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FILED: SUFFOLK COUNTY CLERK 06/04/2024 11:29 AM INDEX NO. 613542/2024
NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 06/04/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
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U.S. BANK TRUST NATIONAL ASSOCIATION, NOT IN ITS
INDIVIDUAL CAPACITY BUT SOLELY AS OWNER TRUSTEE FOR
RCAF ACQUISITION TRUST, CERTIFICATE OF MERIT
PURSUANT TO CPLR 3012-b
Plaintiff,
Mortgaged Premise Address:
- against - 37 Cliff Road West,
Wading River, NY 11792
AUSTIN MCDONNELL, LOANN MCDONNELL A/K/A LOANN M.
MCDONNELL, SUPER PC SYSTEMS, INC., COMPLETE
ORTHOPEDICS, THE PEOPLE OF THE STATE OF NEW YORK, and
“JOHN DOE No. 1'' through ''JOHN DOE No. 100'' inclusive, the name of
the last 100 defendants being fictitious, the true names of said defendants
being unknown to plaintiff, it being intended to designate fee owners,
tenants or occupants of the liened premises and/or persons or parties
having or claiming an interest in or a lien upon the liened premises, if the
aforesaid individual defendants are living, and if any or all of said
individual defendants be dead, their heirs at law, next of kin, distributees,
executors, administrators, trustees, committees, devisees, legatees, and
assignees, lienors, creditors and successors in interest of them and
generally all persons having or claiming under, by, through, or against the
said defendants named as a class, of any right, title, or interest in or lien
upon the premises described in the complaint herein,
Defendant(s).
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STATE OF NEW YORK )
) ss.:
COUNTY OF SUFFOLK )
1. I am an attorney at law duly licensed to practice in the State of New York, and am
affiliated with the law firm of Aldridge Pite, LLP, attorney for plaintiff U.S. BANK TRUST
NATIONAL ASSOCIATION, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS
OWNER TRUSTEE FOR RCAF ACQUISITION TRUST in this action.
2. I have reviewed the facts of this case and reviewed pertinent documents, including
the mortgage, security agreement and note or bond underlying the mortgage executed by
defendant, all instruments of assignment (if any), and all other instruments of indebtedness
including any modification, extension, and consolidation.
3. My office has consulted about the facts of this case with the following
representatives of plaintiff:
Name Title
Korey McGovern Document Execution Specialist
Selene Finance LP
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FILED: SUFFOLK COUNTY CLERK 06/04/2024 11:29 AM INDEX NO. 613542/2024
NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 06/04/2024
4. Upon this review and consultation, to the best of my knowledge, information, and
belief, I certify that there is a reasonable basis for the commencement of this action, and that
plaintiff is the creditor entitled to enforce rights under these documents.
5. Attached hereto in Exhibit A are copies of the following documents not otherwise
included as attachments to the summons and complaint: the mortgage, security agreement and
note or bond underlying the mortgage executed by the defendant; all instruments of assignment
(if any); and any other instrument of indebtedness, including any modification, extension, and
consolidation.
6. I am aware of my obligations under New York Rules of Professional Conduct (22
NYCRR Part 1200) and 22 NYCRR Part 130.
Executed on this ______
4th June
day of ______________,
, 2024
_____________________________
Jaclyn Jordan, Esq.
Attorney
Aldridge Pite, LLP
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