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Joy Harmon Sperling and Sarah Sakson Langstedt wrote an article, “New Jersey Appellate Division Holds Bank Has Standing to Foreclose Even If Allonge to Note Was Not Affixed When Executed,” for Pratt’s Journal of Bankruptcy Law. The article analyzes the significance of the New Jersey Appellate Division’s recent decision in U.S. Bank National Association v. Morris Bayonne Associates I, LLC. In that case, the court ruled that the plaintiff in a foreclosure action had established a prima facie case for foreclosure even though the allonge to the note was not physically attached when the allonge was executed.
