FILED: NASSAU COUNTY CLERK 06/12/ :54 PM INDEX NO /2015 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/12/2015

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1 FILED: NASSAU COUNTY CLERK 06/12/ :54 PM INDEX NO /2015 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/12/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU )( HENRY J. DIGIOVANNI, Index No.: -against- Plaintiff(s), Plaintiff(s) designates: Nassau County as the Place of Trial QUISQUEYA REYNOSO and FRANCIS DEVIZIA, Defendant(s) )( The basis of venue: Place of Plaintiffs Residence SUMMONS Residence Address: 2631 Cypress Avenue East Meadow, NY County ofnassau To the above named Defendant(s): YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance, on the Plaintiff and or Plaintiffs Attorney( s) within 20 days after the service of this summons, exclusive of the day of service (or within 3 0 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Jl...,,. t ~ b 100 Dated: East Meadow, New York ~ June 12, 2015 TO: Henry J. DiGiovanni, Prose Quisqueya Reynoso 410 Torry Avenue Bronx, NY and Francis DeVizia 26 Cedar Court West Hawley PA FILED WITH THE CLERK OF THE COURT- NASSAU COUNTY, ON-----

2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU )( HENRY J. DIGIOVANNI Index Number: ---- plaintiff, against, QUISQUEYA REYNOSO and FRANCIS DEVIZIA, VERIFIED COMPLAINT defendant( s ) )( Plaintiff, complaining ofthe defendants, allege as follows: 1. Plaintiff HENRY J. DIGIOVANNI brings this action to recover the losses suffered by plaintiff at the hands of defendant(s) QUISQUEYA REYNOSO and FRANCIS DEVIZIA. 2. That plaintiff HENRY J. DIGIOVANNI resides in the State of New York, County ofnassau (also referred to herein as "buyer". 3. That upon information and belief, defendant, QUISQUEYA REYNOSO (also referred to herein as "property owner and or seller") resides at 410 Torry A venue in the State of New York, County of Bronx and is in the business of real estate who derives her main source of income buying and selling real estate, which her ownership of 86 Windsor Road, Hawley P A is the subject ofthis action. 4. That upon information and belief, at all times hereinafter mentioned, defendant, QUISQUEYA REYNOSO, was and still is doing business in the State ofnew York. 5. That upon information and belief, at all times hereinafter mentioned, defendant, QUISQUEYA REYNOSO, was and still is transacting business in the State ofnew York.

3 6. That upon information and belief, at all times hereinafter mentioned, defendant, QUISQUEYA REYNOSO, derives substantial revenue from goods and services used or consumed or services rendered in the State ofnew York. 7. That upon information and belief, defendant, FRANCIS DEVIZIA (also referred to herein as "real estate agent or agent") resides at 26 Cedar Court West, Hawley in the State of Pennsylvania County of Wayne and is in the business of real estate who derives his main source of income representing property owners and is the real estate sales agent for the property owner QUISQUEYA REYNOSO for the property located at 86 Windsor Road, Hawley PA that is the subject of this action. 8. That upon information and belief, at all times hereinafter mentioned, defendant, FRANCIS DEVIZIA, was and still is doing business in the State ofnew York. 9. That upon information and belief, at all times hereinafter mentioned, defendant, FRANCIS DEVIZIA, was and still is transacting business in the State of New York. 10. That upon information and belief, at all times hereinafter mentioned, defendant, FRANCIS DEVIZIA, derives substantial revenue from goods and services used or consumed or services rendered in the State of New York. 11. That upon information and belief, at all times hereinafter mentioned, defendant FRANCIS DEVIZIA, is an employee of QUISQUEYA REYNOSO. 12. That upon information and belief, at all times hereinafter mentioned, defendant FRANCIS DEVIZIA, is a representative of QUISQUEYA REYNOSO. 13. That upon information and belief, at all times hereinafter mentioned, defendant FRANCIS DEVIZIA, is an agent ofquisqueya REYNOSO. 14. Plaintiffs allege that this Court has jurisdiction over all parties. 2

4 FACTUAL HISTORY 15. Plaintiff repeats and reiterates and realleges each and every allegation contained in those paragraphs of the complaint marked and designated as 1 through 14 inclusive with the same force and effect as stated fully herein. 16. The defendant FRANCIS DEVIZIA resident of Pennsylvania contacted plaintiff buyer a New York State resident and solicited the sale of real property located at 86 Windsor Road, Hawley P A as agent of defendant QUISQUEY A REYNOSO a real estate purchaser and re-seller and the deeded property owner of 86 Windsor Road, Hawley P A The defendant(s) were aware of plaintiffs desire to purchase property in the State of Pennsylvania and so solicited plaintiff in the State of New York fraudulently encouraging plaintiff to enter into an agreement to make monthly payments to QUISQUEYA REYNOSO'S Chase bank account domiciled in the State of New York. 18. That on September 5th, 2014 on behalf of defendant QUISQUEYA REYNOSO, FRANCIS DEVIZIA (frankdidd@hotmail.com) did solicit plaintiff HENRY J. DIGIOVANNI via plaintiffs account (joebayview@gmail.com) for the intention to sell QUISQUEY A REYNOSO'S property known as 86 Windsor Road, Hawley PA with clear title along with all of its contents, which parties discussed the terms of sale in subsequent telephone conversations. 19. The defendant(s) solicited plaintiff for the express purpose of entering into fraudulent agreement granting plaintiff the right to purchase, occupy, maintain and improve said property while plaintiff made short term scheduled payments, knowing full well that the defendant( s) sold the same property to an unknown party many months earlier. 3

5 20. That from September 27th, 2014 to date all other communications by and between the parties were conducted by cellular telephone voice conversations and or text messaging. 21. That on or about September 20th, 2014 defendant FRANCIS DEVIZIA made arrangements with plaintiff to show the subject property on October 11th, That on the morning of October 11th, 2014 plaintiff and his family drove to FRANCIS DEVIZIA residence located in the Woodledge Village Estates at 26 Cedar Court West, Hawley PA County of Wayne and subsequently drove to 86 Windsor Road, Hawley PA to inspect and take photographs of QUISQUEYA REYNOSO'S property all the while plaintiff being unaware that the defendant(s) previously sold the subject property to another party. 23. That on about October 20th, 2014 plaintiff, defendant(s) discussed options to purchase 86 Windsor Road outright for $6, and transfer of warranty deed to plaintiff name and or to the name of plaintiff and Ronald T. DiGiovanni ("also referred to as potential mortgagor"). 24. That on or about November 1st, 2014 plaintiff and defendant(s) discussed a final purchase price and method of warranty deed transference by the seller QUISQUEY A REYNOSO, as well Ronald T. DiGiovanni also discussed the same terms with QUISQUEY A REYNOSO. 25. That on November 9th, 2014 defendant FRANCIS DEVIZIA contacted plaintiff via text messaging to obtain the information required for the warranty deed, which plaintiff supplied via text message and defendant FRANCIS DEVIZIA acknowledged. 26. That on November 17th, 2014 defendant FRANCIS DEVIZIA dispatched a text massage to plaintiff advising that he had acquired a notarized copy of the warranty deed from 4

6 defendant QUISQUEYA REYNOSO naming plaintiff as purchaser and such instrument was in his possession and would be recorded with the Wayne County Clerk pending the final payment. 27. That on or around November 25th,2014 defendant FRANCIS DEVIZIA requested plaintiff complete the purchase of the subject property before the Christmas holiday, which plaintiff advised he had not yet received the results of title search prompting the defendant(s) to extend the closing upon plaintiff obtain clear title. 28. That on or about November 28th, 2014 plaintiff received a call from the title company advising that plaintiff that the property was conveyed to Wayne County via a tax lien without first notifying all necessary parties to the defaulted now deceased property owner, which meant that the property was sold to defendant QUISQUEY A REYNOSO at auction without first notifying all necessary parties to the defaulted now deceased property owner. 29. That on or about the week of December 1st, 2014 plaintiff QUISQUEYA REYNOSO was contacted by Ronald T. DiGiovanni as the plaintiffs prospective mortgagor regarding the sale of the subject property purported to be of clear title which, QUISQUEYA REYNOSO'S subsequent inability to guarantee clear title caused Mr. DiGiovanni to withdraw his offer to become the mortgagor. 30. That as a result of defendant QUISQUEY A REYNOSO'S inability to guarantee clear title as advertised by her agent I broker FRANCIS DEVIZIA, defendant FRANCIS DEVIZIA dispatched a text message to the plaintiff pursuant to an agreement with QUISQUEYA REYNOSO offering plaintiff a payment option for the purchase of the subject property AS IS, which terms included a down payment of $1, with a monthly payments for a period of six months and defendant( s) granting plaintiff immediate access to the property to begin cleanout and repairs at the plaintiffs sole option. 5

7 31. On or about December 20th, 2014 plaintiff contacted defendant FRANCIS DEVIZIA and agreed to the defendant(s) offer to purchase the property and its contents AS IS, whereby the plaintiff would undertake the risk of obtaining clear title for the outstanding matter of Wayne County's inability to properly serve notice on a relative of the tax defaulted property owner. Plaintiff undertook the AS IS risk in consideration of the defendant(s) offer to undertake the land sale agreement as described herein and plaintiff subsequently ratified the agreement with a down payment 32. That the defendant(s) QUISQUEYA REYNOSO a/k/a PROPERTY OWNER and FRANCIS DEVIZIA a/k/a REAL ESTATE BROKER agreed on a price for the installment sale of the property in the amount of $7, with a $1, deposit and the remainder to be paid on or before six months from the date of the first deposit to commence on or about January That after the plaintiff and defendant(s) agreed to the finance terms, the plaintiff and defendant FRANCIS DEVIZIA spoke via phone and verified that the first payment be on or about January loth, 2015 at which time FRANCIS DEVIZIA advised plaintiff that payments for the purchase of 86 Windsor Road, Hawley P A could be made to FRANCIS DEVIZIA as agent for QUISQUEYA REYNOSO and deposited to his PNC Bank account or plaintiff could make payments directly to QUISQUEY A REYNOSO'S Chase Bank account via wire transfer. 34. That after careful consideration plaintiff advised the defendant(s) that he elected to ratify the agreement with the seller by depositing all sums agreed to for the purchase of 86 Windsor Road, Hawley PA into the Chase bank account of the deeded property owner QUISQUEYA REYNOSO. 6

8 35. That defendant FRANCIS DEVIZIA dispatched a text message to plaintiff containing QUISQUEYA REYNOSO'S Chase Bank account information. PLAINTIFF'S PAYMENT HISTORY 36. Plaintiff repeats and reiterates and realleges each and every allegation contained in those paragraphs of the complaint marked and designated as 1 through 35 inclusive with the same force and effect as stated fully herein. 37. That on 01110/15 defendant FRANCIS DEVIZIA confirmed via text message receipt of plaintiffs initial payment of $1, into defendant QUISQUEYA REYNOSO'S Chase account. 38. That on defendant FRANCIS DEVIZIA confirmed via text message receipt of plaintiffs second payment of $ into defendant QUISQUEY A REYNOSO'S Chase account. 39. That on 01/30/15 defendant FRANCIS DEVIZIA confirmed via text message receipt of plaintiffs third payment of $ into defendant QUISQUEY A REYNOSO'S Chase account. 40. That on 02114/15 defendant FRANCIS DEVIZIA confirmed via text message receipt of plaintiffs forth payment of $ into defendant QUISQUEY A REYNOSO'S Chase account. 41. That on 02/19/15 defendant FRANCIS DEVIZIA confirmed via text message receipt of plaintiffs fifth payment of $ into defendant QUISQUEYA REYNOSO'S Chase account. 42. That on 02119/15 defendant FRANCIS DEVIZIA confirmed via text message a recapitulation of all payments into defendant QUISQUEYA REYNOSO'S Chase account in the 7

9 amount of $3, on account of all dues and debts for the purchase of the subject property. FRANCIS DEVIZIA via text message confirmed a balance for the purchase of the subject property in the amount of $3, That on 03/02115 defendant FRANCIS DEVIZIA confirmed vm phone Conversation receipt of plaintiffs sixth payment of $ into defendant QUISQUEYA REYNOSO'S Chase account. 44. That on defendant FRANCIS DEVIZIA confirmed via text message receipt of plaintiffs seventh payment of $ into defendant QUISQUEY A REYNOSO'S Chase account. 45. That on 04/06/15 defendant FRANCIS DEVIZIA confirmed v1a phone conversation receipt of plaintiffs eighth payment of $ into defendant QUISQUEYA REYNOSO'S Chase account. 46. That on or about April loth, 2015 with plans to take possession of the subject property on or before April 30th, 2015 plaintiff contacted the local electric utility to inquire about electrical services and was advised that electric services were recently activated at 86 Windsor Road. 47. That plaintiff contacted FRANCIS DEVIZIA to advise the defendant(s) that someone activated the electrical service at the subject property. Although FRANCIS DEVIZIA resides minutes from the property he claimed to have no knowledge of when, why or who activated the electric services. 48. That on April 13th, 2015 plaintiff arrived at 86 Windsor Road, Hawley P A and discovered that someone had been working on and residing at the property. 8

10 49. That when plaintiff went to the residence of defendant FRANCIS DEVIZIA he was advised that although he accepted a $ deposit from another individual months prior to plaintiffs involvement that party abandon the purchase and was (according to defendant FRANCIS DEVIZIA) illegally trespassing renovating and harvesting trees without defendant(s) authorization. 50. That defendant(s) refused to remove the trespasser from the property now claiming that the alleged trespasser had previously purchased multiple properties from the defendant(s) and the defendant(s) were unwilling to remove the alleged trespasser as doing so may jeopardize the defendant(s) future interests with said party and payments on other properties with that party. 51. That in an effort to cure the problem of ownership defendant(s) suggested listing the subject property for sale on ebay in order to allow the plaintiff and trespasser to win the property in accordance with the highest final bid, which plaintiff believed to be a scheme frequently practiced by the defendant(s) in order to shake down buyers for additional money. 52. That defendant(s) admitted that breaching the terms of agreement with plaintiff was a business decision that was driven by the prospect of the defendant(s) making more money than they previously agreed to. 53. That defendant(s) made vague offers to sell plaintiff a different property, which plaintiff rejected in favor of completing the sale of the now damaged property for the sum of the $5, the plaintiff already paid to the defendant(s), however to date plaintiff has not heard from either defendant although plaintiff demanded a full refund with damages or the property. 54. That defendant(s) have not responded to plaintiff(s) demands for a refund and or to remove the trespasser from the property. 9

11 55. That defendant(s) voice mail system (Phone Number ) is too full to take messages and defendant(s) are no longer answering or responding to plaintiff(s) phone calls, text messages or s. 56. That pursuant to the agreement by and between the parties, defendant(s) breached the terms of the agreement when defendant(s) sold the subject property to more than one party. 57. That defendant(s) continue to breach the terms of the agreement with the plaintiff by failing to take the necessary legal action to evict the alleged trespassers hereinafter referred to as JOHN DOE and JANE DOE. 58. That plaintiff paid defendant(s) pursuant to an agreement and defendant(s) accepted scheduled monthly payments for the sale of the subject property. 59. That at no time before or after the parties entered into the agreement did the defendant(s) advise the plaintiff that the subject property was already in contract. 60. That the defendant(s) willfully and with intent entered into multiple contracts for the sale of 86 Windsor Road, Hawley PA18428 for the purpose of extorting a sale price beyond the agreed amount in a scheme to become unjustly enriched. 61. Defendant(s) are fully familiar with the purchase and sale of real estate as their primary source of income and are aware of the laws prohibiting the sale of the same property to more than one party at the same time. 62. Plaintiff contacted both New York and Pennsylvania real estate licensing bureaus and discovered that neither defendant has a license to broker and or sell real property for others pursuant to those state statutes. 63. That the real estate licensing division ofboth New York and Pennsylvania encouraged plaintiff to file a complaint against any individual selling the same property to more 10

12 than one person with their agency and further encouraged plaintiff to contact the district attorney and states attorney general in those states, which the plaintiff is willing to do. 64. Plaintiff contacted the district attorney and states attorney general in both New York and Pennsylvania who encouraged plaintiffto file a complaint with their office and the Pensylvennia Real Estate Commission for investigation into the actions of individuals selling the same property to more than one person with the intent to extort a higher price, and further encouraged the plaintiff to file a complaint to the Pennsylvania State Police which the plaintiff is willing to do. 65. Plaintiff contacted the Pennsylvania State Police who encouraged plaintiffto file a complaint for investigation into the actions of individuals selling the same property to more than one person with the intent to extort a higher price, which the plaintiff is willing to do. 66. Defendant(s) intentionally entered into contract with multiple parties in order to become unjustly enriched. 67. Defendant(s) theory of listing the subject property on ebay and let the highest bidder win is extortionary and an attempt to force the plaintiff to abandon the binding agreement between the parties and pay an amount higher than contracted for. 68. To date no money has been returned. 69. To date defendant( s) failed to honor their agreement. 70. During the investigation of the defendant(s) plaintiff discovered that defendant FRANCIS DEVIZIA regularly bids on tax lien properties in the State of Pennsylvania and has a criminal record for breaking and entering into a Pennsylvania county property. 11

13 AS AND FOR A FIRST CAUSE OF ACTION (Sounding In Breach Of Contract) 71. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1-69 with the same force and effect as though more thoroughly set forth herein. 72. That QUISQUEYA REYNOSO and FRANCIS DEVIZIA intentionally breached the contract on January loth, 2015 when they entered into a binding agreement with the plaintiff for the sale of 86 Windsor Road, Hawley P A Wherefore, the Plaintiff respectfully requests the Court to enter judgment for QUISQUEY A REYNOSO and FRANCIS DEVIZIA breach of the contract for the sale of the subject property to their contractual obligations in the amount of $5,400.00, with interest from the date of the breach, reasonable attorney fees and costs of suit. AS AND FOR A SECOND CAUSE OF ACTION (Fraud In The Inducement) 74. Plaintiff repeats andre-alleges each and every allegation contained in paragraphs 1-73 with the same force and effect as though more thoroughly set forth herein. 75. That FRANCIS DEVIZIA agreed to sell 86 Windsor Road, Hawley PA to plaintiff pursuant to representations he made as the alleged real estate agent of QUISQUEY A REYNOSO. 76. That QUISQUEYA REYNOSO and FRANCIS DEVIZIA knew that such representations were false and made such representations for HENRY J. DIGIOVANNI to rely upon in entering into the contract and accepting payments for the purchase of 86 Windsor Road, Hawley PA to plaintiffs detriment. 77. That HENRY J. DIGIOVANNI relied on QUISQUEYA REYNOSO and FRANCIS DEVIZIA representations that the subject property was free and clear of all 12

14 encumbrances and not in contract with any other party prior to HENRY J. DIGIOVANNI wiring the timely scheduled sums of money into the deeded owners bank account thereby ratifying the agreement for the purchase of 86 Windsor Road, Hawley PA That HENRY J. DIGIOVANNI would not have entered into an agreement/contract to purchase 86 Windsor Road, Hawley P A had he known that QUISQUEYA REYNOSO and FRANCIS DEVIZIA did not intend to produce and provide a warrantee deed to the subject property for the $7, amount agreed upon. 79. That HENRY J. DIGIOVANNI suffered damages due to his detrimental reliance on QUISQUEYA REYNOSO and FRANCIS DEVIZIA's representations to provide a warranty deed to the subject property for the amount of$7, That defendants willfully entered into a fraudulent agreement knowing full well that the plaintiff was required to remove his personal property from his primary residence on or before April 30th, 2015 and that property was to be moved to the subject property. 81. That the defendant(s) scheme allowed a third party to occupy the subject property just before the deadline and harvest tens of thousands of dollars in lumber also scheming to remove appliances and tools from the property that were in contract for sale to the plaintiff. 82. Defendant(s) refused to contact the police at the plaintiffs urging, rather the defendant(s) employed their scheme to induce the plaintiff to enter into a last minute bidding war with the alleged trespasser knowing full well that the plaintiff was under duress to remove his personal property from his present residence by April 30th, That at the time of defendant(s) breach plaintiff was on schedule for the closing and to move his belongings into the subject property until he discovered the defendant(s) scheme. 13

15 84. That in order to comply with plaintiff(s) obligation to remove his personal property from his present residence plaintiff was required to transport his property to a secured warehouse at a cost to the plaintiff of$3,650 and counting. 85. Wherefore, plaintiff HENRY J. DIGIOVANNI demands judgment against defendant(s) QUISQUEYA REYNOSO and FRANCIS DEVIZIA in the amount of $5,400.00, contractual damages, $3, consequential and punitive damages and reasonable legal fees and cost of suit, together with any other and further relief this Court seems just and proper. AS AND FOR A THIRD CAUSE OF ACTION (Conversion) 86. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1-79 with the same force and effect as though more thoroughly set forth herein. 87. That on or about April of 2015 HENRY J. DIGIOVANNI demanded QUISQUEYA REYNOSO and FRANCIS DEVIZIA return the $5, in payments to HENRY J. DIGIOVANNI or to warranty deed the now damaged property to HENRY J. DIGIOVANNI, which defendant(s) refused. 88. That QUISQUEYA REYNOSO and FRANCIS DEVIZIA did not return the $5, deposit to HENRY J. DIGIOVANNI. 89. That by failing to return the $5, deposit and or warranty deed the property to HENRY J. DIGIOVANNI, QUISQUEYA REYNOSO and FRANCIS DEVIZIA defendant(s) did convert $5, Wherefore, the Plaintiff respectfully requests the Court to enter judgment in the amount of $5, as against QUISQUEY A REYNOSO and FRANCIS DEVIZIA, with interest thereon from the date of conversion, consequential and punitive damages, and reasonable legal fees and cost of suit. 14

16 AS AND FOR A FORTH CAUSE OF ACTION (Account Stated) 91. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1-89 with the same force and effect as though more thoroughly set forth herein. 92. That on or about April of 2015, QUISQUEYA REYNOSO and FRANCIS DEVIZIA, acknowledged receipt of plaintiffs $5, sum but refused to return plaintiffs money claiming such sums would be applied to another property if and when defendant(s) obtained another property at an upcoming tax auction. 93. That QUISQUEYA REYNOSO and FRANCIS DEVIZIA did not return the $5, to HENRY J. DIGIOVANNI. 94. Wherefore, the Plaintiff respectfully requests the Court to enter judgment as against QUISQUEYA REYNOSO and FRANCIS DEVIZIA in the amount of $5, on an account stated theory, with interest thereon from the inception date of the account stated, consequential and WHEREFORE, the Plaintiff demands judgment against the Defendant(s) as follows: (1) For the First Cause of Action (Sounding In Breach Of Contract) Plaintiff demands judgment in the amount of $5,400.00, as against QUISQUEYA REYNOSO and FRANCIS DEVIZIA., with interest from the date of the breach, reasonable legal fees and costs of suit; (2) For the Second Cause of Action (Fraud In The Inducement) Plaintiff demands judgment in the amount of $5, as against QUISQUEYA REYNOSO and FRANCIS DEVIZIA, and consequential damages of $3, with interest thereon, punitive damages and reasonable legal fees and cost of suit; (3) For the Third Cause of Action (Conversion) Plaintiff demands judgment in the amount of $5,400.00, as against QUISQUEYA REYNOSO and FRANCIS DEVIZIA, with 15

17 interest from the date of conversion, consequential and punitive damages, and reasonable legal fees and cost of suit; (4) For the Fourth Cause of Action (Account Stated) Plaintiff demands judgment in the amount of $5,400.00, as against QUISQUEYA REYNOSO and FRANCIS DEVIZIA, on an account stated theory, with interest thereon from the date of the inception of the account stated, consequential and punitive damages, and reasonable legal fees and cost of suit. (5) Costs and disbursements of this action, with reasonable legal fees; and ( 6) Such other and further relief as to this Court seems just, proper and equitable Dated: East Meadow, New York June 12th, 2015 Henry J. DiGiovani, Prose 2631 Cypress A venue East Meadow, New York To: Quisqueya Reynoso 410 Torry Avenue Bronx, NY and Francis De Vizia 26 Cedar Court West Hawley PA

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