SUPERIOR COURT JPMORGAN CHASE BANK, NATIONAL
RETURN DATE: Ov4,,;., ts2014
: SUPERIOR COURT
JPMORGAN CHASE BANK, NATIONAL : J.D. OF NEW HAVEN ASSOCIATION : AT NEW HAVEN
VS.
lk
CONNOR, DONALD, ET AL
,
20
COMPLAINT 1.
On May 22, 2000, Donald Connor and Jeanie Streater (Deceased) owed Advanta
National Bank $125,900.00, as evidenced by a promissory note for said sum dated on said date, and payable to the order of Advanta National. Bank with interest from said date, in monthly installments of principal and interest. 2.
On said date, by a deed of that date, said Donald Connor and Jeanie Streater
(Deceased), to secure said note, mortgaged to Advanta National Bank the premises known as 251 Treadwell Street, Hamden, Connecticut, and described in Exhibit A attached hereto and made a part hereof 3.
Said mortgage deed was recorded on the Hamden Land Records on May 23,
2000 in Volume 1948 at Page 198. 4.
Advanta National Bank assigned said mortgage to Deutsche Bank National
Trust Company, as Custodian or Trustee F/K/A Bankers Trust Company of California, N.A. by
an assignment dated July 7, 2006 and recorded August 1, 2006 in Volume 3192 at Page 264 of
0328PC-20143487 Page 1 of 6
BE NDETT& Mc HUGH 160 FARMINGTON AVENUE • FARMINGTON,
CT o6o32 • (86o) 677-2868 • Juais No. 102832
the Hamden. Land Records. Said mortgage was further assigned to JPMorgan Chase Bank, National Association by an assignment dated February 9, 2012 and recorded February 27, 2012 in Volume 3891 at page 179 of the Hamden Land Records. 5
Jeanie Streater died on or about July 27, 2003.
6.
On or before May 27, 2014, the Plaintiff became and at all times since then has
been the party entitled to collect the debt evidenced by said note and is the party entitled to enforce said mortgage. The unpaid balance due pursuant to the terms of said note is $117,521.31, plus interest from August 1, 2013 and late charges and collection costs, that have not been paid although due and payable. 7.
Said note and mortgage are now in default by virtue of nonpayment of the
monthly installments of principal and interest due on September 1, 2013 and each and every month thereafter, and the Plaintiff has exercised its option to declare the entire balance of said note due and payable. 8.
The following encumbrances of record upon the property sought to be
foreclosed are prior in right to the Plaintiffs mortgage and are not affected by this action: (a)
Any taxes due the Town of Hamden that remain outstanding and
properly perfected as of the date hereof pursuant to applicable law.
0328FC-20143487 Page 2 of 6
BEND ETT& McHUGH 160 FARMINGTON AVENUE • FARMINGTON, CT o6o32 • (86o) 677-2868 • JURIs No. 102892
9.
On the aforementioned piece of property, the following interests are claimed
which are subsequent to Plaintiffs said mortgage: (a)
The Defendant, State of Connecticut, Department of Revenue Services,
may claim an interest in said premises by virtue of an inchoate lien for possible succession taxes and/or estate taxes and/or gift taxes due the Estate of Jeanie Streater. 10.
Upon information and belief, the Defendant(s), Donald Connor is the owner(s)
of record and in possession of said premises.
0328FC-20143487 Page 3 of 6
BENDETT& McHUGH 160 FARMINGTON AVENUE • FARMINGTON, CT
06032 • (86o) 677-2868 • JURIS No. 102892
WHEREFORE, The Plaintiff claims: 1. 2. 3.
4. 5. 6.
A foreclosure of said mortgage. Immediate possession of the mortgaged premises. A deficiency judgment. No deficiency will be sought against any person whose obligation under the subject promissory note has been heretofore or hereafter discharged in bankruptcy. The appointment of a receiver to collect rents and profits accruing from the premises. Reasonable attorney's fees and costs. Such other relief and further equitable relief as may be required.
NOTICE: A PERSON WHO IS UNEMPLOYED OR UNDER-EMPLOYED AND WHO HAS FOR A CONTINUOUS PERIOD OF AT LEAST TWO YEARS PRIOR TO THE COMMENCEMENT OF THIS FORECLOSURE ACTION OWNED AND OCCUPIED THE PROPERTY BEING FORECLOSED AS SUCH PERSON'S PRINCIPAL RESIDENCE, MAY BE ENTITLED TO CERTAIN RELIEF PROVISIONS UNDER SECTIONS 49-31d to 49-31i, INCLUSIVE, OF THE CONNECTICUT GENERAL STATUTES. YOU SHOULD CONSULT AN ATTORNEY TO DETERMINE YOUR RIGHTS UNDER SECTIONS 49-31d to 49-31i OF THE CONNECTICUT GENERAL STATUTES. NOTICE: THE LAW FIRM OF BENDETT & MCHUGH, P.C. IS A DEBT COLLECTOR AND IS ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY WHICH DISCHARGED THIS DEBT, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
0328FC-20143487 Page 4 of 6
BEND ETT& McHUGH 160
FARMINGTON AVENUE • FARMINGTON,
CT 06032 • (86o) 677-2868 •
JuRis
No. 102892
•
•
This action is within jurisdiction of the Superior Court.
(.4 1 (
Dated at Farmington, Connecticut,
, 20
THE PLAINTIFF, JPMORGAN CHASE BANK, NATIONAL ASSOCIA ON
By es W. Donohue endett & McHugh, P.C. Its Attorneys 160 Farmington Avenue Farmington, CT 06032 (860) 677-2868 Juris No. 102892
0328FC-20143487 Page 5 of 6
BENDETT& Mc HUGH
160 FARMINGTON AVENUE • FARMINGTON, CT 06032 • (86o) 677-2868 • JuRis No. 102892
RETURN DATE:flui ✓., 2014
: SUPERIOR COURT
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
: J.D. OF NEW HAVEN
VS.
: AT NEW HAVEN , 20 1 1
CONNOR, DONALD, ET AL
STATEMENT OF AMOUNT IN DEMAND The amount, legal interest or property in demand is $15,000.00 or more, exclusive of interest and costs. PLAINTIFF, JPMORGAN CHASE BANK, NATIONAL ASSOC TION
J nes . Donohue endett & McHugh, P.C. Its Attorneys 160 Farmington. Avenue Farmington, CT 06032 (860) 677-2868 Juris No. 102892 MLRB/0328FC-20143487
0328FC-20143487 Page 6 of 6
BENDETT&McHUGH 160 FARMINGTON AVENUE • FARMINGTON, CT 06032 • (860) 677-2868 • Jums No. 102892
All that certain piece or parcel of land, with the buildings, and
all other improvements thereon, Situated in the Town of Naliden, in the County of New haven and State of Connecticut, known as '251 Treadwell Street, and bounded: Southwest by Treadwell Street,
69.4$ foot, more or less;
Northwest by land now pr formerly of Cyril A. SIOndin and Georgian:: Slondin, - 126 feet, being a bent line: Northeast 80.97 feat, by a straight line: Southeast by land of Jennie K. Brown, 125 feet, more or less, the easterly terminus thereof being. a point on a line *which line Would intersect the northerly line of Martin Terrace at a point therein distant easterly 125 feat from Treadwell Street, when measured along the northerly line of Martin Terrace, and which line would Corm an angle of 95 degrees, 24 minutes with the northerly line of Martin Terrace, When seasured free the southwest through the vest toward the, north.
: SUPERIOR COURT
JPMORGAN CHASE BANK, NATIONAL : J.D. OF NEW HAVEN ASSOCIATION : AT NEW HAVEN
VS.
lk
CONNOR, DONALD, ET AL
,
20
COMPLAINT 1.
On May 22, 2000, Donald Connor and Jeanie Streater (Deceased) owed Advanta
National Bank $125,900.00, as evidenced by a promissory note for said sum dated on said date, and payable to the order of Advanta National. Bank with interest from said date, in monthly installments of principal and interest. 2.
On said date, by a deed of that date, said Donald Connor and Jeanie Streater
(Deceased), to secure said note, mortgaged to Advanta National Bank the premises known as 251 Treadwell Street, Hamden, Connecticut, and described in Exhibit A attached hereto and made a part hereof 3.
Said mortgage deed was recorded on the Hamden Land Records on May 23,
2000 in Volume 1948 at Page 198. 4.
Advanta National Bank assigned said mortgage to Deutsche Bank National
Trust Company, as Custodian or Trustee F/K/A Bankers Trust Company of California, N.A. by
an assignment dated July 7, 2006 and recorded August 1, 2006 in Volume 3192 at Page 264 of
0328PC-20143487 Page 1 of 6
BE NDETT& Mc HUGH 160 FARMINGTON AVENUE • FARMINGTON,
CT o6o32 • (86o) 677-2868 • Juais No. 102832
the Hamden. Land Records. Said mortgage was further assigned to JPMorgan Chase Bank, National Association by an assignment dated February 9, 2012 and recorded February 27, 2012 in Volume 3891 at page 179 of the Hamden Land Records. 5
Jeanie Streater died on or about July 27, 2003.
6.
On or before May 27, 2014, the Plaintiff became and at all times since then has
been the party entitled to collect the debt evidenced by said note and is the party entitled to enforce said mortgage. The unpaid balance due pursuant to the terms of said note is $117,521.31, plus interest from August 1, 2013 and late charges and collection costs, that have not been paid although due and payable. 7.
Said note and mortgage are now in default by virtue of nonpayment of the
monthly installments of principal and interest due on September 1, 2013 and each and every month thereafter, and the Plaintiff has exercised its option to declare the entire balance of said note due and payable. 8.
The following encumbrances of record upon the property sought to be
foreclosed are prior in right to the Plaintiffs mortgage and are not affected by this action: (a)
Any taxes due the Town of Hamden that remain outstanding and
properly perfected as of the date hereof pursuant to applicable law.
0328FC-20143487 Page 2 of 6
BEND ETT& McHUGH 160 FARMINGTON AVENUE • FARMINGTON, CT o6o32 • (86o) 677-2868 • JURIs No. 102892
9.
On the aforementioned piece of property, the following interests are claimed
which are subsequent to Plaintiffs said mortgage: (a)
The Defendant, State of Connecticut, Department of Revenue Services,
may claim an interest in said premises by virtue of an inchoate lien for possible succession taxes and/or estate taxes and/or gift taxes due the Estate of Jeanie Streater. 10.
Upon information and belief, the Defendant(s), Donald Connor is the owner(s)
of record and in possession of said premises.
0328FC-20143487 Page 3 of 6
BENDETT& McHUGH 160 FARMINGTON AVENUE • FARMINGTON, CT
06032 • (86o) 677-2868 • JURIS No. 102892
WHEREFORE, The Plaintiff claims: 1. 2. 3.
4. 5. 6.
A foreclosure of said mortgage. Immediate possession of the mortgaged premises. A deficiency judgment. No deficiency will be sought against any person whose obligation under the subject promissory note has been heretofore or hereafter discharged in bankruptcy. The appointment of a receiver to collect rents and profits accruing from the premises. Reasonable attorney's fees and costs. Such other relief and further equitable relief as may be required.
NOTICE: A PERSON WHO IS UNEMPLOYED OR UNDER-EMPLOYED AND WHO HAS FOR A CONTINUOUS PERIOD OF AT LEAST TWO YEARS PRIOR TO THE COMMENCEMENT OF THIS FORECLOSURE ACTION OWNED AND OCCUPIED THE PROPERTY BEING FORECLOSED AS SUCH PERSON'S PRINCIPAL RESIDENCE, MAY BE ENTITLED TO CERTAIN RELIEF PROVISIONS UNDER SECTIONS 49-31d to 49-31i, INCLUSIVE, OF THE CONNECTICUT GENERAL STATUTES. YOU SHOULD CONSULT AN ATTORNEY TO DETERMINE YOUR RIGHTS UNDER SECTIONS 49-31d to 49-31i OF THE CONNECTICUT GENERAL STATUTES. NOTICE: THE LAW FIRM OF BENDETT & MCHUGH, P.C. IS A DEBT COLLECTOR AND IS ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY WHICH DISCHARGED THIS DEBT, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
0328FC-20143487 Page 4 of 6
BEND ETT& McHUGH 160
FARMINGTON AVENUE • FARMINGTON,
CT 06032 • (86o) 677-2868 •
JuRis
No. 102892
•
•
This action is within jurisdiction of the Superior Court.
(.4 1 (
Dated at Farmington, Connecticut,
, 20
THE PLAINTIFF, JPMORGAN CHASE BANK, NATIONAL ASSOCIA ON
By es W. Donohue endett & McHugh, P.C. Its Attorneys 160 Farmington Avenue Farmington, CT 06032 (860) 677-2868 Juris No. 102892
0328FC-20143487 Page 5 of 6
BENDETT& Mc HUGH
160 FARMINGTON AVENUE • FARMINGTON, CT 06032 • (86o) 677-2868 • JuRis No. 102892
RETURN DATE:flui ✓., 2014
: SUPERIOR COURT
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
: J.D. OF NEW HAVEN
VS.
: AT NEW HAVEN , 20 1 1
CONNOR, DONALD, ET AL
STATEMENT OF AMOUNT IN DEMAND The amount, legal interest or property in demand is $15,000.00 or more, exclusive of interest and costs. PLAINTIFF, JPMORGAN CHASE BANK, NATIONAL ASSOC TION
J nes . Donohue endett & McHugh, P.C. Its Attorneys 160 Farmington. Avenue Farmington, CT 06032 (860) 677-2868 Juris No. 102892 MLRB/0328FC-20143487
0328FC-20143487 Page 6 of 6
BENDETT&McHUGH 160 FARMINGTON AVENUE • FARMINGTON, CT 06032 • (860) 677-2868 • Jums No. 102892
All that certain piece or parcel of land, with the buildings, and
all other improvements thereon, Situated in the Town of Naliden, in the County of New haven and State of Connecticut, known as '251 Treadwell Street, and bounded: Southwest by Treadwell Street,
69.4$ foot, more or less;
Northwest by land now pr formerly of Cyril A. SIOndin and Georgian:: Slondin, - 126 feet, being a bent line: Northeast 80.97 feat, by a straight line: Southeast by land of Jennie K. Brown, 125 feet, more or less, the easterly terminus thereof being. a point on a line *which line Would intersect the northerly line of Martin Terrace at a point therein distant easterly 125 feat from Treadwell Street, when measured along the northerly line of Martin Terrace, and which line would Corm an angle of 95 degrees, 24 minutes with the northerly line of Martin Terrace, When seasured free the southwest through the vest toward the, north.
