GREATER ATLANTIC LEGAL SERVICES, INC. CHANCERY ABSTRACT WELLS FARGO BANK, N.A. for the Benefit of DLJ Mortgage Capital, Inc.; vs. Plaintiff, MICHAELE DUNN; HOSHEA DAVID ESTRADA; MR. DUNN, husband of Michaele Dunn; MRS. HOSHEA DAVID ESTRADA, his wife; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as nominee for Mortgageit Inc.; Defendants, SUPERIOR COURT OF NEW JERSEY ESSEX COUNTY DOCKET NO. F-001482-08 GREATER ATLANTIC LEGAL SERVICES, INC. hereby certifies to MADISON TITLE AGENCY 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 # MTANJ-131208 TITLE OFFICER
Complaint to Foreclose Filed January 11, 2008 Eschen, Frenkel, Weisman & Gordon, LLP, Attorneys for Plaintiff FIRST COUNT Complaint filed to foreclose mortgage made and executed by Michaele Dunn and Hoshea David Estrada to Mortgage Electronic Registration Systems, Inc., as nominee for Mortgageit, Inc. to secure the sum of $377,600.00. Obligation and mortgage dated April 28, 2006. The mortgage was recorded in Essex County on May 2, 2006 in Book 11230, Page 191, et seq. THIS IS A PURCHASE MONEY MORTGAGE. A COMPLETE COPY OF THE COMPLAINT WITH PROPERTY DESCRIPTION ATTACHED IS ANNEXED HERETO. By virtue of assignments more particularly set forth in the annexed copy of the Complaint, the mortgage was assigned to the Plaintiff. Mr. Dunn, husband of Michaele Dunn, Mrs. Hoshea David Estrada, his wife and Mortgage Electronic Registration Systems, Inc., as nominee for Mortgageit Inc. are made defendants 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 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, Eschen, Frenkel, Weisman & Gordon, LLP Attorneys for Plaintiff Dori L. Scovish, Esq. Summons dated January 23, 2008 (See returns of service for Michaele Dunn, Hoshea David Estrada and Mortgage Electronic Registration Systems, Inc., as nominee for Mortgageit Inc. annexed hereto.) Notice of Dismissal as to Mr. Dunn, husband of Michaele Dunn and Mrs. Hoshea David Estrada, his wife Filed April 29, 2008 2
Request and Certification of Default as to Michaele Dunn; Hoshea David Estrada; Mortgage Electronic Registration Systems, Inc., as nominee for Mortgageit Inc. Filed April 29, 2008 Default Filed April 29, 2008 Notice of Motion for Final Judgment Filed July 6, 2009 The Notice of Motion for Final Judgment is directed to each Michaele Dunn and Hoshea David Estrada at 10 Godfrey Avenue, Roseland, New Jersey 07068 and Mortgage Electronic Registration Systems, Inc., as nominee for Mortgageit Inc. c/o Corporation Trust Company R.A. at 820 Bear Tavern Road, West Trenton, New Jersey 08628. NOTE: WE FAIL TO FIND PROOF OF MAILING OF THE NOTICE OF MOTION FOR FINAL JUDGMENT FILED IN THIS ACTION. Certification as to Mediation Documents Filed January 19, 2010 Certification sets forth that a copy of the Notice of Foreclosure Mediation Availability, Foreclosure Mediation Financial Worksheet, and combination HUD- Certified Housing Counselor Instruction Form and Foreclosure Mediation Recommendation Statement were mailed with the Notice of Motion for Judgment. Certification as to Military Status Filed January 19, 2010 Michaele Dunn and Hoshea David Estrada re not in the military service. Report from the Department of Defense Manpower Data Center annexed thereto. 3
Proof of Mailing Filed January 19, 2010 On June 19, 2009, a copy of the filed default was mailed to each of the defendants at the addresses where they were served with process. Proof of Service of Notice to Cure Pursuant to Fair Foreclosure Act Filed January 19, 2010 On June 19, 2009, a Notice to Cure pursuant to the Fair Foreclosure Act was mailed by regular and certified mail to each Michaele Dunn and Hoshea David Estrada at the following address: 10 Godfrey Avenue, Roseland, New Jersey 07068 As of July 4, 2009, no response has been received to the aforesaid Notice of Intention to Apply for Final Judgment. Certification of Search Fees Filed January 19, 2010 Total fees requested $748.50. Certification of Amount Due RECEIVED January 19, 2010 Certification by a representative of the plaintiff sets forth that there is due the sum of $424,299.85 on its mortgage together with interest to grow due thereon from April 3, 2009. (See copy annexed hereto.) Final Judgment Filed January 19, 2010 (See copy annexed hereto.) 4
NOTE: WE FAIL TO FIND ANY PROOF OF MAILING OF THE FINAL JUDGMENT FILED IN THIS ACTION. Plaintiff s Costs $5,193.91. Writ of Execution issued January 19, 2010 (Writ never returned to Court.) Foreclosure Dismissal Warning Notice for Lack of Prosecution DATED June 28, 2013 Certification of Diligent Inquiry and Accuracy of Foreclosure Documents and Factual Assertions RECEIVED October 31, 2017 Alias Writ of Execution issued December 5, 2017 (Writ not as yet returned to Court.) 5
Certification of Mailing RECEIVED July 10, 2018 On July 3, 2018 a Notice of Sheriff's Sale was mailed by regular and certified mail to each Michaele Dunn and Hoshea David Estrada at 10 Godfrey Avenue, Roseland, New Jersey 07068 and Mortgage Electronic Registration Systems, Inc., as nominee for Mortgageit Inc. c/o Corporation Trust Company R.A. at 820 Bear Tavern Road, West Trenton, New Jersey 08628. 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. 6
THIS CHANCERY ABSTRACT IS CERTIFIED TO MADISON TITLE AGENCY DATED: August 16, 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 7