GREATER ATLANTIC LEGAL SERVICES, INC. CHANCERY ABSTRACT U.S. BANK NATIONAL ASSOCIATION vs. Plaintiff, MARLENE DE LORENZO; ERNEST DE LORENZO, Wife and Husband; JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Defendants, SUPERIOR COURT OF NEW JERSEY WARREN COUNTY DOCKET NO. F-016029-14 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 # 7115381 TITLE OFFICER
Complaint to Foreclose Filed April 22, 2014 Fein, Such, Kahn & Shepard, PC, Attorneys for Plaintiff FIRST COUNT Complaint filed to foreclose mortgage made and executed by Marlene De Lorenzo and Ernest De Lorenzo to Mortgage Electronic Registration Systems, Inc. as Nominee for Infinity Mortgage to secure the sum of $223,300.00. Obligation and mortgage dated September 26, 2005. The mortgage was recorded in Warren County on November 15, 2005 in Book 4222, Page 179. This is a Non 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. JPMorgan Chase Bank, National Association is/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. 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. 1
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. By: The Complaint is signed, Fein, Such, Kahn & Shepard, PC Attorneys for Plaintiff Simone Sebastian Summons dated April 25, 2014 (See return(s) and/or acknowledgment(s) of service for Ernest De Lorenzo; Marlene De Lorenzo; JPMorgan Chase Bank, National Association annexed hereto.) Request and Certification/Affidavit of Default as to, Ernest De Lorenzo; Marlene De Lorenzo; JPMorgan Chase Bank, National Association Filed June 24, 2014 Default Filed June 24, 2014 Foreclosure Dismissal Warning for Lack of Prosecution RECEIVED June 26, 2015 2
Attorney Certification in Response to Rule 4:64-8 Notice RECEIVED July 23, 2015 DENIED: Certification does not set forth exceptional circumstances. Foreclosure Dismissal Order for Lack of Prosecution RECEIVED July 31, 2015 Notice of Motion to Reinstate Matter Filed December 22, 2015 The Notice of Motion to Reinstate is directed to Ernest De Lorenzo; Marlene De Lorenzo. Proof of Mailing RECEIVED December 22, 2015 (See copy annexed hereto) Certification in Support of Motion to Reinstate RECEIVED December 22, 2015 Order Reinstating Matter Filed January 22, 2016 It is on this January 22, 2016, ORDERED that the within matter be and same is hereby reinstated and any Order Dismissing the matter is hereby vacated. It is further ORDERED that a copy of this Order shall be served on all parties within seven days. 3
Certification of Mailing RECEIVED January 25, 2016 On January 25, 2016, a copy of the filed Order Reinstating Matter was mailed via regular and certified mail to, Ernest De Lorenzo; Marlene De Lorenzo at the address where they were served with process. Certification/Affidavit of Diligent Inquiry and Accuracy of Foreclosure Documents and Factual Assertions RECEIVED April 07, 2016 Notice of Motion for Final Judgment Filed April 07, 2016 The Notice of Motion for Final Judgment is directed to Ernest De Lorenzo; Marlene De Lorenzo; JPMorgan Chase Bank, National Association. Proof of Service of Notice of Motion for Final Judgment RECEIVED (See copy annexed hereto) Certification/Affidavit of Non-Military Service or Inability to Ascertain Military Status RECEIVED April 07, 2016 Marlene De Lorenzo and Ernest De Lorenzo is/are not in the military service. Report(s) from the Department of Defense Manpower Data Center annexed thereto. 4
Certification/Affidavit of Costs/Search Fees RECEIVED April 07, 2016 Total fees requested $950.58. Certification/Affidavit of Amount Due RECEIVED April 07, 2016 Certification/Affidavit by a representative of the plaintiff sets forth that there is due the sum of $275,135.67 on its mortgage together with interest to grow due thereon from February 25, 2016. (See copy annexed hereto.) Final Judgment Filed May 04, 2016 (See copy annexed hereto.) Plaintiff s Costs $3,756.24. Writ of Execution issued May 04, 2016 Report of Sale annexed thereto sets forth that on June 19, 2017, the Sheriff of Warren County sold the Mortgaged premises at public vendue to PB Services Limited Liability Company for the sum of $118,000.00. Affidavit of highest and best price annexed thereto. 5
Proof of Mailing RECEIVED May 12, 2016 On May 12, 2016, a copy of the filed Final Judgment was mailed to Marlene De Lorenzo and Ernest De Lorenzo at the address where they were served with process. NOTE: WE FAIL TO FIND ANY PROOF OF MAILING OF A NOTICE OF SALE FILED IN THIS ACTION. Notice of Motion to Direct That the Sheriff of Warren County to Immediately Schedule Sheriff s Sale RECEIVED May 04, 2017 The Notice of Motion for Final Judgment is directed to Ernest De Lorenzo; Marlene De Lorenzo; JPMorgan Chase Bank, National Association; Warren County Counsel and Warren County Sheriff. Certification of Filing and Service RECEIVED May 04, 2017 Certification in Support of Motion to Direct Sheriff of Warren County to Schedule Sheriff s Sale RECEIVED May 04, 2017 Memorandum of Law RECEIVED May 04, 2017 6
Motion to Compel WITHDRAWN RECEIVED May 09, 2017 Plaintiff's office requests that the pending Motion to Compel Sheriff Sale filed on May 04, 2017, transaction ID CHC2017376261, be withdrawn. 7
THIS CHANCERY ABSTRACT IS CERTIFIED TO FIDELITY NATIONAL TITLE GROUP DATED: July 19, 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. 8
SWC F 016029-14 12/14/2017 Pg 5 of 5 Trans ID: CHC2017871526