On March 27, 2019, in a case handled by PIB, New Jersey’s Appellate Division affirmed a trial court decision denying the defendant’s eleventh-hour motion to vacate a sheriff’s sale and restrain delivery of the deed to a third-party purchaser predicated on a novel – but incorrect – theory that a reinstatement quote constituted a binding contract.  The decision is significant because, had Defendant’s argument been successful, it could have created the threat of potential litigation based solely upon routine communications between servicers and borrowers.