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Freedom Mortgage Corporation v. Timothy Jennings et al

Docket 622194/2024, New York State, Suffolk County, Supreme Court (Sept. 6, 2024)
Case TypeReal Property - Mortgage Foreclosure - Residential
TagsReal Property, Mortgage Foreclosure, Residential
Plaintiff Freedom Mortgage Corporation
Defendant Timothy Jennings
Defendant Kelli Anne Jennings
...
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SUMMONS + COMPLAINT Redacted per 22 NYCRR §202.5(e)

Document Freedom Mortgage Corporation v. Timothy Jennings et al, 622194/2024, 1 (N.Y. Sup. Ct., Suffolk County Sep. 6, 2024)
Freedom Mortgage Corporation Plaintiff, -against- Timothy Jennings, Kelli Anne Jennings, New York State Department of Taxation and Finance, Clerk of the Suffolk County Traffic & Parking Violations Agency and "JOHN DOE #1" through "JOHN DOE #10", the last ten names being fictitious and unknown to the plaintiff, the person or parties intended being the persons or parties, if any, having or claiming an interest in or lien upon the mortgaged premises described in the Complaint, Defendants.
-against- Timothy Jennings, Kelli Anne Jennings, New York State Department of Taxation and Finance, Clerk of the Suffolk County Traffic & Parking Violations Agency and "JOHN DOE #1" through "JOHN DOE #10", the last ten names being fictitious and unknown to the plaintiff, the person or parties intended being the persons or parties, if any, having or claiming an interest in or lien upon the mortgaged premises described in the Complaint, Defendants.
note and mortgage by failing and omitting to pay, to the plaintiff, payments due on April 01, 2024 and said default has continued for a period in excess of fifteen (15) days.
That the monies received from the sale be brought into Court and that plaintiff be paid the amount adjudged to be due it with interest thereon to the time of such payment, together with late charges, any sums paid by the plaintiff for real estate taxes, assessments, water charges and sewer rents, insurance premiums, sums expended for the protection or preservation of the property, together with attorneys' fees as demanded in the second cause of action, the costs and disbursements of this action and any other necessary expenses to protect the lien of the mortgage to the extent that the amount of such monies applicable thereto will pay the same;
a judgment foreclosure of of whether you choose to remain in your home, YOUAREREQUIRED Regardless TOTAKECAREOFYOURPROPERTYand pay property taxes in accordance with state and local law.
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AFFIRMATION/AFFIDAVIT OF SERVICE

Document Freedom Mortgage Corporation v. Timothy Jennings et al, 622194/2024, 16 (N.Y. Sup. Ct., Suffolk County Oct. 2, 2024)
-against- Kelli Anne Jennings, New York State Timothy Jennings, Department of Taxation and Finance, Clerk of the Suffolk County Traffic & Parking Violations Agency, and "JOHN DOE#1" through "JOHNDOE#10", ten namesbeing the last and unknown to the plaintiff, the persons or parties fictitious the persons or parties if any having or intended being in or lien upon the mortgaged premises an interest claiming described in the Complaint, Defendants.
: ) action, being duly sworn, deposes and says: deponent I, Danielle Gladstone, in Suffolk County, NewYork.
is over 18 years of age and resides OnOctober 2, 2024, deponent served the within Notice of Discontinuance and Affirmation Cancelling Notice of Pendency on: is not a party to the Timothy Jennings 83 Tremont Avenue Medford, NY11763 Kelli Anne Jennings 83 Tremont Avenue Medford, NY11763 NewYork State Department of Taxation and Finance
a true copy of sameenclosed in a post-paid The above parties were served by depositing properly depository under the exclusive care and custody of the in a post office-official addressed wrapper, the State of NewYork.
United States Postal Service within Danielle Gladstone Sworn to before meon this 2n day of October 20 OTAR i)U L
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NOTICE OF DISCONTINUANCE (PRE RJI)

Document Freedom Mortgage Corporation v. Timothy Jennings et al, 622194/2024, 14 (N.Y. Sup. Ct., Suffolk County Oct. 2, 2024)
-against- Plaintiff, Timothy Jennings, Kelli Anne Jennings, New York State Department of Taxation and Finance, Clerk of the Suffolk County Traffic & Parking Violations Agency, and "JOHN DOE #1" through "JOHN DOE #10", the last ten names being fictitious and unknown to the plaintiff, the persons or parties intended being the persons or parties if any having or claiming an interest in or lien upon the mortgaged premises described in the Complaint, Defendants.
WHEREAS, the Plaintiff has commenced the above-entitled foreclosure action with the filing of a Notice of Pendency and Summons and Complaint on September 06, 2024; This notice of discontinuance is made pursuant to CPLR 3217(a)(1) ,without prejudice
to recommencement pursuant to CPLR 205(a) or otherwise, and all parties are being served with this notice of discontinuance.
for Timothy Jennings and Kelli Anne Jennings who had not yet been served, and no responsive pleading has been served or this notice is being filed within twenty days after service of the pleading asserting the claim.
Clerk of the Suffolk County Traffic & Parking Violations Agency
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CANCELLATION OF NOTICE OF PENDENCY / LIS PENDENS

Document Freedom Mortgage Corporation v. Timothy Jennings et al, 622194/2024, 15 (N.Y. Sup. Ct., Suffolk County Oct. 2, 2024)
Timothy Jennings, Kelli Anne Jennings, New York State Department of Taxation and Finance, Clerk of the Suffolk County Traffic & Parking Violations Agency, and "JOHN DOE #1" through "JOHN DOE #10", et al Defendants.
Robert Tremaroli, Esq. pursuant to CPLR § 2106, and under the penalties of perjury, affirms as follows: 1.
Plaintiff has commenced the above-entitled foreclosure action with the filing of a Notice of Pendency and Summons and Complaint on September 06, 2024; 3.
This Affirmation is made pursuant to CPLR 6514(e) for the purpose of canceling the Notice of Pendency of action filed on September 06, 2024 in the County Clerk's Office .
That no parties have appeared and the time to appear has expired for all parties except Timothy Jennings and Kelli Anne Jennings who were not served.
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AFFIRMATION/AFFIDAVIT OF SERVICE AFFIRMATION OF SERVICE - CLERK OF THE SUFFOLK COUNTY TRAFFIC & PARKING VIOLATIONS AGENCY

Document Freedom Mortgage Corporation v. Timothy Jennings et al, 622194/2024, 9 (N.Y. Sup. Ct., Suffolk County Sep. 26, 2024)
I, Steve Brennan, affirm as follows: I am not a party to this action, I am over 18 years of age and I reside in the State of New York.
On 9/11/2024 at 3:15 PM at 100 Veterans Memorial Highway Hauppauge, NEW YORK 11788, I served the within
3012-B bearing index # 622194/2024, filed 9/6/2024 on CLERK OF THE SUFFOLK COUNTY TRAFFIC & PARKING VIOLATIONS AGENCY, defendant therein named, (X) CORPORATE SERVICE: A corporation, by personally delivering thereat a true copy of each to LAURA COLON, CLERK.
The following is a description of the individual I served to the best of my ability at the time and circumstances of service:
_26 affirm this 26 day of September 2024, under the penalties of perjury under the laws of New York, which may include a fine or imprisonment, that the foregoing is true, and I understand that this document may be filed in an action or proceeding in a court of law.
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STATEMENT OF AUTHORIZATION FOR ELECTRONIC FILING

Document Freedom Mortgage Corporation v. Timothy Jennings et al, 622194/2024, 10 (N.Y. Sup. Ct., Suffolk County Sep. 26, 2024)
I hereby acknowledge and represent that the attorneys in the Firm who are authorized users of the New York State Electronic Filing System (“NYSCEF”) hereby authorize any employee of ________________ who possesses a NYSCEF filing agent ID to file documents on
their behalf and at their direction, as a filing agent, in any e-filed matter in which they are counsel of record through NYSCEF, as provided in Section 202.5-b of the Uniform Rules for the Trial Courts.
This authorization extends to any consensual matter in which these attorneys have previously consented to e-filing or may hereafter consent, to any mandatory matter in which they have recorded their representation, and to any matter in which they authorize the filing agent to record consent or representation in the NYSCEF system.
This authorization, posted once on the NYSCEF website as to each matter in which these attorneys are counsel of record, shall be deemed to accompany any document in that matter filed by the filing agent on behalf of these attorneys.
This authorization regarding this filing agent shall continue until the Firm revokes the authorization in writing on a prescribed form delivered to the E-Filing Resource Center.
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STATEMENT OF AUTHORIZATION FOR ELECTRONIC FILING AUTHORIZATION FORM

Document Freedom Mortgage Corporation v. Timothy Jennings et al, 622194/2024, 8 (N.Y. Sup. Ct., Suffolk County Sep. 16, 2024)
users of the NewYork State in the Firm who are authorized represent the attorneys that Filing System ("NYSCEF") hereby authorize any employee of Electronic who possesses a NYSCEFfiling
ID to file documents on agent their behalf and at in which they are as a filing in any e-filed matter their agent, direction, counsel of record through NYSCEF,as provided in Section 202.5-b of the Uniform Rules for Trial Courts.
agent to record consent or representation extends to any and all documents these attorneys generate and This authorization submit in any such matter.
e-filing the Firm revokes the This authorization agent shall continue until this filing regarding in writing on a prescribed form delivered to the E-Filing Resource Center.
authorization Dated: ignature Print Name City, State and Zip ode Phone Firm/Department bbYtdCñ LO E-Mail Address Street Address .
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