NOTICE OF IN REM FORECLOSURE OF TAX LIEN TITLES SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION-BURLINGTON COUNTY DOCKET NUMBER F-10114-25 By: FIG 20, LLC FBO SEC PTY TAKE NOTICE that an action, In Rem, has been commenced in the Superior Court of New Jersey, by the filing of a Complaint on September 23, 2025, to foreclose and forever bar any and all rights of redemption of the parcels of land described in tax foreclosure list below from Plaintiff's tax lien titles The action is brought against the land only and no personal judgment may be entered therein. That any person desiring to protect a right, title or interest in the described lands or any parcel thereof, by redemption, or to contest Plaintiff's right to foreclosure must do so by paying the amount required to redeem, plus interest to the date of redemption, and such costs, as the court may allow prior to the entry of judgment herein, or by filing and serving an answer to this Complaint setting forth Defendants' defense within forty-five (45) days after the date of publication of this notice. NOTICE OF SURPLUS EQUITY AFFIRMATIVE DEFENSE: Pursuant to New Jersey Court Rule 4:64-1c ("Definition of Uncontested Action") any allegation in a responsive pleading to this complaint that a party has existing equity in the property shall be treated as a contesting answer to this tax foreclosure complaint. Pursuant to Tyler v. Hennepin County, 598 U.S. 631, 143 S. Ct. 1369 (2023), a property owner may be entitled to the surplus which would be realized over and above the amount due to the plaintiff lienholder. According to Black's Law Dictionary 657 (10th ed. 2014), "surplus" is "an amount of something that is more than what is required or used." If you believe there is a surplus beyond the amount owed to the plaintiff, you must assert same in a responsive pleading. NOTIFICATION OF RIGHTS RELATING TO SURPLUS EQUITY (a) the within action could result in the loss of the property owners' equity in the property; and (b) the potential loss of equity is a valid basis for contesting the tax foreclosure. In the event of failure to redeem or answer by any person having the right to redeem or answer, such person shall be forever barred and foreclosed of his right, title and interest and equity of redemption in and to the parcels of land described in the following tax foreclosure list. The following is a copy of the tax foreclosure list showing the lands against which this action is brought. TAX FORECLOSURE LIST Schedule #: 1 Certificate Number: 24-00021 Name of Owner as it appears on last Tax Duplicate: MONTROSE PORTFOLIO LLC Description of lands as it appears on tax dupl. & Certificate of Sale: Block 124, Lot 20 Township of Willingboro, County of Burlington, 10 Shelbourne Ln, Willingboro, New Jersey Date of Tax Sale: 10/16/2024 Amount of Sale: $2,867.91 Amount of Liens accruing subsequent to Tax Sale: $3,863.50 Amount to Redeem as of November 21, 2025: $6,731.41 Date of Recording: 12/17/2024 Book and Page in County Clerk's Office: Bk. OR13747, P. 3377 THE AMOUNT TO REDEEM CHANGES DAILY. FOR AN EXACT REDEMPTION AMOUNT, CONTACT THE TOWNSHIP OF WILLINGBORO TAX COLLECTOR'S OFFICE AT (609)877-2200 x1005. GARY C. ZEITZ, LLC Gary C. Zeitz, Esquire Attorney for Plaintiff 1101 Laurel Oak Road, Suite 170 Voorhees, NJ 08043 Date: November 21, 2025 November 21 2025 LSOM0408940 $55.80