On March 25, 2024 a
CERTIFICATE OF MERIT Redacted per 22 NYCRR - Redacted per 22 NYCRR §202.5(e)
was filed
involving a dispute between
Freedom Mortgage Corporation,
and
Genevieve K. Bishop,
John Doe #1 Through John Doe #10, The Last Ten Names Being Fictitious And Unknown To The Plaintiff, The Person Or Parties Intended Being The Persons Or Parties, If Any, Having Or Claiming An Interest In Or Lien Upon The Mortgaged Premises Described In The
Complaint,
Kurtis A. Marin
A K A Kurtis Marin,
Secretary Of Housing And Urban Development,
Solar Mosaic, Inc.,
for Real Property - Mortgage Foreclosure - Residential
in the District Court of Orange County.
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FILED: ORANGE COUNTY CLERK 03/25/2024 02:20 PM INDEX NO. EF002413-2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/25/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ORANGE
------------------------------------------------------------------X Index #:
Freedom Mortgage Corporation
Plaintiff,
-against- CERTIFICATE OF MERIT
PURSUANT TO CPLR 3012-b
Genevieve K. Bishop, Kurtis A. Marin a/k/a Kurtis Marin,
Solar Mosaic, Inc., Secretary of Housing and Urban
#1"
Development, and "JOHN DOE through "JOHN DOE Mortgaged Premises: 64 Skyline
#10", the last ten names being fictitious and unknown to the Drive, Highland Mills, NY 10930
plaintiff, the person or parties intended being the persons or
parties, if any, having or claiming an interest in or lien upon
the mortgaged premises described in the Complaint,
Defendants.
__________________________________________________________________Ç
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 Frenkel, Lambert, Weiss, Weisman & Gordon, LLP,
the attorney for Plaintiff, Freedom Mortgage Corporation, 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
defendants, Genevieve K. Bishop and Kurtis A. Marin, are residents of the property
subject to foreclosure.
3. I have reviewed the facts ofthis 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 the other instruments of
indebtedness including any modification, extension, and consolidation.
4. I have consulted about the facts of this case with the following representative of
plaintiff:
Heather Marie Diaz - Foreclosure Specialist III
5. Upon this review and consultation, to the best of my knowledge, information and
belief, I certify that there is a reasonable basis for the commencement of this action,
and that plaintiff is the creditor entitled to enforce rights under these documents.
6. 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
Filed in Orange County 03/25/2024 02:20:51 PM $0.00 1 of
Bk: 5157 2 Pg: 215 Index: # EF002413-2024 Clerk: EBR
FILED: ORANGE COUNTY CLERK 03/25/2024 02:20 PM INDEX NO. EF002413-2024
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/25/2024
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: O.)
7. Listed in Exhibit B and attached hereto are supplemental affidavits attesting that
certain documents as described in paragraph 6 supra are lost, whether by destruction,
theft, or otherwise. (Check box if no documents are attached in Exhibit B: [x].)
8. I am aware of my obligations under New York Rules of Professional Conduct (22
NYCRR Part 1200) and 22 NYCRR Part 130.
Dated: March 22, 2024
Todd Falasco, Esq.
2 of 2
Document Filed Date
March 25, 2024
Case Filing Date
March 25, 2024
Category
Real Property - Mortgage Foreclosure - Residential
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FILED: ORANGE COUNTY CLERK 03/25/2024 02:20 PM INDEX NO. EF002413-2024 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/25/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE ------------------------------------------------------------------X Index #: Freedom Mortgage Corporation Plaintiff, -against- CERTIFICATE OF MERIT PURSUANT TO CPLR 3012-b Genevieve K. Bishop, Kurtis A. Marin a/k/a Kurtis Marin, Solar Mosaic, Inc., Secretary of Housing and Urban #1" Development, and "JOHN DOE through "JOHN DOE Mortgaged Premises: 64 Skyline #10", the last ten names being fictitious and unknown to the Drive, Highland Mills, NY 10930 plaintiff, the person or parties intended being the persons or parties, if any, having or claiming an interest in or lien upon the mortgaged premises described in the Complaint, Defendants. __________________________________________________________________Ç 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 Frenkel, Lambert, Weiss, Weisman & Gordon, LLP, the attorney for Plaintiff, Freedom Mortgage Corporation, 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 defendants, Genevieve K. Bishop and Kurtis A. Marin, are residents of the property subject to foreclosure. 3. I have reviewed the facts ofthis 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 the other instruments of indebtedness including any modification, extension, and consolidation. 4. I have consulted about the facts of this case with the following representative of plaintiff: Heather Marie Diaz - Foreclosure Specialist III 5. Upon this review and consultation, to the best of my knowledge, information and belief, I certify that there is a reasonable basis for the commencement of this action, and that plaintiff is the creditor entitled to enforce rights under these documents. 6. 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 Filed in Orange County 03/25/2024 02:20:51 PM $0.00 1 of Bk: 5157 2 Pg: 215 Index: # EF002413-2024 Clerk: EBR FILED: ORANGE COUNTY CLERK 03/25/2024 02:20 PM INDEX NO. EF002413-2024 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/25/2024 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: O.) 7. Listed in Exhibit B and attached hereto are supplemental affidavits attesting that certain documents as described in paragraph 6 supra are lost, whether by destruction, theft, or otherwise. (Check box if no documents are attached in Exhibit B: [x].) 8. I am aware of my obligations under New York Rules of Professional Conduct (22 NYCRR Part 1200) and 22 NYCRR Part 130. Dated: March 22, 2024 Todd Falasco, Esq. 2 of 2