GREATER ATLANTIC LEGAL SERVICES, INC. LILLIAN ZHANG vs. Plaintiff, BRIDGEVIEW REALTY, LLC; STATE OF NEW JERSEY CHANCERY ABSTRACT Defendants, SUPERIOR COURT OF NEW JERSEY ESSEX COUNTY DOCKET NO. F-029349-16 GREATER ATLANTIC LEGAL SERVICES, INC. hereby certifies to ABRAXAS ABSTRACT INC. 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 # 01824231 TITLE OFFICER
Complaint to Foreclose Tax Lien Filed October 27, 2016 Simeone & Raynor, LLC, Attorneys for Plaintiff Amended Complaint to Foreclose Tax Lien Filed October 27, 2016 Simeone & Raynor, LLC, Attorneys for Plaintiff FIRST COUNT Title of record to the premises became vested in Bridgeview Realty, LLC by deed from Noam Skolnick, dated June 17, 2014, and recorded in the Office of Clerk of Essex County, on June 24, 2014 in Deed Book 12501, Page 3597. The premises in question is described as follows All that certain tract or parcel of land and premises situate in the City of Newark, County of Essex and State of New Jersey, as follows BEING Block 4188, Lot 33 on the tax map of the City of Newark. COMMONLY known as 32 Finlay Place, Newark, New Jersey 07106. Tax Sale Certificate #2014-0142 Taxes were assessed against the premises described in Paragraph 2 herein in the name of Beulah Brent for the year 2013 in the amount of $2,204.14, and the said taxes not having been paid, on September 18, 2014, sale of the lands for delinquent taxes in the City of Newark was made by Ernest Turner, CTC, and by virtue of the provisions of statutes in such case made and provided of the State of New Jersey, which said sale was conducted in all things according to the provisions of such act. At the said sale, the lands and premises described in Paragraph 2 herein were struck off and sold to Lillian Zhang, subject to redemption with interest at 18% (eighteen percent), for the sum of $2,492.84, being the unpaid taxes for the year ending December 31, 2013 in the amount of $2,204.14 plus interest in the amount of $239.82 and costs of sale in the amount of $48.88, which Certificate of Sale was in the form prescribed by State of New Jersey. Said Tax Sale Certificate dated September 18, 2014 was recorded in the Office of the Clerk of Essex County on October 20, 2014 in Book 12521, Page 2031. 1
All subsequent municipal liens which have been assessed against the premises described in Paragraph 2 herein by the City of Newark have been paid (or will be paid) by Plaintiff to the commencement of this action prior to the entry of final judgment. More than two (2) years have elapsed since said sale without redemption and the Plaintiff is the holder of said sale certificate, and taxes and assessments have been accrued and are owing to Plaintiff since the date of said sale. SUBORDINATE LIENS The subordinate liens are more particularly set forth in the annexed copy of the Amended Complaint. There is now due on said Tax Sale Certificate #2014-0085 which is described in Paragraphs 3 and 4 herein, the sum of $2,360.21 plus a premium of $7,000.00 which was the original amount due for unpaid taxes and costs. This amount does not include subsequent taxes, premiums paid thereon or statutory interest due to the Plaintiff. Any interest or lien which any of the defendants have or claim to have in or upon the said Premises described in Paragraph 2 herein or some part thereof, is subject to the lien of Plaintiff's tax sale certificate. WHEREFORE, Plaintiff demands judgment a. Fixing the amount due on said Tax Sale Certificate; b. Barring and foreclosing the defendants of all equity of redemption in and to the lands and premises described in Paragraph 2 above; c. Directing that Plaintiff be paid the amount due on the Certificate, together with interest and costs by a short day to be appointed by this Honorable Court for that purposes, or in default thereof, that the said defendants and all persons claiming by, through or under them be debarred and foreclosed of and from all equity and right of redemption in or to the premises in said certificate of tax sale described in Paragraph 2 herein; and d. Directing that Plaintiff be vested with an absolute and indefeasible estate of inheritance in fee simple in and to the lands described in Paragraph 2 herein. 2
SECOND COUNT By virtue of the entry of judgment in the First Count, Plaintiff is entitled to possession of the premises located in the Township of Irvington, County of Essex, and State of New Jersey, more particularly described in Paragraph 2 of the First Count. Said claims are joined in one action pursuant to R. 427-2. Defendants have at all times since that date deprived Plaintiff of possession of said premises. WHEREFORE, Plaintiff, or its assigns, demands Judgment a. Directing that the said defendants and all persons claiming by, through, or under them be directed to deliver up to the Plaintiff possession of the said land and premises, together with all deeds, papers, and writings in their custody and powers relating to or concerning the said lands and premises or any part thereof; and b. Awarding Plaintiff its costs of suit. By The Amended Complaint is signed, Simeone & Raynor, LLC Attorneys for Plaintiff I. Dominic Simeone Affidavit of Service RECEIVED October 10, 2017 (See return of service annexed hereto) NOTE WE FAIL TO FIND A COPY OF THE NOTICE TO STATE WITHIN THE COURT FILE. Notice of Motion to Substitute Plaintiff RECEIVED August 07, 2017 Notice is directed to, Bridgeview Realty, LLC and State of New Jersey. 3
Certification of Mailing RECEIVED August 07, 2017 Certification in Support of Notice of Motion to Substitute Plaintiff RECEIVED August 07, 2017 Tax Sale Certificate # 2014-0142, which is the subject of the above captioned foreclosure action, was assigned to Harty Holdings, LLC, by Assignment of Tax Sale Certificate dated February 24, 2017, copy attached. Tax Sale Certificate #2014-0142, was recorded in the Office of the Clerk of Essex County on February 24, 2017 as Instrument No. 2017016347 Order Substituting Plaintiff DENIED September 27, 2017 Notice of Motion to Substitute Plaintiff RECEIVED September 27, 2017 Notice is directed to, Bridgeview Realty, LLC and State of New Jersey. Certification of Mailing RECEIVED September 27, 2017 (See copy annexed hereto) Certification in Support of Notice of Motion to Substitute Plaintiff RECEIVED September 27, 2017 Tax Sale Certificate # 2014-0142, which is the subject of the above captioned foreclosure action, was assigned to Harty Holdings, LLC, by Assignment of 4
Tax Sale Certificate dated February 24, 2017, copy attached. Tax Sale Certificate #2014-0142, was recorded in the Office of the Clerk of Essex County on February 24, 2017 as Instrument No. 2017016347 Order Substituting Plaintiff Filed October 12, 2017 IT IS on this 12th day of October, 2017, ORDERED that The complaint in this action be and hereby is amended by striking the name of Lillian Zhang as the party plaintiff; Harty Holdings, LLC be and hereby is substituted in the place and stead of Lillian Zhang as the party plaintiff and all subsequent pleadings filed with the Court shall use the name of the substituted plaintiff in the caption; The Superior Court Clerk is directed to change, as herein modified, the name of the party plaintiff on the automated case management system docket. A copy of this order shall be served on all appearing parties within seven (7) day of the date of this order. Certification of Inquiry for Bridgeview Reality LLC RECEIVED October 12, 2017 (See copy annexed hereto) NOTE CONSIDERATION SHOULD BE GIVEN TO THE ADEQUACY OF THE INQUIRY AS TO BRIDGEVIEW REALITY LLC. Certification of Mailing as to Service for Bridgeview Reality LLC RECEIVED October 12, 2017 (See copy annexed hereto) 5
Notice of Motion for Entry of Default After Six Months RECEIVED October 12, 2017 Notice is directed to, Bridgeview Realty, LLC and State of New Jersey. Certification of Service RECEIVED October 12, 2017 (See copy annexed hereto) Certification in Support of Notice of Motion for Entry of Default after Six Months RECEIVED October 12, 2017 Order for Entry of Default after Six Months RECEIVED October 26, 2017 IT IS on this 26th day of October, 2017, ORDERED that default is hereby entered against the following defendants Bridgeview Realty, LLC and State of New Jersey. Certification of Amount Due RECEIVED December 08, 2017 The certification by the plaintiff sets forth that there is due the sum of $30,534.16 on Tax Sale Certificate. Further, there are no unpaid municipal liens due to the municipality through the date of commencement of this action. 6
Certification of Amount Due (Fees/Costs) RECEIVED December 08, 2017 Total fees requested $1,625.42. Certification of Fees/Costs RECEIVED December 08, 2017 There was no pre-action notice. Notice of Motion for Order Setting Time Place and Amount of Redemption RECEIVED December 08, 2017 Notice is directed to, Bridgeview Realty, LLC and State of New Jersey. Certification of Service RECEIVED December 08, 2017 (See copy annexed hereto) Certification in Support of Notice of Motion for Order Setting Time, Place and Amount of Redemption RECEIVED December 08, 2017 Order Setting Time, Place and Amount of Redemption RECEIVED December 22, 2017 (See copy annexed hereto) 7
Certification of Mailing of Order Setting Time, Place and Amount of Redemption and Amount of Redemption RECEIVED March 12, 2018 On December 28, 2017, a copy of the Order Setting Time, Place and Amount of Redemption and Amount of Redemption and filed Default mailed to each of the defendants at the addresses where they were served with process. On December 28, 2017, a copy of the Order Setting Time, Place and Amount of Redemption and Amount of Redemption and the Statement of Taxed Costs were mailed via regular and certified mail to Ernest Turner, CTC at the City of Newark City Hall Room 101 920Broad St Newark, NJ 07102. On December 30, 2017, a Notice to Redeem was published in the Star-Ledger. (Copy of publication annexed hereto.) Notice of Motion for Entry of Final Judgment RECEIVED March 12, 2018 Notice is directed to, Bridgeview Realty, LLC and State of New Jersey. Certification of Mailing of Motion for Final Judgment RECEIVED March 12, 2018 (See copy annexed hereto) Certification in Support of Notice of Motion for Entry of Final Judgment RECEIVED March 12, 2018 Affidavit of Non-Redemption and Payment of Subsequent Taxes RECEIVED March 12, 2018 Affidavit by the Tax Collector of the City of Newark sets forth that she attended her office on February 05, 2018 at the times appointed and that none of the defendants nor any person acting on their behalf paid or offered to pay the plaintiff the amount 8
required to redeem the premises from the lien of the plaintiff s tax sale certificate. The certification sets forth a copy of the Order Setting Time, Place and Amount of Redemption was mailed on or about December 28, 2017 to the Tax Office. Further, there are no unpaid municipal liens due to the municipality through the date of commencement of this action. Final Judgment Filed April 13, 2018 (See copy annexed hereto.) NOTE WE FAIL TO FIND ANY PROOF OF MAILING OF THE FINAL JUDGMENT FILED IN THIS ACTION. 9
THIS CHANCERY ABSTRACT IS CERTIFIED TO ABRAXAS ABSTRACT INC. DATED AUGUST 15, 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. 10
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SWC F 029349-16 12/22/2017 Pg 1 of 3 Trans ID CHC2017890999 I. Dominic Simeone (006911991) SIMEONE & RAYNOR, LLC 1522 Route 38 Cherry Hill, New Jersey 08002 (856) 663-6700 Attorneys for Plaintiff Lillian Zhang HARTY HOLDINGS, LLC, v. Plaintiff, BRIDGEVIEW REALTY, LLC; and STATE OF NEW JERSEY, Defendants, SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION ESSEX COUNTY DOCKET NO. F-29349-16 CIVIL ACTION ORDER SETTING TIME, PLACE AND AMOUNT OF REDEMPTION This matter being opened to the court by I. Dominic Simeone, Esquire of Simeone & Raynor, LLC, Attorneys for Plaintiff, and it appearing that default has been entered against BRIDGEVIEW REALTY, LLC; and STATE OF NEW JERSEY, and Plaintiff has produced before this Court a certified true copy of Tax Sale Certificate No. 2014-0142, which certificate is dated September 18, 2014 and was recorded in the Office of the Essex County Register of Deeds and Mortgages on October 20, 2014 in Book 12521, Page 2031. Said Tax Sale Certificate # 2014-0142 was assigned to Harty Holdings, LLC, by Assignment of Tax Sale Certificate dated February 24, 2017. Said Tax Sale Certification was recorded in the Office of the Essex County Register of Deeds and Mortgages on February 24, 2017 as Instrument No. 2017016347.
SWC F 029349-16 12/22/2017 Pg 2 of 3 Trans ID CHC2017890999 More than two years have elapsed since the sale of said lands by the City of Newark and the lands have not been redeemed from the tax sale; that Plaintiff has produced before this Court a Certification of Plaintiff, showing that there is due on said tax sale certificate, together with subsequent taxes and interest, the sum of $30,534.16 $28,676.91 as of December 22, 2017; and for good cause shown, IT IS on this 22nd day of December 2017 ORDERED as follows 1. The amount required to redeem the premises referred to in the aforementioned Tax Sale Certificate is the sum of $30,534.16 $28,676.91 as of December 22, 2017, which includes the amount due on said Tax Sale Certificate and subsequent taxes and interest, together with interest on said sums from December 22, 2017, together with costs of suit duly taxed in the sum of $ 0.00. 2. The 5th day of February 2018 between the hours of nine o clock in the forenoon and four o clock in the afternoon, at the office of the Tax Collector of the City of Newark with offices at the Newark City Hall, Room 104, 920 Broad Street, Newark, NJ 07102, shall be and the same is hereby fixed as the time and place for the redemption of the said lands as described in the Complaint and making up the premises concerning which the Complaint is filed, and that thereupon the defendant who redeems shall be entitled to the certificate of tax sale duly endorsed for cancellation. 3. In default of the said defendants paying to the Tax Collector of the City of Newark and the Plaintiff, the said sum, interest and costs aforesaid, the said defendants
SWC F 029349-16 12/22/2017 Pg 3 of 3 Trans ID CHC2017890999 shall stand absolutely debarred and foreclosed of and from all right and equity of redemption on, in and to said lands and premises and every part thereof, and the Plaintiff shall have an absolute and indefeasible interest of inheritance in fee simple to said lands and premises. Anything to the contrary notwithstanding, redemption shall be permitted up until the entry of Final Judgment including the whole of the last date upon which judgment is entered. 4. A copy of this Order or a Notice thereof shall be served upon the defendants whose addresses are known, by mailing to each of them such a copy or notice not later than ten (10) days prior to the date fixed for redemption of the lands and premises by this Order. 5. If the addresses of the defendants are not known, a copy of this Order or Notice thereof directed to such defendants shall be published in The Star Ledger, a newspaper circulating in Essex County, at least one time, not less than ten (10) days prior to the date fixed for redemption by this Order. 6. A copy of this Order shall be delivered to the Tax Collector of the City of Newark and said Tax Collector shall certify to this Court whether the premises were or were not redeemed from the Plaintiff s Tax Sale Certificate in accordance with the terms of this Order. /s/ Paul Innes, P.J.Ch Respectfully Recommended R. 134-6 OFFICE OF FORECLOSURE
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SWC F 029349-16 04/13/2018 Pg 1 of 3 Trans ID CHC2018207008 I. Dominic Simeone (006911991) SIMEONE & RAYNOR, LLC 1522 Route 38 Cherry Hill, New Jersey 08002 (856) 663-6700 Attorneys for Plaintiff Harty Holdings, LLC HARTY HOLDINGS, LLC, v. Plaintiff, BRIDGEVIEW REALTY, LLC; and STATE OF NEW JERSEY, Defendants, SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION ESSEX COUNTY DOCKET NO. F-29349-16 CIVIL ACTION FINAL JUDGMENT (Tax Sale Certificate Foreclosure) THIS CAUSE being opened to the Court by Simeone & Raynor, LLC, Attorneys for Plaintiff, and it appearing to the Court that the complaint filed herein was filed to foreclose the right of redemption of the defendants and to confirm in the plaintiff the fee simple title in and to the premises described in the complaint and hereinafter described; And it appearing that the plaintiff is the holder of Tax Sale Certificate #2014-0142 affecting the premises described in the first count of the complaint, which certificate was made by Ernest Turner, Tax Collector of the City of Newark, and sold to Lillian Zhang, which certificate is dated September 18, 2014 and was recorded in the Office of the Essex County Register of Deeds and Mortgages on October 22, 2014 in Book 12521, Page 2031; Said Tax Sale Certificate was sold by Lillian Zhang to Harty Holdings, LLC, by Assignment of Tax Sale Certificate, dated February 24, 2017, and recorded in the Office of the Essex County Register of Deeds and Mortgages on February 24, 2017 as Instrument No. 2017016347. And it further appearing that there was due as of December 22, 2017 in accordance with the certification of plaintiff duly filed in this cause, for principal,
SWC F 029349-16 04/13/2018 Pg 2 of 3 Trans ID CHC2018207008 interest and subsequent taxes upon said certificate #2014-0142, covering Block 4188, Lot 33, on the tax duplicate of the City of Newark, the sum of $28,676.91. The property is commonly known as 32 Finlay Place, Newark, New Jersey 07106. And it further appearing that default has been entered by the Clerk of the Court against the defendants, BRIDGEVIEW REALTY, LLC AND THE STATE OF NEW JERSEY, and the court by its order made on December 22, 2017, fixed February 5, 2018, between the hours of nine o clock in the forenoon and four o clock in the afternoon, at the office of the tax collector of the City of Newark, City Hall, Room 104, 920 Broad Street, Newark, New Jersey 07102, as the time and place for the redemption of the premises upon payment thereof, the defendant who redeems shall be entitled to the tax sale certificate duly endorsed for cancellation; And it further appearing from the Certification of Mailing duly filed herein that the notice of redemption was duly mailed by certified mail, return receipt requested and by regular mail in accordance with the terms of the order of the court concerning the defendants whose addresses are known; And it further appearing from the affidavit of Ernest Turner, Tax Collector of the City of Newark, that he attended at his office at the City of Newark City Hall, Room 104, 920 Broad Street, Newark, New Jersey 07102 on the 5 th day of February, between the hours of nine o clock in the forenoon and four o clock in the afternoon, and had in his possession the tax sale certificate aforesaid ready for cancellation in accordance with the terms of the said order herein; that neither the defendants nor any persons acting on their behalf, appeared before him at the time and place aforesaid; that neither the defendants nor any persons acting on their behalf paid or offered to pay to the plaintiff the sum of money mentioned above found to be due to the plaintiff, at the time and place aforesaid; and that the said sum and said costs still remain due and owing to plaintiff. IT IS therefore on this 13th day of, April 2018, ORDERED AND ADJUDGED that the defendants, BRIDGEVIEW REALTY, LLC AND THE STATE OF NEW JERSEY, and all persons claiming by, from or under them, stand absolutely debarred and foreclosed of and from any and all right, and equity of redemption, in and to the lands and every part thereof, which lands and premises are more particularly described as follows All that certain tract or parcel of land and premises situate in the City of Newark, County of Essex and State of New Jersey, as follows
SWC F 029349-16 04/13/2018 Pg 3 of 3 Trans ID CHC2018207008 BEING Block 4188, Lot 33 on the tax map of the City of Newark. COMMONLY known as 32 Finlay Place, Newark, New Jersey 07106. AND it is further ORDERED AND ADJUDGED that the plaintiff, HARTY HOLDINGS, LLC, whose address is 1922 Morris Avenue Unit #226, Union, NJ 07083, is vested with an absolute and indefeasible estate of inheritance in fee simple to the premises above described; AND it is FURTHER ORDERED AND ADJUDGED that the plaintiff HARTY HOLDINGS, LLC, duly recover against the defendants, BRIDGEVIEW REALTY, LLC AND THE STATE OF NEW JERSEY, and all parties claiming by, through or under them, the possession of the said lands and premises described and mentioned in the complaint and this judgment. NOTWITHSTANDING anything herein to the contrary, this judgment shall not affect the rights of any person protected by the New Jersey Tenant Anti-Eviction Act, N.J.S.A. 2A18-61.1, et seq., the right of redemption given the United States under 28 U.S.C. 2410, the limited priority rights for the aggregate customary condominium assessment for the six month period prior to the recording of any association lien as allowed by N.J.S.A. 458B-21 or rights afforded by the Service Members Civil Relief Act, 50 U.S.C. App. 501, et seq., or N.J.S.A. 3823C-4; /s/ Paul Innes PAUL INNES, P. J. Ch Respectfully Recommended R. 134-6 OFFICE OF FORECLOSURE I, Michelle M. Smith, Clerk of the Superior Court of New Jersey, the same being a Court of Record, do hereby certify that the foregoing is a true copy of the FINAL JUDGMENT now on file in my office. IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of said Court at Trenton, this 13th day of April Two Thousand Eighteen. /s/ Michelle M. Smith MICHELLE M. SMITH, ESQ. Clerk of the Superior Court Signed and Sealed in the Superior Court of New Jersey