that the lender and mortgage broker conspired to obtain an inflated appraisal of thesubject premises and falsified his income, to induce him to enter into a mortgage loan beyondthat which he could afford.A residential foreclosure conference was held on March 8, 2011, but did not result in asettlement. By order of the same date, it was determined that the action could proceed bymotion.With respect to that branch of the motion by plaintiff for summary judgment as againstdefendant Platt, it is well established that the proponent of a summary judgment motion"must make a prima facie showing of entitlement to judgment as a matter of law, tenderingsufficient evidence to demonstrate the absence of any material issues of fact" (
Alvarez vProspect Hosp.
, 68 NY2d 320, 324 ). The failure to make such a prima facie showingrequires the denial of the motion regardless of the sufficiency of the opposing papers (
seeWinegrad v New York Univ. Med. Ctr.
, 64 NY2d 851 ). In support of its motion,plaintiff offers a copy of the pleadings, affidavits of service, an affirmation by its counsel, acopy of the subject mortgage, underlying note and allonge, assignments, and an affidavit of Paul Laird, a vice president of Vericrest Financial, Inc., the attorney in fact for plaintiff,attesting to defendant Platt's default under the mortgage and note.Plaintiff has failed to establish its prima facie entitlement to judgment as a matter of law.[*3]"CPLR 3212 (b) provides that a summary judgment motion shall be supported byaffidavit' of a person having knowledge of the facts' as well as other admissible evidence (
seeGTF Mktg. v Colonial Aluminum Sales
, 66 NY2d 965, 967 )" (
JMD Holding Corp. vCongress Fin. Corp.
, 4 NY3d 373, 384 ). The affidavit of Paul Laird is withoutevidentiary value insofar as the basis of his knowledge and representations regarding themortgage documents and defendant Platt's default in payment are not revealed or inferable(
see Zuckerman v City of New York
, 49 NY2d 557, 562—563 ). In addition, becausethe complaint is verified by counsel, who lacks personal knowledge of the facts, it also doesnot constitute competent evidence to stand in the place of a proper affidavit of merit (
see Alvarez v Prospect Hosp.
, 68 NY2d at 327 ). That branch of the motion by plaintiff forsummary judgment against defendant Platt is denied.With respect to that branch of plaintiff's motion to strike the affirmative defense assertedby defendant Platt based upon lack of standing,