Motion-Secondary: Deutsche Bank National Trust Company, Trustee Under Pooling And Servicing Agreement, Securitized Asset Backed Receivables Llc Trust 2007-Br1, Mortgage Pass-Through Certificates Series 2007-Br1 v. Tony Clanton, Debra Dennis, Mortgage Electronic Registration Systems, Inc, New Century Mortgage Corporation, Board Of Managers Of The Sunrise Tower Condiminium

On June 11, 2008 a Motion-Secondary was filed involving a dispute between Deutsche Bank National Trust Company, Mortgage Pass-Through Certificates Series 2007-Br1, Securitized Asset Backed Receivables Llc Trust 2007-Br1, Trustee Under Pooling And Servicing Agreement, and Board Of Managers Of The Sunrise Tower Condiminium, Debra Dennis, Mortgage Electronic Registration Systems, Inc, New Century Mortgage Corporation, Tony Clanton, for Real Property - Mortgage Foreclosure - Residential in the District Court of Richmond County.

Preview
FILED: RICHMOND COUNTY CLERK 07/02/2021 11:41 AM INDEX NO. 100938/2008
NYSCEF DOC. NO. 35 RECEIVED NYSCEF: 07/02/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
---------- --------------------------------------X
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR SECURITIZED

ASSET BACKED RECEIVABLES LLC TRUST
2007-BR1, MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2007-BR1,

Plaintiff, Index No. 100938/2008

-against-

TONY CLANTON; DEBRA DENNIS; MORTGAGE
ELECTRONIC REGISTRATION SYSTEMS, INC.
AS NOMINEE AND MORTGAGEE OF
* -l
RECORD;
NEW CENTURY MORTGAGE CORPORATION;
BOARD OF MANAGERS OF THE SUNRISE a
"DOE"
TOWER CONDOMINIUM; ROLFF (LAST
NAME REFUSED), Q
155 a
Defendants. a
88
---------------------------------------------------------------X

DEFENDANT TONY CLANTON'S REPLY MEMORANDUM OF LAW IN FURTHER
SUPPORT OF DEFENDANT'S MOTION TO REARGUE

STATEN ISLAND LEGAL SERVICES
By: Sarah Baldwin, Esq.
36 Richmond Terrace, Suite 205
Staten Island, New York 10301

(718) 233-6469 (phone)
(718) 448-2264 (fax)
Attorneys for Defendant Tony Clanton

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TABLEOFCONTENTS

TABLE OF CONTENTS......====,,,,,,,-----, === ...i

TABLE OF AUTHORITIES ii

PRELIMINARY STATEMENT 1

ARGUMENT 2

"MISTAKE"
I. PLAINTIFFS EXCUSE OF IS INAPPLICABLE TO ITS DELIBERATE

ACT OF VOLUNTARILY DISCONTINUING ITS OWN CASE, PRE-ANSWER................ 2

II. GRANTING PLAINTIFF'S MOTION TO RESTORE AND VACATE ITS OWN
PRE-ANSWER STIPULATION TO DISCONTINUE UNDULY PREJUDICED
DEFENDANT. ...........................................................................................................................
5

CONCLUSION 8

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TABLE OF AUTHORITIES

Cases

104-106 East 81st St. LLC v. O'Brien, 12 Misc.3d 1 175(A), 824 N.Y.S.2d 764 (Table) (Civ. Ct.
New York Cty. 4
2006)..................................................................................................................

Brown v. Truck Rental, Inc., 172 A.D.2d 477, 567 N.Y.S.2d 831 (2d Dep't 1991).......................
3

Chery v.Anthony, 156 A.D.2d 414, 548 N.Y.S.2d 535 (2d Dep't 1989).......................................
3

Cucuzza v. Vaccaro, 109 A.D.2d 101, 490 N.Y.S.2d 518 (2d Dep't 1985)...................................
6

DaCosta v. City of New York, 296 F.Supp.3d 569 (E.D.N.Y. 2017)......................................
5, 6, 7

Deutsche Bank Natl. Tr. Co. v. Lee, 60 Misc.3d 171, 70 N.Y.S.3d 791 (Sup. Ct. Westchester Cty.
Jan. 29, 2018)..............................................................................................................................
5

Franklin v. Herbert Lehman College, 508 F. Supp. 945 (S.D.N.Y. 1981).....................................
6

'
Grutman v. Southgate at Bar Harbor Home Owners Assoc., 207 A.D.2d 526, 616 N.Y.S.2d 68
(2d Dep't 1994)...........................................................................................................................
2

Kaplan v. Goldbautn, 258 A.D.2d 620, 685 N.Y.S.2d 769 (2d Dep't 1999).................................
4

Kyles v. City of New York, 262 A.D. 1033, 30 N.Y.S.2d 314 (2d Dep't 1941)..............................
2

Lowe v. Steinman, 284 A.D.2d 506, 728 N.Y.S.2d 56 (2d Dep't 2001).........................................
4

McCarthy v. Chef Italia,105 A.D.2d 992, 482 N.Y.S.2d 143 (2d Dep't 1984).............................
3

Pegalis v. Gibson, 237 A.D.2d 420, 655 N.Y.S.2d 548 (2d Dep't 1997).......................................
1

People 'sUnited Bank v.Latini Tuxedo Mgmt., LLC, 95 A.D.3d 1285, 944 N.Y.S.2d 909 (Mem)
(2d Dep't 2012)...........................................................................................................................
2

Perez v. Mangroo, 2015 WL 7300897 (N.Y.Sup.), 2015 N.Y. Slip Op. 321 152(U) (Trial Order)
(Meshan, J.)(Sup. Ct. Bronx Cty. Oct. 7, 2015).........................................................................
4

Proc. v. Home Ins. Co., 17 N.Y.2d 239, 217 N.E.2d 136 (1966)...................................................
6

Steward v.New York City Housing Auth., 205 A.D.2d 606, 613 N.Y.S.2d 408 (2d Dep't 1994).. 3

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Other Authorities

16 N.Y. Jur.2d. Cancellation and Reformation of Instruments (2018)...........................................
4

Report on New York's Foreclosure Process, New York State Department of Financial Services
(pub. May 2015), available at
https://www.dfs.ny.gov/reportpub/banking/fore_proc_report_052015.pdf................................ 7

iii

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PRELIMINARY STATEMENT

In itsopposition to Defendant's motion to reargue, Plaintiffcontends for the firsttime

"stipulation" discontinuancel
that its of was based upon erroneous information: a forfeiture

decree that was subsequently vacated. Plaintifftenders the vacated forfeiture decree in support

of the notion advanced in the prior counsel's affirmation that thisaction was mistakenly

discontinued. Plaintiff claimed that "due to law office failure, they mistakenly executed and

discontinuance." "stipulation"
filed the stipulation of However, Plaintiff submitted its of

discontinuance two years after the vacatur of the forfeiture decree was made publicly available.

"stipulation"
Moreover, ittook Plaintiff more than six years to submit its of discontinuance after

signaling itsintent to discontinue the action in correspondence to thisCourt. Then, Plaintiff

"stipulation"
waited over two years to move to vacate its based upon itsconclusory contention

"mistake."
that thisdeliberate act was a Plaintiff'srepeated neglect in the prosecution of this

action deprived the Defendant of his right to finality and repose. Such a lack of due diligence

should not be excused by virtue of Plaintiff's thinly supported motion to vacate itsown

"stipulation"
of discontinuance and to restore the status quo ante such that Mr. Clanton cannot

even rely on the statute of limitations.

While Plaintiff
styledit as a stipulation,
thedocument was only signed by thePlaintiff
and the courtbefore
Defendant filedan answer. Nonetheless, Plaintiff
pretendsthisisan actualstipulation,arguingitisunenforceable
because it was signed. Initsopposition to this
motion, Plaintiff
statesit opposedDefendant's cross-
unilaterally
motion "by arguing thatthe stipulation
ofdiscontinuance was unenforceable and should be vacatedbecause it was
Plaintiff."
not executedby any of the defendantsand was mistakenly executed by Plaintiff's
Opposition, ¶5.
However, Plaintiff
reliedon one inappositecase where thestipulationthe plaintiff
moved to vacatewas enteredafter
plaintifp'
defendants had answered the complaint and made several motions to compel deposition.Pegalis v.
Gibson, 237 A.D.2d 420, 421,655 N.Y.S.2d 548 (2d Dep't 1997). The Appellate Division reversed the trial
court's
denialof plaintiff's
motion to vacateon the groundsthatthe stipulation
pertainedonly to the discovery
proceedings
and should nothave resultedin the discontinuance
of case.
the entire Here, Plaintiff
misleads when it that
claims
"stipulation"
thatitsunilateral is unenforceablebecause it wasnot signed by defendant,and when it relies
for this
assertionon a case aboutan actualstipulation
negotiated between and executed by the parties
thatactivelylitigate
theaction.

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Re-argument should therefore be granted and, upon reargument, the Court should deny

Plaintiff's motion.

ARGUMENT

"MISTAKE"
I. PLAINTIFFS EXCUSE OF IS INAPPLICABLE TO ITS
DELIBERATE ACT OF VOLUNTARILY DISCONTINUING ITS OWN CASE,
PRE-ANSWER.

Plaintiffargues that the court properly granted itsmotion to restore based on an

affirmation stating that,due to law office failure,the action was mistakenly discontinued. This is

incorrect, because plaintiff's presentation of the facts ismisleading. Plaintiff presents itssigning

"stipulation"
and filing a to discontinue as a mistake in order to shoehorn itsdeliberate act into

the more narrowly construed excuse of law office failure. However, the facts in the record show

"mistake" failure"
that Plaintiff's and "law office argument lacks merit.

Plaintiff's deliberate, albeit inexplicable, actions are very different than the law office

failures that courts typically accept as reason to excuse a default. The excuse of law office

failure is rooted in the concept of an act of omission, generally, and itmust be accompanied by a

default."
"detailed and credible explanation of the People's United Bank v.Latini Tuxedo Mgmt..

LLC, 95 A.D.3d 1285, 1286, 944 N.Y.S.2d 909, 909 (Mem) (2d Dep't 2012) (quoting Kohn v.

Kohn, 86 A.D.3d 630, 630, 928 N.Y.S.2d 55, 56 (2d Dep't 2011)). The Appellate Division has

found law office failureproperly alleged where an attorney failed to appear or respond, if

sufficient reason was shown for his absence, see Kyles v. City of New York, 262 A.D. 1033, 30

N.Y.S.2d 314 (2d Dep't 1941); where a defendant's response was delayed because itwas served

Owners'
on the plaintiff's prior counsel, see Grutman v. Southgate at Bar Harbor Home Assoc.,

207 A.D.2d 526, 616 N.Y.S.2d 68 (2d Dep't 1994); and even, in certain circumstances, when

delay iscaused by the law office's large volume of cases, see Steward v.New York City Housing

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Auth., 205 A.D.2d 606, 613 N.Y.S.2d 408 (2d Dep't 1994); or a misfiling by the attorney's staff,

see Brown v. Truck Rental, Inc., 172 A.D.2d 477, 567 N.Y.S.2d 831 (2d Dep't 1991).

Unsurprisingly, Plaintiffoffers no legalauthority to support itscontention that unilaterally

asking the court to discontinue the action, and years later determining that itshould not have

done so, gives rise to an instance of law office failure that would entitle itto relieffrom itsown

"stipulation"
voluntary action. Plaintiff,instead, mischaracterizes itsown to discontinue as an

unintentional error to insulate itselffrom the foreseeable consequences resulting from its

deliberate act.

"mistake,"
By mischaracterizing itsdeliberate act as a Plaintiff glosses over the larger

procedural story: that counsel did not just make an isolated error - itneglected the case for years

via repeated failures. This is significant because the Second Department has excluded such

repeated neglect from the kind of law office failure that could provide an excuse fordefault. See

McCarthy v. Chef Italia, 105 A.D.2d 992, 482 N.Y.S.2d 143 (2d Dep't 1984). In Chery v.

Anthony, the Appellate Division held that "[w]hen a default results not from an isolated,

inadvertent mistake, but from repeated neglect, [ ]there is no requirement that the court grant the

default."
motion to vacate a 156 A.D.2d 414, 414, 548 N.Y.S.2d 535, 537 (2d Dep't 1989). The

Appellate Division agreed that a history of intermittent recurrences of illness could form the

basis for a reasonable excuse for a default. Id But the court found that the plaintiff failed to

adequately establish the nexus between thisexcuse and the actual default, which resulted from

counsel's failure to seek assistance or substitute counsel. Id An excuse of law office failure,the

court emphasized, is wholly insufficient where counsel's omission continued after the condition

or the inadvertent mistake that caused the default was resolved. Id. Here, Plaintiff submitted its

"stipulation"
discontinuing the action more than two years after the forfeiture decree was vacated

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and publicly filed, and more than six years after itsignated itsintent to discontinue the action to

"stipulation."
this Court. Then, Plaintiff waited more than two years to vacate its Even if

Plaintiff's deliberate actsconstituted a viable excuse of law office failure, which they do not, the

acts occurred in the context of itsrepeated neglect. Accordingly, Plaintiffshould not have been

permitted to rely upon a conclusory affirmation misrepresenting itsdeliberate act as one of

omission or an inadvertent mistake.

"mistake" failure" mistake."
Plaintiff also refers to its and "law office as a "unilateral

mistake" mistake"
But Plaintiff's invocation of "unilateral is misdirection. "Unilateral is

typically raised in the context of a contract that one party seeks to have voided on the grounds

that they were mistaken as to the subject matter or the terms contained in the contract. 16 N.Y.

Jur.2d. Cancellation and Reformation of Instruments (2018). But there is no contract here,

"stipulation"
Plaintiff's decision to callthe document itsigned a notwithstanding. Cf Perez v.

Mangroo, 2015 WL 7300897, *l-2 (N.Y.Sup.), 2015 N.Y. Slip Op. 321152(U) (Trial Order)

(Mcshan, J.)(Sup. Ct. Bronx Cty. Oct. 7, 2015) (denying defendant's motion in which itasserted

mistake"
"unilateral as the basis forrecission, where all parties signed the stipulation of

mistake"
discontinuance defendant later sought to vacate). Furthermore, a "unilateral of fact

attributable to the negligence of one of the parties does not constitute a basis to rescind a

contract. See Lowe v. Steinman, 284 A.D.2d 506, 507-8, 728 N.Y.S.2d 56 (2d Dep't 2001);

Kaplan v. Goldbautn, 258 A.D.2d 620, 685 N.Y.S.2d 769 (2d Dep't 1999). Even under

mistake"
circumstances where a contract did exist and"unilateral was properly proven by clear

and convincing evidence, courts have not lightly set aside stipulations, especially when the party

seeking to vacate the stipulation had been represented by counsel. 104-106 East 81st St. LLC v.

O'Brien, 12 Misc.3d 1175(A), 824 N.Y.S.2d 764 (Table) (Civ. Ct. New York Cty. 2006). Here,

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Plaintiff's recites the argument in itsopposition to Defendant's cross-motion "that the stipulation

to discontinue was unenforceable and should be vacated because itwas not executed by any of

defendants,"
the without pointing to any case law. Plaintiff's Opposition to Defendant's Motion

to Reargue, ¶ 5.

For these reasons, Defendant's motion to reargue should be granted because the Court

misapprehended the law goveming a motion to vacate a discontinuance and reasonable excuse.

See Deutsche Bank Natl. Tr. Co. v. Lee, 60 Misc.3d 171, 70 N.Y.S.3d 791 (Sup. Ct. Westchester

Cty. Jan. 29, 2018) (denying plaintiff'smotion to vacate itspre-answer discontinuance in a

mortgage foreclosure action and restore itto the court's calendar because plaintiff,the court

"mistake" -
found, incorrectly relied on C.P.L.R. § 2221 and alleged without explanation that the

discontinuance should not have been filed the attorneys for the plaintiff - which
voluntary by

was inadequate to justify granting reliefpursuant to C.P.L.R. § 2001).

IL GRANTING PLAINTIFF'S MOTION TO RESTORE AND VACATE ITS OWN
"STIPULATION"
PRE-ANSWER TO DISCONTINUE UNDULY PREJUDICED
DEFENDANT.

Plaintiffalso contends that this Court properly granted itsmotion to restore because

Defendant did not sufficiently explain how he would be prejudiced ifthe action was restored to

the court's calendar. Yet, Plaintiff's contention ignores the fact that courts treata plaintiff's

extensive delay in pressing itsclaims as inherently prejudicial. For example, in DaCosta v. City

of New York, the district court also considered whether to permit nunc pro tunc the relation back

of an amendment adding a new defendant to avoid a statute of limitations defense. 296

F.Supp.3d 569 (E.D.N.Y. 2017). The court emphasized the role of a federal district court judge

in applying state law and held that, generally, a court would have the discretion to deny a

plaintiff the benefit of New York's relation-back doctrine because plaintiff's nondiligence would

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likely result in prejudice to his adversary. 1d at 580 ("Less often articulated, but certainly a

related element of justification for time limitations, isthe experiential knowledge that

meritorious claims will usually be pressed within a reasonable period of time, which leads to a

presumption of sorts thatthe probability of merit is less in a statethan a fresh claim.") (quoting J.

Weinstein, H. Korn, & A. Miller., N.Y. Civ. Prac. 201.01, at 2-7 to 2-9 (1995)). In Franklin v.

Herbert Lehman College, the district court considered whether a 180-day statute of limitations

could be tolled to the pro se complainant's benefit where she was not responsible for the delayed

filing in the proper forum when she filed her initialcomplaint in a forum experience

administrative backlog. 508 F. Supp. 945 (S.D.N.Y. 1981). The districtcourt found the plaintiff-

complainant's delay reasonable but, nonetheless, declined to tollthe limitations period.1d at

952. The court reasoned that the defendants, who did not contribute to or bring about the delay,

elapsed."
"would be unduly prejudiced by the amount of time that has Id The Appellate

Division has echoed this rationale, for example, in Cucuzza v. Vaccaro, where itreiterated that

"[t]he primary purpose of the Statute of Limitations isto compel the exercise of a right of action

within a reasonable time so that defendant will have a fair opportunity to prepare an adequate

defense free of the attendant prejudices occasioned by inordinate delay...". 109 A.D.2d 101, 490

N.Y.S.2d 518 (2d Dep't 1985).

Conversely, Defendant's inability to participate in theaction did not prevent Plaintiff

from seeking a default judgment, or filing itsjudgment of foreclosure and sale. This is a case

"not of defendant lullingthe plaintiff into a sense of false security but of the latter's sleeping on

rights."
his Proc. v. Home Ins. Co., 17 N.Y.2d 239, 246, 217 N.E.2d 136, 140 (1966). Plaintiff

had taken no action in connection with this case formore than six years - from the time it

signated itsintent to discontinue the action and requested the action be removed from the court's

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- "stipulation"
calendar when itfinally filed its discontinuing the action. Then, more than two

years after filingit,Plaintiff sought to vacate itsown voluntary discontinuance, with itsbare

assertion that "there was no intent to filethe motion to discontinue, itwas simply law office

failure."
Plaintiff's Motion to Restore, ¶ 9. By granting Plaintiff's motion to restore on such

conclusory and self-serving grounds, despite itsown eight-year delay, this Court

misapprehended well-settled law in New York finding inherent prejudice in cases involving

much less egregious delays by the moving party.

Finally, the actions by Plaintiff directly undermine the New York State Legislature's and

the Office of Court Administration's initiativesaimed at eliminating a backlog of thousands of

foreclosure cases that sat dormant foryears. See generally, Report on New York's Foreclosure

Process, New York State Department of Financial Services (pub. May 2015), available at

https://www.dfs.ny.gov/reportpub/banking/fore_proc_report_052015.pdf. The New York State

Legislature took significant steps to preserve the rights of homeowners in foreclosure by

reducing the "unnecessary delays in the foreclosure process [that]harm allNew Yorkers,

including borrowers, and not just the banks and mortgage investors who are unable to obtain

investments."
returns on their Id. These initiatives echo well-settled precedent concluding that

among the many policy considerations shaping statutes of limitations, "[f]airness to the

defendant is primarily stressed, but concern forthe effectiveness ofjudicial machinery isalso

apparent". DaCosta v. City of New York, 296 F. Supp. 3d 569 (E.D.N.Y. 2017) (quoting J.

Weinstein, H. Korn, & A. Miller., N.Y. Civ. Prac. 201.01, at 2-7 to 2-9 (1995)). Defendant has

been prejudiced by Plaintiff's repeated neglect and he should be not be further prejudiced by

Plaintiff's attempts to avoid such foreseeable consequences of itsneglect in thiscase. Plaintiff

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cannot invoke prejudice because itsclaim will likely be found to be time-barred by virtue of the

foreclosure action itfiled in 2008 and then permitted to languish for six years.

CONCLUSION

For the foregoing reasons, Defendant respectfully requests that Defendant's motion to

reargue be granted, and, upon reargument, that Plaintiff's motion to restore be denied, or in the

alternative, that Defendant's cross-motion to dismiss be granted, and for such other reliefas the

Court deems just and proper.

Dated: November 21, 2018
Staten Island, New York

S TEN ISLA D LEGAL SERVICES
Attorneys for Defendant Tony Clanton
By: Sarah Baldwin, Esq.
36 Richmond Terrace, Suite 205
Staten Island, New York 10301

(718) 233-6469 (phone)
(718) 448-2264 (fax)

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
________________________________________--------------------X

DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR SECURITIZED

ASSET BACKED RECEIVABLES LLC TRUST
2007-BR1, MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2007-BRI,

Plaintiff, Index No. 100938/2008

-against-

TONY CLANTON; DEBRA DENNIS; MORTGAGE AFFIRMATION OF
ELECTRONIC REGISTRATION SYSTEMS, INC. AS SERVICE
NOMINEE AND MORTGAGEE OF RECORD; NEW
CENTURY MORTGAGE CORPORATION; BOARD OF
MANAGERS OF THE SUNRISE TOWER
"DOE"
CONDOMINIUM; ROLFF (LAST NAME
REFUSED),

Defendants.
-----------------------------------------------------------X

Sarah Baldwin, an attorney duly licensed to practice law in the Courts of the State of New

York, hereby affirms under penalties of perjury, as follows:

1. I am not a party to this action, am over 18 years of age and reside within the state of

New York.

2. On the 21st of November 2018, I served the Reply Memorandum of Law in Further

Support of Defendant's Motion to Reargue upon the persons listed in paragraph 5 hereof.

3. The number of copies served on said persons was 1.

4. The method of service on said person was by mailing the paper to the persons at the

address designated by them for that purpose by depositing the same in a firstclass, postpaid,

properly addressed wrapper, in an official depository under the exclusive care and custody of the

United States Postal Service within the State of New York pursuant to CPLR § 2103(b)(2).

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5. The names of the persons served and the addresses at which service was made is as

follows:

Greenberg Traurig, LLP
Attn: Steven Lazar, Esq.
Attorneys for Plaintiff
The MetLife Building
200 Park Avenue
New York, New York 10166

Leopold & Associates, PLLC
Attn: Ryan Banich, Esq.
Attorneys for Plaintiff
80 Business Park Drive, Ste. 110

Armonk, New York 10504

Dated: November 21, 2018
Staten Island, New York

S h Baldwin, Esq.
Staten Island Legal Services, Attorneys for Defendant
36 Richmond Terrace, Suite 205
Staten Island, NY 10301
718-233-6469

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND

Index #: 100938 Year 2008

DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR
SECURITIZED ASSET BACKED RECEIVABLES LLC TRUST 2007-BR1,
MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-BR1,

Plaintiff,

-against-

TONY CLANTON; DEBRA DENNIS; MORTGAGE
ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE AND
MORTGAGEE OF RECORD; NEW CENTURY MORTGAGE CORPORATION;
BOARD OF MANAGERS OF THE SUNRISE TOWER CONDOMINIUM; ROLFF
"DOE"
(LAST NAME REFUSED),

Defendants.

REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF
DEFENDANT'S MOTION TO RENEW AND/OR REARGUE

Staten Island Legal Services

By Sarah Baldwin
Attorneys for Defendant Tony Clanton
36 Richmond Terrace, Suite 205
Staten Island, New York 10301
718-233-6480 Tel.
718-448-2264 Fax

Certification Pursuant to 22 NYCRR 130.1-l(a)

Sarah Baldwin, Esq.
Staten 1sland Legal Services

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Case Info

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Charles M Troia Track Judge’s New Case

Case No.

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Document Filed Date

July 02, 2021

Case Filing Date

June 11, 2008

County

Parties

BALDWIN, SARAH BETH Attorney for the Defendant
Board of Managers of the Sunrise Tower Condiminium Defendant
Debra Dennis Defendant
Deutsche Bank National Trust Company Plaintiff
Mortgage Electronic Registration Systems, INC Defendant
Mortgage Pass-Through Certificates Series 2007-BR1 Plaintiff
New Century Mortgage Corporation Defendant
Securitized Asset Backed Receivables LLC Trust 2007-BR1 Plaintiff
SPOSATO, MELISSA A. Attorney for the Plaintiff
Tony Clanton Defendant
Trustee Under Pooling and Servicing Agreement Plaintiff
STEVEN LAZAR Attorneys for Plaintiffs
DEANA CHELI Attorneys for Plaintiffs
ALISON LENIHAN Attorneys for Plaintiffs
RANDI SCHERMAN Attorneys for Defendants
ANDREW TROIA Attorneys for Defendants
DANIEL AJELLO Attorneys for Defendants
CHARLES KWON Attorneys for Plaintiffs
MARY SOYKA Attorney
ANDREW FARLEY Attorneys for Plaintiffs
CHONG LIM Attorneys for Plaintiffs
MICHAEL DEGREE Attorney
RYAN BANICH Attorney
TAMMY SHAPIRO Attorneys for Plaintiffs
ALEXA WEST Attorney
Frances Ha Attorney
RICHARD KWON Attorneys for Plaintiffs
SUSAN WEST Attorney

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