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FILED: WASHINGTON COUNTY CLERK 05/05/2021 04:35 PM INDEX NO. EC2020-31588
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 05/05/2021
SUPREME COURT OF THE STATE QF NEW YORK
COUNTY OF WASHINGTON
INDEX NO. EC2020-31588
JPMorgan Chase Bank, National Association
Plaintiff,
NOTICE OF MOTION
- against -
TQ AMEND SUMMONS
AND COMPIgAINT
Amber R. Gentry-Zeno a/k/a Amber Zeno Gentry; IJ.S.
District Court, and "JOHN DOE", said name being
fictitious, it being the intention of Plaintiff to designate
any and all occupants of premises being foreclosed
herein, and any parties, corporations or entities, if any,
having or claiming an interest or lien upon the mortgaged
premises,
Defendant(s).
SIRS OR MADAMS:
PLEASE TAKE NOTICE THAT upon the Sum=ona, Complaint and Notice of
Pendency originally filed in the office of the Clerk of the County of Washington on March 4,
2020, and upon the annexed affirmation of Ellis M. Oster, Esq., dated April 29, 2021, and any
exhibits annexed thereto, the Plaintiff will move this Court, at the Supreme Court in and for the
County of Washiñgton, held in the Washington County Courthouse, 383 Broadway, Fort
Edward, NY, on June 11, 2021, at 9:30 am, or as soon thereafter as counsel can be heard, for an
Order, pursuant to CPLR §§305(a), 3025(b), to amend the Summons and Complaint herein for
the purposes of naming and adding additional necessary party defendant(s), to amend the
caption, and thereafter, to effect service of process of the Supplemental Summons and Amended
Complaint upon said additional party defendant(s), and for such other and further relief as to this
Court may deem just and proper.
13-029613 Notice of Motion to Amend E=== and Camrplaint Page 1 of 2
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FILED: WASHINGTON COUNTY CLERK 05/05/2021 04:35 PM INDEX NO. EC2020-31588
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 05/05/2021
PLEASE TAKE FURTHER NOTICE THAT, that pursuant to CPLR § 2214(b),
Answering Affidavits, if any, are required to be served upon the Plaintiff's attorneys at least
seven (7) days before the return date of this Motion.
Dated: April 29, 2021
Rochester, New York
Very truly yours,
________________________
Ellis M. Oster, Esq.
Senior Associate, Director of Litigation
LOGS LEGAL GROUP LLP F/K/A
SHAPIRO, DICARO & BARAK, LLC
Attorneys for Plaintiff
175 Mile Crossing Boulevard
Rochester, New York 14624
(585) 247-9000
Fax: (585) 247-7380
To: Amber R. Gentry-Zeno a/k/a Amber Zeno Gentry
30 Rogers Street #3
Glens Falls, NY 12801
13-029613 Notice of Motion to Amend Summons and Complaint Page 2 of 2
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FILED: WASHINGTON COUNTY CLERK 05/05/2021 04:35 PM INDEX NO. EC2020-31588
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 05/05/2021
ATTORNEY'S CERTIFICATION
I, Ellis M. Oster, am an attorney duly admitted to the practice of law in the State of New
York. I am an Associate of LOGS Legal Group LLP f/k/a Shapiro, DiCaro & Barak, LLC, the
attorneys for the Plaintiff, JPMorgan Chase Bank, National Association, in the above captioned
civil action.
I HEREBY CERTIFY, pursuant to § 130-1.1-a of the Rules of the Chief Administrator
(22 NYCRR), to the best of my knowledge, information and belief, formed after an inquiry
reasonable under the circumstances, that the presentation of the papers in this action checked
below, or the contentions therein, are not frivolous as defined in subsection (c) of § 130-1.1 of
the Rules of the Chief Administrator (22 NYCRR):
{ } Summons & Complaint
{ } Answer or Reply
{ } Attorney Affirmation
{X} Other: Notice of Motion to Amend Summons and Complaint
DATED: April 29, 2021 ________________________
Ellis M. Oster, Esq.
Senior Associate, Director of Litigation
LOGS LEGAL GROUP LLP F/K/A
SHAPIRO, DICARO & BARAK, LLC
Attorneys for Plaintiff
175 Mile Crossing Boulevard
Rochester, New York 14624
(585) 247-9000
Fax: (585) 247-7380
3 of 3
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FILED: WASHINGTON COUNTY CLERK 05/05/2021 04:35 PM INDEX NO. EC2020-31588 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 05/05/2021 SUPREME COURT OF THE STATE QF NEW YORK COUNTY OF WASHINGTON INDEX NO. EC2020-31588 JPMorgan Chase Bank, National Association Plaintiff, NOTICE OF MOTION - against - TQ AMEND SUMMONS AND COMPIgAINT Amber R. Gentry-Zeno a/k/a Amber Zeno Gentry; IJ.S. District Court, and "JOHN DOE", said name being fictitious, it being the intention of Plaintiff to designate any and all occupants of premises being foreclosed herein, and any parties, corporations or entities, if any, having or claiming an interest or lien upon the mortgaged premises, Defendant(s). SIRS OR MADAMS: PLEASE TAKE NOTICE THAT upon the Sum=ona, Complaint and Notice of Pendency originally filed in the office of the Clerk of the County of Washington on March 4, 2020, and upon the annexed affirmation of Ellis M. Oster, Esq., dated April 29, 2021, and any exhibits annexed thereto, the Plaintiff will move this Court, at the Supreme Court in and for the County of Washiñgton, held in the Washington County Courthouse, 383 Broadway, Fort Edward, NY, on June 11, 2021, at 9:30 am, or as soon thereafter as counsel can be heard, for an Order, pursuant to CPLR §§305(a), 3025(b), to amend the Summons and Complaint herein for the purposes of naming and adding additional necessary party defendant(s), to amend the caption, and thereafter, to effect service of process of the Supplemental Summons and Amended Complaint upon said additional party defendant(s), and for such other and further relief as to this Court may deem just and proper. 13-029613 Notice of Motion to Amend E=== and Camrplaint Page 1 of 2 1 of 3 FILED: WASHINGTON COUNTY CLERK 05/05/2021 04:35 PM INDEX NO. EC2020-31588 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 05/05/2021 PLEASE TAKE FURTHER NOTICE THAT, that pursuant to CPLR § 2214(b), Answering Affidavits, if any, are required to be served upon the Plaintiff's attorneys at least seven (7) days before the return date of this Motion. Dated: April 29, 2021 Rochester, New York Very truly yours, ________________________ Ellis M. Oster, Esq. Senior Associate, Director of Litigation LOGS LEGAL GROUP LLP F/K/A SHAPIRO, DICARO & BARAK, LLC Attorneys for Plaintiff 175 Mile Crossing Boulevard Rochester, New York 14624 (585) 247-9000 Fax: (585) 247-7380 To: Amber R. Gentry-Zeno a/k/a Amber Zeno Gentry 30 Rogers Street #3 Glens Falls, NY 12801 13-029613 Notice of Motion to Amend Summons and Complaint Page 2 of 2 2 of 3 FILED: WASHINGTON COUNTY CLERK 05/05/2021 04:35 PM INDEX NO. EC2020-31588 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 05/05/2021 ATTORNEY'S CERTIFICATION I, Ellis M. Oster, am an attorney duly admitted to the practice of law in the State of New York. I am an Associate of LOGS Legal Group LLP f/k/a Shapiro, DiCaro & Barak, LLC, the attorneys for the Plaintiff, JPMorgan Chase Bank, National Association, in the above captioned civil action. I HEREBY CERTIFY, pursuant to § 130-1.1-a of the Rules of the Chief Administrator (22 NYCRR), to the best of my knowledge, information and belief, formed after an inquiry reasonable under the circumstances, that the presentation of the papers in this action checked below, or the contentions therein, are not frivolous as defined in subsection (c) of § 130-1.1 of the Rules of the Chief Administrator (22 NYCRR): { } Summons & Complaint { } Answer or Reply { } Attorney Affirmation {X} Other: Notice of Motion to Amend Summons and Complaint DATED: April 29, 2021 ________________________ Ellis M. Oster, Esq. Senior Associate, Director of Litigation LOGS LEGAL GROUP LLP F/K/A SHAPIRO, DICARO & BARAK, LLC Attorneys for Plaintiff 175 Mile Crossing Boulevard Rochester, New York 14624 (585) 247-9000 Fax: (585) 247-7380 3 of 3