MER-DC-001590-20 03/18/2020 10:37:13 AM Pg 1 of 5 Trans ID: SCP2020665520
`
`HILL WALLACK LLP
`Terry A. Kessler, Esq.
`N.J. Attorney ID No.: 026381985
`21 Roszel Road
`P. O. Box 5226
`Princeton, NJ 08540
`(609) 924-0808
`Attorneys for Plaintiff: Colonnade Pointe
`Condominium Association,Inc.
`COLONNADE POINTE CONDOMINIUM~—: SUPERIOR COURT OF NEW JERSEY
`ASSOCIATION,INC.,
`LAW DIVISION: SPECIAL CIVIL PART
`i MERCER COUNTY
`
`Plaintiff
`
`VS.
`
`DOCKET NO.: DC-
`
`Civil Action
`
`APARNA JAISWALand PRABISH
`CHAURASIA,
`
`| COMPLAINT
`
`Defendant
`
`COLONNADE POINTE CONDOMINIUM ASSOCIATION,INC., a New Jersey non-
`
`profit corporation, by way of Complaint against defendant, says:
`
`1.
`
`Colonnade Pointe Condominium Association,
`
`Inc.
`
`(the “Association”)
`
`is a
`
`condominium association established pursuant to the New Jersey Condominium Act, N.J.S.A
`
`46:8B-1 et seq. and by a certain Master Deed and Declaration of Restrictive and Protective
`
`Covenants, Easements, Charges and Liens recorded in the Office of the Mercer County Clerk’s
`
`Office in Deed Book 2414, Page 369 on September 30, 1987.
`
`2. Defendants, Aparna Jaiswal and Prabish Chaurasia, are the owners ofa unit locatedat |.
`
`107 Lassen Court, #7, Princeton, Mercer County, New Jersey, 08540 within the aforesaid
`
`condominium by deed recorded on October 21, 2016 in the Office of the Mercer County Clerk in
`
`Deed Book 6265 at Page 1817.
`
`{F:/WDOX/DOCS/010030/004 19/06471286; 1} {F:/;WDOX/DOCS/010030/00438/03265395; 1
`
`MER-DC-001590-20 03/18/2020 10:37:13 AM Pg 1 of 5 Trans ID: SCP2020665520
`
`
`
`HILL WALLACK LLP
`Terry A. Kessler, Esq.
`N.J. Attorney ID No.: 026381985
`21 Roszel Road
`P. O. Box 5226
`Princeton, NJ 08540
`(609) 924-0808
`Attorneys for Plaintiff: Colonnade Pointe
`Condominium Association,Inc.
`COLONNADE POINTE CONDOMINIUM~—: SUPERIOR COURT OF NEW JERSEY
`ASSOCIATION,INC.,
`LAW DIVISION: SPECIAL CIVIL PART
`i MERCER COUNTY
`
`Plaintiff
`
`VS.
`
`DOCKET NO.: DC-
`
`Civil Action
`
`APARNA JAISWALand PRABISH
`CHAURASIA,
`
`| COMPLAINT
`
`Defendant
`
`COLONNADE POINTE CONDOMINIUM ASSOCIATION,INC., a New Jersey non-
`
`profit corporation, by way of Complaint against defendant, says:
`
`1.
`
`Colonnade Pointe Condominium Association,
`
`Inc.
`
`(the “Association”)
`
`is a
`
`condominium association established pursuant to the New Jersey Condominium Act, N.J.S.A
`
`46:8B-1 et seq. and by a certain Master Deed and Declaration of Restrictive and Protective
`
`Covenants, Easements, Charges and Liens recorded in the Office of the Mercer County Clerk’s
`
`Office in Deed Book 2414, Page 369 on September 30, 1987.
`
`2. Defendants, Aparna Jaiswal and Prabish Chaurasia, are the owners ofa unit locatedat |.
`
`107 Lassen Court, #7, Princeton, Mercer County, New Jersey, 08540 within the aforesaid
`
`condominium by deed recorded on October 21, 2016 in the Office of the Mercer County Clerk in
`
`Deed Book 6265 at Page 1817.
`
`{F:/WDOX/DOCS/010030/004 19/06471286; 1} {F:/;WDOX/DOCS/010030/00438/03265395; 1
`
`MER-DC-001590-20 03/18/2020 10:37:13 AM Pg 1 of 5 Trans ID: SCP2020665520
`
`
`
`MER-DC-001590-20 03/18/2020 10:37:13 AM Pg 2 of 5 Trans ID: SCP2020665520
`
`3.
`
`In accordance with the Condominium Act and Section 5 of the Association’s Master
`
`Deed, each Unit Owner shall be required to pay his proportionate share of the expenses of
`
`maintenance, repair, replacement, administration and operation of the Common Elements. The
`
`Association shall have a lien on each Unit for unpaid Common Expensesassessed against such
`
`Unit by the Association.
`
`4.
`
`In accordance with Article VI, Section 3(c), of the Association’s By-Laws, no
`
`abandonmentof the Unit or a waiver of the use and enjoyment of any of the Common Elements
`
`shall exempt or excuse any memberfrom his contribution toward the expenses.
`
`5.
`
`Further, Article VI, Section 5(b), of the Association’s By-Laws, allows the
`
`Association’s Board of Trustees to accelerate the remaining installments of the Assessment for
`
`such year andfile a lien for such accelerated amount if a Unit Ownerfails to pay, within the five-
`
`day grace period, an installment of a Common Expense Assessment. This firm sent notice, via
`
`certified and regular mail, to the defendant that his assessments were about to be accelerated if
`
`he did not bring the account current within 10 days.
`
`6.
`
`Pursuant
`
`to Article VI, Section 5({c), of the Association’s By-Laws,
`
`the
`
`Association is entitled to reasonable attorneys’
`
`fees, costs, and interest
`
`in this matter.
`
`Additionally, Section 5(c) allowsfor a late fee to be levied against the delinquent Unit Owner.
`
`7.
`
`Pursuant to Section 6 of the Master Deed and Article VI, Section 12 and Article
`
`X, Section 2 of the By-Laws the Association has the power to adopt and publish rules and
`
`regulations including the right to levy fines for violation in an amount not to exceed $50 for a
`
`single violation and said fines may be collected in the same manneras delinquent assessments.
`
`MER-DC-001590-20 03/18/2020 10:37:13 AM Pg 2 of 5 Trans ID: SCP2020665520
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`
`
`MER-DC-001590-20 03/18/2020 10:37:13 AM Pg 3 of 5 Trans ID: SCP2020665520
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`8.
`
`Pursuant to Section 12 of the Master Deed, the buildings containing garden home
`
`units have one water meter per building and each unitis to be billed its pro- rata share.
`
`9,
`
`The defendant
`
`is currently indebted to the Association in the amount. of
`
`$3,983.25 (see Schedule A attached hereto), but not in an amount exceeding $15,000.00 on
`
`account of assessments for common expenses, water charges, late fees, attorneys’ fees and costs,
`
`payment for which has been demanded and has not been made. The Association reserves the
`
`right to prove additional amounts accruingto the dateoftrial.
`
`WHEREFORE,the Association demands judgment in the current amount of $3,983.25
`
`but subject to the Association’s right to demand an increased amount not exceeding $15,000.00,
`
`including attorney’s fees and costs of suit.
`
`HILL WALLACK LLP
`
`Dated: March Ilo. 2020
`
`THIS SPACE INTENTIONALLY LEFT BLANK.
`
`MER-DC-001590-20 03/18/2020 10:37:13 AM Pg 3 of 5 Trans ID: SCP2020665520
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`
`
`MER-DC-001590-20 03/18/2020 10:37:13 AM Pg 4 of 5 Trans ID: SCP2020665520
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`R 4:5-1 CERTIFICATION
`
`Pursuant to R.4:5-1, it is hereby stated that the matter in controversy is not the subject of
`
`any other action pending in any other court or of a pending arbitration proceeding to the best of
`
`our knowledge and belief. Also,
`
`to the best of our belief, no other action or arbitration
`
`proceeding is contemplated. Further, other than the parties set forth in this pleading, we know of
`
`no other parties that should be joined in the within action at the present time.
`
`HILL WALLACK LLP
`Attorneys-far Colonnade Painte
`
`Dated: March Ne 2020
`
`R. 1:38-7(b) CERTIFICATION
`
`I hereby certify that confidential personal identifiers have been redacted from documents
`
`now submitted to the court and will be redacted from all documents submitted in the future in
`
`accordance with R. 1:38-7(b).
`
`HILL WALLACK LLP By:
`
`
`
`ERRY A. KESSLER, ESQ.
`
`
`
`Dated: Marchlp, 2020
`
`MER-DC-001590-20 03/18/2020 10:37:13 AM Pg 4 of 5 Trans ID: SCP2020665520
`
`
`
`MER-DC-001590-20 03/18/2020 10:37:13 AM Pg 5 of 5 Trans ID: SCP2020665520
`
`SCHEDULE A
`
`STATEMENT OF ACCOUNT
`
`ASSOCIATION:
`DATE:
`
`COLONNADEPOINTE CONDOMINIUM ASSOCIATION,INC.
`MARCH ]bv
`, 2020
`
`1.
`
`2.
`
`3.
`
`4.
`
`Unit or Lot No and Block No. : Lot: 307.23, Block 7 Qualifier c2007
`
`Name of Owner: Aparna Jaiswal and Prabish Chaurasia
`
`Address: 107 Lassen Court #7, Princeton, New Jersey 08540
`
`(a)
`
`(b)
`
`(c)
`
`(d)
`
`(e)
`
`(f)
`
`Amount of Arrearages (unaccelerated maintenance):
`
`Accelerated Amount:
`
`Water/Sewer:
`
`Late Charges:
`
`Snow Assessments:
`
`Counsel Fee Accumulated to Date:
`
`TOTAL AMOUNTDUE:
`
`$2,174.00
`
`$ N/A
`
`$ 408.00
`
`$ 200.00
`
`$ N/A
`
`$ 1,201.25
`
`$3,983.25
`
`
`
`MER-DC-001590-20 03/18/2020 10:37:13 AM Pg 5 of 5 Trans ID: SCP2020665520
`
`
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