Shapiro & DeNardo LLC

Shapiro & Denardo LLC located in Mount Laurel, NJ continue to mail letters to my home address and certified mail from the U.SPostage ServiceThe letters states that I am a heir to *** *** *** *** *** the parties are deceased and had a mortgage with *** *** *** with a property in *** *** *** The property was purchased in I mailed a response to Shapiro & Denardo LLC *** *** *** *** *** ** ***My letter indicated the parties are unknown to me as well as my in-lawsI was divorced in July I did not return to my maiden nameI have continued receiving letters from November through the present dateI had a one hour counsel session with an attorney who stated this is a scam

We are in receipt of your letter, dated April 23, 2017, notifying our office that a complaint was submitted on April 11, 2017, by [redacted].  Please note that our office does not have any record of any communication or correspondence from [redacted]  Our firm...

represents the plaintiff, [redacted] et al., in a mortgage foreclosure action pertaining to real property commonly known as [redacted]  [redacted] and her husband, [redacted], were the owners of that property.  On October 17, 2000, Mr. and Mrs. [redacted] borrowed $90,000.00 from Delta Funding Corp. and gave a mortgage upon the aforementioned property.  That mortgage was assigned to [redacted] Minnesota, N.A. (et al.) and then to plaintiff, [redacted], et al.  On June 19, 2009, the loan went in to default for missed payments. On August 25, 2016, a complaint in mortgage foreclosure was filed[redacted]  In attempting to effectuate personal service of the complaint upon [redacted] plaintiff learned that both were deceased. Mr. [redacted] passed away in 2004, leaving Mrs. [redacted] as the sole owner by operation of law.  Mrs. [redacted] then passed away on or about January 25, 2016.  When the owner of real property dies, whether testate or intestate, the owner’s heirs are necessary and proper parties in a proceeding to foreclose a mortgage on the decedent’s property.  [redacted] [redacted] (heirs are “necessary and proper parties” and a decree in foreclosure is not binding upon them if they were excluded from the proceeding); [redacted] [redacted]) (a judgment of foreclosure is not binding on heirs omitted from the foreclosure proceeding).  In New Jersey, a mortgage foreclosure proceeding is an in rem action; plaintiff simply seeks to foreclose the right of redemption for anyone that may hold an interest in the property and also gain possession of the property.  Plaintiff is not seeking an in personam judgment against [redacted].    Upon learning of [redacted] deaths, plaintiff performed a diligent search to discover any heirs that must be named parties to the foreclosure complaint.  In conducting its search for heirs, plaintiff discovered an obituary for [redacted].  (See attached.)  That obituary names [redacted] as the “[b]eloved mother of…[redacted]  Plaintiff then performed a skip trace for [redacted], which provided an address in [redacted].  The address and email of [redacted], provided in the skip trace, are identical to that within the Customer Information section of the subject Revdex.com complaint. On October 3, 2016, plaintiff filed an Amended Complaint, naming as additional defendants the known heirs of [redacted], one of whom is [redacted].  (See attached.)  Paragraph 17 of the Amended Complaint specifically stated that [redacted] – along with several other individuals – were being joined as heirs of [redacted] [redacted] a/k/a [redacted] for any right, title, and interest [she] may have in the mortgaged premises. Pursuant to court rules, plaintiff then sought to serve [redacted] with the foreclosure complaint and summons.  Ultimately, [redacted] was served via publication and a Certification of Inquiry was filed on or about January 10, 2017.  (See attached.)  No responsive pleadings were filed by any defendants, therefore a request for default was submitted to the court.  Final judgment was entered on March 15, 2017, and a writ of execution issued simultaneously.  A sheriff’s sale of the mortgaged premises is scheduled for June 22, 2017.  [redacted] would have received notices of the default, final judgment, and sheriff’s sale, as per the New Jersey Rules of Court.  Shapiro & DeNardo LLC has at all times acted appropriately and in compliance with all relevant rules, regulations, statutes, and decisional law.  Should you have any questions or require any additional information, please feel free to contact me directly at [redacted] ** [redacted]
 Sincerely,      Chandra A[redacted]Managing Partner###-###-#### Office ###-###-#### Fax [redacted] [redacted]