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FREEDOM MORTGAGE CORPORATION v. EMINE SENER et al

Docket 601474/2025, New York State, Nassau County, Supreme Court (Jan. 21, 2025)
Case TypeReal Property - Mortgage Foreclosure - Residential
TagsReal Property, Mortgage Foreclosure, Residential
Plaintiff FREEDOM MORTGAGE CORPORATION
Defendant Emine Sener
Defendant Ilker Sener
...
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SUPPORTING PLEADINGS

Document FREEDOM MORTGAGE CORPORATION v. EMINE SENER et al, 601474/2025, 22 (N.Y. Sup. Ct., Nassau County Feb. 11, 2025)
JOHN DOE (Those unknown tenants, occupants, persons or corporations or their heirs, distributees, executors, administrators, trustees, guardians, assignees, creditors or successors claiming an interest in the mortgaged premises.)
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.
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.
PURSUANT TO CPLR 3012-b Exhibit A In support of the foregoing Certificate of Merit, attached hereto are: _x_ _x_ ___ CEMA/Loan Modification
A copy of the original Note that was duly endorsed or has a firmly affixed allonge is attached to the complaint.
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SUMMONS + COMPLAINT Redacted per 22 NYCRR §202.5(e)

Document FREEDOM MORTGAGE CORPORATION v. EMINE SENER et al, 601474/2025, 1 (N.Y. Sup. Ct., Nassau County Jan. 21, 2025)
JOHN DOE (Those unknown tenants, occupants, persons or corporations or their heirs, distributees, executors, administrators, trustees, guardians, assignees, creditors or successors claiming an interest in the mortgaged premises.)
JOHN DOE (Those unknown tenants, occupants, persons or corporations or their heirs, distributees, executors, administrators, trustees, guardians, assignees, creditors or successors claiming an interest in the mortgaged premises.)
a. Judgment accelerating the maturity of the debt and determining the amount due Plaintiff for principal, interest, late charges, taxes, assessments, insurance, maintenance and preservation of the property and other similar charges, together with costs, allowances, expenses of sale, reasonable attorney's fees, all with interest, pursuant to the terms of the Note and Mortgage.
I will makemymonthly paymenton the 1st I will makethese paymentsevery monthuntil I have paid all of the principal andany other charges described andinterest I mayowe under this Note.
PRINTEDNAMEANDTITLE OFAUTHORIZEDSIGNER: Brandy Barnett, Collateral TeamLead, Power of attorney Roundpoint Mortgage Servicing Corporation Schedule B – Legal Description
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NOTICE OF APPEARANCE AND CLAIMS TO SURPLUS MONIES

Document FREEDOM MORTGAGE CORPORATION v. EMINE SENER et al, 601474/2025, 23 (N.Y. Sup. Ct., Nassau County Feb. 21, 2025)
PLEASE TAKE NOTICE that the defendant United States of America (the “United States”), hereby appears in the action and that the undersigned is duly authorized to appear as attorney for said defendant therein (except as noted below), and hereby waives service of all papers and notice of all proceedings in said action with the exception of the following:
Notice of any motion or other paper seeking to challenge the lien or other interest of record of the United States;
PLEASE TAKE FURTHER NOTICE that to the extent that the pleading served on the United States fails to set forth with particularity an interest or lien of the United States, or to provide the information specifically required with respect to any federal tax lien in the manner required under 28 U.S.C. § 2410(b) (requiring the name and address of the taxpayer whose liability created the lien and, if a notice of the tax lien was filed, the identity of the internal revenue office which filed the notice and the date and place such notice of lien was filed), the undersigned is not authorized to appear for the United States in respect to such unidentified or inadequately identified interest or lien of the United States, and the United States will maintain that it is not party to the matter for purposes of such unidentified or inadequately identified interest of the United States because the statutory waiver of sovereign immunity is conditioned upon compliance with § 2410(b).
In the event that a sale pursuant to the plaintiff’s complaint results in surplus proceeds, the United States is without knowledge of the validity, extent, or priority of any claim of any co-defendant and reserves the right to address such matters at such time as a dispute over surplus proceeds becomes ripe.
To: GROSS POLOWY, LLC Attorneys for Plaintiff 1775 Wehrle Drive, Suite 100 Williamsville, NY 14221
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ADDENDUM - FORECLOSURE (840F)

Document FREEDOM MORTGAGE CORPORATION v. EMINE SENER et al, 601474/2025, 19 (N.Y. Sup. Ct., Nassau County Feb. 11, 2025)
Supreme COURT, COUNTY OF Nassau For use in ALL mortgage foreclosure actions where the property is: (check if applicable) ☒ 1.
Instructions If # 1 or # 2 is applicable: Select "Residential Mortgage Foreclosure Settlement Conference" as the Nature of Judicial Intervention on the RJI.
The Defendant/Respondent Information section below MUST be completed for all defendants and attached to the RJI.
Address: 610 Federal Plaza, Central Islip, NY 11722 Comments: Primary Phone: Secondary Phone: e-mail: 90-day Notice [RPAPL § 1304(1)] mailed on: 10/09/2024 ATTENTION: Proof of service must be filed with this RJI for each defendant upon whom a summons and complaint or summons with notice has been served.
First Name: JOHN Address: 68 Jerusalem Avenue, Levittown, NY 11756 Comments: Primary Phone: e-mail: Secondary Phone: 90-day Notice [RPAPL § 1304(1)] mailed on: 10/09/2024 ATTENTION: Proof of service must be filed with this RJI for each defendant upon whom a summons and complaint or summons with notice has been served.
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AFFIRMATION/AFFIDAVIT OF SERVICE

Document FREEDOM MORTGAGE CORPORATION v. EMINE SENER et al, 601474/2025, 20 (N.Y. Sup. Ct., Nassau County Feb. 11, 2025)
JOHNDOE(Those unknown tenants, persons or corporations or their heirs, executors, distributees, trustees, administrators, or successors guardians, creditors assignees, an interest in the mortgaged premises.)
I, Tanhim Khan, affirm as follows: I am an employee of Gross Polowy LLC the attorney of record for I amnot a party to this action and amover the age of 18 years.
the Plaintiff in the above That on February 11, 2025, I caused to be served, a true copy of the RJI Settlement Conference in Residential Mortgage Foreclosure Action on the following below at as indicated that person's parties last known address and, if by First Class mail, in a postpaid wrapper in a depository then deposited in a under care and custody of post the United States Postal or official the exclusive office depository the United States.
Modeof Service class mailing via USPS £( First _ Certified mail/RR -_ E-mail _ Notice of Electronic - United Parcel Service FedEX class mailing via USPS ¡ Certified mail/RR First OE-mail ¡ Notice of Electronic ¡ United Parcel Service ¡ FedEX the 11th day of February, 2025, under the penalties I affirm this NewYork, which may include a fine or imprisonment, the foregoing that this document maybe filed in an action or proceeding in a court of law.
of perjury under the laws of is true, and I understand that dadhnñ Khan Legal Assistant 601474/2025 Affirmation of Service by Mail
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RJI -RE: RESIDENTIAL MORTGAGE FORECLOSURE SETTLEMENT CONFERENCE

Document FREEDOM MORTGAGE CORPORATION v. EMINE SENER et al, 601474/2025, 18 (N.Y. Sup. Ct., Nassau County Feb. 11, 2025)
If none, leave blank.
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AFFIRMATION/AFFIDAVIT OF SERVICE Amended AOS VILLAGE OF GREAT NECK

Document FREEDOM MORTGAGE CORPORATION v. EMINE SENER et al, 601474/2025, 17 (N.Y. Sup. Ct., Nassau County Feb. 6, 2025)
Supreme Court State of NewYork, County of Nassau Index Number: 60I474/2025
is not a party to this action and is over the age of eighteen years and resides and says deponent I, John Mastrosimone, affirms in the state at 1:33 PMat 767 Middle Neck Road, Great Neck, NY 1 1024, deponent served the within E-FILE of NewYork.
on VILLAGEOFGREATNECKDefendant bearing Index # 601474/2025 VILLAGE AGENCY:A Village Agency by delivering a true copy of each to Nancy Fromigia personally; Agency so served to be the Village Agency described as the namedDefendant and knew said individual authorized person to accept service of process.
deponent knew said Village to be the Clerk thereof an PERCElVEDDESCRIPTION: Deponent describes service as follows: the individual served to the best of deponent's ability the time and circumstances of at Gender: Female Race/Skin: White Age: 36 - 50 Yrs.
20Éunder the penalties of perjury under the laws of NewYork, which may include a fine or this document may be filed in an action or proc is true, and I understand that the foregoing ourt John a rosimone Job # 306333 Client Reference:
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