Preview
FILED: DELAWARE COUNTY CLERK 09/20/2021 11:34 AM INDEX NO. EF2019-1036
NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 09/20/2021
FILED: DELAWARE COUNTY CLERK 09/20/2021 11:34 AM INDEX NO. EF2019-1036
NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 09/20/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF DELAWARE
----------------------------------------------------------------X
U.S. BANK TRUST NATIONAL ASSOCIATION,
NOT IN ITS INDIVIDUAL CAPACITY BUT
SOLELY AS OWNER TRUSTEE FOR REO
TRUST 2017-RPL1,
Plaintiff,
-against-
ALONNA WATSON; VICTORIA DUBOIS;
MELIDA EILEEN DOYLE; REBECCA REED; Index No. EF2019-1036
THE UNKNOWN HEIRS-AT-LAW, next-of-kin,
distributees, executors, administrators, trustees, AFFIDAVIT OF
devisees, legatees, assignees, lienors, creditors and NON-MILITARY SERVICE
successors in interest and generally all persons
having or claiming, under, by or through the
Decedent EDWIN R. LAMB, by purchase,
inheritance, lien or otherwise, any right title or
interest in and to the premises described in the
complaint herein; NEW YORK STATE
DEPARTMENT OF TAXATION AND FINANCE;
THE UNITED STATES OF AMERICA,
Defendants.
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STATE OF NEW YORK:
COUNTY OF DELAWARE: ss.
I, Catrina Sayegh, being duly sworn, says: I am not a party to the action, am over 18 years of
age and reside in Westchester, New York.
Deponent caused a search to be done to determine whether ALONNA WATSON, VICTORIA
DUBOIS, MELINDA EILEEN DOYLE and REBECCA REED, are in the military service.
The search performed by the Department of Defense, Manpower Data Center, Military
Verification Department, 1600 Wilson Boulevard, Ste. 400, Arlington, VA, 22209-259, verifies that
based on information provided, ALONNA WATSON, VICTORIA DUBOIS, MELINDA EILEEN
DOYLE and REBECCA REED, are not in the United States Military (see attached).
-27-
Combined Judgment/2267-003226-FC/EDWIN LAMB
FILED: DELAWARE COUNTY CLERK 09/20/2021 11:34 AM INDEX NO. EF2019-1036
NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 09/20/2021
Based on the above information, I can conclude that the Defendant, ALONNA WATSON,
VICTORIA DUBOIS, MELINDA EILEEN DOYLE and REBECCA REED are not in the military.
Catrina Sayegh
Knuckles, Komosinski & Manfro, LLP
565 Taxter Road, Suite 590
Elmsford, NY 10523
Sworn to before me this
f (//-
if_hi , 2021
ary Pu
o nson Edouard
otary Public, State of New York
Registration NO. 01ED6353054
Qualified in Westchester
County
Commission Expires Jan. 17, 20
-28-
Combined Judg;::::::/2267-003226-FC/EDWIN LAMB
FILED: DELAWARE COUNTY CLERK 09/20/2021 11:34 AM INDEX NO. EF2019-1036
NYSCEF DOC. NO.
Department
59of RECEIVEDResultsaNYSCEF: 09/20/2021
sof: Sep-17-2021
12:33:11
PM
Defense Manpower Data Center
SCRA5.9
Pursuant to Servicemembers Civil Relief Act
SSN: XXX-XX-
Birth Date:
Last Name: REED
First Name: REBECCA
Middle Name:
Status As Of: Sep-17-2021
Certificate ID: 5QR2ZBG80RRMOSC
OnActiveDutyOnActiveDutyStatusDale
I ActiveDutyStartDate ActiveDutyEndDate Status ServiceComponent
NA NA No NA
reflectstheindividuals'
Thisresponse activedutystatusbasedontheActiveDutyStatusDate
LeftActiveDutyWithin367DaysofActiveDutyStatusDate
ActiveDutyStartDate ActiveDutyEndDate Status ServiceComponent
NA NA No NA
Thisresponse
reflectswheretheindividual theActiveDutyStatusDate
leftactivedutystatuswithin367dayspreceding
_..... .......
.. . ...
. ....... .......................
...
or His/HerUnitWasNotifiedofa FutureCall-UptoActiveDutyonActiveDutyStatusDate
TheMember
OrderNotification
StartDate OrderNotification
EndDate Status ServiceComponent
NA NA No NA
Thisresponse
reflectswhethertheindividual
orhis/herunithasreceived toreportforactiveduty
earlynotification
Upon searchingthe data banks of the Department
of DefenseManpower Data Center, based on the !nfermet!en that you provided, the above is the status of
the |. dMdë# of the Uniformed
on the active duty status date aS to all branches Services(Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard).This status includes on a Servicemember
infarinatics or his/her unit receiving of future orders to report for Active Duty.
notification
Director
Michael V. Sorrento,
of Defense - Manpower
Departinent Data Center
400 Gigling Rd,
SeaSide, CA 93955
FILED: DELAWARE COUNTY CLERK 09/20/2021 11:34 AM INDEX NO. EF2019-1036
NYSCEF The DOC. NO.
Defense 59
Manpower Data Center (DMDC) is an organization
of the Depãrtinént
of Defense
RECEIVED NYSCEF: 09/20/2021
(DoD) that -;G|ntu| . ; the Defense
Enrollment
and Eligibility
ReportingSystem(DEERS) databasewhich is the official source of data on eligibility for military
medical care and other eligibility
systems.
The DoD strongly
supportsthe enforcement
of the Servicemembers
Civil Relief Act (50 USC App. § 3901 et seq, as smended) known as
(SCRA) (formerly
the Soldiers'
and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds
of thousands
of "does not possess
any information that the
indicating
individual on active duty" responses,
is currently and has evperienced
only a small error rate. In the event the
.: referenced
above, or any family
member, friend, or representative in any manner that the
asserts . was on active duty for the active duty status date, or is otherwise
entitled to the
of the SCRA, you are strongly
pictéctións encouraged to obtain further
érificat|Ga of the person's that person's
status by contacting Service.Service contact
informat!ce
can be found on the SCRA website's
FAQ page (Q35) via this URL: https://scra.dmde If you have evidence
osd-mi!!scre!#!fegs the person
was on active duty for the active duty status date and you fail to obtain this êddit|énâ! Service of the SCRA may be invoked
punitive prev!sions
verification,
against you. See 50 USC App. § 3921(c).
'
This response
reflects the following
infGrmaticñ:
(1) The individual's the
Active Duty status on the Active Duty Status Date (2) Whether
. left Active
Duty status within 367 days
precedingthe Active
Duty Status Date (3) Whether or his/her unit received
the individual early netmcation to report for active
duty on the Active
Duty Status Date.
Status"
More information on "Active Duty
Active duty status as reported
in this certificate
is defined in accordance Prior to 2010 only some of the active duty periods less
with 10 USC § 101(d) (1).
days in length were available.
than 30 consecutive In the case of a member of the National Guard, this includes service under a call to active service
authorized
by the President
or the Secretary
of Defense of responding
under 32 USC § 502(f) for purposes to a national
Graergency declared
by the
Presidentand :uppenedby Federal funds. against an Ch
must be assigned
All Active Guard Reserve (AGR) members d me'cilizatión
position
in the
unit they support.
This includes (TARs), Marine Corps Active Reserve
and Adr:1:½t: ±t?eñof the Reserves
Navy Training (ARs) and Coast Guard Reserve
Program .^.2 .!±3ter
(RPAs). Active Duty status also applies to a Uniformed
Servicemember who is an active duty commiss!ened
officer of the U.S.
Public Health Service or the National Oceanic
and Atmospheric (NOAA Commissioned
Administration Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories
of persons of the SCRA who would not be
on active duty for purposes
reportedas on Active Duty under this certificate.
SCRA protect!ensare for Title 10 and Title 14 active duty records for all the Uniformed
Services
periods.
with 10 USC § 101(d)(1).
by SCRA, as defined in accordance
Title 32 periods of Active Duty are not covered
Persons seeking to rely on this website
to extend the period of active duty, which would extend SCRA pictGcticas.
Many times orders are amended
should check to make sure the orders on which SCRA prótecti0ns
certification dates of service.
are based have not been emended to extend the inclusive
some protections
Furthermore, but who have not
of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,
The Last Date on Active Duty entry is !mperter:t because
reported for induction.
begun active duty or actually
actually of the SCRA
a number of prefect!és
extend beyond the last dates of active duty.
to Service
legal counsel to ensure that all rights guaranteed
are urged to seek qualified
Those who could rely on this certificate members under the SCRA
are protected
'.^/.^¤|NG: was provided
This certificate by the requester.
of birth, and active duty status date provided
based on a last name, SSN/date Providing
erroneous will cause an circñ6óüo
information to
certificatebe provided.
FILED: DELAWARE COUNTY CLERK 09/20/2021 11:34 AM INDEX NO. EF2019-1036
NYSCEF DOC. NO. 59 RECEIVEDResultsaNYSCEF: 09/20/2021
sof: Sep-17-2021
12:32:41
PM
Department of Defense Manpower Data Center
SCRA5.9
Status Report
Pursuant to Servicemembers Civil Relief Act
SSN: XXX-XX
Birth Date:
Last Name: DOYLE
First Name: MELINDA EILEEN
Middle Name:
Status As Of: Sep-17-2021
Certificate ID: BD79JJ3G6F98GBV
OnActiveDutyOnActiveDutyStatusDate
ActiveDutyStartDate ActiveDutyEndDate Status ServiceComponent
NA NA No NA
reflectstheindividuals'
Thisresponse activedutystatusbasedontheActiveDutyStatusDate
LeftActiveDutyWithin367DaysofActiveDutyStatusDate
ActiveDutyStartDate ActiveDutyEndDate Status ServiceComponent
NA NA No NA
Thisresponse
reflectswheretheindividual theActiveDutyStatusDate
leftactivedutystatuswithin367dayspreceding
or His/HerUnitWasNotifiedofa FutureCall-UptoActiveDutyonActiveDutyStatusDate
TheMember
OrderNotification
StartDate OrderNotification
EndDate Status ServiceComponent
NA NA No NA
Thisresponse
reflectswhethertheindividual earlynotification
orhis/herunithasreceived toreportforactiveduty
Upon searching of Defense
the data banks of the Department that you provided, the above is the status of
Manpuvver Data Center, based on the information
the ind|v|düã| on the active duty status date as to all branches
of the Un|formed
Services(Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard).This status includes on a Servicemember
|nisanât|ón or his/her unit receiving of future orders to report for Active Duty.
net!kat!en
Director
Michael V. Sorrento,
Departmentof Defense - M=:‡ewerData Center
400 Gigling Rd.
Seaside,CA 93955
FILED: DELAWARE COUNTY CLERK 09/20/2021 11:34 AM INDEX NO. EF2019-1036
NYSCEFThe DOC. NO.
Defense
* 59:3r Data Center (DMDC)is an organization
RECEIVED NYSCEF: 09/20/2021
of the Department
of Defense(DoD) that maintains
the DefenseEnic||mentand Eligibility
ReportingSystem (DEERS) databasewhich is the official source of data on eligibility for military systems.
medical care and other eligibility
The DoD strongly
supportsthe enfarccinent
of the Servicemembsis
Civil Relief Act (50 USC App. § 3901 et seq, as emendad) known as
(SCRA) (formerly
Soldiers' Sailors' Civil Relief
the and Act of 1940). DMDC has issued hundreds
of thousands
of "does not possess
any information that the
indicating
duty" and has experienced
individual
is currently
on active responses, only a small error rate. In the event the T.f:.12±
referenced
above, or any family
or hié:!düâ'
member, friend, representative
assertsinany manner the
that was onactivedutyfortheactive
dutystatusdate,orisotherwise
entitled to the
of the SCRA, you are strongly
protections encouraged to obtain further
verification
of the person's
status by contacting
that person's
Service.Servicecontact
information
can be found on the SCRA website's
FAQ page (Q35) via this URL: https://scra.dmdc.onm!!!scra/#/faqs.
If you have evidence
the person
was on active duty for the active duty status date and you fail to obtain this additional
punitive pre
Service ver!ñcat!en, s!ons of the SCRA may be invoked
against you. See 50 USC App. § 3921(c).
This response infairmaticñ:
reflects the following Duty Status Date (2) Whether
(1) The !nd!vidue!'s Active Duty status on the Active the individüâ|
left Active
Duty status within 367 days
precedingthe Active
Duty Status Date (3) Whether
the indiwidüà | or his/her unit received to report for active
early notification
duty on the Active
Duty Status Date.
Status"
More information on "Active Duty
in this certificate
Active duty status as reported is defined in accordance Prior to 2010 only some of the active duty periods less
with 10 USC § 101(d) (1).
In the case of a member of the National
days in length were available.
than 30 consecutive Guard, this includes service under a call to active service
by the President
euthorized of Defense
or the Secretary under 32 USC § 502(f) for purposes to a national emergency
of responding declaredby the
President
and supportedby Federal funds.
All Active Guard Reserve (AGR) members against an euthorized
must be assigned mobilization
position in the
unit they support.
This includes and Adinin|strat:ón
Navy Training of the Reserves
(TARs), (ARs) and Coast Guard Reserve
Marine Corps Active Reserve
Program Adm!nistrater
(RPAs). Active Duty status also applies to a Un|formed
Servicemember who is an active duty comm!es!oned
officer of the U.S.
Public Health Service and Atmospheric
or the National Oceanic (NOAA Commissioned
Administration Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of the SCRA who would not be
of persons on active duty for purposes
reported as on Active Duty under this certificâts.
SCRA protections 14 active duty records for all the Uniformed
are for Title 10 and Title Servicesperiods.
Title 32 periods of Active by SCRA, as defined
Duty are not covered in accordancewith 10 USC § 101(d)(1).
to extend the period of active duty, which would extend SCRA pisteúGens. Persons seeking to rely on this website
Many times orders are amended
are based have not been amended
should check to make sure the orders on which SCRA protections
certification dates of service.
to extend the inclusive
orders to report for active duty or to be inducted,
of the SCRA may extend to persons who have received
ere, some protections but who have not
The Last Date on Active Duty entry is important
reported for induction.
begun active duty or actually
actually because of the SCRA
a number of pictecticns
extend beyond the last dates of active duty.
to Service
legal counsel to ensure that all rights güãranteed
are urged to seek qualified
Those who could rely on this certificate members under the SCRA
are protected
WARN:NG: was provided
This certificate by the requester.
of birth, and active duty status date provided
based on a last name, SSN/date Providing
erroneous will cause an circñéùüd
information to be provided.
certificate
. . .
FILED: DELAWARE COUNTY CLERK 09/20/2021 11:34 AM INDEX NO. EF2019-1036
NYSCEF Departinent
DOC. NO. 59
of Defense
RECEIVED
ResultsaNYSCEF: 09/20/2021
sof: Sep-17-2021
12:32:07
PM
Manpower Data Center
SCRA5.9
Status Report
Pursuant to Servicemembers Civil Relief Act
SSN: XXX-XX
Birth Date:
Last Name: DUBOIS
First Name: VICTORIA
Middle Name:
Status As Of: Sep-17-2021
Certificate ID: LROVMRGC7DFBW1H
OnActiveDutyOnActiveDutyStatusDate
ActiveDutyStartDate ActiveDutyEndDate Status ServiceComponent
NA NA No NA
reflectstheindividuals'
Thisresponse activedutystatusbasedontheActiveDutyStatusDate
LeftActiveDutyWithin367DaysofActiveDutyStatusDate
ActiveDutyStartDate ActiveDutyEndDate Status ServiceComponent
NA NA No NA
Thisresponse
reflectswheretheindividual theActiveDutyStatusDate
leftactivedutystatuswithin367dayspreceding
TheMember
or His/HerUnitWasNotifiedofa FutureCall-UptoActiveDutyonActiveDutyStatusDate
OrderNotification
StartDate OrderNotification
EndDate Status ServiceComponent
NA NA No NA
Thisresponse orhis/herunithasreceived
reflectswhethertheindividual earlynotification
toreportforactiveduty
Upon searchingthe data banks of the Depadrñêñt
of DefenseManpower the above is the status of
Data Center, based on the |ñfairñãtiGñ that you provided,
the !ñddæ! on the active duty status date as to all branches
of the Uniformed
Services(Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). on a Servicemember
informet!en
This status includes or his/her unit receiving of future orders to report for Active Duty.
notification
Director
Michael V. Sorrento,
Departmentof Defense - MâñpswerData Center
Rd.
400 Gigling
Seaside,CA 93955
FILED: DELAWARE COUNTY CLERK 09/20/2021 11:34 AM INDEX NO. EF2019-1036
NYSCEFThe DOC. NO.
Defense 59
Manpower Data Center (DMDC) is an cigâñ|zcities
of the Departrñêñt RECEIVED
(DoD) that me!nte!ne the Defense
of Defense NYSCEF:
Enrollment 09/20/2021
and Eligibility
ReportingSystem (DEERS) databasewhich is the official source of data on eligibility for military medical care and other eligibility
systems.
The DoD strongly
supports the enfürcerñêñt
of the Serviceniéñibers
Civil Relief Act (50 USC App. § 3901 et seq, as amended) known as
(SCRA) (formerly
the Soldiers'
and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds
of thousands
of "does not possess
any infersist:Gñ that the
indicating
individual on active duty" responses,
is currently and has experienced
only a small error rate. In the event the !nd!v!due! referenced
above, or any family
member, friend, or representauve in any manner
asserts that the iñdividüâ|
was on active duty for the active duty status date, or is otherwise
entitled to the
of the SCRA, you are strongly encouraged
protections to obtain further
verification
of the person's
status by contacting
that person's
Service.Servicecontact
can be found on the SCRA website's
information FAQ page (Q35) via this URL: https://scra.dmdc.osd.mil/scra/#/faqs.
If you have evidence
the person
was on active duty for the active duty status date and you fail to obtain this additional
Service verification, provisions
punitive of the SCRA may be invoked
against you. See 50 USC App. § 3921(c).
This response |ñfs76iâü6ñ:
reflects the following (1) The indMdüars
ActiveDuty status on the Active Duty Status Date (2) Whether
the individual
left Active
Duty status within 367 days
preceding the M_h
the Active Duty Status Date (3) Whether or his/her unit received
early ·tEGibñto report for active
duty on the Active Duty Status Date.
Status"
More information on "Active Duty
Active duty status as reported
in this