GREATER ATLANTIC LEGAL SERVICES, INC. CITIMORTGAGE, INC. vs. Plaintiff, CHANCERY ABSTRACT CORA T. GILLESPIE; MR. GILLESPIE, HER HUSBAND; LEXINGTON NATIONAL INSURANCE CORPORATION, BENEFICIARY, ABC BAIL BONDS, INC TRUSTEE Defendants, SUPERIOR COURT OF NEW JERSEY CAMDEN COUNTY DOCKET NO. F-004702-14 GREATER ATLANTIC LEGAL SERVICES, INC. hereby certifies to FIDELITY NATIONAL TITLE GROUP 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. YOUR REFERENCE # 7088404 TITLE OFFICER
Complaint to Foreclose Filed February 07, 2014 Milstead & Associates, LLC, Attorneys for Plaintiff FIRST COUNT Complaint filed to foreclose mortgage made and executed by Cora T. Gillespie to Mortgage Electronic Registration Systems Inc, as Nominee for CitiMortgage, Inc. to secure the sum of $198,618.00. Obligation and mortgage dated September 16, 2008. The mortgage was recorded in Camden County on September 30, 2008 in Book 8913, Page 1903. This mortgage is a non-purchase money mortgage. A COMPLETE COPY OF THE COMPLAINT WITH PROPERTY DESCRIPTION ATTACHED IS ANNEXED HERETO. The mortgage was subsequently assigned to Plaintiff by assignments more particularly set forth in the annexed copy of the Complaint. Lexington National Insurance Corporation, Beneficiary, ABC Bail Bonds, Inc., Trustee; Mr.Gillespie, husband of Cora T. Gillespie are joined as party defendants herein by reason of which are more particularly set forth in the annexed copy of the Complaint. By virtue of a default in the payment of the obligation and 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. 1
SECOND COUNT Plaintiff is entitled to possession of the premises described in the First Count. Pursuant to the terms of the Note and Mortgage, Plaintiff becomes entitled to possession of the premises described in the First Count except as against those tenants protected under N.J.S.A. 2A:18-61.1, et seq. The defendants have or may claim to have certain rights in the premises and have deprived the plaintiff of possession of the premises aforesaid. WHEREFORE, Plaintiff demands judgment against the defendants except those persons protected under N.J.S.A. 2A:18-61.1, et seq: For possession of said premises on behalf of itself or the purchaser at the Sheriff's sale; For costs. THIRD COUNT (Correcting Property Description) (See annexed copy of Complaint) By: The Complaint is signed, Milstead & Associates, LLC Attorneys for Plaintiff James Rolle, Jr. Esq. Summons dated February 12, 2014 (See returns and/or acknowledgments of service for Cora T. Gillespie; Lexington National Insurance Corporation, Beneficiary, ABC Bail Bonds, Inc., Trustee annexed hereto.) 2
NOTE: WE FAIL TO FIND A CERTIFICATION OF INQUIRY OF OUT OF STATE PERSONAL SERVICE AS TO LEXINGTON NATIONAL INSURANCE CORPORATION, BENEFICIARY, ABC BAIL BONDS, INC., TRUSTEE FILED IN THIS ACTION. Notice of Dismissal as to Mr. Gillespie, her husband, Filed April 24, 2014 Request and Certification of Default as to Cora T. Gillespie; Lexington National Insurance Corporation, Beneficiary, ABC Bail Bonds, Inc., Trustee Filed April 24, 2014 Default Filed April 24, 2014 Rule 4:64-2(d) Certification of Diligent Inquiry and Accuracy of Foreclosure Documents and Factual Assertions RECEIVED August 01, 2014 Notice of Motion for Entry of Final Judgment Filed August 01, 2014 Notice is directed to, Cora T. Gillespie. 3
Proof of Mailing RECEIVED August 01, 2014 (See copy annexed hereto) Certification of Service of Notice of Foreclosure Mediation Availability RECEIVED August 01, 2014 The certification sets forth that notices of foreclosure mediation availability were served upon owner/borrower(s) along with the summons and complaint. Certification of Service of Notice to Residential Tenants of Rights During Foreclosure RECEIVED August 01, 2014 On July 22, 2014, a Notice to Residential Tenants of Rights During Foreclosure was mailed by regular and certified mail to each Tenant at the mortgaged premises. Certification of Non-Military Service or Inability to Ascertain Military Status RECEIVED August 01, 2014 Cora T. Gillespie is not in the military service. Report(s) from the Department of Defense Manpower Data Center annexed thereto. Certification of Mailing RECEIVED August 01, 2014 On May 13, 2014, a copy of the filed default was mailed to each of the defendants at the addresses where they were served with summons and complaint. 4
Certification of Mailing Notice for Entry of Final Judgment and No Response from Debtor Pursuant to Fair Foreclosure Act RECEIVED August 01, 2014 On May 13, 2014, a Notice to Cure pursuant to the Fair Foreclosure Act was mailed by regular and certified mail to, Cora T. Gillespie at the address where she was served with summons and complaint More than ten days have elapsed since receipt of the Notice and no statement has been received from the debtor(s) of the reasonable likelihood that the debtor(s) will be able to cure the default. Certification of Filing Fees, Search Fees, Service Fees and Charges RECEIVED August 01, 2014 Total fees requested $796.44 Certification of Proof of Amount Due Certification and Schedule RECEIVED Certification by a representative of the plaintiff sets forth that there is due the sum of $271,748.14 on its mortgage together with interest to grow due thereon from June 06, 2014. (See copy annexed hereto.) Final Judgment Filed September 03, 2014 (See copy annexed hereto.) NOTE: WE FAIL TO FIND ANY PROOF OF MAILING OF THE FINAL JUDGMENT FILED IN THIS ACTION. 5
Writ of Execution issued September 03, 2014 Report of Sale annexed thereto sets forth that on April 08, 2015, the Sheriff of Camden County sold the Mortgaged premises at public vendue to Citimortgage, Inc. for the sum of $100.00. Affidavit of highest and best price annexed thereto. NOTE: WE CALL YOUR ATTENTION TO THE FACT THAT THE REPORT OF SALE HAS NOT BEEN SIGNED. Certification as to Mailing of Sale Notice RECEIVED March 27, 2015 On March 26, 2015, a Notice of Sheriff's Sale was mailed by regular and certified mail to Cora T. Gillespie at. Certification of Non-Military Service or Inability to Ascertain Military Status RECEIVED December 22, 2015 Cora T. Gillespie is 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 John Doe/Jane Doe, and any unknown occupants is in the military service. Writ of Possession issued January 04, 2016 (Certification in Support of Writ of Possession annexed thereto) 6
THIS CHANCERY ABSTRACT IS CERTIFIED TO FIDELITY NATIONAL TITLE GROUP DATED: July 9, 2018 GREATER ATLANTIC LEGAL SERVICES, INC. 1542 KUSER ROAD, SUITE B-9 HAMILTON, NEW JERSEY 08619 Phone 800 345-4631 Fax 609 581-5604 www.greateratlanticlegal.com S. A. 7