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  • Forethought Life Insurance Company v. Robert Purcell, Atlantic Credit & Finance Special Finance Unit, Llc A/P/O Hsbc Household Finance, John Doe #1 Through John Doe #12, John DoeReal Property - Mortgage Foreclosure - Residential document preview
  • Forethought Life Insurance Company v. Robert Purcell, Atlantic Credit & Finance Special Finance Unit, Llc A/P/O Hsbc Household Finance, John Doe #1 Through John Doe #12, John DoeReal Property - Mortgage Foreclosure - Residential document preview
						
                                

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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