On September 23, 2015 a
ANSWER - VERIFIED
was filed
involving a dispute between
Emigrant Savings Bank - Brooklyn Queens,
and
Brian Edkins,
Ford Motor Credit Company Llc,
New York City Parking Violations Bureau,
New York Environmental Control Board,
Regina Edkins,
Rosa Carbial,
Socorro Carbial,
for Real Property - Mortgage Foreclosure - Residential
in the District Court of Richmond County.
Preview
FILED: RICHMOND COUNTY CLERK 04/29/2024 02:44 PM INDEX NO. 130763/2011
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/29/2024
SUrnEME Cou T
County of FJ : State of New York
Plaintiff. Index No.: / 2 o M3 / /
2m U 18 A tI 32
VEidFIED ANSWER TO
FORECLOSURE COMPLAINT
Defendant
Destedaat Answera as fbBows:
General Denial
1 plead the following Defenses and Affirutative Defenses:
O Lack of Standing to Sue: Plaintifidoes not have standing to sue because it was not
the legal owner ofthe Note and/or Mortgage at the time it commenced this
foreclosure lawsuit.
O Improper Service of the Summons and Complaint (NY Civil Practice Law and Rules
Section 308) for the following reason.
O Partial or Full Payment: I have made payments in the amount of $ which
have not been properly credited and are not reflected in the Summons and Complaint:
Foreciosure"
O [ did not receive the notice "Help for Homeowners in that was supposed
to be served with the Fometosure Summons and Complaint (NY Real Property
Actions and Proceedings [2w Section 1303) (amended 2008),
O I have no knowledge was assigned
than the plaintiff my debi or there was no
Affirmative Altegation
of Standing (NY ReaL Property Actions and Proceedings Law
Section 1302. high-cost and subprime home founs) (amended 2008): PlaintitTrailed
to allege (swear) in the Foreclosure Complain1 that 11 is the legal owner and holder of
the Note and/or Mortgage or has the authority to foreclose.
O Pre-Foreclosure Notices (NY Real Property Actions and Proceedings Law
90-Day
Section subprime and non-traditional
home toans) 2D08} (amended
13D4, high
Document Filed Date
April 29, 2024
Case Filing Date
September 23, 2015
Category
Real Property - Mortgage Foreclosure - Residential
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FILED: RICHMOND COUNTY CLERK 04/29/2024 02:44 PM INDEX NO. 130763/2011 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/29/2024 SUrnEME Cou T County of FJ : State of New York Plaintiff. Index No.: / 2 o M3 / / 2m U 18 A tI 32 VEidFIED ANSWER TO FORECLOSURE COMPLAINT Defendant Destedaat Answera as fbBows: General Denial 1 plead the following Defenses and Affirutative Defenses: O Lack of Standing to Sue: Plaintifidoes not have standing to sue because it was not the legal owner ofthe Note and/or Mortgage at the time it commenced this foreclosure lawsuit. O Improper Service of the Summons and Complaint (NY Civil Practice Law and Rules Section 308) for the following reason. O Partial or Full Payment: I have made payments in the amount of $ which have not been properly credited and are not reflected in the Summons and Complaint: Foreciosure" O [ did not receive the notice "Help for Homeowners in that was supposed to be served with the Fometosure Summons and Complaint (NY Real Property Actions and Proceedings [2w Section 1303) (amended 2008), O I have no knowledge was assigned than the plaintiff my debi or there was no Affirmative Altegation of Standing (NY ReaL Property Actions and Proceedings Law Section 1302. high-cost and subprime home founs) (amended 2008): PlaintitTrailed to allege (swear) in the Foreclosure Complain1 that 11 is the legal owner and holder of the Note and/or Mortgage or has the authority to foreclose. O Pre-Foreclosure Notices (NY Real Property Actions and Proceedings Law 90-Day Section subprime and non-traditional home toans) 2D08} (amended 13D4, high