REQUEST FOR LEAVE TO AMEND COMPLAINT. accordance with the amended complaint filed herewith.

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1 DOCKET NUMBER FBT-CV S SUPERIOR COURT WATER POLLUTION CONTROL AUTHORITY FOR THE CITY OF BRIDGEPORT J.D. OF FAIRFIELD VS. AT BRIDGEPORT DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R8 MARCH 27, 2014 REQUEST FOR LEAVE TO AMEND COMPLAINT The Plaintiff in the above entitled matter hereby requests leave to amend its complaint in accordance with the amended complaint filed herewith. THE PLAINTIFF, By /s/ Juda J. Epstein Its Attorney 3543 Main Street, Second Floor Telephone (203) Juris Number

2 CERTIFICATION This is to certify that a copy of the foregoing motion has been mailed this day, postage prepaid to all counsel and pro se parties of record Deutsche Bank National Trust Company, as Trustee for Ameriquest Mortgage Asset-Backed Pass-Through Certificates, Series 2004-R8 60 Wall Street New York, NY /s/ Juda J. Epstein Commissioner of the Superior Court

3 DOCKET NUMBER FBT-CV S RETURN DATE FEBRUARY 4, 2014 SUPERIOR COURT J.D. OF FAIRFIELD WATER POLLUTION CONTROL AUTHORITY FOR THE CITY OF BRIDGEPORT AT BRIDGEPORT VS. DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R8 MARCH 27, 2014 AMENDED COMPLAINT 1. The City of Bridgeport, acting by and through the Plaintiff, Water Pollution Control Authority of The City of Bridgeport, pursuant to Connecticut General Statutes Section et seq brings this action. 2. The Plaintiff provided a connection with, and use of the municipal sewerage system to the premises described as follows All that certain place or parcel of land together with all buildings and improvements thereon, situated the City Bridgeport, County of Fairfield and State of Connecticut, being more particularly bounded and described as follows NORTHERLY EASTERLY SOUTHERLY WESTERLY By land now or formerly of Harold B. Roberts in part, and in part by land now or formerly of Frank J. Ward, in all, feet, more or less; By Iranistan Avenue, 53 feet, more or less; By land now or formerly of Delia Poissant, et al, 100 feet, more or less; By land now or formerly of Lockwood, et al, 41.6 feet. The North line meets the Easterly line of Iranistan Avenue at a point which is 110 feet south from the intersection of Iranistan and North Avenues. Otherwise known as 1689 Iranistan Avenue, Bridgeport, CT.

4 3. Use charges were assessed upon said property and thereafter became due and payable, and Certificates of Continuance of such liens were recorded in the Land Records of the City of Bridgeport upon said property. The Plaintiff is seeking to foreclose all amounts owed and any and all inchoate liens and/or recorded liens inclusive of but not limited to those recorded, as follows DATE RECORDED AMOUNT VOL./PAGE $ / $ / $ / $ / $ / $ / $ / $ / All of the liens recorded are filed together with lien fees and charges thereon. 5. No part of the amounts due under any of these liens have been paid. 6. The Defendant, Deutsche Bank National Trust Company, as Trustee for Ameriquest Mortgage Asset-Backed Pass-Through Certificates, Series 2004-R8, now owns and is in possession of the property. 7. The following encumbrances are prior in right to the Plaintiff's liens and are not affected by this action a. Real Estate Tax Liens, recorded on the Bridgeport Land Records as follows LIST YR. DATE AMOUNT VOL./PAGE ASSIGNEE DATE OF ASG. VOL./ PAGE /22/13 $2, /283 Benchmark Municipal Tax Services, LTD. 8/30/ / Demand has been made upon the Defendant for the amount due and owing, but the Defendant has refused or neglected to make payments and there are no set-offs or counterclaims recognizable under this action.

5 WHEREFORE THE PLAINTIFF CLAIMS 1. Strict Foreclosure of the lien; 2. Immediate possession of the encumbered premises; 3. A deficiency judgment. No deficiency will be sought against any person whose obligation under the subject promissory note has been heretofore or hereafter discharged in bankruptcy; 4. Attorney s Fees and Costs; 5. Receivership of rents; 6. Such other relief and further equitable relief as may be required. Dated at Bridgeport, Connecticut this 27 th day of March THE PLAINTIFF WATER POLLUTION CONTROL AUTHORITY FOR THE CITY OF BRIDGEPORT By Juda J. Epstein, Esq. Law Office of Juda J. Epstein 3543 Main Street, 2nd Floor Telephone (203) Juris Number

6 DOCKET NUMBER FBT-CV S RETURN DATE FEBRUARY 4, 2014 SUPERIOR COURT J.D. OF FAIRFIELD WATER POLLUTION CONTROL AUTHORITY FOR THE CITY OF BRIDGEPORT AT BRIDGEPORT VS. DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R8 MARCH 27, 2014 STATEMENT OF AMOUNT IN DEMAND The amount, legal interest or property in demand is in excess of $15,000.00, exclusive of interest and costs. THE PLAINTIFF WATER POLLUTION CONTROL AUTHORITY FOR THE CITY OF BRIDGEPORT By Juda J. Epstein, Esq. Law Office of Juda J. Epstein 3543 Main Street, 2nd Floor Telephone (203) Juris Number 43029

7 DOCKET NUMBER FBT-CV S RETURN DATE FEBRUARY 4, 2014 SUPERIOR COURT J.D. OF FAIRFIELD WATER POLLUTION CONTROL AUTHORITY FOR THE CITY OF BRIDGEPORT AT BRIDGEPORT VS. DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R8 MARCH 27, 2014 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICE ACT, (THE ACT) 15 U.S.C. SECTION 1601 AS AMENDED Pursuant to 15 U.S.C. 1692e(11), this is to advise you that 1. The amount of debt you owe the Plaintiff is set forth in the foregoing complaint. 2. Unless you, within thirty (30) days after receipt of this notice, dispute the validity of the debt or any portion thereof, the debt will be assumed to be valid. 3. If you notify counsel to the Plaintiff within thirty (30) days of the receipt of this notice that the debt or any portion thereof is disputed, verification of the debt will be obtained and a copy of such verification will be mailed to you. 4. Upon your written request within the thirty (30) day period, counsel to the Plaintiff will provide you with the name of the original creditor, if different from the current creditor. 5. Counsel to the Plaintiff is attempting to collect a debt and any information obtained from you will be used for that purpose. THE PLAINTIFF WATER POLLUTION CONTROL AUTHORITY FOR THE CITY OF BRIDGEPORT By Juda J. Epstein, Esq. Law Office of Juda J. Epstein 3543 Main Street, 2nd Floor Telephone (203) Juris Number