GREATER ATLANTIC LEGAL SERVICES, INC. CHANCERY ABSTRACT CENLAR FSB vs. Plaintiff, ROBERTA NEWFELD; MIDLAND FUNDING LLC O/b/o Chase Bank USA NA; PNC BANK, NATIONAL ASSOCIATION; UNITED STATES OF AMERICA, Defendants, SUPERIOR COURT OF NEW JERSEY SOMERSET COUNTY DOCKET NO. F-046266-14 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. GREATER ATLANTIC LEGAL SERVICES, INC. YOUR REFERENCE # 7223371 TITLE OFFICER
Complaint to Foreclose Filed November 3, 2014 McCabe, Weisberg & Conway, P.C., Attorneys for Plaintiff Summons dated November 7, 2014 (See return(s) and/or acknowledgment(s) of service Midland Funding LLC o/b/o Chase Bank USA NA and PNC Bank National Association annexed hereto.) Certification of Inquiry and Publication (as to Roberta Newfeld) RECEIVED February 4, 2015 (See copy annexed hereto.) Affidavit of Publication annexed thereto sets forth on December 18, 2014, a Notice to Absent Defendants directed to Roberta Newfeld was published in the Courier- News. NOTE: CONSIDERATION SHOULD BE GIVEN TO THE ADEQUACY OF THE INQUIRY AS TO ROBERTA NEWFELD. Notice of Dismissal as to Mr. Newfeld, husband of Roberta Newfeld, John Doe and Jane Doe, Tenants (names being fictitious) Filed February 4, 2015 Request and Certification/Affidavit of Default as to Roberta Newfeld, PNC Bank national Association and Midland Funding LLC o/b/o Chase Bank USA NA Filed February 4, 2015 1
Default Filed February 4, 2015 Certification/Affidavit of Diligent Inquiry and Accuracy of Foreclosure Documents and Factual Assertions RECEIVED December 9, 2015 Notice of Motion for Final Judgment Filed December 9, 2015 The Notice of Motion for Final Judgment is directed to Roberta Newfeld c/o Superior Court of New Jersey, No Mailing Pursuant to Rule 1:5-2 and 3 Beechwood Terrace, Green Brook, New Jersey 08812, PNC Bank National Association at 660 Kings Highway N, Cherry Hill, New Jersey 08034 and Midland Funding LLC o/b/o Chase Bank USA NA at 830 Bear Tavern Road, Ewing, New Jersey 08628. Proof of Service of Notice of Motion for Final Judgment RECEIVED December 9, 2015 On, 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 Roberta Newfeld c/o Superior Court of New Jersey, No Mailing Pursuant to Rule 1:5-2 and 3 Beechwood Terrace, Green Brook, New Jersey 08812, PNC Bank National Association at 660 Kings Highway N, Cherry Hill, New Jersey 08034 and Midland Funding LLC o/b/o Chase Bank USA NA at 830 Bear Tavern Road, Ewing, New Jersey 08628. Certification/Affidavit of Non-Military Service or Inability to Ascertain Military Status RECEIVED December 9, 2015 Roberta Newfeld is/are not in the military service. Report(s) from the Department of Defense Manpower Data Center annexed thereto. 2
Proof of Mailing RECEIVED December 9, 2015 On March 26, 2015, 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 December 9, 2015 On April 6, 2015, a Notice to Cure pursuant to the Fair Foreclosure Act was mailed by regular and certified mail to Roberta Newfeld at the following addresses: 3 Beechwood Terrace, Green Brook, New Jersey 08812 and C/O Superior Court of New Jersey at PO Box 971, Hughes Justice Complex, Trenton, NJ 08625. More than fifteen days have passed since receipt of the notice by the debtor. Certification/Affidavit of Costs/Search Fees RECEIVED December 9, 2015 Total fees requested $1,010.78. Certification/Affidavit of Amount Due RECEIVED December 9, 2015 Certification/Affidavit by a representative of the plaintiff sets forth that there is due the sum of $387,306.52 on its mortgage together with interest to grow due thereon from October 15, 2015. Final Judgment Filed January 15, 2016 (See copy annexed hereto.) 3
Plaintiff s Costs $5,006.09. Writ of Execution issued January 15, 2016 and returned June 14, 2017 not Satisfied Certification/Affidavit of Mailing RECEIVED June 2, 2016 On June 2, 2016, a Notice of Sheriff's Sale was mailed by regular and certified mail to Roberta Newfeld at c/o Superior Court of New Jersey, P.O. Box 971, Hughes Justice Complex, Trenton, New Jersey 08625 and 3 Beechwood Terrace, Green Brook, New Jersey 08812, 728 West Main Street, Lansdale, Pennsylvania 19446 and 1617 Supplee Road, Lansdale, Pennsylvania 19446 and Occupants at 3 Beechwood Terrace, Green Brook, New Jersey 08812. Appearance Entered for Jatin Desai Filed July 11, 2016 Vastola & Sullivan, Attorney(s) for Third Party Purchaser at Sheriff Sale Notice of Motion to Vacate Sheriff Sale /Motion Returnable August 5, 2016 Filed July 14, 2016 Vastola & Sullivan, Attorney(s) for Third Party Purchaser at Sheriff Sale Proof of Service RECEIVED July 14, 2016 Vastola & Sullivan, Attorney(s) for Third Party Purchaser at Sheriff Sale 4
Certification of John J. Sullivan, Jr., Esq. RECEIVED July 14, 2016 Vastola & Sullivan, Attorney(s) for Third Party Purchaser at Sheriff Sale Consent Order Filed August 2, 2016 IT IS on this 2nd day of August. 2016 ORDERED that the Sheriff Sale of the property located at 3 Beechwood Te1rnce, Green Brook, New Jersey on June 7, 2016 to Jatin Desai be and is hereby vacated; and it is further ORDERED that the Sheriff of Somerset County shall refund to Jatin Desai all funds paid to the Sheriff by Jatin Desai; and it is fu1ther ORDERED that a copy of this Order be served on counsel for all parties within seven (7) days of the date hereof. I hereby consent to the Form and entry of the within Order Vastola & Sullivan By: John J. Sullivan, Jr. Esq. Attorney for Jatin Desai McCabe, Weisberg & Conway, PC By: Attorney for Plaintiff NOTE: WE FAIL TO FIND ANY PROOF OF MAILING OF THE CONSENT ORDER AS DIRECTED THEREIN. Notice of Motion to Vacate Final Judgment & Set Aside Writ of Execution Filed March 20, 2017 Notice directed to Roberta Newfeld c/o Superior Court of New Jersey, C/O Superior Court of New Jersey at P.O. Box 971, Hughes Justice Complex, Trenton, NJ 08625 and 3 Beechwood Terrace, Green Brook, New Jersey 08812, PNC Bank National Association at 660 Kings Highway N, Cherry Hill, New Jersey 08034 and Midland Funding LLC o/b/o Chase Bank USA NA at 830 Bear Tavern Road, Ewing, New Jersey 08628. 5
Proof of Mailing of Notice of Motion to Vacate Final Judgment & Set Aside Writ of Execution RECEIVED March 20, 2017 On March 20, 2017, a copy of the Notice of Motion to Vacate Final Judgment, Certification in Support of Order to Vacate Final Judgment & Set Aside Writ of Execution & Proposed Order was sent via certified and regular mail to Roberta Newfeld c/o Superior Court of New Jersey, C/O Superior Court of New Jersey at P.O. Box 971, Hughes Justice Complex, Trenton, NJ 08625 and 3 Beechwood Terrace, Green Brook, New Jersey 08812, PNC Bank National Association at 660 Kings Highway N, Cherry Hill, New Jersey 08034 and Midland Funding LLC o/b/o Chase Bank USA NA at 830 Bear Tavern Road, Ewing, New Jersey 08628. Certification in Support of Order Vacating Final Judgment & Setting Aside The Writ of Execution RECEIVED March 20, 2017 Certification sets forth Final Judgment and the Writ of Execution were entered in this matter on January 15, 2016. The Sheriffs Sale has been vacated by Consent between Plaintiff and Third-Party bidder. Order Vacating Final Judgment, Setting Aside The Wit of Execution Filed April 11, 2017 IT IS on this 11th day of April, 2017 ORDERED, that the Final Judgment and the Writ of Execution issued in this action be and the same are hereby vacated, and set aside, without prejudiced. 6
Amended Complaint to Foreclose Filed April 27, 2017 McCabe, Weisberg & Conway, P.C., Attorneys for Plaintiff FIRST COUNT Amended Complaint filed to foreclose mortgage made and executed by Roberta Newfeld to Mortgage Electronic Registration Systems, Inc., as nominee for Lydian Mortgage, a Division of Lydian Private Bank to secure the sum of $356,250.00. Obligation and mortgage dated August 29, 2007. The mortgage was recorded in Somerset County on September 12, 2007 in Book 6066, Page 2827. THIS IS A NON PURCHASE MONEY MORTGAGE. A COMPLETE COPY OF THE AMENDED COMPLAINT WITH PROPERTY DESCRIPTION ATTACHED IS ANNEXED HERETO. By virtue of assignment(s) more particularly set forth in the annexed copy of the Amended Complaint, the mortgage was assigned to the Plaintiff. Midland Funding LLC O/B/o Chase bank USA NA; PNC Bank, national Association and United States of America is/are made defendant(s) for reasons more particularly set forth in the annexed copy of the Amended 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 7
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, MCCABE, WEISBERG AND CONWAY, P.C. Attorneys for Plaintiff Ian V. Gallo, Esquire Amended Complaint to Foreclose Filed May 3, 2017 McCabe, Weisberg & Conway, P.C., Attorneys for Plaintiff DUPLICATE FILING Summons dated May 8, 2017 (See return(s) and/or acknowledgment(s) of service for United States of America annexed hereto.) Proof of Mailing RECEIVED August 4, 2017 On May 8, 2017, a copy of the Summons and Complaint was mailed via certified mail to United States of America C/O United States Attorney General, U.S. Department of Justice, Washington, DC 20530. A copy of the 60 day Summons and a signed return receipt directed to the aforesaid defendant indicating delivery on May 15, 2017 annexed thereto. 8
Request and Certification/Affidavit of Default as to United States of America Filed August 4, 2017 Default Filed August 4, 2017 Certification/Affidavit of Diligent Inquiry and Accuracy of Foreclosure Documents and Factual Assertions RECEIVED November 27, 2017 Notice of Motion for Final Judgment Filed November 27, 2017 The Notice of Motion for Final Judgment is directed to Roberta Newfeld at 3 Beechwood Terrace, Green Brook, New Jersey 08812 and c/o Superior Court of New Jersey, C/O Superior Court of New Jersey at P.O. Box 971, Hughes Justice Complex, Trenton, NJ 08625, PNC Bank National Association at 660 Kings Highway N, Cherry Hill, New Jersey 08034 and Midland Funding LLC o/b/o Chase Bank USA NA at 830 Bear Tavern Road, Ewing, New Jersey 08628, United States of America-NJ at 970 Broad Street, Room 700 Newark, NJ 07102 and United States of America C/O United States Attorney General, U.S. Department of Justice, Washington, DC 20530. Proof of Service of Notice of Motion for Final Judgment RECEIVED November 27, 2017 On November 27, 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 Roberta Newfeld at 3 Beechwood Terrace, Green Brook, New Jersey 08812 and c/o Superior Court of New Jersey, C/O Superior Court of New Jersey at P.O. Box 971, Hughes Justice Complex, Trenton, NJ 08625, PNC Bank National Association at 660 Kings Highway N, Cherry 9
Hill, New Jersey 08034 and Midland Funding LLC o/b/o Chase Bank USA NA at 830 Bear Tavern Road, Ewing, New Jersey 08628, United States of America-NJ at 970 Broad Street, Room 700 Newark, NJ 07102 and United States of America C/O United States Attorney General, U.S. Department of Justice, Washington, DC 20530. Certification/Affidavit of Non-Military Service or Inability to Ascertain Military Status RECEIVED November 27, 2017 Roberta Newfeld is/are not in the military service. Report(s) from the Department of Defense Manpower Data Center annexed thereto. Proof of Mailing RECEIVED November 27, 2017 On September 18, 2014, 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 November 27, 2017 On September 18, 2017, a Notice to Cure pursuant to the Fair Foreclosure Act was mailed by regular and certified mail to Roberta Newfeld at the following addresses: 3 Beechwood Terrace, Green Brook, New Jersey 08812. More than fifteen days have passed since receipt of the notice by the debtor. Certification/Affidavit of Costs/Search Fees RECEIVED November 27, 2017 Total fees requested $1,105.09. 10
Certification/Affidavit of Amount Due RECEIVED November 27, 2017 Certification/Affidavit by a representative of the plaintiff sets forth that there is due the sum of $427,079.72 on its mortgage together with interest to grow due thereon from September 30, 2017. (See copy annexed hereto.) Certification of Bankruptcy RECEIVED November 27, 2017 (See copy annexed hereto.) Final Judgment Filed December 20, 2017 (See copy annexed hereto.) Plaintiff s Costs $5,465.38. Writ of Execution issued December 20, 2017 and returned June 25, 2018 Paid and Satisfied Proof of Mailing RECEIVED February 6, 2018 On February 6, 2018 a copy of the filed Final Judgment was mailed to Roberta Newfeld at 3 Beechwood Terrace, Green Brook, New Jersey 08812 and c/o Superior Court of New Jersey, C/O Superior Court of New Jersey at P.O. Box 971, Hughes Justice Complex, Trenton, NJ 08625, PNC Bank National Association at 660 Kings Highway N, Cherry Hill, New Jersey 08034 and Midland Funding LLC o/b/o Chase Bank USA NA at 11
830 Bear Tavern Road, Ewing, New Jersey 08628, United States of America-NJ at 970 Broad Street, Room 700 Newark, NJ 07102 and United States of America C/O United States Attorney General, U.S. Department of Justice, Washington, DC 20530. Certification/Affidavit of Mailing RECEIVED April 30, 2018 On April 30, 2018 a Notice of Sheriff's Sale was mailed by regular and certified mail to Roberta Newfeld at c/o Superior Court of New Jersey, P.O. Box 971, Hughes Justice Complex, Trenton, New Jersey 08625, 3 Beechwood Terrace, Green Brook, New Jersey 08812, 728 West Main Street, Lansdale, Pennsylvania 19446 and 1819 N 115th Plaza Apt 3205, Omaha, Nebraska 68154 and Occupants at 3 Beechwood Terrace, Green Brook, New Jersey 08812. Certification/Affidavit of Mailing RECEIVED May 9, 2018 On May 9, 2018, a Notice of Sheriff's Sale was mailed by regular and certified mail to Roberta Newfeld at c/o Superior Court of New Jersey, P.O. Box 971, Hughes Justice Complex, Trenton, New Jersey 08625, 3 Beechwood Terrace, Green Brook, New Jersey 08812, 728 West Main Street, Lansdale, Pennsylvania 19446 and 1819 N 115th Plaza Apt 3205, Omaha, Nebraska 68154 and Occupants at 3 Beechwood Terrace, Green Brook, New Jersey 08812. Report of Sale RECEIVED July 25, 2018 Report of Sale annexed thereto sets forth on May 22, 2018, the Sheriff of Somerset County sold the mortgaged premises at public vendue to Patriot Funding as Trustee for Asset-Backed Certificates 2007-02, LLC for the sum of $244,000.00. Affidavit of highest and best price annexed thereto. 12
THIS CHANCERY ABSTRACT IS CERTIFIED TO FIDELITY NATIONAL TITLE GROUP 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 tll 13
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 1 of 16 Trans ID: CHC2017354673
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 2 of 16 Trans ID: CHC2017354673
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 3 of 16 Trans ID: CHC2017354673
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 4 of 16 Trans ID: CHC2017354673
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 5 of 16 Trans ID: CHC2017354673
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 6 of 16 Trans ID: CHC2017354673 4/27/2017
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 7 of 16 Trans ID: CHC2017354673
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 8 of 16 Trans ID: CHC2017354673
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 9 of 16 Trans ID: CHC2017354673
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 10 of 16 Trans ID: CHC2017354673
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 11 of 16 Trans ID: CHC2017354673
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 12 of 16 Trans ID: CHC2017354673 4/27/2017
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 13 of 16 Trans ID: CHC2017354673 4/27/2017
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 14 of 16 Trans ID: CHC2017354673 4/27/2017
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 15 of 16 Trans ID: CHC2017354673
SWC-F-046266-14 04/27/2017 4:30:14 PM Pg 16 of 16 Trans ID: CHC2017354673
SWC-F-046266-14 08/04/2017 1:10:33 PM Pg 4 of 7 Trans ID: CHC2017591869
SWC-F-046266-14 11/27/2017 9:27:18 AM Pg 1 of 127 Trans ID: CHC2017825884
SWC-F-046266-14 11/27/2017 9:27:18 AM Pg 2 of 127 Trans ID: CHC2017825884
SWC-F-046266-14 11/27/2017 9:27:18 AM Pg 3 of 127 Trans ID: CHC2017825884
SWC-F-046266-14 11/27/2017 9:27:18 AM Pg 1 of 3 Trans ID: CHC2017825884
SWC-F-046266-14 11/27/2017 9:27:18 AM Pg 2 of 3 Trans ID: CHC2017825884
SWC-F-046266-14 11/27/2017 9:27:18 AM Pg 3 of 3 Trans ID: CHC2017825884
SWC-F-046266-14 F 11/27/2017 12/20/2017 9:27:18 AM Pg Pg 1 of 1 3 of Trans 3 Trans ID: ID: CHC2017884864 CHC2017825884 McCABE, WEISBERG & CONWAY, LLC Marisa Myers Cohen, Esquire - 017032001 Carol R. Cobb, Esquire - 028761994 Christopher J. Kelleher, Esquire - 005212000 James French, Esquire 134352014 Francis T. Tarlecki, Esquire 908882012 John M. Kolesnik, Esquire 012412010 Shanna Lyn Spiro, Esquire 212392017 216 HADDON AVENUE, SUITE 201 WESTMONT, NEW JERSEY 08108 (856) 858-7080 ATTORNEYS FOR PLAINTIFF Matter No 14-203177 - 14-203177 Cenlar FSB, Plaintiff, vs. Roberta Newfeld, et al., Defendants. SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION SOMERSET COUNTY Docket No. F-046266-14 Civil Action FINAL JUDGMENT Upon the application of the plaintiff, and it appearing that summons and complaint has been duly issued and return served upon all of the defendants, and their default having been entered; and the plaintiff s note and mortgage having been presented and marked as exhibits by the court; And it appearing from the Affidavit filed herein that there is due to the Plaintiff the sum $427,079.72 on its mortgage described in the complaint and sufficient cause appearing; It is on this 20 day of, December 2017, ORDERED AND ADJUDGED that the Plaintiff is entitled to have the sum of $427,079.72, together with lawful interest from September 30, 2017 on the total sum due Plaintiff, together with costs of this suit to be taxed, and a counsel fee of $ 4420.80 included therein, raised and paid of the mortgage premises described in said complaint;
SWC-F-046266-14 F 11/27/2017 12/20/2017 9:27:18 AM Pg Pg 2 of 2 3 of Trans 3 Trans ID: ID: CHC2017884864 CHC2017825884 1a. The United States of America is named a party defendant by virtue of the attached federal tax lien which lien is subordinate to Plaintiff s mortgage. And it is further ORDERED AND ADJUDGED that so much of the said mortgage premises as will be sufficient to raise and satisfy the said mortgage, interest and costs of the plaintiff be sold, and that an execution do issue for that purpose out of this court directed to the sheriff of the County of Somerset commanding him to make sale, according to law, of so much of the said mortgaged premises as will be sufficient to satisfy the said mortgage, interest and costs; and that he pay out of the proceeds of the sale to the plaintiff or its attorney, its said debt, interest and costs and that in case there is a surplus, the same shall be brought into this Court and deposited with the Clerk subject to the order of this Court; and that said Sheriff make his report to this Court of the sale as required by the rules of this Court; And it is further ORDERED AND ADJUDGED that the Plaintiff or the Purchaser at the foreclosure sale, duly recover against said defendants, Roberta Newfeld, PNC Bank, National Association, Midland Funding LLC o/b/o Chase Bank USA NA and United States of America or any one holding under them, possession of the premises mentioned and described in the complaint with the appurtenances and that a writ of possession issue thereon; And it is further ORDERED AND ADJUDGED that the question of priority between Plaintiff and the United States of America as to any late charges and interest on advances shall await surplus money proceedings, if any And it is further ORDERED AND ADJUDGED that the question of priority between Plaintiff and the United States of America as to any late charges and interest on advances shall await surplus money proceedings, if any
SWC-F-046266-14 F 11/27/2017 12/20/2017 9:27:18 AM Pg Pg 3 of 3 3 of Trans 3 Trans ID: ID: CHC2017884864 CHC2017825884 And it is further ORDERED AND ADJUDGED 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 so much of the said mortgage premises shall be sold as aforesaid under this judgment except Midland Funding LLC o/b/o Chase Bank USA NA shall have the right to redeem within the period provided by 28 U.S.C.A. sec 2410 except United States of America shall have the right to redeem within the period provided by 28 U.S.C.A. sec 2410. This Judgment shall not affect the rights of any person protected by the New Jersey Tenant Anti-Eviction Act (N.J.S.A. 2A:18-61.1 et seq.) Respectfully Recommended R. 1:34-6 Office of Foreclosure Paul Innes, P.J.Ch /s/ Paul Innes, P.J.Ch. J.S.C.
SWC F 046266-14 07/25/2018 Pg 4 of 7 Trans ID: CHC2018424140