On November 30, 2023 a
Party Statement
was filed
involving a dispute between
Forethought Life Insurance Company,
and
Atlantic Credit & Finance Special Finance Unit, Llc A P O Hsbc Household Finance,
John Doe,
John Doe #1 Through John Doe #12,
Robert Purcell,
for Real Property - Mortgage Foreclosure - Residential
in the District Court of Ulster County.
Preview
FILED: ULSTER COUNTY CLERK 11/30/2023 12:25 PM INDEX NO. EF2023-2892
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 11/30/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ULSTER
Forethought Life Insurance Company Certificate of Merit
Plaintiff(s),
-against- Index No.
Robert Purcell, Atlantic Credit & Finance Special Finance
LLC a/p/o HSBC - Household and "JOHN
Unit, Finance,
#1," #12,"
DOE through "JOHN DOE the last twelve
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 being foreclosed
herein,
Defendant(s).
1. I am an attorney at law duly licensed to practice in the State of New York, and am
affiliated with the law firm ofSheldon May & Associates, P.C., attorney for Plaintiff in this
action.
2. This residential foreclosure action involves a home loan, as such term is defined in Real
Property Actions and Proceedings Law §1304. Upon information and belief, defendant is a
resident of the property subject to foreclosure.
3. I have reviewed the facts of this case and reviewed pertinent documents, including the
mortgage, security agreement and note or bond underlying the mortgage executed by defendant,
all instruments of assignment (if any), and all other instruments of indebtedness including any
modification, extension, and consolidation.
4. I have consulted about the facts of this case with the following representatives of Plaintiff:
Title
5. Upon this review and consultation, to the best of my knowledge, information, and belief, I
that there is a reasonable basis for the commencement of this action, and that Plaintiff is
certify
the creditor entitled to enforce rights under these documents.
6. If applicable, listed in Exhibit A and attached hereto are copies of the following
documents not otherwise included as attachments to the summons and complaint: the mortgage,
security agreement and note or bond underlying the mortgage executed by the defendant; all
instruments of assignment (if any); and any other instrument of indebtedness, including any
modification, extension, and consolidation. (Check box if no documents are attached in Exhibit
A: m.)
7. Listed in Exhibit B and attached hereto are supplemental affidavits attesting that certain
documents as described in paragraph 5 supra are lost, whether by destruction, theft, or otherwise.
(Check box if no documents are attached in Exhibit B: m.)
8. I am aware of my obligations under New York Rules of Professional Cõ+idùct (22
NYCRR Part 1200) and 22 NYCRR Part 130.
Dated: November 20, 2023
Rockville Centre, New York
By: Ted-Eric May, Esq.
1 of 1
Document Filed Date
November 30, 2023
Case Filing Date
November 30, 2023
Category
Real Property - Mortgage Foreclosure - Residential
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