Bank of N.Y. Mellon v Edwards

Holding The plaintiff satisfied its prima facie burden of standing by annexing a note endorsed in blank to the complaint. The plaintiff also established compliance with RPAPL 1304 through an affidavit from a document verification specialist and attached USPS tracking records.

The court’s words

Plaintiff satisfied its prima facie burden of establishing its standing by demonstrating that a copy of the note endorsed in blank was annexed to the complaint

2026 NY Slip Op 05848, at the official text

Plaintiff further established that it complied with RPAPL 1304 by submitting the affidavit of Tricia Glodowski, a document verification specialist from NewRez LLC

2026 NY Slip Op 05848, at the official text

Collectively, plaintiff's evidence adequately established that plaintiff mailed the notices in compliance with RPAPL 1304

2026 NY Slip Op 05848, at the official text

Defendant does not explain why evidence of the chain of custody of the note was relevant, given that plaintiff had attached a copy of the note endorsed in blank to the complaint

2026 NY Slip Op 05848, at the official text