Preview
FILED: QUEENS COUNTY CLERK 12/27/2023 01:32 PM INDEX NO. 722924/2023
NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 12/27/2023
EXHIBIT B
FILED: QUEENS COUNTY CLERK 12/27/2023 01:32 PM INDEX NO. 722924/2023
NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 12/27/2023
IN THE MATTER OF THE ESTATE OF MARIA MOUNDRAKIS
AFFIDAVIT OF HEIRSHIP
STATE OF NEW YORK, COUNTY OF SUFFOLK ss.:
The undersigned, being duly sworn, deposes and says: deponent is not a party herein, is over the age of
18 years, and resides in Suffolk County, New York.
Your deponent has been charged by Friedman Vartolo, LLP. with locating the lawful heirs of Maria
Moundrakis. The following searches represent the diligence performed in order to locate said heirs.
On 07/13/2023, your deponent received a previously obtained death certificate for Maria Moundrakis.
The document marks the aforementioned individual's date of death as: August 26, 2020. The informant
29th
listed on the death certificate is George Moundrakis, her son, located at the address of: 3072
Astoria, New York 11102.
(See Exhibit 1)
On 07/13/2023, your deponent conducted an online search using google.com for Maria Moundrakis
Obituary using the search term Maria Moundrakis Obituary. Said search returned a link to
billiongraves.com for Maria Moundrakis indicating her date of death as August 26, 2020. No surviving
relatives were named on said website.
(See Exhibit 2)
On 07/13/2023, your deponent conducted a Tracers Premium People Search for Maria Moundrakis using
her social security number in order to determine her last known address. Said search returned last known
29th 29th
addresses of: 3072 Street, Apt. 2, Astoria, New York 11102; 3072 Street, Astoria, New York11102;
3513 Ditmars Boulevard, Long island City, New York 11005; and 4515 State Route 30, Middleburgh, New
York 12112.
(See Exhibit 3)
On 07/13/2023, your deponent conducted a Tracers Death Records Search for Maria Moundrakis using
her social security number. Said search returned no record of death for Maria Moundrakis.
(See Exhibit 4)
On 07/13/2023, your deponent conducted an IRBsearch Basic Person Search for Maria Moundrakis using
her social security number in order to determine her last known address. Said search returned last known
29th
addresses of: 3072 Street, Apt. 2, Astoria, New York 11102; 4515 State Route 30, Middleburgh, New
20th
York 12212; P.O. Box 379, Middleburgh, New York12122;3601 ÂVe n ue, AstOria, New York11105.
(See Exhibit 5)
Friedman Vartolo, LLP, 85 Broad Street, Ste. 501, New York, NY 10004 Ph.212.471.5100 Fax. 212.471.5150
FILED: QUEENS COUNTY CLERK 12/27/2023 01:32 PM INDEX NO. 722924/2023
NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 12/27/2023
On 07/13/2023, your deponent conducted an IRBsearch Death Records Search for Maria Moundrakis
using her social security number. Said search returned no record of death for Maria Moundrakis.
(See Exhibit 6)
On 07/13/2023, your deponent conducted an IRBsearch Comprehensive Report for Maria Moundrakis in
order to locate any possible surviving relatives of the decedent. Said search returned possible relatives of:
George Michael Moundrakis, Anastasia Orfanos, Konstantinos B. Soukeras, and Niki Soukeras.
(See Exhibit 7)
On 07/13/2023, your deponent conducted an online search using websurrogates.nycourts.gov for Maria
Moundrakis using the search terms Maria Moundrakis and Queens County Surrogate's Court in order to
locate any information regarding Maria Moundrakis and lawful heirs. Said search returned a Probate
Proceeding for Maria Moundrakis a/k/a Maria Moundrakis-Flosses; Estate File 2022-1838; with a filed
Petition for Probate and Letters of Testamentary. Said Petition states that Maria Moundrakis a/k/a Maria
Moundrakis-Flossos is survived by her three children: George Moundrakis, Konstantinos Soukeras, and
Niki Soukeras. Additionally, a Will was filed translated from Greek stating the following "after my death,
Soukeras."
my property devolves to my children, George Moundrakis, Niki Soukeras, and Konstantinos
(See Exhibit 8)
On 08/03/2023, your deponent conducted a TLO Skip Trace Search for Maria Moundrakis using her social
security number in order to determine her last known address. Said search returned last known addresses
29th 29th
of: 3072 Street, Apt. 1, Astoria, New York 11102; 3072 Street, Apt. 2, Astoria, New York 11102;
29th
and 3072 Street, Astoria, New York 11102.
(See Exhibit 9)
George Moundrakis, Surviving Issue, Son
On 07/13/2023, your deponent conducted a TLO Skip Trace Search for George Moundrakis using the
search terms George Moundrakis and Astoria, New York 11102 in order to determine his last known
29th
address. Said search returned a last known address of: 3072 Street, Apt. 2, Astoria, New York 11102.
(See Exhibit 10)
On 07/13/2023, your deponent conducted a Tracers Premium People Search for George Moundrakis using
his social security number in order to determine his last known address. Said search returned a last known
29th
address of: 3072 Street, Apt. 2, AStOria, New York 11102.
(See Exhibit 11)
On 07/13/2023, your deponent conducted a Tracers Death Records Search for George Moundrakis using
his social security number. Said search returned no record of death for George Moundrakis.
(See Exhibit 12)
On 07/13/2023, your deponent conducted an IRBsearch Basic Person Search for George Moundrakis using
his social security number in order to determine his last known address. Said search returned a last known
29th
address of: 3072 Street, Apt. 2, Astoria, New York 11102.
(See Exhibit 13)
FILED: QUEENS COUNTY CLERK 12/27/2023 01:32 PM INDEX NO. 722924/2023
NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 12/27/2023
On 07/13/2023, your deponent conducted an IRBsearch Death Records Search for George Moundrakis
using his social security number. Said search returned no record of death for George Moundrakis.
(See Exhibit 14)
On 07/13/2023, your deponent conducted an IRBsearch People at Work Search for George Moundrakis
using his social security number. Said search returned a record of employment for George Michael
Moundrakis at NY Fine Furniture.
(See Exhibit 15)
On 07/13/2023, your deponent conducted a TLO Social Media Comprehensive Report for George
Moundrakis using the search terms George Moundrakis, his date of birth: July 4, 1978, and Astoria, New
York 11102. Said search returned a Facebook account for George Moundrakis. On 07/18/2023, at 5:09pm
your deponent sent a message with attached copies of the Family Tree Affidavit and Affidavit of Heirship
to George Moundrakis via his Facebook account. To-date, no response has been received.
(See Exhibit 16)
On 07/13/2023, your deponent conducted an online obituary search using google.com for George
Moundrakis using the search term George Moundrakis Obituary. Said search returned no obituary record
for George Moundrakis.
(See Exhibit 17)
On 07/13/2023, your deponent conducted an online search using nysdoccslookup.doccs.ny.gov for
George Moundrakis in order to determine if he is currently incarcerated in the New York State Department
of Corrections system. Said search returned no individual on file bearing the name: Moundrakis.
(See Exhibit 18)
On 07/13/2023, your deponent conducted an online search using bop.gov for George Moundrakis in order
to determine if he is currently incarcerated in the Federal Bureau of Prisons system. Said search returned
no results found for George Moundrakis.
(See Exhibit 19)
On 07/13/2023, your deponent conducted a search on the New York State Department of Motor Vehicles
website for George Moundrakis. Said search returned one match to the name George Moundrakis. Said
29d'
address listed on the Department of Motor Vehicles Records is: 3072 Street, Apt. 2, Astoria, New York
11102.
(See Exhibit 20)
On 07/13/2023, your deponent conducted a search with the Department of Defense Manpower Data
Center to verify if George Moundrakis is an active military member. Said search returned that George
Moundrakis is not currently active in the military.
(See Exhibit 21)
FILED: QUEENS COUNTY CLERK 12/27/2023 01:32 PM INDEX NO. 722924/2023
NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 12/27/2023
On 07/13/2023, your deponent conducted an online search using websurrogates.nycourts.gov for George
Moundrakis using the search term George Moundrakis and 0.ueens County Surrogate's Court in order to
locate any information regarding George Moundrakis and lawful heirs. Said search returned no estate
records found for heir, George Moundrakis.
(See Exhibit 22)
On 07/18/2023, your deponent made a formal request to the United States Post Office located at Astoria,
New York 11102 by submitting a Request for Change of Address or Boxholder Information needed for
Service of Legal Process upon George Moundrakis. Said search returned no change of address on file.
(See Exhibit 23)
On 07/18/2023, your deponent conducted a search with the Board of Elections in the City of New York for
George Moundrakis. To-date, no response has been received.
On 08/03/2023, your deponent conducted an IRBsearch Voter Registration Search for George Moundrakis
using his social security number. Said search returned an active voter registration for George Moundrakis
29th
at the address of: 3072 Street, Apt. 2, Astoria, New York 11102.
(See Exhibit 24)
Konstantinos Soukeras, Surviving Issue, Son
On 07/13/2023, your deponent conducted a TLO Skip Trace Search for Konstantinos Soukeras using the
search term Konstantinos Soukeras and Astoria, New York in order to determine his last known address.
360120th
Said search returned a last known address of: Road, Astoria, New York 11105.
(See Exhibit 25)
On 07/13/2023, your deponent conducted a Tracers Premium People Search for Konstantinos Soukeras
using his social security number in order to determine his last known address. Said search returned a last
20th
known address of: 3601 Road Floor 1, Astoria, New York 11105.
(See Exhibit 26)
On 07/13/2023, your deponent conducted a Tracers Death Records Search for Konstantinos Soukeras
using his social security number. Said search returned no record of death for Konstantinos Soukeras.
(See Exhibit 27)
On 07/13/2023, your deponent conducted an IRBsearch Basic Person Search for Konstantinos Soukeras
using his social security number in order to determine his last known address. Said search returned a last
20th
known address of: 3601 Road 1, Astoria, New York 11105.
(See Exhibit 28)
On 07/13/2023, your deponent conducted an IRBsearch Death Records Search for Konstantinos Soukeras
using his social security number. Said search returned no record of death for Konstantinos Soukeras.
(See Exhibit 29)
FILED: QUEENS COUNTY CLERK 12/27/2023 01:32 PM INDEX NO. 722924/2023
NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 12/27/2023
On 07/13/2023, your deponent conducted an IRBsearch People at Work Search for Konstantinos Soukeras
using his social security number. Said search returned records of employment for Kostas Soukeras at Saint
Demetrios Lower Elementary School; Saint Demetrios Astoria Schooh and Saint Demetrios Cathedral.
(See Exhibit 30)
On 07/13/2023, your deponent conducted a TLO Social Media Comprehensive Report for Konstantinos
Soukeras using the search terms Konstantinos Soukeras, his date of birth: June 4, 1986, and Astoria, New
York 11102. Said search returned Facebook accounts and a Instagram account for Konstantinos Soukeras.
On 07/18/2023, at 5:08pm, your deponent sent a message with attached copies of the Family Tree
Affidavit and Affidavit of Heirship to Konstantino Soukeras via his Facebook account. To-date, no response
has been received. On 07/18/2023, at 5:19pm your deponent located three (3) possible Instagram
accounts matching the name: Konstantinos Soukeras. Your deponent was unable to message any of the
said accounts because there is no private messaging system/application to do so.
(See Exhibit 31)
On 07/13/2023, your deponent conducted an online obituary search using google.com for Konstantinos
Soukeras using the search term Konstantinos Soukeras Obituary. Said search returned no obituary record
for Konstantinos Soukeras.
(See Exhibit 32)
On 07/13/2023, your deponent conducted an online search using nysdoccslookup.doccs.ny.gov for
Konstantinos Soukeras in order to determine if he is currently incarcerated in the New York State
Department of Corrections system. Said search returned no individual on file bearing the name: Soukeras.
(See Exhibit 33)
On 07/13/2023, your deponent conducted an online search using bop.gov for Konstantinos Soukeras in
order to determine if he is currently incarcerated in the Federal Bureau of Prisons system. Said search
returned no results found for Konstantinos Soukeras.
(See Exhibit 34)
On 07/13/2023, your deponent conducted a search on the New York State Department of Motor Vehicles
"no-hit"
website for Konstantinos Soukeras. Said search returned resulted in a condition.
(See Exhibit 35)
On 07/13/2023, your deponent conducted a search with the Department of Defense Manpower Data
Center to verify if Konstantinos Soukeras is an active military member. Said search returned that
Konstantinos Soukeras is not currently active in the military.
(See Exhibit 36)
On 07/13/2023, your deponent conducted an online search using websurrogates.nycourts.gov for
Konstantinos Soukeras using the search term Konstantinos Soukeras and 0.ueens County Surrogate's
Court in order to locate any information regarding Konstantinos Soukeras and lawful heirs. Said search
returned no records found for heir, Konstantinos Soukeras.
(See Exhibit 37)
FILED: QUEENS COUNTY CLERK 12/27/2023 01:32 PM INDEX NO. 722924/2023
NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 12/27/2023
On 07/18/2023, your deponent made a formal request to the United States Post Office located at Astoria,
New York 11105 by submitting a Request for Change of Address or Boxholder Information needed for
Service of Legal Process upon Konstantinos Soukeras. Said search returned no change of address on file.
(See Exhibit 38)
On 07/18/2023, your deponent made a formal request to the United States Post Office located at Astoria,
New York 11105 by submitting a Request for Change of Address or Boxholder Information needed for
Service of Legal Process upon Konstantinos Soukeras. Said search returned no change of address on file.
(See Exhibit 39)
On 07/18/2023, your deponent conducted a search with the Board of Elections in the City of New York for
Konstantinos Soukeras. To-date, no response has been received.
On 08/03/2023, your deponent conducted an IRBsearch Voter Registration Search for Konstantinos
Soukeras using his social security number. Said search returned an active voter registration for
360120th
Konstantinos Soukeras a/k/a/ K. Soukeras at the address of: Road, Astoria, New York 11105.
(See Exhibit 40)
Niki Soukeras, Surviving Issue, Daughter
On 07/13/2023, your deponent conducted a TLO Skip Trace Search for Niki Soukeras using the search
terms Niki M. Soukeras and Astoria, New York 11102 in order to determine her last known address. Said
50th
search returned a last known address of: 2558 Street, Woodside, New York 11377.
(See Exhibit 41)
On 07/13/2023, your deponent conducted a Tracers Premium People Search for Niki Soukeras using her
social security number in order to determine her last known address. Said search returned a last known
50th
address of: 2S58 Street, Woodside, New York 11377.
(See Exhibit 42)
On 07/13/2023, your deponent conducted a Tracers Death Records Search for Niki Soukeras using her
social security number. Said search returned no record of death for Niki Soukeras.
(See Exhibit 43)
On 07/13/2023, your deponent conducted an IRBsearch Basic Person Search for Niki Soukeras using her
social security number in order to determine his last known address. Said search returned a last known
50th
address of: 2558 Street, Woodside, New York 11377.
(See Exhibit 44)
On 07/13/2023, your deponent conducted an IRBsearch Death Records for Niki Soukeras using her social
security number. Said search returned no record of death for Niki Soukeras.
(See Exhibit 45)
FILED: QUEENS COUNTY CLERK 12/27/2023 01:32 PM INDEX NO. 722924/2023
NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 12/27/2023
On 07/13/2023, your deponent conducted an online obituary search using google.com for Niki Soukeras
using the search term Niki M. Soukeras Obituary. Said search returned no obituary record for Niki
Soukeras.
(See Exhibit 46)
On 07/13/2023, your deponent conducted an online search using nysdoccslookup.doccs.ny.gov for Niki
Soukeras in order to determine if she is currently incarcerated in the New York State Department of
Corrections system. Said search returned no individual on file bearing the name: Soukeras.
(See Exhibit 47)
On 07/13/2023, your deponent conducted an online search using bop.gov for Niki Soukeras in order to
determine if she is currently incarcerated in the Federal Bureau of Prisons system. Said search returned
no results found for Niki Soukeras.
(See Exhibit 48)
On 07/13/2023, your deponent conducted a search on the New York State Department of Motor Vehicles
website for Niki Soukeras. Said search returned one match to the name Niki Soukeras. Said address listed
50*
on the Department of Motor Vehicles Records is: 2558 Street, Woodside, New York 11377.
(See Exhibit 49)
On 07/13/2023, your deponent conducted a search on the Department of Defense Manpower Data
Center to verify if Niki Soukeras is an active military member. Said search returned that Niki Soukeras is
not currently an active military member.
(See Exhibit 50)
On 07/18/2023, your deponent made a formal request to the United States Post Office located at
Woodside, New York 11377 by submitting a Request for Change of Address or Boxholder Information
needed for Service of Legal Process upon Niki Soukeras. To-date, no response has been received.
On 07/18/2023, your deponent conducted a search with the Board of Elections in the City of New York for
Niki Soukeras. To-date, no response has been received.
On 08/03/2023, your deponent conducted an IRBsearch People at Work Search for Niki Soukeras using
her social security number. Said search returned no record(s) of employment for Niki Soukeras.
(See Exhibit 51)
On 08/03/2023, your deponent conducted an IRBsearch Voter Registration Search for Niki Soukeras using
her social security number. Said search returned no voter registration record(s) for Niki Soukeras.
(See Exhibit 52)
FILED: QUEENS COUNTY CLERK 12/27/2023 01:32 PM INDEX NO. 722924/2023
NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 12/27/2023
On 08/03/2023, your deponent conducted an updated TLO Social Media Comprehensive Report for Niki
Soukeras using the search terms Niki Soukeras, her date of birth: December 10, 1988, and Woodside, New
York. Said search returned a LinkedIn account and a Facebook account for Niki Soukeras. On 07/18/2023,
at 5:06pm your deponent sent a message with attached copies of the Family Tree Affidavit and Affidavit
of Heirship to Niki Soukeras via her Facebook account. To-date, no response has been received. On
07/18/2023, at 5:27pm your deponent was unable to message Niki Soukeras via her LinkedIn account
because it is private.
(See Exhibit 53)
On 08/03/2023, your deponent conducted an online search using websurrogates.nycourts.gov for Niki
Soukeras using the search term Niki Soukeras and Queens County Surrogate's Court in order to locate any
information regarding Niki Soukeras and lawful heirs. Said search returned no records found for heir, Niki
Soukeras.
(See Exhibit 54)
Correspondence
On 07/18/2023, your deponent mailed a copy of the Family Tree Affidavit, Affidavit of Heirship and a cover
29th
letter sent to George Moundrakis at the address of: 3072 Street, Apt. 2, Astoria, New York 11102 with
a self-addressed return envelope. No such mail has been returned as undeliverable. To-date, no response
has been received.
On 07/18/2023, your deponent mailed a copy of the Family Tree Affidavit, Affidavit of Heirship and a cover
letter 20*
sent to Konstantinos Soukeras at the addresses of: 3601 Road, Astoria, New York 11105 and
20th
3601 Road, Floor 1, Astoria, New York 11105 with self-addressed return envelopes. No such mail has
been returned as undeliverable. To-date, no response has been received.
On 07/18/2023, your deponent mailed a copy of the Family Tree Affidavit, Affidavit of Heirship and a cover
50th
letter sent to Niki Soukeras at the address of: 2S58 Street, Woodside, New York 11377 with a self-
addressed return envelope. No such mail has been returned as undeliverable. To-date, no response has
been received.
Attempted Heirship Interviews via Telephone
On 07/13/2023, your deponent conducted an IRBsearch Phone Plus Search for George Moundrakis using
the search terms George Moundrakis and Astoria, New York 11102. Said search returned possible phone
numbers of: 917-502-2703, 718-310-8390 and 718-932-4118. On 08/17/2023, at 1:58pm your deponent
telephoned 917-502-2703 and went straight to an automated voicemail where it did not state the
person's name which then I left a voice message. To-date, no response has been received. On 08/17/2023,
at 2:00pm, your deponent telephoned 718-310-8390 and went straight to an automated voicemail where
it did not state the person's name which then I left a voice message. To-date, no response has been
received. On 08/17/2023, at 2:04pm your deponent telephoned 718-932-4118 and the phone kept on
ringing where no voicemail