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RETURN DATE: OCTOBER 11, 2016 SUPERIOR COURT
DITECH FINANCIAL LLC JUDICIAL DISTRICT OF
LITCHFIELD
Vv. AT LITCHFIELD
KRISTINA M. LOPARDO, ET AL. : SEPTEMBER
21, 2016
£ MPLAINT
1. The Plaintiff, DITECH FINANCIAL LLC has an office and place of business with an address of
3000 Bayport Drive, Suite 880, Tampa, FL 33607.
2. At all times complained of herein, the Defendant(s), KRISTINA M. LOPARDO, owned real
property situated in the Town of Torrmgton, County of Litchfield and State of Connecticut known as 177
Lisle Street, Unit 1, Torrington, CT, (nereinafier the "Property”) being more particularly described in
Schedule A attached hereto and made a part hereof.
3. On or about August 14, 2007, the Defendant(s), KRISTINA M. LOPARDO, executed and
delivered to COUNTRY WIDE BANK, FSB, a Note (the "Note") for a loan in the original principal amount of
$79,325.00.
4, Ou said date to secure said Note the Defendant(s), KRISTINA M. LOPARDO, did execute and
deliver to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR
COUNTRYWIDE BANK, FSB, a Mortgage on the Property. Said Mortgage was dated August 14, 2007 and
recorded August 14, 2007 in Volume 1021 at Page 667 of the Torrington Land Records. Said Mortgage was
assigned to GREEN TREE SERVICING LLC by virtue of an Assignment of Mortgage dated January 14,
2015 and recorded January 16, 2015 in Volume 1197 at Page 144 of the Torrington Land Records. GREEN
TREE SERVICING LLC changed its name to DITECH FINANCIAL LLC on or about August 33, 2015.
302939 HUNT LEIBERT JACOBSON, PC, © ATTORNEYS
AT LAW
SOWESTON STREET » HARTFORD,CONNECTIC08120
UT © (880) 808-0806 © JURIS NO. 101559
~
pa
The Plaintiff, DITECH FINANCIAL LLC, is the holder of said Note.
5. Said Noie is in default and the Plaintiff, DITECH FINANCIAL LLC as the holder of said Note has
elected to accelerate the balance due on said Note, to declare said Note to be due in full and to foreclose the
Mortgage securing said Note.
6. The Plaintiff has provided written notice in accordance with the Note and Mortgage to the
Defendant(s} of the default under the Note and Morigage, but said Defendani(s) has failed and neglected to
eure the default. The Plaintiff has elected to accelerate the balance due on said Note, to declare said Note to
be due in full and to foreciose the Mortgage securing said Note.
7. The following liens or encumbrances claim to have an interest in the Property which liens or
encumbrances are prior in right to the Mortgage herein:
a. The Town/City of Torrington may claim an interest im the Property by virtue of inchoate
liens for real estate taxes.
b. YORKSHIRE COMMONS ASSOCIATION INC. may have an interest in said premises
by virtue of a statutory lien for priority common charges pursuant to the provisions of Section 47-258(b) of
the General Statutes of Connecticut.
ce. CITY OF TORRINGTON claims an interest in the Property by virtue of a Sewer Lien in
the original principal sum of $106.00 dated May §. 2016 and recorded May 5, 2016 in Volume 1226 im Page
103 of the Torrington Land Records.
8. The following liens or encumbrances claim to have an interest in the Property which liens or
encumbrances are subsequent in right to the Mortgage herein:
a, The Defendant(s), YORKSHIRE COMMONS ASSOCIATION INC. may have an interest
302835 HUNT LEIBERT JAGOBSON, PG. © ATTORNEYS AT LAW
SO WESTON STREET ® HARTFORD, CONNECTICUT 08120 © (R60) 808.0805 « JURIS NG. 104585
ee oe ——
in the premises by virtue of an inchoate lien for common charges in excess of its statutory priority.
b. The Defendant(s), YORKSHIRE COMMONS ASSOCIATION INC. claims an interest in
the Property by virtue of a Notice of Lis Pendens dated October 9, 2015 and recorded on October 20, 2015 in
Volume 1214 at Page 711 of the Torrington Land Records.
9. The Defendant(s) KRISTINA M. LOPARDO, is the owner of the equity of redemption of the
Property and, on information and belief, is in possession of the Property.
10. The Plaintiff, DITECH FINANCIAL LLC, caused a Lis Pendens to be recorded on the Land
Records of the Town of Torrington.
1}. The Plaintiff, DITECH FINANCIAL LLC, has further caused a notice to be given to the
Defendant(s), KRISTINA M. LOPARDO, of his/her rights pursuant to the Statutes pertaining to
unemployment and underemployment by annexing to this Writ, Summons and Complaint a copy of the notice
provided for in said Statute.
302939 HUNT LEIBERT JACOBSON, RC. © ATTORNEYS ATLAW
SO WESTON STREET @ HARTFORD, CONNECTICUT O6120 @ (660) 806-0608 ® JURIS
NO. 101589
au ee ——
WHEREFORE, the plaintiff claims:
1 Foreclosure of the Mortgage;
Be Foreclosure of Mortgage pursuant to Conn. Gen. Staf. Sec 49-17.
Possession of the Property:
A reasonable attorney's fee (unless same has been precluded by virtue of a Bankruptcy
filing);
Interest (uoless same has been precluded by virtue of a Bankruptcy filing);
Costs of suit (unless same has been precluded by virtue of a Bankruptcy filing);
Deficiency Judgment against the makers of, or obligors on, the Note described herein, and/or
their Estate, if deceased (unless same has been precluded by virtue of a Bankruptcy filing);
and
Such other and further relief as the Court may deem just and equitable.
Notice is hereby given to the Defendant(s) that the Plaintiff intends-to seek satisfaction of any
judgment rendered in its favor in this action out of any debt aconuing to said Defendant(s) by reason of ‘their
personal services, (unless same has been precluded by virme of a Bankruptcy filing).
Dated at Hartford, Connecticut on September 21, 2016.
Plaintiff
By:
ars! ore
Hunt Leibert Jacobson, P.C.
Its Attorneys
302939 HUNT LEIBERT JACOBSON, P.C. @ ATTORNEYS AT LAW
SO WESTON STREET » HARTFORD, CONNECTICUT 06120 = (860) 808-0806 = JURISNO. 101569
sea tne — om
eo
RETURN DATE: OCTOBER 11, 2016 SUPERIOR COURT
DITECH FINANCIAL LLC JUDICIAL DISTRICT OF
LITCHFIELD
Vv. AT LITCHFIELD
KRISTINA M. LOPARDO, ET AL. : SEPTEMBER 21, 2016
INFORMATION RELATING TO "VALIDATION NOTICE"
This Writ, Summons and Complaint are legal documents used to commence a lawsuit with regards to the debt
referenced within them. You mast follow the instructions provided therein should-you wish to preserve your
interests in the suit. even if you dispute the validity or the amount of the debt. As lawyers, this office may
file papers in the suit according to the Statutes, Rules of Court and Standing Orders in Connecticut. The
"Validation Notice" which has been or will be sent to the borrower(s) ("consumers") in no way alters their
rights or obligations with respect to this lawsuit. If you are the barrower ¢" nsumer"), and if you notify us
that the debt or any portion thereof is disputed, or if you request proof of the debt or the name and address of
the original creditor within the thirty (30) day time period of the validation notice, we will stop our collection
efforts including this foreclosure suit until we mail the requested information to you.
302Z338 HUNT LEIBERT JACOBSON, RC. » ATTORNEYS AT LAW
SOWESTON STREET @ HARTFORD, CONNECTIGUT 06120 © (850}808-0606 ¢ JURIS NO. 101583
_
RETURN DATE: OCTOBER 11, 2016 SUPERIOR COURT
DITECH FINANCIAL LLC JUDICIAL DISTRICT OF
LITCHFIELD
v AT LITCHFIELD
KRISTINA M. LOPARDO, ET AL. SEPTEMBER 21, 2016
STATEMENT OF AMOUNT IN DEMAND
The amount, legal interest, or property in demand is not Jess than $15,000.00, exclusive of interest
and costs.
Plainiff
f
By
t
(Hunt Leibert Jaeobson, PC.
‘Tts Attomeys
302839 HUNT LEIBERT JACOBSON, P.C. + ATTORNEYS AT LAW
SO WESTON STREET @ HARTFORD, CONNECTICUT 05120 © (680) 808-606 @ JURIS
NO. 101585
-
a a _
RETURN DATE: OCTOBER I}, 20136 SUPERIOR COURT
DITECH FINANCIAL LLC JUDICIAL DISTRICT OF
LITCHFIELD
Vv. AT LITCHFIELD
KRISTINA M. LOPARDO, ET AL, SEPTEMBER 21, 2016
NOTICE TO HOMEOWNER.
If you are a homeowner, under the terms of Conn. Gen. Stat. Section 49-31d, et seq., you are hereby
given notice thai under those statutes, if you are UNEMPLOYED or UNDER-EMPLOYED you may make
application to the Court to which this matter is returnable for relief from foreclosure. You may qualify for
relief under those siatutes ift
NOTICE: A PERSON WHO IS UNDEREMPLOYED OR UNEMPLOYED AND WHO HAS FOR A
CONTINUOUS PERIOD OF AT LEAST TWO YEARS PRIOR TO THE COMMENCEMENT OF
THIS FORECLOSURE ACTION OWNED AND GCCUPIED THE PROPERTY BEING
FORECLOSED AS SUCH PERSON'S PRINCIPAL RESIDENCE, MAY BE ENTITLED TO
CERFAIN RELIEF PROVISIONS UNDER SECTIONS 49-31D TO 49-311, INCLUSIVE, OF THE
CONNECTICLT GENERAL STATUTES. YOU SHOULD CONSULT AN ATTORNEY TO
DETERMINE YOUR RIGHTS UNDER SECTIONS 48-31D TO 49-311, INCLUSIVE, OF THE
CONNECTICUT GENERAL STATUTES.
In order to quatify for relief under those statutes, you must make application for protection from
foreclosure within 25 DAYS of the return date.
302933 HUNT LEIBERT JACOBSON, P.0. © ATTORNEYS AT LAW
SOWESTON STREET @ HARTFORD, CONNECTICUT $6120 {650} 808.0608 © JURIS NO. 101589
st ——
SCHEDULE “A”
That certain unit situated in the Town cf Torrington,
Connecticut, known and designated as Unit 1 of Yorkshire Commons
tegether with an undivided eight and one-third (8 1/3) percent
antersst in the common elements of said condominium, which unit
and common elements are more fully defined, identified and
described in the Declaration of Yorkshire Conmens by Lb & R
Developments, Inc. dated Mey 28, 1987 and recorded June 12, Ls87
in Volume 414, Bage 317 of the Torrington Land Records.
The land submitted to the provisions ef the Common Interest
Ownership Act of the State of Connecticut (Comnecticut General
tetutes Section 47-200, et seq-} by said Declaration is shown
as “Yorkshire Commons” on a survey entitled: “YORKSHIRE COMMONS
177 Liske Street Torrington, Connecticut/YORKSHIRE EAST 1601
Bast Main Street
Torrington, Connecticut Scale 1%=40- Date May,
1587 Sheet No. Ll of 1 Job No. 1065% certified te bea in
accordance with the Standards of a Class A-2 survey as defined
im the Code of Practice for Standards of Accuracy of Surveys and
Maps, adopted December 10, 2875, as amended by the Connecticut
&@ssotiation cf Land Surveyors, inc. by Milliam A. Berglund,
Registexed Land Surveyor No. 7378, which survey is on file in
the Toxrington Town Clerk’s Office.
302e3 HUNT LEIBERT JACOBSON, RG. e ATTORNEYS AT LAW
SOWESTON STAEET © HARTFORD, CONNECTIOUT 06120 © (650) 808.0606 © JURIS NO. 101589
es
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RETURN DATE: OCTOBER 11, 2016 SUPERIOR COURT DITECH FINANCIAL LLC JUDICIAL DISTRICT OF LITCHFIELD Vv. AT LITCHFIELD KRISTINA M. LOPARDO, ET AL. : SEPTEMBER 21, 2016 £ MPLAINT 1. The Plaintiff, DITECH FINANCIAL LLC has an office and place of business with an address of 3000 Bayport Drive, Suite 880, Tampa, FL 33607. 2. At all times complained of herein, the Defendant(s), KRISTINA M. LOPARDO, owned real property situated in the Town of Torrmgton, County of Litchfield and State of Connecticut known as 177 Lisle Street, Unit 1, Torrington, CT, (nereinafier the "Property”) being more particularly described in Schedule A attached hereto and made a part hereof. 3. On or about August 14, 2007, the Defendant(s), KRISTINA M. LOPARDO, executed and delivered to COUNTRY WIDE BANK, FSB, a Note (the "Note") for a loan in the original principal amount of $79,325.00. 4, Ou said date to secure said Note the Defendant(s), KRISTINA M. LOPARDO, did execute and deliver to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR COUNTRYWIDE BANK, FSB, a Mortgage on the Property. Said Mortgage was dated August 14, 2007 and recorded August 14, 2007 in Volume 1021 at Page 667 of the Torrington Land Records. Said Mortgage was assigned to GREEN TREE SERVICING LLC by virtue of an Assignment of Mortgage dated January 14, 2015 and recorded January 16, 2015 in Volume 1197 at Page 144 of the Torrington Land Records. GREEN TREE SERVICING LLC changed its name to DITECH FINANCIAL LLC on or about August 33, 2015. 302939 HUNT LEIBERT JACOBSON, PC, © ATTORNEYS AT LAW SOWESTON STREET » HARTFORD,CONNECTIC08120 UT © (880) 808-0806 © JURIS NO. 101559 ~ pa The Plaintiff, DITECH FINANCIAL LLC, is the holder of said Note. 5. Said Noie is in default and the Plaintiff, DITECH FINANCIAL LLC as the holder of said Note has elected to accelerate the balance due on said Note, to declare said Note to be due in full and to foreclose the Mortgage securing said Note. 6. The Plaintiff has provided written notice in accordance with the Note and Mortgage to the Defendant(s} of the default under the Note and Morigage, but said Defendani(s) has failed and neglected to eure the default. The Plaintiff has elected to accelerate the balance due on said Note, to declare said Note to be due in full and to foreciose the Mortgage securing said Note. 7. The following liens or encumbrances claim to have an interest in the Property which liens or encumbrances are prior in right to the Mortgage herein: a. The Town/City of Torrington may claim an interest im the Property by virtue of inchoate liens for real estate taxes. b. YORKSHIRE COMMONS ASSOCIATION INC. may have an interest in said premises by virtue of a statutory lien for priority common charges pursuant to the provisions of Section 47-258(b) of the General Statutes of Connecticut. ce. CITY OF TORRINGTON claims an interest in the Property by virtue of a Sewer Lien in the original principal sum of $106.00 dated May §. 2016 and recorded May 5, 2016 in Volume 1226 im Page 103 of the Torrington Land Records. 8. The following liens or encumbrances claim to have an interest in the Property which liens or encumbrances are subsequent in right to the Mortgage herein: a, The Defendant(s), YORKSHIRE COMMONS ASSOCIATION INC. may have an interest 302835 HUNT LEIBERT JAGOBSON, PG. © ATTORNEYS AT LAW SO WESTON STREET ® HARTFORD, CONNECTICUT 08120 © (R60) 808.0805 « JURIS NG. 104585 ee oe —— in the premises by virtue of an inchoate lien for common charges in excess of its statutory priority. b. The Defendant(s), YORKSHIRE COMMONS ASSOCIATION INC. claims an interest in the Property by virtue of a Notice of Lis Pendens dated October 9, 2015 and recorded on October 20, 2015 in Volume 1214 at Page 711 of the Torrington Land Records. 9. The Defendant(s) KRISTINA M. LOPARDO, is the owner of the equity of redemption of the Property and, on information and belief, is in possession of the Property. 10. The Plaintiff, DITECH FINANCIAL LLC, caused a Lis Pendens to be recorded on the Land Records of the Town of Torrington. 1}. The Plaintiff, DITECH FINANCIAL LLC, has further caused a notice to be given to the Defendant(s), KRISTINA M. LOPARDO, of his/her rights pursuant to the Statutes pertaining to unemployment and underemployment by annexing to this Writ, Summons and Complaint a copy of the notice provided for in said Statute. 302939 HUNT LEIBERT JACOBSON, RC. © ATTORNEYS ATLAW SO WESTON STREET @ HARTFORD, CONNECTICUT O6120 @ (660) 806-0608 ® JURIS NO. 101589 au ee —— WHEREFORE, the plaintiff claims: 1 Foreclosure of the Mortgage; Be Foreclosure of Mortgage pursuant to Conn. Gen. Staf. Sec 49-17. Possession of the Property: A reasonable attorney's fee (unless same has been precluded by virtue of a Bankruptcy filing); Interest (uoless same has been precluded by virtue of a Bankruptcy filing); Costs of suit (unless same has been precluded by virtue of a Bankruptcy filing); Deficiency Judgment against the makers of, or obligors on, the Note described herein, and/or their Estate, if deceased (unless same has been precluded by virtue of a Bankruptcy filing); and Such other and further relief as the Court may deem just and equitable. Notice is hereby given to the Defendant(s) that the Plaintiff intends-to seek satisfaction of any judgment rendered in its favor in this action out of any debt aconuing to said Defendant(s) by reason of ‘their personal services, (unless same has been precluded by virme of a Bankruptcy filing). Dated at Hartford, Connecticut on September 21, 2016. Plaintiff By: ars! ore Hunt Leibert Jacobson, P.C. Its Attorneys 302939 HUNT LEIBERT JACOBSON, P.C. @ ATTORNEYS AT LAW SO WESTON STREET » HARTFORD, CONNECTICUT 06120 = (860) 808-0806 = JURISNO. 101569 sea tne — om eo RETURN DATE: OCTOBER 11, 2016 SUPERIOR COURT DITECH FINANCIAL LLC JUDICIAL DISTRICT OF LITCHFIELD Vv. AT LITCHFIELD KRISTINA M. LOPARDO, ET AL. : SEPTEMBER 21, 2016 INFORMATION RELATING TO "VALIDATION NOTICE" This Writ, Summons and Complaint are legal documents used to commence a lawsuit with regards to the debt referenced within them. You mast follow the instructions provided therein should-you wish to preserve your interests in the suit. even if you dispute the validity or the amount of the debt. As lawyers, this office may file papers in the suit according to the Statutes, Rules of Court and Standing Orders in Connecticut. The "Validation Notice" which has been or will be sent to the borrower(s) ("consumers") in no way alters their rights or obligations with respect to this lawsuit. If you are the barrower ¢" nsumer"), and if you notify us that the debt or any portion thereof is disputed, or if you request proof of the debt or the name and address of the original creditor within the thirty (30) day time period of the validation notice, we will stop our collection efforts including this foreclosure suit until we mail the requested information to you. 302Z338 HUNT LEIBERT JACOBSON, RC. » ATTORNEYS AT LAW SOWESTON STREET @ HARTFORD, CONNECTIGUT 06120 © (850}808-0606 ¢ JURIS NO. 101583 _ RETURN DATE: OCTOBER 11, 2016 SUPERIOR COURT DITECH FINANCIAL LLC JUDICIAL DISTRICT OF LITCHFIELD v AT LITCHFIELD KRISTINA M. LOPARDO, ET AL. SEPTEMBER 21, 2016 STATEMENT OF AMOUNT IN DEMAND The amount, legal interest, or property in demand is not Jess than $15,000.00, exclusive of interest and costs. Plainiff f By t (Hunt Leibert Jaeobson, PC. ‘Tts Attomeys 302839 HUNT LEIBERT JACOBSON, P.C. + ATTORNEYS AT LAW SO WESTON STREET @ HARTFORD, CONNECTICUT 05120 © (680) 808-606 @ JURIS NO. 101585 - a a _ RETURN DATE: OCTOBER I}, 20136 SUPERIOR COURT DITECH FINANCIAL LLC JUDICIAL DISTRICT OF LITCHFIELD Vv. AT LITCHFIELD KRISTINA M. LOPARDO, ET AL, SEPTEMBER 21, 2016 NOTICE TO HOMEOWNER. If you are a homeowner, under the terms of Conn. Gen. Stat. Section 49-31d, et seq., you are hereby given notice thai under those statutes, if you are UNEMPLOYED or UNDER-EMPLOYED you may make application to the Court to which this matter is returnable for relief from foreclosure. You may qualify for relief under those siatutes ift NOTICE: A PERSON WHO IS UNDEREMPLOYED OR UNEMPLOYED AND WHO HAS FOR A CONTINUOUS PERIOD OF AT LEAST TWO YEARS PRIOR TO THE COMMENCEMENT OF THIS FORECLOSURE ACTION OWNED AND GCCUPIED THE PROPERTY BEING FORECLOSED AS SUCH PERSON'S PRINCIPAL RESIDENCE, MAY BE ENTITLED TO CERFAIN RELIEF PROVISIONS UNDER SECTIONS 49-31D TO 49-311, INCLUSIVE, OF THE CONNECTICLT GENERAL STATUTES. YOU SHOULD CONSULT AN ATTORNEY TO DETERMINE YOUR RIGHTS UNDER SECTIONS 48-31D TO 49-311, INCLUSIVE, OF THE CONNECTICUT GENERAL STATUTES. In order to quatify for relief under those statutes, you must make application for protection from foreclosure within 25 DAYS of the return date. 302933 HUNT LEIBERT JACOBSON, P.0. © ATTORNEYS AT LAW SOWESTON STREET @ HARTFORD, CONNECTICUT $6120 {650} 808.0608 © JURIS NO. 101589 st —— SCHEDULE “A” That certain unit situated in the Town cf Torrington, Connecticut, known and designated as Unit 1 of Yorkshire Commons tegether with an undivided eight and one-third (8 1/3) percent antersst in the common elements of said condominium, which unit and common elements are more fully defined, identified and described in the Declaration of Yorkshire Conmens by Lb & R Developments, Inc. dated Mey 28, 1987 and recorded June 12, Ls87 in Volume 414, Bage 317 of the Torrington Land Records. The land submitted to the provisions ef the Common Interest Ownership Act of the State of Connecticut (Comnecticut General tetutes Section 47-200, et seq-} by said Declaration is shown as “Yorkshire Commons” on a survey entitled: “YORKSHIRE COMMONS 177 Liske Street Torrington, Connecticut/YORKSHIRE EAST 1601 Bast Main Street Torrington, Connecticut Scale 1%=40- Date May, 1587 Sheet No. Ll of 1 Job No. 1065% certified te bea in accordance with the Standards of a Class A-2 survey as defined im the Code of Practice for Standards of Accuracy of Surveys and Maps, adopted December 10, 2875, as amended by the Connecticut &@ssotiation cf Land Surveyors, inc. by Milliam A. Berglund, Registexed Land Surveyor No. 7378, which survey is on file in the Toxrington Town Clerk’s Office. 302e3 HUNT LEIBERT JACOBSON, RG. e ATTORNEYS AT LAW SOWESTON STAEET © HARTFORD, CONNECTIOUT 06120 © (650) 808.0606 © JURIS NO. 101589 es