On December 16, 2019 a
Party Statement
was filed
involving a dispute between
Reverse Mortgage Solutions, Inc,
and
Dennis Tucker,
Gwendolyn Robinson,
Karen Tucker,
Secretary Of Housing And Urban Development,
State Of Connecticut Department Of Administrative Services Representative Of The Estate Of Margaret Tucker,
State Of Connecticut Department Of Revenue Services,
State Of Connecticut, Judicial Branch,
The Widow,
Wanda Tucker,
for P00 - Property - Foreclosure
in the District Court of New Haven County.
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DOCKET NO.: NNH-CV20-6098978-S : SUPERIOR COURT
REVERSE MORTGAGE SOLUTIONS, INC : JUDICIAL DISTRICT OF
: NEW HAVEN
Vv.
: AT NEW HAVEN
THE WIDOW(ER), HEIRS, AND/OR CREDITORS : NOVEMBER. 8 2022
OF THE ESTATE OF MARGARET TUCKER, ET AL.
AFFIDAVIT OF ATTORNEY'S FEES
3. Davenport
of Hartford, Connecticut being duly swom, does hereby depose and say:
1. This affidavit is made on my own personal knowledge;
2. Jam over 18 years of age and competent to testify to the matters stated herein.
3. Tam employed by the Plaintiff's counsel in the above entitled action;
4, The following tasks were performed in connection with this matter:
a. Receipt and review of loan documents; opening of file; request for title examination; drafting of
correspondence to client.
b. Receipt and review of title examination; drafting of Complaint and Lis Pendens; research
regarding appropriate service addresses; preparation of Summons; correspondence to Marshal
with service instructions.
Request for and review of appraisal report of property and Affidavit of Appraiser.
Review of appearance status.
Drafting of Motion For Default for Failure to Appear
Drafting of Motion For Default for Failure to Appear — Publication
Drafting of Motion For Finding of No Further Notice Required
Preparation of Affidavit of Debt and correspondence to client regarding execution of same.
Drafting of Motion for Judgment of Strict Foreclosure; Preliminary Statement of Debt and Listing
of Law Days
Preparation of Affidavit of Attorney's Fees.
Preparation and review of file for short calendar.
Re-preparation of any necessary documents and attendance to the remote hearing (anticipated).
Dopo meas
ma
File: 21-03344CTm. Request for and review of title rundown to ensure no new IRS liens filed; preparation and drafting
of Certificate of Foreclosure and Motion for Deficiency Judgment; correspondence to Town
Clerk with recording instructions (anticipated).
OR
Prepare Fax Bid, Review Committee Deed and prepare Motion for Supplemental Judgment
(anticipated).
Based on the tasks performed in this case, together with previous court awards, Plaintiff's counsel
submits that the attorney's fee requested is reasonable under the circumstances.
Plaintiff respectfully requests an award of attorney's fees of $4,717.72 upon granting of Judgment of
Strict Foreclosure or an award of attomey's fees of $4,967.72 upon granting of a Judgment of Foreclosure
by Sale.
AS AOL ST
Wruuarn ». Davenpore
Affiant / Attorney
Date: November 3 2022
Subscribed and sworn to before me
3. he day of November, 2022
‘ofnmissjqney of Superior Court
B Erik Rarieko
PURSUANT TO FEDERAL LAW, THIS LAW FIRM IS A DEBT COLLECTOR.
WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE
IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS
DEBT, THIS COMMUNICATION IS NOT AN ATTEMPT TO COLLECT THE
DEBT AGAINST YOU PERSONALLY, BUT IS NOTICE OF A POSSIBLE
ENFORCEMENT OF THE LIEN AGAINST THE COLLATERAL PROPERTY.
File: 21-03344CT
Document Filed Date
November 04, 2022
Case Filing Date
December 16, 2019
Category
P00 - Property - Foreclosure
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DOCKET NO.: NNH-CV20-6098978-S : SUPERIOR COURT REVERSE MORTGAGE SOLUTIONS, INC : JUDICIAL DISTRICT OF : NEW HAVEN Vv. : AT NEW HAVEN THE WIDOW(ER), HEIRS, AND/OR CREDITORS : NOVEMBER. 8 2022 OF THE ESTATE OF MARGARET TUCKER, ET AL. AFFIDAVIT OF ATTORNEY'S FEES 3. Davenport of Hartford, Connecticut being duly swom, does hereby depose and say: 1. This affidavit is made on my own personal knowledge; 2. Jam over 18 years of age and competent to testify to the matters stated herein. 3. Tam employed by the Plaintiff's counsel in the above entitled action; 4, The following tasks were performed in connection with this matter: a. Receipt and review of loan documents; opening of file; request for title examination; drafting of correspondence to client. b. Receipt and review of title examination; drafting of Complaint and Lis Pendens; research regarding appropriate service addresses; preparation of Summons; correspondence to Marshal with service instructions. Request for and review of appraisal report of property and Affidavit of Appraiser. Review of appearance status. Drafting of Motion For Default for Failure to Appear Drafting of Motion For Default for Failure to Appear — Publication Drafting of Motion For Finding of No Further Notice Required Preparation of Affidavit of Debt and correspondence to client regarding execution of same. Drafting of Motion for Judgment of Strict Foreclosure; Preliminary Statement of Debt and Listing of Law Days Preparation of Affidavit of Attorney's Fees. Preparation and review of file for short calendar. Re-preparation of any necessary documents and attendance to the remote hearing (anticipated). Dopo meas ma File: 21-03344CTm. Request for and review of title rundown to ensure no new IRS liens filed; preparation and drafting of Certificate of Foreclosure and Motion for Deficiency Judgment; correspondence to Town Clerk with recording instructions (anticipated). OR Prepare Fax Bid, Review Committee Deed and prepare Motion for Supplemental Judgment (anticipated). Based on the tasks performed in this case, together with previous court awards, Plaintiff's counsel submits that the attorney's fee requested is reasonable under the circumstances. Plaintiff respectfully requests an award of attorney's fees of $4,717.72 upon granting of Judgment of Strict Foreclosure or an award of attomey's fees of $4,967.72 upon granting of a Judgment of Foreclosure by Sale. AS AOL ST Wruuarn ». Davenpore Affiant / Attorney Date: November 3 2022 Subscribed and sworn to before me 3. he day of November, 2022 ‘ofnmissjqney of Superior Court B Erik Rarieko PURSUANT TO FEDERAL LAW, THIS LAW FIRM IS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT, THIS COMMUNICATION IS NOT AN ATTEMPT TO COLLECT THE DEBT AGAINST YOU PERSONALLY, BUT IS NOTICE OF A POSSIBLE ENFORCEMENT OF THE LIEN AGAINST THE COLLATERAL PROPERTY. File: 21-03344CT