IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT,

IN AND FOR PALM BEACH COUNTY, FLORIDA

STARLIGHT DISTRIBUTION, INC.,

a Florida corporation, and SYED ALI

RAZA and IRAM HUSSAIN RAZA,

Plaintiffs,

v. Case No. 22-81091-CIV-SMITH

U.S. BANK, N.A., as Trustee for

Velocity Capital Loan Trust 2022-3

By its Registered Agent:

C T Corporation System

1200 South Pine Island Road

Plantation, FL 33324

Defendant.

_________________________________/

FIRST AMENDED COMPLAINT FOR DECLARATORY RELIEF AND FOR DAMAGES

COME NOW Plaintiffs Starlight Distribution, Inc., Syed Ali Raza (“Syed”) and Iram 

Hussain Raza (“Iram”), and file this Complaint for Declaratory Relief and for Damages, and 

state:

VENUE

1. This matter concerns real property located in Palm Beach County, Florida. The 

real property which is the subject of this suit is described as “Lot 26, Block G2, Oaks at Boca 

Raton Plat Eight, according to the map or plat thereof, as recorded in Plat Book 103, Page(s) 

115, of the Public Records of Palm Beach County, Florida” (the “Property”).

2. The actions undertaken by Defendant is damaging Plaintiffs who at all times 

pertinent resided and otherwise conducted business in Palm Beach County, Florida.

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3. Defendant is a foreign business but regularly does business in Palm Beach 

County, Florida.

GENERAL ALLEGATIONS

4. Plaintiffs Syed and Iram are the holders of legal title to the Property.

5. Prior to Plaintiffs owning said Property, the Property was owned by Starlight

Distribution, Inc. (“Starlight”), which is a Florida corporation in good standing whose sole 

officer is Iram Hussain Raza (“Iram”). See “Exhibit A.”

6. In January, 2022, Starlight inquired about refinancing the Property and was 

informed by Robert Houston (“Houston”), who held himself out as a mortgage broker, that 

Starlight would need a cosigner to obtain said refinancing.

7. Starlight cooperated with Houston, who is located in Tampa, Florida, for several 

months until Houston began to avoid responding to Starlight.

8. On May 9, 2022, a Commercial Mortgage, Security Agreement and Assignment 

of Leases and Rents encumbering the Property was recorded in the official records of Palm 

Beach County, Florida at Book 33538, Page 117 (hereinafter, the “Mortgage”). See “Exhibit B.”

9. The Mortgage was signed by someone purporting to be a director of Starlight, but 

who is unknown to Starlight, and purports to grant rights over the Property to Posh Lending, Inc. 

(“Posh”), a California corporation. Posh is Defendant’s predecessor-in-interest.

10. Despite numerous demands made by Starlight to Defendant’s servicer, Houston 

and Posh, Starlight has been unable to obtain any documents pertaining to a closing or which 

otherwise which resulted in the Mortgage. Starlight is, however, receiving a monthly mortgage 

payment invoice from Defendant’s servicer who named by Plaintiff as the original defendant.

11. The Mortgage was assigned to Defendant, which assignment was recorded at 

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Official Records Book 33752, Page 154 of the public records of Palm Beach County, Florida on 

August 2, 2022.

COUNT I – DECLARATORY RELIEF

12. Plaintiffs reincorporate the allegations contained in paragraphs 1 through 11, 

inclusive, as if presented within this count.

13. Starlight did not authorize Defendant to any predecessor-in-interest to enter into a 

mortgage encumbering the Property.

14. The unauthorized Mortgage is clouding Plaintiffs’ title to the Property.

15. As a result of this cloud on title to the Property, Syed and Iram are precluded from 

obtaining more favorable financing secured by the Property and continue to be damaged.

WHEREFORE, Plaintiffs seek declaratory relief establishing that the Mortgage is void ab 

initio.

DAMAGES

16. Plaintiffs reincorporate the allegations contained in paragraphs 1 through 11, 

inclusive, as if presented within this count.

17. At all times pertinent, Houston and Posh served as agents for Defendant or its 

predecessor in interest.

18. As the direct and proximate result of the recording of the unauthorized Mortgage 

against the Property, Plaintiffs are precluded from utilizing the Property’s equity to improve 

same.

19. In addition, the interest rate and resulting monthly payments on the unauthorized 

Mortgage loan are significantly higher than those that were discussed with Defendant’s agent.

20. As the direct and proximate result of Defendant’s actions, Plaintiffs have and are 

continuing to suffer damages.

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21. Plaintiffs have, as the direct and proximate result of Defendant’s actions, been 

required to obtain the services of undersigned counsel and to pay said counsel a reasonable fee 

for which Defendant should be held responsible.

WHEREFORE, Plaintiffs request judgment in their favor for damages for damages

sustained as the direct and proximate result of the recording of the unauthorized Mortgage.

S I S K I N D L E G A L , P L L C

Attorneys & Consultants

_______/s/ Jeffrey M. Siskind_______

Jeffrey M. Siskind, Esq. FBN 138746

1629 K Street, Ste. 300, NW Washington, DC 20006

113 N. Monroe Street, 1st Floor Tallassee, Florida 32301

3465 Santa Barbara Drive Wellington, Florida 33414

TELEPHONE (561) 791-9565

FACSIMILE (561) 791-9581

Email: jeffsiskind@msn.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served on 

September 10, 2022 upon the parties registered on CM/ECF and shall be duly served upon 

Defendant upon issuance of an Alias Summons, after which a Return of Service shall be filed.

_______/s/ Jeffrey M. Siskind_______

Jeffrey M. Siskind, Esq. FBN 138746

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EXHIBIT A 

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EXHIBIT B 

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