Harbor Front Development, LLC v. Clear Skies Title Agency

New Jersey Superior Court Appellate Division·Decided July 13, 2026·No. A-2025-23·Unpublished

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION

DOCKET NO. A-2025-23

HARBOR FRONT DEVELOPMENT, LLC,

Plaintiff-Respondent,

v. CLEAR SKIES TITLE AGENCY, Defendant-Respondent,

and

RYAN M. MULHOLLAND and KEVIN J. MULHOLLAND,

Defendants/Third-Party

Plaintiffs-Appellants,

v. EYAL SHAY,

Third-Party Defendant-

Respondent,

and HARBORFRONT VILLAS

HOMEOWNERS' ASSOCIATION,

Third-Party Defendant.

Argued January 28, 2026 – Decided July 13, 2026 Before Judges Gummer, Paganelli, and Jacobs.

On appeal from the Superior Court of New Jersey, Chancery Division, Union County, Docket No.

C-000006-23.

Keith N. Biebelberg argued the cause for appellants (Biebelberg & Martin, attorneys; Keith N. Biebelberg and Avrin Slatkin, on the briefs).

Gregory J. Skiff argued the cause for respondents Harbor Front Development, LLC and Eyal Shay (A.Y.

Strauss LLC, attorneys; Gregory J. Skiff, on the brief).

PER CURIAM In this townhome-purchase dispute, defendants Ryan M. Mulholland and Kevin J. Mulholland appeal from orders denying their summary-judgment motion, granting the summary-judgment cross-motion of plaintiff Harbor Front Development, LLC (Harbor Front), and denying their reconsideration motion. 1

1 Defendant Ryan M. Mulholland is the son of Nanci Mulholland and defendant Kevin J. Mulholland. Because of their common last name, we use their first names to reference them. Because defendant Clear Skies Title Agency (Clear Skies) did not participate in this appeal, we refer to Ryan and Kevin collectively as "defendants."

A-2025-23

In those orders, the trial court declared the closing was null and void and rescinded the recorded deed, and it held plaintiff had validly terminated the parties' purchase agreement and awarded plaintiff liquidated damages. We affirm the provisions in the orders declaring the closing null and void and rescinding the deed. Because of the existence of genuine issues of material fact, we reverse the provisions in the orders declaring valid the termination of the purchase agreement and awarding liquidated damages. We affirm in part and reverse in part the reconsideration order and remand for proceedings consistent with this opinion.

I.

Harbor Front is a real-estate developer and was the seller of the townhouse at issue in this litigation. Ryan and Nanci signed, as buyers, a May 1, 2021 agreement to purchase a to-be-built townhouse from Harbor Front for $550,000. Eyal Shay signed the agreement on behalf of Harbor Front. The estimated closing date was July 15, 2021.

Paragraph two of the purchase agreement, which was entitled "CLOSING OF TITLE," provided in part:

Seller will provide Buyer with at least ten (10) days written notice of the closing date. When so scheduled, the date and time of closing shall be "OF THE ESSENCE." This means that failure by Buyer to close

A-2025-23

at the time specified shall be considered a breach and default of this Agreement. If Buyer is unable to or refuses to close on the date and time specified by Seller, at Seller's option, Seller may exercise its rights set forth in Paragraph 16 of this Agreement or have Buyer reimburse Seller at or before closing for Seller's total reasonable carrying and administrative costs for postponing the closing to another time, date or place specified by Seller. Buyer agrees that Seller may cancel any Time of the Essence closing without penalty. Seller reserves the right, at its sole option, to conduct closing (i.e., transfer of title) by mail or electronically. Buyer will pay the balance of the Purchase Price due at closing of title by wire transfer.

Paragraph sixteen of the purchase agreement, entitled "DEFAULT OF BUYER; LIQUIDATED DAMAGES," provided:

If Buyer fails to make payments, violates any of the conditions or covenants or fails, for any reason, to complete the purchase in accordance with this Agreement, or if Buyer shall be declared bankrupt or insolvent or shall make an assignment for the benefit of any creditors, or shall be placed under the control or under the custody of any court, or otherwise breaches this Agreement, Buyer will be in default. If Buyer is in default, this Agreement at the option of Seller, may be terminated, and all deposits made by Buyer in an amount equal to ten percent (10%) of the total purchase price, plus the contract price of any payments for options and extras, shall be retained by Seller as liquidated damages. Liquidated damages are a fixed amount to be paid to Seller which the parties agree will be a reasonable estimate of the damages in the event of Buyer's default, since Seller's actual damages would be difficult to establish. If the deposit monies are less than that liquidated sum and Buyer fails to pay the additional

A-2025-23

sums after demand, then Seller may institute legal proceedings to recover the remaining amount due. If Seller elects to retain money as liquidated damages, this Agreement shall be of no further effect in which event Seller agrees to return to Buyer all excess money above the described sum previously paid by Buyer, if any. No delay or forbearance by Seller in exercising any right or remedy hereunder shall be deemed to be a waiver thereof[.]

Harbor Front delayed the estimated closing date multiple times. A November 28, 2022 addendum to the purchase agreement removed Nanci from the contract and added Kevin as an additional buyer. An undated addendum set $558,000 as the purchase price, indicated Harbor Front would provide defendants with an "$8,000 credit for closing costs and prepaid expense[s,]" and stated the closing would "take place in or before December 20, 2022." The addendum provided that "[i]n all other respects the [c]ontract shall remain in effect as is."

The trial court found "a question of fact exists as to the date upon which [p]laintiff provided [defendants] with written notice of the December 20, 2022 [c]losing." Defendants' counsel certified he and Harbor Front's counsel, "[a]fter all the[] delays by [Harbor Front]," had scheduled the closing for December 20, 2022, but did not say when they agreed to the December 20 closing date.

A-2025-23

According to defendants' counsel, Shay signed the addendum on behalf of Harbor Front on December 19, 2022.

Clear Skies acted as the closing escrow agent for both parties. In a November 28, 2022 "Escrow Closing Letter," Harbor Front's counsel provided Clear Skies with Harbor Front's closing documents to be held in escrow. He instructed that Clear Skies could not release the documents from escrow until certain conditions were met, including receipt of "written confirmation by email" from Harbor Front or its legal representative authorizing Clear Skies "to close the transaction and release [Harbor Front's c]losing [d]ocuments from escrow." Shay forwarded those documents in a November 30, 2022 email to a Clear Skies representative, copying defendants' counsel and a representative of defendants' lender, Paramount Residential Mortgage Group, Inc. (PRMG), on the email.

On the December 20, 2022 closing date, Ryan appeared at Clear Skies's office. Emails between the parties that day indicate they continued to negotiate certain aspects of the transaction. For example, in emails exchanged at 1:39 p.m. and 2:28 p.m., the parties confirmed defendants had accepted Harbor Front's offer to waive the first two years of "common charges." At some point that day, PRMG submitted a proposed "[b]uydown [a]greement" for Harbor

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