GREATER ATLANTIC LEGAL SERVICES, INC. CHANCERY ABSTRACT QUEEN'S PARK OVAL ASSET HOLDING TRUST, vs. Plaintiff, TAUNYA TURNER, his/her heirs, devisees, and personal representatives, and his, her, their or any of their successors in right, title and interest; MR. TURNER, husband of Taunya Turner; FORD MOTOR CREDIT COMPANY; ENCOMPASS PROPERTY & CASUALTY Insurance Company of New Jersey; AMERICA GENERAL FINANCE INC.; OUR LADY OF LOURDES MEDICAL CENTER; CAMDEN COUNTY BOARD OF SOCIAL SERVICES; PORTFOLIO RECOVERY ASSOC. LLC; UNITED STATES OF AMERICA, Defendants, SUPERIOR COURT OF NEW JERSEY CAMDEN COUNTY DOCKET NO. F-038486-14 GREATER ATLANTIC LEGAL SERVICES, INC. hereby certifies to DATA TRACE AND LENDERLIVE 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 # LLSS520-323093 TITLE OFFICER
Complaint to Foreclose Filed September 15, 2014 Zucker, Goldberg & Ackerman, LLC, Attorneys for Plaintiff FIRST COUNT Complaint filed to foreclose mortgage made and executed by Taunya Turner to American Residential Mortgage to secure the sum of $46,937.00. Obligation and mortgage dated March 5, 2001. The mortgage was recorded in Camden County on March 21, 2001 in Book 5474, Page 759. 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. Mr. Turner, husband of Taunya Turner; Ford Motor Credit Company; Encompass Property & Casualty Insurance Company of New Jersey; America General Finance Inc.; Our Lady of Lourdes Medical Center; Camden County Board of Social Services; Portfolio Recovery Assoc. LLC and United States of America is/are made defendant(s) for reasons more particularly set forth in the annexed copy of the Complaint. In the event plaintiff is unable to determine the present whereabouts of defendant(s) Taunya Turner or ascertain if he/she/they is/are presently alive, and as a precaution, plaintiff has joined the following persons as party defendants to this foreclosure action for any lien, claim or interest they may have in, to, or against the mortgaged premises: Taunya Turner; his/her/their heirs, devisees and personal representatives, and his/her/their or any of their successors in right, title and interest. 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. 1
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. 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 Plaintiff repeats and re-alleges each and every allegation to the first two counts of the Complaint as if each were set forth herein at length. Inadvertently and due to typographical error, the First of the legal description attached to plaintiff's recorded mortgage incorrectly reads as: 1975 Feet when in fact the First Course of the metes and bounds should read as follows: 19. 75 Feet. WHEREFORE, plaintiff demands judgment on the third count of this Complaint reforming plaintiff's mortgage to correct the First course of the metes and bounds to read as follows: 19.75 Feet. By: The Complaint is signed, ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff Monika S. Pundalik, Esq. 2
Summons dated September 26, 2014 (See return(s) and/or acknowledgment(s) of service for Taunya Turner, Our Lady of Lourdes Medical Center, Camden County Board of Social Services, Springleaf Financial Services, Inc f/k/a America General Finance Inc., United States of America, Ford Motor Credit Company and Encompass Property & Casualty Insurance Company of New Jersey annexed hereto.) Notice of Motion to Correct Defendant's Name America General Finance Inc. Filed January 16, 2015 Notice directed to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021, Ford Motor Credit Company R/A Corporation Trust Company at 820 Bear Tavern Road, Trenton, NJ 08628, Encompass Property & Casualty Insurance Company of New Jersey C/O Law Offices of Steven G. Kraus at 122 Mount Bethel Road, Warren, NJ 07059, Springleaf Financial Services, Inc f/k/a America General Finance Inc. R/A Corporation Trust Company at 820 Bear Tavern Road, West Trenton, NJ 08628, Our Lady of Lourdes Medical Center C/O Lee S. Dennison Esq at 231 High Street, Mount Holly, NJ 08060, Camden County Board of Social Services at Althea Wright Administration Building 600 Market Street, Camden, NJ 08102, Portfolio Recovery Assoc. LLC at 140 Corporate Boulevard, Suite 100, Norfolk, VA 23502, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001. Certification of Mailing RECEIVED January 16, 2015 On January 16, 2015, a copy of the Notice of Motion, Supporting Certification and Proposed Order was sent via certified and regular mail to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021, Ford Motor Credit Company R/A Corporation Trust Company at 820 Bear Tavern Road, Trenton, NJ 08628, Encompass Property & Casualty Insurance Company of New Jersey C/O Law Offices of Steven G. Kraus at 122 Mount Bethel Road, Warren, NJ 07059, Springleaf Financial Services, Inc f/k/a America General Finance Inc. R/A Corporation Trust Company at 820 Bear Tavern Road, West Trenton, NJ 08628, Our Lady of Lourdes Medical Center C/O Lee S. Dennison Esq at 231 High Street, Mount Holly, NJ 08060, Camden County Board of Social Services at Althea Wright Administration Building 600 Market Street, Camden, NJ 3
08102, Portfolio Recovery Assoc. LLC at 140 Corporate Boulevard, Suite 100, Norfolk, VA 23502, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001. Certification Correcting Defendant's Name RECEIVED January 16, 2015 After diligent inquiry, this firm has determined that the caption of the Complaint, or Amended Complaint, if any, incorrectly designates defendant as America General Finance Inc. wherein the correct designation should be Springleaf Financial Services, Inc. f/k/a America General Finance Inc. Order Correcting Name of Defendant, America General Finance Inc. Filed February 13, 2015 IT IS ON THIS 13th DAY OF February' 2015. ORDERED, that the caption of the Complaint, or Amended Complaint, if any, and subsequent pleadings are hereby corrected to properly designate defendant as Springleaf Financial Services, Inc. f/k/a America General Finance Inc. instead of America General Finance Inc. Certification of Mailing Summons and Complaint to Attorney General of the United States of America RECEIVED February 27, 2015 On January 16, 2015, a copy of the Summons and Complaint was mailed via certified mail to United States of America c/o Attorney General, 950 Pennsylvania Avenue, N.W. Washington, DC 20530. A copy of the 60 day Summons and a signed return receipt directed to the aforesaid defendant indicating delivery on October 6, 2014 annexed thereto. 4
Certification of Inquiry and Mailing Summons and Complaint to Defendant Portfolio Recovery Assoc LLC by Regular Mail and Certified Mail and Summons RECEIVED February 27, 2015 On September 26, 2014, A copy of the Summons and Complaint was sent via certified and regular mail to Portfolio Recovery Assoc., LLC at140 Corporate Boulevard Suite 100, Norfolk, VA 23502. A signed return receipt directed to the aforesaid defendant at indicating delivery on October 3, 2014 annexed thereto. Notice of Dismissal as to Mr. Turner, Husband of Taunya Turner Filed February 27, 2015 Notice of Dismissal as to the heirs, devisees, etc of Taunya Turner Filed February 27, 2015 Notice of Motion for Entry of Default Filed February 27, 2015 Notice directed to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021, Ford Motor Credit Company R/A Corporation Trust Company at 820 Bear Tavern Road, Trenton, NJ 08628, Encompass Property & Casualty Insurance Company of New Jersey C/O Law Offices of Steven G. Kraus at 122 Mount Bethel Road, Warren, NJ 07059, Springleaf Financial Services, Inc f/k/a America General Finance Inc. R/A Corporation Trust Company at 820 Bear Tavern Road, West Trenton, NJ 08628, Our Lady of Lourdes Medical Center C/O Lee S. Dennison Esq at 231 High Street, Mount Holly, NJ 08060, Camden County Board of Social Services at Althea Wright Administration Building 600 Market Street, Camden, NJ 08102, Portfolio Recovery Assoc. LLC at 140 Corporate Boulevard, Suite 100, Norfolk, VA 23502, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001. 5
Certification of Mailing Notice of Motion for Entry of Default with Supporting Certification and Proposed Form or Order for Entry of Default RECEIVED February 27, 2015 On February 27, 2015, a copy of the Notice of Motion for Entry of Default, Supporting Certification and Proposed Form of Order for Entry of Default was sent via certified and regular mail to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021, Ford Motor Credit Company R/A Corporation Trust Company at 820 Bear Tavern Road, Trenton, NJ 08628, Encompass Property & Casualty Insurance Company of New Jersey C/O Law Offices of Steven G. Kraus at 122 Mount Bethel Road, Warren, NJ 07059, Springleaf Financial Services, Inc f/k/a America General Finance Inc. R/A Corporation Trust Company at 820 Bear Tavern Road, West Trenton, NJ 08628, Our Lady of Lourdes Medical Center C/O Lee S. Dennison Esq at 231 High Street, Mount Holly, NJ 08060, Camden County Board of Social Services at Althea Wright Administration Building 600 Market Street, Camden, NJ 08102, Portfolio Recovery Assoc. LLC at 140 Corporate Boulevard, Suite 100, Norfolk, VA 23502, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001. Certification in Support of Order Permitting Entry of Default RECEIVED February 27, 2015 Order for Entry of Default Filed March 23, 2015 IT is on this 23rd day of March, 2015 ORDERED that default is hereby entered against the defendants Taunya Turner; Ford Motor Credit Company; Encompass Property & Casualty Insurance Company of New Jersey; Springleaf Financial Services, Inc. f/k/a America General Finance Inc.; Our Lady of Lourdes Medical Center; Camden County Board of Social Services; Portfolio Recovery Assoc. LLC; United States of America 6
Default Filed March 23, 2015 Substitution of Attorney Filed July 28, 2015 Zucker, Goldberg & Ackerman, LLC, do hereby consent to the substitution of Phelan Hallinan & Diamond, as Attorneys for Plaintiff. Notice of Motion to Allow for Service of Remedial Notice of Intention to Foreclose Filed March 9, 2016 Notice directed to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021. Motion Returnable April 1, 2016. Attorney Certification in Support of Motion Allowing Service of Remedial Notice of Intention to Foreclose RECEIVED March 9, 2016 Certification sets forth Since the substitution of attorney has been filed, Plaintiffs counsel has undertaken the review of all documents and pleadings to ascertain the status of the within matter and to determine what course of action is next required. During said review, it was ascertained that the aforementioned Notice of Intention to Foreclose contained one or more error(s). Because the Order to Show Cause process is no longer available to Plaintiff as a remedy, Plaintiff respectfully requests the relief in the within motion as a matter of equity. Certification of Filing and Service RECEIVED March 9, 2016 On March 9, 2016, a copy of the R.1:5-4(b) Certification in Lieu of Oath was sent via certified and regular mail to Taunya Turner at 550 Bilper Avenue, Apt 5608, 7
Lindenwold, NJ 08021. Memorandum of Law RECEIVED March 9, 2016 Order Allowing Service of Remedial Notice of Intention to Foreclose Filed April 1, 2016 IT IS on this 1st day of April, 2016, ORDERED as follows: 1. Plaintiff is hereby ordered and allowed to send a new Notice of Intent to Foreclose, in full compliance with the Fair Foreclosure Act, to the Defendant(s) ; and 2. Defendant(s) shall be allowed the opportunity to cure the arrears, without foreclosure fees/costs pursuant to the Fair Foreclosure Act; and 3. If the Defendant(s) are unable to cure the arrears, Plaintiff may proceed with the within foreclosure action as an uncontested matter. Proof of Mailing Order Allowing Service of Notice of Remedial Intention to Foreclose RECEIVED May 23, 2016 On May 23, 2016, a copy of the Order Allowing Service of Notice of Remedial Intention to Foreclose was sent via certified and regular mail to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021. Proof of Mailing Received November16, 2016 On October 24, 2016, a copy of the filed default was mailed to each at the addresses where they were served with summons and complaint. 8
Proof of Mailing of Tenants' Rights Pursuant to R 4:64-1 Received November 18, 2016 On October 28, 2016, a Notice to Residential Tenants of Rights During Foreclosure was mailed by regular and certified mail to each Tenant and Inquilino, at 214 Maple Avenue, Oaklyn, NJ 08107-2202. Proof of Service of Notice to Cure Pursuant to Fair Foreclosure Act Received December 1, 2016 On October 27, 2016, a Notice to Cure pursuant to the Fair Foreclosure Act was mailed by regular and certified mail to Taunya Turner at the following addresses: 214 Maple Avenue, Oaklyn, NJ 08107 and 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021. More than ten days have passed since receipt of the notice by the debtor. Foreclosure Dismissal Notice (Lack of Prosecution) Filed April 7, 2017 Attorney Certification in Opposition to the Court's Notice to Dismiss for Lack of Prosecution Under R. 4:64-8 RECEIVED May 5, 2017 DENIED CLERK'S NOTATION: CERTIFICATION DOES NOT SET FORTH EXCEPTIONAL CIRCUMSTANCES. Foreclosure Dismissal Order Filed May 12, 2017 It is hereby Ordered that Pursuant to Rule 4:64-8, The Above-Captioned matter has been Dismissed without Prejudice for Lack of Prosecution. Reinstatement of the matter after Dismissal may be Requested by a Motion for Good Cause. 9
Notice of Motion to Reinstate Case to Active Status Filed June 19, 2017 Notice directed to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021, Ford Motor Credit Company R/A Corporation Trust Company at 820 Bear Tavern Road, Trenton, NJ 08628, Encompass Property & Casualty Insurance Company of New Jersey C/O Law Offices of Steven G. Kraus at 122 Mount Bethel Road, Warren, NJ 07059, Springleaf Financial Services, Inc f/k/a America General Finance Inc. R/A Corporation Trust Company at 820 Bear Tavern Road, West Trenton, NJ 08628, Our Lady of Lourdes Medical Center C/O Lee S. Dennison Esq at 231 High Street, Mount Holly, NJ 08060, Camden County Board of Social Services at Althea Wright Administration Building 600 Market Street, Camden, NJ 08102, Portfolio Recovery Assoc. LLC at 140 Corporate Boulevard, Suite 100, Norfolk, VA 23502, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001. Certification of Mailing Notice of Motion RECEIVED June 19, 2017 On June 19, 2017, a copy of the Notice of Motion to Reinstate Case to Active Status, Memorandum of Law, Certification in Support, Proof of Mailing and Proposed Order was sent via certified and regular mail to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021, Ford Motor Credit Company R/A Corporation Trust Company at 820 Bear Tavern Road, Trenton, NJ 08628, Encompass Property & Casualty Insurance Company of New Jersey C/O Law Offices of Steven G. Kraus at 122 Mount Bethel Road, Warren, NJ 07059, Springleaf Financial Services, Inc f/k/a America General Finance Inc. R/A Corporation Trust Company at 820 Bear Tavern Road, West Trenton, NJ 08628, Our Lady of Lourdes Medical Center C/O Lee S. Dennison Esq at 231 High Street, Mount Holly, NJ 08060, Camden County Board of Social Services at Althea Wright Administration Building 600 Market Street, Camden, NJ 08102, Portfolio Recovery Assoc. LLC at 140 Corporate Boulevard, Suite 100, Norfolk, VA 23502, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001. 10
Certification in Support of Order to Reinstate Case to Active Status RECEIVED June 19, 2017 Memorandum of Law RECEIVED June 19, 2017 Order Reinstating Case to Active Status Filed July 5, 2017 IT IS on this day of, 2017, ORDERED that The case of Queen's Park Oval Asset Holding Trust Vs. Taunya Turner, etal., Docket Number F-038486-14, which was dismissed for lack of prosecution, be and is hereby reinstated as of record. Proof of Mailing Order Restating Case to Active Status RECEIVED July 11, 2017 On July 7, 2017, a copy of the Order Reinstating Case to Active Status was sent via certified and regular mail to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021, Ford Motor Credit Company R/A Corporation Trust Company at 820 Bear Tavern Road, Trenton, NJ 08628, Encompass Property & Casualty Insurance Company of New Jersey C/O Law Offices of Steven G. Kraus at 122 Mount Bethel Road, Warren, NJ 07059, Springleaf Financial Services, Inc f/k/a America General Finance Inc. R/A Corporation Trust Company at 820 Bear Tavern Road, West Trenton, NJ 08628, Our Lady of Lourdes Medical Center C/O Lee S. Dennison Esq at 231 High Street, Mount Holly, NJ 08060, Camden County Board of Social Services at Althea Wright Administration Building 600 Market Street, Camden, NJ 08102, Portfolio Recovery Assoc. LLC at 140 Corporate Boulevard, Suite 100, Norfolk, VA 23502, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001. 11
Notice of Motion for Entry of Order Substituting Plaintiff Filed August 31, 2017 Notice directed to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001. Proof of Mailing Notice of Motion for Entry of Order Substituting Plaintiff RECEIVED August 31, 2017 On August 30, 2017, a copy of the Order Substituting Plaintiff was mailed to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001. NOTE: WE CALL YOUR ATTENTION TO THE FACT THAT THE CERTIFICATION OF SERVICE OF THE NOTICE OF MOTION FOR ENTRY OF ORDER SUBSTITUTING PLAINTIFF DOES NOT SPECIFY THAT THE NOTICE WAS SERVED VIA CERTIFIED MAIL Certification in Support of Order Substituting Plaintiff RECEIVED August 31, 2017 It has been ascertained that on 05/19/2017, Queen's Park Oval Asset Holding Trust By: Roundpoint Mortgage Servicing Corporation its Attorney in Fact assigned said mortgage to Trent Bridge Asset Holding Trust, recorded on 06/14/2017 in Book 10648, Page 315. It has been ascertained that on 07/20/2017, Trent Bridge Asset Holding Trust By: Roundpoint Mortgage Servicing Corporation its Attorney in Fact assigned said mortgage to Carisbrook Asset Holding Trust, recorded on 08/18/2017 in Book 10689, Page 918. 12
Order Substituting Plaintiff Filed September 22, 2017 It is on this day 22ndday of September, 2017, ORDERED and ADJUDGED that: 1. The complaint in this action be and hereby is amended by striking the name of Queen's Park Oval Asset Holding Trust. 2. Carisbrook Asset Holding Trust be and hereby is substituted in the place and stead of Queen's Park Oval Asset Holding Trust as the party plaintiff and all subsequent pleadings be filed with the Court shall use the name of the substituted plaintiff in the caption. 3. The Superior Court Clerk is directed to change, as herein modified, the name of the party plaintiff on the automated case management system docket. 4. A copy of the order shall be served on all appearing parties within Seven (7) days of the date of this order. Proof of Mailing Order Substituting Plaintiff RECEIVED September 29, 2017 On September 28, 2017, a copy of the Order Substituting Plaintiff was sent via certified and regular mail to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001. Certification/Affidavit of Diligent Inquiry and Accuracy of Foreclosure Documents and Factual Assertions RECEIVED February 28, 2018 Proof of Mailing of Tenants' Rights Pursuant to R 4:64-1 Received March 23, 2018 On March 23, 2018, a Notice to Residential Tenants of Rights During Foreclosure was mailed by regular and certified mail to each Tenant and Inquilino, at 214 Maple Avenue, Oaklyn, NJ 08107-2202. 13
Proof of Service of Notice to Cure Pursuant to Fair Foreclosure Act Received April 24, 2018 On April 9, 2018, a Notice to Cure pursuant to the Fair Foreclosure Act was mailed by regular and certified mail to Taunya Turner at the following addresses: 214 Maple Avenue, Oaklyn, NJ 08107 and 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021. More than ten days have passed since receipt of the notice by the debtor. Administrative Order Requiring a Certification Setting Forth the Status of a Pending Foreclosure Matter Filed May 8, 2018 It is hereby Ordered that the Plaintiff shall file a certification setting forth the status of this pending foreclosure matter, including when it is anticipated that the matter will move to judgment or otherwise be resolved. That certification shall be filed on or before May 21, 2018. Certification/Affidavit of Diligent Inquiry and Accuracy of Foreclosure Documents and Factual Assertions RECEIVED May 18, 2018 Notice of Motion for Final Judgment Filed May 18, 2018 The Notice of Motion for Final Judgment is directed to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021, Ford Motor Credit Company R/A Corporation Trust Company at 820 Bear Tavern Road, Trenton, NJ 08628, Encompass Property & Casualty Insurance Company of New Jersey C/O Law Offices of Steven G. Kraus at 122 Mount Bethel Road, Warren, NJ 07059, Springleaf Financial Services, Inc f/k/a America General Finance Inc. R/A Corporation Trust Company at 820 Bear Tavern Road, West Trenton, NJ 08628, Our Lady of Lourdes Medical Center C/O Lee S. Dennison Esq at 231 High Street, Mount Holly, NJ 08060, Camden County Board of Social Services at Althea Wright Administration Building 600 Market Street, Camden, NJ 08102, Portfolio Recovery Assoc. LLC at 140 Corporate Boulevard, Suite 100, Norfolk, 14
VA 23502, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001. Proof of Service of Notice of Motion for Final Judgment RECEIVED May 18, 2018 On May 15, 2018, the Notice of Motion for Final Judgment, Certification of Diligent Inquiry pursuant to R 4:64-2, Certification of Proof of Amount Due and Notice to Tenants (if applicable) were mailed to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021, Ford Motor Credit Company R/A Corporation Trust Company at 820 Bear Tavern Road, Trenton, NJ 08628, Encompass Property & Casualty Insurance Company of New Jersey C/O Law Offices of Steven G. Kraus at 122 Mount Bethel Road, Warren, NJ 07059, Springleaf Financial Services, Inc f/k/a America General Finance Inc. R/A Corporation Trust Company at 820 Bear Tavern Road, West Trenton, NJ 08628, Our Lady of Lourdes Medical Center C/O Lee S. Dennison Esq at 231 High Street, Mount Holly, NJ 08060, Camden County Board of Social Services at Althea Wright Administration Building 600 Market Street, Camden, NJ 08102, Portfolio Recovery Assoc. LLC at 140 Corporate Boulevard, Suite 100, Norfolk, VA 23502, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001 and Tenant at 214 Maple Avenue, Woodlynne, NJ 08107-2202. 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/Affidavit of Non-Military Service or Inability to Ascertain Military Status RECEIVED May 18, 2018 Taunya Turner is/are not in the military service. Report(s) from the Department of Defense Manpower Data Center annexed thereto. 15
Proof of Mailing RECEIVED May 18, 2018 On October 24, 2016, 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 Received May 18, 2018 On April 9, 2018, a Notice to Cure pursuant to the Fair Foreclosure Act was mailed by regular and certified mail to Taunya Turner at the following addresses: 214 Maple Avenue, Oaklyn, NJ 08107 and 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021. More than ten days have passed since receipt of the notice by the debtor. Certification/Affidavit of Costs/Search Fees RECEIVED May 18, 2018 Total fees requested $450.00. Certification/Affidavit of Amount Due RECEIVED May 18, 2018 Certification/Affidavit by a representative of the plaintiff sets forth that there is due the sum of $125,029.09 on its mortgage together with interest to grow due thereon from March 30, 2018. (See copy annexed hereto.) Certification Correcting Clerical Error RECEIVED May 18, 2018 It has been ascertained that the first course of the legal description attached to the plaintiff s recorded mortgage incorrectly reads as 1975 Feet. The first course of the legal description attached to the plaintiff s recorded mortgage should set forth 19.75 Feet. It has been ascertained that the first course of the legal description attached to the 16
complaint incorrectly sets forth Southwardly feet. The first course of the legal description attached to the complaint should set forth Southwardly 19.75 feet. Attorney Certification in Response to Administrative Order Requiring A Certification Setting Forth The Status of a Pending Foreclosure Matter RECEIVED May 21, 2018 Certification sets forth The status of the within Foreclosure matter is that a Motion for Final Judgment was submitted to the Court for filing on May 18, 2018. As of May 18, 2018, Final Judgment is pending entry by the Court. Final Judgment Filed June 8, 2018 (See copy annexed hereto.) Plaintiff s Costs $2,200.29. Writ of Execution issued June 8, 2018 (Not as yet returned into Court.) Proof of Mailing RECEIVED June 13, 2018 On June 11, 2018, a copy of the filed Final Judgment was mailed to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021 and 214 Maple Avenue, Woodlynne, NJ 08107-2202, Ford Motor Credit Company R/A Corporation Trust Company at 820 Bear Tavern Road, Trenton, NJ 08628, Encompass Property & Casualty Insurance Company of New Jersey C/O Law Offices of Steven G. Kraus at 122 Mount Bethel Road, Warren, NJ 07059, Springleaf 17
Financial Services, Inc f/k/a America General Finance Inc. R/A Corporation Trust Company at 820 Bear Tavern Road, West Trenton, NJ 08628, Our Lady of Lourdes Medical Center C/O Lee S. Dennison Esq at 231 High Street, Mount Holly, NJ 08060, Camden County Board of Social Services at Althea Wright Administration Building 600 Market Street, Camden, NJ 08102, Portfolio Recovery Assoc. LLC at 140 Corporate Boulevard, Suite 100, Norfolk, VA 23502, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001 and Tenant at 214 Maple Avenue, Woodlynne, NJ 08107-2202. Certification/Affidavit of Mailing RECEIVED July 18, 2018 On July 16, 2018, a Notice of Sheriff's Sale was mailed by regular and certified mail to Taunya Turner at 550 Bilper Avenue, Apt 5608, Lindenwold, NJ 08021 and 214 Maple Avenue, Woodlynne, NJ 08107-2202, United States of America C/O United States Attorney for the District of New Jersey at 970 Broad Street, Newark, NJ 07102 and United States of America C/o Attorney General at U.S. Dept of Justice-950 Pennsylvania Avenue, NW, Washington, DC 20530-0001. LAST ENTRY 18
THIS CHANCERY ABSTRACT IS CERTIFIED TO DATA TRACE AND LENDERLIVE DATED: September 10, 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 tll 19
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SWC F 038486-14 06/08/2018 Pg 1 of 3 Trans ID: CHC2018327066 681997 PHELAN HALLINAN DIAMOND & JONES, PC 400 Fellowship Road Suite 100 Mt. Laurel, NJ 08054 856-813-5500 Attorney for Plaintiff CARISBROOK ASSET HOLDING TRUST PLAINTIFF TAUNYA TURNER, ET AL. DEFENDANT (S) SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION CAMDEN COUNTY DOCKET NO: F-038486-14 CIVIL ACTION FINAL JUDGMENT This matter having been opened to the Court by Phelan Hallinan Diamond & Jones, PC attorney s for plaintiff, and it appearing that service of the Summons and Complaint has/have been made upon the defendants, in accordance with the Rules of this Court and default having been entered against all non-answering defendants; and plaintiff s obligation, Mortgage and assignment of Mortgage having been presented and marked as exhibits by the Court, and proof having been submitted of the amount due on the plaintiff s Mortgage and sufficient cause appearing: It is on June 8, 2018 ORDERED and ADJUDGED that the plaintiff is entitled to have the sum of $125,029.09 together with interest at the Contract rate of 7% on $99,453.78 being the principal sum in default including advances from March 31, 2018 to June 8, 2018 and lawful interest thereafter on the total sum due to plaintiff together with costs of this suit to be taxed including counsel fee of $1,400.29 raised and paid in the first place out of the mortgaged premises and it is further ordered that the plaintiff, its assignee or purchaser at sale recover against the following defendants: TAUNYA TURNER
SWC F 038486-14 06/08/2018 Pg 2 of 3 Trans ID: CHC2018327066 and all parties holding under said defendants the possession of the premises so mentioned and described in the said Complaint with the appurtenances; and it is further ORDERED and ADJUDGED that the mortgaged premises be sold to raise and satisfy the several sums of money due, in the first place to the plaintiff, CARISBROOK ASSET HOLDING TRUST, in the sum of $125,029.09 together with contract and lawful interest thereon to be computed as aforesaid, the plaintiff s costs to be taxed, with interest thereon, and that an execution for the purpose be duly issued out of this Court directed to the Sheriff of CAMDEN County, commanding said Sheriff to make sale according to law of the mortgaged premises, as described in the Complaint, and out of the money arising from said sale, that said Sheriff pay in the first place, to the plaintiff, said plaintiff s debt, with interest thereon as aforesaid and said plaintiff s costs with interest thereon as aforesaid, and in case more money shall be realized by the said sale than shall be sufficient to satisfy such several payments as aforesaid, that such surplus be brought into this Court to abide the further Order of this Court and that the Sheriff aforesaid make a report of the aforesaid sale without delay as required by the rules of this Court, and it is further ORDERED and ADJUDGED that the defendants in this cause, and each of them stand absolutely debarred and foreclosed of and from all equity of redemption of, in and to said mortgaged premises described in the Complaint, when sold as aforesaid by virtue of this judgment except as provided by 28 U.S.C. 2410. ORDERED and ADJUDGED that the first course of the legal description attached to the plaintiff s recorded mortgage incorrectly reads as 1975 Feet. The first course of the legal description attached to the plaintiff s recorded mortgage should set forth 19.75 Feet. It is further ORDERED AND ADJUDGED that the question of priority between plaintiff and the defendant United States of America as to late charges and any interest on advances shall
SWC F 038486-14 06/08/2018 Pg 3 of 3 Trans ID: CHC2018327066 await surplus money proceedings, if any. This judgment shall not affect the right of any person protected by the provisions of the New Jersey Tenant Anti-Eviction Statute (NJSA 2A: 18-61.1 et seq.). Respectfully Recommended R. 1:34-6 Office of Foreclosure /s/ Nan S. Famular NAN S. FAMULAR, P.J.Ch.