On August 12, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Deutsche Bank National Trust Company, As Trustee Under The Pooling And Servicing Agreement Relating To Impac Secured Assets Corp., Mortgage Pass-Through Certificates, Series 2006-1,
and
James Frederick,
John Doe
1-John Doe 12 The Last Twelve Names Being Fictitious And Unknown To Plaintiff,The Persons Or Parties Intended Being The Tenants, Occupants, Persons Or Corps, If Any, Having Or Claiming An Interest In Or Lien Upon The Subject Property, Described In The Com,
New York City Environmental Control Board,
New York City Parking Violations Bureau,
New York City Transit Adjucation Bureau,
for Real Property - Mortgage Foreclosure - Residential
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 11/18/2022 05:41 PM INDEX NO. 520498/2021
NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 11/18/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------------------------------------------------------------------X
DEUTSCHE BANK NATIONAL TRUST COMPANY AS
TRUSTEE UNDER THE POOLING AND SERVICING
AGREEMENT RELATED TO IMPAC SECURED ASSETS
CORP., MORTGAGE PASS-THROUGH CERTIFICATES
SERIES 2006-1, NOTICE OF MOTION
Plaintiff,
-against- Index No: 520498/2021
JAMES FREDERICK, et al.,
Defendants.
--------------------------------------------------------------------------------X
SIRS:
PLEAST TAKE NOTICE, that upon the annexed affirmation of Angelyn D. Johnson, Esq.,
dated November 17, 2022, and upon all pleadings and prior proceedings heretofore had herein,
the undersigned, will moved this Supreme Court, County of Kings, located at the County
Courthouse, at 360 Adams Street, Brooklyn, NY 11201, at motion part thereof, before the Hon. Larry
Martin, J.S.C., on the 15thth day of December, 2022 at 9:30 o’clock in the forenoon or as soon
thereafter as counsel can be heard, for an order: (a) pursuant to CPLR 2221 to reargue the Court’s
Decision and Order, entered on October 19, 2022 and for such other and further relief as may be
just and proper.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR §2214(b) answering affidavits, if any,
are required to be served upon the undersigned at least seven (7) days before the return date of
this motion.
Dated: November 17, 2022
Brooklyn, NY
Yours, etc.,
____________________________________________
ANGELYN D. JOHNSON & ASSOCIATES, LLC
By: Angelyn D. Johnson, Esq.
Attorneys for Defendant Santos Argueta
26 Court Street, Suite 2610
Brooklyn, NY 11242
(718) 875-2145
ajohnson@adj-law.com
1 of 2
FILED: KINGS COUNTY CLERK 11/18/2022 05:41 PM INDEX NO. 520498/2021
NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 11/18/2022
ANGELYN JOHNSON & ASSOCIATES
SUPREME COURT OF THE CITY OF NEW YORK
COUNTY OF KINGS INDEX NO.: 520498/2021
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT RELATING TO IMPAC SECURED ASSETS CORP., MORTGAGE PASS-
THROUGH CERTIFICATES, SERIES 2006-1
Plaintiff,
-against-
JAMES FREDERICK; NEW YORK CITY ENVIRONMENTAL CONTROL BOARD; NEW YORK CITY
PARKING VIOLATIONS BUREAU; NEW YORK CITY TRANSIT ADJUDICATION BUREAU,
“JOHN DOE #1” through “JOHN DOE #2,” the last twelve names being fictitious and
unknow to plaintiff, the persons or parties intended being the tenants, occupants,
persons or corporations, if any, having or claiming an interest in or lien upon the Subject
Property described in the Complaint,
Defendant.
NOTICE FOR MOTION
ANGELYN JOHNSON & ASSOCIATES
Attorney(s) for Defendant James Frederick
Office Address & Tel. No.:
26 Court Street, Suite 2610
Brooklyn, New York 11242
(718) 875-2145 (Office)
(516) 395-6902 (Cell)
ajohnson@adj-law.com
ADMISSION OF SERVICE CERTIFICATION PURSUANT
The undersigned acknowledges to Rule 130-1, 1-a
receipt of a copy of the within
On
at am/pm
_______________________________ _________________________________
Attorney (s) for Angelyn Johnson & Associates LLC
By: By: Angelyn D. Johnson, Esq.
2 of 2
Preview
FILED: KINGS COUNTY CLERK 11/18/2022 05:41 PM INDEX NO. 520498/2021 NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 11/18/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ------------------------------------------------------------------------------X DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT RELATED TO IMPAC SECURED ASSETS CORP., MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2006-1, NOTICE OF MOTION Plaintiff, -against- Index No: 520498/2021 JAMES FREDERICK, et al., Defendants. --------------------------------------------------------------------------------X SIRS: PLEAST TAKE NOTICE, that upon the annexed affirmation of Angelyn D. Johnson, Esq., dated November 17, 2022, and upon all pleadings and prior proceedings heretofore had herein, the undersigned, will moved this Supreme Court, County of Kings, located at the County Courthouse, at 360 Adams Street, Brooklyn, NY 11201, at motion part thereof, before the Hon. Larry Martin, J.S.C., on the 15thth day of December, 2022 at 9:30 o’clock in the forenoon or as soon thereafter as counsel can be heard, for an order: (a) pursuant to CPLR 2221 to reargue the Court’s Decision and Order, entered on October 19, 2022 and for such other and further relief as may be just and proper. PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR §2214(b) answering affidavits, if any, are required to be served upon the undersigned at least seven (7) days before the return date of this motion. Dated: November 17, 2022 Brooklyn, NY Yours, etc., ____________________________________________ ANGELYN D. JOHNSON & ASSOCIATES, LLC By: Angelyn D. Johnson, Esq. Attorneys for Defendant Santos Argueta 26 Court Street, Suite 2610 Brooklyn, NY 11242 (718) 875-2145 ajohnson@adj-law.com 1 of 2 FILED: KINGS COUNTY CLERK 11/18/2022 05:41 PM INDEX NO. 520498/2021 NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 11/18/2022 ANGELYN JOHNSON & ASSOCIATES SUPREME COURT OF THE CITY OF NEW YORK COUNTY OF KINGS INDEX NO.: 520498/2021 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT RELATING TO IMPAC SECURED ASSETS CORP., MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2006-1 Plaintiff, -against- JAMES FREDERICK; NEW YORK CITY ENVIRONMENTAL CONTROL BOARD; NEW YORK CITY PARKING VIOLATIONS BUREAU; NEW YORK CITY TRANSIT ADJUDICATION BUREAU, “JOHN DOE #1” through “JOHN DOE #2,” the last twelve names being fictitious and unknow to plaintiff, the persons or parties intended being the tenants, occupants, persons or corporations, if any, having or claiming an interest in or lien upon the Subject Property described in the Complaint, Defendant. NOTICE FOR MOTION ANGELYN JOHNSON & ASSOCIATES Attorney(s) for Defendant James Frederick Office Address & Tel. No.: 26 Court Street, Suite 2610 Brooklyn, New York 11242 (718) 875-2145 (Office) (516) 395-6902 (Cell) ajohnson@adj-law.com ADMISSION OF SERVICE CERTIFICATION PURSUANT The undersigned acknowledges to Rule 130-1, 1-a receipt of a copy of the within On at am/pm _______________________________ _________________________________ Attorney (s) for Angelyn Johnson & Associates LLC By: By: Angelyn D. Johnson, Esq. 2 of 2