On March 17, 2020 a
Party Statement
was filed
involving a dispute between
Newrez Llc D B A Shellpoint Mortgage Servicing,
and
Cavalry Spv I, Llc,
Crouse Health Hospital, Inc. D B A Crouse Hospital,
John Doe #1 Through #6, And Jane Doe #1 Through #6, The Last Twelve Names Being Fictitious, It Being The Intention Of Plaintiff To Designate Any And All Occupants, Tenants, Persons Or Corporations, If Any, Having Or Claiming An Interest In Or Lien Upon
The Premises Being Foreclosed Herein,
Randall Tomasino,
for Real Property - Mortgage Foreclosure - Residential
in the District Court of Onondaga County.
Preview
FILED: ONONDAGA COUNTY CLERK 03/17/2020 10:21 AM INDEX NO. 002757/2020
NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 03/17/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ONONDAGA
NewRez LLC d/b/a Shellpoint Mortgage CERTIFICATE OF MERIT PURSUANT TO
Servicing, CPLR 3012-B
Plaintiff,
INDEX NO.:
vs.
MORTGAGED PREMISES:
Randall Tomasino; Cavalry SPV I, LLC; Crouse
4029 Plum Yew Circle
Health Hospital, Inc. d/b/a Crouse Hospital; John
Liverpool, New York 13090
Doe #1 through #6, and Jane Doe #1 through #6,
the last twelve names being fictitious, it being the
Section: 055. Block: 06 Lot: 83.0
intention of Plaintiff to designate any and all
occupants, tenants, persons or corporations, if any,
having or claiming an interest in or lien upon the
premises being foreclosed herein,
Defendants.
I, Monica G. Christie, Esq., hereby certify as follows:
1. I am an attorney at law duly licensed to practice in the State of New York and am affiliated with
the law firm of McCalla Raymer Leibert Pierce, LLC, the attorneys of record for Plaintiff in the
above-captioned mortgage foreclosure action. As such, I am fully aware of the underlying
action, as well as the proceedings had herein.
2. I have reviewed the facts of this case and communicated with Zil'lah Scott, a representative of
Plaintiff's servicer concerning the subject of this action.
3. Based upon my communication with Plaintiff's servicer and my review of the pertinent
documents, including the mortgage, security agreement and note or bond underlying the
mortgage executed by the defendants and all instruments of assignment, if any, and any other
instrument of indebtedness including any modification, extension, and/or consolidation, and to
the best of my knowledge, information and belief, there is a reasonable basis for the
commencement of this action and that Plaintiff is currently the creditor entitled to enforce rights
under such documents.
[THIS SPACE IS INTENTIONALLY LEFT BLANK]
9550-5029
1 of 2
FILED: ONONDAGA COUNTY CLERK 03/17/2020 10:21 AM INDEX NO. 002757/2020
NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 03/17/2020
4. I further certify that to the best of my knowledge, information and belief, formed after
reasonable inquiry regarding the present action, the presentation of the pleadings or the
contentions contained herein are not frivolous as defined in 22 NYCRR 130-1.1(c).
It is hereby certified on # 24&C By:
Monica G. istie, Esq.
McCalla Raymer Leibert Pierce, LLC
420 Lexington Avenue, Suite 840
New York, New York 10170
Phone: 347-286-7409
Fax: 347-286-7414
Attorneys for Plaintiff
NewRez LLC d/b/a Shellpoint Mortgage
Servicing
File No. 9550-5029
9550-5029
2 of 2
Document Filed Date
March 17, 2020
Case Filing Date
March 17, 2020
Category
Real Property - Mortgage Foreclosure - Residential
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Preview
FILED: ONONDAGA COUNTY CLERK 03/17/2020 10:21 AM INDEX NO. 002757/2020 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 03/17/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ONONDAGA NewRez LLC d/b/a Shellpoint Mortgage CERTIFICATE OF MERIT PURSUANT TO Servicing, CPLR 3012-B Plaintiff, INDEX NO.: vs. MORTGAGED PREMISES: Randall Tomasino; Cavalry SPV I, LLC; Crouse 4029 Plum Yew Circle Health Hospital, Inc. d/b/a Crouse Hospital; John Liverpool, New York 13090 Doe #1 through #6, and Jane Doe #1 through #6, the last twelve names being fictitious, it being the Section: 055. Block: 06 Lot: 83.0 intention of Plaintiff to designate any and all occupants, tenants, persons or corporations, if any, having or claiming an interest in or lien upon the premises being foreclosed herein, Defendants. I, Monica G. Christie, Esq., hereby certify as follows: 1. I am an attorney at law duly licensed to practice in the State of New York and am affiliated with the law firm of McCalla Raymer Leibert Pierce, LLC, the attorneys of record for Plaintiff in the above-captioned mortgage foreclosure action. As such, I am fully aware of the underlying action, as well as the proceedings had herein. 2. I have reviewed the facts of this case and communicated with Zil'lah Scott, a representative of Plaintiff's servicer concerning the subject of this action. 3. Based upon my communication with Plaintiff's servicer and my review of the pertinent documents, including the mortgage, security agreement and note or bond underlying the mortgage executed by the defendants and all instruments of assignment, if any, and any other instrument of indebtedness including any modification, extension, and/or consolidation, and to the best of my knowledge, information and belief, there is a reasonable basis for the commencement of this action and that Plaintiff is currently the creditor entitled to enforce rights under such documents. [THIS SPACE IS INTENTIONALLY LEFT BLANK] 9550-5029 1 of 2 FILED: ONONDAGA COUNTY CLERK 03/17/2020 10:21 AM INDEX NO. 002757/2020 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 03/17/2020 4. I further certify that to the best of my knowledge, information and belief, formed after reasonable inquiry regarding the present action, the presentation of the pleadings or the contentions contained herein are not frivolous as defined in 22 NYCRR 130-1.1(c). It is hereby certified on # 24&C By: Monica G. istie, Esq. McCalla Raymer Leibert Pierce, LLC 420 Lexington Avenue, Suite 840 New York, New York 10170 Phone: 347-286-7409 Fax: 347-286-7414 Attorneys for Plaintiff NewRez LLC d/b/a Shellpoint Mortgage Servicing File No. 9550-5029 9550-5029 2 of 2