COMPLAINT

COMPLAINT STEVEN PROSCIA PLAINTIFF V. MG HOLDING USA, LLC DEFENDANTS. IN THE COURT OF COMMON PLEAS WAYNE COUNTY, PENNSYLVANIA NO.: 2024-CV-608 NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within 20 days after this complaint and notice are served, by entering personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by Plaintiff. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. PA LAWYER REFERRAL SERVICE 110 SOUTH STREET P.O. BOX 186 HARRISBURG, PA 17108 (800) 692-7375 (PA residents) (717) 238-6715 NORTH PENN LEGAL SERVICES 10 N. Tenth Street Stroudsburg, PA 18360 570-424-5338 800-532-8282 (Toll Free) STEVEN PROSCIA PLAINTIFF V. MG HOLDING USA, LLC DEFENDANTS. IN THE COURT OF COMMON PLEAS WAYNE COUNTY, PENNSYLVANIA NO.: 2024-CV-608 COMPLAINT IN QUIET TITLE AND NOW, comes the Plaintiff, STEVEN PROSCIA, through their attorneys, Spall, Rydzewski, Anderson, Lalley and Krajkovich, by Kyle Krajkovich, Esq., and files the following Action to Quiet Title, whereof the following is a true and correct statement, to wit: 1.The Plaintiff, Steven Proscia ("Proscia" or "Plaintiff"), is an individual of sound mind with a principal place of residence at 17 Seba Avenue, Brooklyn, NY 11229. 2.The Defendant, upon belief and information, is New Jersey Corporation, with a last known address care of Adam David Markel, P.C., 23 West Main Street Freehold, NJ 07728. 3.The property equitably and legally owned by Plaintiff is described as follows: Sale #0561-2017 Being those premises assessed to AHPA Properties, Inc., by deed recorded in Record Book #3924 at Page #0159. Property described as Residential Acreage One to Ten Acres and assigned Map #14-0-0050-0050 and Control #114633 by Wayne County Assessment Office. 4.Plaintiff's Lot is further known as Lot 50 in the Rainbow Run Subdivision, Gouldsboro, Pennsylvania. 5.A copy of Plaintiff's Deed is attached here as Exhibit "A". 6.Plaintiff purchased the premises on or about January 15th, 2021, the date of recording for Plaintiff's Deed. 7.A title search has revealed that Defendant has an unsatisfied of-record mortgage encumbering the property described above, said Mortgage recorded in Wayne County Record Book 2996, Page 99. Defendant's Mortgage is attached as Exhibit B. 8.Defendant's Mortgage is dated December 22, 2005. 9.The amount of the Mortgage is listed as Two Hundred Twenty Thousand and 00/100 Dollars ($220,000.00). 10.The mortgage encumbers many lots in addition to the Lot owned by Plaintiff. 11.The property currently owned by Plaintiff was exposed to tax sale in 2018. 12.The owner at the time of sale was not the Mortgagor listed on the subject mortgage, and as such notice of the sale was not sent to Defendant. 13.Since purchase by Plaintiff, Defendant has not attempted to reclaim the property for non-payment of the loan, nor instituted any action to collect payment of same, and has not contacted Plaintiff for repayment of the debt or for payment of release of mortgage. 14.Upon information and belief, the Defendant corporation is no longer in business. 15.Defendant corporation filed for cancellation of their business, effective January 30, 2023, with the New Jersey Division of Revenue. See attached Exhibit "C" WHEREFORE, the Plaintiffs prays this Honorable Court to enter: (a) An Order barring forever the right of the Defendant and their successors, heirs and assigns from asserting any right, title or interest in and to premises; and (b) An Order decreeing Plaintiff Steven Proscia are the owners in fee simple free of any encumbrances of the Defendant of the premises herein described. BY: KYLE KRAJKOVICH, ESQ. I.D. #320170 Attorney for Plaintiff 2573 Route 6 Hawley, PA 18428 (570) 226-6229 October 9 2025 LSOM0384885