Notice of Motion for Entry of Final Judgment
(Residential Foreclosure) (NJ)

Summary

This template notice of motion for entry of final judgment may be included in a residential foreclosure plaintiff's application for final judgment in New Jersey. This template includes practical guidance and drafting notes. In a residential foreclosure action in New Jersey, once a default has been entered and the 14-day notice to cure has been mailed out and expired, the plaintiff may make application for the entry of final judgment upon notice to the borrower and all answering defendants. See N.J. Court Rules, R. 4:64-1(d) and N.J. Court Rules, R. 4:64-9. N.J. Court Rules, R. 4:64-2 R. sets forth the procedure for an application of final judgment in foreclosure. Notice of motion is one of many documents that must be included in the application and it must follow the form prescribed in N.J. Court Rules, R. 4:64-9. The notice must be served on all parties obligated on the note and all parties who have appeared in the action, including those who's answers have been stricken or rendered non-contesting. Any objections must comport with N.J. Court Rules, R. 4:64-2(d)(2). See also N.J. Court Rules, R. 1:34-6. For additional templates that must be included in the application for final judgment see Residential Foreclosure Resource Kit (NJ). For additional guidance on residential foreclosure in New Jersey see Residential Foreclosure (NJ).