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THE SUMMARY JUDGMENT OBTAINED IN THE PLAINTIFF S FAVOR ON OR AROUND 06/27/2009, IS DEFECTIVE AS IT DOES NOT MEET THE REQUIREMENTS

OF ADMINISTRATIVE 1. The Summary Judgment of Foreclosure obtained by the Plaintiff on or around 06/27/2007, does not meet the requirement. It does not have the address of the Plaintiff as required. 2. The address on the FINAL JUDGMENT OF FORECLOSURE is: 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 3. This is not the address of the named Plaintiff. This address is being used by more than 20 Plaintiffs, Banks, loan servicing companies. Here is an example of the companies using this address: THE BANK OF NEW YORK 1270 NORTHLAND DR STE 200 SAINT PAUL MN 55120 WELLS FARGO BANK NA TRUSTEE 1270 NORTHLAND DR SUITE 200 MENDOTA HEIGHTS, MN 55120 INSPECTOR: Eddie Prieto 274-5545 DEUTSCHE BANK NATIONAL TRUST 1270 NORTHLAND DR STE 200 MENDOTA HEIGHTS, MN 55120 INSPECTOR: RANDEL SMITH 274-5545 Current Beneficiary: MERS as nominee for Aegis Mortgage Corp Care of Servicer Aegis Mortgage Corp/Fidelity C/O Fidelity National Foreclosure Solutions 1270 Northland Drive. Suite 200 Mendota Heights, MN 55120 BANK ONE NATIONAL ASSN TRUSTEE 1270 NORTHLAND DR STE 200 MENDOTA HEIGHTS MN 55120 LONG BEACH MTG LOAN TRUST 1270 NORTHLAND DR STE 20 MENDOTA HEIGHTS MN 551201156 HomEq Servicing Corp. 1270 Northland Dr., #200 Mendota MN 55120-

IndyMac Bank-FSB;The Leader Mortgage Co. 1270 Northland Drive, Suite 200 Mendota Heights MN 55120Saxon Mortgage; Homecomings Financial 1270 Northland Dr., #200 Mendota Heights MN 55120FEDERAL NATIONAL MORTGAGE ASSOC 1270 NORTHLAND DR STE 200 MENDOTA HEIGHTS MN 55120 JPMORGAN CHASE BANK 1270 NORTHLAND DR STE 200 MENDOTA HEIGHTS MN 55120 BANK ONE AS TRUSTEE 1270 NORTHLAND DR STE 200 MENDOTA HEIGHTS MN 55120JP MORGAN CHASE BANK (TRUSTEE) 1270 NORTHLAND DR SUITE 200 SAINT PAUL, MN 55120 WELLS FARGO BANK NA 1270 NORTHLAND DR STE 200 MENDOTA HEIGHTS MN, 55120 SELECT PORTFOLIO SERVICING, INC
1270 NORTHLAND DR STE 200 MENDOTA HEIGHTS MN 55120

Select Portfolio Servicing Inc. 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 4. The named Plaintiff commenced this foreclosure action without having and holding the Original Note and Original Mortgage, without having a Note Indorsed

/ Endorsed in blank or to the named Plaintiff and without having a valid assignment of mortgage recorded in Public Records of Miami-Dade County, Florida; 5. The Assignment filed by plaintiff AFTER this foreclosure action was commenced is bogus, fraudulent, and due to the fact that the Assignment of Mortgage was not signed and notarized by employees of the Original Lender. They are all employees of the Assignee, Plaintiffs Attorneys and/or Subcontractors 6. Defendant would like to address the court to please place extra attention to who was the alleged authorized representative from MERS. On September 25, 2009, R.K. Arnold, the President and CEO of MERSCORP, Inc. the parent corporation of Mortgage Electronic Registration Systems, Inc. was deposed in Alabama. Arnold is also an Officer of MERS. Arnold admitted MERS does not have a beneficial interest in any mortgage; does not loan money; does not suffer a default if monies are not paid; etc. etc. On November 11, 2009, William C. Hultman was deposed in Alabama and made the same admissions. And, of course, the internal agreement used by MERS expressly disavows any beneficial interest. 7. In addition, there are, however, three defects in the Plaintiffs Complaint which prove fatal to its cause. The facts surrounding each defect are explained in detail below.

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