PELLEGRINO & FELDSTEIN, L.L.C. Seth A. Kurs, Esq. 290 Route 46 West Denville, NJ 07834 (973) 586-2300 CAP File No. 30811-24 skurs@taxlienlawyer.net Attorneys for Plaintiff(s) ACT PROPERTY LLC, Plaintiff vs. HAROLD F. WOODS; MRS. HAROLD F. WOODS, WIFE OF HAROLD F. WOODS; DRAKESVILLE AT ROXBURY HOMEOWNERS' ASSOCATION, INC. Defendant(s) SUPERIOR COURT OF NEW JERSEY MERCER COUNTY CHANCERY DIVISION FORECLOSURE DOCKET NO. F-012478-24 CIVIL ACTION NOTICE OF MOTION NOTICE OF MOTION FOR RECONSIDERATION OF MODIFIED FINAL JUDGMENT AND ORDER DIRECTING JUDICIAL SALE AND TO NEGATE REQUEST FOR JUDICIAL SALE Harold F. Woods Mrs. Harold F. Woods, Wife of Harold F. Woods 175 Drake Lane Apartment 32 Ledgewood, NJ 07852-9674 haroldwoods10@outlook.com 175 Drake Lane Apartment 32 Ledgewood, NJ 07852-9674 8811 Bergen Line Avenue Apt. 64 North Bergen, NJ 07047-5265 8811 Bergen Line Avenue Apt. 64 North Bergen, NJ 07047-5265 79 Malapardis Road Morris Plains NJ 07950-2508 79 Malapardis Road Morris Plains, NJ 07950-2508 500 80th Street North Bergen, NJ 07047-5061 500 80th Street North Bergen, NJ 07047-5061 9009 3rd Avenue Apartment 1A North Bergen, NJ 07047-5219 9009 3rd Avenue Apartment 1A North Bergen, NJ 07047-5219 C/O Clerk Of The Superior Court Of New Jersey Hughes Justice Complex 25 West Market Street, CN971 Trenton, NJ 08625 C/O Clerk Of The Superior Court Of New Jersey Hughes Justice Complex 25 West Market Street, CN971 Trenton, NJ 08625 Drakesville At Roxbury Homeowners' Association, Inc. C/O Registered Agent Griffin Griffin & Alexander PC 415 Rt 10, Ste 68 Randolph, NJ 07869 Tax Collector of Roxbury 1715 Route 46 Ledgewood, NJ 07852 PLEASE TAKE NOTICE that on July 3, 2026, at 09:00 a.m., or as soon thereafter as counsel may be heard, before the Honorable James M. DeMarzo, P.J.Ch., at the Morris County Courthouse, Court Street & Washington Street, P.O. Box 910, Morristown, NJ 07960-0910, Plaintiff ACT PROPERTY LLC will move this Court for an Order: Granting Plaintiff's Motion for Reconsideration of the Modified Final Judgment and Order Directing Judicial Sale entered on January 22, 2026;Striking or negating the purported demand for judicial sale filed on January 9, 2026, as having been filed by unknown third parties without authorization from Defendant Harold F. Woods;Vacating or modifying the directives in the January 22, 2026 order requiring that the foreclosure proceed by way of judicial sheriff's sale;Permitting the matter to proceed to entry of final judgment vesting title in Plaintiff in accordance with the ordinary tax-foreclosure process; andGranting such other and further relief as the Court deems just and proper. This motion is made pursuant to the express authorization and directive of this Court's Order Memorializing May 29, 2026 Conference, which granted Plaintiff leave to file a motion for reconsideration out of time and to seek to negate the alleged letter filed by Harold Woods. This motion is supported by the accompanying Brief in Support of Motion for Reconsideration and the Certification of Mailing documenting service of this motion. The grounds for this motion are: The Court's May 29, 2026 Order expressly authorized this out-of-time motion for reconsideration and to negate the January 9, 2026 letter;Defendant Harold F. Woods has failed to appear at two court-ordered Case Management Conferences scheduled for February 19, 2026 and May 29, 2026, despite proper notice;The Court's January 22, 2026 order required confirmation of the identities and interests of all parties before proceeding with the sheriff's sale, and this prerequisite has not been satisfied;Despite diligent efforts by Plaintiff and the Court, Defendant Woods cannot be located or contacted by any means, including email, telephone, mail, or personal service;The Court has placed on the record its concerns regarding the authenticity of the January 9, 2026 letter and the possibility of third-party involvement; The standards for reconsideration under New Jersey law are satisfied based on newly discovered evidence, changed circumstances, and questions regarding the authenticity of the January 9 letter; and The Court has authority under Rule 1:2-4 to strike filings when a party fails to appear at court-ordered proceedings and has inherent equitable authority to protect the integrity of the judicial sale and surplus distribution process. DATED: June 10, 2026 PELLEGRINO & FELDSTEIN, LLC Seth A. Kurs, Esq. Attorney for Plaintiff PELLEGRINO & FELDSTEIN, L.L.C. Seth A. Kurs, Esq. 290 Route 46 West Denville, NJ 07834 (973) 586-2300 CAP File No. 30811-24 skurs@taxlienlawyer.net Attorneys for Plaintiff(s) ACT PROPERTY LLC, Plaintiff vs. HAROLD F. WOODS; MRS. HAROLD F. WOODS, WIFE OF HAROLD F. WOODS; DRAKESVILLE AT ROXBURY HOMEOWNERS' ASSOCATION, INC. Defendant(s) SUPERIOR COURT OF NEW JERSEY MERCER COUNTY CHANCERY DIVISION FORECLOSURE DOCKET NO. F-012478-24 CIVIL ACTION CERTIFICATION I, Seth A. Kurs, Esq., of full age, hereby certify as follows: I am an attorney of Pellegrino & Feldstein, LLC, and I am authorized to make this Certification on behalf of Plaintiff ACT Property LLC.I have personal knowledge of the facts set forth herein, or such facts are based upon a review of the business records maintained by Plaintiff and/or its counsel in the ordinary course.On January 9, 2026, a letter purporting to be from Defendant Harold Woods was filed with the Court requesting that this tax foreclosure proceed by way of a judicial (sheriff's) sale and asserting a claim to surplus equity.On January 22, 2026, the Court entered a Modified Final Judgment and Order Directing Judicial Sale, including a requirement that, prior to scheduling any sheriff's sale, the Court would hold an in-person conference to confirm the identities and interests of all parties.Defendant Harold F. Woods failed to appear at the Court's February 19, 2026 case management conference, despite notice, and Plaintiff's counsel and the Court made multiple attempts to contact him, including by email at haroldwoods10@outlook.com, without response.Plaintiff attempted additional efforts to locate and serve Defendant Woods, including mailing and attempting personal service at an alternative address provided by the Homeowners' Association (8811 Bergen Line Avenue, Apt. 64, North Bergen, New Jersey), without response after three attempts, and a postal search confirmed no change of address on file.On May 5, 2026, the Court rescheduled the case management conference and advised Defendant Woods that if he failed to appear or respond, the Court may strike his request for a sheriff's sale and surplus equity as having been filed by unknown third parties and may proceed to vest title in Plaintiff in accordance with law.Defendant Harold F. Woods failed to appear at the May 29, 2026 case management conference despite notice by eCourts, direct email, and regular mail.On May 29, 2026, the Court entered an Order Memorializing the May 29, 2026 Conference granting Plaintiff leave to file a motion for reconsideration out of time and to seek to negate the alleged letter filed by Harold Woods and directing Plaintiff to make diligent attempts to serve Defendant Woods personally, by regular and certified mail, and by publication if necessary.I make this Certification in support of Plaintiff's motion consistent with the Court's May 29, 2026 Order. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. DATED: June 10, 2026 PELLEGRINO & FELDSTEIN, LLC Seth A. Kurs, Esq. Attorney for Plaintiff June 12 2026 LNYS0536742 $152.88