THE SUPERIOR COURT FOR THE COUNTY OF FULTON STATE OF GEORGIA _______________________________ BENJAMIN TODD COLLINS,

) ) Plaintiff, ) ) vs. ) ) BANK OF AMERICA, N.A. and DEUTSCHE ) BANK NATIONAL TRUST COMPANY, ) AS TRUSTEE FOR CERTIFICATE HOLDERS ) OF FIRST FRANKLIN MORTGAGE LOAN ) TRUST 2006-FF13, MORTGAGE PASS ) -THROUGH CERTIFICATES, SERIES ) 2006-FF13. ) ) Defendants. ) _______________________________ )

CIVIL ACTION FILE NO:

VERIFIED PETITION AND MOTION FOR TEMPORARY RESTRAINING ORDER, PRELIMINARY INJUNCTION, AND PERMANENT INJUNCTION COMES NOW, Benjamin Todd Collins (hereinafter referred to as Plaintiff), by his attorneys and pursuant to O.C.G.A. 9-11-65, hereby moves this Court for the entry of a Temporary Restraining Order and, pending a hearing thereon, the entry of a Preliminary Injunction, and a Permanent Injunction against the Defendants who have given notice to the Plaintiff that the Defendants intend to foreclose and sell under power the Plaintiffs home located at 1220 East Beechwood Drive, Atlanta, Fulton County, Georgia. (The Property). The Defendants claim in the Notice of Sale Under Power that Deutsche Bank National Trust Company, As Trustee For Certificate Holders Of FFMLT 2006-FF13, Mortgage Pass-Through Certificates, Series 2006-FF13 is the assignee of a Security Deed executed by the Plaintiff in favor of Mortgage Electronic Page 1 of 3

Registration System, Inc. and recorded with the Fulton County records at Book 42940 Page 700. Defendants fail to identify either the Book and Page location of the recorded assignment or the date of the assignment relied upon. Said assignment is invalid and the Defendant has no right to exercise the power of sale provision in the Security deed. Plaintiff would suffer immediate and irreparable harm should the foreclosure and sale of the Plaintiffs home if the Defendant is allowed to go forward with the foreclosure and sale. Plaintiff respectfully requests this Court to enjoin the Defendants and issue a Temporary Restraining Order prohibiting the foreclosure and sale of the property pending further hearing of the matter by this Court. In support of this Application and Motion, Plaintiff offer his Statement of Facts and Memorandum of Law and Plaintiffs sworn and notarized affidavit and documents, which are attached and incorporated by reference in this action which sets forth the claims and prayers for relief. WHEREFORE, Plaintiff prays that the Court enter a temporary restraining order and preliminary injunction, and a permanent injunction, enjoining Defendants and all others acting in concert with them, from pursuing and otherwise foreclosing and selling Plaintiffs residence located 1220 East Beechwood Drive, Atlanta, Fulton County, Georgia. Respectfully submitted, this the ____ day of July, 2012

_______________________ THOMPSON LAW GROUP, LLC Robert Thompson, Jr., Esq. Georgia Bar No. 709750 H. Kirk Henson, Esq. Georgia Bar No. 348088 Page 2 of 3

Mailing Address: THOMPSON LAW GROUP, LLC P.O. Box 53484 Atlanta, Georgia 30355 Telephone: (404) 816-0500 Facsimile: (404) 816-6856 rthompson@thomlaw.net khenson@thomlaw.net

Street Address: THOMPSON LAW GROUP, LLC Ivy Place 3423 Piedmont Road, Suite 530 Atlanta, Georgia 30305

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