Plaintiff pursued its claim solely against defendant under the Act. Plaintiff and defendant both filed motions for summary judgment. In January 2014, the court granted summary judgment to plaintiff, and denied defendant's motion.

Defendant sought to vacate summary judgment pursuant to Rule 4:50-1(d). She argued that the court lacked subject matter jurisdiction because co-defendant had filed for bankruptcy. Defendant conceded, however, that she did not file a petition for bankruptcy. Plaintiff contended that its summary judgment against defendant was independent from anything that co-defendant had done leading to his filing of the Chapter 7 petition. Plaintiff argued that it obtained judgment against defendant based on fraudulent transfers that Hanna had made directly to defendant, unrelated to any transfers that co-defendant may have made, or any transfers that Hanna may have made to co-defendant.

The judge denied defendant's motion to vacate plaintiff's summary judgment, entered the order under review, and then denied defendant's motion for reconsideration.

On appeal, defendant contends that co-defendant's Chapter 7 petition prevents plaintiff from pursuing its claim against her under the Act. As a result, defendant repeats her Rule 4:50-1(d) argument that the judge erred by not vacating plaintiff's summary judgment because the court arguably lacked subject matter jurisdiction.

After reviewing the record and the briefs, we conclude that defendant's argument is without sufficient merit to warrant discussion in a written opinion. R. 2:11-3(e)(1)(E). We add the following brief remarks.

In reviewing a grant of summary judgment, we apply the same standard under Rule 4:46-2(c) that governed the trial court. Wilson ex rel. Manzano v. City of Jersey City, 209 N.J. 558, 564 (2012). Here, there are no genuine issues of material fact. Because the judge resolved legal questions, we review her conclusions on issues of law de novo. Manalapan Realty, L.P. v. Twp. Comm. of Manalapan, 140 N.J. 366, 378 (1995).
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"The purpose of the [Act] is to prevent a debtor from placing his or her property beyond a creditor's reach." Gilchinsky v. Nat'l Westminster Bank N.J., 159 N.J. 463, 475 (1999). The Act defines "transfer" as "every mode, direct or indirect, absolute or conditional, voluntary or involuntary, of disposing of or parting with an asset or an interest in an asset, and includes payment of money, release, lease, and creation of a lien or other encumbrance." N.J.S.A. 25:2-22. A transfer of assets may be fraudulent under the Act if the transaction was completed (1) with the actual intent to defraud the creditor, or (2) through constructive fraud, where the debtor had no actual intent to commit fraud. State Dep't of Envtl. Prot. v. Caldeira, 171 N.J. 404, 409 (2002).