GREATER ATLANTIC LEGAL SERVICES, INC. CHANCERY ABSTRACT QUICKEN LOANS INC. Plaintiff, vs. KIMBERLY MCKENZIE AND CHRISTOPHER MCKENZIE, wife and husband Defendants, SUPERIOR COURT OF NEW JERSEY MONMOUTH COUNTY DOCKET NO. F-000486-16 GREATER ATLANTIC LEGAL SERVICES, INC. hereby certifies to COASTAL TITLE AGENCY, 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 # CT-71420 TITLE OFFICER
Complaint to Foreclose FILED January 7, 2016 KML Law Group, P.C., Attorneys for Plaintiff FIRST COUNT Complaint filed to foreclose mortgage made and executed by Kimberly McKenzie and Christopher McKenzie to Mortgage Electronic Registration System Inc. Solely as Nominee for Quicken Loans Inc. to secure the sum of $184,828.00. Obligation and mortgage dated March 4, 2013. The mortgage was recorded in Monmouth County on March 11, 2013 in Book OR-9001, Page 3563. THIS IS NOT 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. 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 repeats and reiterates all the allegations contained in the First Count and makes them part hereof as though fully set forth. 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, KML Law Group, P.C. Attorneys for Plaintiff Jamie R. Ackerman Summons dated February 2, 2016 (See return(s) of service for Kimberly McKenzie and Christopher McKenzie annexed hereto.) NOTE: WE CALL YOUR ATTENTION TO THE FACT THAT THE SUMMONS SERVED UPON KIMBERLY MCKENZIE AND CHRISTOPHER MCKENZIE DOES NOT APPEAR TO CONFORM WITH RULE 4:4-2 IN THAT IT FAILS TO CONTAIN A CURRENT LISTING BY COUNTY OF TELEPHONE NUMBERS OF THE LEGAL SERVICES OFFICE AND THE LAWYER REFERRAL OFFICE SERVING EACH COUNTY. Foreclosure Dismissal Warning Notice for Lack of Prosecution DATED January 13, 2017 2
Notice of Motion for Entry of Default FILED February 8, 2017 The Notice of Motion for Entry of Default is directed to Kimberly McKenzie and Christopher McKenzie. Certification/Affidavit in Support of Motion for Entry of Default RECEIVED February 8, 2017 Proof of Mailing of Notice of Motion RECEIVED February 8, 2017 On February 8, 2017 a copy of the Notice of Motion for Entry of Default was mailed by regular and certified mail to Kimberly McKenzie and Christopher McKenzie. (See copy annexed hereto) Order for Entry of Default FILED February 28, 2017 It is on this 28th day of February, 2017 ORDERED that default is hereby entered against Kimberly McKenzie and Christopher McKenzie. Notice of Motion for Entry of Order Substituting Plaintiff FILED April 12, 2017 The Notice of Motion is directed to Kimberly McKenzie and Christopher McKenzie. 3
Certification/Affidavit in Support of Order Substituting Plaintiff RECEIVED April 12, 2017 The certification sets forth that on March 9, 2017 the mortgage was assigned to Bayview Loan Servicing, LLC. The assignment was recorded on March 17, 2017 in Book OR-9217, Page 8655. Proof of Mailing RECEIVED April 12, 2017 On April 12, 2017 the Notice of Motion was mailed in separate envelopes to Kimberly McKenzie and Christopher McKenzie. (See copy annexed hereto) Order Substituting Plaintiff FILED May 1, 2017 It is on this 1st day of May, 2017 ORDERED AND ADJUDGED that the complaint in this action be and hereby is amended by striking the name of Quicken Loans Inc. Bayview Loan Servicing, LLC be and hereby is substituted as plaintiff. 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 10 days of the date of this Order. Certification/Affidavit of Diligent Inquiry and Accuracy of Foreclosure Documents and Factual Assertions RECEIVED June 9, 2017 Notice of Motion for Final Judgment FILED June 9, 2017 The Notice of Motion for Final Judgment is directed to Kimberly McKenzie and Christopher McKenzie. 4
Proof of Service of Notice of Motion for Final Judgment RECEIVED June 9, 2017 On June 9, 2017 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 by regular and certified mail to Kimberly McKenzie and Christopher McKenzie. (See copy annexed hereto) Certification/Affidavit of Non-Military Service or Inability to Ascertain Military Status RECEIVED June 9, 2017 Kimberly McKenzie and Christopher McKenzie is/are not in the military service. Report(s) from the Department of Defense Manpower Data Center annexed thereto. Certification of Mediation Program Forms RECEIVED June 9, 2017 Certification sets forth that a copy of the Notice of Foreclosure Mediation Availability in English and Spanish, Mediation Request Statement, Foreclosure Mediation Financial Worksheet, Loan Modification Checklist, and List of Housing Counseling Agencies was served with the summons and complaint. Proof of Mailing RECEIVED June 9, 2017 On April 13, 2017 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 June 9, 2017 On April 14, 2017 a Notice to Cure pursuant to the Fair Foreclosure Act was mailed by regular and certified mail to each Kimberly McKenzie and Christopher 5
McKenzie at the following addresses: 780 Shore Concourse, Keyport, NJ 07735 and to Kimberly Mckenzie at 8 Dartmouth Road, Parlin, NJ 08859. As of 10 days no response has been received to the aforesaid Notice of Intention to Apply for Final Judgment. Certification/Affidavit of Costs/Search Fees RECEIVED June 9, 2017 Total fees requested $923.00. Certification/Affidavit of Amount Due RECEIVED June 9, 2017 Certification/Affidavit by a representative of the plaintiff sets forth that there is due the sum of $190,230.03 on its mortgage together with interest to grow due thereon from May 15, 2017. (See copy annexed hereto.) Final Judgment FILED July 12, 2017 (See copy annexed hereto.) Plaintiff s Costs $2,975.30. Writ of Execution issued July 12, 2017 6
NOTE: WE FAIL TO FIND ANY PROOF OF MAILING OF THE FINAL JUDGMENT FILED IN THIS ACTION. Consent Order FILED March 16, 2018 (See copy annexed hereto) Consent Order FILED May 1, 2018 (See copy annexed hereto) Emergent Application for Stay of Sheriff's Sale FILED June 18, 2018 Kimberly McKenzie, Pro Se Order to Stay Sheriff's Sale FILED June 18, 2018 DENIED LAST ENTRY 7
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. THIS CHANCERY ABSTRACT IS CERTIFIED TO COASTAL TITLE AGENCY, INC. DATED: September 17, 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 KW 8
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SWC-F-000486-16 04/12/2017 10:28:48 AM Pg 1 of 2 Trans ID: CHC2017305339 Colleen M. Hirst, Esq. (039742003) Paul W. Luongo, Esq. (000172009) Caitlin M. Donnelly, Esq. (034832011) Nicholas J. Zabala, Esq. (156532015) NJ22148FC KML Law Group, P.C. Kristina G. Murtha, Esq., Managing Attorney (034041990) A Professional Corporation incorporated in Pennsylvania 216 Haddon Avenue, Ste. 406 Westmont, NJ 08108 609-250-0700 (NJ) 215-627-1322 (PA) Attorney for Plaintiff Brian C. Nicholas, Esq. (036432003) Jaime R. Ackerman, Esq. (025782003) Christopher Ford, Esq. (006712005) Denise Carlon, Esq. (001392008) Quicken Loans Inc. Plaintiff vs. Kimberly Mckenzie, et al Defendant(s) SUPERIOR COURT OF NEW JERSEY Monmouth County CHANCERY DIVISION GENERAL EQUITY Docket No. F-000486-16 CIVIL ACTION PROOF OF SERVICE I, Shannon Boryszewski, hereby certifies as follows: 1. I am a Paralegal with KML Law Group, P.C., attorneys for Plaintiff herein. As such I have knowledge of the facts contained herein. I am responsible for service of the within motion upon all parties of record. 2. On April 12, 2017, our firm caused to have mailed the a copy of the within notice of motion, supporting certification, letter brief, proposed form of order and proof of service regarding same which were filed on this date through the court s electronic system. 3. On April 12, 2017, our firm caused to have mailed a copy of the within notice of motion, supporting certification, letter brief, proposed form of order and proof of service to the following persons by regular and certified mail, return receipt requested.
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SWC F 000486-16 05/01/2017 Pg 1 of 2 Trans ID: CHC2017362358 Colleen M. Hirst, Esq. (039742003) Paul W. Luongo, Esq. (000172009) Caitlin M. Donnelly, Esq. (034832011) Nicholas J. Zabala, Esq. (156532015) NJ22148FC KML Law Group, P.C. Kristina G. Murtha, Esq., Managing Attorney (034041990) A Professional Corporation incorporated in Pennsylvania 216 Haddon Avenue, Ste. 406 Westmont, NJ 08108 609-250-0700 (NJ) 215-627-1322 (PA) Attorney for Plaintiff Brian C. Nicholas, Esq. (036432003) Jaime R. Ackerman, Esq. (025782003) Christopher Ford, Esq. (006712005) Denise Carlon, Esq. (001392008) Quicken Loans Inc. Plaintiff vs. Kimberly Mckenzie, et al Defendant(s) SUPERIOR COURT OF NEW JERSEY Monmouth County CHANCERY DIVISION GENERAL EQUITY Docket No. F-000486-16 CIVIL ACTION ORDER SUBSTITUTING PLAINTIFF THIS MATTER having been brought before the Court on motion of Plaintiff s counsel, KML Law Group, P.C., and the Court having read all papers submitted, and having considered the arguments therein, and good cause having been shown, IT IS ON THIS 1st day of May 2017, Ordered as follows: 1. The Complaint in this action be and hereby is amended striking the name of Quicken Loans Inc. as the party plaintiff. 2. Bayview Loan Servicing, LLC, be and hereby is substituted in the place and stead of Quicken Loans Inc. as the party Plaintiff and all subsequent pleadings filed with the Court shall use the name of the substituted Plaintiff in the caption.
SWC F 000486-16 05/01/2017 Pg 2 of 2 Trans ID: CHC2017362358 3. The Superior Clerk is directed to change, as herein modified, the name of the party Plaintiff on the automated case management system docket. 4. Copies of this Order shall be served on all counsel and defendants of record within 10 days of the date the Order is received by plaintiff s counsel. The Motion was [ ] opposed [ ] unopposed
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SWC F 000486-16 07/12/2017 Pg 1 of 2 Trans ID: CHC2017536244 Colleen M. Hirst, Esq. (039742003) Paul W. Luongo, Esq. (000172009) Caitlin M. Donnelly, Esq. (034832011) Nicholas J. Zabala, Esq. (156532015) KML Law Group, P.C. Kristina G. Murtha, Esq., Managing Attorney (034041990) A Professional Corporation incorporated in Pennsylvania 216 Haddon Avenue, Ste. 406 Westmont, NJ 08108 609-250-0700 (NJ) 215-627-1322 (PA) Attorney for Plaintiff Brian C. Nicholas, Esq. (036432003) Jaime R. Ackerman, Esq. (025782003) Christopher Ford, Esq. (006712005) Denise Carlon, Esq. (001392008) Bayview Loan Servicing, LLC Plaintiff vs. Kimberly Mckenzie, et al Defendant(s) SUPERIOR COURT OF NEW JERSEY Monmouth County CHANCERY DIVISION GENERAL EQUITY DOCKET NO. F-000486-16 CIVIL ACTION FINAL JUDGMENT FOR FORECLOSURE Upon application of the plaintiff and it appearing that the Summons, Complaint and Amendments, if any, were served upon all defendants pursuant to the Rules of Court and the default of all defendants having been entered; and the plaintiff's Note and Mortgage and Assignment 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 this 12th day of July, 2017, ORDERED AND ADJUDGED that the plaintiff is entitled to have the sum of $190,230.03, together with lawful interest thereon to be computed from May 15, 2017, together with costs of this action to be taxed including a counsel fee of $ 2,052.30 raised and paid out of the mortgaged premises described in the Complaint; And it is further ORDERED and ADJUDGED that the mortgaged premises be sold to raise
SWC F 000486-16 07/12/2017 Pg 2 of 2 Trans ID: CHC2017536244 and satisfy the monies due the plaintiff and that an execution issue for that purpose to the Sheriff of Monmouth County, commanding him to make sale according to law of the mortgaged premises and out of the monies arising from sale that he pay the plaintiff's debt, with interest thereon and costs as aforesaid, to the plaintiff or its attorney, and that in case there is a surplus remaining after said sale that such surplus be brought into court to abide the further order of the court, and that the Sheriff make his report of the said sale as required by the rules of this court: And it is further ORDERED that all of the defendants to this action, and each of them, stand absolutely debarred and foreclosed of and from all equity of redemption of, in and to said mortgaged premises as shall be sold as aforesaid by virtue of this judgment except as provided by 28 U.S.C. Section 2410. And it is further ORDERED that the plaintiff and any purchaser under the foreclosure sale duly recover against the defendants and all parties holding by, through or claiming under them or any of them, possession of the premises mentioned and described in the Complaint, with the appurtenances, and that a Writ of Possession issue thereon; This judgment shall not affect the rights of any person protected by the New Jersey Tenant Anti-Eviction Act (N.J.S.A. 2A: l8-6l-l Et Seq). BY THE COURT
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SWC-F-000486-16 F 04/12/2018 05/01/2018 10:23:18 AM Pg Pg 1 of 12 of Trans 2 Trans ID: ID: CHC2018242639 CHC2018203346 1st May XXXX
SWC-F-000486-16 F 04/12/2018 05/01/2018 10:23:18 AM Pg Pg 2 of 22 of Trans 2 Trans ID: ID: CHC2018242639 CHC2018203346 /s/ Katie A. Gummer Katie A. Gummer, P.J.,Ch. XXXX x