Preview
RETURN DATE: NOVEMBER 21, 2023 SUPERIOR COURT
JUDICIAL DISTRICT
OF STAMFORD-NORWALK
AT STAMFORD
FINANCE OF AMERICA REVERSE
LLC
VS.
VERNIE V. WILLIAMS; ET AL October_3Q_, 2023
COMPLAINT
1 Upon information and belief Defendant, Vernie V. Williams (the “Defendant(s)”), is/are
the owner of property located at 14 Sherman Street, Stamford, CT 06902, more
particularly described on Exhibit “A” attached hereto (the “Property”) by virtue of a
Deed dated June 6, 1986 and recorded June 6, 1986 in Volume 2787 Page 190 of the
Stamford Land Records.
On March 14, 2019, Vernie V. Williams promised to pay Fairway Independent Mortgage
Corporation up to a maximum principal amount of $517,500.00, as evidenced by a
promissory note executed on said date, and payable to the order of Fairway Independent
Mortgage Corporation in a principal amount equal to the sum of all loan advances and
fees under the terms of said note with interest thereon.
On May 19, 2019, by a deed of that date, Recorded in Volume 12110 at Page 297 of the
Stamford Land Records, said Vernie V. Williams, to secure said note, mortgaged to
Mortgage Electronic Registration Systems, Inc., as nominee for Fairway Independent
Mortgage Corporation the premises known as 14 Sherman Street, Stamford, Connecticut, 7
and described in Exhibit A attached hereto and made a part hereof.
B&S File No.: 23-27029 FCO
4. Finance of America Reverse LLC (hereinafter “the Plaintiff’) is the current holder of the
Note and Mortgage.
The Mortgage was assigned to the Plaintiff by assignment from Mortgage Electronic
Registration Systems, Inc., as mortgagee, as nominee for Fairway Independent Mortgage
Corporation dated July 7, 2023, recorded with the Stamford Land Records in Book 13201
at Page 72.
On or before, June 27, 2023, the Plaintiff became and at all times since then has been the
party entitled to collect the debt evidenced by said note and is the party entitled to enforce
said mortgage. The Plaintiff has complied with any applicable Department of Housing
and Urban Development regulations that are a precondition to acceleration of the debt
and foreclosure of the mortgage relative to this loan, prior to commencement of the
subject action. The unpaid balance due pursuant to the terms of said note is the unpaid
principal balance due at time of referral to counsel to begin foreclosure proceedings in the
amount of $115,278.71, plus interest, servicing fees allowed by the contracts and the
enabling rules and statutes and collection costs, that have not been paid although due and
payable.
Said note and mortgage are in default because the properly has ceased to be the principal
residence of the borrower for reasons other than death.
The Plaintiff has caused a Notice of Availability of Emergency Mortgage Assistance
(“EMAP”) be sent as required by C.G.S. §§ 8-265cc et seq.
Defendant is presently the owner of the Property and, upon information and belief is in
possession thereof.
10 The Defendant, The Federal Housing Commissioner, may claim an interest in said
premises by virtue of a mortgage in the original principal amount of $517,500.00 dated
March 14, 2019, and recorded March 19, 2019 in Volume 12110 at Page 312 of the
Stamford Land Records.
11. The following parties claim an interest in the Property prior in right to the interest of
Plaintiff.
a. Town of Stamford for taxes for any previous year now due and all subsequent
years not yet due;
Town of Stamford, Water Pollution Control Authority for sewer use charges for
the calendar years not yet due; and any previous year now due; and by virtue of
a continuing sewer lien dated February 28, 2023 recorded March 2, 2023 in
Volume 13141 at Page 216 with the Stamford Land Records; and by virtue of a
continuing sewer lien dated August 16, 2023 and recorded August 22, 2023 in
Volume 13221 at Page 332 of the Stamford Land Records.
C. Stamford Tax District for tax district fees, if applicable.
THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT
TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE. IF YOU: ARE A DEBTOR IN AN ACTIVE BANKRUPTCY CASE;
ARE UNDER THE PROTECTION OF A BANKRUPTCY STAY; OR, HAVE RECEIVED
A DISCHARGE IN BANKRUPTCY AND YOU HAVE NOT REAFFIRMED THE DEBT,
THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE
CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT FROM YOU PERSONALLY.
WHEREFORE, Plaintiff prays for the following relief:
1 A foreclosure of the mortgage;
2 Immediate possession of the mortgaged premises;
The appointment of a receiver to collect the rents and profits accruing from the premises;
Monetary damages;
Costs of this action;
Interest on mortgage debt from date of default;
Attorney’s fees; and
Such other and further relief as the court may deem just and equitable.
Plaintiff,
Finance of America Reverse LLC
By its Attorney,
405518
Diane S. Summers, Esq.
BROCK & SCOTT, PLLC
270 Farmington Avenue
Suite 151
Farmington, CT 06032
Telephone: (401) 217-8701
Email: CT_FC_Team@BrockandScott.com
Juris No.: 439942
B&S File No.: 23-27029 FCO1
EXHIBIT A
EL OF ther with the
buildings ford, County
of Pairfield
and Lot No, 12
as shown and
of the
Town Clerk being hereby had
NORTHERLY: . by Sherman Street,
100: Jand now or
Memoli and
SOUTHERLY: ‘50 fe
formerly
part; and
WESTERLY:
. 100 Jand now or
B&S File No.: 23-27029 FCO1
RETURN DATE: NOVEMBER 21, 2023 SUPERIOR COURT
JUDICIAL DISTRICT
OF STAMFORD-NORWALK
AT STAMFORD
FINANCE OF AMERICA REVERSE
LLC
VS.
VERNIE V. WILLIAMS, ET AL October_30_, 2023
STATEMENT OF AMOUNT IN DEMAND
The amount in demand, exclusive of interest and costs, is greater than Fifteen Thousand.
Dollars ($15,000.00).
Plaintiff,
By its Attorney,
405518
Diane S. Summers, Esq.
BROCK & SCOTT, PLLC
270 Farmington Avenue
Suite 151
Farmington, CT 06032
Telephone: (401) 217-8701
Email: CT_FC_Team@BrockandScott.com
Juris No.: 439942
B&S File No.: 23-27029 FCO1
Preview
RETURN DATE: NOVEMBER 21, 2023 SUPERIOR COURT JUDICIAL DISTRICT OF STAMFORD-NORWALK AT STAMFORD FINANCE OF AMERICA REVERSE LLC VS. VERNIE V. WILLIAMS; ET AL October_3Q_, 2023 COMPLAINT 1 Upon information and belief Defendant, Vernie V. Williams (the “Defendant(s)”), is/are the owner of property located at 14 Sherman Street, Stamford, CT 06902, more particularly described on Exhibit “A” attached hereto (the “Property”) by virtue of a Deed dated June 6, 1986 and recorded June 6, 1986 in Volume 2787 Page 190 of the Stamford Land Records. On March 14, 2019, Vernie V. Williams promised to pay Fairway Independent Mortgage Corporation up to a maximum principal amount of $517,500.00, as evidenced by a promissory note executed on said date, and payable to the order of Fairway Independent Mortgage Corporation in a principal amount equal to the sum of all loan advances and fees under the terms of said note with interest thereon. On May 19, 2019, by a deed of that date, Recorded in Volume 12110 at Page 297 of the Stamford Land Records, said Vernie V. Williams, to secure said note, mortgaged to Mortgage Electronic Registration Systems, Inc., as nominee for Fairway Independent Mortgage Corporation the premises known as 14 Sherman Street, Stamford, Connecticut, 7 and described in Exhibit A attached hereto and made a part hereof. B&S File No.: 23-27029 FCO 4. Finance of America Reverse LLC (hereinafter “the Plaintiff’) is the current holder of the Note and Mortgage. The Mortgage was assigned to the Plaintiff by assignment from Mortgage Electronic Registration Systems, Inc., as mortgagee, as nominee for Fairway Independent Mortgage Corporation dated July 7, 2023, recorded with the Stamford Land Records in Book 13201 at Page 72. On or before, June 27, 2023, the Plaintiff became and at all times since then has been the party entitled to collect the debt evidenced by said note and is the party entitled to enforce said mortgage. The Plaintiff has complied with any applicable Department of Housing and Urban Development regulations that are a precondition to acceleration of the debt and foreclosure of the mortgage relative to this loan, prior to commencement of the subject action. The unpaid balance due pursuant to the terms of said note is the unpaid principal balance due at time of referral to counsel to begin foreclosure proceedings in the amount of $115,278.71, plus interest, servicing fees allowed by the contracts and the enabling rules and statutes and collection costs, that have not been paid although due and payable. Said note and mortgage are in default because the properly has ceased to be the principal residence of the borrower for reasons other than death. The Plaintiff has caused a Notice of Availability of Emergency Mortgage Assistance (“EMAP”) be sent as required by C.G.S. §§ 8-265cc et seq. Defendant is presently the owner of the Property and, upon information and belief is in possession thereof. 10 The Defendant, The Federal Housing Commissioner, may claim an interest in said premises by virtue of a mortgage in the original principal amount of $517,500.00 dated March 14, 2019, and recorded March 19, 2019 in Volume 12110 at Page 312 of the Stamford Land Records. 11. The following parties claim an interest in the Property prior in right to the interest of Plaintiff. a. Town of Stamford for taxes for any previous year now due and all subsequent years not yet due; Town of Stamford, Water Pollution Control Authority for sewer use charges for the calendar years not yet due; and any previous year now due; and by virtue of a continuing sewer lien dated February 28, 2023 recorded March 2, 2023 in Volume 13141 at Page 216 with the Stamford Land Records; and by virtue of a continuing sewer lien dated August 16, 2023 and recorded August 22, 2023 in Volume 13221 at Page 332 of the Stamford Land Records. C. Stamford Tax District for tax district fees, if applicable. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU: ARE A DEBTOR IN AN ACTIVE BANKRUPTCY CASE; ARE UNDER THE PROTECTION OF A BANKRUPTCY STAY; OR, HAVE RECEIVED A DISCHARGE IN BANKRUPTCY AND YOU HAVE NOT REAFFIRMED THE DEBT, THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT FROM YOU PERSONALLY. WHEREFORE, Plaintiff prays for the following relief: 1 A foreclosure of the mortgage; 2 Immediate possession of the mortgaged premises; The appointment of a receiver to collect the rents and profits accruing from the premises; Monetary damages; Costs of this action; Interest on mortgage debt from date of default; Attorney’s fees; and Such other and further relief as the court may deem just and equitable. Plaintiff, Finance of America Reverse LLC By its Attorney, 405518 Diane S. Summers, Esq. BROCK & SCOTT, PLLC 270 Farmington Avenue Suite 151 Farmington, CT 06032 Telephone: (401) 217-8701 Email: CT_FC_Team@BrockandScott.com Juris No.: 439942 B&S File No.: 23-27029 FCO1 EXHIBIT A EL OF ther with the buildings ford, County of Pairfield and Lot No, 12 as shown and of the Town Clerk being hereby had NORTHERLY: . by Sherman Street, 100: Jand now or Memoli and SOUTHERLY: ‘50 fe formerly part; and WESTERLY: . 100 Jand now or B&S File No.: 23-27029 FCO1 RETURN DATE: NOVEMBER 21, 2023 SUPERIOR COURT JUDICIAL DISTRICT OF STAMFORD-NORWALK AT STAMFORD FINANCE OF AMERICA REVERSE LLC VS. VERNIE V. WILLIAMS, ET AL October_30_, 2023 STATEMENT OF AMOUNT IN DEMAND The amount in demand, exclusive of interest and costs, is greater than Fifteen Thousand. Dollars ($15,000.00). Plaintiff, By its Attorney, 405518 Diane S. Summers, Esq. BROCK & SCOTT, PLLC 270 Farmington Avenue Suite 151 Farmington, CT 06032 Telephone: (401) 217-8701 Email: CT_FC_Team@BrockandScott.com Juris No.: 439942 B&S File No.: 23-27029 FCO1