1. Second Major Motion in a Foreclosure Action – More procedurally oriented than motion for summary judgment. Some overlap. But showing court that technical aspects of foreclosure are met: notices, forms, deadlines, computations, service etc. The resulting Judgment of Foreclosure and Sale allows the plaintiff to schedule and proceed to a foreclosure sale date.
2. Opposition Involves Defenses Not Previously Raised or Raised in Same Manner – Standing defense (can’t be waived); service of process (jurisdictional); dispute of computations and asking for referee hearing (where numbers are newly calculated but in dispute) or asking for a new referee report (where the numbers are old due to delays in the foreclosure proceeding); new possible remedial options (asking for new conferences.