In a legal battle that could have significant financial implications, Nancy Roncati Dowden has filed a civil complaint against multiple defendants in the United States District Court for the District of New Jersey. The complaint, filed on December 1, 2025, targets Keith David Stacy and Michael and Robyn Conn among others, accusing them of breaching mortgage agreements and unauthorized occupancy of a valuable beachfront property in Long Beach Township, New Jersey.
The lawsuit initiated by Nancy Roncati Dowden centers around a large beachfront property located at 61D Long Beach Boulevard. According to the complaint, Dowden sold this property to Keith David Stacy under an agreement that included profit-sharing from any future resale. On April 10, 2018, Stacy executed a Promissory Note in favor of Dowden for $375,000 with terms entitling her to fifty percent of any sale price exceeding $6.5 million. However, issues arose when Stacy allegedly allowed Michael and Robyn Conn to occupy the property without Dowden’s consent starting May 27, 2022. This action is claimed to be a breach of the mortgage terms which explicitly required prior written consent for any such transfer or occupancy.
Dowden’s legal team argues that this unauthorized use resulted in significant financial losses due to unpaid fair-market rent estimated at $75,000 per week. The lawsuit further alleges that Stacy failed to maintain necessary insurance policies naming Dowden as beneficiary and improperly distributed proceeds from a subsequent sale of the property without escrow as previously agreed upon.
In seeking relief from the court, Dowden demands enforcement of her rights under the mortgage agreement including damages for lost profits and rental income along with attorney fees and costs associated with enforcing these rights. She also seeks declaratory judgments affirming her entitlement to rents and other profits from the property independent of any ongoing disputes over profit-sharing agreements.
The case is being handled by Mark S. Guralnick from his professional corporation based in Cherry Hill, NJ. The presiding judge is yet to be named but will oversee proceedings under Case ID: 3:25-cv-18073.
Source: 325cv18073_Dowden_v_Stacy_Complaint_District_New_Jersey.pdf
