Preview
FILED: ONONDAGA COUNTY CLERK 07/03/2024 08:59 AM INDEX NO. 006790/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/03/2024
SUPREMECOURTOFTHESTATEOFNEWYORK
COUNTYOF ONONDAGA
THESUMMITFEDERALCREDIT UNION, Index No.
Plaintiff, SU MMON S
-vs-
VANESSAL. ANDREWS A/K/A VANESSAANDREWS;
NANCYB. ANDREWS A/K/A NANCYANDREWS;
AAO
TD BANKUSA, N.A.; CAVALRYSPVI LLCDOE,"
DOE"AND"JANE
CITIBANK, N.A.; "JOHN
Defendants.
TOTHEABOVENAMED
DEFENDANTS:
YOUAREHEREBYSUMMONED
to answer the Complaint in this action and to serve a
copy of your Answer, or, if the Complaint is not served with this Summons, to serve a Notice of
Appearance, on the Plaintiffs attorneys within twenty (20) days, after the service of this Summons
exclusive of the day of service (or within 30 days after the service is complete if this Summons is
not personally delivered to you within the State of NewYork); and in case of your failure to appear
or answer, judgment will be taken against you by default for the relief demanded in the Complaint.
Onondaga County is designated as the place of trial. The basis of venue is the location of
the mortgaged property.
NOTICE
YOUAREIN DANGEROFLOSING YOURHOME
Ifyou do not respond to this summons and complaint by serving a copy of the
answer on the attorney for the mortgage company who filed this foreclosure
proceeding against you and filing the answer with the court, a default judgment
may be entered and you can lose your home.
Speak to an attorney or go to the court where your case is pending for further
information on how to answer the summons and protect your property.
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Sending a payment to your mortgage company will not stop this foreclosure action.
YOUMUSTRESPONDBY SERVINGA COPYOFTHE ANSWERONTHE
ATTORNEYFORTHE PLAINTIFF (MORTGAGE ANDFILING
COMPANY)
THE ANSWER
WITHTHE COURT.
DATED: July , 2024
Amanda C. Shaw
Riehlman, Shafer & Shaw, LLC
Attorneys for Plaintiff
7693 Route 281
PO Box 544
Tully,NewYork 13159-0544
(315) 696-6347
THELAWFIRM OF RIEHLMAN, SHAFER& SHAW,LLC IS ATTEMPTINGTO
COLLECTA DEBTANDANYINFORMATIONOBTAINEDWILL BEUSEDFOR
THATPURPOSE.THIS LAWFIRM IS A DEBTCOLLECTOR.
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HELP FORHOMEOWNERS
IN FORECLOSURE
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/03/2024
New York State Law requires that we send you this notice about the foreclosure
process. Please read it carefully.
SUMMONS
ANDCOMPLAINT
You are in danger of losing your home. If you fail respond to the summons and
to
complaint in this foreclosure action, you may lose your home. Please read the
summonsand complaint carefully. You should immediately contact an attorney or your
local legal aid office to obtain advice on how to protect yourself.
OFINFORMATIONANDASSISTANCE
SOURCES
The State encourages you to become informed about your options in foreclosure. In
addition seeking assistance from an attorney or legal aid office, there are government
to
agencies and non-profit organizations that you may contact for information about
possible options, including trying to work with your lender during this process.
To an entity near you, you may call the toll-free
locate helpline maintained by the New
York State Department of Financial Services at 1-800-342.3736 or visit the
Department's website at http://www.dfs.ny.gov/consumer/mortg.htm.
RIGHTS ANDOBLIGATIONS
YOUARENOTREQUIREDTOLEAVEYOURHOME
AT THIS TIME. You
have the right your home during the foreclosure
to stay in process. You are not
required to leave your home unless and until your property is sold at auction pursuant to
a judgment of foreclosure and sale.
Regardless of whether you choose to remain in your home, YOUAREREQUIRED
TO TAKECAREOF YOURPROPERTYand pay taxes in accordance with state
and local law.
FORECLOSURE
RESCUESCAMS
"save"
Be careful of people who approach you with offers to your home. There are individ-
uals who watch for notices of foreclosure actions in order to unfairly profit from a home-
owner's distress. You should be extremely careful about any such promises and any sug-
gestions that you pay them a fee or sign over your deed. State law require anyone offering
such services for profit to enter into a contract which fully describes the services they will
perform and fee they will charge, and which prohibits them from taking any money from
you until they have completed all such promised services.
3 of 8
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COURT
SUPREME OFTHESTATEOFNEWYORK
COUNTYOFONONDAGA
THESUMMITFEDERALCREDITUNION, Index No.
Plaintiff, VERIFIED COMPLAINT
MORTGAGE
TOFORECLOSE
-vs-
VANESSAL. ANDREWS
A/K/A VANESSAANDREWS;
A/K/A NANCY
NANCYB. ANDREWS ANDREWS;
AAO
TD BANKUSA, N.A.; CAVALRYSPVI LLCDOE,"
"JOHN DOE"AND"JANE
CITIBANK, N.A.;
Defendants.
The Plaintiff by Riehlman, Shafer & Shaw, LLC,
herein, its attorneys, complains of
the Defendants above named, and for its cause of action, alleges:
FIRST: That the Plaintiff herein is a federally chartered credit union authorized to
conduct business in the State of NewYork, having its office and principal place of business at 100
Marina Drive, Rochester, NewYork.
SECOND: Upon information and belief, that at all times hereinafter mentioned,
the defendants set forth in Exhibit A-Defendants are made defendants in this action in the capacities
therein alleged and for the reasons set forth in said exhibit.
5*
THIRD: That on day of December 2019, for the purpose of securing
the
payment to The Summit Federal Credit Union of the sum of Ninety Thousand and 00/100 Dollars
($90,000.00) with interest thereon, Nancy B. Andrews a/k/a Nancy Andrews executed
and delivered
to The Summit Federal Credit Union a New York Fixed Rate Note (hereinafter referred to as the
"Note") bearing the same date and whereby she covenanted to pay to The Summit Federal Credit
Union, its successors and assigns, the sum of $90,000.00 with interest thereon at the rate of 4.625%
per annum, until the entire unpaid balance of principal and accrued interest was paid in full. A copy
of said Note is annexed hereto and marked Exhibit B.
FOURTH: That as security for the payment of the aforesaid indebtedness, a
Mortgage was executed, acknowledged and delivered to The Summit Federal Credit Union, its
successors or assigns, [Exhibit C being a copy of said Mortgage], whereby Nancy B. Andrews a/k/a
Nancy Andrews pledged to The Summit Federal Credit Union, its successors and assigns,
the
premises known as 322 Chestnut Heights Drive, Liverpool, New York, tax map no. 079.-01-15.0
(hereinafter called "mortgaged premises") more particularly described therein, under certain
conditions with rights, duties and privileges between or among them as more fully appears in said
Mortgage.
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FIFTH: That Mortgage was duly recorded (and the mortgage tax due
the said
thereon duly paid) in the OnondagaCounty Clerk's Office on December 11, 2019 as Instrument No.
2019-00047066. The Note and securing Mortgage provide that, in the case of default in payment of
the principal sum secured and the interest that might grow due and after the time frame to cure said
default has passed, the mortgagee may declare the principal sum immediately due and payable and
it further provided that in case of said default the mortgagee was empowered to sell the premises
according to law.
SIXTH: By Warranty Deed dated March 26, 2020, Nancy B. Andrews,
individually and as surviving spouse of Mason E. Andrews Jr., transferred the mortgaged premises
to her daughter, Vanessa L. Andrews, and retained a life estate interest in and to the premises.
SEVENTH:That owner of the subject Mortgage and Note, which
the Plaintiff is the
said documents are, at the time of commencementof this action, in Plaintiffs physical possession
thereof. Plaintiff has complied with all of the provisions of §595-a of the Banking Law and any
rules and regulations promulgated thereunder, §6-1 or §6-m of the Banking Law, and §1304 and
§1306 of the Real Property Actions and Proceedings Law and, as such, has standing to bring the
within action.
EIGHTH: That the Defendant, Nancy B. Andrews a/k/a Nancy Andrews, so
named, has failed and neglected to comply with
the conditions of said Note and Mortgage by
omitting and failing to pay items of principal and interest or taxes, assessments, water rates,
insurance premiums, escrow and/or other charges, including, but not limited to monthly payments
from October 1, 2023. The last voluntary payment remitted to plaintiff was credited to the subject
account on November 7, 2023.
NINTH: That the Plaintiff has issued a notice of default to the Defendants as
required pursuant to the terms of the aforesaid Mortgage and the Defendants have failed or
neglected to cure the defaults.
TENTH: That more than 30 days have elapsed since payment in full was due and
as
it remains unpaid according to the terms of the Note and Mortgage, the Plaintiff hereby elects to call
"FOURTH"
due the entire amount secured by the Mortgage described in paragraph hereof.
Accordingly, there is now due and owing to Plaintiff from Defendants the principal sum of
$84,428.95 accrued but unpaid interest as of April 15, 2024 in the sum of $2,428.90, with future
interest thereon at the contractual rate of 4.625% per annum from April 15, 2024, accumulated late
charges of $101.75, negative escrow balance of $1,010.60, less an unapplied balance of $685.00.
ELEVENTH: That in order to protect its security, the Plaintiff may be compelled
during the pendency of this action
pay to local taxes, insurance premiums
assessments, water rates,
and other charges affecting the mortgaged premises, and the Plaintiff requests that any sums thus
paid by it for said purposes (together with interest thereon), should be added to the sum otherwise
due and be deemed secured by the said Mortgage and be adjudged a valid lien on the mortgaged
premises.
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TWELFTH: That all the Defendants herein have, or claim to have, some interest
in, or lien upon said mortgaged premises or some part thereof, which interest or lien, if any, has
accrued subsequent to the lien of Plaintiffs Mortgage, excepting any real property taxing authorities
namedherein.
THIRTEENTH: That the Plaintiff is now the sole, true and lawful owner of the
said Note and Mortgage securing the same and there are no pending proceedings at law or otherwise
to collect or enforce the Note and Mortgage.
FOURTEENTH: That Exhibits A, B and C are expressly incorporated and made a
part of this Complaint for all purposes with the same force and effect as if they were completely and
fully set forth herein wherever reference has been made to each or any of them.
FIFTEENTH: That if the security for the indebtedness consists of more than one
parcel Plaintiff respectfully requests that the judgment of foreclosure provide for the sale of the
parcels in a particular order to the extent necessary to satisfy the indebtedness.
WHEREFORE,
Plaintiff demands judgment against the Defendants as follows:
1. That the interest of all Defendants and persons claiming under them be declared
subordinate to the interest of the Plaintiff, excepting any real property taxing authorities named
herein.
2.Defendant, Nancy B. Andrews a/k/a Nancy Andrews, and all other
That the
Defendants and all other persons under them subsequent to the filing of the Notice of Pendency in
this action on the OnondagaCounty Clerk's Office, be barred and foreclosed of all right, title, claim,
lien and of redemption in the said
equity
mortgaged premises, and each and every part thereof.
That the mortgaged premises be declared
3. to be sold according to law, and that the
mortgaged premises be sold in one parcel.
That the amount of principal
4. and interest due Plaintiff under the Note and
Mortgage be adjudged and that from the monies arising from said sale, the Plaintiff be paid the
amount due on the Note and Mortgage with interest to the time of said payment with the expenses
of the sale, including reasonable attorneys fees, and the costs and any monies advanced to protect
the lien of the Plaintiffs Mortgage including taxes, water and sewer charges, insurance premiums,
and all other charges and liens thereon paid with interest upon said amounts from the date of the
respective payments or advances thereof.
5. That the Defendant, Nancy B. Andrews a/k/a Nancy Andrews, be adjudged to
pay any deficiency which may remain, unless said Defendant has been discharged in bankruptcy.
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6. That the Plaintiff have such other and further relief as may seem just and proper,
together with the costs and disbursements of this action.
Dated: July 2024
Amanda . Shaw
RIEHLMAN, SHAFER& SHAW,LLC
Attorneys for Plaintiff
7693 Route 281
PO Box 544
Tully,NewYork 13159-0544
(315) 696-6347
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STATEOFNEWYORK )
COUNTYOF MONROE ) ss.:
Michelle Bell, being duly sworn, deposes and says that deponent is the Collection Manager
of The Summit Federal Credit Union, the plaintiff named in the within action; that deponent has
read the foregoing Summonsand Complaint and knows the contents thereof; that the same is true
to deponent's own knowledge, except as to the matters therein stated to be alleged upon information
and belief, and as to those matters deponent believes it to be true.
The Summit Federal Credit Union
Michelle Bell, Collection Manager
Sw rn to before me this
day of July, 2024
Notafy-P3blic
ELIZABETHA. STROMOUIST
Notary Public, State of NewYo&
_
Monroe County
Qualified in
No. 01ST4922997
Commission Expires March 14,
8 of 8
Preview
FILED: ONONDAGA COUNTY CLERK 07/03/2024 08:59 AM INDEX NO. 006790/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/03/2024 SUPREMECOURTOFTHESTATEOFNEWYORK COUNTYOF ONONDAGA THESUMMITFEDERALCREDIT UNION, Index No. Plaintiff, SU MMON S -vs- VANESSAL. ANDREWS A/K/A VANESSAANDREWS; NANCYB. ANDREWS A/K/A NANCYANDREWS; AAO TD BANKUSA, N.A.; CAVALRYSPVI LLCDOE," DOE"AND"JANE CITIBANK, N.A.; "JOHN Defendants. TOTHEABOVENAMED DEFENDANTS: YOUAREHEREBYSUMMONED to answer the Complaint in this action and to serve a copy of your Answer, or, if the Complaint is not served with this Summons, to serve a Notice of Appearance, on the Plaintiffs attorneys within twenty (20) days, after the service of this Summons exclusive of the day of service (or within 30 days after the service is complete if this Summons is not personally delivered to you within the State of NewYork); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the Complaint. Onondaga County is designated as the place of trial. The basis of venue is the location of the mortgaged property. NOTICE YOUAREIN DANGEROFLOSING YOURHOME Ifyou do not respond to this summons and complaint by serving a copy of the answer on the attorney for the mortgage company who filed this foreclosure proceeding against you and filing the answer with the court, a default judgment may be entered and you can lose your home. Speak to an attorney or go to the court where your case is pending for further information on how to answer the summons and protect your property. 1 of 8 FILED: ONONDAGA COUNTY CLERK 07/03/2024 08:59 AM INDEX NO. 006790/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/03/2024 Sending a payment to your mortgage company will not stop this foreclosure action. YOUMUSTRESPONDBY SERVINGA COPYOFTHE ANSWERONTHE ATTORNEYFORTHE PLAINTIFF (MORTGAGE ANDFILING COMPANY) THE ANSWER WITHTHE COURT. DATED: July , 2024 Amanda C. Shaw Riehlman, Shafer & Shaw, LLC Attorneys for Plaintiff 7693 Route 281 PO Box 544 Tully,NewYork 13159-0544 (315) 696-6347 THELAWFIRM OF RIEHLMAN, SHAFER& SHAW,LLC IS ATTEMPTINGTO COLLECTA DEBTANDANYINFORMATIONOBTAINEDWILL BEUSEDFOR THATPURPOSE.THIS LAWFIRM IS A DEBTCOLLECTOR. 2 of 8 FILED: ONONDAGA COUNTY CLERK 07/03/2024 08:59 AM INDEX NO. 006790/2024 HELP FORHOMEOWNERS IN FORECLOSURE NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/03/2024 New York State Law requires that we send you this notice about the foreclosure process. Please read it carefully. SUMMONS ANDCOMPLAINT You are in danger of losing your home. If you fail respond to the summons and to complaint in this foreclosure action, you may lose your home. Please read the summonsand complaint carefully. You should immediately contact an attorney or your local legal aid office to obtain advice on how to protect yourself. OFINFORMATIONANDASSISTANCE SOURCES The State encourages you to become informed about your options in foreclosure. In addition seeking assistance from an attorney or legal aid office, there are government to agencies and non-profit organizations that you may contact for information about possible options, including trying to work with your lender during this process. To an entity near you, you may call the toll-free locate helpline maintained by the New York State Department of Financial Services at 1-800-342.3736 or visit the Department's website at http://www.dfs.ny.gov/consumer/mortg.htm. RIGHTS ANDOBLIGATIONS YOUARENOTREQUIREDTOLEAVEYOURHOME AT THIS TIME. You have the right your home during the foreclosure to stay in process. You are not required to leave your home unless and until your property is sold at auction pursuant to a judgment of foreclosure and sale. Regardless of whether you choose to remain in your home, YOUAREREQUIRED TO TAKECAREOF YOURPROPERTYand pay taxes in accordance with state and local law. FORECLOSURE RESCUESCAMS "save" Be careful of people who approach you with offers to your home. There are individ- uals who watch for notices of foreclosure actions in order to unfairly profit from a home- owner's distress. You should be extremely careful about any such promises and any sug- gestions that you pay them a fee or sign over your deed. State law require anyone offering such services for profit to enter into a contract which fully describes the services they will perform and fee they will charge, and which prohibits them from taking any money from you until they have completed all such promised services. 3 of 8 FILED: ONONDAGA COUNTY CLERK 07/03/2024 08:59 AM INDEX NO. 006790/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/03/2024 COURT SUPREME OFTHESTATEOFNEWYORK COUNTYOFONONDAGA THESUMMITFEDERALCREDITUNION, Index No. Plaintiff, VERIFIED COMPLAINT MORTGAGE TOFORECLOSE -vs- VANESSAL. ANDREWS A/K/A VANESSAANDREWS; A/K/A NANCY NANCYB. ANDREWS ANDREWS; AAO TD BANKUSA, N.A.; CAVALRYSPVI LLCDOE," "JOHN DOE"AND"JANE CITIBANK, N.A.; Defendants. The Plaintiff by Riehlman, Shafer & Shaw, LLC, herein, its attorneys, complains of the Defendants above named, and for its cause of action, alleges: FIRST: That the Plaintiff herein is a federally chartered credit union authorized to conduct business in the State of NewYork, having its office and principal place of business at 100 Marina Drive, Rochester, NewYork. SECOND: Upon information and belief, that at all times hereinafter mentioned, the defendants set forth in Exhibit A-Defendants are made defendants in this action in the capacities therein alleged and for the reasons set forth in said exhibit. 5* THIRD: That on day of December 2019, for the purpose of securing the payment to The Summit Federal Credit Union of the sum of Ninety Thousand and 00/100 Dollars ($90,000.00) with interest thereon, Nancy B. Andrews a/k/a Nancy Andrews executed and delivered to The Summit Federal Credit Union a New York Fixed Rate Note (hereinafter referred to as the "Note") bearing the same date and whereby she covenanted to pay to The Summit Federal Credit Union, its successors and assigns, the sum of $90,000.00 with interest thereon at the rate of 4.625% per annum, until the entire unpaid balance of principal and accrued interest was paid in full. A copy of said Note is annexed hereto and marked Exhibit B. FOURTH: That as security for the payment of the aforesaid indebtedness, a Mortgage was executed, acknowledged and delivered to The Summit Federal Credit Union, its successors or assigns, [Exhibit C being a copy of said Mortgage], whereby Nancy B. Andrews a/k/a Nancy Andrews pledged to The Summit Federal Credit Union, its successors and assigns, the premises known as 322 Chestnut Heights Drive, Liverpool, New York, tax map no. 079.-01-15.0 (hereinafter called "mortgaged premises") more particularly described therein, under certain conditions with rights, duties and privileges between or among them as more fully appears in said Mortgage. 4 of 8 FILED: ONONDAGA COUNTY CLERK 07/03/2024 08:59 AM INDEX NO. 006790/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/03/2024 FIFTH: That Mortgage was duly recorded (and the mortgage tax due the said thereon duly paid) in the OnondagaCounty Clerk's Office on December 11, 2019 as Instrument No. 2019-00047066. The Note and securing Mortgage provide that, in the case of default in payment of the principal sum secured and the interest that might grow due and after the time frame to cure said default has passed, the mortgagee may declare the principal sum immediately due and payable and it further provided that in case of said default the mortgagee was empowered to sell the premises according to law. SIXTH: By Warranty Deed dated March 26, 2020, Nancy B. Andrews, individually and as surviving spouse of Mason E. Andrews Jr., transferred the mortgaged premises to her daughter, Vanessa L. Andrews, and retained a life estate interest in and to the premises. SEVENTH:That owner of the subject Mortgage and Note, which the Plaintiff is the said documents are, at the time of commencementof this action, in Plaintiffs physical possession thereof. Plaintiff has complied with all of the provisions of §595-a of the Banking Law and any rules and regulations promulgated thereunder, §6-1 or §6-m of the Banking Law, and §1304 and §1306 of the Real Property Actions and Proceedings Law and, as such, has standing to bring the within action. EIGHTH: That the Defendant, Nancy B. Andrews a/k/a Nancy Andrews, so named, has failed and neglected to comply with the conditions of said Note and Mortgage by omitting and failing to pay items of principal and interest or taxes, assessments, water rates, insurance premiums, escrow and/or other charges, including, but not limited to monthly payments from October 1, 2023. The last voluntary payment remitted to plaintiff was credited to the subject account on November 7, 2023. NINTH: That the Plaintiff has issued a notice of default to the Defendants as required pursuant to the terms of the aforesaid Mortgage and the Defendants have failed or neglected to cure the defaults. TENTH: That more than 30 days have elapsed since payment in full was due and as it remains unpaid according to the terms of the Note and Mortgage, the Plaintiff hereby elects to call "FOURTH" due the entire amount secured by the Mortgage described in paragraph hereof. Accordingly, there is now due and owing to Plaintiff from Defendants the principal sum of $84,428.95 accrued but unpaid interest as of April 15, 2024 in the sum of $2,428.90, with future interest thereon at the contractual rate of 4.625% per annum from April 15, 2024, accumulated late charges of $101.75, negative escrow balance of $1,010.60, less an unapplied balance of $685.00. ELEVENTH: That in order to protect its security, the Plaintiff may be compelled during the pendency of this action pay to local taxes, insurance premiums assessments, water rates, and other charges affecting the mortgaged premises, and the Plaintiff requests that any sums thus paid by it for said purposes (together with interest thereon), should be added to the sum otherwise due and be deemed secured by the said Mortgage and be adjudged a valid lien on the mortgaged premises. 5 of 8 FILED: ONONDAGA COUNTY CLERK 07/03/2024 08:59 AM INDEX NO. 006790/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/03/2024 TWELFTH: That all the Defendants herein have, or claim to have, some interest in, or lien upon said mortgaged premises or some part thereof, which interest or lien, if any, has accrued subsequent to the lien of Plaintiffs Mortgage, excepting any real property taxing authorities namedherein. THIRTEENTH: That the Plaintiff is now the sole, true and lawful owner of the said Note and Mortgage securing the same and there are no pending proceedings at law or otherwise to collect or enforce the Note and Mortgage. FOURTEENTH: That Exhibits A, B and C are expressly incorporated and made a part of this Complaint for all purposes with the same force and effect as if they were completely and fully set forth herein wherever reference has been made to each or any of them. FIFTEENTH: That if the security for the indebtedness consists of more than one parcel Plaintiff respectfully requests that the judgment of foreclosure provide for the sale of the parcels in a particular order to the extent necessary to satisfy the indebtedness. WHEREFORE, Plaintiff demands judgment against the Defendants as follows: 1. That the interest of all Defendants and persons claiming under them be declared subordinate to the interest of the Plaintiff, excepting any real property taxing authorities named herein. 2.Defendant, Nancy B. Andrews a/k/a Nancy Andrews, and all other That the Defendants and all other persons under them subsequent to the filing of the Notice of Pendency in this action on the OnondagaCounty Clerk's Office, be barred and foreclosed of all right, title, claim, lien and of redemption in the said equity mortgaged premises, and each and every part thereof. That the mortgaged premises be declared 3. to be sold according to law, and that the mortgaged premises be sold in one parcel. That the amount of principal 4. and interest due Plaintiff under the Note and Mortgage be adjudged and that from the monies arising from said sale, the Plaintiff be paid the amount due on the Note and Mortgage with interest to the time of said payment with the expenses of the sale, including reasonable attorneys fees, and the costs and any monies advanced to protect the lien of the Plaintiffs Mortgage including taxes, water and sewer charges, insurance premiums, and all other charges and liens thereon paid with interest upon said amounts from the date of the respective payments or advances thereof. 5. That the Defendant, Nancy B. Andrews a/k/a Nancy Andrews, be adjudged to pay any deficiency which may remain, unless said Defendant has been discharged in bankruptcy. 6 of 8 FILED: ONONDAGA COUNTY CLERK 07/03/2024 08:59 AM INDEX NO. 006790/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/03/2024 6. That the Plaintiff have such other and further relief as may seem just and proper, together with the costs and disbursements of this action. Dated: July 2024 Amanda . Shaw RIEHLMAN, SHAFER& SHAW,LLC Attorneys for Plaintiff 7693 Route 281 PO Box 544 Tully,NewYork 13159-0544 (315) 696-6347 7 of 8 FILED: ONONDAGA COUNTY CLERK 07/03/2024 08:59 AM INDEX NO. 006790/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/03/2024 STATEOFNEWYORK ) COUNTYOF MONROE ) ss.: Michelle Bell, being duly sworn, deposes and says that deponent is the Collection Manager of The Summit Federal Credit Union, the plaintiff named in the within action; that deponent has read the foregoing Summonsand Complaint and knows the contents thereof; that the same is true to deponent's own knowledge, except as to the matters therein stated to be alleged upon information and belief, and as to those matters deponent believes it to be true. The Summit Federal Credit Union Michelle Bell, Collection Manager Sw rn to before me this day of July, 2024 Notafy-P3blic ELIZABETHA. STROMOUIST Notary Public, State of NewYo& _ Monroe County Qualified in No. 01ST4922997 Commission Expires March 14, 8 of 8