Document for Massachusetts Housing Finance Agency vs. Velez, Francheska

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                                COMMONWEALTH OF MASSACHUSETTS
                                    SUPERIOR COURT DEPARTMENT
                                                                                                  FILED
Worcester,
                                                           Xx                                    JAN 05 2024
MASSACHUSETTS HOUSING
FINANCE AGENCY

                               Plaintiff,
                                                                                            OL
Vv.                                                                     CIVIL ACTION NO. DYevi7
FRANCHESKA VELEZ,
             Defendant.
                                                           x

        EX PARTE MOTION FOR APPROVAL OF REAL ESTATE ATTACHMENT

          NOW        COMES        the Plaintiff, Massachusetts Housing Finance Agency cMeatonin

by and through its counsel, pursuant to Mass. R. Civ. P. 4.1, and moves this Honorable Court for

an ex parte Order approving                 an attachment in the amount of $22,454.91,      plus interest and

attorney’s fees and costs, of all real property located within the Counties of Worcester and Essex

that are owned by the Defendant, Francheska Velez (“Defendant”), or within which the Defendant

holds any equitable or legal interest.

           In support of this Motion, MassHousing states that there is a reasonable likelihood that it

will recover judgment against the Defendant in an amount equal or greater than the amount of the

requested attachment over and above any liability insurance known or reasonably believed to be

available to satisfy the judgment. Further, the Defendant has listed the property located at 1 Hale

Street, Fitchburg, MA (the “Property”), which is the subject matter of instant action, for sale with

an anticipated purchase price of $340,000.00. It is anticipated that the sale of the Property will not

result in funds sufficient to satisfy the debt secured by the encumbrances on the Property while

also reimbursing MassHousing for funds advanced to the Defendant under the MassDREAMS

program as a result of her breach of the MassDREAMS Pro;                      rant Agreement.

Massachusetts Housing Finance Agency v. Francheska Velez            fat       —x0.N.        +5     sesue Rab
1 Hale Street, Fitchburg, MA
DG&L File No.: 57253                                                y    © 3100p       in        Cortvoow       11,

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