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JOHN LAWYER, ESQ. 12 Main Street Anywhere, USA Attorneys for Plaintiff ______________________________ JANE DOE, As Administratrix of the Estate of JOHN DOE,Plaintiff, vs. BARBARA DOE, Defendant. _______________________________ SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION [insert]COUNTY DOCKET NO. CIVIL ACTION COMPLAINT FOR FORECLOSURE Plaintiff, Jane Doe, As Administratrix of the Estate of John Doee ("Plaintiff"), by and through her attorneys, [insert] alleges as follows: 1. Plaintiff Jane Doe is the Administratrix of the Estate of John Doe, with Mrs. Doe maintaining, her principal place of residence at [insert address]. 2. Upon information and belief, defendant Barbara Doe is a United States citizen and resident of the State of [insert], [insert] County. Defendant Barbara Doe, upon information and belief, maintains her principal place of residence at [insert address]. FIRST COUNT (Foreclosure) A. The Loan 3. On or about [insert date], John Doe ("Lender") made a loan to defendant in the original amount of $[insert] (the "Loan"). 4. To evidence its indebtedness under the Loan, on or about [insert date], defendant executed and delivered to Lender a certain promissory note (the "Note") in the original principal amount of $[insert], payable in equal monthly installments of principal and interest in the amount of $[insert] to be paid on the first day of each and every month beginning on the first day of [insert date] and continuing until [insert date], when the final payment was due and owing. The Note provided for interest at an initial rate of [insert]% per annum. 5. To secure payment of the Note, on or about [insert], the defendant executed and delivered a Mortgage ("Mortgage") in favor of Lender in the original principal amount of $[insert]. The Mortgage was recorded on [insert] in the [insert] County Clerk ฀s Office in Mortgage Book [insert] at Page [insert] et seq. 6. The Mortgage encumbers all that certain real property commonly known as [insert address], and also known as Lot [insert] in Block [insert] as shown on the Tax Map of the [insert], [insert] County, [insert], including all improvements thereon, more particularly described on Exhibit 1 annexed hereto and made a part hereof (the "Mortgaged Property"). 7. A true copy of the Note and Mortgage are appended hereto as Exhibit 2. B.The Defendant ฀s Default Under the Loan Documents 8. The Note and Mortgage provided that if the defendant failed to make any payment of principal or interest within 15 days from the date it is due, such failure constituted an event of default. 9. The Note and Mortgage further provided that upon the occurrence of an event of default the whole principal sum shall bear interest at a default rate set forth therein. 10. The Note and Mortgage further provided that upon an event of default, the defendant shall be liable for all costs incurred for collecting, securing or attempti ng to collect, or securing any amounts due under both the Note and Mortgage, including reasonable attorney ฀s fees and other legal costs. 11. The Defendant defaulted under the terms of the Note and Mortgage by failing to make the monthly principal and interest payments due on [insert date].12. There is now due, owing and payable to Plaintiff under the Note and Mortgage: (i) $[insert] in principal; (ii) accrued and unpaid interest at the contract and default rates; (iii) attorneys ฀ fees, costs and expenses; and (iv) all other sums provided for under the Note and Mortgage. 13. The Mortgaged Property is commercial in nature and was never occupied by the defendant as a personal residence. Accordingly, [insert] Fair Foreclosure Act, [insert statute ], et seq., does not govern the within action. 14. Furthermore, Plaintiff does not seek a Writ of Possession to evict any occupant protected by the [insert state] Anti-Eviction Act, [insert statute], et seq. WHEREFORE, Plaintiff demands judgment against defendant as follows: A. Fixing the amount due to Plaintiff pursuant to the Note and Mortgage; B. Directing that Plaintiff be paid the amounts due pursuant to the Note and Mortgage, with interest, advances, other charges, attorneys ฀ fees and costs; C. Adjudging that the Mortgaged Property be sold according to law to satisfy the amounts due to Plaintiff; D. Barring and foreclosing the defendant from all equity of redemption in and to the Mortgaged Property; E. Awarding such other and further relief as the Court may deem just and proper. DESIGNATION OF TRIAL COUNSEL Pursuant to R. 4:25-4, John Lawyer, Esq. Is hereby designated as trial counsel in this matter. CERTIFICATION PURSUANT TO RULE 4:5-1 I hereby certify that, to the best of my knowledge and belief, the matter in controversy is not the subject of any action pending in any other court or of a pending arbitration proceeding, nor is any other action or arbitration proceeding contemplated. I know of no other parties ot her than the parties set forth in this pleading who should be joined in the above acti on. I recognize the continuing obligation of each party to file with the Court and serve on all pa rties an amended Certification if there is a change in the facts stated in the original Certification. Dated: ____________________________________ JOHN LAWYER EXHIBIT 1 [Insert legal description]