MEMORANDUM IN OPPOSITION TO MOTION to Open and Vacate Judgment

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On October 31, 2017 a case was filed by Deutsche Bank National Trust Company, As Trustee Under The Pooling And Servicing Agreement Dated As Of July 1, 2002, Morgan Stanley Dean Witter Capital I Inc. Trust 2002-He2, represented by Christa Ashley Menge, and Mccalla Raymer Leibert Pierce Llc, against Joseph E Genovese Jr Aka Genovese, Jr., Joseph E., and Theresa D Genovese, represented by Brown Law Llc, in the jurisdiction of Hartford County. Judge Joseph M. Shortall presiding.

                        
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                           DOCKET NO. HHB-CV17-6040347-S                            :              SUPERIOR COURT

 DEUTSCHE BANK NATIONAL TRUST
 COMPANY, AS TRUSTEE UNDER THE
 POOLING AND SERVICING AGREEMENT
 DATED AS OF JULY 1, 2002, MORGAN
 STANLEY DEAN WITTER CAPITAL I INC.                       :          J.D. OF NEW BRITAIN
 TRUST 2002-HE2

 VS.                                                      :               AT NEW BRITAIN

 GENOVESE, THERESA D., ET AL                              :                 MARCH 14, 2024

     PLAINTIFF’S OBJECTION TO DEFENDANTS’ MOTION TO OPEN AND VACATE
                                JUDGMENT

        Plaintiff, Deutsche Bank National Trust Company, As Trustee Under the Pooling and

Servicing Agreement Dated as of July 1, 2002, Morgan Stanley Dean Witter Capital I Inc. Trust

2002-HE2 (the “Plaintiff”) in the above-entitled matter hereby objects to the Defendants’ Theresa

D. Genovese and Joseph E. Genovese, Jr.’s (the “Defendants”), Motion to Open and Set Aside

Judgmen…