COMPLAINT

IN THE UNITED STATES OF AMERICA DISTRICT COURT                        Civ. Act. No.

NEW YORK CITY CIVIL COURT                                                           CASE NO.

                                                                                                      COMPLAINT TO

SALY ABDELATY                                                                              QUIET TITLE

PLAINTIFF                                                                                       TO REAL

                                                                                                      PROPERTY

VERSUS

 

COMMISSIONER OF FINANCE – CITY OF SYRACUSE

DEFENDANT

 

COMPLAINT

The Plaintiff SALY ABDELATY complains against the named defendant as follows;

1. The Plaintiff is a resident of Syracuse City in New York and at all material times mentioned the owner of LOT 19 X2 BL1007TR FURMAN AMD.

 

2. The Defendant is the Commissioner of finance in the finance department of Syracuse City in New York.

 

3. The Plaintiff alleges that the defendant herein unfairly seized the Plaintiff’s property without following the proper procedure and/or denying the Plaintiff a chance to redeem the payment for the property.

 

4. The Plaintiff avers that she was ready and willing to make the payment, and indeed she already had, yet the same was rejected and the defendant herein stated that the property had already been seized by the city.

 

5. The Plaintiff is distressed and wishes to have her property back as she is ready and willing to continue with the outstanding payment.

 

6. The Plaintiff also claims a legal interest in the property and avers that the title to the aforementioned property still vests in her.

 

7. The Plaintiff now seeks a declaration that the title to the aforementioned property vests in her and that the same was unfairly seized, that the defendant be declared to have no rights in the subject and that such defendant be permanently stopped from asserting any right, title or interest in the subject property adverse to the Plaintiff herein.

 

WHEREFORE, the Plaintiff prays for judgment against the defendant as follows;

1. An order compelling the defendant to hand back legal title and possession of the seized property to the plaintiff.

 

1. A declaration and determination that the plaintiff is the rightful holder of the title to the property and the defendant be declared to have no right or interest in the estate.

 

1. Judgment permanently barring the defendant from claiming any estate, right or interest in the subject property.

 

1. Costs of suit herein incurred.

 

1. For such other and further relief as the court may deem proper.

 

DATED:                                                                       SIGNATURE:

                                                                                                                                                                                                                                                                                                               

 

I, SALY ABDELATY, am a Plaintiff in the above action. I have read the foregoing and know the contents thereof. The same is true of my own knowledge, except as to those matters which are therein alleged on information and belief, and as to those matters, I believe it to be true.

 

I declare under penalty of perjury that the foregoing is true and correct and that this declaration was execute in Syracuse, New York.

 

DATED:

 

                                                     

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