Motion To Enter Default

ESX-DC-014376-21 06/17/2022 12:16:10 PM Pg 1 of 4 Trans ID: SCP20221538791
OFFICE: 993 LENOX DRIVE LAWRENCEVILLE, NJ 08648-2389

MAILING: PO BOX 5315 PRINCETON, NJ 08543-5315
June 17, 2022 609-896-9060 (PHONE) 609-896-0629 (FAX)
WWW.STARK-STARK.COM
VIA ECOURTS
Clerk, Superior Court of New Jersey
Essex County Special Civil Part
465 Dr. M.L. King, Jr. Boulevard, Room 201
Newark, NJ 07102
Re: Highland Lofts Condominium Association, Inc. v. Kyle Donovan

(350 Scotland Road, Apt. 101, Orange, NJ 07050)
Docket No. ESX-DC-014376-21
Dear Sir/Madam:
Stark & Stark, A Professional Corporation, represents Highland Lofts Condominium Association.
Attached please find the following documents with respect to the above-referenced matter:
1. Notice of Motion for Entry of Default 6. Affidavit of Non-Military Service;

Judgment; 7. Certification of Providing Source of Service
2. Certification of Melissa A. Volet, Esq. Address;
3. Certification of Proof of Amount Due; 8. Proposed form of Order; and
4. Certification of Attorneys’ Fees and Costs; 9. Certification of Service.
5. Certification regarding Defendant’s Failure
to Respond to Discovery;
Please charge the filing fee to our firm’s collateral account #140139. Our attorney charge reference
number is 679760005.
Thank you for your appreciated cooperation.
Very truly yours,
STARK & STARK

A Professional Corporation
A Law Firm Engaged in Debt Collection
By: /s/ Melissa A. Volet

MELISSA A. VOLET, ESQUIRE
MAV:tao
Attachments
cc: Kyle Donovan, Pro Se (w/attachment) (via certified mail, return receipt requested & regular
mail)
David J. Montag, Esq., Milber, Makris Plousadis & Seiden, LLP, w/attachments (via regular and
certified mail, return receipt requested)
STARK & STARK, A Professional Corporation

Mailing Address: PO Box 5315, Princeton, NJ 08543-5315
Office Location: 993 Lenox Drive, Lawrenceville, NJ 08648-2389
(609) 896-9060
Melissa A. Volet, Esquire - 03080-2002
Attorneys for Plaintiff
HIGHLAND LOFTS CONDOMINIUM SUPERIOR COURT OF NEW JERSEY

ASSOCIATION, INC., LAW DIVISION, SPECIAL CIVIL PART
ESSEX COUNTY
Plaintiff,
DOCKET NO. ESX-DC-014376-21
v.
CIVIL ACTION
KYLE DONOVAN,
NOTICE OF MOTION FOR ENTRY OF
Defendant. DEFAULT JUDGMENT
TO: KYLE DONOVAN, PRO SE

350 SCOTLAND ROAD, APT. 101
ORANGE, NJ 07050
DAVID J. MONTAG, ESQ.

MILBER MAKRIS PLOUSADIS & SEIDEN, LLP
75 LIVINGSTON AVENUE, SUITE 101
ROSELAND, NJ 07068
PLEASE TAKE NOTICE that the undersigned counsel for Highland Lofts Condominium
Association, Inc. (the “Association”) shall move before the Superior Court of New Jersey, Essex
County, Law Division, Special Civil Part, located at the Essex County Historic Court House, 470
Dr. Martin Luther King Jr. Boulevard, Newark, NJ 07102, for an Order entering Default
Judgment against the Defendant named herein.
STARK & STARK

A PROFESSIONAL CORPORATION
In support of its Motion, the Association shall rely upon the Certification of Attorneys’
ATTORNEYS AT LAW
Fees and Costs, Certification of Proof of Amount Due, Certification of Counsel as to Source of
4831-5138-2782, v. 1
Service Address, Affidavit of Non-Military Service, and any other evidence subsequently
presented and deemed admissible by the Court.
The Order sought will be entered in the discretion of the Court unless you notify the
Clerk of the Court and Stark & Stark, A Professional Corporation, in writing that you object to
the entering of this Order no later than ten (10) days after date of service of this Motion.
NOTICE. IF YOU WANT TO RESPOND TO THIS MOTION,

YOU MUST DO SO IN WRITING.
Your written response must be in the form of a certification or affidavit. That means that
the person signing it swears to the truth of the statements in the certification or affidavit and is
aware that the Court can punish him or her if the statements are knowingly false. You may ask
for oral argument, which means you can ask to appear before the Court to explain your position.
If the Court grants oral argument, you will be notified of the time, date and place. Your
response, if any, must be in writing even if you request oral argument. Any papers you send to
the Court must also be sent to the opposing party’s attorney, or the opposing party if they are not
represented by an attorney.
We are asking the Court to make a final decision against you without a trial or an
opportunity for you to present your case to a judge. We are requesting that a decision be entered
against you, because we say that the important facts are not in dispute and the law entitles us to a
judgment. If you object to the motion, you must file a written response stating what facts are
disputed and why a decision should not be entered against you.
No oral argument is requested.
STARK & STARK

ATTORNEYS AT LAW
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A proposed form of Order has been filed in conjunction with this Motion.
Respectfully submitted,
STARK & STARK

By: /s/ Melissa A. Volet

Dated: June 17, 2022
STARK & STARK

ATTORNEYS AT LAW
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4831-5138-2782, v. 1

(609) 896-9060

ESSEX COUNTY
Plaintiff,
v.
CIVIL ACTION
KYLE DONOVAN,
CERTIFICATION OF ATTORNEYS’
Defendant. FEES AND COSTS
I, MELISSA A. VOLET, ESQUIRE, hereby certify:
1. I am an attorney with Stark & Stark, a Professional Corporation, attorneys for the
Plaintiff. I am one of the attorneys responsible for the representation of Highland Lofts
Condominium Association Inc., (the “Association”). As such, I have full knowledge of the facts
as set forth herein.
2. The Association seeks reasonable attorneys’ fees associated with its collection
proceeding against the Defendant, Kyle Donovan (the “Debtor”).
3. The Association is a non-profit corporation responsible for administration,
maintenance and operation of the common elements within the Association.
4. As Unit owner, in accordance with the Association’s Master Deed, paragraph 5,

STARK & STARK
ATTORNEYS AT LAW and By-Laws, Article VI Sections 1, 4(A) and 4(B), Debtor is required to pay common expense
maintenance fees to the Association. These fees are payable in monthly installments each year.
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(True and correct copies of the relevant portions of the Master Deed and By-Laws are attached to
the Lyle Certification as Exhibit “B.”)
5. Despite demand, the Debtor failed to make common expense maintenance
payments to the Association as required by the Master Deed. (A true and correct copy of the
account history for the Unit as provided by the Association is attached hereto as Exhibit “A.”)
6. The Condominium Act provides that an “association may levy and collect
assessments duly made by the association for a share of common expenses or otherwise,
including any other monies duly owed the association, upon proper notice to the appropriate unit
owner, together with interest thereon, late fees and reasonable attorneys’ fees, if authorized by
the Master Deed or By-Laws.” N.J.S.A. 46:8B-15(e) (emphasis added).
7. Pursuant to the Association’s Master Deed, Section 18, and By-Laws, Article VI,
Section 6 and Article X, Section 1, and N.J.S.A. 46:8B-21, the Association is entitled to
reasonable attorneys’ fees and costs. (See Lyle Certification, Exhibit “B”).
8. The attorneys’ fees, out-of-pocket expenses and Court costs incurred by the
Association in this matter total $5,620.05 through March 23, 2022. (A true and correct copy of
the billing summary for this work showing the dates, time spent and hourly rates charged is
attached hereto as Exhibit “B.”)
I. RPC 1.5(A) FACTORS:
Time and Labor Required, Novelty/Difficulty of Issues and

Skill Necessary to Perform the Services
9. Community Association law is unique and requires substantial experience in, and
knowledge of, the industry. Our attorneys and paralegals have this experience and knowledge,
STARK & STARK
ATTORNEYS AT LAW
as discussed supra.
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10. The Association is burdened by a number of delinquent homeowners. The
Association decided to engage Stark & Stark in order to ensure that assessments are paid by all
owners. The Association contends that only counsel with sufficient staff, energy, expertise and
effort can ensure collection of assessments - the lifeblood of a condominium. Counsel without
such incentive cannot sufficiently do this.
11. The fees charged by Stark & Stark are identical to, or less than, those fees
normally charged by Stark & Stark to its clients for representation in matters similar to the matter
herein.
12. I personally developed knowledge and awareness of the legal and practical issues
faced by the Association.
13. Stark & Stark’s collection-related services have provided significant financial
help to the Association through the years.
14. Stark & Stark cooperates with the Association to provide the best services at the
lowest possible charges.
15. Stark & Stark provides detailed status reports with respect to delinquent owners,
at no charge.
16. Stark & Stark often meets with the Association’s Board and/or speaks with
individual members of the Board, also at no charge, to discuss delinquencies and the collection
of same including this matter.
17. Stark & Stark assists the Association’s property management company in
reviewing each delinquent account, adjusting the accounts to reflect payment plans, credits and
STARK & STARK
ATTORNEYS AT LAW
the like - also at no charge.
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18. Overall, Stark & Stark has demonstrated to the Association that its attorneys are
competent, efficient and able to obtain favorable results.
Acceptance of this Case will Preclude other Employment
19. The acceptance by Stark & Stark of this case, as is apparent to the Association,
precludes Stark & Stark from accepting other legal employment.
Our Fees are Customarily Charged in the Industry in this Location
20. Stark & Stark’s hourly rates are similar to those rates customarily charged in the
Community Association Law industry in this locality.
21. I have been a member of the Community Association Institute (“CAI”) since
2005. CAI consists of various professionals in the community association industry. Through
CAI, I am in contact with other lawyers in the industry and believe Stark & Stark’s rates for
community association work is in line with what other lawyers in the industry charge.
22. Many of our client associations regularly go out to bid for attorneys to represent
their association. The bid process usually consists of the associations’ boards reviewing three
fee agreements from competing firms in the industry. If a client association sees a lower hourly
rate or flat fee from a competing firm, the client association may inform Stark & Stark that they
would like us to lower our fee for similar work, or to keep our hourly rate the same for an
additional year to stay competitive. We are able to keep our hourly rates and fees competitive
with other law firms in the industry based upon feedback from our existing clients.
23. In addition, the attorneys in our Community Associations Department are in
frequent contact with property managers in the industry. Property managers have a lot of
STARK & STARK
A PROFESSIONAL CORPORATION exposure to fee agreements from other law firms in the industry. Through property managers,
ATTORNEYS AT LAW
our firm obtains information regarding fees charged by other law firms in the industry.
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The Amount of Time Spent on this File is Reasonable and Similar to

what Others would have Spent
24. Stark & Stark’s Community Associations Department consists of attorneys that
have been in the Community Association industry from 16 years to over 25 years; our paralegals
have been in the Community Association industry from 10 years to over 15 years, as discussed
supra. Given the experience of the attorneys and paralegals in the department, we are able to
work efficiently on our files. Attorneys of like experience in the industry would spend a similar
amount of time working on this file.
The Amount Involved and Results Obtained
25. The principal amount owed, less attorneys’ fees, is $12,558.00.
26. Of importance is the fact that some association fees are $100.00 per month, some
are $200.00 per month, some are $700.00 per month. The services required to proceed in the
collection process, i.e., initial collection letter, lien preparation and filing, notices of lien,
preparation of a complaint, etc., are the same whether the principal amount owed for arrears that
year is $1,200.00, $2,400.00, or $8,400.00. As a result, there may be cases where the principal
owed is the same or less than the attorneys’ fees sought. Whatever the amount due, the unpaid
maintenance fees are vital to the functioning of the Association.
Time Limitations Imposed by the Client or the Circumstances
27. No time limits were specifically imposed by the client or the circumstances.
The Nature and Length of Professional Relationship with Client
28. Stark & Stark has regularly represented the Association for years in both
collection and general governance matters.

STARK & STARK
ATTORNEYS AT LAW
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The Experience, Reputation and Ability of Lawyer
29. (a) Melissa A. Volet, Esq. I am an attorney admitted to practice in the State
of New Jersey since 2002. I have been an attorney with Stark & Stark since 2005. Since June
2005, I have worked almost exclusively in the firm’s Community Associations Practice Group
and focus solely on representing condominium and homeowners associations. I appear on the
legal bills as “M-V,” and bill my time at the following rates each year:
(i) In 2009 at $250.00 per hour;

(ii) In 2010 at $250.00 per hour;
(iii) In 2011 at $270.00 per hour;
(iv) In 2012 at $285.00 per hour;
(v) In 2013 at $285.00 per hour;
(vi) In 2014 at $285.00 per hour;
(vii) In 2015 at $265.00 per hour;
(viii) In 2016 at $280.00 per hour;
(ix) In 2017 at $285.00 per hour;
(x) In 2018 at $295.00 per hour;
(xi) In 2019 at $295.00 per hour;
(xii) In 2020 at $305.00 per hour;
(xiii) In 2021 at $310.00 per hour;
(xiv) In 2022 at $320.00 per hour.
(b) A. Christopher Florio, Esq. Mr. Florio is the head and founder of the
firm’s Community Associations Group. He is an attorney admitted to practice in the State of
New Jersey since 1989. He has been an attorney at Stark & Stark since June 1989 and a
shareholder since July 1996. Mr. Florio’s expertise in condominium law is extensive. Mr. Florio
has written numerous articles for both the Community Associations Institute’s Community Trends
and the national publication of Community Association Law Reported, addressing such issues as
affordable housing, collections and free speech. Mr. Florio appears on the legal bills as “ACF”
and bills for his time at the following rates each year:
STARK & STARK
ATTORNEYS AT LAW
(i) In 2009 at $290.00 per hour;
(ii) In 2010 at $295.00 per hour;
(iv) In 2012 at $320.00 per hour;
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(v) In 2013 at $320.00 per hour;

(vi) In 2014 at $320.00 per hour;
(viii) In 2016 at $295.00 per hour;
(ix) In 2017 at $305.00 per hour;
(x) In 2018 at $310.00 per hour;
(xi) In 2019 at $310.00 per hour;
(xii) In 2020 at $310.00 per hour;
(xiii) In 2021 at $315.00 per hour;
(xiv) In 2022 at $330.00 per hour.
Paralegal Qualifications, and Rates
30. (a) Donna Sica. Ms. Sica has been employed by Stark & Stark for over six
years focusing on collections. Ms. Sica appears on the legal bills as “DS,” and has billed her
time at the following rates each year:
(i) In 2015 at $135.00 per hour;

(ii) In 2016 at $135.00 per hour;
(iv) In 2018 at $150.00 per hour;
(v) In 2019 at $150.00 per hour;
(vi) In 2020 at $155.00 per hour;
(viii) In 2022 at $165.00 per hour.
Our Fees are Not Contingent
31. Fees are not charged on a contingency basis. (A true and correct copy of the
Retainer Agreement between the Association and Stark & Stark is attached hereto as
Exhibit “C.”)
Certain Services are Performed on a Flat Fee Basis
32. Certain services that are performed on a regular basis, such as preparation of
collection letter, preparation of a lien, preparation of a discharge of lien, preparation of a money
STARK & STARK

judgment complaint, preparation of a judgment package, are charged on a flat fee basis. Stark &
ATTORNEYS AT LAW
Stark performs these services on a flat fee basis to provide the client associations with a sense of
certainty that fees for services performed on a regular basis would not exceed a certain dollar
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amount. A client association knows that if they want our firm to prepare a lien against a debtor’s
unit, that it will cost a certain amount, no matter how long it takes to prepare the lien. Preparation
of a lien requires numerous tasks in addition to preparing the lien itself, such as review of title to
confirm ownership and lot and block information, review of account ledger, review of legal bills,
review of file for prior liens recorded, and preparation of breakdown of arrears; these tasks are
not billed separately, they are encompassed in the flat fee.
33. It is important to note that certain steps are necessary in our collection process.
For example, every year, before filing an updated lien, we must order and review a current title
search to confirm that ownership of the unit has not changed since the last lien was filed. Also,
we must conduct a PACER search prior to proceeding with each collection action to ensure that
Debtor has not filed bankruptcy. Therefore, these are not duplicate entries, they are necessary
actions.
34. In light of the foregoing, the Association respectfully requests its reasonable
attorneys’ fees associated with this litigation be included in the Order Entering Default Judgment
in the amount of $5,620.05.
STARK & STARK

ATTORNEYS AT LAW
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I certify that the statements made herein are true. I am aware that if any of the statements
made herein are willfully false, I am subject to punishment.
/s/ Melissa A. Volet

STARK & STARK

ATTORNEYS AT LAW
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4819-7704-3198, v. 1
Melissa A. Volet, Esquire

New Jersey Attorney ID#03080-2002
STARK & STARK
993 Lenox Drive, Building Two
Lawrenceville, New Jersey 08648
(609) 896-9060

ESSEX COUNTY
Plaintiff,
v.
CIVIL ACTION
KYLE DONOVAN,
ORDER ENTERING
Defendant. DEFAULTJUDGMENT
THIS MATTER having been opened to the Court by Stark & Stark, A Professional
Corporation, attorneys for plaintiff, Highland Lofts Condominium Association, Inc. (the
“Association”) (Melissa A. Volet, Esquire, appearing,), and Defendant, Kyle Donovan,
appearing Pro Se, for an Order granting Default Judgment against the defendant aforesaid,
and the Court having considered the papers submitted by the parties, if any and good cause
appearing; and the Plaintiff having filed Certifications setting forth a particular statement of
the items of the claim, their amounts and dates, a calculation in figures of the amount of
interest, the payments or credits, if any, and the net amount due;
IT is ORDERED on this _____ day of ____________, 2022,
1. Plaintiff’s Motion for Default Judgment is hereby granted.

STARK & STARK
ATTORNEYS AT LAW
2. Judgment is hereby entered in favor of the Plaintiff, Highland Lofts Condominium
Association, Inc., and against the Defendant, Kyle Donovan, in the amount of $18,178.05, as
follows:
Breakdown through 3/23/22
Maintenance:
11/20 – 3/22 = 17 x $483.00 $8,211.00
Accelerated Maintenance:
4/22-12/22 = 9 x $483.00 $4,347.00
Attorneys’ Fees & Costs through 3/23/22: $5,620.05
TOTAL ARREARS THROUGH 3/23/22: $18,178.05
3. A copy of this Order shall be served on Defendant within seven (7) days of Plaintiff’s
counsel’s receipt of this Order.
J.S.C.
Opposed: ( )
Unopposed: ( )
STARK & STARK

ATTORNEYS AT LAW
2
4822-7883-6478, v. 1

New Jersey Attorney ID #03080-2002
STARK & STARK
(609) 896-9060

ESSEX COUNTY
Plaintiff,
DOCKET NO. ESX-014376-21
v.
CIVIL ACTION
KYLE DONOVAN,
CERTIFICATION OF PROOF OF
Defendant. AMOUNT DUE
I, HELLURA LYLE, certify and state:
1. I am the Treasurer of Highland Lofts Condominium Association, Inc. (the
“Association”), Plaintiff in this matter. I make this Certification based on a review of the
Association’s books and records and on my own personal knowledge.
2. I have examined the records of the Association and find there is due to the
Association in this matter the sum of $18,178.05.
3. Defendant, Kyle Donovan (the “Debtor”), is the owner of a condominium unit
within the Association commonly known as 350 Scotland Road, Apt. #101, Orange, NJ
07050 (the “Unit”). (A true and correct copy of the Unit Deed is attached hereto as
STARK & STARK
Exhibit “A.”)
ATTORNEYS AT LAW
4877-5696-7450, v. 1
4. Pursuant to the Association’s Master Deed, Paragraph 5, and By-Laws, Article
VI Sections 1, 4(A) and 4(B), Debtor is responsible for a proportionate share of the expenses
and administrative costs of operating the Association. The common expenses are assessed by
the Association on an annual basis but are due and payable to the Association in the form of
monthly payments. (True and correct copies of the relevant portions of the Master Deed and
By-Laws are attached hereto as Exhibit “B.”)`
5. Pursuant to the Association’s Master Deed, Section 18, and By-Laws, Article
VI, Section 6 and Article X, Section 1, and N.J.S.A. 46:8B-21, the Association is entitled to
its reasonable attorneys’ fees and costs. (See Exhibit “B”).
6. Pursuant to the Certification of Attorneys’ Fees and Costs accompanying the
within Motion papers, $5,620.05 in attorneys’ fees and costs through March 23, 2022, should
be included in the Order Entering Judgment.
7. Pursuant to the Association’s By-Laws, Article VI, Section 6, the Association
may accelerate assessments upon default. (See Exhibit “B”).
8. The Debtor defaulted on his obligation to the Association because he failed
and refused to make common expense payments to the Association in accordance with the
terms and conditions set forth in the Master Deed.
9. Despite demand, the Debtor failed and refused to make payment to the
Association as required by the terms of the Master Deed and By-Laws and failed and refused
to pay the Association the amounts due. (A true and correct copy of the account history for
the Unit is attached hereto as Exhibit “C.”)

STARK & STARK
ATTORNEYS AT LAW
10. As a result of Debtor’s delinquency, the Association filed a Complaint on
September 29, 2021. Debtor filed an Answer and Counterclaim on November 8, 2021. (A
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true and correct copy of Debtor’s Answer and Counterclaim is attached hereto as Exhibit
“D.”)
11. The total amount to be included in the Order Entering Summary Judgment is
$18,178.05. As of March 23, 2022, the Debtor is indebted to the Association as follows:
Breakdown through 3/23/22
Maintenance:
11/20 – 3/22 = 17 x $483.00 $8,211.00
Accelerated Maintenance:
4/22-12/22 = 9 x $483.00 $4,347.00
Attorneys’ Fees & Costs through 3/23/22: $5,620.05
TOTAL ARREARS THROUGH 3/23/22: $18,178.05
12. There are no just debts, set-offs, credits or allowances due or to become due
from the Debtor, other than those included in this amount due.
13. Pursuant to Commentary 2.1.3. of Court Rule 6:4-1, in collection actions
where attorneys’ fees and costs are not an amount certain, they are not to be included in the
Special Civil Part’s monetary limit.
14. The Association respectfully requests that $18,178.05 be awarded in the Order
Entering Summary Judgment.
I certify that the foregoing statements made herein are true. I am aware that if any of
the foregoing statements made herein are willfully false, I am subject to punishment.
____________________________________
HELLURA LYLE, TREASURER
STARK & STARK
A PROFESSIONAL CORPORATION Dated: April ___, 2022
ATTORNEYS AT LAW
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4877-5696-7450, v. 1
CERTIFICATION
Pursuant to R. 1:4-4(c), I hereby certify that the above affiant’s signature is genuine,
that the above affiant acknowledged that the signature is genuine, and that an original
executed copy will be made available if requested. I understand that if any of the above
statements are willfully false, I am subject to punishment.

Dated: April 4, 2022
STARK & STARK

ATTORNEYS AT LAW
4831-0203-0656, v. 1
EXHIBIT A
4841-0983-6166, v. 1
Inst. # 2020105331 - Page 1 of 6
Essex County Register Document Summary Sheet
Transaction Identification Number 4503670

ESSEX COUNTY REGISTER OF DEEDS & MORTGAGES
Recorded Document to be Returned by Submitter to:
LANDVIEW TITLE AGENCY, LI.C
HALL OF RECORDS - ROOM {30 . .
750 CHESTNUT RIDGE ROAD STE 118
465 DR. MARTIN LUTHER KING BLVD try adi X
CHESTNUT RIDGE, NY 10977
NEWARK NJ (07102
Official Use Only Submission Date (mm/dd/yyvy) 10/21/2020

No. of Pages (excluding Summar Sheet)
4
Recording Fee (excluding transfer tax) $73.00
JUAN M. RIVERA, JR
REG. OF DEEDS & MORTGAGES -
ESSEX COUNTY Realty Transfer Tax
$767.50
New Jersey
Total Amount $840.50
DOCUMENT TYPE Document Type | DEED/NO EXEMPTION FROM REALTY TRANSFER FEE
1
INSTRUMENT NUMBER
2020105331 - -
RECORDED ON Electronic Recordation Level i
L2- Level 2 (With Images)
oct 26, 2020
8:01:10 au Municipal Codes
Total Pages: 6
ORANGE 17
COUNTY REALTY TAX $175.00
COUNTY REALTY TAX - $87.50
PHPFA
NJ PRESERVATION ACCOUNT $30.00
REGISTER RECORDING FEE $40,00
STATE REALTY TAX $437.50
STATE REALTY TAX - EAA $30.00
NJRHTE $37.50
HOMELESSNESS TRUST FUND $3.00
TOTAL PAID $840.50
INV: 411685 USER: BB
434507
Additional Information (Official Use Only)
*DO NOT REMOVE THIJS PAGE.

COVER SHEET [DOCUMENT SUMMARY FORM] IS PART OF ESSEX COUNTY REGIST
ER FILING RECORD,
RETAIN THIS PAGE FOR FUTURE REFERENCE.
6486231 _10M21D{12H28M15554)/4706818 4503670

Page | of 2
08/05/2021 10:40:48 AM ESSEX COUNTY inst.# 2020105331 - Page 1 of 6

Inst. # 2020105331 - Page 2 of §
Essex County Register Document Summary Sheet
Type DEED/NO EXEMPTION FROM REALTY TRANSFER FEE
Consideration $175,000.00
Submitted By LANDVIEW TITLE AGENCY, LLC (CSC/INGEO SYSTEMS
INC)
Document Date 10:1922020
Reference Info
Book [ID Book Beginning Page Instrument No. Recorded/File Date
DEED/NO GRANTOR Name Address

EXEMPTION
FROM REALTY COLONY HOLDINGS LLC
TRANSFER FEE
GRANTEE Name Address

KYLE DONOVAN
Parcel Info
Property Type Tax Dist. Block Lot Qualifier Municipality

17 4901 28 17
“DO NOT REMOVE THIS PAGE.

COVER SHEET [DOCUMENT SUMMARY FORM} IS PART OF ESSEX
COUNTY REGISTER FILING REC ‘ORD.
RETAIN THIS PAGE FOR FUTURE REFERENCE.
6486231 _10M21D(1 TH28M15554)/4706818 4503670

Page 2 of 2
08/05/2021 10:40:48 AM ESSEX COUNTY Inst.# 2020105331 - Page 2 of 6

Inst. # 2020105331 - Page 3 of 6
BARGAIN AND SALE (Covenants as to Grantor's Acts)
Prepared by:
Asher Handle
DEED
This Deed is made on october\] , 2020
BETWEEN
Colony Holdings LLC, with an address at 350 Scotland Road, Unit 101, Orange, NJ 07050
referred to as the Grantor,
AND
Kyle Donovan, with an address at 350 Scotland Road, Unit 204, Orange, NJ 07050
referred to as the Grantee.
The words “Grantor” and “Grantee” shall mean all Grantors and all Grantees listed above.
TRANSFER OF TITLE. The grantor does hereby grant and convey the property described below to the
Grantee.
CONSIDERATION. This transfer of ownership is made for the sum and consideration of $175,000.00.
The Grantor acknowledges receipt of this money.
TAX MAP REFERENCE. The property located in the Municipality of Orange, Block No. 4901, Lot No.
28, Qualifier No. C0101.
PROPERTY DESCRIPTION. The property consists of all the land, buildings, structures and
improvements contained on the property, and is located in.the Township of Orange, County of Essex,
and State of New Jersey, and is described as follows:
SEE LEGAL DESCRIPTION ANNEXED HERETO AND MADE A PART HEREOGF.
The street address of the property is: 350 Scotland Road, Unit 101, Orange, NJ 07050.
BEING THE SAME LAND AND PREMISES, which became vested in;
Colony Holdings LLC, by deed from Hawk Investments, LLC, dated August 04, 2016, recorded October
17, 2016 in the Essex County Clerk’s/Register’s Office in Instrument No. 2016088594,
PROMISES BY GRANTOR. The Grantor promises and warrants that Grantor, by acts of the Grantor, has
not encumbered the property. This promise means that the Grantor has not allowed anyone else to obtain
any legal right which would affect the property being transferred (such as a mortgage or entering a judgment
against the Grantor). This promise is called a “covenant as to grantor's acts” (N.I.S.A. 46:4-6).
Bargain and Sale (Covenant as to Grantor's Acts) -1- CMS Form No. NJ-61 |

Inst. # 2020105331 ~ Page 4 of 6
BARGAIN AND SALE (Covenants as to Grantor’s Acts)
SIGNATURES. The Grantor signs this Deed as of date first above written.
Colony Hold 2 LL
By:
Va Handler,"Sole Member
STATE OF NEW JERSEY CEH
COUNTY OF (Xo
Header o¢ Looe Ho\dings ic
I CERTIFY that on October 1M _, 2620, Asher Handler? personally came before me and acknowledged
under oath, to my satisfaction, that this person (or if more than one, each person):
(2) was the maker of the attached Deed;

(b) was authorized to and did execute this Deed as the sole member of Colony Holdings LLC, the
entity named in this Deed,
(c) made this Deed for $175,000.00 as the full and actual consideration paid or to be paid for the
transfer of title (such consideration is defined in N.J.S.A. 46:15-5); and
(d) executed this Deed as the act of the entity.
To
SARAH KRAMER RSEY i)
NO TA RY PUBLIC OF NEW JE Frit tare & Tite Below
Slgnatine)
{0 No: 50049428 ——
ember 10,
tv; Comm ission Expires Nov
Colony Holdings LLC,
Grantor David Treyster, Esq.

Hudson Law Group
TO 745 Fifth Avenue, Suite 500
New York, NY 10151
Kyle Donovan,
Grantee
Bargain and Sale (Covenant as to Grantor's Acts) -2- CMS Form No. NI-611
08/05/2021 10:40:48 AM ESSEX COUNTY Inst# 2020105331 - Page 4 of 6

Inst. # 2020105331 - Page 5 of 6
Chicago Title Insurance Company

Commitment for Title Insurance
Adopted 08-01-2016
Technical Corrections 04-02-2018
Legal Description
All that certain lot, piece or parcel of land with the buildings and
improvements thereon erected, situate
tying and being in the City of Orange, County of Essex, State of
New Jersey:
KNOWN as and designated as Unit No. 101P, situate in Highiand Lofts
Condominium, a condominium,
established in accordance with the N.J.S.A 46:8b-1 et seq; together
with an undivided 6.2662% Interest
in the general common elements of said condominium appurten
ant to the aforesaid unit in accordance
with and subject to the terms, conditions, covenants, restrictions,
easements, as for assessments and
other provisions set for in the current Master Deed of Jeanne
C. Harmon recorded October 2,1998, in the
Office of the Essex Clerk/ Register in Deed Book 5561, page, 543; as
same may nor or hereafter be
lawfully amended.
Tax Lot: 28 Block: 4901 Tax Map of the Township of Orange, County
of Essex. State of New Jersey
NOTE: Lot and Block shown for informational purposes only.
This page is only a part of a 2016 ALTA® Commitment for Title Insurance {issued by Old Republic
Nationa! Title Insurance
Company]. This Commitment is not valid without the Notice; the Commitment to Issue Policy,
the Commitment Conditions; Schedule
A; Schedule B, Part I—Requirements; Schedule B, Part li—Exceptions, and a counter-signature
by the Company or its issuing agent
that may be in electronic form.
NEW JERSEY LAND TITLE

~ NJRB 3-09
INSURANCE RATING BUREAU Last Revised: 07/01/18

Inst. # 2020105331 - Page 6 of 6
GIT/REP-3 State of New Jersey

(8-19) Seller's Residency Certification/Exemption
{Print or Type)
Seller’s Information
Name(s)
Colony Holdings LLC
Current Street Address
350 Scotland Road, Unit 101
City, Town, Posi Office State 2iP Code
Orange NJ 07050
Property Information
Block(s) Lot(s) Quaiifier
45801 28 C0101
Streel Address
350 Scotland Road, Unit 101
City, Town, Post Office State ZIP Code
Orange NJ 07050
Seller's Percentage of Ownership Total Consideration Owner's Share of Corsideraticn ~~ Closing Dale
100% $175,000.00 100% 10192020
1. OJ Seller is a resident taxpayer (individual, estate, or trust) of the State of New Jersey pursuant to the New Jersey Gross Income Tax Act,
will file a resident Gross Income Tax return, and will pay any applicable taxes on any gain or income from the disposition of this property.
The real property sold or transferred is used exclusively as a principal residence as defined in 26 U.S. Code section 121.
0 Oo
Seller is a mortgagor conveying the mortgaged property to a mortgagee in foreclosure or in a transfer in lieu of foreclosures with no
additional consideration.
Seller, transferor, or transferee is an agency or authority of the United States of America, an agency or authority of the State of New
Jersey, the Federal National Mortgage Association, the Federal Home Loan Mortgage Corporation, the Government National Mortgage
Association, or a private morlgage insurance company.
Seller is not an individual, estate, or trust and is not required to make an estimated Gross income Tax payment,
OO
The total consideration for the property is $1,000 or less so the seller is not required to make an estimated Income Tax payment.
The gain from the sale is not recognized for federal income tax purposes under 26 U.S. Cade section 721, 1031, or 1033 (CIRCLE THE
APPLICABLE SECTION). If the indicated section does not ultimately apply to this transaction, the seller acknowledges the obligation to
file a New Jersey Income Tax return for the year of the sale and report the recognized gain.
Seller did not receive non-like kind propery.
00
The real property is being transferred by an executor or administrator of a decedent to a devisee or heir to effect distribution of the
decedent's estate in accordance with the provisions of the decedent's will ar the intestate laws of this State.
The real property being sald is subject to a short sale instituled by the mortgagee, whereby the seller agreed not to receive any
0
proceeds from the sate and the mortgagee will receive all proceeds paying off an agreed amount of the mortgage.
The deed is dated prior to August 1, 2004, and was not previously recorded.
O00
The real property is being transferred under a relocation company transaction where a trustee of the relocation company buys the
property from the selier and then sells the house to a third party buyer for the same price.
The real property is being transferred between spouses or incident to a divorce decree or property settlement agreement under 26 U.S.
Code section 1041.
The property transferred is a cemetery plot.
00
The seller is not receiving net proceeds from the sale. Net proceeds from the sale means the net amount due to the seller on the
settlement sheet.
15. The seller is a retirement trust that received an acknowledgment letter from the Internal Revenue Service that the seller is 2 retirement
trust, and is therefore not required to make the estimated Gross [ncemes Tax payment.
16. Od The seller (and/or spouse/civil union partner) originally purchased the property while a resident of New Jersey as a member of the U.S.
Armed Forces and is now selling the property as a resuit of being deployed on active duty outside of New Jersey. (Only check this box if
applicable and neither boxes 1 nor 2 apply.)
and, to the best of my knowledge and belief, it is true, corp nd co pet . By checking this box [] | certify that a Power of Attorney to repre-
sent the seller(s) has been previously recorded or is being muineously with the deed to which this form is attached.
Colony Hovdirmas 4c
1p 1 -2020 Gy Asner Headlas, Meee
Date / Signature {Seller} Indicate it Power of Attorney or Attorney in Fact
Date Signature (Seller) indicate if Power of Attorney or Attorney in Fact
08/05/2021 10:40:48 AM ESSEX COUNTY Inst# 2020105331 - Page 6 of 6

EXHIBIT B
4841-0983-6166, v. 1
8k5561P60543
HIGHLAND LOFTS CONDIMINUM
+292 Lafayette Street

- Newark, New Jersey 07105
(201) 589-0085
.
Bk556
1 P6059
(a) The Association shall have a perpetual and exclusive easement for the maintenance of
any Common Elements, which may presently or hereafter encroach upon a Unit; and
(b) A perpetual, blanket and non-exclusive easement in, upon, over, under, across and
through the Common Elements for surface water runoff and drainage caused by natural
forces and elements, grading, and/or the improvements located upon the Property. No
individual Unit Owner shall directly or indirectly interfere with or alter the drainage
and runoff patterns and systems within the Condominium; and
(c) The Association, through the Board or any manager, or managing agent, or their
respective-agents or employees shall have the perpetual and non-exclusive right of
access to each Unit (i) to inspect same (ii) to remedy any violations set forth in the
Master Deed, the By-Laws or in any Rule, or Regulations of the Association, and (iii)
to perform any operations required in connection with the maintenance, repairs or
replacements of or the Common Elements, or any equipment, facilities or fixtures
affecting or serving other Unit(s) or the Common Elements; provided that requests for
entry are made in advance and that such entry is at a time reasonably convenient to the
Unit Owner. In case of an emergency, such right of entry shall be immediate whether
the Unit Owner is present at the time or not; and
(d) Any Institutional Lender, and Sponsor with respect to a Permitted First Mortgage or
Permitted Second Mortgage (as defined in the Master Deed) held by it, their officers,
agents, and employees and any Seller of a Unit holding a Permitted First Mortgage (as
defined in the Master Deed) shall have a blanket, perpetual and non-exclusive easement
to enter the Condominium or any part thereof to inspect the condition and repair of the
common elements, or any Units so encumbered. Except in cases of emergency, this
right shall be exercised only during reasonable daylight hours, and then whenever
practicable only after advance notice to the Unit Owner and with the permission of the
Board or its managing agent; and
(e) A blanket, perpetual and non-exclusive easement in, upon, over, across and through the
Common Elements for the purpose of the installation, maintenance, repair, service and
replacement of all sewer, water, power and telephone pipes, lines, mains, conduits,
waters, poles, transformers, meters, cable television, master television antenna and any
and all other equipment or machinery necessary or incidental to the proper functioning
of any utility Systems serving the Property, which easement shall be for the benefit of
any governmental agency, or utility company or other entity which requires same for
the purposes of furnishing one or more of the foregoing services; and
(f) Ablanket, perpetual and non-exclusive easement of unobstructed ingress and egress in,
upon, over, across and through the Common Elements to the City of Orange, the
Association their respective officers, agents and employees (but not the public in
general) and all police, fire and ambulance personnel in the proper performance of their
respective duties, (including but not limited to emergency or other necessary repairs to
a Unit which the Unit Owner has failed to perform), and for repair and maintenance of
the Common Elements. Except in the event of emergencies, the rights accompanying
the easements provided for in this sub-paragraph shall be exercised only during
reasonable daylight hours and, whenever practicable, only after advance notice to and
with permission of the Unit Owners directly affects thereby.
5. COMMON EXPENSES: Until the conveyance of title to the first Condominium

Unit in the condominium, the Grantor shall be solely responsible for all Common
Expenses. Following the first conveyance, each Unit Owner shall be required to pay a
proportionate part of the expenses of maintenance, repair, replacement, administration and
operation of the Common Elements, which expenses are hereinafter referred to collectively
gs the “Common Expenses” and shall share proportionately in any common surplus.
Payment of Common Expenses shall be in such amount and at such times as may be
provided in the By-Laws. Until the earlier of (a) two years after the date the Master Deed
shall have been recorded or (b) the date on which title to all Condominium Units shall have
been transferred by the Grantor to Unit Owners, or (c ) at such carlier time as the Grantor
may elect to turn over the control of the Board of Trustees under Article IV Section 1 of the
-
pe
i
a ——
ee eee
592
P606
Bk51 5
rtionate part of the Common
not be required to pay a propo
By Laws, the Grantor shall balan ce of Common Expenses actually
required to pay the
Ex enses, but shall only be ed to Unit Owners, except that the
on expenses charg
incurred in excess of the Comm y-unit basis. Payment shall be made
e for reserves on a unit-b
Developer shall be responsibl as and when needed by the
immediately preceding sentence
by tiie Grantor pursuant to the
t expens es.
Association to meet curren
a lien on each Unit for
of the Unit Owner, shall have
The Association, on behalf by the Association which lien may
ed agains t such Unit
unpaid Common Expenses assess foreclosure of a mortgage on
n in the same manner as the
be foreclosed by the Associatio and unpaid taxes, due
be subordinate to any lien for past
real property. All such liens shall to which such Unit may be subject, and to any
mortg age
to the lien of a prior recorded first lien. The liability of each
time of recording of the claim of
other lien recorded prior to the ses assess ed agains t his Unit accruing after
Common expen
Unit Owner for the payment of of such Unit shall termin ate upon such transfer
conveyance
a valid permissible transfer or subjec t to the provi sions of the By-Laws. A
with and
or conveyance in accordance y and severa lly liable with the Seller or Grantor
jointl
purchaser or grantee of a Unit (being as provi ded in the Cond omin ium Act) shall be
Expenses
of a Unit for unpaid Common assess ed agains t his Unit prior to the acquisition
on Expenses
required to pay unpaid Comm of record or a purchaser
if a mortgagee of a first mortgage
by him of such Unit, except that of a forecl osure sale of the first mortgage,
Unit as a result
of a Unit obtains title to such shall not be liable for unpaid assessments
and assign s
such acquirer of title, his successors r Unit Owner which becam e due prior to
to the forme
pertaining to said Unit or chargeable and in the event said lien has not been
result of the foreclosure
the acquisition of title as a satisfied at the foreclosure
the even said lien has not been
satisfied at the foreclosure and i 1 a lien for the unpaid assessment applicable
to
shall not be subjec t to
sale, thereafter the Unit such Unit by such mortgagee or purchaser
at a
acqui sitio n of title to
the period prior to the whether by a mortgagee
2 foreclosure of a first mortgage
foreclosure sale. In the event of asses sment s) and the proceeds of a foreclosure
(of its lien for unpai d
or by the Association , the unpaid balance
payment of such unpaid assessment
sale shall not be sufficient for the on Expen se (including the purchaser of the
Owner s as a Comm
shall be charged to all Unit ded to the unit owners
Any surplus funds shall be refun
Unit sold at the foreclosure sale). st in the cond ominium on an annual basis.
owner ship intere
pursuant to their proportionate
. The Board of Trustees of
6.
es”) shall consti tute the gover ning Board referred to in
the Association (“Board of Truste autom atica lly becom e and be a member of
Owner shall
the Condominium Act. Bach Unit Unit Owner . Upon the termination of the
nues to be a
the Association so long as he conti there upon autom atica lly terminate and inure
shall
interest of a Unit Owner, his membership pursuant to its
unit Owner succe eding him in interest. Each unit shall vote
to the new ed by a majority of the total votes eligibl
e
ship. All votes shall be decid
percentage of owner ws confer a power on the Association
this Mater Deed or the By-La
to be cast. Whenever only by vote of
Trustees) said power shall be exercised
(as distinguished from the Board of
of the Assoc iatio n.
the Association at a meeting
of
: Any controversy of claim arising out
7. by arbitration administered by
or By-La ws shall be settled
or relating to the Master Deed ation Rules, and
ation under its Commercial Arbitr
the American Arbitration Associ may be entered in any court having
by the arbitra tor(s)
judgment cn the award rendered
jurisdiction thereof.
the Condominium
8. : The parking facilities within
Eleme nts and, subjec t to the provisions of
d Common
Property shall be part of the Limite the Associ ation. Parkin g in spaces
will be regula ted by
this Master Deed and the By-Laws, and
Unit Owner 's person al use only and shall be subject to such other rules
shall be for the
ished by the Board of Truste es.
regulations establ
be the right to mortgage
9. MORTGAGI OF NGUNITS: Each Unit Owner shall
e is made to a bank, trust
that such mortgage or encumbranc
or encumber his Unit provided trust, Federal or State saving
s and
real estate inves tment
company, insurance company,
Gm
BK5561P6059L
washing (including windows, inside and outside),
including painting, wall papering,
curtains, lamps and other
cleaning, paneling, floor covering, draperies, window shades,
and interior decorating . Each Unit Owner shall be entitled to the exclusive use
furnishings
of the perimeter walls, floors and ceilings which constitute the
of the interior surfaces
the respective Condomin ium Unit owned by him, and such owner
exterior boundaries of
condition at his sole expense
shall maintain such interior surfaces (or drop ceiling) in good
shall have the right to decorate
as may be required from time to time, and each such Owner
and at his sole expense. The use
such interior surfaces from time to time as he may see fit
and the doors leading to the
of and the covering of the interior surfaces of such windows
visible on the exterior of the Building,
decks, whether by draperies, shades or other items
on. Decorating of the Common
shall »e subject to the rules and regulations of the Associati
Condominium Units to the extent made
Elem =nts (other than interior surfaces) within the by
Condominium Unit causéd
necessary by any damage to existing decorating of such
Elements by the Association,
maintenance, repair or replacement work on the Common
furnished by the Associati on as part of the Common Expenses.
shall be
ADDITIONS AND IMPROVEMENTS: No Unit Owner

15. ALTERATIONS,
additions, alterations or improvements in
(other than the Grantor) may make any structural
nium Unit or of the Common Elements without the prior written approval of
his Condomi
any easement without the written
the Board of Trustees of the Association or impair or Owners for
consent of the Board ofTrustées of the Association or of the Unit Owner
whose benefit such easement exists.
Trustees, it shail make no
While the sponsor maintains a majority of the Board of
ated in this offering which
additions, alterations, improvements or purchases not contempl
increase in the monthly assessment
would necessitate a special assessment or a substantial
company, mortgage lender or in
unless required by a governmental agency, title insurance
the event of an emergency. '
Elements shal} actually

16. ENCROACHMENTS: If any portion of the Common
upon any Condominium Unit or if any Condomi nium Unit shall actually encroach
encroach ium
Common Elements and Condomin
upon any portions of the Common Elements, as the
to be mutual easements in favor of
Units are shown on the Survey, there shall be deemed
Elements and the respectiv e Unit Owners involved to the extent
the owners of the Common
of such encroachment so long as the same shall exist.
Should the Unit
17. SALE OR LEASE OR OTHER DISPOSITION OF UNITS: to sell or lease his
any offer
Owner wish to sell or lease his Unit, he shall, before accepting
specifically, but not limited to,
Unit, comply with the applicable provision of the By-Laws,
as provided in the By-Laws, shall be
Article VII. Any attempt to sell or lease a Unit except
whatsoever upon the intended
wholly nuil and void and shall confer no title or interest
or lessee. In the event the sponsor exercises its right to rent or Jease to non-
purchaser
for the payment of the appropriate
contract occupants, the Sponsor shall be responsible
to the terms of the Public Offering Statement,
maintenance fee to the Association, pursuant
Master Deed and By-Laws of the Condominium.
a Unit Owner under the provisions...
18. REMEDIES: In the event of any default by
By-Laws or rules and regulations of the
of the Condominium Act, this Master Deed, the
Trustees shall have each and all of the rights
Association, the Association and the Board of otherwise
nium Act (except as
and remedies which may be provided for in the Condomi
this Master Deed, the By-Laws or said rules
provided in this Master Deed or the By-Laws),
at law or in equity, and may prosecute any.
and regulations or which may be available
g Unit Owner and/or others for
action or other proceedings against such defaultin
foreclosure of such lien and the
Ee
enforcement of any lien, statutory or otherwise , including

a receiver for the Unit or for damages or an injunction or specific
appointment of
for payment of money and collection thereof, or for any
performance or for judgment
for any other relief. All expenses of the Association in
combination of remedies, or
court costs and attorneys’ fees
connection with any such actions or proceedings, including
or otherwise, together with interest
and other fees and expenses, all damages, liquidated
charged to and assessed against such
thereon at the maximum legal rate until paid, shall be
part of his respective part of the .
defauiting Unit Owner, and shall be added to and deemed
Elements and the Associati on shall have a lien for all of the same. In the eventof :
Common
wf
adopted or given by
Unit Owners owning
total number of Units in not less than Sixty-se
the Condominium Prop ven (67%) percent
of the
erty ; provided, however,
if the
Owners or of all lien hold
ers for any action spec
any amendment or ified in the Act or in the
amendments with
resp
Master Deed, then
consent or agreement ect to such action
as may be provided shal] require unanimou
in the Condominium s
Act or in this Master
Deed.
recorded,
20. NOTICE: All noti

ces provided for in
or the By-Laws shal] the Condominium Act,
be in writing, and shall this Master Deed,
Owner at the Building, or be addressed to the
at such other address as Association or to any
hereinafter provided. The Unit
Board of Trustees may Association or
designate a different addr
respectively, by giving writ ess or addresses for noti
ten notice of such change ces to them
time. Any Unit Owner of address to all Unit Owne
may also designate a diff rs at such
him by giving written noti erent address or addresse
ce of his change of addr s for notice to
as above shall be deemed ess to the Association.
delivered when mailed in Notice addressed
mail or when delivered in the United States register
person with written acknow ed or certified
addressed to a Unit Owne ledgment of the receipt there
r, when deposited in
his
of, or, if
his Condominium Unit mailbox in the Building
in the Building, or at the door of
21. : The invalidity of any

the By-Laws attached heret provisions of this Mast
er Deed or of
o shall not be deemed to
validity, enforceability impair or affect in any mann
or effect the remainder
of this
er the
such event, all of the other Master Deed or the By-L
provisio
ns of this Master Deed aws, and in
in full force and effect as and the By-Laws shall
if such invalid Provision continue
document. had never been included
in either
22. : No Unit Owner or Owne

Common Elements nor to do rs shall have the right to
any act or take any action that partition the
of condominium form or owne would result in the destructio
rship as established by the n
Condominium Act,
upon each and all of the Unit

Owners and their respective heirs, repre
assigns, purchasers, lesse
es, grantees, and mort sentatives, successors,
conveyance or the enter gagees. The acceptance of a
ing into of a lease or deed of
the act of occupancy of
a Condominium Unit
—8~
pr
rm —— ee
Eis 2
B(S56 1 pgg3y,
BY-LAWS
OF
HIGHLAND LOFTS CONDOMINIUM
ASSOCIATION, INC.
A New Jersey Not for Profit
Corporation
(located at 350 Scotland Road

in the City of Orange,
Coun ty of Essex, State of New
Jersey)
ARTICLE I
NAME, OFFICE AND PURPOSE

Section 1.
inci . These are the By-Laws
LOI'TS CONDOMINIUM of HIGHLAND
ASSOCIATION, INC, (the
office shall be located at 350 “Association” whose princi
Scotland Road, in the City pal
Jersey. of Orange, Essex County, New
Section 2. Purpose. The Association

is formed to Serve as a means
whizh the condominium reside through
ntial unit owners (the “Unit Owner
with regard to the administration, s”) may take action
m gement, maintenance, repair and
Cordominium Property (hereinafter defined) operation of the
CONDOMINIUM (the “Cond known as HIGHLAND LOFTS
ominium"™), situated in the City
New Jersey, which has been create of Orange, Essex County,
d and established in accordance with
a master deed (the “Master Deed” the provisions of
) executed by HIGHLAND LOFT
(the “Grantor, and recorded S CONDOMINIUM
in the office of the Essex County Clerk,
Jersey, to which these By-L Newark, New
aws are appended as an exhibi
condominium in effect in the t. The statutes relating to
State of New Jersey pursuant
has been created and established to which the condominium
and is to be governed are P.L.
46:8B-1 et seq., as amended, 1969, Ch. 257, RS.
of the laws of the State of New
Act”) and the Association is Jersey (the “Condominium
intended to be the entity respo
and management of the condomin nsible for the administration
ium as provided in the Condominum
Act.
ARTICLE II
PLAN OF RESIDENTIAL UNIT OWNE
RSHIP
Section 1. Applicability of By-Laws. The provisions of these
applicable to the condominium and By-Laws are
to the use and occupancy thereof.
“Condominium Property” as used The term
herein shall include the land,
(“Buildings”) and all other improvemen the buildings
ts thereon, including the Residential
Coramon Elements, as defined in Units and the
the Master Deed, and all easements,
appurtenances belonging thereto, rights and
and all other property, personal
use in connection therewith, all as set forth or mixed, intended for
in the Master Deed.
Section 2. Application. All present and future
owners, mortgagees, lessees and
occupants of Residential Units and their
employees, and any other persons who
the facilities of the Condominium Proper may use
ty in any manner are subject to these
the rules and regulations of the Association and the Master
By-Laws,
deed of conveyance or the enteri Deed, The acceptance of a
ng into of a lease of the act of occupa
Unit shall constitute an agreement ncy of a Residential
that these By-Laws, the rules and
Association and the regulations of the
provisions of the Master Deed, as they
time, are accepted and ratified and may be amended from time to
will be complied with. ' Each purcha
Residential Unit in the Condominiu ser of a
m will, by virtue of his ownership,
of the association. Title to a Residential become a member
Unit may be taken in the name of an
or in the name; of two or more Person individual
s, as tenants in common, as joint
terants by the entirety, or in the name tenants, or as
of a corporation or partnership, or in
fiduciary. the name ofa
BK556
1 P60552
(c) Despite a and b above, the GRANTOR may retain one member of the Board
of Trustees so long as there are any units remaining unsold in the regular course of
business;
(d) A GRANTOR may surrender control ‘of the Board of Trustees of the
ASSOCIATION prior to the time as specified, provided the owners agree by a majority
vate to assume control.
(e) Within 30 days after the unit owners other than the GRANTOR are entitled to
lect a member or members of the Board of Trustees, the ASSOCIATION shall call, and
vive not lest than 20 days’ nor more than 30 days’ notice of, a meeting of the Unit
Owners to «:ect the members of said board. The meeting may be called and the notice
riven by an; Unit Owner if the ASSOCIATION fails to do so.
(f) Prior to, or not more than 60 days after, the time that Unit Owners other than
the CRANTOR elect a majority of the members of the Board of Trustees, the GRANTOR
shall relinquish control of the ASSOCIATION, and the Unit Owners shall accept control,
Simultaneously, the GRANTOR shall deliver to the’ ASSOCIATION all property of the
Unit Owners and of the ASSOCIATION held or contiolied by the GRANTOR including
but not limited to, the items set forth in N.J.S.A. 4%6:8B-12.1. Which are as follows:
Certified copy of the complete Master Deed and amendments, certified copy of
association Articles of Incorporation, copy of By-Laws, minutes, rules and regulations,
officer resignations, association fund accounting, association funds, personal property of .
association, copy of plans and specifications, insurance policies, certificate of
occupancies, any permits issued within one year, warranties, roster of unit owners, leases,
employment and management contracts and any other contracts to which the association
i~ a party.
Section 2. Powers and Duties. The Board of Trustees shall have the powers and
Cuties necessary for the administration and management of the affairs of the Association
«:d may do all such acts and things, except those which by law or by Master Deed or by
these By-Laws may not be delegated to the Board of Trustees by Unit Owners. In
addition to those powers and duties granted the Board of Trustees pursuant to the
“ondominium Act, the powers and duties of the Board of Trustees shall include, but shall
not be limited to, the following:
(a) Operation, care, upkeep, repair and replacement of the Common Elements and
service and personal property of the Association, if any, together with the right
to use all funds collected by the Association to effectuate the foregoing.
(b) Determination of the Common Expenses required for the affairs and duties of
the Association, including the establishment of reasonable reserves for future
replacement of, and maintenance to the Condominium Property.
1. The Board of Trustees shall, prior to the beginning of each fiscal year of the
Association, prepare a budget which shall determine the amount of common charges
payable by cach Residential Unit to meet.the Common Expenses of the Association,
including the aforesaid reserves, and to make up any deficit in the Common Expenses for
any prior yer. The Board of Trustees shall allocate and assess such charges equally
among the U it Owners in accordance with the applicable provisions of the Master Deed.
nit Owners are permitted to attend and participate at the meeting held for the purpose of
preparing thr budget but said Unit Owners shall not be permitted to vote on matters
nertaining tl “reto. Unit owners shall be advised of the amount of Common Expenses
payable by each of them and these charges shall be paid to the Association in twelve (12)
equal monthly installments on the 1* day of each month of the fiscal year, in advance, at
the office of the Association. A statement of the aforesaid yearly charges along with 2
copy of the annual budget shall be mailed to each Unit Owner at the commencement of
cach fiscal year and no further billing by the Association shall be required.
BK556
1 P60553
2. The fiscal year of the Association shall be a calendar year.
3. Despite anything in these By-Laws or elsewhere to the contrary, the

Board of
Trustees shall not have the authority, except for the repair and/or replacement
of any
common element or such other emergency as determined in the Board of Trustees,
to
expend in excess of $5,000.00, on any item of expense in any year which is not specified
in, or if specified, over the amount indicated for such item in, the aforesaid budget for
such year, without the consent of the majority of the Unit Owners.
(c¢) Employment and dismissal of personnel necessary for the maintenance and operation
of the Condominium Property, including the Common Elements and other property
which may be owned by the Association.
(d) Adopting and amendment of rules and regulations covering the operation and use of
the Condominium Property.
(¢) Opening of bank accounts on behalf of the Association and designating the
signatories required therefor.
(f) Purchase or arrangement for such services, machinery, tools, supplies, and the like as
in the opinion of the Board of Trustees may from time to time be necessary for the proper
operation and maintenance of the Condominium Property and Common Elements and the
facilities and general business of the Association. The Board of Trustees may also
employ a manager for the Association at such compensation as it may deem appropriate,
to perform such duties as the Board of Trustees may so designate and may lawfully
delegate.
(8) Employment of legal counsel, engineer, and accountants and fixing their
compensations whenever such services may be deemed necessary by the Board of
Trustees.
(h) Maintenance of detailed books of account of the receipts and expenditures of the
Association. Such books of accounts shall be audited when requested by the Board of
Trustees but not less than annually by a certified public accountant and a statement
reflecting the financial condition and transactions of the Association shall be furnished (0
each Unit Owner on an annual basis. The books of account and any supporting vouchers
shall be made available for examination by a Unit Owner at convenient hours on working
days that shall be established by the Board of Trustees and announced for general
knowledge.
(i) While the developer maintains a majority of the executive board he shall have an
annual audit of association funds prepared by an independent accountant, a copy of which
shall be delivered to each unit owner within 90 days of the expiration of the fiscal year of
the association. The audit shall cover the operation budget and reserve accounts.
(i) Maintenance of adequate fidelity bonds for Association officers, agents, and
employees handling Association funds and records, at such times and in such amounts as
the Board of Trustees may deem necessary. The premiums for such coverage shall be
paid by the Association and shall constitute a Common Expense.
(k) While the developer maintains a majority of representation on the executive board, he
shall post a fidelity bond or other guarantee acceptable to the Agency, in an amount equal
to the annual budget. For the second and succeeding years, the bond or other guarantee
shall include accumulated reserves.
(1) Payment of all taxes, assessments, utility charges and the like assessed against any
property of the Association or assessed against any Common Elements exclusive of any
taxes or assessments properly levied against any Unit Owners.
—-6-
- ak5561°60560
Trustees full account of the

President and the Board of
law. He shall render to the regul ar meeti ngs of the Board of Trustees
iation at the
financial condition of the Assoc Board of Trust ees shall so require.
President or the
and whenever either the
any compensation
of Officers. No officers shall receive
Section 8. Compensation they shall be entitled to
acting as such except that
from the Association for disch arge of their duties.
reasonably incurred in the
reimbursement for all expenses
. All agreements,
Section 9. be
s and other instr ument s of the Association shall
contracts, deeds, leases, check as
of the Associatio n or by such other person Or persons
exccuted by eny two officers of Trustees.
the Board
may be designated in writing by
his heirs, administrators
of Officers. Rach Officer,
. Section 10. Indemnification ess by the Association against any
nified and held harml
and executors shall be indem ction with any action or
fees reasonably incurred in conne
losses, expenses and counsel heirs, admin istra tors and executors are made a party
officer, his
pro-eeding in which said such officer be adjudged in
such
ded, however, that should
by reason of such office; provi the aforesaid
nduct,
gross negligence or willful misco
action to have been guilty of a settl ement , such offic er shall be indemnified
the event of
indemnity shall not apply. In Association is advised by its
ed by the settlement which the
only as to such matters cover gence or willf ul misconduct of such officer
gross negli
counsel is not the result of such is appro ved by the Board of Trustees. Such
settlement
ar d only if and to the extent such the offic ers as such to the extent herein
encompass acts of
ir lemnification is intended to tive with respect to any duties, oblig
ations or
not inten ded to be opera
provided and is iatio n memb ers.
r as Unit Owners or Assoc
lisbilities assumed by such office
ARTICLE VI
TY
OPERATION OF THE PROPER
t of Common EXpenses . The Board

Section 1. Determination and Establishmen annually, prepare a budget for the
time, and at least
o~ Trustees shall from time to payable by the Unit
amount of Common Expenses
Condominium, getermining the Expens es among the Unit Owners or, in
Commo n
Cwners, and allocate and assess such among the Unit Owners in accordance
commo n surplus
th case of surplus, distribute said the common surplus
the Common Elements or apply
with their respective interests in ing the year in ‘which the common
for the year follow
against the Common Expenses include , among other things, the cost
Expenses shall
splus was created. The Common been
ums on all policie s of insura nce required to be or which have
¢< insurance premi to the provisions of Section 2 of
ARTICLE
of Truste es pursua nt
tained by the Board Board of Trustees
also include such amounts as thé
\1. The Common Expenses shall nance of the Condominium Property,
operat ion and mainte
ray deem proper for the of the Association, for a
an amount for working capital
including, but not limited to, in the Common Expenses for any
to make up any deficit
general operating reserve, and of Trustees, with the approval of the
prior year. Despite the above, the Board year.
an annual contri bution to the reserve in any single
/ sociation, may provide for be required for the
include such amounts as may
1 se Common Expenses may also Owners, of any
or its designee, on behalf of all Unit
p.r-hase or lease by the Association is to be sold at a foreclosure or other
ntial Unit which
F.zsidential Unit, or of any Reside ly, in writing, of
shall advise all Unit Owners prompt
jdicial sale. The Board of Trustees by each of them respec tively , as determined by
payabl e
t'-e amount of Common Expenses on which such
Unit Owners copies of each budget
{= Board, and shall furnish to all in these By-La ws to the contrary, the
Despite anythi ng
(*ommon Expenses are based. incur any liabilit y or expend any funds
the authority to
“yoard of Trustees shall not have in respect of capital improv ements
the Association
‘0 behalf of the Unit Owners or books of the Association) in
or not so designated on the
proposed to be made (whether each instance the
in any fiscal year of the Association, without, in
excess of $5,000.00
s by the affirmativevote of 67% of the votes cast on
vrior authorization of the Unit Owner be present.
Owners at which a quorum shall
the question at a meeting of Unit
Lr
Bk556
1 P6056 |
Section 2. Insurance.
A. The Board of Trustees shall be required to obtain and maintain, to the extent
obtainable, the following insurance upon the Condominium Property and the equipment
and personal property owned by the Association. The policies so obtained shall be for the
benefit and protection of the Association and the owners of the Residential Units and
their respective mortgagees as their interest may appear. All policies shall be written
with a company licensed to do business in the State of New Jersey and holding a rating of
“AAA” or better by Best's Insurance Reports or by an equivalent rating bureau should
Best's Insurance Reports cease to be issued. If agreeable to the insurer, such policies
shall include provisions that they be without contribution, that improvements to
Residential Units made by Unit Owners shall not affect the valuation of the
Condominium Property for the purposes of insurance and that the insurer waives its rights
of subrogation as to any claims against Unit Owners, the Association and their respective
families, employees, servants, agents, and guests. The insurance maintained shall cover
the following perils and contingencies.
(1) CASUALTY: The Building and all improvements upon the Condominium
Property and all personal property included therein, except such personal property as may
be owned by the Unit Qwners in their respective Units, shall be insured in an amount
equal to the maximum insurable repfacement value thereof (exclusive of excavation,
foundations and other construction components customarily excluded as determined
periodically by the insurance company affording such coverage. Such coverage shall
afford protection against:
(a) Loss or damage by fire or other hazards covered by the standard extended
coverage endorsements; and
(b) such other risks as from time to time shall customarily be covered with respect
to buildings similar in construction, location and use as the building,
including, but not limited to vandalism, malicious mischief, windstorm and
water damage.
(2) COMPREHENSIVE PUBLIC LIABILITY AND PROPERTY DAMAGE: In

such amount and in such forms, as shall be required by the Association, including, but not
limited to, water damage, legal liability, hired automobiles, non-owned automobiles and
off premises employee coverage.
(3) WORKERS’ COMPENSATION: Coverage to meet the requirments of law.
All liability insurance shall contain cross-liability endorsements to cover

liabilities of the Association and the Unit Owners, as a group, to an individual Unit
Owners.
Each Unit Owner shall have the right to obtain insurance, at his own expense,
affording coverage upon his personal property and for his personal liability and as may be
required by law, and shall obtain insurance, at his own expense, affording coverage upon
the betterments and improvements owned by said Unit Owner, but all such insurance
shall contain the same waiver of subrogation as that referred to hereinabove if same is
available, and must be obtained from the insurance company from which the Association
obtains coverage against the same risk, liability or peril if the Association has such
coverage and if available from such company. However, a Unit Owner shall not be
obligated to purchase such insurance through the broker or agent used by the Association.
B. All insurance policies maintained by the Association shall be for the benefit of
the Association and the Unit Owners, and their mortgagees, as their respective interests
may appear, and shall provide that all proceeds payable as a result of casualty losses shall
be paid to the Association. All betterments and improvement insurance policies
maintained by Unit Owners shall provide that all proceeds payable as a result of casualty
-lb4=
BK556
1 P6056 L
beneficiary of an insurance policy, the proceeds of which are included in the

Reconstruction and Repair Account, such Account shall be disbursed in the
manner hereafter provided for the reconstruction and repair of major damage.
(c) In the Event of Major Damage:
If the amount of the estimated costs of reconstruction and repair of the

Building or other improvements are more than the total of the annual assessments
for Common Expenses made during the year in which the casualty occurs, then
the Reconstruction and Repair Account shall be disbursed in payment of such
costs in the manner required by the Board of Trustees of the Association, but only
upon approval of any architect qualified to practice in the State of New Jersey and *
employed by the Association to supervise the work.
(d) Distribution of Surplus:
It shall be presumed that the first monies disbursed in payment in costs of

reconstruction and repair shall be from insurance proceeds. If there is a balance in
the Reconstruction and Repair Account after payment of all costs of
reconstruction and repair for which the Account is established, and after
distribution of any remaining insurance proceeds as to affected Unit Owners as
provided for above, such balance shall be distributed to all of the Unit Owners
whose interests are reflected in such Account by reason of their having made
payments of assessments thereto, in proportion to their contributions.
Section 4. Payment
of Common Expenses.
A. All Unit Owners (including the Grantor as limited by Section 5 of the Master
Deed) shali be obligated to pay the Common Expenses assessed by the Board of Trustees
pursuant to the provisions of Sestion 1 of ARTICLE VI of these By-Laws. Payments
shall be made to the Association monthly, in advance, on the first day of each month at
the principal office of the Association or at such other place as may be designated for
such purposes by the Board of Trustees or pursuant to the provisions of these By-Laws.
In the even a Unit Owner shall fail to make payment on his part of the Common Expenses
when due, said Common Expenses shall bear interest at a maximum legal rate permitted
under law from the due date set by the Board of Trustees until payment is made in full of
the Common Expenses due. Each member of the Association, other than the Grantor,
shall, in addition, be required to maintain with the Association a sum equal to a non-
refandable 3/12 of the estimated annual assessment for his Residential Unit, or as
otherwise provided by law, as security against non-payment of future assessments.
Except to the extent permitted to be used hereunder, the sums so paid as security against
non-payment of future assessments shall be held by the Association in a separate account,
or scparate accounts which may be, but are not required to be, interest-bearing. Said sum
may be used by the Association for working capital and may be, but need not be, applied
by the Board of Trustees against Common Expenses and Assessments which are in
arrears. Unit Owners shall be required to supplement said security from time to time by
future payments in the event. that the estimated annual assessments for future years is
increase, or if the amount theretofore paid has been applied in whole or in part for
working capital or to cure a default by the Unit Owner. The Grantor shall not be required
to make any such prepayment of security deposit on account of any Residential Units
owned by it.
B. No abandonment of the Residential Unit owned by a Unit Owner or a waiver

of the use and enjoyment of any of the Common Elements shall exempt or excuse any
Unit Owner from his contribution toward such expenses.
Section 5. i . Special Assessments, when levied

by the Board of Trustees pursuant to these By-Laws, shall be paid by the Unit Owners in
such manner as may be determined by the Board of Trustees; provided, however, that,
other than those special assessments levied pursuant to paragraph (t) of Section 2 of
iy
NS
” 8k556 1760565
for such special
tion of each member
By-Laws, the contribu Com mon Expenses
Article IV of these same man ner as the
ssme nt shall be appo rtioned equally in the
asse
this Article.
pursuant to Section 1 of
0d Assenels All
ment of Common Expensss er for his
Section 6. Default in Pay char geab le to and payable by a Unit Own
Expenses and asse ssments ial Unit in favo r of the
Common
constitute a lienagainst said Resident
Residential Unit shall line with the office
such lien or notice of
with out the necessity of filing any d lien shall be prio
r to all other
Association l offic ial. The aforesai
or Municipa
of any State, County
liens except:
asscssments;
for prior charges and
by the Association
(a) any similar liens
Unit;
taxes due on said Residential
and charges for unpaid
(b) assessments, liens
Residential Unit.
of record upon such
(©) permitted mortgages
the County of
the Clerk's Office of
file a claim of lien in after the unpaid
The Association may on of fort y-fi ve days
form upon the expirati esaid may be
Union in appropriate payable. The lien afor
ssment shall be due and the event of such
Common Expense or asse mort gage s, and in
manner as real estate entitled to recover
foreclosed in the same to the amount due, be
ion shall, in addition the reasonable
foreclosure the Associat or sums due, toge ther with
est at the max imu m legal rate on such sum A suit by the Association
inter s’ fees.
of such acti on, incl uding costs and attorney for the unpa id Common
expenses ey judgment
member to recover a mon foreclosing or waiving
the lien
against the delinquent main tain able with out
shall be ration of
Expenses and assessments g actions shall be main
tained upon the expi
the foregoin due and payable, and,
securing the same. Both or assessment shall be
any Common Expense ced by the
fifteen (15) days after 2 fore clos ure action must be commen
Common Expenses of
ing circumstance s,
except under extenuat i
one hundred eigh ty (180) days after the of any of the i
Association not later than to pay any installment
shall be due and payable. Failure the Board of
assessment whe n due, shall , at the option of
and assessments ent
Common Expenses nt due and paya ble, as if no installment paym
e annual amou d of Trustees to take any
Trustees, render the entir the Asso ciat ion oF boar
e. The failure of Trustees shall not
provisions were operativ Association or Board of
ired to be taken by the
action permitted or requ futu re.
right to do so in the
constitute a waiver of their
Repair
Section 7. Maintenance and
whether
the Common Elements,
irs and replacements {0 negligence,
A. All maintenance, repa (unless nece ssit ated by the
of the Residential Unit ants, in
located inside or outside guests, licensees, or serv
or negl ect of 8 Unit Owner, his tenant, agents, r), and rega rdless of
misu se Unit Owne
shall be charged to such made by the
which case such expense ar Unit Owners, shall be
her there is spec ial benefit thereby to particul nse.
whet mon Expe
to all members as a Com
Association and be charged
which
of any Residential Unit
repairs to such portion belonging
B. All maintenance and , or any part or parts ther eof
of the Common Elements carefully by the
does not comprise a part be made promptly and
e or in part to othe r Unit Owners, shall risk, cost and expense.
in whol s at their own
g such Residential Unit costs or expenses, incl
uding
member or members owin dama ges, liabi litie s,
liable for any to promptly and/or care
fully
Each member shall be out of his failu re
by or arising
attorneys’ fees, caused r work .
nce and repai
perform any such maintena
r or
makes & necessary repai
ciation or Unit Owner the obligation of the
C. In the event the Asso ed that the same was
equently determin acement shall
replacement and it is subs ble for tlre repair or repl
shall have been responsi the cost of the same or
other, then the party who r or repl acem ent for
has made such repai
indemnify the party who thereto.
ctly to the person entitled
shall make payment dire
-18- .
~ ak556 1p60569
such mortgagor's obligations under the Master Deed, these By-Laws or the rules and
regulations adopted pursuant thereto which default is not cured within thirty (30) days.
ARTICLE VIII
RECORDS
Section 1. Records and Audit. The Board of Trustees shall keep detailed records
of its actions, minutes of the meetings of the Board of Trustees minutes of the meetings
of Unit Owners and financial records and books of account of the Association, including
a chronological listing of receipts and expenditures as well as a separate account for each
Residential Unit which, among other things shall contain the amount of each assessment
of Common Expenses against such Residential Unit, the date when due, the amounts paid
thereon, the balance remaining unpaid and the amount of any interest in common surplus.
An annual report of the receipts and expenditures of the Association certified by an
to all
independent certified public accountant shall be rendered by the Board of Trustees
same,
Unit Owners and to all mortgagees of Residential Units who have requested the
a
promptly after the end of each fiscal year. The cost of such report shall constitute
in
Common Expense. The accounting records of the Association shall be maintained
accordance with generally accepted accounting principles and shall be open to inspection
at reasonable times to all Unit Owners and holders of permitted mortgages.
ARTICLE IX
DISSOLUTION
Section 1. Procedure. The provisions of the then applicable laws of the State of
New Jersey, including the provisions of the Condominium Act, shall be followed should
it be deemed advisable that the Association be dissolved, subject to the rights of any
mortgage or lienor with respect thereto.
Section 2. Owner Dissolution.

Uponship In the event of dissolution, the
Condominium Property shall thereupon be owned by all of the Unit Owners as tenants in
common, each having an undivided percentage interest therein equal to his proportionate
part of the Common Elements owed prior to termination. Each Unit Owner may be
required to execute such deed and any other document or instrument which may be
reasonably required to effect the sale of the Condominium Property by the Association
following a decision to dissolve the Association.
ARTICLE X
COMPLIANCE WITH BY-LAWS AND MASTER DEED
Section 1. Penalties. These By-Laws, the rules and regulations adopted pursuant
hereto, all future amendments hereof and thereof, and the covenants and restrictions in the
Master Deed shall be strictly complied with by each Unit Owner. Failure to comply with
or for
any of the same shall entitle the Association to bring suit to recover monies due
has
damages and/or injunctive relief or both against the offending Unit Owner. If suit
to
been instituted by the Association and the Unit Owner has been found by the Court
the
have committed the violation complained of, the Unit Owner shall reimburse
the Court.
Association for reasonable attorneys’ fees and costs as may be permitted by
action for
Nothing herein shall be deemed to preclude any Unit Owner from bringing
which
relief against another Unit Owner or Unit Owners or the Association for a violation
affects such aggrieved Unit Owner's occupancy.
ARTICLE XI
MISCELLANEOUS
-22
EXHIBIT C
4841-0983-6166, v. 1
A B C D E F G H I
4 101 Kyle Donovan
Transaction Memo/Description
5 Name Date Num Type Amount Payment Balance
6 October 2020
Check received from Landview Title Agency, LLC - close of unit 101
between Colony Holdings LLC and Kyle Donovan on 10/19/2020
7 101 Kyle Donovan 10/26/2020 1219 Payment 1,932.00 (1,932.00)
Common Expense payable by unit owners in accordance with their
8 101 Kyle Donovan 10/26/2020 1275 Invoice respective interest in the Common Elements. 483.00 (483.00)
9 101 Kyle Donovan 10/26/2020 1275 Invoice HOA dues collected from purchaser at close of condo sale 1,449.00 (1,449.00)
10 Total for October 2020 $ 3,864.00 -$ 3,864.00 $ 0.00
11 November 2020
12 101 Kyle Donovan 11/16/2020 1295 Invoice respective interest in the Common Elements. 483.00 -
13 Total for November 2020 $ 483.00 - $ 483.00
14 December 2020
16 Total for December 2020 $ 483.00 - $ 483.00
17 January 2021
19 Total for January 2021 $ 483.00 - $ 483.00
20 February 2021
22 Total for February 2021 $ 483.00 - $ 483.00
23 March 2021
25 Total for March 2021 $ 483.00 - $ 483.00
26 April 2021
28 Total for April 2021 $ 483.00 - $ 483.00
29 May 2021
31 Total for May 2021 $ 483.00 - $ 483.00
32 June 2021
34 101 Kyle Donovan 06/15/2021 1445 Invoice Legal Fees - Pending 0.00 -
35 Total for June 2021 $ 483.00 - $ 483.00
36 July 2021

38 101 Kyle Donovan 07/15/2021 1465 Invoice Legal Fees - May 31, 2021 Invoice #2034445 767.00 -
A B C D E F G H I
39 101 Kyle Donovan 07/15/2021 1465 Invoice Legal Fees - June 30, 2021 Invoice #2038618 413.00 -
41 Total for July 2021 $ 1,846.75 - $ 1,846.75
42 Aug-21
44 101 Kyle Donovan 8/15/2021 1486 Invoice Legal Fees - Pending -
45 Total for August 2021 $ 483.00 - $ 483.00
46 Sep-21
48 101 Kyle Donovan 9/15/2021 1505 Invoice Legal Fees - Invoice #2042404 151.20 -
50 101 Kyle Donovan 9/15/2021 1505 Invoice Legal Fees - Invoice #2046378 1,084.43 -
51 Total for September 2021 $ 1,873.51 - $ 1,873.51

52 Oct-21
54 101 Kyle Donovan 10/15/2021 1524 Invoice Legal Fees - Pending
55 Total for October 2021 $ 483.00 - $ 483.00

56
57 Nov-21
61 Total for November 2021 $ 2,053.68 - $ 2,053.68
62
63 Dec-21
65 101 Kyle Donovan 12/15/2021 1563 Invoice Legal Fees - Invoice #02058404 (12/2/21) 307.58
67
68 TOTAL $ 11,145.94
69
70
71
72 Jan-22

76
77 Feb-22
A B C D E F G H I

81
82 Mar-22
83 101 Kyle Donovan 3/15/2022 Invoice respective interest in the Common Elements. 483.00 -
84 101 Kyle Donovan 3/15/2022 Invoice Legal Fees - Invoice #02070419 (3/9/22) 590.63
85 Total for March 2022 $ 1,073.63 - $ 1,073.63
86
$13,831.05
Accelerated Maint. Fees 4/22-12/22 4,347.00
Total $18,178.05
EXHIBIT D
4841-0983-6166, v. 1
STARK
STARK &
& STARK,
STARK, A
A Professional
Professional Corporation
Corporation
Mailing Address: PO
Mailing Address: PO Box
Box 5315,
5315, Princeton, NJ 08543-5315
Princeton, NJ 08543-5315
Office
Office Location:
Location: 993
993 Lenox
Lenox Drive,
Drive, Lawrenceville, NJ 08648-2389
Lawrenceville, NJ 08648-2389
(609)
(609) 896-9060
896-9060
Melissa A. Volet,
Esquire -- 03080-2002
03080-2002
Attorneys
Attorneys for
for Plaintiff
Plaintiff
HIGHLAND
HIGHLAND LOFTS
LOFTS CONDOMINIUM
CONDOMINIUM SUPERIOR
SUPERIOR COURT
COURT OF NEW JERSEY
OF NEW JERSEY
ASSOCIATION,
ASSOCIATION, INC.,
INC., LAW
LAW DIVISION,
DIVISION, SPECIAL
SPECIAL CIVIL
CIVIL PART
PART
ESSEX
ESSEX COUNTY
COUNTY
Plaintiff,
Plaintiff,
v.
CIVIL ACTION
CIVIL ACTION
KYLE
KYLE DONOVAN,
DONOVAN,
AFFIDAVIT OF
AFFIDAVIT OF NON-MILITARY
NON-MILITARY
Defendant.
Defendant. SERVICE
SERVICE
I,
I, MELISSA
MELISSA A.
A. VOLET,
VOLET, ESQUIRE,
ESQUIRE, hereby
hereby certify:
certify:
1.
I. II am
am an
an attorney
attorney with
with Stark
Stark &
& Stark,
Stark, aa Professional
Professional Corporation.
Corporation. II am
am one
one of the
of the
attorneys responsible for

attorneys responsible the representation
for the representation of
of Highland
Highland Lofts
Lofts Condominium
Condominium Association,
Association, Inc.
Inc.
(the
(the “Association”).
“Association”). As
As such,
such, II have
have full
full knowledge
knowledge of
of the
the facts
facts as
as set
set forth
forth herein.
herein.
2.
2. The
The defendant
defendant herein
herein is
is not
not an
an infant,
infant, incompetent,
incompetent, nor
nor in the military
in the military service
service of
of
the United
the United States.
States. (A true and
(A true and correct
correct copy
copy of the Statement
of the Statement from the Department
from the Department of
of Defense
Defense is
is
attached
attached hereto as Exhibit
hereto as Exhibit “A.”)
“A.”)
II certify
certify that
that the
the statements
statements made
made herein
herein are
are true.
true. II am
am aware
aware that
that if
if any
any of the statements
of the statements
made
made herein
herein are
are willfully
willfully false,
false, II am
am subject
subject to punishment.
to punishment.
STARK &
STARK
A
& STARK
STARK
A PROFESSIONAL
PROFESSIONAL CORPORATION
/s/ Melissa
/s/ Melissa A.
A. Volet
Volet
MELISSA A. VOLET,
VOLET, ESQUIRE
CORPORATION
ATTORNEYS AT LAW
ATTORNEYS AT LAW MELISSA A. ESQUIRE
Dated:
Dated: June
June 17, 2022
17,2022
4811-7167-1294, v.
4811-7167-1294, v. 11
EXHIBIT
EXHIBIT “A”
“A”
STARK
STARK &
& STARK
STARK
A
A PROFESSIONAL
CORPORATION
ATTORNEYS
ATTORNEYS AT
AT LAW
LAW
-2-
4811-7167-1294, v.
4811-7167-1294, v. 11
Department of Defense Manpower Data Center Results as of : Apr-06-2022 09:20:24 AM
SCRA 5.12
SSN:
Birth Date: Dec-XX-1971
Last Name: DONOVAN
First Name: KYLE
Middle Name:
Status As Of: Apr-06-2022
Certificate ID: 46B9JRCGS2TZ514
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
NA NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status Service Component
NA NA No NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
Michael V. Sorrento, Director

Department of Defense - Manpower Data Center
400 Gigling Rd.
Seaside, CA 93955
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 3901 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service. Service contact
information can be found on the SCRA website's FAQ page (Q35) via this URL: https://scra.dmdc.osd.mil/scra/#/faqs. If you have evidence the person
was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked
against you. See 50 USC App. § 3921(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"

Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases

Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.

New Jersey Attorney ID #03080-2002
STARK & STARK
(609) 896-9060

ESSEX COUNTY
Plaintiff,
v.
CIVIL ACTION
KYLE DONOVAN,
CERTIFICATION OF SERVICE
Defendant.
1. I am an attorney with Stark & Stark, A Professional Corporation, and I
represent the interests of the Plaintiff, Highland Lofts Condominium Association Inc. (the
“Association”), in the above-entitled matter.
2. On June 17, 2022, true and correct copies of the Association’s Notice of
Motion for Default Judgment, Certification of Proof of Amount Due, Certification of
Attorneys’ Fees and Costs, Affidavit of Non-Military Service, and proposed form of Order
and Certification of Service were mailed to Defendant, Kyle Donovan, at 350 Scotland Road,
STARK & STARK

Apt. #101, Orange, NJ 07050, via Federal Express.
ATTORNEYS AT LAW
3. On June 17, 2022, true and correct copies of the Association’s Notice of
4825-3049-4718, v. 1
Motion for Default Judgment, Certification of Proof of Amount Due, Certification of
Attorneys’ Fees and Costs, Affidavit of Non-Military Service, and proposed form of Order
and Certification of Service were mailed to Association’s Defense Counsel, David J. Montag,
Esq., at Milber, Makris Plousadis & Seiden, LLP, at 75 Livingston Avenue, Suite 101,
Roseland, New Jersey 07068, via e-mail, regular and certified mail, return receipt requested.
4. On June 17, 2022, a courtesy copy of the Plaintiff’s Notice of Motion for
Default Judgment, Certification of Proof of Amount Due, Certification of Attorneys’ Fees and
Costs, Affidavit of Non-Military Service, and proposed form of Order and Certification of
Service were mailed to the Honorable Annette Scoca, J.S.C., at the Essex County Historic
Court House, 470 Dr. Martin Luther King, Jr. Blvd., 2nd Floor, Newak, New Jersey 07102,
via Federal Express.
5. Defendant’s address has not changed since service of original process.
I certify that the statements made herein are true. I am aware that if any of the
statements made herein are willfully false, I am subject to punishment.

STARK & STARK

ATTORNEYS AT LAW
4825-3049-4718, v. 1
Department of Defense Manpower Data Center Results as of : Apr-06-2022 09:20:24 AM
SCRA 5.12
SSN:
Birth Date: Dec-XX-1971
Last Name: DONOVAN
First Name: KYLE
Middle Name:
Status As Of: Apr-06-2022
Certificate ID: 46B9JRCGS2TZ514
On Active Duty On Active Duty Status Date
NA NA No NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
NA NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status Service Component
NA NA No NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
Michael V. Sorrento, Director

Department of Defense - Manpower Data Center
400 Gigling Rd.
Seaside, CA 93955
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 3901 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service. Service contact
information can be found on the SCRA website's FAQ page (Q35) via this URL: https://scra.dmdc.osd.mil/scra/#/faqs. If you have evidence the person
was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked
against you. See 50 USC App. § 3921(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"

Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases

Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
NOT APPLICABLE

(609) 896-9060

ESSEX COUNTY
Plaintiff,
v.
CIVIL ACTION
KYLE DONOVAN,
CERTIFICATION OF COUNSEL AS TO
Defendant. SOURCE OF SERVICE ADDRESS
1. I am an attorney with Stark & Stark, a Professional Corporation, attorneys for the
Plaintiff. I am one of the attorneys responsible for the representation of Highland Lofts
Condominium Association, Inc. (the “Association”). As such, I have full knowledge of the facts
as set forth herein.
2. The Defendant, Kyle Donovan, resides at 350 Scotland Road, #101, Orange, New
Jersey 07050. The source of the address used for service of the Summons and Complaint upon
the Debtor was a Trans Union search which is attached hereto as Exhibit “A.”
I certify that the statements made herein are true. I am aware that if any of the statements
made herein are willfully false, I am subject to punishment.

STARK & STARK
ATTORNEYS AT LAW /s/ Melissa A. Volet
Dated: April 6, 2022
4860-1307-0106, v. 1
EXHIBIT “A”
STARK & STARK

ATTORNEYS AT LAW
-2-
4860-1307-0106, v. 1
FOR COLLECTIONS PURPOSES ONLY KYLE DONOVAN 350 SCOTLAND RD #204 ORANGE NJ-People-Search-202109291132
1 Result Found for people named KYLE DONOVAN located at 350 SCOTLAND RD #204, ORANGE, NEW JERSEY.
KYLE D DONOVAN,
Subject Information Address History (27) Possible Phones
KYLE D DONOVAN (02/13/1996 to 350 SCOTLAND RD APT 101, ORANGE, NJ 07050-2382 (ESSEX COUNTY)
08/04/2021) (12/14/2020 to 09/29/2021)
KYLE DONOVAN MCCRAY SENIOR Subdivision Name: HIGHLAND LOFTS CONDO
(08/18/1995 to 04/22/2021) Address contains: 19 apartments
KYLE DONOVAN MCCRAY (07/01/1993 to Current Commercial Phone at address
04/22/2021)
O KYLE MCCRAY (11/01/1995 to
11/30/2020)
Other Observed Names

KYLE DONOVAN DONOVAN (11/01/2006 to
08/04/2021)
Page 1 of 5 09/29/2021
STARK
STARK &
& STARK,
STARK, A
A Professional
Corporation
Mailing Address: PO
Mailing Address: PO Box
Box 5315,
5315, Princeton, NJ 08543-5315
Princeton, NJ 08543-5315
Office
Office Location:
Location: 993
993 Lenox
Lenox Drive,
Drive, Lawrenceville, NJ 08648-2389
Lawrenceville, NJ 08648-2389
(609)
(609) 896-9060
896-9060
Melissa A. Volet,
Esquire -- 03080-2002
03080-2002
Attorneys
Attorneys for
for Plaintiff
Plaintiff
HIGHLAND
HIGHLAND LOFTS
LOFTS CONDOMINIUM
SUPERIOR COURT
COURT OF NEW JERSEY
OF NEW JERSEY
ASSOCIATION,
ASSOCIATION, INC.,
INC., LAW
LAW DIVISION,
DIVISION, SPECIAL
SPECIAL CIVIL
CIVIL PART
PART
ESSEX
ESSEX COUNTY
COUNTY
Plaintiff,
Plaintiff,
v.
CIVIL ACTION
CIVIL ACTION
KYLE
KYLE DONOVAN,
DONOVAN,
CERTIFICATION
CERTIFICATION OF
OF MELISSA A.
MELISSA A.
Defendant.
Defendant. VOLET,
VOLET, ESQ.
ESQ.
I,
I, MELISSA
MELISSA A. VOLET, ESQUIRE,
A. VOLET, ESQUIRE, hereby
hereby certify:
certify:
1.
I. II am
am an
an attorney
attorney with
with Stark
Stark &
& Stark,
Stark, aa Professional
Professional Corporation,
Corporation, attorneys
attorneys for
for the
the
Plaintiff.
Plaintiff. I1 am
am one
one of
of the
the attorneys
attorneys responsible
responsible for
for the
the representation
representation of
of Highland
Highland Lofts
Lofts
Condominium Association Inc.,

Condominium Association Inc., (the
(the “Association”).
“Association”). As
As such,
such, II have
have full
full knowledge
knowledge of
of the
the facts
facts
as
as set
set forth
forth herein.
herein.
2.
2. On
On June
June 8,
8, 2022,
2022, an Amended Order
an Amended Order was
was entered
entered Striking
Striking Defendant’s
Defendant’s Answer
Answer
and
and Counterclaim,
Counterclaim, aa true
true and
and correct
correct copy
copy of
of which
which is
is attached
attached hereto as Exhibit
hereto as Exhibit “A”.
“A”. The
The
Association files
Association files the
the within Notice of
within Notice of Motion
Motion for
for Entry
Entry of
of Default
Default Judgment,
Judgment, relying
relying on
on the
the
Certification
Certification of
of Proof
Proof of Amount Due
of Amount Due and
and Certification
Certification of Attorneys’ Fees
of Attorneys’ Fees and
and Costs.
Costs.
STARK
STARK &
& STARK
STARK
A PROFESSIONAL
CORPORATION
ATTORNEYS
ATTORNEYS AT
AT LAW
LAW
4856-1500-0356, v.
4856-1500-0356, v. 11
II certify
certify that
that the
the statements
statements made
made herein
herein are
are true.
true. II am
am aware
aware that
that if
if any
any of the statements
of the statements
made
made herein
herein are
are willfully
willfully false,
false, II am
am subject
subject to punishment.
to punishment.
/s/ Melissa
/s/ A. Volet
Melissa A. Volet
MELISSA
MELISSA A. A. VOLET,
VOLET, ESQUIRE
ESQUIRE
Dated:
Dated: June
June 10,
10, 2022
2022
STARK
STARK &
& STARK
STARK
A PROFESSIONAL
CORPORATION
ATTORNEYS
ATTORNEYS AT
AT LAW
LAW
-2-
4856-1500-0356, v.
4856-1500-0356, v. 11
EXHIBIT
EXHIBIT “A”
“A”
STARK
STARK &
& STARK
STARK
A
A PROFESSIONAL
CORPORATION
ATTORNEYS
ATTORNEYS AT
AT LAW
LAW
-3-
4856-1500-0356, v.
4856-1500-0356, v. 11
ESX- ESX-DC-014376-21
ESX-DC-014376-21
ESX-DC-014376-21
ESX-DC-014376-21 06/08/2022
06/17/2022
05/05/2022
06/08/2022
12:16:10PgPM
2:55:33PgPM11 of
ofPg
2 14Trans
Pg
2 Trans
of ID: SCP20221450205
of15 Trans
ID:
Trans
SCP20221450205
ID: 53259
ID:SCP20221153259
SCP20221538791
David
David J.J. Montag,
Montag, Esq.,
Esq., Attorney
Attorney IDID #
# 027351997
027351997
MILBER
MILBER MAKRISMAKRIS PLOUSADIS
PLOUSADIS
&
& SEIDEN,
SEIDEN, LLP LLP
75
75 Livingston Avenue, Suite
Livingston Avenue, Suite 101
101
Roseland,
Roseland, NewNew Jersey
Jersey 07068
07068
(201)
(201) 443-0778
443-0778
Attorneys for
Attorneys for Highland
Highland Loft
Loft Condominium Association, Inc.,
Condominium Association, Inc., on
on the
the Counterclaim
Counterclaim
File No.: 1290-21525
File No.: 1290-21525
HIGHLAND
HIGHLAND LOFTS
LOFTS CONDOMINIUM
SUPERIOR COURT
COURT OF NEW JERSEY
OF NEW JERSEY
ASSOCIATION,
ASSOCIATION, INC.,
INC., LAW
LAW DIVISION:
DIVISION: SPECIAL
SPECIAL CIVIL
CIVIL PART
PART
| ESSEX COUNTY
ESSEX COUNTY
Plaintiff,
Plaintiff,
| DOCKET
DOCKET NO.:
NO.: ESX-DC-014376-21
ESX-DC-014376-21
-against-
-against-
Civil Action
Civil Action
KYLE
KYLE DONOVAN,
DONOVAN,
AMENDED
AMENDED ORDER
ORDER
Defendant.
Defendant.
THIS
THIS MATTER
MATTER having
having come before the
come before the Court upon application
Court upon by Milber
application by Milber Makris
Makris
Plousadis
Plousadis &
& Seiden,
Seiden, LLP,
LLP, as
as attorneys
attorneys for
for Plaintiff
Plaintiff Highland
Highland Lofts
Lofts Condominium Association,
Inc.,
Inc., on
on the
the counterclaim
counterclaim only,
only, and
and the
the Court
Court having
having considered
considered the
the moving papers, and
moving papers, and any papers
any papers
submitted
submitted in
in opposition
opposition thereto
thereto and
and oral
oral argument,
argument, if
if any,
any, and
and good
good cause
cause having been shown:
having been shown:
ITISIS on
IT on this
this 8th
8th day of
day of June
June ,,2022,
2022,
ORDERED
ORDERED that
that the
the instant
instant motion
motion to
to strike
strike Defendant’s
Defendant’s Answer
Answer and
and counterclaim without
counterclaim without
prejudice, as
prejudice, per R.
as per R. 4:23-5,
4:23-5, is
is hereby
hereby granted;
granted; and
and it
it is
is further
further
ORDERED
ORDERED that
that aa copy
copy of
of this
this Order
Order shall be served
shall be upon all
served upon all counsel,
counsel, via
via eCourts.
eCourts.
So
So ORDERED.
ORDERED.
/s/
/s/ Hon.
Hon. Annette
Annette Scoca
___________________________________
Scoca
J.S.C.
J.S.C.
____Opposed
Opposed
X_ Unopposed
____Unopposed
This
This Order
Order hereby
hereby amends
amends the
the Court's
Court's Order
Order dated
dated April
April 11th,
11th, 2022.
2022.
ESX-DC-014376-21
ESX-DC-014376-21
ESX-DC-014376-21 06/08/2022
06/17/2022
06/08/2022 PgPM
12:16:10Pg 2 of
2 of Pg
2 5Trans
2 Trans ID:
of 5 ID: SCP20221450205
Trans
SCP20221450205
ID: SCP20221538791
STARK &
STARK & STARK,
STARK, A
A Professional
Corporation
Mailing Address:
Mailing Address: POPO Box
Box 5315,
5315, Princeton,
Princeton, NJ
NJ 08543-5315
08543-5315
Office Location:
Office Location: 993
993 Lenox
Lenox Drive,
Drive, Lawrenceville,
Lawrenceville, NJ
NJ 08648-2389
08648-2389
(609) 896-9060
(609) 896-9060
Melissa A.
Melissa A. Volet, Esquire -- 03080-2002
Volet, Esquire 03080-2002
HIGHLAND LOFTS
HIGHLAND LOFTS CONDOMINIUM
CONDOMINIUM SUPERIOR COURT
SUPERIOR COURT OF
OF NEW
NEW JERSEY
JERSEY
ASSOCIATION, INC.,
ASSOCIATION, INC,, LAW DIVISION,
LAW DIVISION, SPECIAL
SPECIAL CIVIL
CIVIL PART
PART
ESSEX COUNTY
ESSEX COUNTY
Plaintiff,
Plaintiff, DOCKET NO.
ESX-DC-014376-21
V.
v. CIVIL ACTION
CIVIL ACTION
KYLE DONOVAN,
KYLE DONOVAN, CERTIFICATION
CERTIFICATION
Defendant.
Defendant.
I,I, Donna
Donna Sica,
Sica, certify
certify and
and state
state as
as follows:
follows:
1. Ilam
1. am aa paralegal,
paralegal, and
and an
an employee
employee of
of Stark
Stark &
& Stark,
Stark, P.C.,
P.C., attorneys
attorneys for
for Plaintiff.
Plaintiff.
2. On
2. On December
December 23,
23, 2021,
2021, our
our office
office served
served Interrogatories,
Interrogatories, and
and Requests
Requests for
for
Admissions directed to
Admissions directed to defendant,
defendant, Kyle
Kyle Donovan
Donovan via
via regular
regular first
first class
class mail
mail and
and certified
certified
mail. See
mail. See Exhibit
Exhibit “A”
“A” attached
attached hereto.
hereto.
3. As
3. of today’s
As of today’s date,
date, we
we have
have not
not received
received responses
responses to
to Interrogatories
Interrogatories and
and Requests
Requests for
for
Admissions.
Admissions.
STARK &
STARK & STARK
STARK
A PROFESSIONAL
CORPORATION
TORNEYSAT LAW I| certify
certify that
that the
the foregoing
foregoing statements
statements made
made by
by me
me are
are true.
true. I| am
am aware
aware that
that if
if any
any of
of
A
ATTORNEYS AT LAW
4870-2012-2127,v.v. 1
4870-2012-2127, 1
the foregoing
the foregoing statements
statements made
made by
by me
me are
are wilfully
wilfully false,
false, II am
am subject
subject to
to punishment.
punishment.
Dated: 2/16/22
Dated: 2/16/22 /s/ Donna
Isl Donna Sica
Sica
Donna Sica,
Donna Sica, Paralegal
Paralegal
STARK &
STARK & STARK
STARK
A PROFESSIONAL
CORPORATION
ATTORNEYS AT
ATTORNEYS AT LAW
LAW
-2-
4870-2012-2127,v.v. 1
4870-2012-2127, 1
EXHIBIT
EXHIBIT "A"
"A"
STARK&STARK
ATTORNEYS AT LAW
OFFICE:
OFFICE: 993
993 LENOX
LENOX DRIVE
DRIVE LAWRENCEVILLE,
LAWRENCEVILLE, NJ
NJ 08648-2389
08648-2389
MAILING:
MAILING: PO
PO BOX
BOX 5315
5315 PRINCETON,
PRINCETON, NJ
NJ 08543-5315
08543-5315
609-896-9060
609-896-9060 (PHONE)
(PHONE) 609-896-0629
609-896-0629 (FAX)
(FAX)
WWW.STARK-STARK.COM
WWW STARK-STARK.COM
December
December 23,
23, 2021
2021
VIA REGULAR
VIA REGULAR AND AND CERTIFIED
CERTIFIED MAIL,
MAIL
RETURN
RETURN RECEIPT
RECEIPT REQUESTED
REQUESTED
Kyle
Kyle Donovan,
Donovan, Pro
Pro Se
Se
350
350 Scotland
Scotland Road,
Road, Apt.
Apt. 101
101
Orange, NJ 07050-2382
Orange, NJ 07050-2382
RE:
RE: Highland
Highland Lofts
Lofts Condominium
Association, Inc. v. Kyle
Inc. v. Kyle Donovan
Donovan
Docket
Docket No.
No. ESX-DC-014376-21
ESX-DC-014376-21
(350
(350 Scotland
Scotland Road,
Road, #101,
#101, Orange,
Orange, New
New Jersey
Jersey 07050)
07050)
Dear
Dear Sir/Madam:
Sir/Madam:
Stark
Stark && Stark,
Stark, AA Professional
Professional Corporation,
Corporation, represents
represents Highland
Highland Lofts
Lofts Condominium
Condominium
Association,
Association, Inc., plaintiff in
Inc., plaintiff in the
the above-referenced
above-referenced matter.
matter. Enclosed please find
Enclosed please find Interrogatories
Interrogatories
and
and Requests
Requests for Admissions which
for Admissions which we
we are
are serving upon you
serving upon pursuant to
you pursuant to the
the Rules
Rules of
of the
the Court.
Court.
Be
Be guided
guided accordingly.
accordingly.
Thank you.
Thank you.
Very truly
Very yours,
truly yours,
STARK
STARK & & STARK
STARK
A
A Professional
Corporation
AA Law
Law Firm
Firm Engaged
Engaged in
in Debt
Debt Collection
Collection
By: /s/ Melissa

By:__/s/ Melissa A.
A. Volet
Volet
MELISSA
MELISSA A. A. VOLET,
VOLET, ESQUIRE
ESQUIRE
MAV:tao
MAV:tao
Enclosures
Enclosures
THIS
THIS CORRESPONDENCE
CORRESPONDENCE IS IS FROM
FROM A
A DEBT
DEBT COLLECTOR
COLLECTOR AND
AND THIS
THIS IS
IS AN
AN EFFORT
EFFORT TO
TO COLLECT
COLLECT
AA DEBT.
DEBT. ANY
ANY INFORMATION
INFORMATION OBTAINED
OBTAINED WILL
WILL BE
BE USED
USED FOR
FOR THAT
THAT PURPOSE.
PURPOSE.
NEW JERSEY « PENNSYLVANIA « NEW YORK
Exhibit A
Exhibit A
EXHIBIT A
4841-0983-6166, v. 1
A B C D E F G H I
4 101 Kyle Donovan
Transaction Memo/Description
5 Name Date Num Type Amount Payment Balance
6 October 2020
Check received from Landview Title Agency, LLC - close of unit 101
between Colony Holdings LLC and Kyle Donovan on 10/19/2020
7 101 Kyle Donovan 10/26/2020 1219 Payment 1,932.00 (1,932.00)
8 101 Kyle Donovan 10/26/2020 1275 Invoice respective interest in the Common Elements. 483.00 (483.00)
9 101 Kyle Donovan 10/26/2020 1275 Invoice HOA dues collected from purchaser at close of condo sale 1,449.00 (1,449.00)
10 Total for October 2020 $ 3,864.00 -$ 3,864.00 $ 0.00
11 November 2020
13 Total for November 2020 $ 483.00 - $ 483.00
14 December 2020
17 January 2021
20 February 2021
23 March 2021
25 Total for March 2021 $ 483.00 - $ 483.00
26 April 2021
28 Total for April 2021 $ 483.00 - $ 483.00
29 May 2021
31 Total for May 2021 $ 483.00 - $ 483.00
32 June 2021
34 101 Kyle Donovan 06/15/2021 1445 Invoice Legal Fees - Pending 0.00 -
35 Total for June 2021 $ 483.00 - $ 483.00
36 July 2021

38 101 Kyle Donovan 07/15/2021 1465 Invoice Legal Fees - May 31, 2021 Invoice #2034445 767.00 -
A B C D E F G H I
41 Total for July 2021 $ 1,846.75 - $ 1,846.75
42 Aug-21
44 101 Kyle Donovan 8/15/2021 1486 Invoice Legal Fees - Pending -
45 Total for August 2021 $ 483.00 - $ 483.00
46 Sep-21
50 101 Kyle Donovan 9/15/2021 1505 Invoice Legal Fees - Invoice #2046378 1,084.43 -
51 Total for September 2021 $ 1,873.51 - $ 1,873.51

52 Oct-21
55 Total for October 2021 $ 483.00 - $ 483.00

56
57 Nov-21
61 Total for November 2021 $ 2,053.68 - $ 2,053.68
62
63 Dec-21
67
68 TOTAL $ 11,145.94
69
70
71
72 Jan-22

76
77 Feb-22
A B C D E F G H I

81
82 Mar-22
83 101 Kyle Donovan 3/15/2022 Invoice respective interest in the Common Elements. 483.00 -
84 101 Kyle Donovan 3/15/2022 Invoice Legal Fees - Invoice #02070419 (3/9/22) 590.63
85 Total for March 2022 $ 1,073.63 - $ 1,073.63
86
$13,831.05
Accelerated Maint. Fees 4/22-12/22 4,347.00
Total $18,178.05
EXHIBIT B
4841-0983-6166, v. 1
Highland Lofts Condominium Association Date: July 8, 2021

350 Scotland Road Invoice No.: 2038620
Orange, NJ 07050 Client No.: 067976
Matter No.: 00005
Billing Attorney: MWB
__________________________________________________________________________________________
INVOICE SUMMARY
For professional services rendered and costs advanced through June 30, 2021:
RE: KYLE DONOVAN (350 SCOTLAND ROAD, #101)
Professional Services $ 175.00

Total Costs Advanced $ 8.75
TOTAL THIS INVOICE $ 183.75
Page 1
STARK & STARK, P.C.

Date: July 8, 2021
Invoice No.: 2038620
Client No.: 067976
Matter No.: 00005
PROFESSIONAL SERVICES RENDERED
STANDARD FEES
6/07/21 Collection Letter (Plus Bankruptcy Court Debtor Search) 175.00
Total Standard Fees $ 175.00
TOTAL PROFESSIONAL SERVICES $ 175.00
SUMMARY OF PROFESSIONAL SERVICES
Name Init Hours Rate Total

STANDARD CHARGES STD .00 .00 175.00
TOTALS .00 $ 175.00
COSTS ADVANCED
Description Amount
6/30/21 Fax, Phone, Postage & Admin 8.75
TOTAL COSTS ADVANCED $ 8.75
Page 2
Highland Lofts Condominium Association Date: August 20, 2021

Matter No.: 00005
__________________________________________________________________________________________
INVOICE SUMMARY
For professional services rendered and costs advanced through July 31, 2021:

Unpaid Invoices $ 183.75
TOTAL BALANCE DUE $ 334.95
Page 1
STARK & STARK, P.C.

Date: August 20, 2021
Client No.: 067976
Matter No.: 00005
Date Init Description of Services Rendered Amount

7/26/21 DS Receipt and review of current account ledger; preparation of ADR 144.00
Notice to debtor

DONNA SICA DS .90 160.00 144.00
TOTALS .90 $ 144.00
COSTS ADVANCED
Description Amount
Page 2
STARK & STARK, P.C.

Date: August 20, 2021
Client No.: 067976
Matter No.: 00005
UNPAID INVOICES
INVOICE DATE INVOICE PAYMENTS ENDING

NUMBER TOTAL RECEIVED BALANCE
2038620 7/08/21 183.75 .00 183.75
Balance Due This Invoice $ 151.20
AR AGING
Current - 30 31 - 60 61 - 90 91 - 120 Over 120

$ .00 $ 183.75 $ .00 $ .00 $ .00
Page 3
Highland Lofts Condominium Association Date: September 8, 2021

Matter No.: 00005
__________________________________________________________________________________________
INVOICE SUMMARY
For professional services rendered and costs advanced through August 31, 2021:

TOTAL THIS INVOICE $ 1,084.43
TOTAL BALANCE DUE $ 1,419.38
Page 1
STARK & STARK, P.C.

Date: September 8, 2021
Client No.: 067976
Matter No.: 00005

8/05/21 DS Preparation of Unit Deed Request 64.00
8/05/21 DS Preparation of correspondence to debtor advising a lien will be 48.00
recorded against the unit
8/10/21 DS Use Attorney case notations to update Status Report to include 48.00
purchase price, mortgage information, liens, etc. to provide client with
updated information
8/23/21 DS Receipt of signed lien; preparation of lien cover sheet; e-file lien 64.00
8/30/21 M-V Conducted PACER search to determine whether Defendant(s) filed 94.50
bankruptcy.
8/30/21 M-V Preparation of Money Judgment Complaint 400.00
Total Hourly Professional Fees $ 718.50
STANDARD FEES
8/12/21 Preparation of Assessment Lien Document 200.00
Total Standard Fees $ 200.00

MELISSA A. VOLET M-V 1.70 235.29 400.00
MELISSA A. VOLET M-V .30 315.00 94.50
DONNA SICA DS 1.40 160.00 224.00
STANDARD CHARGES STD .00 .00 200.00
TOTALS 3.40 $ 918.50
COSTS ADVANCED
Description Amount
Page 2
STARK & STARK, P.C.

Client No.: 067976
Matter No.: 00005
Description Amount
8/13/21 ATLANTIC COAST ABSTRACT COMPANY, INC., Search Fee 08/13/2021, 36858, 120.00
Donovan
TOTAL THIS INVOICE $ 1,084.43
Page 3
STARK & STARK, P.C.

Client No.: 067976
Matter No.: 00005
UNPAID INVOICES

2038620 7/08/21 183.75 .00 183.75
2042404 8/20/21 151.20 .00 151.20
Balance Due This Invoice $ 1,084.43
AR AGING
Current - 30 31 - 60 61 - 90 91 - 120 Over 120

$ 151.20 $ .00 $ 183.75 $ .00 $ .00
Page 4
Highland Lofts Condominium Association Date: October 5, 2021

Matter No.: 00005
__________________________________________________________________________________________
INVOICE SUMMARY
For professional services rendered and costs advanced through September 30, 2021:

Unpaid Invoices $ 1,419.38
Page 1
STARK & STARK, P.C.

Date: October 5, 2021
Client No.: 067976
Matter No.: 00005

8/06/21 M-V Receipt and review title search; preparation of notations regarding 126.00
ownership information, purchase price, mortgages liens, judgments and
notices of lis pendens recorded against unit; determine lien priority if
any.
9/08/21 M-V Preparation of Detailed Breakdown of Arrears. 157.50
9/10/21 DS Receipt of recorded lien; preparation of correspondence to debtor 64.00
enclosing copy of lien
9/27/21 DS Preparation of file for litigation 64.00
9/29/21 M-V Receipt and review notice from court advising that Summons was 126.00
mailed to Defendant(s), and setting default date; calendar default date;
conference with paralegal to advise of case status for client's monthly
report.

DONNA SICA DS .80 160.00 128.00
TOTALS 2.10 $ 537.50
COSTS ADVANCED
Description Amount
9/13/21 CSC, Client Disbursements (Misc.), 9/13/2021, 43269041102709092021 58.50
Page 2
STARK & STARK, P.C.

Date: October 5, 2021
Client No.: 067976
Matter No.: 00005
UNPAID INVOICES

2038620 7/08/21 183.75 .00 183.75
2042404 8/20/21 151.20 .00 151.20
2046378 9/08/21 1,084.43 .00 1,084.43
AR AGING
Current - 30 31 - 60 61 - 90 91 - 120 Over 120

$ 1,084.43 $ 151.20 $ 183.75 $ .00 $ .00
Page 3
Highland Lofts Condominium Association Date: November 3, 2021

Matter No.: 00005
__________________________________________________________________________________________
INVOICE SUMMARY
For professional services rendered and costs advanced through October 31, 2021:

Page 1
STARK & STARK, P.C.

Date: November 3, 2021
Client No.: 067976
Matter No.: 00005

10/28/21 M-V Conducted PACER search to determine whether Defendant(s) filed 94.50
bankruptcy.
10/28/21 M-V Conducted non-military search; preparation of Affidavit of Non-Military 126.00
Service.
10/28/21 M-V Preparation of Certification of Proof. 189.00
10/28/21 M-V Preparation of Final Judgment Package 450.00

TOTALS 2.80 $ 859.50
COSTS ADVANCED
Description Amount
10/22/21 FILING FEE 82.00
Page 2
STARK & STARK, P.C.

Date: November 3, 2021
Client No.: 067976
Matter No.: 00005
UNPAID INVOICES

2038620 7/08/21 183.75 .00 183.75
2042404 8/20/21 151.20 .00 151.20
2046378 9/08/21 1,084.43 .00 1,084.43
2050253 10/05/21 622.88 .00 622.88
AR AGING
Current - 30 31 - 60 61 - 90 91 - 120 Over 120

$ 622.88 $ 1,084.43 $ 151.20 $ 183.75 $ .00
Page 3
Highland Lofts Condominium Association Date: December 2, 2021

Matter No.: 00005
__________________________________________________________________________________________
INVOICE SUMMARY
For professional services rendered and costs advanced through November 30, 2021:

Page 1
STARK & STARK, P.C.

Date: December 2, 2021
Client No.: 067976
Matter No.: 00005

11/03/21 M-V Preparation of Detailed Breakdown of Arrears. 126.00
11/22/21 M-V Receipt and review Answer and Counterclaim filed by Debtor; 126.00
preparation of correspondence to Association regarding same.

MELISSA A. VOLET M-V .80 315.00 252.00
TOTALS .80 $ 252.00
COSTS ADVANCED
Description Amount
Page 2
STARK & STARK, P.C.

Date: December 2, 2021
Client No.: 067976
Matter No.: 00005
UNPAID INVOICES

2038620 7/08/21 183.75 .00 183.75
2042404 8/20/21 151.20 .00 151.20
2046378 9/08/21 1,084.43 .00 1,084.43
2050253 10/05/21 622.88 .00 622.88
2054323 11/03/21 947.80 .00 947.80
AR AGING
Current - 30 31 - 60 61 - 90 91 - 120 Over 120

$ 947.80 $ 622.88 $ 1,084.43 $ 151.20 $ 183.75
Page 3
Highland Lofts Condominium Association Date: January 11, 2022

Matter No.: 00005
__________________________________________________________________________________________
INVOICE SUMMARY
For professional services rendered and costs advanced through December 31, 2021:

Page 1
STARK & STARK, P.C.

Date: January 11, 2022
Client No.: 067976
Matter No.: 00005

12/03/21 M-V Preparation of Interrogatories; preparation of Statement of Admissions; 378.00
preparation of correspondence to Debtor serving discovery demands.
12/21/21 DS [No Charge] Search of E-Courts to determine which case debtor has N/C
filed an Answer and Counterclaim in; review of both files

TOTALS 1.20 $ 378.00
COSTS ADVANCED
Description Amount
Page 2
Highland Lofts Condominium Association Date: March 9, 2022

Matter No.: 00005
__________________________________________________________________________________________
INVOICE SUMMARY
For professional services rendered and costs advanced through February 28, 2022:

Page 1
STARK & STARK, P.C.

Date: March 9, 2022
Client No.: 067976
Matter No.: 00005

2/15/22 M-V Convert Judgment Package into Summary Judgment Motion; 480.00
preparation of Legal Brief; preparation of Statement of Material Facts;
preparation of updated Breakdown of Arrears to be included in
Certification of Proof and proposed Order for Judgment.
2/15/22 DS [No Charge] Receipt and review of e-mail correspondence from N/C
Insurance Counsel requesting any communication with debtor;
preparation of e-mail correspondence to Insurance Counsel regarding
same
2/16/22 DS Preparation of Certification of Failure to Respond to Discovery 82.50

DONNA SICA DS .50 165.00 82.50
TOTALS 2.00 $ 562.50
COSTS ADVANCED
Description Amount
Page 2
STARK & STARK, P.C.

Date: March 9, 2022
Client No.: 067976
Matter No.: 00005
UNPAID INVOICES

2062522 1/11/22 396.90 .00 396.90
AR AGING
Current - 30 31 - 60 61 - 90 91 - 120 Over 120

$ .00 $ 396.90 $ .00 $ .00 $ .00
Page 3
Time Report Unbilled
HIGHLAND LOFTS CONDOMINIUM ASSOCIATION / DONOVAN, KYLE (350 SCOTLAND ROAD, #101) (067976-00005) 03/25/2022
Date SM/Task Attorney Name Staff Level Description Rate Orig Hrs Orig Amt Orig Rate Rev Hrs Rev Amt Rev Rate Service Activity Invoice Status
03/23/2022 3470 DONNA SICA 300 Paralegal 1 0.50 82.50 165.00 0.50 82.50 165.00 10000 0 Unbilled
Update breakdown of arrears
Report Totals: 0.50 82.50 0.50 82.50

Confidential - For Internal Purposes Only. Page 1

Cost Report Unbilled
03/25/2022
Date SM/Task Service Code Description Attorney Orig Qty Orig Amt Rev Qty Rev Amt Vendor Voucher Check No. Check Date Check Status Invoice Status
Report Totals: 0.00 0.00 0.00 0.00


Bill and Payment Report Last Payment (12/14/2021): 3,297.64
Invoice Client Matter Matter Description Type Date Time Cost Total Balance Status Check No. Check Date Payor
2038620 067976 00005 DONOVAN, KYLE (350 Invoice 07/08/2021 175.00 8.75 183.75 183.75 Paid
SCOTLAND ROAD, #101)
2042404 067976 00005 DONOVAN, KYLE (350 Invoice 08/20/2021 144.00 7.20 151.20 334.95 Paid
2046378 067976 00005 DONOVAN, KYLE (350 Invoice 09/08/2021 918.50 165.93 1,084.43 1,419.38 Paid
2050253 067976 00005 DONOVAN, KYLE (350 Invoice 10/05/2021 537.50 85.38 622.88 2,042.26 Paid
2062522 067976 00005 DONOVAN, KYLE (350 Invoice 01/11/2022 378.00 18.90 396.90 3,694.54 Open
2070419 067976 00005 DONOVAN, KYLE (350 Invoice 03/09/2022 562.50 28.13 590.63 4,285.17 Open
Report Totals: 3,827.00 458.17 4,285.17


Invoice Inquiry Report Last Payment (12/14/2021): 3,297.64
Invoice Client Client Name Matter Matter Description Type Date Time Cost Total Balance Status Check No. Check Date
2038620 067976 HIGHLAND LOFTS 00005 DONOVAN, KYLE (350 SCOTLAND ROAD, #101) Invoice 07/08/2021 175.00 8.75 183.75 183.75 Paid
CONDOMINIUM ASSOCIATION
2038620 067976 HIGHLAND LOFTS 00005 DONOVAN, KYLE (350 SCOTLAND ROAD, #101) Payment 12/14/2021 -175.00 -8.75 -183.75 0.00 995143 12/13/2021
2046378 067976 HIGHLAND LOFTS 00005 DONOVAN, KYLE (350 SCOTLAND ROAD, #101) Invoice 09/08/2021 918.50 165.93 1,084.43 1,084.43 Paid
2046378 067976 HIGHLAND LOFTS 00005 DONOVAN, KYLE (350 SCOTLAND ROAD, #101) Payment 12/14/2021 -918.50 -165.93 -1,084.43 0.00 995143 12/13/2021
2062522 067976 HIGHLAND LOFTS 00005 DONOVAN, KYLE (350 SCOTLAND ROAD, #101) Invoice 01/11/2022 378.00 18.90 396.90 396.90 Open
2070419 067976 HIGHLAND LOFTS 00005 DONOVAN, KYLE (350 SCOTLAND ROAD, #101) Invoice 03/09/2022 562.50 28.13 590.63 987.53 Open
Report Totals: 940.50 47.03 987.53


Invoice Summary Report
Client Matter Invoice Date Last Payment Age Total Billed Total Receipts Total Adj Total LC Time Balance Cost Balance LC Balance Total Balance
067976 00005 2038620 07/08/2021 12/14/2021 183.75 183.75 0.00 0.00 0.00 0.00 0.00 0.00
067976 00005 2042404 08/20/2021 12/14/2021 151.20 151.20 0.00 0.00 0.00 0.00 0.00 0.00
067976 00005 2046378 09/08/2021 12/14/2021 1,084.43 1,084.43 0.00 0.00 0.00 0.00 0.00 0.00
067976 00005 2050253 10/05/2021 12/14/2021 622.88 622.88 0.00 0.00 0.00 0.00 0.00 0.00
067976 00005 2054323 11/03/2021 12/14/2021 947.80 947.80 0.00 0.00 0.00 0.00 0.00 0.00
067976 00005 2058404 12/02/2021 12/14/2021 307.58 307.58 0.00 0.00 0.00 0.00 0.00 0.00
067976 00005 2062522 01/11/2022 73 396.90 0.00 0.00 0.00 378.00 18.90 0.00 396.90
067976 00005 2070419 03/09/2022 16 590.63 0.00 0.00 0.00 562.50 28.13 0.00 590.63
Report Totals: 4,285.17 3,297.64 0.00 0.00 940.50 47.03 0.00 987.53

EXHIBIT C
4841-0983-6166, v. 1

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VIA EMAIL jallen04@yahoo.com ONLY
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Re: Highland Lofts Condominium Association, Inc.

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4847-4031-1764, v. 1

Motion To Enter Default

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Motion To Enter Default

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ESX-DC-014376-21 06/17/2022 12:16:10 PM Pg 1 of 4 Trans ID: SCP20221538791

OFFICE: 993 LENOX DRIVE LAWRENCEVILLE, NJ 08648-2389

Re: Highland Lofts Condominium Association, Inc. v. Kyle Donovan

1. Notice of Motion for Entry of Default 6. Affidavit of Non-Military Service;

Thank you for your appreciated cooperation.

Very truly yours,

STARK & STARK

By: /s/ Melissa A. Volet

STARK & STARK, A Professional Corporation

HIGHLAND LOFTS CONDOMINIUM SUPERIOR COURT OF NEW JERSEY

TO: KYLE DONOVAN, PRO SE

DAVID J. MONTAG, ESQ.

Judgment against the Defendant named herein.

STARK & STARK

presented and deemed admissible by the Court.

NOTICE. IF YOU WANT TO RESPOND TO THIS MOTION,

disputed and why a decision should not be entered against you.

No oral argument is requested.

STARK & STARK

STARK & STARK

By: /s/ Melissa A. Volet

Dated: June 17, 2022

STARK & STARK

STARK & STARK, A Professional Corporation

HIGHLAND LOFTS CONDOMINIUM SUPERIOR COURT OF NEW JERSEY

I, MELISSA A. VOLET, ESQUIRE, hereby certify:

as set forth herein.

proceeding against the Defendant, Kyle Donovan (the “Debtor”).

3. The Association is a non-profit corporation responsible for administration,

maintenance and operation of the common elements within the Association.

4. As Unit owner, in accordance with the Association’s Master Deed, paragraph 5,

the Lyle Certification as Exhibit “B.”)

5. Despite demand, the Debtor failed to make common expense maintenance

the Master Deed or By-Laws.” N.J.S.A. 46:8B-15(e) (emphasis added).

attached hereto as Exhibit “B.”)

I. RPC 1.5(A) FACTORS:

Time and Labor Required, Novelty/Difficulty of Issues and

10. The Association is burdened by a number of delinquent homeowners. The

such incentive cannot sufficiently do this.

faced by the Association.

help to the Association through the years.

lowest possible charges.

of same including this matter.

competent, efficient and able to obtain favorable results.

Acceptance of this Case will Preclude other Employment

precludes Stark & Stark from accepting other legal employment.

Our Fees are Customarily Charged in the Industry in this Location

Community Association Law industry in this locality.

23. In addition, the attorneys in our Community Associations Department are in

The Amount of Time Spent on this File is Reasonable and Similar to

amount of time working on this file.

The Amount Involved and Results Obtained

25. The principal amount owed, less attorneys’ fees, is $12,558.00.

maintenance fees are vital to the functioning of the Association.

Time Limitations Imposed by the Client or the Circumstances

The Nature and Length of Professional Relationship with Client

collection and general governance matters.

The Experience, Reputation and Ability of Lawyer

(i) In 2009 at $250.00 per hour;

firm’s Community Associations Group. He is an attorney admitted to practice in the State of

(v) In 2013 at $320.00 per hour;

Paralegal Qualifications, and Rates

time at the following rates each year:

IT is ORDERED on this _ day of ________, 2022,