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New Jersey Institute for Continuing Legal Education W198.11
MORTGAGE FORECLOSURE UPDATE
2011 Seminar Material
Honorable Margaret Mary McVeigh, P.J.Ch. (Paterson) Rosemarie Diamond, Esq. Phelan Hallinan & Schmieg (Mt. Laurel; Philadelphia, PA) Bruce Levitt, Esq. Levitt & Slafkes, P.C. (South Orange) Kevin M. Wolfe, Esq. Administrative Office of the Courts (Trenton)
THE NEW JERSEY INSTITUTE FOR CONTINUING LEGAL EDUCATION
The New Jersey Institute for Continuing Legal Education was created in 1961 to help lawyers and judges increase their general professional competence, keep abreast of developments in the law, and become more proficient in selected areas of practice. Since 1961, ICLE has served the educational needs of the New Jersey bench and bar and continually strives to respond to their many and varied concerns.
A non-profit, completely self-supporting organization, ICLE is the joint venture of the New Jersey State Bar Association, Rutgers - The State University of New Jersey, and Seton Hall University. Representing a merger of the practicing bar and the academic community, the Institute is governed by an autonomous Board of Trustees, which includes representatives of the State Bar Association, deans of the law schools and officers of the participating universities.
The Institute presents more than 250 seminars each year throughout the State, offers audio and video cassettes of seminars, markets software programs especially designed for the practicing attorney, and publishes comprehensive practice manuals and lecture handbooks. Its programs and publications must be financially self-supporting since ICLE is not subsidized in any way. The professional staff of attorneys and other professionals, aided by a dedicated support staff, is headquartered at the New Jersey Law Center in New Brunswick, along with the State Bar Association, the State Bar Foundation, and IOLTA.
The ingredients which contribute most to the stature of the Institute are the talent, time and effort expended by the very best of New Jersey attorneys, representing every field of specialization and every type of practice. The voluntary participation of practicing lawyers and judges as ICLE lecturers, authors, and advisors is appreciated and encouraged, for without their assistance, and the continued support of those we serve, high quality continuing legal education would not be possible.
The material contained in this publication is for educational purposes only and is not intended as a substitute for the professional services an attorney would normally provide to a client, including up to the
minute legal research
Copyright © 2011 by the NEW JERSEY INSTITUTE FOR CONTINUING LEGAL EDUCATION
All Rights Reserved
About the Panelists… Rosemarie Diamond is a Member of Phelan Hallinan & Schmieg, LLP with offices in Mount Laurel, New Jersey, and Philadelphia, PA. Her practice areas include creditors’ rights, foreclosures, bankruptcy law, real estate law and collections. Ms. Diamond is admitted to practice in New Jersey, Pennsylvania and New York. She received her B.S. from Mary Washington College and her J.D. from Temple University School of Law. Bruce Levitt is a Founding Partner of Levitt & Slafkes, P.C. in South Orange, New Jersey, a firm which practices almost exclusively in bankruptcy, commercial litigation and residential real estate transactions. He handles both consumer and commercial bankruptcy matters. Admitted to practice in New Jersey, Mr. Levitt served for twelve years as a panel bankruptcy trustee for the Office of the United States Trustee, where he administered chapter 7 and 11 cases. He also served for six years on the Lawyers’ Advisory Committee of the United States Bankruptcy Court for the District of New Jersey, where he helped draft rules for bankruptcy law in the New Jersey Bankruptcy Courts. Mr. Levitt serves on the Supreme Court of New Jersey District V-B Fee Arbitration Committee and is a member of the National Association of Consumer Bankruptcy Attorneys. A Master in the Bankruptcy American Inn of Court, he frequently lectures on bankruptcy topics and his articles have appeared in the New Jersey Law Journal. Mr. Levitt received his B.A., magna cum laude, from Fairleigh Dickinson University and his J.D. from Emory University School of Law, where he served on the Board of Editors of the Emory Law Journal. He served as a law clerk to a three-judge panel of the Eleventh Circuit Court of Appeals. Honorable Margaret Mary McVeigh, P.J.Ch. is Presiding Judge of the Chancery Division, General Equity Part, Passaic County vicinage, and sits in Paterson, New Jersey. Her responsibilities include the General Equity Part and Probate. A Superior Court Judge for 18 years, Judge McVeigh has served in Special Civil Part, the Family Division and the Civil Division. She is Chair of the Probate Part Judges Committee, Chair of the Special Committee to Study Guardianship Monitoring and a member of the Judiciary Surrogates Liaison Committee. Judge McVeigh is a founding member of the Robert Clifford American Inns of Court and serves on its Board of Directors. She was an Adjunct Professor at Montclair State University. Judge McVeigh is a graduate of Mary Washington College and Seton Hall Law School. Kevin M. Wolfe is an Assistant Director at the Administrative Office of the Courts in Trenton, New Jersey.
Mr. Wolfe received his B.S.M.E. from the New Jersey Institute of Technology and his J.D. from Rutgers University School of Law.
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FORECLOSURE CASE SUMMARIES (April 2011)
Honorable Margaret M. McVeigh, P.J.Ch. Kevin M. Wolfe, Esq. Rosemarie Diamond, Esq. Bruce Levitt, Esq. Deutsche Bank National Trust Company, as Trustee v. Geeta P. Kollory, Unpublished Appellate Division Opinion; DOCKET No. A‐1199508T2‐‐‐DECIDED JANUARY 7, 2010
The appellate court upheld the lower court’s summary judgment in favor of the plaintiff, holding the lower court created a sufficient record of an undisputed default in forbearance payments, leaving no doubt that the defendant was in default of the terms of the forbearance agreement. Defendant had argued there was evidence that the payments were current and the foreclosure was improper. The record includes a court transcript of oral argument during which the court reviewed the payment history in detail to confirm the existence of the default.
Greenpoint Mortgage Funding, Inc. v. Doris Odoemene, et. al., Unpublished Appellate Division Opinion; DOCKET NO. A‐4438‐08T2‐‐‐DECIDED JANUARY 28, 2010
The appellate court upheld the lower court’s denial of defendant’s motion to vacate summary judgment. Defendant claimed the plaintiff lacked standing because the assignment of mortgage from MERS into the plaintiff was not recorded until after the foreclosure complaint was filed. The lower court rejected this argument because the plaintiff clearly illustrated that it was the lender at origination and held the note at the time for foreclosure complaint was filed. MERS had functioned as its nominee on the original mortgage. Moreover, MERS assigned the mortgage into plaintiff prior to the entry of final judgment. Thus, plaintiff was the correct party in interest at the time the foreclosure complaint was filed.
Emmanuel Odoemene v. Greenpoint Mortgage Funding, Inc., Unpublished Appellate Division Opinion; DOCKET NO. A‐2659‐08T3‐‐‐DECIDED JANUARY 28, 2010
The appellate court upheld the lower court’s determination, on defendant’s motion for summary judgment, that no private cause of action exists under the Fair Credit Reporting Act; and, that even viewing the facts in the light most favorable to the plaintiff, there was no evidence that the defendant had acted willfully of negligently in erring on the plaintiff’s credit report. Also, the error had been corrected.
U.S. Bank, National Association as Trustee for CSMC Mortgage‐Backed Pass‐Through Certificates, Series 2006‐4 v. Verna Thomas, et. al., Unpublished Appellate Division Opinion; DOCKET NO. A‐3640‐08T2; DECIDED MARCH 23, 2010
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The Appellate Division upheld the lower court’s rejection of the defendants’ claim that they were misled by the mortgage broker about the applicable interest rate for the loan. The court found that the interest rate was clearly listed in the TILA disclosure statement and the note itself; and, no evidence was presented to contradict the closing documents. Moreover, the defendants made payments for two years without raising the issue of an erroneous interest rate. The court also rejected the defendants’ argument that the property cannot be foreclosed because the husband signed only the mortgage and not the promissory note. To the contrary, the husband’s signature secures the property as collateral for the loan.
Ronald Patetta v. Wells Fargo Bank, N.A.; Unpublished Federal District Court Opinion, 2010 U.S. Dist. LEXIS 47233, DECIDED‐‐‐MAY 12, 2010
The district court applies the Rooker‐Feldman Doctrine in dismissing the plaintiff’s complaint. Acknowledging that many of the plaintiff’s allegations could have served as defenses in the foreclosure action, attempts to now rescind the mortgage transaction in the present matter are barred because the claims are inextricably intertwined with the foreclosure judgment. Plaintiffs had alleged that they did not receive a loan they originally bargained for, despite being represented by counsel at closing, and that Argent, as lender and Dana Capital, as mortgage broker, failed to make disclosures under the TILA, 15 U.S.C. Section 1601 and HOEPA, 15 U.S.C. Section 1639.
Avelo Mortgage, LLC v. Rodney Jeffery, Unpublished Appellate Division Opinion, DOCKET NO. A‐0765‐08T1, DECIDED‐ JULY 15, 2010
The appellate court reversed the lower court’s voiding of the plaintiff’s mortgage, and remanded the matter for further proceedings to determine the appropriate terms of a modified mortgage that will restore the parties to their appropriate status. Defendants had rescinded the plaintiff’s mortgage, but failed to return the proceeds. The court acknowledged that rescission is a defense to foreclosure; however, the consumer must return the proceeds of the loan. If the consume cannot do so, the court can judicially modify the mortgage and allow its enforcement.
One West Bank, FSB v. Maria Capo, et. al and Marva Coleman v. Maria Capo, et. al., Unpublished Trial Court Opinion, Docket No: F ‐5952‐09, Bergen County; DECIDED‐‐JULY 19, 2010
This case involves a mortgage rescue scan. Marva Coleman, the former owner, was able to prove unequivocally that she was the victim of fraud by Maria Capo and other parties. The court also acknowledged that the plaintiff was an innocent victim of the fraud but rejected the assertion that the plaintiff was entitled to holder in due course status. The court declared that the plaintiff’s mortgage, which was obtained through fraud, was void ab initio. Instead, the
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court granted the plaintiff an equitable mortgage on the property, in the name of the Marva Coleman. The court fashioned the principal balance and interest rate for the equitable mortgage.
HSBC Bank, USA, National Association for the benefit of ACE Securities Corp. Home Equity Loan Trust, Series 2006‐NC2 v. Lamiaa Gouda. et. al., Unpublished Appellate Division Opinion, DOCKET NO. A‐1983‐09T2; DECIDED‐‐DECEMBER 17, 2010
The appellate court affirmed the lower court’s grant of summary judgment in favor of the plaintiff, rejecting defendants’ arguments that (1) the note is non‐negotiable because it imposes an obligation on defendants, in addition to payment, to notify lender of pre‐payment, in violation of N.J.S.A. 12A:3‐104(a); (2) the plaintiff was not a holder in due course because it knew or should have known about irregularities in the closing documents. The court finds no legal authority in defendants’ argument that the note is not a negotiable instrument; and, the circumstances of the closing do not imply a lack of good faith by the plaintiff sufficient to overcome holder in due course status.
In the Matter of Kemp/John Kemp v. Countrywide Home Loans, Case No, 08‐18700‐JHW; Adversary Number 08‐2448, (Bankruptcy Ct. D. N.J.) DECIDED NOVEMBER 16, 2010
Debtor filed an adversary action in bankruptcy court, challenging creditorʹs ability to enforce its obligation because (1) the promissory note executed by the debtor was not properly endorsed to the creditor; and (2) the creditor was not in possession of the note. The court expunged the creditor’s secured claim. The court cited the New Jersey Uniform Commercial Code (“NJUCC”) to define both what constitutes a negotiable instrument and what parties may exercise rights under the negotiable instrument. The promissory note identified Countrywide Home Loans, Inc. as the original lender. The note attached an unsigned allonge and was not endorsed to Bank of New York. The loan was sold into a pool of loans with Bank of New York as Trustee and Countrywide Home Loans Servicing LP as the master servicer. The pooling and servicing agreement contained terms for endorsement of a note entering the pool. The mortgage was assigned to Bank of New York as Trustee. The court determined that the note, a negotiable instrument governed the NJ UCC, was not properly endorsed, nor in the physical custody of the Bank of New York at the time the proof of claim was filed. Consequently, the creditor had no basis on which to enforce the note.
Bank of New York, as Trustee for Home Mortgage Investment Trust 2004‐4 Mortgage Backed Notes, Series 2004‐4 v. Michael J. Raftogianis, 418 N.J. Super. 323 (Ch. Div. 2010)., DECIDED June 29, 2010
The court dismissed the foreclosure complaint without prejudice, holding that the plaintiff failed to prove it had physical possession of the note and was the holder as defined under the
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New Jersey Uniform Commercial Code, at the time the foreclosure complaint was filed. In refilling the complaint, the plaintiff must certify the facts as to when it took possession of the note and its status as holder. The plaintiff was the trustee under a pooling and servicer agreement; and, the pooling and servicing agreement contained specific instructions for endorsement of the note. The decision contains extensive commentary on the securitization of mortgages and the requirements for establishing a party as holder of the note. The court rejected the argument that the presence of MERS as a nominee caused a separation of the note and mortgage, rendering the mortgage unenforceable.
U.S. Bank National Association v. Mark Williams, Unpublished Appellate Division Opinion, A‐6185‐08T2, LEXIS 175, DECIDED August 25, 2010
The trial court denied defendant’s motion to stay redemption. Defendant alleged he was denied a meaningful opportunity to participate in New Jerseyʹs residential mortgage Foreclosure Mediation Program (FMP) because he was unrepresented and not assisted by a housing counselor. The appellate court ruled that Defendant did have an opportunity to participate in mediation, including assistance of housing counselor as outlined by the FMP. Defendant did not demonstrate the financial ability to qualify for a mortgage modification and was not approved. The court noted that an agreement resulting in a loan modification is not a requirement of the FMP if the borrower is not qualified. Participating in mediation translates into a meaningful opportunity.
U.S. Bank Natʹl Assʹn v. Berg, Unpublished Appellate Division Opinion., A‐4696‐08T2, LEXIS 2413, DECIDED October 5, 2010
Defendant filed a motion to vacate default, Final Judgment, Sheriffʹs Sale, to void deed and stay eviction approximately five months after the Sheriffʹs Sale. Defendant argued that Plaintiff lacked standing to foreclose because it did not possess the note at the time the complaint was filed. The lower court held that Plaintiff need only gain possession of the note before entry of Final Judgment and denied the motion. The Appellate Division ruled that: (1) the Plaintiff had possession of the note when the complaint was filed; (2) the Defendant acknowledged the validity of the note/mortgage at various times; (3) Defendant did not move to vacate judgment sale within a reasonable time.
Bank of America, NA, as successor by merger to LaSalle Bank, NA as Trustee for WaMu Mortgage Pass‐Through Certificate Series 2006 ‐AR11 Trust v. Janett Alvarado, Unpublished Trial Court Opinion, Docket: F‐47941‐08, DECIDED January 7, 2011
The court granted summary judgment in favor of the plaintiff, rejecting the defendant’s argument that the plaintiff cannot enforce the note because the note was lost prior to its transfer
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to plaintiff. The court found that common law principles of unjust enrichment preclude the borrower from receiving the windfall that would be created by a failure to deem the note enforceable. The original note was certified as lost by the original lender. Also, the pass‐through trust was intended to include acquisition of Defendantʹs note; and, Bank of America, as successor has the right to enforce the obligation represented by the Lost Note. Also, Bank of America is the assignee of the rights possessed by Washington Mutual, and the common law of assignments is broad enough to encompass the circumstances set forth in this case.
Allen v. LaSalle Bank, N.A., 629 F.3d. 364 (2011) DECIDED January 12, 2011
Plaintiff filed a class action lawsuit against multiple parties alleging violation of 15 U.S.C. §1692f(1) because the servicer’s attorney sent the borrower’s attorney a payoff letter which contained allegedly excessive fees in connection with the foreclosure of her home. The district court dismissed the complaint holding that communication from a debt collector to a consumerʹs attorney should be analyzed under the standard of a competent attorney, and because a competent attorney would have recognized the charges as being excessive, the complaint failed to state a cause of action. The Third Circuit reversed the decision finding that §1692f (1) was a strict liability statute which did not depend upon the nature of the recipient, and that the letter to the consumerʹs attorney constituted an indirect communication with the consumer herself.
Deutsche Bank National Trust Company as Trustee v. Wilson, Unpublished Appellate Division Opinion Docket Number A‐1384‐09T1, Decided January 19, 2011
Appellate Division reversed summary judgment in favor of the foreclosing plaintiff. The Appellate Division found the affidavits submitted in support of plaintiff’s motion for summary judgment failed to establish the criteria for the admission of business records as exceptions to the hearsay rule; the affidavits failed to attach the computer printouts in support of the affidavit; and, the party executing the affidavit was employed by a company other than the servicer, but signed under corporate authority, as an officer of the plaintiff.
U.S. Bank National Association, as Trustee for JP Morgan Acquisition Corp. 2006‐FRE2, Asset Backed Pass‐Through Certificates, Series 2006‐FRE2 v. Arthur Spencer, et.al, Docket No. BER‐10591‐10, Unpublished Trial Court Opinion, DECIDED March 22, 2011
The court dismissed plaintiff’s foreclosure complaint on defendant’s motion for summary judgment because the plaintiff failed to prove it had physical possession of the note and standing to pursue the foreclosure under the requirements of the New Jersey Uniform Commercial Code; failed to present a prima facie case with evidence from a competent witness; and, the Defendant raised defenses which would have required further exploration. The
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property was destroyed by fire and the proper application of insurance proceeds was disputed between the parties, although the default of the mortgage was not in dispute.
Wells Fargo Bank, N.A., as Trustee v. Sandra A. Ford, ___ N.J. Super ___ (App. Div. 2011) Docket No: A‐3627‐06T1, Approved for Publication; DECIDED January 28, 2011
The Appellate Division reversed the trial court’s grant of summary judgment in favor of the plaintiff. The defendants challenged the plaintiff’s standing to bring the foreclosure action and whether the plaintiff was the holder, as well as the holder in due course. The Appellate Division found that the documents relied on in plaintiff’s motion for summary judgment were not properly authenticated and did not support the grant of summary judgment. If properly authenticated, the documents presented may support summary judgment. Once the plaintiff presents adequate evidence that it is the holder, the question of whether it is the holder in due course, and therefore not subject to certain defenses pertaining to origination, can be addressed.
U.S. Bank v. Gleason, Unpublished Trial Court Opinion, Docket No: F ‐5319‐08, Passaic County; DECIDED March 15, 2011
The trial court dismissed the foreclosure because the plaintiff failed to prove standing, as defined in the New Jersey Uniform Commercial Code, at trial. The plaintiff did not present a witness qualified to testify as to whether the loan was properly secured into the trust, in accordance with the terms of the pooling and servicing agreement, by delivery of possession of the note. Nor could the witness explain why documents, specifically a series of executed assignments, contradicted the documents previously presented to the Court. The contradictory assignments raised questions about the chain of title. Given the inadequacy of the evidence, despite the existence of an undisputed default, the complaint was dismissed.
The Bank of New York Mellon‐F/K/A The Bank of New York Trustee Under The Pooling and Servicing Agreement Series 2004‐24 CB v. George C. Elghossain, __ N.J. Super ___ (Ch. Div. 2010) Docket No: F‐13402‐10, Decided December 23, 2010; Approved for Publication April 4, 2011 (J. Berman)‐‐DECIDED
The Court dismissed the foreclosure complaint without prejudice for failure to comply with the Fair Foreclosure Act’s requirements pertaining to the pre‐foreclosure notice of intention to foreclose. The Court viewed the statute as requiring strict compliance with its provisions. Specifically, court found that the notice sent by the plaintiff’s servicer did not comply with the statute because it listed only the servicer and the servicer’s address, omitting the name of the lender and the lender’s address. The court pondered the question of whether the lender must
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also be the party to mail the notice, but concluded that the issue of who may mail the notice was not before the court.
US Bank NA, as Trustee v. Guillaume, Unpublished Appellate Division Opinion, A‐0376‐10T3 DECIDED April 20, 2011
The Appellate Division upheld the trial courtʹs denial of application to vacate default judgment. The defendants alleged that they had a meritorious defense because the plaintiff violated the Fair Foreclosure Act, specifically; the NOI listed the servicerʹs address and not the lenderʹs address. The Appellate Division setout N.J.S.A. 2A:50‐56c, to wit, the FFA notice (NOI) requires “[t]he name and address of the lender and the telephone number of a representative . . . ”, but stated, ʺ[t]he NOI satisfied the purpose of the FFA because ASC (the servicer) is the appropriate party for the Guillaumes to contact to cure their default.”
Thank you for logging in – the webinar will begin shortly.s o t y
•The Honorable Margaret M McVeigh Presiding Judge of the Chancery •The Honorable Margaret M. McVeigh, Presiding Judge of the Chancery Court for the County of Passaic
•Kevin M. Wolfe, Esquire, Assistant Director, Administrative Office of the Kevin M. Wolfe, Esquire, Assistant Director, Administrative Office of the Courts for the Civil Practice Division
•Rosemarie Diamond, Esquire, Phelan Hallinan & Schmiegq g
•Bruce Levitt, Esquire, Levitt & Slafkes, P.C.
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NJICLE PRESENTS: MORTGAGE FORECLOSURE MORTGAGE FORECLOSURE UPDATE
A NJICLE Webinar
Topics to be Coveredp
Mortgage Mediation ProgramMortgage Mediation ProgramAppointment of Special Master: Order to Show Cause, Administrative Order and Amendment to Cause, Administrative Order and Amendment to Court Rules of 12/20/10Seeking Stays of Sheriff’s SalesSeeking Stays of Sheriff s SalesThe New Jersey Foreclosure Fairness ActOffice of Foreclosure UpdatesOffice of Foreclosure UpdatesCase Law Updates (available on request)
Mortgage Mediationg g
Overview and Updatesp- Where to get the forms?- Recommendations for Preparation
Perspectives on the Program- Perspective of the Judiciary- Perspective of the Administrative Office- Perspective of Lender’s Counsel- Perspective of Borrower’s Counsel
Court’s Response to Servicer D t ti IDocumentation IssuesOn December 20, 2010, the following actions were taken:, , gThe Supreme Court adopted emergency foreclosure rules
to Court Rules 1:5-6, 4:64-1 and 4:64-2, requiring fil ffid i f d diliattorneys to file affidavits of due diligence;
Mary C. Jacobson, P. J. Ch., for Mercer County, issued an Order to Show Cause directed to six lender-servicers in Order to Show Cause directed to six lender servicers in response to servicer documentation issues widely reported in the media.
Glenn A. Grant, Acting Administrative Director of the Courts, issued an Administrative Order directed to twenty-four other lender-plaintiffs.twenty four other lender plaintiffs.
O M h 29 2011 J d J b d d On March 29, 2011, Judge Jacobson entered an order approving the Recommended Stipulation submitted by the Court’s appointed counsel, Edward Dauber, by the Court s appointed counsel, Edward Dauber, Esquire. The order includes appointment of a Special Master.
From February 1, 2011 to February 28, 2011, a public comment period was opened with respect to the emergent rule amendment. The Court’s response is anticipated in early May of 2011is anticipated in early May of 2011.
Please record this code for your MCLE forms:page@59th
Seeking Stays of Sheriff’s Salesg y
Forms Available on Judicial Website and at local Forms Available on Judicial Website and at local courthouse for use by counsel and pro se defendants
Recommendations for seeking a stay:-Has the defendant exhausted his statutory Has the defendant exhausted his statutory
adjournments?- What is the basis for the request for the stay?What is the basis for the request for the stay?
The New Jersey Foreclosure Fairness Act (“NJFFA”)( NJFFA )
The NJFFA was enacted on January 17, 2010, The NJFFA was enacted on January 17, 2010, amending the Mortgage Stabilization and Relief Act passed in 2009.p
Relevant Provisions:(1) Notices to Municipalities( ) N M p(2) Maintenance of Abandoned Properties(3) Tenants’ Rights under Anti-Eviction Act(3) Tenants Rights under Anti Eviction Act(4) Notice of Right to opt in to Stay of Foreclosure
Updates from the Office of Foreclosurep
- Affidavit/ Certification of Due DiligenceAffidavit/ Certification of Due Diligence- Staffing
Expedited (Substantial) Commercial Mortgage - Expedited (Substantial) Commercial Mortgage Foreclosure
JEFIS - Foreclosure
JEFIS – ForeclosureJEFIS Foreclosure- Electronic filing and electronic case jackets
Public Access- Public Access- Foreclosure Auto Storage
Superior Court Clerk Docket (ACMS)- Data Entry Responsibilities
The webinar has ended.
The program handbook, relevant CLE forms and additional materials for this program can be additional materials for this program can be accessed at: njicle.com/webinar
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