IMOGENE COLE and GEORGIA BROWN,

-against-

STEVEN J. BAUM, P.C.,

PRELIMINARY STATEMENT

I. Plaintiffs Imogene Cole and Georgia Brown bring this action on behalf of themselves and a class of similarly situated New York residents challenging the unfair and unconscionable debt collection and deceptive practices by defendant Steven J. Baum, P.C.(“Baum”) in residential foreclosure actions by grossly neglecting or willfully failing to file the specialized Request for Judicial Intervention required by the Uniform Rules for the New York State Trial Courts (“Uniform Rules”) § 202.12-a(b), 22 New York Code of Rules and Regulations § 202.12-a(b), which, in tum, deprives Plaintiffs and class members of their right to the statutorily mandated settlement conferences under New York Civil Practice Law and Rules (“CPLR”) Rule 3408 in foreclosure actions (the “Class”).

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