State of New York County Court County of Erie KEYBANK NATIONAL ASSOCIATION, Plaintiff, Index No.2015/600022 Hon. Sheila A. DiTullio [ Deborah Ann Buezek, et.al JOHN DOES," AND "JANE DOES" said names being fictitious, parties intended being possible tenants or occupants of premises and corporations, other entities or persons who have, claim, or may claim, a lien against, or other interest in, the premises, Defendant’s Defendant, NOTION OF MOTION FOR JOINDER § CPLR 3211 DATE, TIME & PLACE June 28,2018, at 10:00 AM Hon. Sheila A. DiTullio Supreme Court Erie County County Court Judge 25 Delaware Avenue Part 17 - 3rd floor Buffalo New York 14202 RELIEF REQUESTED: To: Reversing Plaintiffs award of Summary Judgment in its entirety; Granting Defendants’ Motion for Dismissal of Plaintif?s Complaint; Staying any further action by the Plaintiff, Granting such other relief as the court may deem. just and proper.‘TYPE OF ACTION; ANSWERING PAPERS: Dated: May 30" 2018 Deed recorded in the Erie County Clerk's Office in Erie County New York in Book Type: D; Book 11317; Page 2562 owner Shane Christopher: Buezek with STATMENT OF LEGAL FACTS whether an effective judgment may be rendered in the absence of the person who is not joined. The lack of standing where the line of credit has been, sold as unsecured debt refers to any type of debt or general obligation that is not protected by a guarantor. Unsecured Debts With unsecured debts, lenders don’t have rights to any collateral for the debt, See William McCaffrey Affidavit with over (30) years of employment for federal insured institutions Sign August 6",2015 See Attachment (1) and Exhibits (A) — (E) Foreclosure Action filed by mistake Pursuant to CPLR 2214 (b), answering papers, if any, are to be served seven (7) days prior to the return date of this motion, By: QipncbO Buscaph Deborah Ann BuczekState of New York County Court County of Brie x KEYBANK NATIONAL ASSOCIATION, Plaintiff, Hon. Sheila A. DiTullio -vs- Index No.2015/600022 Deborah Ann Buczek, et.al. MOTION TO DISMIss JOHN DOES," AND "JANE DOES" said names being fictitious, parties intended being possible tenants or occupants of premises and corporations, other entities or persons who have, claim, or may claim, a lien against, or other interest in, the premises, Defendant’s