Brighter Capital v Groce, Lorrese F-5202-25

Brighter Capital v Groce, Lorrese F-5202-25 NOTICE TO ABSENT DEFENDANTS Docket No: F-5202-25 SUPERIOR COURT OF NEW JERSEY, BURLINGTON COUNTY STATE OF NEW JERSEY TO: CARSEY HERSELL ROBINSON, her heirs, devisees and personal representatives and their or any of their successors in right, title and interest; LORRESE GROCE Individually and as heir to Carsey Hersell Robinson, her heirs, devisees and personal representatives and their or any of their successors in right, title and interest; ALVESTER UNDERWOOD, heir to Carsey Hersell Robinson, her heirs, devisees and personal representatives and their or any of their successors in right, title and interest; KEITH ROBINSON, heir to Carsey Hersell Robinson, his heirs, devisees and personal representatives and their or any of their successors in right, title and interest; LAUREN ROBINSON, heir to the Estate of Keith Robinson; NATALIE ROBINSON, heir to the Estate of Keith Robinson; NATIONAL STATE BANK; SERVHL UNDERLYING TRUST 2019-1; RUTHINA JOSEPH; SHARHONDA Q WARD; AW-RITE 24/7 BAIL BONDS LLC, AGENT FOR FIRST INDEMNITY OF AMERICA INSURANCE COMPANY; SYLVIA G. CAMPBELL; AMBER BROWN; IJAAZ A PINKMAN; TERRI WILLIAMS and SONYA FRANKLIN 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 Brighter Capital LLC is Plaintiff and Carsey Hersell Robinson and Lorrese Groce, et al. are Defendants pending in the Superior Court of New Jersey, Chancery Division, Burlington County and bearing Docket No. F-5202-25, within thirty-five (35) days after December 1, 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 #16-00036 dated November 30, 2016, made by the Collector of Taxes for the City of Burlington, County of Burlington and State of New Jersey, to MTAG Cust/Empire VIII NJ PORTF and recorded in the office of the Burlington County Clerk/Register in mortgage book OR13262, page 8162. Most recent assignment recorded on January 13, 2025 in mortgage book 13750, page 4388, and covers real estate located at 810 High St, City of Burlington, County of Burlington and State of New Jersey known as Block 78, Lot 13, 14, as shown on the Tax Assessment Map and Tax Map duplicate of the City of Burlington. 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. YOU, CARSEY HERSELL ROBINSON, her heirs, devisees and personal representatives and their or any of their successors in right, title and interest; LORRESE GROCE Individually and as heir to Carsey Hersell Robinson, her heirs, devisees and personal representatives and their or any of their successors in right, title and interest; ALVESTER UNDERWOOD, heir to Carsey Hersell Robinson, her heirs, devisees and personal representatives and their or any of their successors in right, title and interest; KEITH ROBINSON, heir to Carsey Hersell Robinson, his heirs, devisees and personal representatives and their or any of their successors in right, title and interest; LAUREN ROBINSON, heir to the Estate of Keith Robinson; NATALIE ROBINSON, heir to the Estate of Keith Robinson 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, NATIONAL STATE BANK is a defendant to this action because he/she/it is the current holder of the following instrument, to wit, a mortgage executed in favor of General Home Financial Services, Inc by Joseph Robinson on July 16, 1990 and recorded on October 12, 1990 at mortgage book 4092, page 218, in the principal amount of $10,685.00. Most recent assignment recorded May 8, 1991 at mortgage book 711, page 41. YOU, SERVHL UNDERLYING TRUST 2019-1 is joined as a defendant to this action by virtue of a UCC Financing Statement filed against Alvester Underwood and recorded October 5, 2020 in book 13475 at page 7430. YOU, RUTHINA JOSEPH are joined as a defendant to this action by virtue of the following judgment: judgment number J-025581-2008 dated February 4, 2008 in an amount that varies date to date for child support against Keith Robinson. YOU, SHARHONDA Q WARD are joined as a defendant to this action by virtue of the following judgment: judgment number J-080902-2005 dated April 4, 2005 in an amount that varies date to date for child support against Darryle R Robinson. YOU, AW-RITE 24/7 BAIL BONDS LLC, AGENT FOR FIRST INDEMNITY OF AMERICA INSURANCE COMPANY are joined as a defendant to this action by virtue of the following judgment: judgment number J-017389-2016 dated January 28, 2016 in the amount of $20,375.00 against Daryle Robinson and James Swindell. YOU, SYLVIA G. CAMPBELL are joined as a defendant to this action by virtue of the following judgment: judgment number J-028221-2022 dated March 2, 2022 in an amount that varies date to date for child support against Darryl Daniel Robinson. YOU, AMBER BROWN are joined as a defendant to this action by virtue of the following judgment: judgment number J-158049-2022 dated December 1, 2022 in an amount that varies date to date for child support against Darryl L Davis Robinson. YOU, IJAAZ A PINKMAN are joined as a defendant to this action by virtue of the following judgment: judgment number J-000096-2023 dated January 3, 2023 in an amount that varies date to date for child support against Darryl Daniel Robinson. YOU, TERRI WILLIAMS are joined as a defendant to this action by virtue of the following judgment: judgment number J-112774-2008 dated May 14, 2008 in an amount that varies date to date for child support against Keith Robinson. YOU, SONYA FRANKLIN are joined as a defendant to this action by virtue of the following judgment: judgment number J-282196-2008 dated November 12, 2008 in an amount that varies date to date for child support against Keith Robinson. 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 (609) 261-4862. If you cannot afford an attorney, you may communicate with the Legal Services Office of the county of venue by calling (609) 496-4570. 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: November 25, 2025 /s/ Michelle M. Smith, Esq. Michelle M. Smith, Esquire, Clerk Superior Court of New Jersey December 1 2025 LSOM0415373 $118.42