GREATER ATLANTIC LEGAL SERVICES, INC. CHANCERY ABSTRACT NEW YORK COMMUNITY BANK, successor in Interest to Penn Federal Savings Bank; vs. Plaintiff, BAHGAT G. AWAD; NADRA B. AWAD, husband and wife, each of their heirs, devisees, and personal representatives, and his, her, their or any of their successors in right, title and interest; LITENDA MORTGAGE CORPORATION; HOSPITAL & DOCTORS SERVICE BUREAU; JAMES STREET ANESTHESIA ASSOCIATES; ABC RECEIVABLES MANAGEMENT INC t/a Medical Dental Hospital Bureau; Defendants, SUPERIOR COURT OF NEW JERSEY ESSEX COUNTY DOCKET NO. F-018170-15 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. GREATER ATLANTIC LEGAL SERVICES, INC. YOUR REFERENCE # 7109223 TITLE OFFICER
Complaint to Foreclose Filed May 20, 2015 Zucker, Goldberg & Ackerman, LLC, Attorneys for Plaintiff FIRST COUNT Complaint filed to foreclose mortgage made and executed by Bahgat G. Awad and Nadra B. Awad, husband and wife to Greentree Mortgage Company, L.P. to secure the sum of $75,000.00. Obligation and mortgage dated April 15, 1994. The mortgage was recorded in Essex County on April 29, 1994 in Book 6376, Page 676. THIS IS NOT A PURCHASE MONEY MORTGAGE. A COMPLETE COPY OF THE COMPLAINT WITH PROPERTY DESCRIPTION ATTACHED IS ANNEXED HERETO. By virtue of assignment(s) more particularly set forth in the annexed copy of the Complaint, the mortgage was assigned to the Plaintiff. James Street Anesthesia Associates, ABC Receivables Management Inc t/a Medical Dental Hospital Bureau, Hospital & Doctors Service Bureau and Litenda Mortgage Corporation are made defendant(s) for reasons more particularly set forth in the annexed copy of the Complaint. By virtue of a default in accordance with the terms 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. 1
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 hereby repeats, re-alleges, and incorporates the allegations set forth in the First Count of the Complaint, as if set forth herein at length. By the terms of he Note and Mortgage, plaintiff is entitled to possession of the Mortgaged Premises and all appurtenances. The Mortgagor(s) and Obligor(s) named herein has or may claim to have certain rights in the Mortgaged Premises, and by reason thereof, has or have deprived plaintiff of 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. By: The Complaint is signed, Zucker, Goldberg & Ackerman, LLC Attorneys for Plaintiff Jamar Benjamin, Esq. For the Firm Substitution of Attorney Filed September 10, 2015 Zucker, Goldberg & Ackerman, LLC do hereby consent to the substitution of McCabe, Weisberg & Conway, P.C. as Attorneys for Plaintiff. 2
Affidavits' of Service RECEIVED December 10, 2015 (See return(s) and/or acknowledgment(s) of service for Bahgat G. Awad, Hospital & Doctors Service Bureau, Nadra B. Awad, James Street Anesthesia Associates and ABC Receivables Management Inc t/a Medical Dental Hospital Bureau annexed hereto.) NOTE: WE FAIL TO FIND ANY SUMMONS DIRECTED TO BAHGAT G. AWAD, HOSPITAL & DOCTORS SERVICE BUREAU, NADRA B. AWAD, JAMES STREET ANESTHESIA ASSOCIATES AND ABC RECEIVABLES MANAGEMENT INC. T/A MEDICAL DENTAL HOSPITAL BUREAU FILED IN THIS ACTION. NOTE: WE CALL YOUR ATTENTION TO THE FACT THAT THE SUMMONS SERVED UPON BAHGAT G. AWAD AND NADRA B. AWAD DOES NOT APPEAR TO CONFORM WITH RULE 4:4-2 IN THAT IT FAILS TO CONTAIN A CURRENT LISTING BY COUNTY OF TELEPHONE NUMBERS OF THE LEGAL SERVICES OFFICE AND THE LAWYER REFERRAL OFFICE SERVING EACH COUNTY. Certification in Support of Publication (as to Litenda Mortgage Corporation) RECEIVED December 10, 2015 (See copy annexed hereto.) NOTE: CONSIDERATION SHOULD BE GIVEN TO THE ADEQUACY OF THE CERTIFICATION IN SUPPORT OF PUBLICATION AS TO LITENDA MORTGAGE CORPORATION. Notice of Dismissal as to the heirs, devisees, etc. of Bahgat G. Awad, Nadra B. Awad Filed December 11, 2015 3
Request and Certification of Default as to Bahgat G. Awad; Nadra B. Awad; Hospital & Doctors Service Bureau; James Street Anesthesia Associates; ABC Receivables Management Inc. t/a Medical Dental Hospital Bureau; Litenda Mortgage Corporation Filed December 11, 2015 Default Filed December 11, 2015 Rule 4:64-2(d) Certification of Diligent Inquiry and Accuracy of Foreclosure Document and Factual Assertions RECEIVED March 28, 2016 Notice of Motion for Entry of Final Judgment Filed March 28, 2016 The Notice of Motion for Final Judgment is directed to Hospital & Doctors Service Bureau, James Street Anesthesia Associates, Bahgat G. Awad, ABC Receivables Management Inc. t/a Medical Dental Hospital Bureau, Nadra B. Awad and Litenda Mortgage Corporation (No Mailing Required Pursuant to Rule 1:5-2. Proof of Mailing of Notice of Motion for Final Judgment RECEIVED March 28, 2016 (See copy annexed hereto.) 4
Certification in Support of Service RECEIVED March 28, 2016 On May 22, 2015, a coy of the Mediation Program Firms were served upon each Bahgat G. Awad and Nadra B. Awad at 18 Manor Blvd., Edison, New Jersey 08820. Certification of Non-Military Status RECEIVED March 28, 2016 Certification sets forth that Bahgat G. Awad and Nadra B. Awad are not in the military service. Report(s) from the Department of Defense Manpower Data Center annexed thereto. Proof of Mailing RECEIVED March 28, 2016 On December 17, 2015, a copy of the filed default was mailed to each of the defendants at the addresses where they were served with process. Certification of Mailing of 14 Day Notice of Entry of Final Judgment and No Response RECEIVED March 28, 2016 On December 17, 2015, a Notice to Cure pursuant to the Fair Foreclosure Act was mailed by regular and certified mail to each Bahgat G. Awad and Nadra B. Awad at the following addresses: 601 Grove Street, Irvington, New Jersey 07111 and 18 Manor Blvd., Edison, New Jersey 08820. As of March 23, 2016, no response has been received to the aforesaid Notice of Intention to Apply for Final Judgment. Certification of Search Fees RECEIVED March 28, 2016 Total fees requested $673.46. 5
Proof of Amount Due Affidavit and Schedule RECEIVED March 28, 2016 Certification/Affidavit by a representative of the plaintiff sets forth that there is due the sum of $55,050.25 on its mortgage together with interest to grow due thereon from February 1, 2016. The property described in the complaint in this action cannot be divided and should be sold as a single tract. (See copy annexed hereto.) Certification as to Mailing of 14 Day Notice of Entry of Final Judgment and No Response RECEIVED (See copy annexed hereto.) Final Judgment Filed May 13, 2016 (See copy annexed hereto.) NOTE: WE FAIL TO FIND ANY PROOF OF MAILING OF THE FINAL JUDGMENT FILED IN THIS ACTION. Plaintiff s Costs $1,373.96. Writ of Execution issued May 13, 2016 (Writ never returned to Court.) 6
Proof of Mailing of Notice of Sale RECEIVED December 19, 2016 (See copy annexed hereto.) LAST ENTRY THIS CHANCERY ABSTRACT IS A REFLECTION OF THE SUPERIOR COURT FILE AS IT APPEARS ON THE DATE OF THIS CHANCERY ABSTRACT. BECAUSE OF A DELAY IN THE DOCKETING AND FILING OF PLEADINGS THERE MAY BE ADDITIONAL PLEADINGS WHICH HAVE BEEN RECEIVED BY THE CLERK'S OFFICE BUT ARE NOT YET SHOWING AS FILED. 7
THIS CHANCERY ABSTRACT IS CERTIFIED TO FIDELITY NATIONAL TITLE GROUP DATED: July 17, 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 BA 8
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