Kamikaze Capital v Hickson, Alice F-1730-25

Kamikaze Capital v Hickson, Alice F-1730-25 NOTICE TO ABSENT DEFENDANTS Docket No: F-1730-25 SUPERIOR COURT OF NEW JERSEY, CAMDEN COUNTY STATE OF NEW JERSEY TO: ALICE HICKSON, her heirs, devisees and personal representatives and their or any of their successors in right, title and interest; HEARTWOOD 55, LLC; JEROME BAILEY, heir to Alice Hickson, his heirs, devisees and personal representatives and their or any of their successors in right, title and interest; HARRIET PERRY, Heir to Alice Hickson, her heirs, devisees and personal representatives and their or any of their successors in right, title and interest; DESTYNI LOWERS; BAIL BONDS OF AMERICA; ROSIE JIGGETTS and POWANDA DIMARCO 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 Kamikaze Capital, LLC is Plaintiff and Willie Hickson and Alice Hickson, et al. are Defendants pending in the Superior Court of New Jersey, Chancery Division, Camden County and bearing Docket No. F-1730-25, within thirty-five (35) days after November 14, 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 #09-03487 dated June 29, 2009, made by the Collector of Taxes for the City of Camden, County of Camden and State of New Jersey, to Mooring Tax Asset Group, LLC and recorded in the office of the Camden County Clerk/Register in mortgage book 9190, page 1127. Most recent assignment recorded on September 10, 2024 in mortgage book 12655 at page 1613; and covers real estate located at 1326 Decatur St, City of Camden, County of Camden and State of New Jersey known as Block 1373, Lot 94, 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 ALICE HICKSON, her his heirs, devisees and personal representatives and their or any of their successors in right, title and interest and such owner is named as proper party Defendant 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, HEARTWOOD 55, LLC is a defendant to this action because he/she/it is the current holder of Tax Sale Certificate #7-2731 dated July 10, 2006 and recorded on August 11, 2006 at mortgage book 8295, page 1031, in the principal amount of $1399.24. The most recent assignment recorded on October 10, 2012 at mortgage book 9674, page 723. YOU, JEROME BAILEY, heir to Alice Hickson, his heirs, devisees and personal representatives and their or any of their successors in right, title and interest and HARRIET PERRY, Heir to Alice Hickson, her heirs, devisees and personal representatives and their or any of their successors in right, title and interest are joined as party defendants 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, DESTYNI LOWERS are joined as a defendant to this action by virtue of the following judgment: judgment number J-229761-2014 dated December 2, 2014 in an amount that varies date to date for child support against Corey Jones. YOU, BAIL BONDS OF AMERICA; are joined as a defendant to this action by virtue of the following judgment: judgment number DJ-228149-2012 dated October 19, 2012 in the amount of $1,337.50 against Kyle Klotz, Cory Jones and Pamela Bethea. YOU, ROSIE JIGGETTS are joined as a defendant to this action by virtue of the following judgment: judgment number J-297661-2010 dated November 17, 2010 in the amount of $230,000.00 against Sharon Jones and Mary Alice Jones. YOU, POWANDA DIMARCO are joined as a defendant to this action by virtue of the following judgment: judgment number DJ-113525-2010 dated April 27, 2010 in the amount of $34,850.00 against Urban Angels Daycare Center Inc and Crystal L Jones. 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: November 11, 2025 /s/ Michelle M. Smith, Esq. Michelle M. Smith, Esquire, Clerk Superior Court of New Jersey November 14 2025 LNYS0406152 $121.68