SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ULSTER
INDEX NO. EF2025-881
Plaintiff designates ULSTER as the place of trial situs of the real property
SUPPLEMENTAL SUMMONS
Mortgaged Premises:
89 CEDAR STREET,
WEST HURLEY, NY 12491
Section: 38.10,
Block: 3, Lot: 16
WELLS FARGO BANK, N.A.,
Plaintiff,
vs.
JOAN MOSHER, AS HEIR AND DISTRIBUTEE OF THE ESTATE OF BAR BARA CULLEN A/K/A BARBARA L. CULLEN; SCOTT B MOSHER, AS HEIR AND DISTRIBUTEE OF THE ESTATE OF BARBARA CULLEN A/K/A BARBARA L. CULLEN; UNKNOWN HEIRS AND DISTRIBUTEES OF THE ESTATE OF BARBARA CULLEN A/K/A BARBARA L. CULLEN, any and all persons unknown to plaintiff, claiming, or who may claim to have an interest in, or general or specific lien upon the real property described in this action; such unknown persons being herein generally described and intended to be included in the following designation, namely: the wife, widow, husband, widower, heirs at law, next of kin, descendants, executors, administrators, devisees, legatees, creditors, trustees, committees, lienors, and assignees of such deceased, any and all persons deriving interest in or lien upon, or title to said real property by, through or under them, or either of them, and their respective wives, widows, husbands, widowers, heirs at law, next of kin, descendants, executors, administrators, devisees, legatees, creditors, trustees, committees, lienors and assigns, all of whom and whose names, except as stated, are unknown to plaintiff; NEW YORK STATE DEPARTMENT OF TAXATION AND FINANCE; UNITED STATES OF AMERICA,
"JOHN DOE #1" through "JOHN DOE #12," the last twelve names being fictitious and unknown to plaintiff, the persons or parties intended being the tenants, occupants, persons or corporations, if any, having or claiming an interest in or lien upon the premises, described in the complaint,
Defendants.
To the above named Defendants
YOU ARE HEREBY SUMMONED to answer the Complaint in the above entitled action and to serve a copy of your Answer on the plaintiff’s attorney within twenty (20) days of the service of this Summons, exclusive of the day of service, or within thirty (30) days after service of the same is complete where service is made in any manner other than by personal delivery within the State. The United States of America, if designated as a defendant in this action, may answer or appear within sixty (60) days of service. Your failure to appear or to answer will result in a judgment against you by default for the relief demanded in the Complaint. In the event that a deficiency balance remains from the sale proceeds, a judgment may be entered against you.
NOTICE OF NATURE OF ACTION AND RELIEF SOUGHT
THE OBJECT of the above caption action is to foreclose a Mortgage to secure the sum of $60,800.00 and interest, recorded on March 22, 2001, in Book 04580 at Page 0229, of the Public Records of ULSTER County, New York., covering premises known as 89 CEDAR STREET, WEST HURLEY, NY 12491.
The relief sought in the within action is a final judgment directing the sale of the premises described above to satisfy the debt secured by the Mortgage described above.
ULSTER County is designated as the place of trial because the real property affected by this action is located in said county.
NOTICE
YOU ARE IN DANGER OF LOSING YOUR HOME
If you do not respond to this summons and complaint by serving a copy of the answer on the attorney for the mortgage company who filed this foreclosure proceeding against you and filing the answer with the court, a default judgment may be entered and you can lose your home.
Speak to an attorney or go to the court where your case is pending for further information on how to answer the summons and protect your property.
Sending a payment to the mortgage company will not stop the foreclosure action.
YOU MUST RESPOND BY SERVING A COPY OF THE ANSWER ON THE ATTORNEY FOR THE PLAINTIFF (MORTGAGE COMPANY) AND FILING THE ANSWER WITH THE COURT.
Dated: December 15th, 2025
ROBERTSON, ANSCHUTZ, SCHNEID, CRANE & PARTNERS, PLLC
Attorney for Plaintiff
Matthew Rothstein, Esq.
900 Merchants Concourse, Suite 310
Westbury, NY 11590
516-280-7675