A Absolute Escrow Settlement Co., Inc., a small Millburn, New Jersey escrow firm, has appeared in two notable federal lawsuits in the District of New Jersey: a 2018 fraud case it filed against Wells Fargo Bank that settled in 2019, and a 2024 putative class action in which it was named as a defendant over alleged kickbacks and inflated closing fees. In the second case, the court dismissed the central federal claim in July 2025 but gave the plaintiff a chance to refile.
Who the Company Is
A Absolute is a New Jersey real estate escrow agent based at 55 Essex Street in Millburn. It was incorporated in 2009 and operates as a small business with an estimated two employees and roughly $145,000 in annual revenue.1Manta. A Absolute Escrow Settlement Business directory filings list Jeffrey M. Bockman as a principal, but court records from related litigation identify Peter A. Uzzolino as the company’s owner and connect A Absolute to a group of affiliated title and settlement companies he controls.2Carlton Fields. Lannin v. NRT Title Agency, LLC
The 2018 Fraud Suit Against Wells Fargo
On May 7, 2018, A Absolute filed suit in the U.S. District Court for the District of New Jersey against Wells Fargo Bank, N.A., NMS Capital Realty Advisors, LLC, Trevor Saliba, and a “John Doe” defendant. The case was docketed as No. 2:18-cv-08911, brought under federal diversity jurisdiction, and classified as “Other Fraud.”3CourtListener. A Absolute Escrow Settlement Co., Inc. v. Wells Fargo Bank, NA4PACER Monitor. A Absolute Escrow Settlement Co., Inc. v. Wells Fargo Bank, NA et al
A Absolute demanded a jury trial. The docket shows motions to dismiss for lack of jurisdiction and motions for jurisdictional discovery before the case resolved. The specific factual allegations behind the fraud claim are not detailed in publicly available docket summaries.
The case ended on March 19, 2019, when the parties settled. The court signed a stipulation and order of dismissal without prejudice, meaning the claims were dropped but could in theory be refiled.4PACER Monitor. A Absolute Escrow Settlement Co., Inc. v. Wells Fargo Bank, NA et al5CourtListener. A Absolute Escrow Settlement Co., Inc. v. Wells Fargo Bank, NA – Integrated Database The settlement terms are not public.
The 2024 Class Action: Salmon v. Uzzolino
A Absolute appears again in federal court in 2024, this time as a defendant. In Salmon v. Uzzolino, No. 24-cv-09305, filed in the District of New Jersey, plaintiff Scott D. Salmon sued A Absolute alongside Acres Land Title Agency, Inc. and Peter A. Uzzolino, described in the complaint as a principal and owner of both companies.6CaseMine. Salmon v. Uzzolino, No. 24-cv-09305
Salmon brought the case as a putative class action under the New Jersey Consumer Fraud Act and Section 8(b) of the federal Real Estate Settlement Procedures Act (RESPA). The complaint alleged that the defendants charged homebuyers improper fees that operated as kickbacks. Specifically identified charges included:
- Fees for secondary mortgage market endorsements that were “rarely required”
- Transaction management fees for services actually performed by third-party software vendors
- Title examination fees where it was unclear which entity did the work
- A $30 “overnight fee” the complaint characterized as a sham cost given cheaper delivery options
The complaint argued that homebuyers rarely know much about title insurance and that the choice of insurer is typically controlled by lawyers, realtors, mortgage brokers, or lenders rather than the buyer.7NJ Law Journal. Title Insurance Agency on Hot Seat Over Homebuyer Fees, Alleged Kickbacks
The July 2025 Dismissal of the RESPA Claim
On July 30, 2025, the court granted the defendants’ motion to dismiss the RESPA Section 8(b) claim. The judge found that Salmon had not pleaded facts showing the challenged fees were actually “divided between two or more persons,” a required element of a RESPA kickback violation. Bare labels like “kickbacks” and “markups,” the court said, are legal conclusions rather than factual allegations, and charging fees a plaintiff considers unnecessary or too high does not by itself violate the statute. RESPA, the court noted, is not a “price-control statute.”6CaseMine. Salmon v. Uzzolino, No. 24-cv-09305
The dismissal was not necessarily the end. The court ordered Salmon to state by August 6, 2025, whether he intended to file an amended complaint, and set September 3, 2025, as the deadline for any revised pleading.6CaseMine. Salmon v. Uzzolino, No. 24-cv-09305
A Pattern Involving Uzzolino-Affiliated Companies
The Salmon case is not the first time A Absolute has been grouped with other companies owned by Peter Uzzolino. In the 2018 case Lannin v. NRT Title Agency, LLC, A Absolute was named among the “Uzzolino Group Defendants,” and the plaintiff there alleged Uzzolino was the “mastermind behind the illicit billing practices” of affiliated title agencies. The court in Lannin dismissed consumer fraud and contract claims against the Uzzolino entities for failing to meet federal pleading standards.2Carlton Fields. Lannin v. NRT Title Agency, LLC
Across both suits, plaintiffs have alleged that homebuyers are overcharged through a network of related settlement and title entities that pass fees among themselves. So far, courts have found the allegations insufficiently specific to survive motions to dismiss. Whether an amended complaint in Salmon changes that record remains open.