|| RETURN DATE: FEBRUARY 28, 2017 SUPERIOR COURT
FEDERAL NATIONAL MORTGAGE 1D. OF DANBURY
|| ASSOCIATION
|| VS. AT DANBURY
|
|| GUCKER, KENNETH M. A/K/A as .20/ +
GUCKER, KENNETH , ET AL
COMPLAINT
1. On September 2, 2003, Kenneth M. Gucker a/k/a Kenneth Gucker owed
Fortune Lending Group, LLC $135,000.00, as evidenced by a promissory note for said sum
dated on said date, and payable to the order of Fortune Lending Group, LLC with interest from
said date, in monthly installments of principal and interest,
2. On said date, by a deed of that date, said Kenneth M. Gucker a/k/a Kenneth
Gucker and Sharon D. Gucker , to secure said note, mortgaged to Mortgage Electronic
Registration Systems, Inc., as Nominee for Fortune Lending Group, LLC the premises known
as 89 Padanaram Road, Danbury, Connecticut, and described in Exhibit A attached hereto and
made a part hereof.
| 3. Said mortgage deed was recorded on the Danbury Land Records on September
19, 2003 in Volume 1588 at Page 1106
4. Mortgage Electronic Registration Systems, Inc., as Nominee for Fortune
Lending Group, LLC assigned said mortgage to CitiMortgage, Ine, by an assignment dated
RENDET Te MetIVGH
| 160 Fatuscros Avenue» PusaoToN, CT o6032 » (B60) 677-2868» Joni No, soa892April 13, 2010 and recorded April 19, 2010 in Volume 2084 at Page 1188 of the Danbury Land
Records. Said mortgage was further assigned to Federal National Mortgage Association by an
assignment dated February 27, 2014 and recorded March 6, 2014 in Volume 2268 at page 192
of the Danbury Land Records.
5. Onor before December 7, 2016, 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
$99,685.41, plus interest from July 1,2016 and late charges and collection costs, that have not
been paid although due and payable.
6. Said note and mortgage are now in default by virtue of nonpayment of the
monthly installments of principal and interest due on August 1, 2016 and each and every month
thereafter, and the Plaintiff has exercised its option to declare the entire balance of said note
due and payable.
7. The following encumbrances of record upon the property sought to be
foreclosed are prior in right to the Plaintiff's mortgage and are not affected by this action:
(a) Any taxes due the Town of Danbury that remain outstanding and
properly perfected as of the date hereof pursuant to applicable law.
BENDETT@ McHUGH
160 FARMINGTON AVENUE * FARMINGTON. CT 06032 * (860) 677-2868 + JuRis No. 1028928 On the aforementioned piece of property, the following interests are claimed
which are subsequent to Plaintiff's said mortgage:
None.
9. Upon information and belief, the Defendant, Kenneth M. Gucker a/k/a Kenneth
|| Gucker is the owner of record and in possession of said premises by virtue ofa quit claim deed
dated November 19, 2009 and recorded November 19, 2009 on the Danbury Land Records.
BENDETT@ McHUGH
160 FARMINGTON AVENUE * FARMINGTON, CT 06032 + (860) 677-2868 + JuRis No. 102892WHEREFORE, The Plaintiff claims:
1. A foreclosure of said mortgage.
2. Immediate possession of the mortgaged premises.
3. 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.
4, The appointment of a receiver to collect rents and profits accruing from the premises.
5. Reasonable attomey’s fees and costs.
6. Such other relief and further equitable relief as may be required.
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.
BENDETTg@ McHUGH
160 FARMINGTON AVENUE + FARMINGTON. CT 06032 + (860) 677-2868 + Junts No. 102892‘This action is within jurisdiction of the Superior Court.
Dated at Farmington, Connecticut, Taw s 95-0 [tk
‘THE PLAINTIFFS
Go FarMiverow AVENUE *
DERAL NATIONAL MORTGAGE,
ASSOCIATION
Its Attorneys
160 Farmington Avenue
Farmington, CT 06032
(860) 677-2868
Juris No. 102892
BENDETTe McHUGH
FanwiNcrox, CT 06032 + (860) 677-2868 + Jonis No. 102892RETURN DATE: FEBRUARY 28, 2017 : SUPERIOR COURT
FEDERAL NATIONAL MORTGAGE : LD. OF DANBURY
ASSOCIATION
| vs. : ATDANBURY
| GUCKER, KENNETH M. AIK/AGUCKER, =: Jum : 2 ft
KENNETH , ET AL
STATEMENT OF AMOUNT IN DEMA‘
D
The amount, legal interest or property in demand is $15,000.00 or more, exclusive of
interest and costs,
PLAINTIFF,
FEDERAL NATIONAL MORTGAGE,
ASSOCIATION
Its Attorneys
160 Farmington Avenue
Farmington, CT 06032
(860) 677-2868
Juris No. 102892
MLRRST#BEC- 20166158 |
Rev. 083016
BENDETT@ McHUGH
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