Preview
FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
LAKEVIEW LOAN SERVICING, LLC Index No.
Date Filed:
Plaintiff,
-against- SUMMONS
Premises Address:
WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR; 157 HAWTHORNE STREET
STEPHANIE A. TAYLOR; SUSTAINABLE BROOKLYN, NY 11225
NEIGHBORHOODS, LLC; MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS INC, AS NOMINEE FOR
SECRETARY OF HOUSING AND URBAN
DEVELOPMENT; UNITED STATES OF AMERICA ON
BEHALF OF SECRETARY OF HOUSING AND URBAN
DEVELOPMENT; and "John Doe" and/or "Jane Doe" # 1-
10 inclusive, the last ten names being fictitious and
unknown to Plaintiff, the persons or parties intended being
the tenants, occupants, persons, corporations or heirs at
law, if any, having or claiming an interest in or lien upon
the premises described in the complaint herein,
Defendant(s).
To the above-named Defendant(s):
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy
of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance, on
the Plaintiff's attorneys within twenty (20) days after the service of this summons, exclusive of the day
of service (or within thirty (30) days after the service is complete if this summons is not personally
delivered to you within the State of New York) or within (60) days after service of this summons if it is
the United States of America; and in case of your failure to appear or answer, judgment will be taken
against you by default for the relief demanded in the complaint.
NOTICE OF NATURE OF ACTION AND RELIEF SOUGHT
This is an action to foreclose a mortgage lien on the premises described herein.
The object of the above captioned action is to foreclose a Mortgage executed by STEPHANIE
A. TAYLOR AND WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR as Mortgagors, to
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS MORTGAGEE, AS NOMINEE
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FOR 1ST ALLIANCE LENDING, LLC a Mortgage to secure $434,520.00 and interest, dated July 15,
2011 and recorded in the Office of the City Register of Kings County on July 27, 2011 in CFRN
2011000264020, (the "Mortgage"), which was assigned to 1ST ALLIANCE LENDING, LLC by
Assignment of Mortgage dated July 20, 2012, which was recorded in the Office of the City Register of
Kings County on January 25, 2013 in CFRN 2013000033889, which was assigned to MORTGAGE
ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR 1ST ALLIANCE
LENDING, LLC by Assignment of Mortgage dated June 14, 2016, which was recorded in the Office of
the City Register of Kings County on September 8, 2016 in CFRN 2016000311589, which loan was
modified by a Loan Modification Agreement dated April 15, 2016 to modify said mortgage to an
amount of $336,964.68, which was recorded in the Office of the City Register of Kings County on
July 5, 2016 in CFRN 2016000226636, which was assigned to Lakeview Loan Servicing, LLC by
Assignment of Mortgage dated January 27, 2020, which was recorded in the Office of the City Register
of Kings County on January 30, 2020 in CFRN 2020000038195, which was assigned to Lakeview
Loan Servicing, LLC by Assignment of Mortgage dated February 20, 2020, which was recorded in the
Office of the City Register of Kings County on February 25, 2020 in CFRN 2020000070839, which
loan was modified by a Loan Modification Agreement dated November 1, 2023 to modify said
mortgage to an amount of $331,230.36, which was recorded in the Office of the City Register of Kings
County on October 24, 2023 in CFRN 2023000275535, covering premises known as 157 Hawthorne
Street, Brooklyn, NY 11225.
The relief sought herein is a final judgment directing sale of the premises described above to
satisfy the debt secured by the mortgage described above. The Plaintiff also seeks a deficiency
judgment against the Defendant(s), WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR and
STEPHANIE A. TAYLOR, for any debt secured by said Mortgage which is not satisfied by the
proceeds of the sale of said premises, unless discharged in bankruptcy.
Plaintiff designates Kings County as the place of trial. Venue is based upon the County in which
the mortgaged premises is located.
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NOTICE
YOU ARE IN DANGER OF LOSING YOUR HOME
If you do not respond to this summons and complaint by serving a copy of the answer on
the attorney for the mortgage company who filed this foreclosure proceeding against you and
filing the answer with the court, a default judgment may be entered and you can lose your home.
Speak to an attorney or go to the court where your case is pending for further information on
how to answer the summons and protect your property. Sending a payment to your mortgage
company will not stop this foreclosure action.
YOU MUST RESPOND BY SERVING A COPY OF THE ANSWER ON THE
ATTORNEY FOR THE PLAINTIFF (MORTGAGE COMPANY) AND FILING THE ANSWER
WITH THE COURT.
Dated: May 31, 2024
Tromberg, Morris & Partners, PLLC
By: ____________________________
Joseph G. Devine, Jr.
Attorneys for Plaintiff
39 Broadway, Suite 1250, New York, NY 10006
Phone: (800) 280-6205 Fax: 212-227-9656
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
LAKEVIEW LOAN SERVICING, LLC Index No.
Plaintiff,
-against- COMPLAINT
Mortgaged Premises:
WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR; 157 HAWTHORNE STREET
STEPHANIE A. TAYLOR; SUSTAINABLE BROOKLYN, NY 11225
NEIGHBORHOODS, LLC; MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS INC, AS NOMINEE FOR
SECRETARY OF HOUSING AND URBAN
DEVELOPMENT; UNITED STATES OF AMERICA ON
BEHALF OF SECRETARY OF HOUSING AND URBAN
DEVELOPMENT; and "JOHN DOE" and/or "JANE
DOE" # 1-10 inclusive, the last ten names being fictitious
and unknown to Plaintiff, the persons or parties intended
being the tenants, occupants, persons, corporations or heirs
at law, if any, having or claiming an interest in or lien upon
the premises described in the complaint,
Defendant(s).
The Plaintiff herein, by its attorneys, Tromberg, Morris & Partners, PLLC, complains of the
defendants above named herein and upon information and belief, alleges as follows:
1. At all times herein mentioned, Plaintiff was, and still is a Limited Liability Company organized
and existing under and by virtue of the laws of the State of Delaware, authorized to transact
business in the State of New York.
2. On or about July 15, 2011, STEPHANIE A. TAYLOR, ("Defendant(s)") executed and delivered
to 1st Alliance Lending, LLC, A Connecticut Limited Liability Company a Note (the "Note"),
whereby the Defendant(s) agreed to pay to 1st Alliance Lending, LLC, A Connecticut Limited
Liability Company or its transferees the sum of $434,520.00, plus increases in principal, if any,
with interest thereon, installments of principal and interest to be paid monthly, in substantially
equal payments on the same date of each month until maturity, all as provided in the Note. A
copy of the Note is annexed hereto and made a part hereof.
3. The Plaintiff is the mortgagee and the holder of the subject note and mortgage and if not the
owner, has been delegated the authority to institute a mortgage foreclosure action by the owner
and holder of the subject note and mortgage. See attached note incorporated herein.
Foreclosing party or creditor ("Noteholder"), directly or through an agent, has possession of the
promissory note. The promissory note is either made payable to the Foreclosing Party or has
been duly indorsed.
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4. As collateral security for the payment of said indebtedness, the aforesaid defendant(s) executed
a mortgage by STEPHANIE A. TAYLOR AND WILLIAM E. TAYLOR A/K/A WILLIAM
TAYLOR, as Mortgagors, to Mortgage Electronic Registration Systems, Inc. as nominee for 1st
Alliance Lending, LLC, A Connecticut Limited Liability Company a Mortgage to secure
$434,520.00 and interest, dated July 15, 2011 and recorded in the Office of the City Register of
Kings County on July 27, 2011 in CFRN 2011000264020, which was assigned to 1ST
ALLIANCE LENDING, LLC by Assignment of Mortgage dated July 20, 2012, which was
recorded in the Office of the City Register of Kings County on January 25, 2013 in CFRN
2013000033889, which was assigned to MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INC., AS NOMINEE FOR 1ST ALLIANCE LENDING, LLC by Assignment of
Mortgage dated June 14, 2016, which was recorded in the Office of the City Register of Kings
County on September 8, 2016 in CFRN 2016000311589, which was assigned to Lakeview Loan
Servicing, LLC by Assignment of Mortgage dated January 27, 2020, which was recorded in the
Office of the City Register of Kings County on January 30, 2020 in CFRN 2020000038195,
which was assigned to Lakeview Loan Servicing, LLC by Assignment of Mortgage dated
February 20, 2020, which was recorded in the Office of the City Register of Kings County on
February 25, 2020 in CFRN 2020000070839, which loan was modified by a Loan Modification
Agreement to modify said mortgage to an amount of $336,964.68, which was recorded in the
Office of the City Register of Kings County on July 5, 2016 in CFRN 2016000226636, which
loan was modified by a Loan Modification Agreement to modify said mortgage to an amount of
$331,230.36, which was recorded in the Office of the City Register of Kings County on October
24, 2023 in CFRN 2023000275535, covering premises known as 157 Hawthorne Street,
Brooklyn, NY 11225.
5. The Premises encumbered by said Mortgage, with all appurtenances thereto, is bounded and
fully described in Schedule A annexed hereto and made part hereof.
6. Where applicable, the Plaintiff has complied with all of the provisions of the New York Banking
Law § 595-a, 9-X and rules and regulations promulgated thereunder, Banking Law § 6-l or 6-m
as applicable to the subject loan, and RPAPL § 1304 and §1306, as amended.6.
COUNT I
MORTGAGE FORECLOSURE
7. This is an action to foreclose a mortgage lien on the premises described herein.
8. The object of the instant action is to foreclose a Mortgage securing the premises known as 157
Hawthorne Street, Brooklyn, NY 11225 (hereinafter "Mortgaged Premises"). The Mortgaged
Premises is more fully described in Schedule "A" annexed hereto and made a part hereof.
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9. Pursuant to the terms of said instrument[s] notice of default was mailed to the mortgagor by
certified mail to the last known address of the Mortgagor. The Notice demanded payment at
least 30 days after the date in which the Notice was mailed to the mortgagor.
10. A ninety (90) day pre-foreclosure notice ("90 Day Notice") was sent to WILLIAM E. TAYLOR
A/K/A WILLIAM TAYLOR on 01/19/2024 to the address of the property, at 157 Hawthorne
Street, Brooklyn, NY 11225 and to the Borrowers' last known address which is 157 Hawthorne
Street, Brooklyn, NY 11225 by registered or certified and first class mail. The certified mailing
bore United States Postal Service Tracking Number 9207 1902 5072 8601 2851 56. Copies of
the 90 Day Notices sent to the Borrower are annexed hereto and made a part hereof.
11. A ninety (90) day pre-foreclosure notice ("90 Day Notice") was sent to STEPHANIE A.
TAYLOR on 01/19/2024 to the address of the property, at 157 Hawthorne Street, Brooklyn, NY
11225 and to the Borrowers' last known address which is 157 Hawthorne Street, Brooklyn, NY
11225 by registered or certified and first class mail. The certified mailing bore United States
Postal Service Tracking Number 9207 1902 5072 8601 2851 63. Copies of the 90 Day Notices
sent to the Borrower are annexed hereto and made a part hereof.
12. The Plaintiff, assignee or mortgage loan servicer, has timely complied with the provisions of
RPAPL § 1306. Copies of the RPAPL § 1306 Proof of Filing Step 1 with the DFS are included
with the 90 Day Notices sent to the Borrower are annexed hereto and made a part hereof.
13. WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR and STEPHANIE A. TAYLOR are named
as Defendant(s) because he/she is the purported owner(s) of record of the Premises and is
obligor(s) on a certain note secured by a mortgage on the Premises. (See Schedule B attached
hereto)
14. "John Doe" and/or "Jane Doe" # 1-10 inclusive, are fictitious and unknown to Plaintiff. They
are named as Defendant(s) to designate any and all tenants, occupants, persons, corporations or
heirs at law, if any, having or claiming an interest in or lien upon the Premises
15. The Note provides that in the event any installment shall become overdue for a period in excess
of 15 days, a late charge on the overdue sum may be charged for the purpose of defraying the
expense in handling such delinquent payment.
16. The Mortgage provides, that in the event of a default in the payment of any principal or interest
that might become due thereon, Plaintiff may declare the entire indebtedness secured by the
Mortgage immediately due and payable and commence an action to foreclose the Defendant(s)
rights in the Premises and sell them pursuant to applicable law.
17. The Note and Mortgage obligates the Defendant(s), to pay Plaintiff's reasonable attorney's fees
in the event of a default and in any action to foreclose the Mortgage.
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18. That the Mortgagor(s) defaulted on the Mortgage on November 1, 2023 and since that date has
failed to comply with the conditions of the Mortgage by failing to pay portions of principal,
interest or taxes, assessments, water rates, insurance premiums, escrow and/or other charges.
19. As a result of the foregoing and in accordance with its rights under the Note and Mortgage,
Plaintiff has elected to exercise its option to demand immediate payment in full of the amounts
outstanding under the Note and Mortgage and has notified the Defendant(s) of its decision to
demand immediate payment in full.
20. As a result of the Defendant(s) failure to pay the obligation under the Note and Mortgage and
any loan modifications, there is now due and owing to Plaintiff on the principal of the Mortgage
the sum of $331,230.36, together with accrued interest from October 1, 2023 at the present rate
of 7.75000% as stated in the Note and Mortgage, and such other payments as are set forth in the
Note and Mortgage. Notwithstanding the foregoing, Plaintiff seeks the unpaid principal balance,
interest arrears, escrows and such other payments as may be due under the note and mortgage as
may be collected under applicable New York law. Plaintiff does not seek to sue or collect on
any debt that may be barred under the statute of limitations.
21. In order to protect the value of the property and its rights in the property, the Plaintiff may have
to pay additional taxes, assessments, water charges, insurance premiums and other charges and
the costs, allowances, expenses of sale, and reasonable attorney's fees for the foreclosure.
Plaintiff requests that any amount it pays, together with interest, be included in the total amount
due.
22. The Mortgage provides that, in the case of foreclosure, the mortgaged premises may be sold in
one parcel.
23. That in order to protect its security, Plaintiff may be compelled during the pendency of this
action to make repairs to, board, secure, protect and maintain the premises, to pay taxes,
assessments, water rates, sewer rentals, insurance premiums, mortgage insurance premiums, if
there be any, and other charges affecting the premises, and the Plaintiff requests that any sum so
paid be added to the sum otherwise due, with interest as provided in the aforesaid instruments,
and be deemed secured by said instrument[s] and adjudged a valid lien on the premises
hereinabove described.
24. That the Plaintiff requests that in the event this action proceeds to Judgment of Foreclosure and
Sale, said premises be sold subject to covenants, restrictions and easements, prior mortgages
and liens, and amendments, if any, of record; any state of facts an accurate survey may show;
restrictions, regulations, ordinances and zoning ordinances of any municipal or governmental
authority having jurisdiction thereof; and municipal, departmental and other governmental
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violations, if any, affecting the premises; and real estate taxes, sewer rents, water charges, if
any, open of record.
25. The Plaintiff shall not be deemed to have waived, altered, released or changed the election
hereinbefore made by reason of the payment, after the date of the commencement of this action,
of any or all of the defaults mentioned herein; and such election shall continue and remain
effective until the costs and disbursements of this action, and all present and future defaults
under the Note and Mortgage and occurring prior to the discontinuance of this action are fully
paid.
26. In the event the Plaintiff possesses any other liens against the mortgaged premises either by way
of a junior mortgage or otherwise, the Plaintiff requests that such other liens shall not be merged
into the cause of action set forth in this complaint, but that the Plaintiff shall be permitted to
enforce said other liens and seek determination of the priority thereof in any independent action
or proceeding including without limitation any surplus money proceeding.
27. No separate pending action was brought to recover any part of the mortgage debt or if any such
action is pending final judgment for Plaintiff was not rendered and it is the intent of the Plaintiff
to discontinue it.
WHEREFORE, Plaintiff demands judgment against the Defendant(s) as follows:
(a) Defendant(s) and all persons claiming under said defendant(s) or any of them
subsequent to the filing of a Notice of Pendency of this action in the appropriate County
Clerk's Office, and every person whose conveyance is subsequent or subsequently
recorded, be barred and foreclosed of all right, title claim or lien and equity of
redemption in said mortgaged premises; that such mortgaged premises be decreed to be
sold as one parcel, subject to and should be sold subject to any state of facts an accurate
survey or inspection of the premises would show, encroachments, covenants,
restrictions, agreements and easements of record, if any, real estate taxes and zoning
restrictions and otherwise of any governmental authority having jurisdiction thereover
affecting said premises and any prior mortgages or liens of record and the rights of the
United States of America to redeem the Premises, and that the monies arising from said
lien be paid into Court;
(b) That the Court direct that the Premises can be sold according to law, in one
parcel or otherwise as equity may require;
(c) That a receiver be appointed for the property, if requested by Plaintiff;
(d) That the monies arising from the sale of the Premises may be brought into Court
or paid to the Plaintiff in accordance with RPAPL§ 1354.
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(e) That the monies due to Plaintiff on the Mortgage may be adjudged and
computed;
(f) That Plaintiff may be paid the amount adjudged to be due on the Mortgage with
interest at the time of such payment, together with any monies advanced and paid
pursuant to any term or provision of the Mortgage so as to protect the lien of the
Mortgage, and together with taxes, insurance premiums and all other charges and liens
paid thereon with interest upon said amount from the date of the respective payments
and advances, together with all amounts due by virtue of statutory costs, allowances and
attorney's fees, together with any reasonable attorney's fees over and above the amounts
covered by the statutory attorney's fees, together with the expenses of the sale insofar as
the amount of such monies properly applicable thereto will pay the same;
(g) That if the proceeds of the sale of the Premises are insufficient to pay the amount
found due to Plaintiff as set forth in the immediately preceding paragraph, the officer
making the sale be required by the judgment of sale herein to specify the amount of such
deficiency in the report of sale;
(h) The obligor(s) may be adjudged to pay any deficiency which may remain after
applying all of said monies so applicable thereto unless the obligors were discharged in
bankruptcy;
(i) That Plaintiff be awarded reasonable attorney's fees as provided in the Note and
Mortgage, as well as the costs and disbursements of this action; and
(j) That Plaintiff has such other and further relief as may be just and proper
Dated: May 31, 2024
Tromberg, Morris & Partners, PLLC
By: ____________________________
Joseph G. Devine, Jr.
Attorneys for Plaintiff
39 Broadway, Suite 1250, New York, NY 10006
Phone: (800) 280-6205 Fax: 212-227-9656
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INDEX #
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
LAKEVIEW LOAN SERVICING, LLC
Plaintiff,
-against-
WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR; STEPHANIE A. TAYLOR; SUSTAINABLE
NEIGHBORHOODS, LLC; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC, AS
NOMINEE FOR SECRETARY OF HOUSING AND URBAN DEVELOPMENT; UNITED STATES
OF AMERICA ON BEHALF OF SECRETARY OF HOUSING AND URBAN DEVELOPMENT;
and "John Doe" and/or "Jane Doe" # 1-10 inclusive, the last ten names being fictitious and unknown
to Plaintiff, the persons or parties intended being the tenants, occupants, persons, corporations or heirs
at law, if any, having or claiming an interest in or lien upon the premises described in the complaint
Defendant(s)
SUMMONS AND COMPLAINT
Tromberg, Morris & Partners, PLLC
Attorneys for Plaintiff
39 Broadway, Suite 1250, New York, NY 10006
Phone: (800) 280-6205 Fax: 212-227-9656
Our file #: 24-000631
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
LAKEVIEW LOAN SERVICING, LLC Index No.
Plaintiff,
-against-
WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR;
STEPHANIE A. TAYLOR; SUSTAINABLE
NEIGHBORHOODS, LLC; MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS INC, AS NOMINEE FOR
SECRETARY OF HOUSING AND URBAN DEVELOPMENT;
UNITED STATES OF AMERICA ON BEHALF OF SECRETARY
OF HOUSING AND URBAN DEVELOPMENT; ''JOHN DOES''
and ''JANE DOES,'' said names being fictitious, parties intended
being possible tenants or occupants of premises and corporations,
other entities or persons who have, claim, or may claim, a lien
against or other interest in, the premises,
Defendant(s).
NOTICE REGARDING AVAILABILITY OF ELECTRONIC FILING
SUPREME COURT CASES
PLEASE TAKE NOTICE that Plaintiff(s)/petitioner(s) [defendant(s)/respondent(s)] in the case
captioned above intends that this matter proceed as an electronically-filed case in the New York State
Courts Electronic Filing System ("NYSCEF") in accordance with the procedures therefor, set forth in
Uniform Rule 202.5-b and described below. Under that Rule, filing and service of papers by electronic
means cannot be made by a party nor can electronic service be made upon a party unless that party has
consented to use of the System for the case in question. Each party served with this Notice must
promptly file with the court and serve on all other parties either a consent or a declination of consent to
electronic filing and service through NYSCEF for this case. (See Instruction # 2 below.)
General Information
Electronic filing offers significant benefits for attorneys and litigants, permitting documents to
be filed with the County Clerk and the court and served, between or among consenting parties, by
posting the documents on the NYSCEF Website, which can be done at any time of the day or night on
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any day of the week. There is no fee to use the NYSCEF System, whether for filing, service, or
consultation of the electronic docket, nor is there a charge to print documents from the docket. Normal
filing fees must be paid, but this can be done by credit or bank card on-line. For additional procedures
and information, see Uniform Rule 202.5-b, any e-filing protocol that may have been promulgated by
the court in question, and the NYSCEF Website at www.nycourts.gov/efile.
Instructions
1. Service of this Notice constitutes consent to e-filing and a statement of intent by the
undersigned to use the NYSCEF System in this case. When an action or proceeding is being
commenced through the NYSCEF System, this Notice must accompany service of the initiating papers.
2. Each party served with this Notice may consent to e-filing either: (i) by filing with the court and
serving on all parties of record a consent to e-filing, or (ii) if an authorized e-filing user, by filing a
consent electronically in the manner provided at the NYSCEF site. Parties who do not wish to consent
must file and serve a written declination of consent. If one party or some but fewer than all parties
consent, NYSCEF may be used by and between or among consenting parties.
3. Each participating attorney, unless already registered, or self-represented party must
PROMPTLY create a NYSCEF account and obtain the confidential Filing User Identification Number
and Password necessary to use the system. To create a NYSCEF account, go to
www.nycourts.gov/efile, click the Create an Account link, and follow the instructions.
4. For additional information about NYSCEF, see the User's Manual and Frequently Asked
Questions on the Website, or contact the court in question or the NYSCEF Resource Center (at 646-
386-3033 or efile@courts.state.ny.us).
Dated: May 31, 2024
Tromberg, Morris & Partners, PLLC
By: ____________________________
Joseph G. Devine, Jr.
Attorneys for Plaintiff
39 Broadway, Suite 1250, New York, NY 10006
Phone: (800) 280-6205 Fax: 212-227-9656
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SCHEDULE A
ALL THAT CERTAIN PLOT, PIECE OR PARCEL OF LAND, SITUATE, LYING AND BEING
IN THE BOROUGH OF
BROOKLYN, COUNTY OF KINGS, CITY AND STATE OF NEW YORK, BOUNDED AND
DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT ON THE NORTHERLY SIDE OF HAWTHORNE STREET
DISTANT 353 FEET; 2 1/2 INCHES
EASTERLY FROM THE CORNER FORMED BY THE INTERSECTION OF THE
NORTHERLY SIDE OF HAWTHORNE
STREET AND THE EASTERLY SIDE OF BEDFORD AVENUE;
RUNNING THENCE NORTHERLY AT RIGHT ANGLES TO HAWTHORNE STREET 167
FEET 5 INCHES;
THENCE EASTERLY NEARLY PARALLEL WITH HAWTHORNE STREET 29 FEET 8
INCHES TO A POINT IN A LINE
DRAWN AT RIGHT ANGLES TO HAWTHORNE STREET AND DISTANT 167 FEET 4-1/2
INCHES NORTHERLY
THEREFROM; THENCE SOUTHERLY ALONG SAID LINE 167 FEET 4-1/2 INCHES TO
THE NORTHERLY SIDE OF HAWTHORNE
STREET AND THENCE WESTERLY ALONG THE NORTHERLY SIDE OF HAWTHORNE
STREET 29 FEET 8 INCHES TO THE POINT OR PLACE OF BEGINNING.
Property Address: 157 Hawthorne Street, Brooklyn, NY 11225
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SCHEDULE B
WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR and STEPHANIE A. TAYLOR is named herein
as party defendant(s) because they are certified owners of the subject premises, are obligors under the
note and they mortgaged their interest.
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS MORTGAGEE is named herein
as party defendant because it has or claims to have a judgment; Dated: 03/28/2016; Recorded:
07/05/2016, In favor of: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS
MORTGAGEE, Against: 1ST ALLIANCE LENDING, LLC, Amount: $0.00, which is subordinate to
Plaintiff.
SUSTAINABLE NEIGHBORHOODS, LLC is named herein as party defendant because it has or
claims to have a judgment; Dated: 10/11/2023; Recorded: 10/11/2023, In favor of: SUSTAINABLE
NEIGHBORHOODS, LLC, Against: STEPHANIE A. TAYLOR AND WILLIAM E. TAYLOR A/K/A
WILLIAM TAYLOR, Amount: $0.00, which is subordinate to Plaintiff.
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC, AS NOMINEE FOR SECRETARY
OF HOUSING AND URBAN DEVELOPMENT is named herein as party defendant because it has or
claims to have a lien by virtue of a Mortgage, Dated: 07/15/2011; Recorded: 07/27/2011, Amount:
$110,701.01, which is subordinate to Plaintiff.
UNITED STATES OF AMERICA ON BEHALF OF SECRETARY OF HOUSING AND URBAN
DEVELOPMENT is named herein as party defendant because it has or claims to have a lien by virtue
of a Mortgage, Dated: 04/15/2016; Recorded: 07/05/2016, Amount: $124,559.89, which is
subordinate to Plaintiff.
UNITED STATES OF AMERICA ON BEHALF OF SECRETARY OF HOUSING AND URBAN
DEVELOPMENT is named herein as party defendant because it has or claims to have a lien by virtue
of a Mortgage, Dated: 10/13/2023; Recorded: 10/24/2023, Amount: $305.36, which is subordinate to
Plaintiff.
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.. . CERTIF1 D COPY
NOTE
FHACase No.
JULY 15 , 2 011 EAST HARTFORD CONNECTICUT
[Date] [city] [state]
157 HAWTHORNE
STREET, BROOKLYN, NEWYORK112 2 5
[Property Address]
1. PARTIES
"Borrower" end of
raeans each person signing at the this Note, and the person's successors and assigns.
"Lender"means 1ST ALLIANCE LENDING, LLC, A CONNECTICUTLIMITED
LIABILITY COMPANY and its successors and assigns.
2. BORROWER'S
PROMISETO PAY; INTEREST
In retura for a loan received from Lender, Borrower promises to pay the principal sum of
FOUR HUNDREDTHIRTY- FOUR THOUSANDFIVE HUNDREDTWENTYAND O0 / 10 O
Dollars (U.S. 5 43 4 , 5 20 . 0 0 ),
plus interest, to the order of Leader. Interest will be charged on unpaid principal, from the date of disbursement of
the loan proceeds by Lender, at the rate of SIX 25 O/1O OO AND percent
( 6 . 2 5O %) per year until the full amount of principal has been paid.
3. PROMISETO PAYSECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated
Instrument."
the same date as this Note and called the "Security The Security Instrument protects the Lender from
losses which might result if Borrower defaults under this Note.
4. MANNEROFPAYMENT
(A) Time
Borrower shall makeapayment of principal and interest to Lender on the 1st day of each month beginning
on AUGUST1, 2 011 . Any principal and interest remaining on the 1st day of
JULY , 2 041 , will be due on that date, which is called the "Maturity Date."
(B) Place
Payment shall be madeat P . O. BOX 8 O6 8 , VIRGINIA BEACH, VIRGINIA 23 45 O
, or at such other place
as Leader may designate in writing by notice to Borrower.
(C) Amount
Each rnonthly payment of principal and interest will be in the amount of U.S. $ 2 , 67 S . 41 .
This amount win be part of a larger monthly payment required by the Security Instrument, that shall be applied to
principal, interest and other items in the order described in the Security Instrument.
(D) Allonge to this Note for Payment Adjustments
Ifan allonge providing for payment adjustments is executedby Borrowertogether with this Note, the covenants
of the allonge shall be incorporated into and shall amendand supplement the covenants ofthis Note as if the allonge
were a part of this Note.
MULTISTATE- FHA FlXED RATENOTE DocMa c
U$FHA.NTE09/25/09 Page 1 of 3 www. cmagic.com
15 of 152
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(Check applicable box.)
O Growing Equity Allonge
¡ Graduated Payment Allonge
¡ Other [specify]:
5. RIGHT TO PREPAY
BORROWER'S
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty,
that Borrower pays interest
on the first day of any month. Lender shall accept prepayment on other days provided
required Lender and permitted by regulations
on the amount prepaid for the remainder of the month to the extent by
the due date or in the amount
of the Secretary. If Borrower makes a partial prepayment, there will be no changes in
those changes.
of the monthly payment unless Lender agrees in writing to
6. FAILURE TO PAY
BORROWER'S
(A) Late Charge for Overdue Payments
as described in
If Leader has not received the full monthly payment required by
the Security Instrument,
the end of fifteen calendar days after the payment is due, Lender may collect a late
Paragraph 4(C) of this Note, by
charge in the amount of FOUR AND
0 0 O/10 0 O percent ( 4 . 00 0 %)
of the overdue amount of each payment.
(B) Default
except as limited by
If Borrower defaults by failing any monthly payment, then Lender may,
to pay in full
immediate payment in of the principal balance
regulations ofthe Secretary in the case of payment defaults, require full
Leader may choose not to exercise this option without waiving fts rights in
remaining due and all accrued interest.
issued the Secretary wíII limit Lender's
the event of any subsequent default. In many circumstances, regulations by
rights to require immediate payment in full in the case of
payment defaults. This Note does not authorize acceleration
"Secretary" means the
when not permitted by HUD
regulations- As used in this Note, Secretary of Housing and
Urban Development or his or her designee.
(C) Payment of Costs and
Expenses
IfLender has required immediate payment in full, as described above,
Lender mayrequire Borrower to pay costs
attorneys' prohibited
and expenses including reasonable and customary fees for enforcing this Note to the extent not
disbursement at the same rate as the
by applicable law. Such fees and costs shall bear interest from the date of
principal of this Note.
7. WAlVER
Preview
FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS LAKEVIEW LOAN SERVICING, LLC Index No. Date Filed: Plaintiff, -against- SUMMONS Premises Address: WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR; 157 HAWTHORNE STREET STEPHANIE A. TAYLOR; SUSTAINABLE BROOKLYN, NY 11225 NEIGHBORHOODS, LLC; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC, AS NOMINEE FOR SECRETARY OF HOUSING AND URBAN DEVELOPMENT; UNITED STATES OF AMERICA ON BEHALF OF SECRETARY OF HOUSING AND URBAN DEVELOPMENT; and "John Doe" and/or "Jane Doe" # 1- 10 inclusive, the last ten names being fictitious and unknown to Plaintiff, the persons or parties intended being the tenants, occupants, persons, corporations or heirs at law, if any, having or claiming an interest in or lien upon the premises described in the complaint herein, Defendant(s). To the above-named Defendant(s): YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance, on the Plaintiff's attorneys within twenty (20) days after the service of this summons, exclusive of the day of service (or within thirty (30) days after the service is complete if this summons is not personally delivered to you within the State of New York) or within (60) days after service of this summons if it is the United States of America; and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. NOTICE OF NATURE OF ACTION AND RELIEF SOUGHT This is an action to foreclose a mortgage lien on the premises described herein. The object of the above captioned action is to foreclose a Mortgage executed by STEPHANIE A. TAYLOR AND WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR as Mortgagors, to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS MORTGAGEE, AS NOMINEE 1 of 152 FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 FOR 1ST ALLIANCE LENDING, LLC a Mortgage to secure $434,520.00 and interest, dated July 15, 2011 and recorded in the Office of the City Register of Kings County on July 27, 2011 in CFRN 2011000264020, (the "Mortgage"), which was assigned to 1ST ALLIANCE LENDING, LLC by Assignment of Mortgage dated July 20, 2012, which was recorded in the Office of the City Register of Kings County on January 25, 2013 in CFRN 2013000033889, which was assigned to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR 1ST ALLIANCE LENDING, LLC by Assignment of Mortgage dated June 14, 2016, which was recorded in the Office of the City Register of Kings County on September 8, 2016 in CFRN 2016000311589, which loan was modified by a Loan Modification Agreement dated April 15, 2016 to modify said mortgage to an amount of $336,964.68, which was recorded in the Office of the City Register of Kings County on July 5, 2016 in CFRN 2016000226636, which was assigned to Lakeview Loan Servicing, LLC by Assignment of Mortgage dated January 27, 2020, which was recorded in the Office of the City Register of Kings County on January 30, 2020 in CFRN 2020000038195, which was assigned to Lakeview Loan Servicing, LLC by Assignment of Mortgage dated February 20, 2020, which was recorded in the Office of the City Register of Kings County on February 25, 2020 in CFRN 2020000070839, which loan was modified by a Loan Modification Agreement dated November 1, 2023 to modify said mortgage to an amount of $331,230.36, which was recorded in the Office of the City Register of Kings County on October 24, 2023 in CFRN 2023000275535, covering premises known as 157 Hawthorne Street, Brooklyn, NY 11225. The relief sought herein is a final judgment directing sale of the premises described above to satisfy the debt secured by the mortgage described above. The Plaintiff also seeks a deficiency judgment against the Defendant(s), WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR and STEPHANIE A. TAYLOR, for any debt secured by said Mortgage which is not satisfied by the proceeds of the sale of said premises, unless discharged in bankruptcy. Plaintiff designates Kings County as the place of trial. Venue is based upon the County in which the mortgaged premises is located. 2 of 152 FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 NOTICE YOU ARE IN DANGER OF LOSING YOUR HOME If you do not respond to this summons and complaint by serving a copy of the answer on the attorney for the mortgage company who filed this foreclosure proceeding against you and filing the answer with the court, a default judgment may be entered and you can lose your home. Speak to an attorney or go to the court where your case is pending for further information on how to answer the summons and protect your property. Sending a payment to your mortgage company will not stop this foreclosure action. YOU MUST RESPOND BY SERVING A COPY OF THE ANSWER ON THE ATTORNEY FOR THE PLAINTIFF (MORTGAGE COMPANY) AND FILING THE ANSWER WITH THE COURT. Dated: May 31, 2024 Tromberg, Morris & Partners, PLLC By: ____________________________ Joseph G. Devine, Jr. Attorneys for Plaintiff 39 Broadway, Suite 1250, New York, NY 10006 Phone: (800) 280-6205 Fax: 212-227-9656 3 of 152 FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS LAKEVIEW LOAN SERVICING, LLC Index No. Plaintiff, -against- COMPLAINT Mortgaged Premises: WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR; 157 HAWTHORNE STREET STEPHANIE A. TAYLOR; SUSTAINABLE BROOKLYN, NY 11225 NEIGHBORHOODS, LLC; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC, AS NOMINEE FOR SECRETARY OF HOUSING AND URBAN DEVELOPMENT; UNITED STATES OF AMERICA ON BEHALF OF SECRETARY OF HOUSING AND URBAN DEVELOPMENT; and "JOHN DOE" and/or "JANE DOE" # 1-10 inclusive, the last ten names being fictitious and unknown to Plaintiff, the persons or parties intended being the tenants, occupants, persons, corporations or heirs at law, if any, having or claiming an interest in or lien upon the premises described in the complaint, Defendant(s). The Plaintiff herein, by its attorneys, Tromberg, Morris & Partners, PLLC, complains of the defendants above named herein and upon information and belief, alleges as follows: 1. At all times herein mentioned, Plaintiff was, and still is a Limited Liability Company organized and existing under and by virtue of the laws of the State of Delaware, authorized to transact business in the State of New York. 2. On or about July 15, 2011, STEPHANIE A. TAYLOR, ("Defendant(s)") executed and delivered to 1st Alliance Lending, LLC, A Connecticut Limited Liability Company a Note (the "Note"), whereby the Defendant(s) agreed to pay to 1st Alliance Lending, LLC, A Connecticut Limited Liability Company or its transferees the sum of $434,520.00, plus increases in principal, if any, with interest thereon, installments of principal and interest to be paid monthly, in substantially equal payments on the same date of each month until maturity, all as provided in the Note. A copy of the Note is annexed hereto and made a part hereof. 3. The Plaintiff is the mortgagee and the holder of the subject note and mortgage and if not the owner, has been delegated the authority to institute a mortgage foreclosure action by the owner and holder of the subject note and mortgage. See attached note incorporated herein. Foreclosing party or creditor ("Noteholder"), directly or through an agent, has possession of the promissory note. The promissory note is either made payable to the Foreclosing Party or has been duly indorsed. 4 of 152 FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 4. As collateral security for the payment of said indebtedness, the aforesaid defendant(s) executed a mortgage by STEPHANIE A. TAYLOR AND WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR, as Mortgagors, to Mortgage Electronic Registration Systems, Inc. as nominee for 1st Alliance Lending, LLC, A Connecticut Limited Liability Company a Mortgage to secure $434,520.00 and interest, dated July 15, 2011 and recorded in the Office of the City Register of Kings County on July 27, 2011 in CFRN 2011000264020, which was assigned to 1ST ALLIANCE LENDING, LLC by Assignment of Mortgage dated July 20, 2012, which was recorded in the Office of the City Register of Kings County on January 25, 2013 in CFRN 2013000033889, which was assigned to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR 1ST ALLIANCE LENDING, LLC by Assignment of Mortgage dated June 14, 2016, which was recorded in the Office of the City Register of Kings County on September 8, 2016 in CFRN 2016000311589, which was assigned to Lakeview Loan Servicing, LLC by Assignment of Mortgage dated January 27, 2020, which was recorded in the Office of the City Register of Kings County on January 30, 2020 in CFRN 2020000038195, which was assigned to Lakeview Loan Servicing, LLC by Assignment of Mortgage dated February 20, 2020, which was recorded in the Office of the City Register of Kings County on February 25, 2020 in CFRN 2020000070839, which loan was modified by a Loan Modification Agreement to modify said mortgage to an amount of $336,964.68, which was recorded in the Office of the City Register of Kings County on July 5, 2016 in CFRN 2016000226636, which loan was modified by a Loan Modification Agreement to modify said mortgage to an amount of $331,230.36, which was recorded in the Office of the City Register of Kings County on October 24, 2023 in CFRN 2023000275535, covering premises known as 157 Hawthorne Street, Brooklyn, NY 11225. 5. The Premises encumbered by said Mortgage, with all appurtenances thereto, is bounded and fully described in Schedule A annexed hereto and made part hereof. 6. Where applicable, the Plaintiff has complied with all of the provisions of the New York Banking Law § 595-a, 9-X and rules and regulations promulgated thereunder, Banking Law § 6-l or 6-m as applicable to the subject loan, and RPAPL § 1304 and §1306, as amended.6. COUNT I MORTGAGE FORECLOSURE 7. This is an action to foreclose a mortgage lien on the premises described herein. 8. The object of the instant action is to foreclose a Mortgage securing the premises known as 157 Hawthorne Street, Brooklyn, NY 11225 (hereinafter "Mortgaged Premises"). The Mortgaged Premises is more fully described in Schedule "A" annexed hereto and made a part hereof. 5 of 152 FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 9. Pursuant to the terms of said instrument[s] notice of default was mailed to the mortgagor by certified mail to the last known address of the Mortgagor. The Notice demanded payment at least 30 days after the date in which the Notice was mailed to the mortgagor. 10. A ninety (90) day pre-foreclosure notice ("90 Day Notice") was sent to WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR on 01/19/2024 to the address of the property, at 157 Hawthorne Street, Brooklyn, NY 11225 and to the Borrowers' last known address which is 157 Hawthorne Street, Brooklyn, NY 11225 by registered or certified and first class mail. The certified mailing bore United States Postal Service Tracking Number 9207 1902 5072 8601 2851 56. Copies of the 90 Day Notices sent to the Borrower are annexed hereto and made a part hereof. 11. A ninety (90) day pre-foreclosure notice ("90 Day Notice") was sent to STEPHANIE A. TAYLOR on 01/19/2024 to the address of the property, at 157 Hawthorne Street, Brooklyn, NY 11225 and to the Borrowers' last known address which is 157 Hawthorne Street, Brooklyn, NY 11225 by registered or certified and first class mail. The certified mailing bore United States Postal Service Tracking Number 9207 1902 5072 8601 2851 63. Copies of the 90 Day Notices sent to the Borrower are annexed hereto and made a part hereof. 12. The Plaintiff, assignee or mortgage loan servicer, has timely complied with the provisions of RPAPL § 1306. Copies of the RPAPL § 1306 Proof of Filing Step 1 with the DFS are included with the 90 Day Notices sent to the Borrower are annexed hereto and made a part hereof. 13. WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR and STEPHANIE A. TAYLOR are named as Defendant(s) because he/she is the purported owner(s) of record of the Premises and is obligor(s) on a certain note secured by a mortgage on the Premises. (See Schedule B attached hereto) 14. "John Doe" and/or "Jane Doe" # 1-10 inclusive, are fictitious and unknown to Plaintiff. They are named as Defendant(s) to designate any and all tenants, occupants, persons, corporations or heirs at law, if any, having or claiming an interest in or lien upon the Premises 15. The Note provides that in the event any installment shall become overdue for a period in excess of 15 days, a late charge on the overdue sum may be charged for the purpose of defraying the expense in handling such delinquent payment. 16. The Mortgage provides, that in the event of a default in the payment of any principal or interest that might become due thereon, Plaintiff may declare the entire indebtedness secured by the Mortgage immediately due and payable and commence an action to foreclose the Defendant(s) rights in the Premises and sell them pursuant to applicable law. 17. The Note and Mortgage obligates the Defendant(s), to pay Plaintiff's reasonable attorney's fees in the event of a default and in any action to foreclose the Mortgage. 6 of 152 FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 18. That the Mortgagor(s) defaulted on the Mortgage on November 1, 2023 and since that date has failed to comply with the conditions of the Mortgage by failing to pay portions of principal, interest or taxes, assessments, water rates, insurance premiums, escrow and/or other charges. 19. As a result of the foregoing and in accordance with its rights under the Note and Mortgage, Plaintiff has elected to exercise its option to demand immediate payment in full of the amounts outstanding under the Note and Mortgage and has notified the Defendant(s) of its decision to demand immediate payment in full. 20. As a result of the Defendant(s) failure to pay the obligation under the Note and Mortgage and any loan modifications, there is now due and owing to Plaintiff on the principal of the Mortgage the sum of $331,230.36, together with accrued interest from October 1, 2023 at the present rate of 7.75000% as stated in the Note and Mortgage, and such other payments as are set forth in the Note and Mortgage. Notwithstanding the foregoing, Plaintiff seeks the unpaid principal balance, interest arrears, escrows and such other payments as may be due under the note and mortgage as may be collected under applicable New York law. Plaintiff does not seek to sue or collect on any debt that may be barred under the statute of limitations. 21. In order to protect the value of the property and its rights in the property, the Plaintiff may have to pay additional taxes, assessments, water charges, insurance premiums and other charges and the costs, allowances, expenses of sale, and reasonable attorney's fees for the foreclosure. Plaintiff requests that any amount it pays, together with interest, be included in the total amount due. 22. The Mortgage provides that, in the case of foreclosure, the mortgaged premises may be sold in one parcel. 23. That in order to protect its security, Plaintiff may be compelled during the pendency of this action to make repairs to, board, secure, protect and maintain the premises, to pay taxes, assessments, water rates, sewer rentals, insurance premiums, mortgage insurance premiums, if there be any, and other charges affecting the premises, and the Plaintiff requests that any sum so paid be added to the sum otherwise due, with interest as provided in the aforesaid instruments, and be deemed secured by said instrument[s] and adjudged a valid lien on the premises hereinabove described. 24. That the Plaintiff requests that in the event this action proceeds to Judgment of Foreclosure and Sale, said premises be sold subject to covenants, restrictions and easements, prior mortgages and liens, and amendments, if any, of record; any state of facts an accurate survey may show; restrictions, regulations, ordinances and zoning ordinances of any municipal or governmental authority having jurisdiction thereof; and municipal, departmental and other governmental 7 of 152 FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 violations, if any, affecting the premises; and real estate taxes, sewer rents, water charges, if any, open of record. 25. The Plaintiff shall not be deemed to have waived, altered, released or changed the election hereinbefore made by reason of the payment, after the date of the commencement of this action, of any or all of the defaults mentioned herein; and such election shall continue and remain effective until the costs and disbursements of this action, and all present and future defaults under the Note and Mortgage and occurring prior to the discontinuance of this action are fully paid. 26. In the event the Plaintiff possesses any other liens against the mortgaged premises either by way of a junior mortgage or otherwise, the Plaintiff requests that such other liens shall not be merged into the cause of action set forth in this complaint, but that the Plaintiff shall be permitted to enforce said other liens and seek determination of the priority thereof in any independent action or proceeding including without limitation any surplus money proceeding. 27. No separate pending action was brought to recover any part of the mortgage debt or if any such action is pending final judgment for Plaintiff was not rendered and it is the intent of the Plaintiff to discontinue it. WHEREFORE, Plaintiff demands judgment against the Defendant(s) as follows: (a) Defendant(s) and all persons claiming under said defendant(s) or any of them subsequent to the filing of a Notice of Pendency of this action in the appropriate County Clerk's Office, and every person whose conveyance is subsequent or subsequently recorded, be barred and foreclosed of all right, title claim or lien and equity of redemption in said mortgaged premises; that such mortgaged premises be decreed to be sold as one parcel, subject to and should be sold subject to any state of facts an accurate survey or inspection of the premises would show, encroachments, covenants, restrictions, agreements and easements of record, if any, real estate taxes and zoning restrictions and otherwise of any governmental authority having jurisdiction thereover affecting said premises and any prior mortgages or liens of record and the rights of the United States of America to redeem the Premises, and that the monies arising from said lien be paid into Court; (b) That the Court direct that the Premises can be sold according to law, in one parcel or otherwise as equity may require; (c) That a receiver be appointed for the property, if requested by Plaintiff; (d) That the monies arising from the sale of the Premises may be brought into Court or paid to the Plaintiff in accordance with RPAPL§ 1354. 8 of 152 FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 (e) That the monies due to Plaintiff on the Mortgage may be adjudged and computed; (f) That Plaintiff may be paid the amount adjudged to be due on the Mortgage with interest at the time of such payment, together with any monies advanced and paid pursuant to any term or provision of the Mortgage so as to protect the lien of the Mortgage, and together with taxes, insurance premiums and all other charges and liens paid thereon with interest upon said amount from the date of the respective payments and advances, together with all amounts due by virtue of statutory costs, allowances and attorney's fees, together with any reasonable attorney's fees over and above the amounts covered by the statutory attorney's fees, together with the expenses of the sale insofar as the amount of such monies properly applicable thereto will pay the same; (g) That if the proceeds of the sale of the Premises are insufficient to pay the amount found due to Plaintiff as set forth in the immediately preceding paragraph, the officer making the sale be required by the judgment of sale herein to specify the amount of such deficiency in the report of sale; (h) The obligor(s) may be adjudged to pay any deficiency which may remain after applying all of said monies so applicable thereto unless the obligors were discharged in bankruptcy; (i) That Plaintiff be awarded reasonable attorney's fees as provided in the Note and Mortgage, as well as the costs and disbursements of this action; and (j) That Plaintiff has such other and further relief as may be just and proper Dated: May 31, 2024 Tromberg, Morris & Partners, PLLC By: ____________________________ Joseph G. Devine, Jr. Attorneys for Plaintiff 39 Broadway, Suite 1250, New York, NY 10006 Phone: (800) 280-6205 Fax: 212-227-9656 9 of 152 FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 INDEX # SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS LAKEVIEW LOAN SERVICING, LLC Plaintiff, -against- WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR; STEPHANIE A. TAYLOR; SUSTAINABLE NEIGHBORHOODS, LLC; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC, AS NOMINEE FOR SECRETARY OF HOUSING AND URBAN DEVELOPMENT; UNITED STATES OF AMERICA ON BEHALF OF SECRETARY OF HOUSING AND URBAN DEVELOPMENT; and "John Doe" and/or "Jane Doe" # 1-10 inclusive, the last ten names being fictitious and unknown to Plaintiff, the persons or parties intended being the tenants, occupants, persons, corporations or heirs at law, if any, having or claiming an interest in or lien upon the premises described in the complaint Defendant(s) SUMMONS AND COMPLAINT Tromberg, Morris & Partners, PLLC Attorneys for Plaintiff 39 Broadway, Suite 1250, New York, NY 10006 Phone: (800) 280-6205 Fax: 212-227-9656 Our file #: 24-000631 10 of 152 FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS LAKEVIEW LOAN SERVICING, LLC Index No. Plaintiff, -against- WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR; STEPHANIE A. TAYLOR; SUSTAINABLE NEIGHBORHOODS, LLC; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC, AS NOMINEE FOR SECRETARY OF HOUSING AND URBAN DEVELOPMENT; UNITED STATES OF AMERICA ON BEHALF OF SECRETARY OF HOUSING AND URBAN DEVELOPMENT; ''JOHN DOES'' and ''JANE DOES,'' said names being fictitious, parties intended being possible tenants or occupants of premises and corporations, other entities or persons who have, claim, or may claim, a lien against or other interest in, the premises, Defendant(s). NOTICE REGARDING AVAILABILITY OF ELECTRONIC FILING SUPREME COURT CASES PLEASE TAKE NOTICE that Plaintiff(s)/petitioner(s) [defendant(s)/respondent(s)] in the case captioned above intends that this matter proceed as an electronically-filed case in the New York State Courts Electronic Filing System ("NYSCEF") in accordance with the procedures therefor, set forth in Uniform Rule 202.5-b and described below. Under that Rule, filing and service of papers by electronic means cannot be made by a party nor can electronic service be made upon a party unless that party has consented to use of the System for the case in question. Each party served with this Notice must promptly file with the court and serve on all other parties either a consent or a declination of consent to electronic filing and service through NYSCEF for this case. (See Instruction # 2 below.) General Information Electronic filing offers significant benefits for attorneys and litigants, permitting documents to be filed with the County Clerk and the court and served, between or among consenting parties, by posting the documents on the NYSCEF Website, which can be done at any time of the day or night on 11 of 152 FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 any day of the week. There is no fee to use the NYSCEF System, whether for filing, service, or consultation of the electronic docket, nor is there a charge to print documents from the docket. Normal filing fees must be paid, but this can be done by credit or bank card on-line. For additional procedures and information, see Uniform Rule 202.5-b, any e-filing protocol that may have been promulgated by the court in question, and the NYSCEF Website at www.nycourts.gov/efile. Instructions 1. Service of this Notice constitutes consent to e-filing and a statement of intent by the undersigned to use the NYSCEF System in this case. When an action or proceeding is being commenced through the NYSCEF System, this Notice must accompany service of the initiating papers. 2. Each party served with this Notice may consent to e-filing either: (i) by filing with the court and serving on all parties of record a consent to e-filing, or (ii) if an authorized e-filing user, by filing a consent electronically in the manner provided at the NYSCEF site. Parties who do not wish to consent must file and serve a written declination of consent. If one party or some but fewer than all parties consent, NYSCEF may be used by and between or among consenting parties. 3. Each participating attorney, unless already registered, or self-represented party must PROMPTLY create a NYSCEF account and obtain the confidential Filing User Identification Number and Password necessary to use the system. To create a NYSCEF account, go to www.nycourts.gov/efile, click the Create an Account link, and follow the instructions. 4. For additional information about NYSCEF, see the User's Manual and Frequently Asked Questions on the Website, or contact the court in question or the NYSCEF Resource Center (at 646- 386-3033 or efile@courts.state.ny.us). Dated: May 31, 2024 Tromberg, Morris & Partners, PLLC By: ____________________________ Joseph G. Devine, Jr. Attorneys for Plaintiff 39 Broadway, Suite 1250, New York, NY 10006 Phone: (800) 280-6205 Fax: 212-227-9656 12 of 152 FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 SCHEDULE A ALL THAT CERTAIN PLOT, PIECE OR PARCEL OF LAND, SITUATE, LYING AND BEING IN THE BOROUGH OF BROOKLYN, COUNTY OF KINGS, CITY AND STATE OF NEW YORK, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE NORTHERLY SIDE OF HAWTHORNE STREET DISTANT 353 FEET; 2 1/2 INCHES EASTERLY FROM THE CORNER FORMED BY THE INTERSECTION OF THE NORTHERLY SIDE OF HAWTHORNE STREET AND THE EASTERLY SIDE OF BEDFORD AVENUE; RUNNING THENCE NORTHERLY AT RIGHT ANGLES TO HAWTHORNE STREET 167 FEET 5 INCHES; THENCE EASTERLY NEARLY PARALLEL WITH HAWTHORNE STREET 29 FEET 8 INCHES TO A POINT IN A LINE DRAWN AT RIGHT ANGLES TO HAWTHORNE STREET AND DISTANT 167 FEET 4-1/2 INCHES NORTHERLY THEREFROM; THENCE SOUTHERLY ALONG SAID LINE 167 FEET 4-1/2 INCHES TO THE NORTHERLY SIDE OF HAWTHORNE STREET AND THENCE WESTERLY ALONG THE NORTHERLY SIDE OF HAWTHORNE STREET 29 FEET 8 INCHES TO THE POINT OR PLACE OF BEGINNING. Property Address: 157 Hawthorne Street, Brooklyn, NY 11225 13 of 152 FILED: KINGS COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 SCHEDULE B WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR and STEPHANIE A. TAYLOR is named herein as party defendant(s) because they are certified owners of the subject premises, are obligors under the note and they mortgaged their interest. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS MORTGAGEE is named herein as party defendant because it has or claims to have a judgment; Dated: 03/28/2016; Recorded: 07/05/2016, In favor of: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS MORTGAGEE, Against: 1ST ALLIANCE LENDING, LLC, Amount: $0.00, which is subordinate to Plaintiff. SUSTAINABLE NEIGHBORHOODS, LLC is named herein as party defendant because it has or claims to have a judgment; Dated: 10/11/2023; Recorded: 10/11/2023, In favor of: SUSTAINABLE NEIGHBORHOODS, LLC, Against: STEPHANIE A. TAYLOR AND WILLIAM E. TAYLOR A/K/A WILLIAM TAYLOR, Amount: $0.00, which is subordinate to Plaintiff. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC, AS NOMINEE FOR SECRETARY OF HOUSING AND URBAN DEVELOPMENT is named herein as party defendant because it has or claims to have a lien by virtue of a Mortgage, Dated: 07/15/2011; Recorded: 07/27/2011, Amount: $110,701.01, which is subordinate to Plaintiff. UNITED STATES OF AMERICA ON BEHALF OF SECRETARY OF HOUSING AND URBAN DEVELOPMENT is named herein as party defendant because it has or claims to have a lien by virtue of a Mortgage, Dated: 04/15/2016; Recorded: 07/05/2016, Amount: $124,559.89, which is subordinate to Plaintiff. UNITED STATES OF AMERICA ON BEHALF OF SECRETARY OF HOUSING AND URBAN DEVELOPMENT is named herein as party defendant because it has or claims to have a lien by virtue of a Mortgage, Dated: 10/13/2023; Recorded: 10/24/2023, Amount: $305.36, which is subordinate to Plaintiff. 14 of 152 FILED: KINGS13:COUNTY CLERK 05/31/2024 12:39 PM INDEX NO. 515159/2024 11/ 27 /2012 NYSCEF DOC. NO. 1 06 A S ATRUE AND PAGE 02/05 RECEIVED NYSCEF: 05/31/2024 .. . CERTIF1 D COPY NOTE FHACase No. JULY 15 , 2 011 EAST HARTFORD CONNECTICUT [Date] [city] [state] 157 HAWTHORNE STREET, BROOKLYN, NEWYORK112 2 5 [Property Address] 1. PARTIES "Borrower" end of raeans each person signing at the this Note, and the person's successors and assigns. "Lender"means 1ST ALLIANCE LENDING, LLC, A CONNECTICUTLIMITED LIABILITY COMPANY and its successors and assigns. 2. BORROWER'S PROMISETO PAY; INTEREST In retura for a loan received from Lender, Borrower promises to pay the principal sum of FOUR HUNDREDTHIRTY- FOUR THOUSANDFIVE HUNDREDTWENTYAND O0 / 10 O Dollars (U.S. 5 43 4 , 5 20 . 0 0 ), plus interest, to the order of Leader. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of SIX 25 O/1O OO AND percent ( 6 . 2 5O %) per year until the full amount of principal has been paid. 3. PROMISETO PAYSECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated Instrument." the same date as this Note and called the "Security The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNEROFPAYMENT (A) Time Borrower shall makeapayment of principal and interest to Lender on the 1st day of each month beginning on AUGUST1, 2 011 . Any principal and interest remaining on the 1st day of JULY , 2 041 , will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be madeat P . O. BOX 8 O6 8 , VIRGINIA BEACH, VIRGINIA 23 45 O , or at such other place as Leader may designate in writing by notice to Borrower. (C) Amount Each rnonthly payment of principal and interest will be in the amount of U.S. $ 2 , 67 S . 41 . This amount win be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for Payment Adjustments Ifan allonge providing for payment adjustments is executedby Borrowertogether with this Note, the covenants of the allonge shall be incorporated into and shall amendand supplement the covenants ofthis Note as if the allonge were a part of this Note. MULTISTATE- FHA FlXED RATENOTE DocMa c U$FHA.NTE09/25/09 Page 1 of 3 www. cmagic.com 15 of 152 FILED: KINGS13:06 COUNTY CLERK 05/31/2024 VAULT 12:39 PM INDEX NO. 515159/2024 11/27/2012 PAGE 03/05 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/31/2024 (Check applicable box.) O Growing Equity Allonge ¡ Graduated Payment Allonge ¡ Other [specify]: 5. RIGHT TO PREPAY BORROWER'S Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, that Borrower pays interest on the first day of any month. Lender shall accept prepayment on other days provided required Lender and permitted by regulations on the amount prepaid for the remainder of the month to the extent by the due date or in the amount of the Secretary. If Borrower makes a partial prepayment, there will be no changes in those changes. of the monthly payment unless Lender agrees in writing to 6. FAILURE TO PAY BORROWER'S (A) Late Charge for Overdue Payments as described in If Leader has not received the full monthly payment required by the Security Instrument, the end of fifteen calendar days after the payment is due, Lender may collect a late Paragraph 4(C) of this Note, by charge in the amount of FOUR AND 0 0 O/10 0 O percent ( 4 . 00 0 %) of the overdue amount of each payment. (B) Default except as limited by If Borrower defaults by failing any monthly payment, then Lender may, to pay in full immediate payment in of the principal balance regulations ofthe Secretary in the case of payment defaults, require full Leader may choose not to exercise this option without waiving fts rights in remaining due and all accrued interest. issued the Secretary wíII limit Lender's the event of any subsequent default. In many circumstances, regulations by rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration "Secretary" means the when not permitted by HUD regulations- As used in this Note, Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses IfLender has required immediate payment in full, as described above, Lender mayrequire Borrower to pay costs attorneys' prohibited and expenses including reasonable and customary fees for enforcing this Note to the extent not disbursement at the same rate as the by applicable law. Such fees and costs shall bear interest from the date of principal of this Note. 7. WAlVER