Party Statement: M&T Bank v. The Estate Of Hugh H. Quail a/k/a Hugh H. Quail, Sr., Unknown Heirs Of The Estate Of Hugh H. Quail a/k/a Hugh H. Quail, Sr., New York State Department Of Taxation And Finance, United States Of America o/b/o Internal Revenue Service, John Doe #1 Through #6, And Jane Doe #1 Through #6, The Last Twelve Names Being Fictitious, It Being The Intention Of Plaintiff To Designate Any And All Occupants, Tenants, Persons Or Corporations, If Any, Having Or Claiming An Interest In Or Lien Upon the premises being foreclosed herein

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                                FILED: BROOME COUNTY CLERK 02/29/2024 01:19 PM                                                INDEX NO. EFCA2024000558
NYSCEF DOC. NO. 3                                                                         RECEIVED NYSCEF: 02/29/2024



       SUPREME COURT OF THE STATE OF NEW YORK
       COUNTY OF BROOME
       M&T Bank,                           CERTIFICATE OF MERIT PURSUANT TO
                                           CPLR 3012-B
       Plaintiff,
                                                              INDEX NO.:
       vs.
                                                            MORTGAGED PREMISES:
       The Estate of Hugh H. Quail a/k/a Hugh H. Quail,
       Sr.; Unknown Heirs of the Estate of Hugh H. 617 Hunts Corners Road
       Quail a/k/a Hugh H. Quail, Sr.; New York State Richford, NY 13835
       Department of Taxation and Finance; United
       States of America o/b/o Internal Revenue Service;
                                                            Section: 011.01 Block: 1 Lot: 7
       John Doe #1 through #6, and Jane Doe #1 through
       #6, the last twelve names being fictitious, it being
       the intention of Plaintiff to designate any and all
       occupants, tenants, persons or corporations, if any,
       having or claiming an interest in or lien upon the
       premises being foreclosed herein,

       Defendants.

       I, Ammar Jaber, Esq., hereby certify as follows:

             1. I am an attorney at law duly licensed to practice in the State of New York and am affiliated with
                the law firm of McCalla Raymer Leibert Pierce, LLC, the attorneys of record for Plaintiff in the
                above-captioned mortgage foreclosure action. As such, I am fully aware of the underlying
                action, as well as the proceedings had herein.
             2. I have reviewed the facts of this case and communicated with __________________________,
                                                                                         Summer Young
                a representative of Plaintiff's servicer concerning the subject of this action.
             3. Based upon my communication with Plaintiff's servicer and my review of the pertinent
                documents, including the mortgage, security agreement and note or bond underlying the
                mortgage executed by the defendants and all instruments of assignment, if any, and any other
                instrument of indebtedness including any modification, extension, and/or consolidation, and to
                the best of my knowledge, information and belief, there is a reasonable basis for the
                commencement of this action and that Plaintiff is currently the creditor entitled to enforce rights
                under such documents.



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FILED: BROOME COUNTY CLERK 02/29/2024 01:19 PM                                      INDEX NO. EFCA2024000558
NYSCEF DOC. NO. 3                                                               RECEIVED NYSCEF: 02/29/2024




          4. I further certify that to the best of my knowledge, information and belief, formed after
             reasonable inquiry regarding the present action, the presentation of the pleadings or the
             contentions contained herein are not frivolous as defined in 22 NYCRR 130-1.1(c).
          It is hereby certified on   02/29/2024   By:
                                                         Ammar Jaber, Esq.
                                                         McCalla Raymer Leibert Pierce, LLC
                                                         420 Lexington Avenue, Suite 840
                                                         New York, New York 10170
                                                         Phone: 347-286-7409
                                                         Fax: 347-286-7414
                                                         Attorneys for Plaintiff
                                                         M&T Bank
                                                         File No. 23-16687NY




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