On XX/XX/XXXX XXXX XXXX obtained a mortgage for the property located at XXXX XXXX XXXX XXXX New Jersey XXXX with XXXX as the servicer. On XX/XX/XXXX XXXX XXXX XXXX joined as tenant owner of XXXX XXXX XXXX XXXX New Jersey and a new deed was recorded and filed. On XX/XX/XXXX the loan was transferred to Shell Point Mortgage Servicing. 
On XX/XX/XXXX XXXX XXXX made a private payment to Shell Point Mortgage. Shortly thereafter the loan was satisfied and a lien release letter was sent to XXXX County Superior Court of New Jersey to vacate the mortgage and the mortgage was discharged on XX/XX/XXXX. 
On XX/XX/XXXX XXXX XXXX and XXXX XXXX were served with a complaint from XXXX. and XXXX XXXX XXXX. on behalf of XXXX XXXX representing XXXX XXXX who is a third party debt collector and not a mortgage servicer. XXXX XXXX XXXX is a collection agency who buys portfolios of old debt from banks for pennies on the dollar and tries to collect the full amount from consumers, plus interest, penalties, late fees, etc. According to XXXX it is a manager and services domestic and international consumer debt portfolios for credit grantors and debt buyers. 
This complaint contained erroneous information. XXXX XXXX XXXX is a violator of the Federal Debt Collection laws as the Fair Debt Collection Practices Act ( FDCPA ) states it precludes third party debt collectors from using false, misleading, deceptive, and harassing debt collection tactics. To Resurgent, XXXX XXXX XXXX is data, no more than an entry on the spreadsheet. Unfortunately for XXXX XXXX XXXX entries on a spreadsheet are not enough to file a claim against XXXX XXXX XXXX and XXXX XXXX XXXX. 
This complaint stated that XXXX XXXX failed to pay XXXX XXXX but XXXX XXXX has never done business with Resurgent Capital. The complaint also states mortgage was transferred from Shellpoint to XXXX to service this loan. Again this information is false and XXXX XXXX has evidence that this loan was never serviced or transferred to XXXX XXXX. Resurgent Capital is not and has never been assigned to service the mortgage of XXXX XXXX XXXX XXXX New Jersey. The complaint also states XXXX XXXX never made any mortgage payments prior to paying the mortgage in full and XXXX XXXX request the original mortgage amount be reinstated and did not take in account any and all payments that were made by XXXX XXXX XXXX. Again this information is false. 
XXXX XXXX must meet the burden of proof based on " Personal Knowledge ''. Personal knowledge means that the person offering evidence on behalf of XXXX XXXX XXXX must be a witness to the event shown in the complaint. 
On XX/XX/XXXX the motion submitted by XXXX XXXX asking the Judge for a summary judgment to cancel the vacate of lien release for property XXXX XXXX XXXX XXXX NJ XXXX for XXXX XXXX and XXXX XXXX, was dismissed by Judge XXXX pursuant to Rule 1:6-6 ( Counsel does not have personal knowledge of these facts which were in the complaint and the certification was not sufficient ). 
This complaint was written in fraud and the attorneys were aware of this. As attorneys representing XXXX XXXX, they had a duty to investigate the claims brought forth in this complaint. Once they were aware of the fraud perpetrated by XXXX the attorneys had an obligation to withdraw this complaint and they failed to withdraw. 
These attorneys made statements such as, " XXXX failed to make payments on the mortgage loan but rather submit counterfeit money order to Shellpoint ''. The statement is false. These attorneys also make mention of XXXX being in the XXXX XXXX,