Preview
FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477
NYSCEF DOC. NO. 177 RECEIVED NYSCEF: 04/24/2023
EXHIBIT A
FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477
NYSCEF INDEX NO. EF2022-477
FILED:DOC. NO. 177
MONTGOMERY COUNTY CLERK 02/10/2023 12:56 PM|
RECEIVED NYSCEF: 04/24/2023
NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 02/10/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTYOF MONTGOMERY
-----..-...-----......-----.--..--..-------..-----x
FAIRBRIDGE REAL ESTATE INVESTMENT TRUST,
LLC,
Plaintiff/Petitioner,
- against - Index No. EF2022-477
LITTLE FALLS GARDEN APARTMENTS LLC, et al,
Defendant/Respondent.
--------------------------------------··--··x
NOTICE OF ELECTRONIC FILING
(Mandatory Case)
(Uniform Rule § 202.5-bb)
You have received this Notice because:
1) The Plaintiff/Petitioner, whose name is listed above, has filed this case using the
New York State Courts E-filing system ("NYSCEF"), and
2) You are a Defendant/Respondent (a party) in this case.
" If you are represented by an attorney:
Attorneys"
Give this Notice to your attorney. (Attorneys: see "Information for pg. 2).
" If you are not represented by an attorney:
You will be served with all documents in paper and you must serve and file your
documents in paper, unless you choose to participate in e-filing.
If you choose to participate in e-filing, you must have access to a computer and a
scanner or other device to convert documents into electronic format, a connection
to the internet, and an e-mail address to receive service of documents.
The benefits of participating in e-filing include:
" and your documents
serving filing electronically
" free access to view and print your e-filed documents
" limiting your number of trips to the courthouse
" court fees on-line (credit card
paying any needed)
To register for e-filing or for more information about how e-filing works:
" visit: www.nycourts.gov/efile-unrepresented or
" contact the Clerk's Office or Center at the court where the case was filed. Court
Help
contact information can be found at www.nycourts.gov
Page 1 of 2 6/6/18 EFM-1
FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477
NYSCEF INDEX NO. EF2022-477
FILED:DOC. NO. 177
MONTGOMERY COUNTY CLERK 02/10/2023 12:56 PM|
RECEIVED NYSCEF: 04/24/2023
NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 02/10/2023
To find legal information to help you represent yourself visit www.nycourthelp.gov
Information for Attorneys
(E-filing is Mandatory for Attorneys)
An attorney representing a party who is served with this notice must either:
1) immediately record his or her representation within the e-filed matter on the
NYSCEF site www.nycourts.gov/efile ; or
2) file the Notice of Opt-Out form with the clerk of the court where this action is
pending and serve on all parties. Exemptions from mandatory e-filing are limited to
attorneys who certify in good faith that they lack the computer hardware and/or
scanner and/or internet connection or that they lack (along with all employees subject
to their direction) the knowledge to operate such equipment. [Section 202.5-bb(e)]
For additional information about electronic filing and to create a NYSCEF account, visit the
NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center
(phone: 646-386-3033; e-mail: ny_snef@ny£oo.urtsaov).
Dated: September 13, 2022
Andrew M. Roth, Esq. 333 Earle Ovington Blvd., Suite 601
Name Address
Sahn Ward Braff Koblenz PLLC
Uniondale, New York 11553
Firm Name
(516) 228-1300
Phone
rabiuso@sahnward-com
E-Mail
To: All Defendants
See attached list
Index # Page 2 of 2 6/6/18 EFM-1
FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477
NYSCEF DOC.: NO. 177 INDEX
RECEIVED NO. EF2022-477
NYSCEF: 04/24/2023
[F ILED MONTGOMERY COUNTY CLERK 0 2 /10 / 2 0 2 3 12 : 5 6 PM)
NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 02/10/2023
To Defendants:
LITTLE FALLS GARDEN APARTMENTS LLC
Defendant
c/o Cor Holdings, LLC
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
ROBINHOOD PROPERTIES LLC
Defendant
clo Cor Holdings, LLC
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
BROOKVIEW TOWN HOUSES LLC
Defendant
c/o Cor Holdings, LLC
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
COR HOLDINGS LLC
Defendant
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
DAVID RAVEN
Defendant
133 Main Street
Mountaindale, New York 12763
CARL ORSINI A/K/A CARLOS M. ORSINI
Defendant
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE
Defendant
Harriman Campus Rd.
Albany, NY 12226
GEORGE LUMBER & BUILDING MATERIAL INC.
Defendant
525 E. Mill St.
Little Falls, New York 13365
FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477
NYSCEF INDEX
F ILEDDOC.
: NO. 177
MONTGOMERY COUNTY CLERK 0 2 / 10 / 2 0 2 3 12 : 5 6 PM)
RECEIVED NYSCEF:
NO. 04/24/2023
EF2022-477
NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 02/10/2023
KEY BANK AS SUCCESSOR BY MERGER
TO FIRST NIAGARA BANK, N.A.
Defendant
127 Public Square
Cleveland, OH 44114
FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477
NYSCEF DOC.: NO. 177 INDEX
RECEIVED NO.
NYSCEF: EF2022-477
04/24/2023
F ILED MONTGOMERY COUNTY CLERK 0 2 / 10 / 2 0 23 12 : 5 6 PM|
RECEIy§§g#YfgfEFEF2Md 023
"W2ifEB°:°4TiÈCMERY COUNTY CLERK 09 /13 / 2 0 2 2 0 4 : 11 PM)
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/13/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MONTGOMERY
FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, SUMMONS
LLC F/K/A REALFI REAL ESTATE INVESTMENT
TRUST LLC'
Index No.: EF2022-477
Plaintiff'
Date Filed: 9/13/2022
-against-
Plaintiff designates
LITTLE FALLS GARDEN APARTMENTS LLC, c of a
ROBINHOOD PROPERTIES L.L.C., BROOKVIEW
TOWN HOUSE LLC A/K/A BROOKVIEW TOWN
HOUSES LLC, COR HOLDINGS LLC, DAVID
RAVEN, CARL ORSINI A/K/A CARLOS M. ORSINI,
NEW YORK STATE DEPARTMENT OF TAXATION
AND FINANCE, GEORGE LUMBER & BUILDING
MATERIAL INC., KEYBANK AS SUCCESSOR BY
MERGER TO FIRST NIAGARA BANK, N.A., JOHN
DOE NOS. JOHN D OE CORPORATION NOS. 1-
1-100,
100 and JOHN DOE COMPANY NOS. 1-100,
Defendants.
Doe"
The Names of the "John Defendants Being Fictitions
and Unknown to Plaintiff, the Persons and Firms Intended
Being Those Who May Be in Possession or, or May have
Possessory, Lien or Other Interests in, the Premises
Herein Described.
TO THE ABOVE-NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED to answer the Verified Complaint in this action
and to serve a copy of your Verified Answer, or, if the Verified Complaint is not served with this
Summons, to serve a Notice of Appearance, on the Plaintiff's Attorneys within twenty (20) days
after the service of this Summons, exclusive of the day of service (or within thirty (30) days after
the service is complete if this Summons is not personally delivered to you within the State of
New York); and in case of your failure to appear or answer, judgment will be taken against you
by default for the relief demanded in the Verified Complaint.
1 of 21
FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477
NYSCEF INDEX
F ILEDDOC.
:
NO. 177
MONTGOMERY COUNTY CLERK 0 2 /10 / 2 0 2 3 12 : 5 6 PM|
RECEIVED NYSCEF:
NO. 04/24/2023
EF2022-477
N RECEIy§§g1JWE%F2(6 d /9023
C.M T ÔMERY COUNTY CLERK 0 9 /13 / 2 02 2 0 4 : 11 PM)
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/13/2022
Montgomery County is designated as the venue of this proceeding on the basis that it is
the County where the subject property is located pursuant to CPLR § 507.
Dated: Uniondale, New York SAHN WARD BRAFF KOBLENZ PLLC
September 7, 2022 Co-Attorneys for Plaintiff Fairbridge Real Estate
Investment Trust, LLC f/k/a Realfi Real Estate
Investment Trust LC
By:
JON/A. WARD, ESQ
ANDREW M. ROTH, ESQ.
333 Earle Ovington Boulevard, Suite 601
Uniondale, New York 11530
(516) 228-1300
LAW OFFICES OF JOHN R. MERTZ
Co-Attorneys for Plaintiff Fairbridge Real Estate
Investment Trust, LLC f/k/a Realfi Real Estate
Investment Trust LLC
P.O. Box 7118
The Capitol
Albany, NY 12224-0118
TO: LITTLE FALLS GARDEN APARTMENTS LLC
Defendant
c/o Cor Holdings, LLC
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
ROBINHOOD PROPERTIES LLC
Defendant
c/o Cor Holdings, LLC
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
BROOKVIEW TOWN HOUSES LLC
Defendant
c/o Cor Holdings, LLC
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
2
2 of 21
FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477
NYSCEF INDEX NO. EF2022-477
F ILEDDOC.
: NO. 177
MONTGOMERY COUNTY CLERK 0 2 / 10 / 2 0 2 3 12 : 5 6 PM|
RECEIVED NYSCEF: 04/24/2023
023
ED : MÓNTÒPMERY F2
COUNTY CLERK 0 9 / 13 / 2 0 2 2 0 4 : 11 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/13/2022
COR HOLDINGS LLC
Defendant
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
DAVID RAVEN
Defendant
133 Main Street
Mountaindale, New York 12763
CARL ORSINI A/K/A CARLOS M. ORSINI
Defendant
200 South Middle Neck Road, Unit 5
Great Neck, New York 11021
NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE
Defendant
Harriman Campus Rd.
Albany, NY 12226
GEORGE LUMBER & BUILDING MATERIAL INC.
Defendant
525 E. Mill St.
Little Falls, New York 13365
KEY BANK AS SUCCESSOR BY MERGER
TO FIRST NIAGARA BANK, N.A.
Defendant
127 Public Square
Cleveland, OH 44114
. . . . .
3
3 of 21
FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477
NYSCEF DOC. NO.
FILED:
177
MONTGOMERY COUNTY CLERK 02 /10 /2023 12 : 5 6
RECEIVED NYSCEF:
INDEX NO. 04/24/2023
EF2022-477
PM|
N E 023
C.1ÊÓNTUCMERY COUNTY CLERK 09/13/2022 04:11 RECEIM 2 Ó Ó
PM|
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/13/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MONTGOMERY
FAIRBRIDGE REAL ESTATE INVESTMENT TRUST,
LLC F/K/A REALFI REAL ESTATE INVESTMENT
TRUST LLC, VERIFIED
COMPLAINT
Plaintiff,
Index No.: EF2022-477
-against-
LITTLE FALLS GARDEN APARTMENTS LLC,
ROBINHOOD PROPERTIES L.L.C., BROOKVIEW
TOWN HOUSE LLC A/K/A BROOKVIEW TOWN
HOUSES LLC, COR HOLDINGS LLC, DAVID RAVEN,
CARL ORSINI A/K/A CARLOS M. ORSINI, NEW YORK
STATE DEPARTMENT OF TAXATION AND FINANCE,
GEORGE LUMBER & BUILDING MATERIAL INC.,
KEYBANK AS SUCCESSOR BY MERGER TO FIRST
NIAGARA BANK, N.A., JOHN DOE NOS. 1-100, JOHN
DOE CORPORATION NOS. 1-100 and JOHN DOE
COMPANY NOS. 1-100,
Defendants.
The Names Doe"
of the "John Defendants Being Fictitious and
Unknown to Plaintiff, the Persons and Firms Intended Being
Those Who May Be in Possession or, or May have Possessory,
Lien or Other Interests in, the Premises Herein Described.
Plaintiff, FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, LLC F/K/A
REALFI REAL ESTATE INVESTMENT TRUST, LLC (the "Plaintiff"), by its attorneys,
SAHN WARD BRAFF KOBLENZ PLLC, as and for its Verified Complaint against the
above-named Defendants, respectfully alleges as follows:
The Parties
1. Plaintiff is and, at all relevant times hereinafter mentioned, was a limited liability
company organized and existing under the laws of the State of Delaware, with an address at 707
4 of 21
FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477
NYSCEF DOC.: NO. 177 INDEX
RECEIVED NO. EF2022-477
NYSCEF: 04/24/2023
F ILED MONTGOMERY COUNTY CLERK 0 2 / 10 / 2 0 2 3 12 : 5 6 PM|
RECEI E 023
F2
D 1 PÈ4T(ÎÔMERY COUNTY CLERK 0 9 / 13 / 2 0 2 2 0 4 : 11 PM|
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/13/2022
Westchester Avenue, Suite 304, White Plains, New York 10604, and is the lawful owner and
herein.1
holder of the Consolidated Mortgage (hereinafter defined) being foreclosed
2. Defendant, Little Falls Garden Apartments LLC ("Little Falls"), is and, at all
relevant times hereinafter mentioned, was a New York limited liability company organized and
existing under the laws of the State of New York, with an address at c/o Cor Holdings, LLC, 200
South Middle Neck Road, Unit 5, Great Neck, New York 11021.
3. Little Falls is the owner of record of a parcel of real property located in the
County of Herkimer, City of Little Falls, identified as Section 115.45, Block 1, Lot 2.2 on the
Tax Map of Herkimer County, known as and located at 759 East Monroe Street Extension, Little
Falls, New York, with appurtenances thereto and improvements thereon, all as more specifically
described "A" (the "Little Property").
in Schedule annexed hereto Falls
4. Defendant, Robinhood Properties L.L.C. ("Robinhood"), is and, at all relevant
times hereinafter mentioned, was a New York limited liability company organized and existing
under the laws of the State of New York with an address at c/o Cor Holdings, LLC, 200 South
Middle Neck Road, Unit 5, Great Neck, New York 11021.
5. Robinhood is the owner of record of the parcel of real property located in the
County of Montgomery, Town of Mohawk, Village of Fonda, identified as Section 35.12, Block
3, Lot 23 on the Tax of Montgomery County, known as and located at 60 East Main Street,
Map
Mohawk, New York, with appurtenances thereto and improvements thereon, all as more
"A" Property").
specifically described in Schedule annexed hereto (the "Robinhood
6. Defendant, Brookview Town House LLC a/k/a Brookview Town Houses LLC
("Brookview"), is and, at all relevant times hereinafter mentioned, was a limited liability
I
As originally formed on January 2, 2020, the name of the Plaintiff was Tradex Real Estate Investment
Trust LLC.
The Plaintiff's name was changed on June 1, 2020, to RealFi Real Estate Investment Trust LLC and
changed again on March 21, 2022 to Fairbridge Real Estate Investment Trust, LLC.
2
5 of 21
FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477
NYSCEF DOC.: NO.
(F ILED
177
MONTGOMERY COUNTY CLERK 0 2 / 10
RECEIVED NYSCEF:
INDEX NO. 04/24/2023
EF2022-477
/ 2 O2 3 12 : 5 6 PM|
RECEI EFMF2HÚ 023
COUNTY
Preview
FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477 NYSCEF DOC. NO. 177 RECEIVED NYSCEF: 04/24/2023 EXHIBIT A FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477 NYSCEF INDEX NO. EF2022-477 FILED:DOC. NO. 177 MONTGOMERY COUNTY CLERK 02/10/2023 12:56 PM| RECEIVED NYSCEF: 04/24/2023 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 02/10/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTYOF MONTGOMERY -----..-...-----......-----.--..--..-------..-----x FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, LLC, Plaintiff/Petitioner, - against - Index No. EF2022-477 LITTLE FALLS GARDEN APARTMENTS LLC, et al, Defendant/Respondent. --------------------------------------··--··x NOTICE OF ELECTRONIC FILING (Mandatory Case) (Uniform Rule § 202.5-bb) You have received this Notice because: 1) The Plaintiff/Petitioner, whose name is listed above, has filed this case using the New York State Courts E-filing system ("NYSCEF"), and 2) You are a Defendant/Respondent (a party) in this case. " If you are represented by an attorney: Attorneys" Give this Notice to your attorney. (Attorneys: see "Information for pg. 2). " If you are not represented by an attorney: You will be served with all documents in paper and you must serve and file your documents in paper, unless you choose to participate in e-filing. If you choose to participate in e-filing, you must have access to a computer and a scanner or other device to convert documents into electronic format, a connection to the internet, and an e-mail address to receive service of documents. The benefits of participating in e-filing include: " and your documents serving filing electronically " free access to view and print your e-filed documents " limiting your number of trips to the courthouse " court fees on-line (credit card paying any needed) To register for e-filing or for more information about how e-filing works: " visit: www.nycourts.gov/efile-unrepresented or " contact the Clerk's Office or Center at the court where the case was filed. Court Help contact information can be found at www.nycourts.gov Page 1 of 2 6/6/18 EFM-1 FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477 NYSCEF INDEX NO. EF2022-477 FILED:DOC. NO. 177 MONTGOMERY COUNTY CLERK 02/10/2023 12:56 PM| RECEIVED NYSCEF: 04/24/2023 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 02/10/2023 To find legal information to help you represent yourself visit www.nycourthelp.gov Information for Attorneys (E-filing is Mandatory for Attorneys) An attorney representing a party who is served with this notice must either: 1) immediately record his or her representation within the e-filed matter on the NYSCEF site www.nycourts.gov/efile ; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is pending and serve on all parties. Exemptions from mandatory e-filing are limited to attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or internet connection or that they lack (along with all employees subject to their direction) the knowledge to operate such equipment. [Section 202.5-bb(e)] For additional information about electronic filing and to create a NYSCEF account, visit the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone: 646-386-3033; e-mail: ny_snef@ny£oo.urtsaov). Dated: September 13, 2022 Andrew M. Roth, Esq. 333 Earle Ovington Blvd., Suite 601 Name Address Sahn Ward Braff Koblenz PLLC Uniondale, New York 11553 Firm Name (516) 228-1300 Phone rabiuso@sahnward-com E-Mail To: All Defendants See attached list Index # Page 2 of 2 6/6/18 EFM-1 FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477 NYSCEF DOC.: NO. 177 INDEX RECEIVED NO. EF2022-477 NYSCEF: 04/24/2023 [F ILED MONTGOMERY COUNTY CLERK 0 2 /10 / 2 0 2 3 12 : 5 6 PM) NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 02/10/2023 To Defendants: LITTLE FALLS GARDEN APARTMENTS LLC Defendant c/o Cor Holdings, LLC 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 ROBINHOOD PROPERTIES LLC Defendant clo Cor Holdings, LLC 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 BROOKVIEW TOWN HOUSES LLC Defendant c/o Cor Holdings, LLC 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 COR HOLDINGS LLC Defendant 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 DAVID RAVEN Defendant 133 Main Street Mountaindale, New York 12763 CARL ORSINI A/K/A CARLOS M. ORSINI Defendant 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE Defendant Harriman Campus Rd. Albany, NY 12226 GEORGE LUMBER & BUILDING MATERIAL INC. Defendant 525 E. Mill St. Little Falls, New York 13365 FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477 NYSCEF INDEX F ILEDDOC. : NO. 177 MONTGOMERY COUNTY CLERK 0 2 / 10 / 2 0 2 3 12 : 5 6 PM) RECEIVED NYSCEF: NO. 04/24/2023 EF2022-477 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 02/10/2023 KEY BANK AS SUCCESSOR BY MERGER TO FIRST NIAGARA BANK, N.A. Defendant 127 Public Square Cleveland, OH 44114 FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477 NYSCEF DOC.: NO. 177 INDEX RECEIVED NO. NYSCEF: EF2022-477 04/24/2023 F ILED MONTGOMERY COUNTY CLERK 0 2 / 10 / 2 0 23 12 : 5 6 PM| RECEIy§§g#YfgfEFEF2Md 023 "W2ifEB°:°4TiÈCMERY COUNTY CLERK 09 /13 / 2 0 2 2 0 4 : 11 PM) NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/13/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MONTGOMERY FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, SUMMONS LLC F/K/A REALFI REAL ESTATE INVESTMENT TRUST LLC' Index No.: EF2022-477 Plaintiff' Date Filed: 9/13/2022 -against- Plaintiff designates LITTLE FALLS GARDEN APARTMENTS LLC, c of a ROBINHOOD PROPERTIES L.L.C., BROOKVIEW TOWN HOUSE LLC A/K/A BROOKVIEW TOWN HOUSES LLC, COR HOLDINGS LLC, DAVID RAVEN, CARL ORSINI A/K/A CARLOS M. ORSINI, NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE, GEORGE LUMBER & BUILDING MATERIAL INC., KEYBANK AS SUCCESSOR BY MERGER TO FIRST NIAGARA BANK, N.A., JOHN DOE NOS. JOHN D OE CORPORATION NOS. 1- 1-100, 100 and JOHN DOE COMPANY NOS. 1-100, Defendants. Doe" The Names of the "John Defendants Being Fictitions and Unknown to Plaintiff, the Persons and Firms Intended Being Those Who May Be in Possession or, or May have Possessory, Lien or Other Interests in, the Premises Herein Described. TO THE ABOVE-NAMED DEFENDANTS: YOU ARE HEREBY SUMMONED to answer the Verified Complaint in this action and to serve a copy of your Verified Answer, or, if the Verified Complaint is not served with this Summons, to serve a Notice of Appearance, on the Plaintiff's Attorneys within twenty (20) days after the service of this Summons, exclusive of the day of service (or within thirty (30) days after the service is complete if this Summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the Verified Complaint. 1 of 21 FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477 NYSCEF INDEX F ILEDDOC. : NO. 177 MONTGOMERY COUNTY CLERK 0 2 /10 / 2 0 2 3 12 : 5 6 PM| RECEIVED NYSCEF: NO. 04/24/2023 EF2022-477 N RECEIy§§g1JWE%F2(6 d /9023 C.M T ÔMERY COUNTY CLERK 0 9 /13 / 2 02 2 0 4 : 11 PM) NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/13/2022 Montgomery County is designated as the venue of this proceeding on the basis that it is the County where the subject property is located pursuant to CPLR § 507. Dated: Uniondale, New York SAHN WARD BRAFF KOBLENZ PLLC September 7, 2022 Co-Attorneys for Plaintiff Fairbridge Real Estate Investment Trust, LLC f/k/a Realfi Real Estate Investment Trust LC By: JON/A. WARD, ESQ ANDREW M. ROTH, ESQ. 333 Earle Ovington Boulevard, Suite 601 Uniondale, New York 11530 (516) 228-1300 LAW OFFICES OF JOHN R. MERTZ Co-Attorneys for Plaintiff Fairbridge Real Estate Investment Trust, LLC f/k/a Realfi Real Estate Investment Trust LLC P.O. Box 7118 The Capitol Albany, NY 12224-0118 TO: LITTLE FALLS GARDEN APARTMENTS LLC Defendant c/o Cor Holdings, LLC 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 ROBINHOOD PROPERTIES LLC Defendant c/o Cor Holdings, LLC 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 BROOKVIEW TOWN HOUSES LLC Defendant c/o Cor Holdings, LLC 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 2 2 of 21 FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477 NYSCEF INDEX NO. EF2022-477 F ILEDDOC. : NO. 177 MONTGOMERY COUNTY CLERK 0 2 / 10 / 2 0 2 3 12 : 5 6 PM| RECEIVED NYSCEF: 04/24/2023 023 ED : MÓNTÒPMERY F2 COUNTY CLERK 0 9 / 13 / 2 0 2 2 0 4 : 11 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/13/2022 COR HOLDINGS LLC Defendant 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 DAVID RAVEN Defendant 133 Main Street Mountaindale, New York 12763 CARL ORSINI A/K/A CARLOS M. ORSINI Defendant 200 South Middle Neck Road, Unit 5 Great Neck, New York 11021 NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE Defendant Harriman Campus Rd. Albany, NY 12226 GEORGE LUMBER & BUILDING MATERIAL INC. Defendant 525 E. Mill St. Little Falls, New York 13365 KEY BANK AS SUCCESSOR BY MERGER TO FIRST NIAGARA BANK, N.A. Defendant 127 Public Square Cleveland, OH 44114 . . . . . 3 3 of 21 FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477 NYSCEF DOC. NO. FILED: 177 MONTGOMERY COUNTY CLERK 02 /10 /2023 12 : 5 6 RECEIVED NYSCEF: INDEX NO. 04/24/2023 EF2022-477 PM| N E 023 C.1ÊÓNTUCMERY COUNTY CLERK 09/13/2022 04:11 RECEIM 2 Ó Ó PM| NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/13/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MONTGOMERY FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, LLC F/K/A REALFI REAL ESTATE INVESTMENT TRUST LLC, VERIFIED COMPLAINT Plaintiff, Index No.: EF2022-477 -against- LITTLE FALLS GARDEN APARTMENTS LLC, ROBINHOOD PROPERTIES L.L.C., BROOKVIEW TOWN HOUSE LLC A/K/A BROOKVIEW TOWN HOUSES LLC, COR HOLDINGS LLC, DAVID RAVEN, CARL ORSINI A/K/A CARLOS M. ORSINI, NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE, GEORGE LUMBER & BUILDING MATERIAL INC., KEYBANK AS SUCCESSOR BY MERGER TO FIRST NIAGARA BANK, N.A., JOHN DOE NOS. 1-100, JOHN DOE CORPORATION NOS. 1-100 and JOHN DOE COMPANY NOS. 1-100, Defendants. The Names Doe" of the "John Defendants Being Fictitious and Unknown to Plaintiff, the Persons and Firms Intended Being Those Who May Be in Possession or, or May have Possessory, Lien or Other Interests in, the Premises Herein Described. Plaintiff, FAIRBRIDGE REAL ESTATE INVESTMENT TRUST, LLC F/K/A REALFI REAL ESTATE INVESTMENT TRUST, LLC (the "Plaintiff"), by its attorneys, SAHN WARD BRAFF KOBLENZ PLLC, as and for its Verified Complaint against the above-named Defendants, respectfully alleges as follows: The Parties 1. Plaintiff is and, at all relevant times hereinafter mentioned, was a limited liability company organized and existing under the laws of the State of Delaware, with an address at 707 4 of 21 FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477 NYSCEF DOC.: NO. 177 INDEX RECEIVED NO. EF2022-477 NYSCEF: 04/24/2023 F ILED MONTGOMERY COUNTY CLERK 0 2 / 10 / 2 0 2 3 12 : 5 6 PM| RECEI E 023 F2 D 1 PÈ4T(ÎÔMERY COUNTY CLERK 0 9 / 13 / 2 0 2 2 0 4 : 11 PM| NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/13/2022 Westchester Avenue, Suite 304, White Plains, New York 10604, and is the lawful owner and herein.1 holder of the Consolidated Mortgage (hereinafter defined) being foreclosed 2. Defendant, Little Falls Garden Apartments LLC ("Little Falls"), is and, at all relevant times hereinafter mentioned, was a New York limited liability company organized and existing under the laws of the State of New York, with an address at c/o Cor Holdings, LLC, 200 South Middle Neck Road, Unit 5, Great Neck, New York 11021. 3. Little Falls is the owner of record of a parcel of real property located in the County of Herkimer, City of Little Falls, identified as Section 115.45, Block 1, Lot 2.2 on the Tax Map of Herkimer County, known as and located at 759 East Monroe Street Extension, Little Falls, New York, with appurtenances thereto and improvements thereon, all as more specifically described "A" (the "Little Property"). in Schedule annexed hereto Falls 4. Defendant, Robinhood Properties L.L.C. ("Robinhood"), is and, at all relevant times hereinafter mentioned, was a New York limited liability company organized and existing under the laws of the State of New York with an address at c/o Cor Holdings, LLC, 200 South Middle Neck Road, Unit 5, Great Neck, New York 11021. 5. Robinhood is the owner of record of the parcel of real property located in the County of Montgomery, Town of Mohawk, Village of Fonda, identified as Section 35.12, Block 3, Lot 23 on the Tax of Montgomery County, known as and located at 60 East Main Street, Map Mohawk, New York, with appurtenances thereto and improvements thereon, all as more "A" Property"). specifically described in Schedule annexed hereto (the "Robinhood 6. Defendant, Brookview Town House LLC a/k/a Brookview Town Houses LLC ("Brookview"), is and, at all relevant times hereinafter mentioned, was a limited liability I As originally formed on January 2, 2020, the name of the Plaintiff was Tradex Real Estate Investment Trust LLC. The Plaintiff's name was changed on June 1, 2020, to RealFi Real Estate Investment Trust LLC and changed again on March 21, 2022 to Fairbridge Real Estate Investment Trust, LLC. 2 5 of 21 FILED: MONTGOMERY COUNTY CLERK 04/24/2023 04:56 PM INDEX NO. EF2022-477 NYSCEF DOC.: NO. (F ILED 177 MONTGOMERY COUNTY CLERK 0 2 / 10 RECEIVED NYSCEF: INDEX NO. 04/24/2023 EF2022-477 / 2 O2 3 12 : 5 6 PM| RECEI EFMF2HÚ 023 COUNTY