Preview
FILED: KINGS COUNTY CLERK 05/09/2023 12:24 PM INDEX NO. 523039/2021
NYSCEF DOC. NO. 82 RECEIVED NYSCEF: 05/09/2023
EXHIBIT R
FILED: KINGS COUNTY CLERK 05/09/2023 12:24 PM INDEX NO. 523039/2021
NYSCEFDOC.
NYSCEF DOC.
NO.NO.82 55 RECEIVEDNYSCEF:
RECEIVED NYSCEF:05/09/2023
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"" ^"
SUPREME C^7R1 THE NE "3RK
Plaintiff(s), nu .
-against-
CARMEN LEGGETT AKA CARMEN TANNER, AS HEIR
AND DISTRIBUTEE OF THE ESTATE OF DOROTHY
LEGGETT AKA DOROTHY TALIAFERROW-LEGGETT,
if living, and if she/he be dead, any and all person unknown to
plaintiff, claiming, or who may claim to have an interest in, or
general or specific lien upon the real property described in this
action; such unknown persons being herein generally described
and intended to be included in the following designation, namely:
the wife, widow, husband, widower, heirs at law, next of kin,
descendants, executors, administrators, devisees, legatees,
creditors, trustees, committees, lianors, and assignees of such
deceased, and all persons deriving interest in or lien upon, or title to
said real property by, through or under them, or either of them,
and their respective wives, widows, husbands, widowers, heirs
at law, next of kin, descendants, executors, administrators, devisees,
legatees, creditors, trustees, committees, lienors and assigns, all of
whom and whose names, except as states, are unknown to plaintiff;
UNKOWN HEIRS AND DISTRIBUTEES OF THE ESTATE OF
DOROTHY LEGGETT AKA DOROTHY TALIAFERROW-
LEGGETT, and any and all persons unknown to Plaintiff, claiming,
or who may claim to have an interest in, or general or specific lien
upon the real property described in this action; such unknown persons
being herein generally described and intended to be included in the
following designation. Namely: the wife, husband, widower, heirs at
law, next of kin, descendants, executom, administrators, devisees,
legatees, creditors, trustees, committees, lienors, and assignees of
such deceased, any and all persons deriving interest in or lien upon,
or title to said real property by, through or under them, or either of
them, and their respective wives, widows, husbands, widows,
husbands, widowers, heirs at law, next of kin, descendants, executors,
administrators, devisees, legatees, creditors, trustees, committees,
lienom and assigns, all whom and whose names, except as stated,
are unknown to Plaintiff, SECRETARY OF HOUSING AND
URBAN DEVELOPMENT; THE BOARD OF MANAGERS OF
THE MEADOWOOD AT GATEWAY CONDOMINIUM F/K/A
THE FAIRFIELD TOWERS CONDOMINIUM; NEW YORK
CITY PARKING VIOLATIONS BUREAU; NEW YORK CITY
ENVIRONMENTAL CONTROL BOARD; NEW YORK CITY
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FILED: KINGS COUNTY CLERK 05/09/2023 12:24 PM INDEX NO. 523039/2021
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DOCT1MNSTF ADJUDICATION BUREAU; NEW YORK STATE RECEIVEDNYSCEF:
RECEIVED NYSCEF:05/09/2023
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DEPARTMENT OF TAXATION AND FINANCE; UNITED
STATES OF AMERICA; THE PEOPLE OF THE STATE OF
NEW YORK; JOHN DOE AS "JOHN DOE #1; JANE DOE
AS "JOHN DOE #2";
#3" #12,"
"JOHN DOE through "JOHN DOE the last ten names
heing fictitious and unknown to plaintift the persons or parties
intended being the tenants, occupants, persons or corporations,
if any, having or claiming an interest in or lien upon the
p emises, described in the complaint,
Defendant(s).
......---.._.........--.---.._.......--.___.._...........x
PLEASE TAKE NOTICE, that PAUL B. GROMAN, with offices located at 32 Court
Street, Suite 404, Brooklyn, New York 11201, hereby appears herein, and that the undersigned
has been appointed as Guardian ad Litem on behalf of the defendants who may be infants,
absentees or incompetents, or unknown successors of interest of the defendant Carmen Leggett
and if deceased, any unknown heirs, who may no longer be in existence, and demands that all
. .
papers and notices in the above-captioned action be served upon the undersigned attomey at the
address stated below.
Dated: Brooklyn, NY
August 10, 2022
Paul B. Oroman
Guardian ad Litem for Defendant(s)
Carmen Leggett and Any Unknown
Heirs
32 Coutt Street, Suite 404
Brooklyn, NY 11201
Phone: (718) 852-1196
To: Sara Z. Boriskin, Esq.
Robertson, Anschutz, Schneid, Crane & Partners, PLLC
Attorneys for the Plaintiff (9
900 Merchants Concourse
Westbury, NY 11590
Phone: (973) 575-0707
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. AFFIDAVIT OF SERVICE
STATE OF NEW YORK )
.) ss:
COUNTY OF KINGS )
ANGELA COOK, being duly sworn, deposes and says:
That Af6ant is not a party to this action. is over the age of 18 years and resides in Kings
County, New York.
Appearance"
That on August 10, 2022, Affiant served the within "Notice of in the
matter Bank of New York Mellon Trust Compam v. Carmen Legett. et al.. venued in Supreme
Court-Kings County and designated by Index Number 523039/2021 on the addressees listed
below, being the addresses designated by said parties for that purpose, by depositing a true copy
of same enclosed in a postpaid properly addressed wrapper, via USPS First Class Mail in an
official depository under the exclusive care and custody of the United States Post Office
Department within New York, addressed to:
To: Sara Z. Boriskin, Esq.
Robertson, Anschutz, Schneid, Crane & Partners, PLLC
900 Merchants Concourse
Westbury, NY 11590
ANGE A COOK
Sworn to before me this the
10*
day of August, 2022
NOTdY PUBLIC
New
No.onan
QualMed
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FILED: KINGS COUNTY CLERK 05/09/2023 12:24 PM INDEX NO. 523039/2021
NYSCEF DOC. NO. 82 523039 Vear: 2021 usceh 05/09/2023
Recedve NYSCEF:
RECEIVED
SUPREME COURT OF THE STATE OF NEW YORK
coUNTY OF KINGS
BANK OF NEW VORK MBLLON TRUST COMPANY,
PlaintifRs),
-against-
CARMEN LBGGBTT et at,
Defendant(s),
NOTICE OF APPEARANCE
PAUL B. GROMAN
Ganrdian adUtemfor Defendant Carman Leggettfunknown/heirs)
Oface and Post Office Address; Telephone
32 Court Suite 40s,
Street,
Brooklyn,New York 21201
Phone: ('/18) 852496
Anorneyfe) ibr
Phase·tidrenodles,
Ititf afasurpa tmo copy of a
fa the odice of thiroterfief the yrithin named ocurt on 200
tlu in citler . of whleh the wit%fn is a true copy willibe presented ibr
. eastidaBON. one ofthejudges
withiq nanted tourt at
an 200. at M.
Dated, Yoms, etc.
PAUL & GROMAN"
Attorney for Defendent (s), Guardian Ad
Litam for Defendarit Cannæp Leggetf
(unknomVhedra)
To
OdBce and PostoShe Address
Amoungnsi dbr 32 Court Stmet, Suite 404
Brooklyn. NY 11201
(718) 852-1196
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
____________......______________....________.._______________..._________ _______Ç
C
O .
BANK t n NEW YORK MELLON TRUST COMPANY.
N.A. AS TRUSTEE FOR MORTGAGE ASSERTS
MANAGEMENT SERIES I TRUST
Plaintiff(s), Index No. 523039/2021
-against-
CARMEN LEGGETT AKA CARMEN TANNER, AS HEIR
AND DISTRIBUTEE OF THE ESTATE OF DOROTHY
LEGGETT AKA DOROTHY TALIAFERROW-LEGGETT,
if living, and if she/he be dead, any and all person unknown to
plaintiff, claiming, or who may claim to have an interest in, or
general or specific lien upon the real property described in this
action; such unknown persons being herein generally described
and intended to be included in the following designation, namely:
the wife, widow, husband, widower, heirs at law, next of kin,
descendants, executom, administrators, devisees, legatees,
creditors, trustees, committees, lienors, and assignees of such
deceased, and all persons deriving interest in or lien upon, or title to
said real property by, thNugh or under them, or either of them,
and their aspective wives, widows, husbands, widowers, heirs
at law, next of kin, descendants, executors, administrators, devisees,
legatees, creditors, trustees, committees, lienors and assigns, all of
whom and whose names, except as states, are unknown to plaintiff;
UNKOWN HEIRS AND DISTRIBUTEES OF THE ESTATE OF
DOROTHY LEGGETT AKA DOROTHY TALIAFERROW-
LEGGETT, and any and all persons unknown to Plaintiff, claiming,
or who may claim to have an interest in, or general or specific lien
upon the real property described in this action; such unknown persons
being herein generally described and intended to be included in the
designation. Namely: the wife, husband, widower, heirs at
following
law, next of kin, descendants, executors, administrators, devisees,
legatees, creditors, trustees, committees, lienors, and assignees of
such deceased, and all persons deriving interest in or lien upon,
any
or title to said real property by, through or under them, or either of
them, and their respective wives, widows, husbands, widows,
husbands, widowers, heirs at law, next of kin, descendants, executors,
administrators, devisees, legatees, creditors, trustees, committees,
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lienors and assigns. all whom and whose names, except as stated.
are unknown to Plaintiff; SECRETARY OF HOUSING AND
URBAN DEVELOPMENT; THE BOARD OF MANAGERS OF
THE MEADOWOOD AT GATEWAY CONDOMINIUM F/K/A
THE FAIRFIELD TOWERS CONDOMINIUM; NEW YORK
CITY PARUNG VIOLATIONS BUREAU; NEW YORK CITY
ENVIRONMENTAL CONTROL BOARD; NEW YORK CITY
TRANSIT ADJUDICATION BUREAU; NEW YORK STATE
DEPARTMENT OF TAXATION AND FINANCE; UNITED
STATES OF AMERICA; THE PEOPLE OF THE STA'lE OF
NEW YORK; JOHN DOE AS "JOHN DOE #1; JANE DOE
AS "JOHN DOE #2";
#3" #12,"
"JOHN DOE through "JOHN DOE the last ten names
being fictitious and unknown 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
premises, described in the complaint,
Defendant(s).
.............._.._..----..........--.__......._..............Ç
I, PAUL B. GROMAN, appointed as Guardian Ad Litem by an Order of this Court duly made
27*
and entered in the above-entitled action on the day of June, 2022 do solemnly affirm under
the penalties of perjury:
THAT I will faithfully and fairly protect and defend the rights and interests of the
defendant set forth below; and
DO hereby consent to said appointment of Guardian Ad Litem for such of the defendant
who be infants, absentees or incompetents, or unknown successors of interest of the
may
defendant who may no longer be in existence.
THAT Ihave no adverse interest to that of the defendants herein.
FILED: KINGS COUNTY CLERK 05/09/2023 12:24 PM INDEX NO. 523039/2021
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-
1 ! · am not connected in business with the attorney for any of the parties to
the action herein.
Very truly yours,
PAUL B. GROMAN
Guardian ad Litem for Defendant(s)
Carmen Leggett and any unknown heirs
32 Court Street, suite 404
Brooklyn, New York 11201
Phone: (718) 852-1196
10*
Affirmed this day
of August, 2022
TO: Sara Z. Boriskin, Esq.
Robertson, Anschutz, Schneid, Crane & Partners, PLLC
Attorneys for the Plaintiff (5)
900 Merchants Concourse
Westbury, NY 11590
Phone: (973) 575-0707
FILED: KINGS COUNTY CLERK 05/09/2023 12:24 PM INDEX NO. 523039/2021
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NYSCEF DOC.NO.NO.
82 56 RECEIVEDNYSCEF:
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FFIDAVIT OF SERVICE
STATE OF NEW YORK )
) ss:
COLNTY OF KINGS )
ANGELA COOK, being duly sworn, deposes and says:
That Affiant is not a party to this action, is over the age of 18 years and resides in Kings
County, New York.
Oath"
That on August 10, 2022, Affiant served the within "Consent and in the rnatter
Bank ofNew York Mellon Trust compum v. Carmen Leenett. et al.. venued in Supreme Court-
Kings County and designated by Index Number 523039/2021 on the addressees listed below,
being the addresses designated by said parties for that purpose, by depositing a true copy of
same enclosed in a postpaid properly addressed wrapper, via USPS First Class Mail in an
official depository under the exclusive care and custody of the United States Post Office
Department within New York, addressed to:
To: Sara Z. Boriskin, Esq.
Robertson, Anschutz, Schneid, Crane & Partners, PLLC
900 Merchants Concourse
Westbury, NY 11590
ANGE COOK
Sworn to before me this the
10th
day of August, 2022
NOTARY PUBLIC
PAUL B GROMAN
Notary Public, State of New York
No. 020R6011778
Qualified in Kings
County
Commission Expires August 17, 2022
4 of S
m -manum,
FILED: munraramws
KINGS ww-was w a
COUNTY w¡mummam
CLERK -w w f a w f m. w a 12:24
05/09/2023 w a. w
m. w .m... asPM INDEX NO. 523039/2021
"
NYSCEFCBC ·dourii
DOC. EN
NO. 82 . 523039 Yeat! 2021 RECEIVEDNYSCEF:
RECEIVED ÑYSCEr:05/09/2023
B8/10/20
5UPREME COURT OF THE STATE OF . NEW Y ORK
COUNTY OF KINGS
BANK OF NEW YORK MELLON TRUST COMPANY,
Plaintits),
-against-
CAR1@NLEOGBTT et ah,
Defimdant(s),
CONSENT AND OATH
PAUL B. GROMAN
0mmitoI·ad Lifem for Defendant Carmen Imggatt (unknown/hahm)
Oface andPostofBee Address, Telephone
82 Court5treet,Suite404
Brooklyn, New York 1501
Phone:(718)852-1196
d[ervieeof atopy of be witidn Winenty admined.
liinged,
. ..
Attbrasy(s) Air
lth.Pipisselt¼ilogice
. amnpayssdarr,
. , . aree withib is a fourt#feÆ tue copy ofa
. didó·eitigirdll$h@e éMáa oftbe cl4rk ofthe withia named ecurt on 200
natan anger of which the witigin is a tma copy wUI be presented f br
ammmametatheB0N.. one of the judges
%ftheskhinessbd courg at
as 200,,,. at M.
Dated, Yours, olo.
PAUL & GROMAN
Attorney for Defendant (s)
To
Oface and Post Oface Address
Atgoomy(ear 32 Court Street, Sales 404
Brooklyn, NY 11201
Phone (718) 852-1196
s ac s