printed, or SEAL) Stamped 9 9 of 9