NOTICE TO ABSENT DEFENDANTS
Docket No: F-1088-25
SUPERIOR COURT OF NEW JERSEY, CAMDEN COUNTY
STATE OF NEW JERSEY
TO: IDA JEFFERSON, her heirs, devisees and personal representatives and their or any of their successors in right, title and interest; NIKOL LIGON, Individually and as heir to Ida Jefferson; MICHAEL TRYKOWSKI a/k/a MIECZYSLAW TRYKOSKI a/k/a MICHAEL TRACY his heirs, devisees and personal representatives and their or any of their successors in right, title and interest; BENJAMIN TRYKOWSKI, Individually as heir to MICHAEL TRYKOWSKI a/k/a MIECZYSLAW TRYKOSKI a/k/a MICHAEL TRACY, his heirs, devisees and personal representatives and their or any of their successors in right, title and interest and LEROY NUNN, possible heir to Ida Jefferson
You are hereby summoned and required to serve upon GARY C. ZEITZ, L.L.C., Plaintiff's Attorney, whose address is 1101 Laurel Oak Road, Suite 170, Voorhees, New Jersey 08043, an answer to the Complaint (and any amendments thereto) filed in a civil action in which Pro Cap 8 FBO Firstrust Bank is Plaintiff and Ida Jefferson and Nikol Ligon, et al. are Defendants pending in the Superior Court of New Jersey, Chancery Division, Camden County and bearing Docket No. F-1088-25, within thirty-five (35) days after September 12, 2025, exclusive of such date. If you fail to do so, judgment by default may be rendered against you for the relief demanded in the Complaint. You shall file your answer and proof of service in duplicate with the Clerk of the Superior Court of New Jersey, Hughes Justice Complex, 25 West Market Street, P.O. Box 971, Trenton, New Jersey 08625, in accordance with the Rules of Civil Practice and Procedure.
This action has been instituted for the purpose of foreclosing tax sale certificate #21-00287 dated December 14, 2021, made by the Collector of Taxes for the City of Camden, County of Camden and State of New Jersey and recorded in the office of the Camden County Clerk/Register in mortgage book 11993, page 308; and covers real estate located at 912 Atlantic Ave, City of Camden, County of Camden and State of New Jersey known as Block 416, Lot 65, as shown on the Tax Assessment Map and Tax Map duplicate of the City of Camden .
NOTIFICATION OF RIGHTS RELATING TO SURPLUS EQUITY (a) the
within action could result in the loss of the property owners' equity in the property; (b) the
potential loss of equity is a valid basis for contesting the tax foreclosure; and (c) the property
owner has the ability to request a sheriff's sale of the property which would require any surplus
beyond the amount owed to be deposited with the Superior Court Trust Fund.
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.
NOTICE OF THE OWNER'S, OR OWNER'S HEIRS RIGHT TO REQUEST A SHERIFF'S SALE:
THE OWNER, OR OWNER'S HEIRS, OF THE PROPERTY BEING FORECLOSED HAS THE RIGHT TO DEMAND THAT THE FORECLOSURE PROCEED TO A JUDICIAL SALE OF THE SUBJECT PROPERTY AS IN THE MANNER OF THE FORECLOSURE OF A MORTGAGE, OR AN INTERNET AUCTION, BY THE OFFICE OF THE COUNTY SHERIFF TO PRESERVE ANY EQUITY THAT MAY BE IN THE PROPERTY.
IN ORDER FOR THE SHERIFF'S SALE TO OCCUR, THE OWNER, OR OWNER'S HEIRS, MUST FILE A WRITTEN REQUEST CONTAINING THE DEMAND WITH THE CLERK OF THE SUPERIOR COURT, HUGHES JUSTICE COMPLEX, P.O. BOX 971, TRENTON, NJ 08625-0971, BEFORE THE DATE THAT A FINAL JUDGMENT IS ENTERED. IF THE OWNER, OR OWNER'S HEIRS, DEMAND A JUDICIAL SALE, IN A TIMELY MANNER, THE SUPERIOR COURT WILL ORDER THE ENTRY OF A FINAL JUDGMENT AND WRIT OF EXECUTION DIRECTING THAT THE SUBJECT PROPERTY BE SOLD AT A JUDICIAL SALE, AND ANY SURPLUS BEYOND THE AMOUNT OWED ON THE TAX LIEN WILL BE DEPOSITED WITH THE SUPERIOR COURT TRUST FUND.
IF THE OWNER, OR OWNER'S HEIRS, DO NOT MAKE A TIMELY DEMAND FOR A JUDICIAL SALE, THE FORECLOSURE ACTION OF THE SUBJECT PROPERTY SHALL PROCEED TO A FINAL JUDGMENT WITHOUT A JUDICIAL SALE, WHICH COULD RESULT IN THE LOSS OF EQUITY IN THE PROPERTY.
The record owner of the lands and premises is/are IDA JEFFERSON, her heirs, devisees and personal representatives and their or any of their successors in right, title and interest; NIKOL LIGON, Indvidually and as heir to Ida Jefferson and such owner(s) is/are named as proper party Defendant(s) to this action to foreclose his/her/their interest, and that of his/her/their successors, in the land and premises described in this Count of the Complaint.
YOU, MICHAEL TRYKOWSKI a/k/a MIECZYSLAW TRYKOSKI a/k/a
MICHAEL TRACY his heirs, devisees and personal representatives and their or any of their successors in right, title and interest; BENJAMIN TRYKOWSKI, Individually as heir to MICHAEL TRYKOWSKI a/k/a MIECZYSLAW TRYKOSKI a/k/a MICHAEL TRACY his heirs, devisees and personal representatives and their or any of their successors in right, title and interest, are joined as a party defendant to this action for any right, title, interest or claim he/she, his/her heirs or successors may have in or to the subject property by virtue of dower, curtesy, inheritance or for any other reason.
YOU, LEROY NUNN, possible heir to Ida Jefferson is joined as a party defendant to this action for any right, title, interest or claim he/she, his/her heirs or successors may have in or to the subject property by virtue of dower, curtesy, inheritance or for any other reason.
If you are unable to obtain an attorney, you may communicate with the New Jersey State Bar Association by calling (732)249-5000. You may also contact the Lawyer Referral Services of the county of venue by calling 856-964-4520. If you cannot afford an attorney, you may communicate with the Legal Services Office of the county of venue by calling 856-964-2010.
The nature of which and the reason that you and each of you are joined as defendants is set forth with particularity in the complaint (and any amendments thereto) a copy of which will be furnished you on request addressed to the attorneys of the Plaintiff at the above mentioned address.
Dated: September 8, 2025 /s/ Michelle M. Smith, Esq.
Michelle M. Smith, Esquire, Clerk
Superior Court of New Jersey
September 12 2025
LNYS0367457
$104.52