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6 DOCKET NO. FST-CV24-6064522-S SUPERIOR COURT
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U.S. BANK TRUST COMPANY, NATIONAL
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COMMERCIAL CAPITAL LOAN TRUST 2023-2 STAMFORD/NORWALK
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UNIT 9 LLC, and CHANEL RAMIREZ JANUARY 23, 2024
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9- X A MORTGAGE ON NON-OWNER OCCUPIED PROPERTY
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COUNT ONE - FORECLOSURE OF COMMERCIAL MORTGAGE
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• — 1. The Plaintiff, U.S. Bank Trust Company, National Association, as Trustee for Velocity
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Commercial Capital Loan Trust 2023-2 (the “Plaintiff’), is a national bank having an address of 190 South
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2. The defendant, 44 Cerretta Street Stamford CT. 06907 Unit 9 LLC (the “Borrower”), is a
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’A document reflecting the amendments from the Complaint filed on December 22, 2024, is attached hereto as Schedule 1.
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Z 3. The defendant, Chanel Ramirez (“Ms. Ramirez”), is an individual having a last known
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address of 1406 Nostrand Ave. #2, Brooklyn, NY 11226 or 44 Cerretta Street, Stamford, CT, 06907.
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oo 4. On January 25, 2023, the Borrower was the owner of certain real property located in
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Street, Unit 9C, Stamford, CT 06907 (the “Mortgaged Premises”), as more particularly described in Exhibit
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Velocity an Open-End Mortgage (the “Mortgage”) dated on said date and recorded on the Stamford Land
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Records on February 3, 2023, in Volume 13133 at Page 185. Pursuant to Practice Book § 10-29, a copy of
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personal property (the “Personal Property”) to secure the payment and satisfaction of the Loan.
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Z 8. The Plaintiff is the owner and holder of the Note and Mortgage (together, the “Loan
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Documents”) by virtue of (i) an Allonge to Promissory Note from Velocity; (ii) an Assignment of Open-
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9. The Borrower is in default under the terms of the Loan Documents by virtue of:
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3 10. The Plaintiff has accelerated the Loan and demanded that the Borrower repay the sums due.
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12. The Note provides that the Borrower shall be liable for all costs and expenses incurred by
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the Plaintiff in the collection of the Loan, including, but not limited to, attorneys’ fees.
8 13. The following encumbrances of record relating to the Mortgaged Premises are prior in right
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5 to the Mortgage and will not be foreclosed by the Judgment to be rendered in this action:
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(a) Any municipal real property taxes currently due to the City of Stamford; and
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(b) Any sewer or water use liens.
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Z 14. The following encumbrances of record relating to the Mortgaged Premises are junior in
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COUNT TWO - (Breach of Guaranty as to Defendant Chanel Ramirez)
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— cn 1-12. The allegations of Paragraphs 1 through 12 of Count One are hereby reasserted and realleged
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14. Ms. Ramirez has failed and/or refused to pay the amounts now due and owing under the
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Note pursuant to the terms of his Unlimited Guaranty.
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15. The Plaintiff has been damaged.
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6 WHEREFORE, the Plaintiff prays for the following relief:
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As to Count One:
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2. Immediate possession of the properties that comprise the Mortgaged Premises;
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1. Monetary damages;
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2. Attorneys’ fees, interest and costs of suit; and
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3. Such other and further relief as at law and/or in equity may pertain.
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Z NOTICE: A PERSON WHO IS UNEMPLOYED OR UNDEREMPLOYED AND WHO HAS
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FOR A CONTINUOUS PERIOD OF AT LEAST TWO YEARS PRIOR TO THE
COMMENCEMENT OF THIS FORECLOSURE ACTION OWNED AND OCCUPIED THE
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PROPERTY BEING FORECLOSED AS SUCH PERSON’S PRINCIPAL RESIDENCE, MAY BE
co ENTITLED TO CERTAIN RELIEF PROVISIONS UNDER SECTIONS 49-31d TO 49-31i,
INCLUSIVE, OF THE CONNECTICUT GENERAL STATUTES. YOU SHOULD CONSULT AN
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THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
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OC . THE PLAINTIFF,
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JamesR.I yrne, Esq. (410021)
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Hartford, CT 06103
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Tel.: (860) 548-2683
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Fax.: (860) 548-2680
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Email: jbyrne@uks.com
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6 DOCKET NO. FST-CV24-6064522-S SUPERIOR COURT
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U.S. BANK TRUST COMPANY, NATIONAL
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ASSOCIATION, AS TRUSTEE FOR VELOCITY JUDICIAL DISTRICT OF
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COMMERCIAL CAPITAL LOAN TRUST 2023-2 STAMFORD/NORWALK
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44 CERRETTA STREET STAMFORD CT. 06907
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A UNIT 9 LLC, and CHANEL RAMIREZ JANUARY 23, 2024
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STATEMENT OF AMOUNT IN DEMAND
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The amount in demand, exclusive of interest and costs, is in excess of $15,000.00.
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THE PLAINTIFF,
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ASSOCIATION, AS TRUSTEE FOR VELOCITY
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Fax.: (860) 548-2680
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Juris No. 065040
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EXHIBIT "A"
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ALL that certain real property being described as follows:
0 All that certain piece of real property situated in the City of
Stamford in the County of Fairfield and State of Connecticut,
being part of a condominium and known and designated as Unit 9C,
’’SPRING BROOK TERRACE", Stamford, Connecticut, together with an
co undivided interest in and to the common areas and facilities of
the condominium, all as set forth in the condominium documents
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regulations and easements of record, all as more particularly set
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recorded in Volume 1356 at Page 13 of the Stamford Land Records,
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Parcel Id #: 002/ 7071/ / 9C/ (Map #86 350)
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I hereby certify that a copy of the above was mailed or electronically delivered on January 23,2024,
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received from all counsel and self-represented parties of record who were electronically served:
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44 Cerretta Street Stamford CT. 06907 Unit 9 LLC
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44 Cerretta Street
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Stamford, CT 06907
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Non-appearing defendant
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44 Cerretta Street, Unit 9
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SCHEDULE 1
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RETURN DATE: JANUARY 2. 2024DOCKET NO. FST-CV24-6064522-S
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SUPERIOR
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O U.S. BANK TRUST COMPANY, NATIONAL
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UNIT 9 LLC, and CHANEL RAMIREZ DE€feMBER 12.-2O2-3J ANU ARY 23. 2024
AMENDED COMPLAINT1
(filed as of right per Practice Book § 10-59)
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O THIS COMPLAINT SEEKS HIE FORECLOSURE OF A COMMERCIAL LOAN SECURED BY
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8 □ A MORTGAGE ON NON-OWNER OCCUPIED PROPERTY
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• 0>c COUNT ONE - FORECLOSURE OF COMMERCIAL MORTGAGE
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O 1. The Plaintiff, U.S. Bank Trust Company, National Association, as Trustee for Velocity
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Commercial Capital Loan Trust 2023-2 (the “Plaintiff’), is a national bank having an address of 190 South
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LaSalle Street, 7th Floor, Chicago, IL 60603.
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o 2. The defendant, 44 Cerretta Street Stamford CT. 06907 Unit 9 LLC (the “Borrower”), is a
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Connecticut limited liability company having an address listed with the Connecticut Secretary of State of
1406 Nostrand Ave. #2, Brooklyn, NY 11226.
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I 'A document reflecting the amendments from the Complaint filed on December 22. 2024, is attached hereto as Schedule I
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address of 1406 Nostrand Ave. #2, Brooklyn, NY 11226 or 44 Cerretta Street, Stamford, CT, 06907.
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oo 4. On January 25, 2023, the Borrower was the owner of certain real property located in
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CO Stamford, Connecticut, commonly known as 44 Cerretta Street, Stamford, CT 06907 a/k/a 44 Cerretta
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Street, Unit 9C, Stamford, CT 06907 (the “Mortgaged Premises”), as more particularly described in Exhibit
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88 .1 Note (the “Note”) in that amount payable to the order of Velocity. Pursuant to Practice Book § 10-29, a
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Documents”) by virtue of (i) an Allonge to Promissory Note from Velocity; (ii) an Assignment of Open-
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9. The Borrower is in default under the terms of the Loan Documents by virtue of
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(a) its failure to make payments on the Note when due including the payments due for
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13. The following encumbrances of record relating to the Mortgaged Premises are prior in right
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to the Mortgage and will not be foreclosed by the Judgment to be rendered in this action:
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(a) Any municipal real property taxes currently due to the City of Stamford; and
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occupant or tenant with an unrecorded lease.
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15. The Plaintiff recorded a Notice of Lis Pendens on the Stamford Land Records evidencing
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the pendency of this action.
C COUNT TWO - (Breach of Guaranty as to Defendant Chanel Ramirez)
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1-12. The allegations of Paragraphs 1 through 12 of Count One are hereby reasserted and realleged
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Unlimited Guaranty pursuant to which he personally guaranteed the Loan.
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14. Ms. Ramirez has failed and/or refused to pay the amounts now due and owing under the
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3 15. The Plaintiff has been damaged.
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As to Count One:
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2. Immediate possession of the properties that comprise the Mortgaged Premises;
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3. A deficiency judgment;
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NOTICE: A PERSON WHO IS UNEMPLOYED OR UNDEREMPLOYED AND WHO HAS
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FOR A CONTINUOUS PERIOD OF AT LEAST TWO YEARS PRIOR TO THE
COMMENCEMENT OF THIS FORECLOSURE ACTION OWNED AND OCCUPIED THE
98 PROPERTY BEING FORECLOSED AS SUCH PERSON’S PRINCIPAL RESIDENCE, MAY BE
00 ENTITLED TO CERTAIN RELIEF PROVISIONS UNDER SECTIONS 49-31d TO 49-3li,
INCLUSIVE, OF THE CONNECTICUT GENERAL STATUTES. YOU SHOULD CONSULT AN
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oo ATTORNEY TO DETERMINE YOUR RIGHTS UNDER SECTIONS 49-31d TO 49-311,
INCLUSIVE, OF THE CONNECTICUT GENERAL STATUTES.
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P THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
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GIVEN WILL BE USED FOR THAT PURPOSE.
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ASSOCIATION, AS TRUSTEE FOR VELOCITY
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COMMERCIAL CAPITAL LOAN TRUST 2023-2
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S 0 James R. Byrne, Esq. (410021)
SI Updike, Kelly & Spellacy, P.C.
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Goodwin Square
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225 Asylum St., 20th Floor
Hartford, CT 06103
Tel.: (860)548-2683
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3 Juris No. 065040
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SCHEDULE 1
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RETURN DATE: JANUAR¥-a7-2024DQCKET NO. FST-CV24-6064522-S
COURT
SUPERIOR
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U.S. BANK TRUST COMPANY, NATIONAL
00 ASSOCIATION, AS TRUSTEE FOR VELOCITY JUDICIAL DISTRICT OF
COMMERCIAL CAPITAL LOAN TRUST 2023-2 STAMFORD/NORWALK
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A 44 CERRETTA STREET STAMFORD CT. 06907
co UNIT 9 LLC, and CHANEL RAMIREZ DECEMBER 12. 2023JANUARY 23. 2024
U s STATEMENT OF AMOUNT IN DEMAND
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The amount in demand, exclusive of interest and costs, is in excess of $15,000.00.
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N = THE PLAINTIFF,
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ASSOCIATION, AS TRUSTEE FOR VELOCITY
COMMERCIAL CAPITAL LOAN TRUST 2023-2
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James R. Byrne, Esq. (410021)
Updike, Kelly & Spellacy, P.C.
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225 Asylum St., 20th Floor
Hartford, CT 06103
Fax.: (860) 548-2680
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Juris No. 065040
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Z EXHIBIT A
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EXHIBIT ”A”
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ALL that certain real property being described as follows:
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All that certain piece of real property situated in the City of
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being part of a condominium and known and designated as Unit 9C,
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"SPRING BROOK TERRACE", Stamford, Connecticut, together with an
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the condominium, all as set forth in the condominium documents
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filed and recorded in the Stamford land records.
TOGETHER with the benefits, rights, privileges, easements and
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subject to the burdens, covenants, restrictions bylaws, rules,
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o regulations and easements of record, all as more particularly set
d8 o forth in the Declaration of Condominium dated July 12, 1973 and
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Parcel Id #: 002/ 7071/ / 9C/ (Map #86 350)
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cs ALL that certain zeal property being described as follows:
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’’SPRING BROOK TERRACE", Stamford, Connecticut, together with an
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filed and recorded in the Stamford land records.
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TOGETHER iteh fehe benefits-;—gightes ,— privileges. and
subject to the burdens, covenants, restrictions bylaws, rules,
regulations and easements of record, all as more particularly set
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forth in the Declaration of Condominium dated July 12, 1973 and
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recorded in Volume 1356 at Page 13 of the Stamford Land Records,
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as same may be amended and/or supplemented from time to time.
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■P For information only: 44 CERRETTA STREET, STAMFORD, CT 06907.
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Q 44 Cerretta Street Stamford CT. 06907 Unit 9 LLC
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c/o Agent for Service Chanel Ramirez
44 Cerretta Street
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o 44 Cerretta Street, Unit 9
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James R. By me. Esq. (410021)
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o o so © 6 DOCKET NO. FST-CV24-6064522-S SUPERIOR COURT Z • 5 U.S. BANK TRUST COMPANY, NATIONAL o oo ASSOCIATION, AS TRUSTEE FOR VELOCITY JUDICIAL DISTRICT OF Q COMMERCIAL CAPITAL LOAN TRUST 2023-2 STAMFORD/NORWALK oc VS. AT STAMFORD C L 44 CERRETTA STREET STAMFORD CT. 06907 C UNIT 9 LLC, and CHANEL RAMIREZ JANUARY 23, 2024 oc 'Al r ; • AMENDED COMPLAINT1 U sO CL oc (filed as of right per Practice Book § 10-59) S O o C • THIS COMPLAINT SEEKS THE FORECLOSURE OF A COMMERCIAL LOAN SECURED BY o o 9- X A MORTGAGE ON NON-OWNER OCCUPIED PROPERTY 8 — COUNT ONE - FORECLOSURE OF COMMERCIAL MORTGAGE 0 g 2 S • — 1. The Plaintiff, U.S. Bank Trust Company, National Association, as Trustee for Velocity Q- 1 • 8 X Commercial Capital Loan Trust 2023-2 (the “Plaintiff’), is a national bank having an address of 190 South o o LaSalle Street, 7th Floor, Chicago, IL 60603. o 2. The defendant, 44 Cerretta Street Stamford CT. 06907 Unit 9 LLC (the “Borrower”), is a D D E Connecticut limited liability company having an address listed with the Connecticut Secretary of State of < 1406 Nostrand Ave. #2, Brooklyn, NY 11226. R C 5 § ‘U O o O ’A document reflecting the amendments from the Complaint filed on December 22, 2024, is attached hereto as Schedule 1. 4231152 o o vo 6 Z 3. The defendant, Chanel Ramirez (“Ms. Ramirez”), is an individual having a last known o 5 address of 1406 Nostrand Ave. #2, Brooklyn, NY 11226 or 44 Cerretta Street, Stamford, CT, 06907. o oo oo 4. On January 25, 2023, the Borrower was the owner of certain real property located in o O Q Stamford, Connecticut, commonly known as 44 Cerretta Street, Stamford, CT 06907 a/k/a 44 Cerretta X — Street, Unit 9C, Stamford, CT 06907 (the “Mortgaged Premises”), as more particularly described in Exhibit o OC A attached hereto as well as in the Mortgage (as defined below). nJ 0 5. On or about January 25, 2023, the Borrower became indebted to Velocity Commercial o O , C Capital, LLC (“Velocity”), in the principal amount of $287,000.00 (the “Loan”) as evidenced by a Term 0C § l O U o d 5 Note (the “Note”) in that amount payable to the order of Velocity. Pursuant to Practice Book § 10-29, a o CD c o copy of the Note will be filed as Exhibit B. 0° M > 6. To secure the Note, on or about January 25, 2023, the Borrower executed and delivered to © • 3 C O Velocity an Open-End Mortgage (the “Mortgage”) dated on said date and recorded on the Stamford Land o L o C Records on February 3, 2023, in Volume 13133 at Page 185. Pursuant to Practice Book § 10-29, a copy of o D the Mortgage will be filed as Exhibit C. d E 5 7. Pursuant to the terms of the Mortgage, the Borrower granted to Velocity, among other things, < C C an interest in the Mortgaged Premises and the rents produced thereby as well as a security interest in certain • personal property (the “Personal Property”) to secure the payment and satisfaction of the Loan. § o o C 2 o o vo 6 Z 8. The Plaintiff is the owner and holder of the Note and Mortgage (together, the “Loan • Documents”) by virtue of (i) an Allonge to Promissory Note from Velocity; (ii) an Assignment of Open- CO A oc End Commercial Mortgage, Security Agreement, and Assignment of Leases and Rents from Velocity to the 0 Plaintiff dated November 16, 2023, and recorded on November 20, 2023, in Volume 13265 at Page 174 of o the Stamford Land Records. o O C co 9. The Borrower is in default under the terms of the Loan Documents by virtue of: o (a) its failure to make payments on the Note when due including the payments due for CL 75 O . C the months of August 1,2023, and thereafter. oQ- 8o 3 10. The Plaintiff has accelerated the Loan and demanded that the Borrower repay the sums due. o O E o 11. Notwithstanding the demand, the Borrower has failed and/or refused to pay the amounts now - U 'O© 81 due and owing under the Note. • C — X O 12. The Note provides that the Borrower shall be liable for all costs and expenses incurred by o the Plaintiff in the collection of the Loan, including, but not limited to, attorneys’ fees. 8 13. The following encumbrances of record relating to the Mortgaged Premises are prior in right 0 e 5 to the Mortgage and will not be foreclosed by the Judgment to be rendered in this action: < (a) Any municipal real property taxes currently due to the City of Stamford; and 8 (b) Any sewer or water use liens. ? O o O 3 o o vo d Z 14. The following encumbrances of record relating to the Mortgaged Premises are junior in right to the Mortgage and will be foreclosed by the Judgment to be rendered in this action: oc oc (a) Defendant Chanel Ramirez may claim an interest in the Mortgaged Premises as an so Q occupant or tenant with an unrecorded lease. X cd — o 15. The Plaintiff recorded a Notice of Lis Pendens on the Stamford Land Records evidencing oc I the pendency of this action. o 2 a- oc COUNT TWO - (Breach of Guaranty as to Defendant Chanel Ramirez) .e o 37 C — cn 1-12. The allegations of Paragraphs 1 through 12 of Count One are hereby reasserted and realleged o • Q- o U o 3 as Paragraphs 1 through 12 of Count Two with the same effect as if more fully set forth herein. • CD c N c o 13. To further secure the Loan, on or about August 16, 2022, Ms. Ramirez executed an O- U 8 eg Unlimited Guaranty pursuant to which he personally guaranteed the Loan. — E — X o 14. Ms. Ramirez has failed and/or refused to pay the amounts now due and owing under the o E C Note pursuant to the terms of his Unlimited Guaranty. O D C/D 15. The Plaintiff has been damaged. g < N C C 0 § o o J 4 Q o vo 6 WHEREFORE, the Plaintiff prays for the following relief: z t 8 As to Count One: CO A oo 1. A judgment of strict foreclosure of the Mortgaged Premises unless the U.S. Government is o' co a party defendant at the time of judgment in which case a foreclosure by sale; 8 L 2. Immediate possession of the properties that comprise the Mortgaged Premises; PC8 3. A deficiency judgment; CU O 4. Interest; O . C P 5. Costs; a• 2O U o d8 6. Attorneys’ fees; and — O O E M § 7. Such other and further relief as at law and/or equity may pertain. - (J $ - Q- — As to Count Two: • — X8 o 1. Monetary damages; O 2. Attorneys’ fees, interest and costs of suit; and • o D 3. Such other and further relief as at law and/or in equity may pertain. E 5 < on C C • c Z o o O 5 o o SO 6 Z NOTICE: A PERSON WHO IS UNEMPLOYED OR UNDEREMPLOYED AND WHO HAS o 8 FOR A CONTINUOUS PERIOD OF AT LEAST TWO YEARS PRIOR TO THE COMMENCEMENT OF THIS FORECLOSURE ACTION OWNED AND OCCUPIED THE 9 PROPERTY BEING FORECLOSED AS SUCH PERSON’S PRINCIPAL RESIDENCE, MAY BE co ENTITLED TO CERTAIN RELIEF PROVISIONS UNDER SECTIONS 49-31d TO 49-31i, INCLUSIVE, OF THE CONNECTICUT GENERAL STATUTES. YOU SHOULD CONSULT AN 0 ATTORNEY TO DETERMINE YOUR RIGHTS UNDER SECTIONS 49-3Id TO 49-3li, E C INCLUSIVE, OF THE CONNECTICUT GENERAL STATUTES. o o THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION co GIVEN WILL BE USED FOR THAT PURPOSE. § oc cu OC . THE PLAINTIFF, U.S. BANK TRUST COMPANY, NATIONAL 9Q- 8o ASSOCIATION, AS TRUSTEE FOR VELOCITY U o COMMERCIAL CAPITAL LOAN TRUST 2023-2 0 4> C = o $ e U By: '-5 ©. JamesR.I yrne, Esq. (410021) E D X Updike, Kelly & Spellacy, P.C. o Goodwin Square o 225 Asykm St., 20th Floor — Hartford, CT 06103 • Tel.: (860) 548-2683 o cZ Fax.: (860) 548-2680 E • Email: jbyrne@uks.com U Juris No. 065040 < C —Its Attorneys— C • E 0 c 3 o o C 6 o o U \O o 6 DOCKET NO. FST-CV24-6064522-S SUPERIOR COURT Z U U.S. BANK TRUST COMPANY, NATIONAL © CO O ASSOCIATION, AS TRUSTEE FOR VELOCITY JUDICIAL DISTRICT OF CM COMMERCIAL CAPITAL LOAN TRUST 2023-2 STAMFORD/NORWALK Q o O oc VS. AT STAMFORD 03 [X 44 CERRETTA STREET STAMFORD CT. 06907 o A UNIT 9 LLC, and CHANEL RAMIREZ JANUARY 23, 2024 co I r ; O STATEMENT OF AMOUNT IN DEMAND CO Q- O The amount in demand, exclusive of interest and costs, is in excess of $15,000.00. C THE PLAINTIFF, 3 5 U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, AS TRUSTEE FOR VELOCITY o 8 COMMERCIAL CAPITAL LOAN TRUST 2023-2 -o Js -5 ■P CL D 8 By: o o E James R. Byrne, Esq. (410021) Updike, Kelly & Spellacy, P.C. Goodwin Square • D 225 Asylum St., 20th Floor 0 g Hartford, CT 06103 5 Fax.: (860) 548-2680 < Email: jbyme@uks.com R Juris No. 065040 —Its Attorneys— S c 3 o oo 4231152 o o U d Z EXHIBIT A o 8 EXHIBIT "A" o CO 1-01725175 O C oo ALL that certain real property being described as follows: 0 All that certain piece of real property situated in the City of Stamford in the County of Fairfield and State of Connecticut, being part of a condominium and known and designated as Unit 9C, ’’SPRING BROOK TERRACE", Stamford, Connecticut, together with an co undivided interest in and to the common areas and facilities of the condominium, all as set forth in the condominium documents o' O oc filed and recorded in the Stamford land records. O . TOGETHER with the benefits, rights, privileges, easements and C 9 8 subject to the burdens, covenants, restrictions bylaws, rules, o U o regulations and easements of record, all as more particularly set 38 — forth in the Declaration of Condominium dated July 12, 1973 and recorded in Volume 1356 at Page 13 of the Stamford Land Records, O c c as same way be amended and/or supplemented from time to time, O - U O Parcel Id #: 002/ 7071/ / 9C/ (Map #86 350) & O cd D X For information only: 44 CERRETTA STREET, STAMFORD, CT 0 6907, o O o C D GO E in < C C 0 § O o o o 2 o o vo 6 Z CERTIFICATE OF SERVICE co 8 I hereby certify that a copy of the above was mailed or electronically delivered on January 23,2024, o oo oo to all counsel and self-represented parties of record and that written consent for electronic delivery was 0 received from all counsel and self-represented parties of record who were electronically served: X C 44 Cerretta Street Stamford CT. 06907 Unit 9 LLC C c/o Agent for Service Chanel Ramirez oo 44 Cerretta Street o J oo Stamford, CT 06907 CL O Non-appearing defendant 8 • g8 d o Chanel Ramirez 3 i 44 Cerretta Street, Unit 9 O E Stamford, CT 06907 c O - U O CL D C X 6 O By:_____ /s/ James R. Byrne James R. Byrne, Esq. (410021) o Updike, Kelly & Spellacy, P.C. D E S 2 < D S c o o O 3 SCHEDULE 1 Q g □ RETURN DATE: JANUARY 2. 2024DOCKET NO. FST-CV24-6064522-S COURT SUPERIOR o 00 O U.S. BANK TRUST COMPANY, NATIONAL 00 ASSOCIATION, AS TRUSTEE FOR VELOCITY JUDICIAL DISTRICT OF COMMERCIAL CAPITAL LOAN TRUST 2023-2 STAMFORD/NORWALK Q O 00 re vs. AT STAMFORD U 33 i 44 CERRETTA STREET STAMFORD CT. 06907 UNIT 9 LLC, and CHANEL RAMIREZ DE€feMBER 12.-2O2-3J ANU ARY 23. 2024 AMENDED COMPLAINT1 (filed as of right per Practice Book § 10-59) C • Q 8 O THIS COMPLAINT SEEKS HIE FORECLOSURE OF A COMMERCIAL LOAN SECURED BY o 8 □ A MORTGAGE ON NON-OWNER OCCUPIED PROPERTY 9 • 0>c COUNT ONE - FORECLOSURE OF COMMERCIAL MORTGAGE S• O5 O 1. The Plaintiff, U.S. Bank Trust Company, National Association, as Trustee for Velocity D x Commercial Capital Loan Trust 2023-2 (the “Plaintiff’), is a national bank having an address of 190 South o o LaSalle Street, 7th Floor, Chicago, IL 60603. 3 o 2. The defendant, 44 Cerretta Street Stamford CT. 06907 Unit 9 LLC (the “Borrower”), is a — E Connecticut limited liability company having an address listed with the Connecticut Secretary of State of 1406 Nostrand Ave. #2, Brooklyn, NY 11226. re c o o p I 'A document reflecting the amendments from the Complaint filed on December 22. 2024, is attached hereto as Schedule I O Z 3. The defendant, Chanel Ramirez (“Ms. Ramirez”), is an individual having a last known un □ address of 1406 Nostrand Ave. #2, Brooklyn, NY 11226 or 44 Cerretta Street, Stamford, CT, 06907. O C oo 4. On January 25, 2023, the Borrower was the owner of certain real property located in • 0 CO Stamford, Connecticut, commonly known as 44 Cerretta Street, Stamford, CT 06907 a/k/a 44 Cerretta X re Street, Unit 9C, Stamford, CT 06907 (the “Mortgaged Premises”), as more particularly described in Exhibit 8 co A attached hereto as well as in the Mortgage (as defined below). u 'O 00 5. On or about January 25, 2023, the Borrower became indebted to Velocity Commercial 1^ 03 Capital, LLC (“Velocity”), in the principal amount of $287,000.00 (the “Loan”) as evidenced by a Term Q O 0 IS 88 .1 Note (the “Note”) in that amount payable to the order of Velocity. Pursuant to Practice Book § 10-29, a P o — । in certain personal property (the “Personal Property”) to secure the payment and satisfaction of the Loan. E 5 o o O 2 o 8. The Plaintiff is the owner and holder of the Note and Mortgage (together, the “Loan Zon H Documents”) by virtue of (i) an Allonge to Promissory Note from Velocity; (ii) an Assignment of Open- co co End Commercial Mortgage, Security Agreement, and Assignment of Leases and Rents from Velocity to the oo Plaintiff dated November 16, 2023, and recorded on November 20, 2023, in Volume 13265 at Page 174 of X CS the Stamford Land Records. Cl oo 9. The Borrower is in default under the terms of the Loan Documents by virtue of x> (a) its failure to make payments on the Note when due including the payments due for 0 eg • the months of August 1, 2023, and thereafter. 9 2 Q. O • o 10. The Plaintiff has accelerated the Loan and demanded that the Borrower repay the sums due. 8E 2 5 — o = 2 = o 11. Notwithstanding the demand, the Borrower has failed and/or refused to pay the amounts now O due and owing under the Note. □ E I o 12. The Note provides that the Borrower shall be liable for all costs and expenses incurred by o N the Plaintiff in the collection of the Loan, including, but not limited to, attorneys’ fees. 9 13. The following encumbrances of record relating to the Mortgaged Premises are prior in right E to the Mortgage and will not be foreclosed by the Judgment to be rendered in this action: N (a) Any municipal real property taxes currently due to the City of Stamford; and re = (b) Any sewer or water use liens. E o o O 3 o Z 14. The following encumbrances of record relating to the Mortgaged Premises are junior in right to the Mortgage and will be foreclosed by the Judgment to be rendered in this action: 8 co W None-? C (a) Defendant Chanel Ramirez may claim an interest in the Mortgaged Premises as an X 03 occupant or tenant with an unrecorded lease. 8 oo 15. The Plaintiff recorded a Notice of Lis Pendens on the Stamford Land Records evidencing o O oo the pendency of this action. C COUNT TWO - (Breach of Guaranty as to Defendant Chanel Ramirez) Q 1-12. The allegations of Paragraphs 1 through 12 of Count One are hereby reasserted and realleged 5 o c c o as Paragraphs 1 through 12 of Count Two with the same effect as if more fully set forth herein. O 13. To further secure the Loan, on or about August 16, 2022, Ms. Ramirez executed an E I o Unlimited Guaranty pursuant to which he personally guaranteed the Loan. o 14. Ms. Ramirez has failed and/or refused to pay the amounts now due and owing under the Note pursuant to the terms of his Unlimited Guaranty. =E 3 15. The Plaintiff has been damaged. CO 5 0 c s o o o 4 O Z WHEREFORE, the Plaintiff prays for the following relief: e s As to Count One: oo sO 9 CO 1. A judgment of strict foreclosure of the Mortgaged Premises unless the U.S. Government is 00 a party defendant at the time ofjudgment in which case a foreclosure by sale; X rc 2. Immediate possession of the properties that comprise the Mortgaged Premises; 8 co 3. A deficiency judgment; C 4. Interest; C 5. Costs; o 0 o eg 5 6. Attorneys’ fees; and 5 o c o 7. Such other and further relief as at law and/or equity may pertain. 0 As to Count Two: X o 1. Monetary damages; o 2. Attorneys’ fees, interest and costs of suit; and 5 9 3. Such other and further relief as at law and/or in equity may pertain. c = 2 in ~i • e 3 M C 3 o o O 5 2 NOTICE: A PERSON WHO IS UNEMPLOYED OR UNDEREMPLOYED AND WHO HAS en 3 FOR A CONTINUOUS PERIOD OF AT LEAST TWO YEARS PRIOR TO THE COMMENCEMENT OF THIS FORECLOSURE ACTION OWNED AND OCCUPIED THE 98 PROPERTY BEING FORECLOSED AS SUCH PERSON’S PRINCIPAL RESIDENCE, MAY BE 00 ENTITLED TO CERTAIN RELIEF PROVISIONS UNDER SECTIONS 49-31d TO 49-3li, INCLUSIVE, OF THE CONNECTICUT GENERAL STATUTES. YOU SHOULD CONSULT AN 8 oo ATTORNEY TO DETERMINE YOUR RIGHTS UNDER SECTIONS 49-31d TO 49-311, INCLUSIVE, OF THE CONNECTICUT GENERAL STATUTES. s P THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION 00 GIVEN WILL BE USED FOR THAT PURPOSE. U C V THE PLAINTIFF, cP * U.S. BANK TRUST COMPANY, NATIONAL g 8 ASSOCIATION, AS TRUSTEE FOR VELOCITY 0 8 COMMERCIAL CAPITAL LOAN TRUST 2023-2 I E S J 9 By:__________________________ S 0 James R. Byrne, Esq. (410021) SI Updike, Kelly & Spellacy, P.C. o Goodwin Square o 225 Asylum St., 20th Floor Hartford, CT 06103 Tel.: (860)548-2683 V Fax.: (860) 548-2680 E Email: jbyme@uks.com E 3 Juris No. 065040 -Its Attorneys— N € 3 0 E O o O 6 SCHEDULE 1 2 □ RETURN DATE: JANUAR¥-a7-2024DQCKET NO. FST-CV24-6064522-S COURT SUPERIOR o OO ri U.S. BANK TRUST COMPANY, NATIONAL 00 ASSOCIATION, AS TRUSTEE FOR VELOCITY JUDICIAL DISTRICT OF COMMERCIAL CAPITAL LOAN TRUST 2023-2 STAMFORD/NORWALK o sO OO X re VS. AT STAMFORD 9 A 44 CERRETTA STREET STAMFORD CT. 06907 co UNIT 9 LLC, and CHANEL RAMIREZ DECEMBER 12. 2023JANUARY 23. 2024 U s STATEMENT OF AMOUNT IN DEMAND c0 > • 03 • The amount in demand, exclusive of interest and costs, is in excess of $15,000.00. o O c0 N = THE PLAINTIFF, —‘ o U.S. BANK TRUST COMPANY, NATIONAL - = o ASSOCIATION, AS TRUSTEE FOR VELOCITY COMMERCIAL CAPITAL LOAN TRUST 2023-2 O re O o By:__________________________ James R. Byrne, Esq. (410021) Updike, Kelly & Spellacy, P.C. Goodwin Square E 225 Asylum St., 20th Floor Hartford, CT 06103 Fax.: (860) 548-2680 Email: jbyme@uks.com £ re Juris No. 065040 5 0 —Its Attorneys— C o o O O Z EXHIBIT A Formatted: Font: Not Bold, No underline □ EXHIBIT ”A” co 1-01725175 c CI o ALL that certain real property being described as follows: C oo All that certain piece of real property situated in the City of X re Stamford in the County of Fairfield and State of Connecticut, being part of a condominium and known and designated as Unit 9C, 0 C 1 "SPRING BROOK TERRACE", Stamford, Connecticut, together with an o undivided interest in and to the common areas and facilities of the condominium, all as set forth in the condominium documents U 0 cO filed and recorded in the Stamford land records. TOGETHER with the benefits, rights, privileges, easements and & subject to the burdens, covenants, restrictions bylaws, rules, Q c o o regulations and easements of record, all as more particularly set d8 o forth in the Declaration of Condominium dated July 12, 1973 and 5o recorded in Volume 1356 at Page 13 of the Stamford Land Records, = as same may be amended and/or supplemented from time to time. 2 o= Parcel Id #: 002/ 7071/ / 9C/ (Map #86 350) O E For information only: 44 CERRETTA STREET, STAMFORD, CT 06907. 9 o 5 0 E re □ M E 4 o o O 2 o z EXHIBIT "A" 5 1-01725175 S cs ALL that certain zeal property being described as follows: co o All that certain piece of real property situated in the City of O 00 Stamford in the County of Fairfield and State of Connecticut, xc being part of a condominium and known and designated as Unit 9C, ’’SPRING BROOK TERRACE", Stamford, Connecticut, together with an undivided interest in and to the common areas and facilities of co the condominium, all as set forth in the condominium documents filed and recorded in the Stamford land records. 2 U co TOGETHER iteh fehe benefits-;—gightes ,— privileges. and subject to the burdens, covenants, restrictions bylaws, rules, regulations and easements of record, all as more particularly set Q forth in the Declaration of Condominium dated July 12, 1973 and c 8 recorded in Volume 1356 at Page 13 of the Stamford Land Records, 8 5 o 5 as same may be amended and/or supplemented from time to time. = 2 c o Parcel Id #: 002/ 7071/ / 9C/ (Map #86 350) ■P For information only: 44 CERRETTA STREET, STAMFORD, CT 06907. reE = o o V 0 EE a e • 9 o o O 3 o CERTIFICATE OF SERVICE 3 I hereby certify that a copy of the above was mailed or electronically delivered on January 23, 2024, © 9 < co to all counsel and self-represented parties of record and that written consent for electronic delivery was o 00 received from all counsel and self-represented parties of record who were electronically served: Q 44 Cerretta Street Stamford CT. 06907 Unit 9 LLC P co c/o Agent for Service Chanel Ramirez 44 Cerretta Street 8 cO Stamford, CT 06907 Non-appearing de fendant 8 Q c Chanel Ramirez 88 5 o 44 Cerretta Street, Unit 9 8 Stamford. CT 06907 2 Eo o .O E 3 re E o o By:______ /s/ James R. Byrne____ James R. By me. Esq. (410021) Updike. Kelly & S pel lacy. P.C. V 0 E 5 e 0 c 3 o o O 4