United states of america acting through the rhs

UNITED STATES OF AMERICA ACTING THROUGH THE RURAL HOUSING SERVICE OR SUCCESSOR AGENCY, UNITED STATES DEPARTMENT OF AGRICULTURE v. TINA HART AKA et al, EC2022-33719, 2 (N.Y. Sup. Ct., Washington County

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UNITED STATES OF AMERICA ACTING THROUGH THE RURAL HOUSING SERVICE OR SUCCESSOR AGENCY, UNITED STATES DEPARTMENT OF AGRICULTURE v. TINA HART AKA et al, EC2022-33719, 2 (N.Y. Sup. Ct., Washington County

FILED: WASHINGTON COUNTY CLERK 02/17/2022 12:03 PM
`NYSCEF DOC. NO. 2
`
`
`INDEX NO. EC2022-33719
`
`RECEIVED NYSCEF: 02/17/2022
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF WASHINGTON
`
`
`______________________________________________
`
`UNITED STATES OF AMERICA ACTING
`THROUGH THE RURAL HOUSING SERVICE OR
`SUCCESSOR AGENCY, UNITED STATES
`DEPARTMENT OF AGRICULTURE,
`
`
`Plaintiff,
`
`
`-against-
`
`TINA HART AKA TINA VANNESS; GLENS FALLS
`HOSPITAL; UNITED STATES OF AMERICA-
`INTERNAL REVENUE SERVICE; NEW YORK
`STATE DEPARTMENT OF TAXATION AND
`FINANCE; and JOHN DOE AND JANE DOE #1 through
`#7, the last seven (7) names being fictitious and unknown
`to the Plaintiff, the persons or parties intended being the
`tenants, occupants, persons or parties, if any, having or
`claiming an interest in or lien upon the mortgaged
`premises described in the complaint,
`
`
`Defendants.
`______________________________________________
`
`
`
`INDEX NO:
`
`CERTIFICATE OF MERIT
`PURSUANT TO CPLR
`3012-b
`
`Mortgaged Premises Address:
`3881 State Route 4
`Hudson Falls, NY 12839
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1.
`
`I am an attorney at law duly licensed to practice in the State of New York, and am
`
`affiliated with the law firm of Pincus Law Group, PLLC., attorney for Plaintiff in this action.
`
`2.
`
`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. Copies of these documents are
`
`attached as exhibits to the summons and complaint.
`
`3.
`
`I have consulted about the facts of this case with Mirian Jackson, a representative
`
`of Plaintiff.
`
`
`
`1 of 2
`
`

`FILED: WASHINGTON COUNTY CLERK 02/17/2022 12:03 PM
`NYSCEF DOC. NO. 2
`
`INDEX NO. EC2022-33719
`
`RECEIVED NYSCEF: 02/17/2022
`
`4.
`
`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
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`Plaintiff is the creditor entitled to enforce rights under these documents.
`
`5.
`
`I am aware of my obligations under New York Rules of Professional Conduct (22
`
`NYCRR Part 1200) and 22 NYCRR Part 130.
`
`Dated: Uniondale, New York
`February 17
`_________________, 2022
`
` Respectfully submitted,
`
` Pincus Law Group, PLLC.
`
` By:___________________________________
` George J. Weissinger, Esq.
`Attorneys for Plaintiff
`425 RXR Plaza
`Uniondale, NY 11556
`516-699-8902
`
`2 of 2
`
`

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