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 MOTION for FIRST ORDER of NOTICE FORECLOSURE ACTION 2020-2025

Notice Foreclosure Action 2020-2025 Form

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may please the court my name is nicole moskowitz i represent pablo salazar council would you like to reserve some time for rebuttal yes three minutes please now this was a um foreclosure case in which judgment was entered upon a motion for summary judgment the appellant then filed a motion to vacate the sale and the judgment based upon the fact that he had been told by the bank that he was under well he was in uh on review for a loan modification and was told not to worry about the summary judgment and that the case would be resolved and the bank was overwhelmed and that's why it was taking a long time and upon the motion to vacate the judgment the court withheld the issuance of title pending an explanation from the bank about why um pending about why the loan modification denied the motion denied the motion correct to set aside the judgment correct so what jurisdiction was left at that point your honor the judgment specifically reserve jurisdiction to enter further orders that

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