GREATER ATLANTIC LEGAL SERVICES, INC.

Transcription

1 GREATER ATLANTIC LEGAL SERVICES, INC. CHANCERY ABSTRACT REVERSE MORTGAGE SOLUTIONS, INC. vs. Plaintiff, SONIA PARRA-APEL, Individually and as Executrix of the Estate of Encarnacion Parra; MERCEDES PARRA; ALFREDO PARRA; BRANDON PARRA; THE STATE OF NEW JERSEY; UNITED STATES OF AMERICA: KIMBERLY ANN PARRA aka Kim Parra, Defendants, SUPERIOR COURT OF NEW JERSEY UNION COUNTY DOCKET NO GREATER ATLANTIC LEGAL SERVICES, INC. hereby certifies to DATA TRACE AND BRIGHTLINE TITLE that it has reviewed the proceedings currently on file in the Superior Court Clerk s office for the above entitled action and reports the same regular as to form, except as hereinafter noted. GREATER ATLANTIC LEGAL SERVICES, INC. TITLE OFFICER YOUR REFERENCE # BRIGHTLINEBNJ

2 Complaint to Foreclose Filed November 23, 2009 Fein, Such, Kahn & Shepard, P.C., Attorneys for Plaintiff Summons dated December 13, 2009 (See return(s) and/or acknowledgment(s) of service Sonia Parra-Apel as Executrix of the Estate of Encarnacion Parra, Sonia Parra-Apel, Brandon Parra, Alfredo Parra and United States of America annexed hereto.) Certification of Inquiry and Publication (as to Mercedes Parra) RECEIVED August 30, 2010 (See copy annexed hereto.) Affidavit of Publication annexed thereto sets forth on January 14, 2010, a Notice to Absent Defendants directed to Mercedes Parra was published in the Union County Local Source. NOTE: CONSIDERATION SHOULD BE GIVEN TO THE ADEQUACY OF THE INQUIRY AS TO MERCEDES PARRA. Notice to State RECEIVED August 30, 2010 Service of the Notice to State and a copy of the Complaint is acknowledged for the State of New Jersey on December 16, Anne Milgram Attorney General of the State of New Jersey by: Annette Smallacombe. Certification of Mailing Summons and Complaint to Attorney General of The United States of America RECEIVED August 30,

3 On February 24, 2010, a copy of the Summons and Complaint was mailed via certified mail to United States of America C/O United States Attorney General, U.S. Department of Justice, Washington, DC A copy of the 60 day Summons and a signed return receipt directed to the aforesaid defendant indicating delivery on March 5, 2010 annexed thereto. Notice of Motion for Entry of Default Filed September 16, 2010 Notice directed to Sonia Parra-Apel as Executrix of the Estate of Encarnacion Parra at 1241 Wilkinson Dr., Toms River, NJ 08755, Brandon Parra at 429 Myrtle Avenue, Roselle Park, NJ 07204, Alfredo Parra at 429 Myrtle Avenue, Roselle Park, NJ 07204, Mercedes Parra at 65 Elmwood Ln, Union, NJ 07083, The State of New Jersey Justice Hughes Complex at 25 Market Street, P.O. Box 080, Trenton, NJ and United States of America at 970 Broad Street, Newark NJ Certification of Service of Notice RECEIVED September 16, 2010 On September 8, 2010, a copy of the Notice of Motion for Entry of Default was sent via certified and regular mail to Sonia Parra-Apel as Executrix of the Estate of Encarnacion Parra at 1241 Wilkinson Dr., Toms River, NJ 08755, Brandon Parra at 429 Myrtle Avenue, Roselle Park, NJ 07204, Alfredo Parra at 429 Myrtle Avenue, Roselle Park, NJ 07204, Mercedes Parra at 65 Elmwood Ln, Union, NJ 07083, The State of New Jersey Justice Hughes Complex at 25 Market Street, P.O. Box 080, Trenton, NJ and United States of America at 970 Broad Street, Newark NJ Certification in Support of Order Permitting Entry of Default RECEIVED September 16,

4 Request and Certification/Affidavit of Default as to United States of America Filed September 17, 2010 Default Filed September 17, 2010 Objection to Motion for Entry of Default Filed September 17, 2010 Mercedes Parra, Pro Se Order for Entry of Default Filed August 2, 2011 IT is on this 2nd day of August 20 11, ORDERED that default is hereby entered against the defendants, Sonia Parra-Apel, Individually and as Executrix of the Estate of Encarnacion Para, Brandon Parra, Alfredo Parra, Mercedes Parra, The State of New Jersey, United States of America Foreclosure Dismissal Notice (Lack of Prosecution) Filed August 2, 2013 Amended Complaint to Foreclose Filed August 30, 2013 Fein, Such, Kahn & Shepard, P.C., Attorneys for Plaintiff 3

5 CONTESTING Answer entered for Mercedes Parra Filed October 3, 2013 Mercedes Parra, Pro Se Second Amended Complaint to Foreclose Filed October 22, 2013 Fein, Such, Kahn & Shepard, P.C., Attorneys for Plaintiff FIRST COUNT Second Amended Complaint filed to foreclose mortgage made and executed by Encarnacion Parra by Sonia Parra-Apel, her Attorney-in-Fact to BNY Mortgage Company, LLC to secure the sum of $421, Obligation and mortgage dated July 25, The mortgage was recorded in Union County on October 2, 2003 in Book 10342, Page 524, et seq. THIS IS A NON PURCHASE MONEY MORTGAGE. A COMPLETE COPY OF THE SECOND AMENDED COMPLAINT WITH PROPERTY DESCRIPTION ATTACHED IS ANNEXED HERETO. By virtue of assignment(s) more particularly set forth in the annexed copy of the Second Amended Complaint, the mortgage was assigned to the Plaintiff. Upon information and belief, Encarnacion Parra, original mortgagor and owner of 65 Elmwood Avenue, Union, NJ, 07083, passed away on 10/28/07. At the time of her death, she was a resident of 65 Elmwood Avenue, County of Union, State of New Jersey. Upon information and belief, she was not married at the time of her death. Upon information and belief, an application to probate the Last Will and Testament of Encarnacion Parra, was filed in the Union County 4

6 Surrogate's records, on December 17, 2007, under Docket number , by Sonia Parra-Apel. Pursuant to the Last Will an Testament of Encarnacion Parra, Sonia Parra-Apel, is made a party defendant as Executrix of the Estate and for any right, title and interest in the subject property of liability on the note. Mercedes Parra; Alfredo Parra; Brandon Parra; The State of New Jersey; United States of America: Kimberly Ann Parra aka Kim Parra is/are made defendant(s) for reasons more particularly set forth in the annexed copy of the Second Amended Complaint. By virtue of a default in accordance with the terms of the mortgage, plaintiff has elected to call the whole of the principal sum due. The Notice of Intention was mailed to the debtors in compliance with the Fair Foreclosure Act. WHEREFORE, Plaintiff demands judgment: Fixing the amount due on the mortgage; Barring and foreclosing all of the defendants of all equity or redemption in and to the aforesaid lands; Directing that plaintiff be paid the amount due to plaintiff as provided in the mortgage together with interest and costs; Adjudging that the lands described above be sold according to law to satisfy the amount due to plaintiff; Such other and further relief as may be set forth in the demand for judgment included on the annexed copy of the Complaint. SECOND COUNT Plaintiff is entitled to possession of the mortgaged premises. WHEREFORE, Plaintiff demands judgment against said defendants for possession of the mortgaged premises and for any other relief that may be set forth in the demand for judgment on the copy of the Complaint annexed hereto. 5

7 By: The Second Amended Complaint is signed, FEIN SUCH KAHN AND SHEPARD, PC Attorneys for Plaintiff Nicholas J. Canova Summons dated October 31, 2013 (See return(s) and/or acknowledgment(s) of service for Sonia Parra-Apel Individually and as Executrix of the Estate of Encarnacion Parra, Alfredo Parra, United States of America, annexed hereto.) Adjournment Request RECEIVED November 1, 2013 Mercedes Parra, Pro Se Case Management Order Filed November 13, 2013 Certification of Inquiry and Publication (as to Mercedes Parra and Brandon Parra) RECEIVED February 26, 2014 (See copy annexed hereto.) Affidavit of Publication annexed thereto sets forth on November 21, 2013, a Notice to Absent Defendants directed to Mercedes Parra and Brandon Parra was published in the Union County Local Source. NOTE: CONSIDERATION SHOULD BE GIVEN TO THE ADEQUACY OF THE INQUIRY AS TO MERCEDES PARRA AND BRANDON PARRA. 6

8 Notice to State RECEIVED February 26, 2014 Service of the Notice to State and a copy of the Second Amended Complaint is acknowledged for the State of New Jersey on November 6, John J. Hoffman, Acting Attorney General of the State of New Jersey by: Annette Smallacombe. Certification of Mailing Summons and Second Amended Complaint to Attorney General of The United States of America RECEIVED February 26, 2014 On October 31, 2013, a copy of the Summons and Second Amended Complaint was mailed via certified mail to United States of America C/O United States Attorney General, U.S. Department of Justice, Washington, DC A copy of the 60 day Summons and a signed return receipt directed to the aforesaid defendant indicating delivery on November 5, 2013 annexed thereto. Plaintiff's Pre-Trial Memorandum Filed March 20, 2014 Order Case Management Conference Filed March 21, 2014 Notice of Motion for Summary Judgment RECEIVED April 22, 2014 CLERK'S NOTATION: RECEIVED BUT NOT FILED! PROOF OF MAILING IS NOT SIGNED. 7

9 Proof of Mailing RECEIVED April 22, 2014 Certification of Michael S. Hanusek, Attorney for Plaintiff RECEIVED April 22, 2014 Brief in Support of Summary Judgment Motion on Behalf of Plaintiff RECEIVED April 22, 2014 Statement of Material Facts RECEIVED April 22, 2014 Certification in Support of Motion for Summary Judgment RECEIVED April 22, 2014 Objection/Motion for Dismissal of Case RECEIVED June 16, 2014 Mercedes Parra, Pro Se CLERK'S NOTATION: RECEIVED BUT NOT FILED! MISSING $30.00 FILING FEE FOR MOTION. Notice of Motion for Summary Judgment Filed June 20, 2014 Notice directed to Mercedes Parra at 65 Elmwood Avenue, Union, NJ 07083, Pro 8

10 Se Defendant. Motion Returnable July 25, Proof of Mailing RECEIVED June 19, 2014 On June 19, 2014, a copy of the Notice of Motion, Statement of Material Facts, Certification in Support of Motion for Summary Judgment, Proposed Order, Brief in Support of Summary Judgment Motion on Behalf of Plaintiff and Certification of Counsel was sent via certified and regular mail to Mercedes Parra at 65 Elmwood Avenue, Union, NJ 07083, Pro Se Defendant. Certification in Support of Motion for Summary Judgment RECEIVED June 19, 2014 Statement of Material Facts RECEIVED June 19, 2014 Brief in Support of Summary Judgment Motion on Behalf of Plaintiff RECEIVED June 19, 2014 Certification of Joshua B. Sears, Attorney for Plaintiff RECEIVED June 19,

11 Notice of Motion to Dismiss Complaint Filed July 24, 2014 Mercedes Parra, Pro Se Certification in Support of Motion RECEIVED July 24, 2014 Mercedes Parra, Pro Se Plaintiff's Reply Memorandum in Support of Motion for Summary Judgment & in Opposition to Defendant's Cross-Motion to Dismiss Filed August 19, 2014 Order for Summary Judgment Filed September 19, 2014 (See copy annexed hereto.) NOTE: WE FAIL TO FIND ANY PROOF OF MAILING OF THE ORDER FOR SUMMARY JUDGMENT AS DIRECTED THEREIN. Order to Dismiss Complaint Filed September 19, 2014 DENIED Mercedes Parra, Pro Se 10

12 Notice of Motion for Entry of Default and Certification of Service Filed October 15, 2014 Notice directed to Sonia Parra-Apel as Individually and as Executrix of the Estate of Encarnacion Parra at 1241 Wilkinson Dr., Toms River, NJ 08755, Brandon Parra at 65 Elmwood Avenue, Union, NJ 07083, Alfredo Parra at 429 Myrtle Avenue, Roselle Park, NJ 07204, Mercedes Parra at 65 Elmwood Avenue Apt 1, Union, NJ 07083, The State of New Jersey Justice Hughes Complex at 25 Market Street, P.O. Box 080, Trenton, NJ 08625, United States of America at 970 Broad Street, Newark NJ and United States of America C/O Attorney General at 950 Pennsylvania Avenue, Washington, DC Certification of Service of Notice RECEIVED October 15, 2014 On October 15, 2014, a copy of the Notice of Motion was mailed via certified and regular mail to Sonia Parra-Apel as Individually and as Executrix of the Estate of Encarnacion Parra at 1241 Wilkinson Dr., Toms River, NJ 08755, Brandon Parra at 65 Elmwood Avenue, Union, NJ 07083, Alfredo Parra at 429 Myrtle Avenue, Roselle Park, NJ 07204, Mercedes Parra at 65 Elmwood Avenue Apt 1, Union, NJ 07083, The State of New Jersey Justice Hughes Complex at 25 Market Street, P.O. Box 080, Trenton, NJ 08625, United States of America at 970 Broad Street, Newark NJ and United States of America C/O Attorney General at 950 Pennsylvania Avenue, Washington, DC Certification in Support of Order Permitting Entry of Default RECEIVED October 15, 2014 Motion to Appeal The Order Granting Summary Judgment/and Entry of Default and Certification of Service RECEIVED October 28, 2014 CLERK'S NOTATION: RECEIVED BUT NOT FILED! NO FILING FEE INCLUDED. 11

13 Order for Entry of Default Filed November 17, 2014 IT is on this 17th day of November, 2014, ORDERED that default is hereby entered against the defendants, Sonia Parra-Apel, Individually and as Executrix of the Estate of Encarnacion Parra, Brandon Parra, Alfredo Parra, Mercedes Parra, the State of New Jersey, United States of America. Default Filed November 17, 2014 Order for Entry of Default Filed November 20, 2014 DENIED CLERK'S NOTATION: ALL DEFENDANTS PREVIOUSLY DEFAULTED BY PRIOR ORDER. Notice of Motion to Permit Plaintiff to Record A Copy of an Assignment of Mortgage Filed July 9, 2015 Notice directed to Sonia Parra-Apel as Individually and as Executrix of the Estate of Encarnacion Parra at 1241 Wilkinson Dr., Toms River, NJ and 65 Elmwood Avenue, Union, NJ 07083, Brandon Parra at 65 Elmwood Avenue, Union, NJ 07083, Alfredo Parra at 429 Myrtle Avenue, Roselle Park, NJ 07204, Mercedes Parra at 65 Elmwood Avenue Apt 1, Union, NJ Motion Returnable August 7, CLERK'S NOTATION: SONIA PARRA-APEL EXECUTRIX OF THE ESTATE OF ENCARNACION PARRA IS NOT LISTED IN THE CASE MANAGEMENT SYSTEM. 12

14 Certification of Mailing RECEIVED July 9, 2015 On July 9, 2015, a copy of the Notice of Motion, Certification in Support, Proposed Order and Certification of Mailing was sent via certified and regular mail to Sonia Parra-Apel as Individually and as Executrix of the Estate of Encarnacion Parra at 1241 Wilkinson Dr., Toms River, NJ and 65 Elmwood Avenue, Union, NJ 07083, Brandon Parra at 65 Elmwood Avenue, Union, NJ 07083, Alfredo Parra at 429 Myrtle Avenue, Roselle Park, NJ 07204, Mercedes Parra at 65 Elmwood Avenue Apt 1, Union, NJ Certification of Nicholas J. Canova, Esq. In Support of Plaintiff's Motion to Permit Plaintiff to Record a Copy of an Assignment of Mortgage RECEIVED July 9, 2015 Certification sets forth it is respectfully requested that this Court enter an Order allowing Plaintiff to record a corrective Assignment of Mortgage from BNY Mortgage Company, LLC, to Seattle Mortgage, by Assignment dated July 25, 2003, so that it correctly attaches to the Mortgage being foreclosed herein. Objection Motion Filed August 4, 2015 Mercedes Parra, Pro Se Certification in Support of Motion for Order Permitting Plaintiff to Record a Corrective Assignment of Mortgage Filed August 28, 2015 Certification sets forth The intent of the parties was to assign the Mortgage recorded in Book 10342, Page 524, at Instrument # The Mortgage remains in default and no new defense is handed to Defendant, Mercedes Parra, who is not obligated for the mortgage debt. Mercedes Parra is joined as a defendant to this action simply for any ownership interest and for any other right, title and interest she may have in the mortgaged premises pursuant to the last will and testament of the decedent, Encarnacion Parra. 13

15 Defendant, Mercedes Parra, is not prejudiced by the relief sought by Plaintiff which does not serve as an opportunity to re-open the issue of legal standing in this matter. Plaintiff's Motion was served on Defendant via regular and certified mail consistent with the requirements of Rule 1:5-2. Proof of Mailing RECEIVED On August 27, 2015, a copy of the Plaintiff's Certification in Support of Motion for Order Permitting Plaintiff to Record a Corrective Assignment of Mortgage was sent via FedEx Overnight Mail to Mercedes Parra at 65 Elmwood Avenue, Union, NJ Order Permitting Plaintiff to Record a Copy of an Assignment of Mortgage Filed September 18, 2015 IT IS on this 18th day of September, 2015; ORDERED, that the Plaintiff, Reverse Mortgage Solutions, Inc., be and is hereby permitted to record a corrective copy of the Assignment of Mortgage from BNY Mortgage Company, LLC, to Seattle Mortgage, by Assignment dated July 25, 2003, and it is further ORDERED, for any other relief that the Court deems necessary; and it is further ORDERED, that a true copy of this Order be served upon all parties within 7 days of the date herein. Certification of Mailing RECEIVED September 30, 2015 On September 30, 2015, a copy of the Order Permitting Plaintiff to Record a Copy of an Assignment of Mortgage was sent via certified and regular mail to Sonia Parra-Apel as Individually and as Executrix of the Estate of Encarnacion Parra at 1241 Wilkinson Dr., Toms River, NJ and 65 Elmwood Avenue, Union, NJ 07083, Brandon Parra at 65 Elmwood Avenue, Union, NJ 07083, Alfredo Parra at 429 Myrtle Avenue, Roselle Park, NJ 07204, Mercedes Parra at 65 Elmwood Avenue Apt 1, Union, 14

16 NJ Letter of Objection/Appeal of Order Filed October 13, 2015 Mercedes Parra, Pro Se Appeal as to Judge Joseph R. Perfililo's Decision Filed November 2, 2015 Mercedes Parra, Pro Se Order Filed January 29, 2016 DENIED CLERK'S NOTATION: MOTION MUST BE NOTICED TO THE JUDGE IN THE COUNTY. Foreclosure Dismissal Notice (Lack of Prosecution) Filed October 15, 2016 Certification/Affidavit of Diligent Inquiry and Accuracy of Foreclosure Documents and Factual Assertions RECEIVED October 18,

17 Notice of Motion for Final Judgment Filed October 18, 2016 The Notice of Motion for Final Judgment is directed to Sonia Parra-Apel as Individually and as Executrix of the Estate of Encarnacion Parra at 1241 Wilkinson Dr., Toms River, NJ and 65 Elmwood Avenue, Union, NJ 07083, Brandon Parra at 65 Elmwood Avenue, Union, NJ 07083, Alfredo Parra at 429 Myrtle Avenue, Roselle Park, NJ 07204, Mercedes Parra at 65 Elmwood Avenue Apt 1, Union, NJ 07083, The State of C/O Attorney General at 25 Market Street, P.O. Box 080, Trenton, NJ 08625, United States of America at 970 Broad Street, Newark NJ and United States of America C/O Attorney General at 950 Pennsylvania Avenue, Washington, DC Proof of Service of Notice of Motion for Final Judgment RECEIVED October 18, 2016 On October 18, 2016, the Notice of Motion for Final Judgment, Certification of Diligent Inquiry pursuant to R 4:64-2, Certification of Proof of Amount Due and Notice to Tenants (if applicable) were mailed by regular and certified mail to Sonia Parra-Apel as Individually and as Executrix of the Estate of Encarnacion Parra at 1241 Wilkinson Dr., Toms River, NJ and 65 Elmwood Avenue, Union, NJ 07083, Brandon Parra at 65 Elmwood Avenue, Union, NJ 07083, Alfredo Parra at 429 Myrtle Avenue, Roselle Park, NJ 07204, Mercedes Parra at 65 Elmwood Avenue Apt 1, Union, NJ 07083, The State of C/O Attorney General at 25 Market Street, P.O. Box 080, Trenton, NJ 08625, United States of America at 970 Broad Street, Newark NJ and United States of America C/O Attorney General at 950 Pennsylvania Avenue, Washington, DC Pursuant to the Amended Court Rules, effective April 1,2013, mediation papers were provided to the borrowers upon service of the Summons and Complaint and/or Amended Complaint. Certification/Affidavit of Non-Military Service or Inability to Ascertain Military Status RECEIVED October 18, 2016 Sonia Parra-Apel as Individually and as Executrix of the Estate of Encarnacion Parra, Alfredo Parra and Mercedes Parra is/are not in the military service. Report(s) from the Department of Defense Manpower Data Center annexed thereto. Due to lack of a social security number, plaintiff cannot determine whether Brandon Parra, is in the military service. 16

18 Proof of Mailing RECEIVED October 18, 2016 On April 10, 20015, a copy of the filed default was mailed to each of the defendants at the addresses where they were served with process or last known address. Certification of Robert E. Smithson, Jr. RECEIVED October 18, 2016 ENCARNACION PARRA, the obligor, is deceased, therefore the 14 day letter pursuant to Section 6 of the Fair Foreclosure Act NJSA 2A: does not apply and was not mailed. Certification/Affidavit of Costs/Search Fees RECEIVED October 18, 2016 Total fees requested $1, Certification/Affidavit of Amount Due RECEIVED October 18, 2016 Certification/Affidavit by a representative of the plaintiff sets forth that there is due the sum of $400,00.72 on its mortgage together with interest to grow due thereon from. (See copy annexed hereto.) Certification of Marital Status RECEIVED October 18, 2016 Certification sets forth an examination of the Plaintiff's file which discloses that there are no curtesy/dower or other marital interests for the spouse of the Defendants, Mercedes Parra, Alfredo Parra and Brandon Parra. An examination of the Plaintiff's file which discloses that, SONIA PARRA-APEL is married, however, this is not the primary marital residence being foreclosed upon 17

19 herein. Notice of Dismissal as to Kimberly Ann Parra aka Kim Parra RECEIVED October 18, 2016 Objection to Motion for Entry of Judgment Filed November 4, 2016 Mercedes Parra, Pro Se Administrative Order Transferring Foreclosure Matter to a Vicinage Filed February 17, 2017 It is hereby ordered that the above captioned foreclosure matter is administratively transferred to UNION County to be reviewed by a judge. The basis for this administrative transfer is that on November 4, 2016, an objection to the Motion for Final Judgement was filed by the Defendant pursuant to Rule 4:64-9 contesting the foreclosure matter. Certification in Support of Motion for Entry of Final Judgment in Foreclosure Filed March 1, 2017 Opposition and Motion for Non-Acceptance of Certification in Support of Motion Filed March 13, 2017 Mercedes Parra, Pro Se 18

20 Order Denying Objection Filed March 31, 2017 IT IS ORDERED this 31st day of March 2017; that The objection to the final judgment is denied and the matter returned to the Foreclosure Unit for entry of Final Judgment. Letter to Appeal RECEIVED April 10, 2017 Mercedes Parra, Pro Se Final Judgment Filed April 28, 2017 (See copy annexed hereto.) Plaintiff s Costs $5, Writ of Execution issued April 28, 2017 and returned (It appears from the Sheriff s Statement that there was a deficiency.) Notice of Motion for Reconsideration Filed May 5, 2017 Mercedes Parra, Pro Se 19

21 Certification in Support of Motion RECEIVED May 5, 2017 Mercedes Parra, Pro Se Proof of Mailing RECEIVED May 9, 2017 On May 9, 2017, a copy of the filed Final Judgment was mailed to Sonia Parra- Apel as Individually and as Executrix of the Estate of Encarnacion Parra at 1241 Wilkinson Dr., Toms River, NJ and 65 Elmwood Avenue, Union, NJ 07083, Brandon Parra at 65 Elmwood Avenue, Union, NJ 07083, Alfredo Parra at 429 Myrtle Avenue, Roselle Park, NJ and 65 Elmwood Avenue, Union, NJ 07083, Mercedes Parra at 65 Elmwood Avenue Apt 1, Union, NJ 07083, The State of C/O Attorney General at 25 Market Street, P.O. Box 080, Trenton, NJ 08625, United States of America at 970 Broad Street, Newark NJ and United States of America C/O Attorney General at 950 Pennsylvania Avenue, Washington, DC Letter Memorandum of Law in Lieu of a More Formal Brief in Opposition to Defendant, Mercedes Parra's Motion for Reconsideration Filed May 9, 2017 Appeal of Final Judgment Filed June 19, 2017 Mercedes Parra, Pro Se Order to Reconsideration Filed August 4, 2017 Mercedes Parra, Pro Se DENIED (Statement of Reason annexed thereto.) 20

22 Order Filed August 4, 2017 IT IS on this 4th day of August, 2017 ORDERED: 1. The Motion for Reconsideration is denied. (Statement of Reason annexed thereto.) Certification/Affidavit of Mailing RECEIVED November 10, 2017 On October 23, 2017, a Notice of Sheriff's Sale was mailed by regular and certified mail to Sonia Parra-Apel as Individually and as Executrix of the Estate of Encarnacion Parra at 1241 Wilkinson Dr., Toms River, NJ and 65 Elmwood Avenue, Union, NJ 07083, Brandon Parra at 65 Elmwood Avenue, Union, NJ 07083, Alfredo Parra at 429 Myrtle Avenue, Roselle Park, NJ and 65 Elmwood Avenue, Union, NJ 07083, Mercedes Parra at 65 Elmwood Avenue Apt 1, Union, NJ 07083, The State of C/O Attorney General at 25 Market Street, P.O. Box 080, Trenton, NJ 08625, United States of America at 970 Broad Street, Newark NJ and United States of America C/O Attorney General at 950 Pennsylvania Avenue, Washington, DC Emergent Motion for Stay of Sheriff's Sale Filed December 12, 2017 Mercedes Parra, Pro Se Certification in Support of Emergent Motion for Stay of Sheriff's Sale RECEIVED December 12, 2017 Mercedes Parra, Pro Se Order Staying Sheriff's Sale RECEIVED December 12, 2017 Mercedes Parra, Pro Se DENIED 21

23 Request Extension for Time/Adjournment Request Filed January 2, 2018 Mercedes Parra, Pro Se Appearance Entered for Federal National Mortgage Association Filed April 25, 2018 Phelan Hallinan Diamond & Jones, PC, Attorney(s) for Plaintiff Certification in Support of Issuance of Writ of Possession RECEIVED April 26, 2018 Certification/Affidavit of Non-Military Service or Inability to Ascertain Military Status RECEIVED April 26, 2018 Sonia Parra-Apel as Individually and as Executrix of the Estate of Encarnacion Parra, Alfredo Parra and Mercedes Parra is/are not in the military service. Report(s) from the Department of Defense Manpower Data Center annexed thereto. Due to lack of a social security number, plaintiff cannot determine whether Brandon Parra, is in the military service. Writ of Possession issued April 27, 2018 (Not as yet returned into Court.) Report of Sale RECEIVED June 7, 2018 Report of Sale annexed thereto sets forth on December 13, 2017, the Sheriff of Union County sold the mortgaged premises at public vendue to Federal National 22

24 Mortgage Association for the sum of $1, Affidavit of highest and best price annexed thereto. Order Waiving Filing Fees Filed September 7, 2018 Mercedes Parra, Pro Se Certification Application Support of a Fee Waiver RECEIVED September 7, 2018 Mercedes Parra, Pro Se Notice of Motion to Reinstate My Appeal and Stop Eviction on September 10, 2018 Until Appeal is Heard Filed September 7, 2018 Mercedes Parra, Pro Se Emergent Motion for Stay of Eviction Filed September 7, 2018 Mercedes Parra, Pro Se Certification in Support of Emergent Motion for Stay of Eviction RECEIVED September 7, 2018 Mercedes Parra, Pro Se 23

25 Order Staying Eviction Filed September 7, 2018 IT is on this 7 th day of September 2018 ORDERED as Follows: 1. The eviction scheduled for October 10, 2018 is adjourned to October 8, 2018 upon the following terms. 2. Writ of Possession is hereby extended through November 30, There shall be no further adjournments of the eviction. 24

26 THIS CHANCERY ABSTRACT IS CERTIFIED TO DATA TRACE AND BRIGHTLINE TITLE DATED: September 12, 2018 GREATER ATLANTIC LEGAL SERVICES, INC KUSER ROAD, SUITE B-9 HAMILTON, NEW JERSEY Phone Fax tll 25

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

51

52

53

54

55

56

57

58

59

60 SWC-F /18/2016 1:27:53 PM Pg 1 of 24 Trans ID: CHC

61 SWC-F /18/2016 1:27:53 PM Pg 2 of 24 Trans ID: CHC

62 SWC-F /18/2016 1:27:53 PM Pg 3 of 24 Trans ID: CHC

63 SWC-F /18/2016 1:27:53 PM Pg 4 of 24 Trans ID: CHC

64 SWC F /28/2017 Pg 1 of 4 Trans ID: CHC FEIN, SUCH, KAHN & SHEPARD, P.C. ROBERT E. SMITHSON, JR Century Drive, Suite 201 Parsippany, New Jersey (973) YRMT024/KB Attorney for Plaintiff REVERSE MORTGAGE SOLUTIONS, INC. vs. Plaintiff SONIA PARRA-APEL, INDIVIDUALLY AND AS EXECUTRIX OF THE ESTATE OF ENCARNACION PARRA, et als. Defendant SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION- UNION COUNTY DOCKET NO.: F CIVIL ACTION FINAL JUDGMENT This matter being opened to the Court by the Law Firm of Fein, Such, Kahn & Shepard, PC, attorneys for Plaintiff, and it appearing that service of the Summons and Complaint, and Amended Complaint, if any, have been made upon the following Defendants, in accordance with the Rules of this Court, and default having been entered against said Defendants, and it appearing SONIA PARRA-APEL, INDIVIDUALLY AND AS EXECUTRIX OF THE ESTATE OF ENCARNACION PARRA; BRANDON PARRA; ALFREDO PARRA; MERCEDES PARRA; THE STATE OF NEW JERSEY; UNITED STATES OF AMERICA; and the Plaintiff's obligation, mortgage and assignments of mortgage having been presented and marked as exhibits by the Court, and proofs having been submitted of the amount due on Plaintiff's mortgage, and sufficient cause appearing; IT IS on this 28th day of April, 2017,

65 SWC F /28/2017 Pg 2 of 4 Trans ID: CHC ORDERED AND ADJUDGED that the Plaintiff is entitled to have the sum of $400, together with lawful interest thereon from 08/22/16 together with costs of this suit to be taxed, including a counsel fee of $ 4,150 raised and paid in the first place out of the mortgaged premises, The Question of priority as between the Plaintiff and the United States of America with regard to counsel fees shall await surplus money proceedings, if any; and it is further ORDERED that the Plaintiff or its assignee or the successful purchaser at the Sheriff's Sale duly recover against the following Defendants: SONIA PARRA-APEL, INDIVIDUALLY AND AS EXECUTRIX OF THE ESTATE OF ENCARNACION PARRA; BRANDON PARRA; ALFREDO PARRA; MERCEDES PARRA; and all parties holding under said Defendants, the possession of the premises mentioned and described in the said Complaint, and Amended Complaint, if any, with the appurtenances; and it is further ORDERED AND ADJUDGED that the mortgaged premises be sold to raise and satisfy the several sums of money due, in the first place, to Plaintiff, the sum of $400, together with contract rate and lawful interest thereon to be computed as aforesaid with the plaintiff's costs to be taxed, with lawful interest thereon, and that an execution for that purpose be duly issued out of this Court directed to the Sheriff of UNION County, commanding him to make sale according to law of the mortgaged premises described in the Complaint and Amended Complaint, if any, and out of the monies

66 SWC F /28/2017 Pg 3 of 4 Trans ID: CHC arising from said sale, that said Sheriff or any other Court appointed officer, attorney or special master pay in the first place, to the Plaintiff, said Plaintiff's debt, with interest thereon as aforesaid and said Plaintiff's costs with interest thereon as aforesaid, and in case more money shall be realized by the said sale then shall be sufficient to satisfy such several payments as aforesaid, that such surplus be brought into this Court to abide the further Order of this Court and that the Sheriff aforesaid make a report of the aforesaid sale without delay as required by the Rules of this Court; and it is further ORDERED AND ADJUDGED that the Defendants in this cause, and each of them stand absolutely debarred and foreclosed of and from all equity of redemption of, in, and to said mortgaged premises described in the Complaint, and Amended Complaint, if any, when sold as aforesaid by virtue of this judgment, except as provided by 28 USC Section Notwithstanding anything herein to the contrary, this judgment shall not affect the rights of any person protected by the New Jersey Tenant Anti-Eviction Act, N.J.8.A. 2A: , et seq., the right of redemption given the United States under 28 US. C 2410, the limited priority rights for the aggregate customary condominium assessment for the six-month period prior to the recording of any association lien as allowed by NJ.S.A. 46:8B-21 or rights afforded by the Servicemembers Civil Relief Act, 50 US. C. App. 501 et seq.

67 SWC F /28/2017 Pg 4 of 4 Trans ID: CHC or N.J.S.A 38:23C-4. /s/ Paul Innes, P.J.Ch. HON. PAUL INNES, P.J. CH. File No. YRMT024 Respectfully Recommended R. 1:34-6 Office of Foreclosure

68 SWC F /07/2018 Pg 1 of 5 Trans ID: CHC