Hsbc bank usa national association as trustee for form
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JOHN LAWYER, ESQ.12 MAIN STREETANYWHERE, USAAttorneys for plaintiffs____________________________JOHN DOE AND JANE DOE, husband and
wife,Plaintiffs,v.JAMES SMITH AND MARY SMITH,Defendants._______________________________SUPERIOR COURT OF NEW JERSEY[INSERT] COUNTY[INSERT] DIVISIONDOCKET NUMBER: CIVIL ACTIONFINAL JUDGMENTThis matter having been brought before the Court by the law firm of _____________,
L.L.C., as counsel for the plaintiffs in the above captioned action with ______________, Esq.,
appearing, with the plaintiffs seeking relief commanding the defendants to immediately remove,
demolish, or abate certain structures, debris, and encroachments upon the plaintiffs land located
in the [insert town] and commonly known as Block ____, Lot ____ in accordance with the
allegations recited in the plaintiffs verified complaint and upon the Court reviewing the papers
filed in support of this application and for good cause shown; IT IS on this _____ day of ________, 2005,ORDERED that the defendants are hereby commanded to immediately remove,
demolish, or abate all structures, debris, and encroachments upon the plaintiffs land located in
the [insert Town] and commonly known as Block ___, Lot ___ in accordance with the
allegations recited in the plaintiffs verified complaint; and it is further ORDERED that shall the defendants fail to remove, demolish or abate all structures,
encroachments and debris within ______ days of this order, then they will have been deemed to
have abandoned any right, entitlement or interest in said property and the plaintiffs may dispose
of said property as they see fit or remove, demolish or abate said structure, encroachment or
debris as they see fit; and it is furtherORDERED that shall the plaintiffs have to either remove, demolish, or abate any
structures, encroachments or debris from their property which the defendants failed to do in
accordance with this order, that the plaintiffs shall retain the right to make application before the
court for an award of damages for the cost of said removal, demolition, or abatement; and it is
furtherORDERED that in either removing, demolishing, or abating any structures or debris from
the plaintiffs land the defendants shall retain the services of a licensed and insured contractor
who shall certify to the plaintiffs the manner in which said structures, encroachments or debris
were removed, the date of such procedure(s), and exactly what structure(s) or debris was
removed from the property with said certification being provided to the plaintiffs within _____
days following the completion of all removal, demolition, and/or abatement; and it is furtherORDERED that the defendants agree to fully indemnify and hold harmless the plaintiffs
from any claims brought by third parties who sustain injuries during the removal, demolition, or
abatement of any structure, encroachment or debris from the plaintiffs land in the event the
defendants effectuate the removal, demolition or abatement through a contractor or contractors
hired by the defendants; and it is furtherORDERED that defendants shall pay to plaintiffs counsel fees in the amount of
$___________ and costs in the amount of $____________, within ______ days of the entry of
this judgment._______________________________________________ [JUDGE]
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