GREATER ATLANTIC LEGAL SERVICES, INC. CHANCERY ABSTRACT SANTANDER BANK, N.A. vs. Plaintiff, VIRGINIA K. OROKOS MR. OROKOS, Husband of Virginia K. Orokos CHASE BANK USA NA TARGET NATIONAL BANK EVERGREEN WOODS PARK ASSOCIATION, INC. Defendants, SUPERIOR COURT OF NEW JERSEY OCEAN COUNTY DOCKET NO. F-027755-14 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 # 7119542 TITLE OFFICER
Complaint to Foreclose FILED July 8, 2014 Phelan Hallinan & Diamond, PC Attorneys for Plaintiff FIRST COUNT Complaint filed to foreclose mortgage made and executed by Virginia K. Orokos to Select Mortgage Corporation to secure the sum of $132,000.00. Obligation and mortgage dated January 31, 2005. The mortgage was recorded in Ocean County on February 4, 2005 in Book 12464, Page 0549. THIS IS 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. Mr. Orokos, Husband of Virginia K. Orokos, Chase Bank USA, NA, Target National Bank, and Evergreen Woods Park Association, Inc. 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. THIRD COUNT It having been revealed that the county on the page #2 of the mortgage omitted the type of recording jurisdiction requiring reformation, the plaintiff desires its mortgage to be reformed to correct the county to The County of Ocean. WHEREFORE it is respectfully requested that the mortgage documents be reformed to reflect the correct county and the Final Judgment entered in this matter provided for reformation of the plaintiff's mortgage so as to correct the clerical error set forth therein. By: The Complaint is signed, Phelan Hallinan & Diamond, PC Attorneys for Plaintiff William Adam Aitken, Esq. NOTE: WE CALL YOUR ATTENTION TO THE FACT THAT THE CERTIFICATION PURSUANT TO RULE 4:64-1(a) ANNEXED TO THE COMPLAINT FAILS TO SPECIFICALLY STATE THAT PLAINTIFF HAS RECEIVED AND REVIEWED THE TITLE SEARCH. Summons dated July 22, 2014 (See returns of service for Chase Bank USA, NA Evergreen Woods Park Association, Inc. annexed hereto.) 2
Proof of Mailing of Tenants' Rights Pursuant to R 4:64-1 RECEIVED August 8, 2014 On July 14, 2014 a Notice to Residential Tenants of Rights During Foreclosure was mailed by regular and certified mail to each Tenant and Inquilino at 1228 Baylis Court, Brick, NJ 08724. Certification of Inquiry/Mailing as to Virginia K. Orokos and Mr. Orokos, Husband of Virginia Orokos RECEIVED January 26, 2015 On October 23, 2014 a copy of the summons and complaint was sent via regular and certified mail to Virginia K. Orokos and Mr. Orokos, Husband of Virginia Orokos at 1228 Baylis Court, Brick, NJ 08724. A copy of the confirmation indication that service was returned unclaimed is annexed thereto. Certification of Inquiry/First Name of Spouse Unknown RECEIVED Certification sets forth that the actual name of the actual, real or giving name of Mr. Orokos, Husband of Virginia K, Orokos could not be ascertained. Certification of Inquiry/Mailing for Our of State Business RECEIVED January 26, 2015 On July 23, 2014 a copy of the summons and complaint was sent via regular and certified mail to Target National Bank at 3901 W. V53rd Street, Sioux Falls, SD 57106. A copy of the confirmation indicating service was completed on July 28, 2014 is annexed hereto. Request and Certification of Default as to Virginia K. Woods, Chase Bank USA, NA and Target National Bank FILED February 6, 2015 3
CLERK'S NOTATION: DEFAULT NOT ENTERED AS TO MR. OROKOS. CERTIFICATION IS REQUIRED. ALSO DEFAULT NOT ENTERED AS TO EVERGREEN WOODS PARK ASSOCIATION, INC. PARTY IS NOT A PARTY TO THE CASE. Default FILED February 6, 2015 Notice of Motion to Correct MetaData and Add Defendant's Name Into the Court Case Management System (ACMS) FILED August 31, 2015 Notice of Motion directed to Virginia K. Orokos, Mr. Orokos, Husband of Virginia K. Orokos, Chase Bank USA, NA, Target National Bank, and Evergreen Woods Park Association, Inc. Certification in Support of Motion to Correct MetaData and Add Defendant's Name Into the Court Case Management System(ACMS) RECEIVED August 31, 2015 Proof of Mailing Notice of Motion to Correct MetaData and Add Defendant's Name Into the Court Case Management System (ACMS) RECEIVED August 31, 2015 DENIED CLERK'S NOTATION: 9/28/2015 AFF-SERVICE IS FOR A DIFFERENT CASE/CAPTION. 4
Notice of Motion to Correct MetaData and Add Defendant's Name Into the Court Case Management System (ACMS) FILED October 13, 2015 Notice of Motion directed to Virginia K. Orokos, Mr. Orokos, Husband of Virginia K. Orokos, Chase Bank USA, NA, Target National Bank, and Evergreen Woods Park Association, Inc. Certification in Support of Motion to Correct MetaData and Add Defendant's Name Into the Court Case Management System(ACMS) RECEIVED October 13, 2015 Proof of Mailing Notice of Motion to Correct MetaData and Add Defendant's Name Into the Court Case Management System (ACMS) RECEIVED October 13, 2015 On August 28, 2015 a copy of the Motion to Correct MetaData and Add Defendant's Name Into the Court Case Management System (ACMS) was mailed to each Virginia K. Orokos, Mr. Orokos, Husband of Virginia K. Orokos, Chase Bank USA, NA, Target National Bank, and Evergreen Woods Park Association, Inc. (See copy annexed hereto). Order Correcting MetaData and Add Defendant's Name Into the Court Case Management System(ACMS) FILED November 6, 2015 IT IS on this 6th day of November, 2015 ORDERED that the following party is hereby added to the case management system (ACMS): Evergreen Woods Park Association, Inc. 5
Proof of Mailing Order to Correct MetaData and Add Defendant's Name Into the Court Case Management System (ACMS) RECEIVED November 20, 2015 On November 19, 2015 a copy of the Order to Correct MetaData and Add Defendant's Name Into the Court Case Management System (ACMS) was mailed to each Virginia K. Orokos, Mr. Orokos, Husband of Virginia K. Orokos, Chase Bank USA, NA, Target National Bank, and Evergreen Woods Park Association, Inc. at the addresses where they were served the summons and complaint. Notice of Motion for Entry of Default FILED December 4, 2015 The Notice of Motion for Entry of Default is directed to Mr. Orokos, Husband of Virginia K. Orokos and Evergreen Woods Park Association Inc. Certification/Affidavit in Support of Motion for Entry of Default RECEIVED December 4, 2015 Proof of Mailing of Notice of Motion RECEIVED December 4, 2015 On December 1, 2015 a copy of the Notice of Motion for Entry of Default was mailed by regular and certified mail to Mr. Orokos, Husband of Virginia K. Orokos and Evergreen Woods Park Association Inc. (See copy annexed hereto) Order for Entry of Default FILED January 15, 2016 It is on this 15th day of January, 2016 ORDERED that default is hereby entered against Mr. Orokos, Husband of Virginia K. Orokos and Evergreen Woods Park Association Inc. 6
Proof of Mailing - Entry of Default RECEIVED May 20, 2016 On January 29, 2016 a copy of the filed default was mailed to each Virginia K. Orokos, Mr. Orokos, Husband of Virginia K. Orokos, Chase Bank USA, NA, Target National Bank, and Evergreen Woods Park Association, Inc. at the addresses where they were served with summons and complaint. Proof of Service of Notice to Cure Pursuant to Fair Foreclosure Act RECEIVED May 20, 2016 On February 1, 2016 a Notice to Cure pursuant to the Fair Foreclosure Act was mailed by regular and certified mail to Virginia K. Orokos at the following address: 1228 Baylis Court, Brick, NJ 08724. More than ten days have passed since receipt of the notice by the debtors. Certification/Affidavit of Diligent Inquiry and Accuracy of Foreclosure Documents and Factual Assertions RECEIVED May 20, 2016 Certifications of Non-Military Service or Inability to Ascertain Military Status RECEIVED May 20, 2016 Virginia K. Orokos 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 Mr. Orokos, Husband of Virginia K. Orokos is in the military service. Notice of Motion for Entry of Judgment FILED May 20, 2016 The Notice of Motion for Entry of Judgment is directed to Virginia K. Orokos, Mr. Orokos, Husband of Virginia K. Orokos, Chase Bank USA, NA, Target National Bank, Evergreen Woods Park Association, Inc., and Tenant. 7
Proof of Service of Notice of Motion for Final Judgment RECEIVED May 20, 2016 On May 9, 2016 a copy of the Notice of Motion for Entry of Judgment, Certification of Amount Due and Certification of Diligent Inquiry pursuant to R 4:64-2 were mailed to Virginia K. Orokos, Mr. Orokos, Husband of Virginia K. Orokos, Chase Bank USA, NA, Target National Bank, Evergreen Woods Park Association, Inc., and Tenant. NOTE: WE CALL YOUR ATTENTION TO THE FACT THAT THE CERTIFICATION OF SERVICE OF THE NOTICE OF MOTION FOR ENTRY OF JUDGMENT DOES NOT SPECIFY THAT THE NOTICE WAS SERVED VIA CERTIFIED MAIL. Certification of Costs/Search Fees RECEIVED May 20, 2016 Total fees requested $667.00 Proof of Amount Due and Schedule RECEIVED May 20, 2016 Certification by a representative of the plaintiff sets forth that there is due the sum of $146,089.42 on its mortgage together with interest to grow due thereon from March 4, 2016. (See copy annexed hereto.) Final Judgment FILED June 24, 2016 (See copy annexed hereto.) Plaintiff s Costs $2,377.89 8
Writ of Execution issued June 24, 2016 and returned Proof of Mailing RECEIVED July 6, 2016 On July 6, 2016 a copy of the filed Final Judgment was mailed by regular and certified mail to each Virginia K. Orokos, Mr. Orokos, Husband of Virginia K. Orokos, Chase Bank USA, NA, Target National Bank, and Evergreen Woods Park Association, Inc. at the addresses where they were served the summons and complaint. Certification of Proof of Mailing RECEIVED February 20, 2017 On February 17, 2017 a Notice of Sheriff's Sale was mailed by regular and certified mail to Virginia K. Orokos at the address where she was served the summons and complaint. Report of Sale RECEIVED May 12, 2017 On April 18, 2017, the Sheriff of Ocean County sold the mortgaged premises at public vendue to Federal National Mortgage Association, for the sum of $81,000.00. Affidavit of highest and best price annexed thereto. Appearance Entered for Federal National Mortgage Association FILED August 7, 2017 Fein, Such, Kahn & Shepard, Attorney(s) for Assignee/Successful Bidder Writ of Possession issued August 9, 2017 9
THIS CHANCERY ABSTRACT IS CERTIFIED TO FIDELITY NATIONAL TITLE GROUP DATED: July 24, 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 KKW 10
SWC F 027755-14 05/12/2017 Pg 1 of 1 Trans ID: CHC2017399496