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DIVISION
______________
WITHOUT RECOURSE.
Plaintiffs
v.
Defendants.
__________________________________________________
_________________
___________
School Bd. V. Radio Station WQBA, 731 So.2d 638, 643 (Fla.
1999).
CONCLUSION
Respectfully submitted.
____________________________
__________________
Defendant, pro se
(000) 000-0000
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been sent via
facsimile and regular mail to __________, Esq., 00000 Biscayne Blvd., Ste. 000,
_________
______________________________
______________________
Defendant, pro se
Page 6
Ann An excellent Guide to Foreclosure Defense
10/16/10 at http://www.scribd.com/doc/39483420/Guide-to-Defending-Your-
01:00 PM Florida-Foreclosure-2009
http://www.scribd.com/doc/36645226/Foreclosure-Answer-With-
27-Affirmative-Defenses
Cheryl Kalil How can John Cottrell sign as the Asst. Vice President to Mers, on
my mtg transfer to Deutsche Bank and also sign as Asst. Vice
09/28/10 at President to Saxon in other people's documents?? Is it true that
09:25 PM Deutsche Bank, Saxon and Mers is owned by 1? Or are the same
company?
We are going thru a bankruptcy/relief of stay/reaffirmation or
sueing them right now.
Cheryl
Ann
27 AFFIRMATIVE FORECLOSURE DEFENSES -
09/04/10 at -----------------------------------------------------------------------
09:48 AM Thanks for sharing - D. Graham Esq. 305-445-9185
XXXXX Case No :
Plaintiff
YYYY
Defendant
----------------------------------------------------/
DEFENDANT YYYYY’S
ANSWER AND AFFIRMATIVE DEFENSES
Defendant YYYYY by and through undersigned counsel and pursuant to
applicable rules of the Florida Rules of Civil Procedures files this Answer and
Plaintiff’s right of action, right to attorney’s fee and or right to accelerate herein
were
AFFIRMATIVE DEFENSES
fails to state a cause of action which relief requested may be granted and
therefore
not have capacity to sue or bring this action and this action is therefore barred.
5. As a third affirmative defense, defendant states that Plaintiff is not the real
Party in interest and or duly authorized agent of same upon which plaintiff’s
alleged
Perform conditions precedent to the initiation of this action and or for acceleration
of
payment allegedly due. As a result, defendant has been denied a good faith
opportunity, pursuant to the mortgage and the servicing obligations of the plaintiff,
the promissory notes and mortgage upon which plaintiff’s alleged claim is based.
lawful assignee of the Promissory Note and Mortgage upon which plaintiff’s
alleged
claim is based.
produce the original Promissory Note and Mortgage upon which this action is
based
12. As ninth affirmative defense, defendant states that plaintiff is not the
holder of the Promissory Note and Mortgage upon which this action is based and
in possession of the Promissory Note and Mortgage upon which this action is
based
and belief, the note has been paid in full by an undisclosed third party who prior
to
or contemporaneously with the closing on the loan transaction paid the Lender in
exchange for certain unrecorded rights to the revenues arising out of the loan
documents. Upon information and belief, Plaintiff has no financial interest in the
note
or mortgage. Upon information and belief, the missing assignments on the note
may
have made it void and legal nullity, thus they have exploited key and vital
evidence
In the note or mortgage or the revenue therefrom. Upon information and belief,
plaintiff’s allegation that the note and the mortgage is lost, stolen or destroyed is
claim is barred and or limited for violation of the federal Truth in Lending Act
(TILA).
Is barred and or limited for violation of RESPA. Upon information and belief,
Plaintiff and or its predecessor(s) in interest violated various provision of the Real
exchange for referrals of settlement service business, and splitting fees and
d) Charging a fee at the time of the loan closing for the preparation of
truth-
is barred and or limited for violation of the state and or federal Fair Debt
Collection
Practices Act.
claim for attorney’s fee is barred for failure to perform or meet conditions
precedent
under the promissory note and or mortgage upon which action is allegedly based.
parties permitting the award of attorney’s fees in connection with this action.
comes to court with unclean hands and is prohibited by reason thereof from
obtaining the equitable relief of foreclosure from this court. The plaintiff’s unclean
hands result from the plaintiff’s improvident and predatory intentional failure to
comply with material term of the mortgage and note; the failure to comply with the
herein above. As a matter of equity, this court should refuse to foreclose this
mortgage because acceleration of the note would be inequitable, unjust, and the
refuse the acceleration and deny foreclosure because plaintiff has waived the
right
and belief, Defendant have made all payments required by law under the
applied such payments resulting in the fiction that Defendant was in default.
and general ledger for the account since a dump or summary of said information
cannot be relied upon to determine the rightful amount owed. Further, the
principal
balance claimed as owed is not owed and is the wrong amount ; the loan has not
plaintiff pursuant to the National Housing Act, 12 U.S.C. 1701x( c) (5) which
requires all private lenders serving non-federally insured home loans, including
Housing and Urban Development . The U.S Department of Housing and Urban
legal duty on the part of the plaintiff. Plaintiff’s non-compliance with the law’s
denies plaintiff’s ability to carry out this foreclosure. Plaintiff cannot legally pursue
and or collected payments from defendant for attorneys fees, legal fees, litigation
attorney
fees, foreclosure cost, late charges, property inspection fees, “property valuation”
charges, and other charges and advances, and predatory fees, force placed
insurance
and other charges that are not authorized by or in conformity with the terms of the
subject
note and mortgage. Plaintiff wrongfully added and continues to unilaterally add
these illegal
charges to the balance plaintiff claims is due owing under the subject note and
mortgage.
to provide defendant with legitimate and non predatory access to the debt
management
and relief that must be made available to borrowers, including the defendant
pursuant to
and in accordance with the Pooling and Servicing Agreement or other trust
agreement that
controls and applies to the subject mortgage loan. Plaintiff’s non-compliance with
the
Pooling and Service Agreement is an actionable event that makes the filing of
this
Plaintiff cannot legally pursue foreclosure unless and until plaintiff demonstrates
Pooling and Servicing or Trust Agreement under which the Plaintiff owns the
unintentionally failed to act in good faith or to deal fairly with the defendants by
the foregoing defenses, and on the face of the purported loan documents, the
terms
and circumstances of the Note and Mortgage were unconscionable when made
and
mortgage by foreclosure.
cannot prove its case against defendants and therefore this court should enter
judgment in defendant’s favor and quiet title in their favor, voiding the alleged
liable for defendant’s costs and attorney’s fees pursuant to terms of the
agreement
between the parties and Florida Statutes, Section 57.105 and or applicable
Provisions of the State and Federal Fair Debt Collection Practices act and or the
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was
Attorney for Plaintiff , 1800 NW 49 Street, Suite 120, Forth Lauderdale FL 33309
On June 2, 2010
Ann
Critical Courtroom Objections ...
08/29/10 at
10:26 PM From a lawyer:
Putting the Brakes on Crooked Judges &
Lawyers!
Timely objections!
Each time you object (and state the grounds for your
objections, unlike TV actors) you put the judge on
notice that overruling your objection threatens appeal.
6. Attend mediation
Consider these possibilities: If you want to leave the home, consider: 1. Giving a
deed in lieu of foreclosure (be sure you get a guarantee of debt forgiveness) 2.
Asking for move-out money ("Cash for Keys") 3. A short sale (be sure you get a
guarantee of debt forgiveness) 4. Setting a move-out date long into the future. If
you want to stay in the home, consider: 1. Ask for a reduction in principal to the
value of the home (A recent federal program may help facilitate this in part) 2.
Asking about the HAMP program (if you qualify, the interest rate is reduced and
the term extended so that the payments are reduced) 3. Asking about
conventional refinancing to current rates Remember, you do not have to agree on
anything. You can let the foreclosure take its course. Remember, the promissory
note is negotiable paper, it may be able to be sold and then enforced against you
if you do not get the original note back.
Ann
Judicial Foreclosure Process
06/30/10 at
12:55 AM Written by: Margery Ellen Golant
Foreclosure is the process by which the lender takes control of the property and
sells it to raise money to pay the debt. The process varies depending on if your
state is a judicial or nonjudicial state. Find out how judicial foreclosure works.
2.Interested Parties
In order for the interests of all parties who may have a claim to the property be
extinguished, the foreclosure must be done properly, and all interested parties
must be given proper notice as detailed by state law. The typical interested
parties are other owners of the property, spouses, junior mortgages, lienholders,
and some taxes. If the borrower is deceased, his or her heirs and estate are
interested parties.
3. Judicial Foreclosure
Judicial foreclosure is a lawsuit, similar to other kinds of lawsuits. It is formal and
much more complex, and generally takes longer than non-judicial foreclosure,
although this varies by jurisdiction. The point of a judicial foreclosure is for the
lender to obtain from the court a judgment in foreclosure, and the right to hold a
sale of the mortgaged property. The court is involved in the foreclosure process
all the way through. So, if a borrower feels there is something wrong or improper
occurring, he or she can raise those issues within the judicial foreclosure
proceeding.
5. Service of Process
Lawsuits are begun by service of process. All states have laws that govern
exactly how this has to work to be valid. In most states, it means that the
Summons and Complaint (see below) must be handed directly to you or to an
adult member of your household. However, all states have laws to cover
situations where you avoid service of process or cannot be served personally.
Service of process must be done properly in accordance with the law of the state
in question to be valid. These days we see many examples of improper service of
process. If process is not served properly, this issue MUST be raised before any
other defensive pleadings or it is waived.
8.Response - Answer
Answers fully address the allegations of the Complaint. In most cases, if issues
exist which can be raised by Motion or Objection, this is waived if an Answer is
filed first. Answers raise legal issues which are defenses to foreclosure (See
Guide - Defenses to Foreclosure). The amount of time allowed for a Response is
governed by state law, usually 20 or 30 days. Many people try to file their own
"Answer". This is normally a very dangerous move. The filing of an Answer
generally extinguishes the right to file preliminary motions, which can be critical to
the correct handling of a defense case. The only things which should be
contained in an Answer are legal defenses to foreclosure. These are rarely what
you would expect. Typically, the sorts of things people file talk about their
financial difficulties, about the fact that they are trying to get the mortgage
company to work with them, or trying to get a better job, and that they need more
time.
9.Default
If a Defendant does not file a response within the time allowed by law, the
Plaintiff can cause default to be entered against that Defendant, which precludes
his or her being able to raise defenses. In some states, it also allows the
foreclosure to proceed without any further notice to defaulting defendants.
10. Counterclaim
If a borrower has been wronged by the mortgage lender or servicer, he or she
may file a counterclaim. A counterclaim is just that - a suit within a suit, where the
Borrower is suing the Lender or Servicer.
11.Discovery
Interrogatories, Requests for Production, Requests for Admission, Depositions -
These are tools which can be used by any party to a lawsuit to obtain more
information to prove or disprove his, her or its case. Interrogatories are written
questions which one party serves on the other, demanding information. Requests
for Production are requests for tangible things, such as documents, files, objects,
etc. Requests for Admissions are used by attorneys to attempt to compel the
other side to admit or deny issues. Depositions are in-person testimony, under
oath, all of which is taken down by a court reporter. Cases may involve all or any
combination of these, however each jurisdiction has specific rules as to when
discovery can be propounded, how long the other side has to respond, and how
to handle a failure to respond or to respond properly. Properly done discovery is
usually the key to a successful outcome in a lawsuit.
06/26/10 at
11:25 PM
Ann Show this Motion to your attorney. Hope this may help
DEBTORS' OPPOSITION TO SUNTRUST'S MOTION FOR ORDER
06/09/10 at LIFTING AUTOMATIC STAY
11:31 AM
UNITED STATES BANKRUPTCY COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
In Re:
AYANNA K. CAMARA aka ROSIE P.
HINTON and LARRY LEE
Debtors
--------------------------------------------------
SUNTRUST MORTGAGE, INC.
Movant
v.
AYANNA K. CAMARA aka ROSIE P.
HINTON and LARRY LEE
Debtors
and
KEVIN R. MCCARTHY
Trustee
Respondents
No. 10-10856-RGM
DEBTORS' OPPOSITION TO SUNTRUST'S MOTION FOR ORDER LIFTING
AUTOMATIC STAY
Debtors Ayanna K. Camara and Larry Lee respectfully oppose SunTrust's motion
to lift
automatic stay filed on March 25, 2010 and served upon the Debtors on April 2,
2010. The
motion should be denied because, based on the record before the court,
SunTrust is not a creditor
of the instant bankruptcy estate and is not entitled to enforce the subject debt. In
addition to
SunTrust's lack of standing, its lift-stay motion fails to satisfy both procedural and
substantive
requirements applicable to this proceeding.
BACKGROUND
Today, more and more homeowners turn to the bankruptcy system for protection
when
facing financial hardship and impending foreclosure. It is bankruptcy courts'
responsibility to
ensure that these debtors receive the full protection of the Bankruptcy Code,
including the benefit
of the automatic stay, for as long as the debtors are entitled to it. Unfortunately,
contemporaneously with the increase in foreclosures, there is an increase in
lenders and entities
posing as lenders who, in their rush to foreclose, haphazardly fail to comply even
with the most
basic legal requirements of the bankruptcy system. It is the movant's
responsibility to comply,
and this Court's responsibility to ensure compliance, with both substantive and
procedural
requirements of the Bankruptcy Code, the federal rules, and other applicable law.
See, e.g., In re
Maisel, 378 B.R. 19 (Bankr. Mass. 2007); In re Foreclosure Cases, 2007 WL
3232430 (N.D.
Ohio 2007); In re Foreclosure Cases, 521 F. Supp. 2d 650 (S.D. Ohio 2007).
The most basic elements required to obtain relief from stay are that a movant (1)
have the
right to enforce the subject debt (2) in a way it is attempting to do so (through
foreclosure), i.e.,
that the movant have standing to bring and prosecute a lift-stay motion. Id. In this
case, SunTrust
satisfies neither of these elements. SunTrust does not have the right to enforce
the subject debt in
the first place, much less to enforce it as a secured creditor by way of
foreclosure.
FACTS
The Note and the Deed of Trust
On February 18, 2006, Debtor Ayanna Camara executed and delivered to
Synergy One
Financial Services, LLC ("Synergy One") a 3-page, fixed-rate promissory note in
the principal
sum of $287,000.00 ("Note") secured by a Deed of Trust on real property located
at 11977
Beaver Mill Lane, Manassas, VA 20112. Page 3 of the note contained Debtor
Camara's
notarized signature. Exh. A (copy of the Note as provided to Debtor at closing).
Some time in August-September 2009, after receiving a notice that her home
may be
foreclosed upon, Debtor Camara apparently wrote to SunTrust or its attorneys
requesting, inter
alia, a copy of the note in SunTrust's possession. On September 26, 2009,
Camara received from
one of SunTrust's attorneys a 3-page copy of the note, attached hereto as Exh.
B. The last page
of the Note produced by SunTrust contained a stamp with words "Without
Recourse / PAY TO
THE ORDER OF / SunTrust Mortgage Inc. / Deborah P. Ellis, Vice President." Id.
In other
words, the note produced by SunTrust in September 2009 consisted of 3 pages
and contained a
blank endorsement by SunTrust (thus evidencing a transfer of the note by
SunTrust to another
entity). As will be shown below, these 3 pages, with page 3 containing SunTrust's
blank
endorsement, are what the Court will see if it examines the original note.
The Deed of Trust accompanying the Note was signed by Debtor Camara on
February 18,
2005 and subsequently recorded in Prince William County, Virginia. The Deed of
Trust lists
Synergy One as the "Lender," and Mortgage Electronic Registration Systems,
Inc. ("MERS") as
"the beneficiary" of the Deed of Trust "solely as nominee for Lender and Lender's
successors and
assigns." See Exh. A to SunTrust's lift-stay motion [Dkt.29] (copy of Deed of
Trust).
The Deed of Trust was given by Debtor Camara and Joint Debtor Lee "to Robert
T. Heltzel as
[blank] and Eula R. Morgan as Trustee, for the benefit of [MERS] as beneficiary.
Id.
Upon information and belief, and a search of appropriate SEC filings, Synergy
One does
not fund mortgage loans it originates, but operates under a Flow Servicing
Agreement or other
similar agreement with another entity or entities that provide the actual funds
used to fund
mortgages originated by Synergy One. Because Synergy One uses someone
else's funds, it
charges, inter alia, a yield spread premium (YSP) that makes loans more costly
to consumers and
that violates federal consumer protection laws when undisclosed.
Currently, neither Synergy One nor SunTrust owns the Note (and thus the
Debtors'
mortgage loan), as the loan is listed as having been owned by Fannie Mae. Exh.
D (Fannie May
loan database printout). Fannie Mae, in turn sells about 85% of all mortgages it
owns to
investors through the process known as securitization, and has most likely sold
the Note to
unknown third parties. See, e.g., James R. Barth et al., A Short History of the
Subprime
Mortgage Market Meltdown 5 (Milken Institute 2008), available at
http://www.milkeninstitute.org/publications (showing percentage of securitized
mortgages by
issue date).
Bankruptcy Events
Some time on or after March 2, 2009, Debtors fell in default on their obligations
under
the Note. See Exh. C to SunTrust's lift-stay motion (copy of payment schedule).
On February 4,
2010, Debtors filed a Chapter 13 petition. [Dkt.1]. On February 17, 2010, said
petition was
converted into a Chapter 7 petition. [Dkt.13].
On March 25, 2010, SunTrust, through its attorneys, filed a Motion for Order
Granting
Relief From Automatic Stay. [Dkt.29]. Attached to that motion as an exhibit was a
copy of the
Note, allegedly in possession of SunTrust, which contained 4 pages (rather than
3 contained in
the September 2009 version produced by SunTrust), with the third page not
containing a blank
endorsement by SunTrust, and the fourth page purporting to evidence a special
endorsement of
the Note from Synergy One to SunTrust. See Exh. B to SunTrust's motion to lift
stay [Dkt.29]
(copy of the Note). A copy of this version of the Note is also attached hereto as
Exh. C for easy
-5-
comparison and contrast with the original 3-page version produced by SunTrust
prior to its filing
of its lift-stay motion. The purported special endorsement is undated. Id. Further,
there is no
evidence that the alleged special endorsement is affixed to the original Note. On
the contrary,
circumstantial evidence (such as: (1) the special endorsement being on a
separate page 4 even
though there is still room on page 3 of the Note, and (2) the presence of a blank
endorsement by
SunTrust on Page 3 of an earlier version, and (3) the absence of the blank
endorsement on page 3
of the later, 4-page version) strongly points to the conclusion that the 4-page
version is not a copy
of the original note, and that page 4 was added ad hoc to mislead the Court as to
the actual right
(or lack thereof) of SunTrust to enforce the note. See Exs. B & C.
In light of the above facts, Debtors oppose SunTrust's lift-stay motion. For the
reasons
stated fully below, the lift-stay motion should be denied and applicability of Rule
9011 sanctions
should be considered against SunTrust and its attorneys.
Pursuant to Local Rule 4001(a)-1(A), "[a]ll motions for relief from stay . . . are
contested
matters and are governed by FRBP 9014, 11 U.S.C. § 362[] and [the] Local
Bankruptcy Rules."
Local Rule 4001(a)-1(D) provides that the following elements "must be included
in a motion for
relief from stay: . . . (4) a description of the security interest and its perfection; (5)
a statement of
the basis for the relief claimed . . . . The specific facts constituting cause shall be
set forth if a
motion is brought for cause." (Emphasis added.) Thus, this Court's rules of
procedure require
that each lift-stay motion contain certain indispensable elements, the absence of
which should
result in a denial of such motion, just like a complaint failing to state a claim
would be subject to
dismissal on a 12(b)(6) motion.
-As noted above, lift-stay motions are contested matters governed by, inter alia,
Rule
9014. Rule 9014, in turn, makes such motions subject to Rule 7017, which, in
turn, incorporates
Fed. R. Civ. P. 17 providing that an "action must be prosecuted in the name of
the real party in
interest." As this Court previously noted, "[i]t is axiomatic that in federal courts a
claim may
only be asserted by the real party in interest. Rule 7017 of the Federal Rules of
Bankruptcy
Procedure incorporates the provisions of Rule 17 of the Federal Rules of Civil
Procedure. . . .
The purpose of Rule 17 is to ensure that the person bringing a lawsuit has the
right to enforce
the asserted claim." In re Smith, 419 B.R. 622, 628 (Bankr. E.D. Va. 2008)
(citation omitted)
(emphasis added) (finding purported creditor lacked standing to file proof of claim
with respect
to judgment rendered in favor of another party).
Importantly, as a general rule, a person who is an attorney-in-fact or an agent
solely for
the purpose of bringing suit is viewed as a nominal rather than a real party in
interest and will be
required to litigate in the name of his principal rather than in his own name. See,
e.g., In re
Hwang, 396 B.R. 757 (Bankr. C.D. Cal. 2008) (quoting 6A Wright, Miller & Kane,
Federal
Practice and Procedure: Civil 2d § 1553).
Sylvia Sirmonss Well they are still at it in Indiana. Robbing the American people of
their homes. We have been fighting since 2006 and are still at it. It
06/09/10 at started with Countrywide and has went to New Century and thru
12:45 AM assignment has gone to Deutshe Bank, with Fraud all through the
loan, and Appraisal's changed and forged. New Century is
Bankrupt. The broker was employed thru Empire Equity of New
Jersey, and on December 31, 2009 they went bankrupt. So who do
they (Deutshe Bank) come after, The Sirmons because they didn't
check the paper that they bought, and then sold to a German Bank
in Pass thru Cettificates. Now we have asked for them to Produce
the Documents and of course they sent copies, and not the Note it
self. We wrote a letter of Recission and they ignored us, and we
then hired an Attorney and she wrote a letter of Recission and they
pretty much told her, we had no right to Recind. So now we are at
Bankruptcy ourselves, and of course they have presented a Motion
to Stay, so now we have to go at the end of this month to fight the
Motion. We have been in our home since July 1, 2004, that is 6
years, and I don't want to move!
Ann Case No
COMES NOW the Defendant, John Smith , and pursuant to Rule 1.140(f) moves
this honorable Court to strike the documents placed into the court file on October
17, 2009
referred to by the Plaintiff as the "original note," and in support thereof states as
follows:
1. When the Plaintiff initially filed its Complaint On July 25, 2008 it failed to
support the Complaint with any original documentation, negotiable instrument,
note or mortgage.
Attached to the Complaint was a photocopy of the May 21, 1999 promissory note
obligating the Defendant to the "original lender" APPROVED, and a photocopy of
an alleged allonge assigningthe note from "Approved Residential Mortgage Inc."
(hereinafter "APPROVED") to "NorwestBank Minnesota N.A. As Trustee For
Provident Bank Home Equity Loan Trust 1999-3"(hereinafter "NORWEST").
There was no documentation filed with the complaint connectingthe note or
mortgage to the named Plaintiff WELLS FARGO BANK, N.A. (hereinafter
"WELLS FARGO"). The Plaintiff at that time sought reestablishment of the
original note which it claimedwas "lost, destroyed or stolen."
2. On October 17, 2008 the Plaintiff filed a document into the case file purported
to
be the "Original Note" along with two allonges, one allonge being identical to the
allonge filed with the Complaint, purportedly assigning the note to NORWEST,
and the other allonge titled NOTE ALLONGE, which was not initially filed with the
complaint, allegedly assigning an attached note from the Plaintiff WELLS FARGO
to itself as trustee (hereinafter "WELLS FARGO allonge"). Copies of the note and
allonges are attached as Exhibit B.
3. On February 10, 2009 the Plaintiff filed into the case file a copy of an
Assignment
of Mortgage which assignment was executed on August 20, 2004 and filed into
the Hernando
County official records on September 9, 2004, a copy of which is attached
herewith as Exhibit A.
4. Regardless of the document's title, the said Assignment of Mortgage assigned
both the note and mortgage constituting the subject or res of this action to The
Provident Bank, Inc., reading as follows in pertinent part:
"...APPROVED RESIDENTIAL MORTGAGE,...does convey, grant, bargain, sell,
assign, transfer and set over to: THE PROVIDENT BANK, INC., ...The described
Mortgage, together with the certain note(s) described therein with all interest, all
liens, and any rights due or to become due thereon..."
5. On February 16, 2010 the Defendant inspected the alleged "Original Note"
placed
in the file and denies its authenticity and that of the purported signature thereon
(see "Affidavit of Defendant, John Smith in Opposition to Plaintiff's Motion for
Summary Judgment" filed concurrently herewith and incorporated herein by
reference thereto.
6. On the same date the Defendant observed that while there is generous room
on the
Note itself for indorsement, there is no indorsement on the Note, and the allonges
filed with the note were not attached affixed to the note prior to filing.
8. Furthermore, even if the alleged "original note" filed by the Plaintiff on October
17, 2008 is ruled to be authentic, it remains unenforceable because the alleged
allonges are
contradicted and invalidated by competing evidence entered by the Plaintiff in the
recorded
Assignment of Mortgage (Exhibit A), showing another named signatory assigning
both the note and mortgage to Provident Bank on August 20, 2004. This fact is
corroborated by the
aforementioned affidavit of title attorney Gregory D. Clark, Esq., filed concurrently
herewith and fully incorporated herein by reference thereto. The allonges filed on
October 17, 2008 are therefore not valid and must be stricken.
9. Furthermore the WELLS FARGO allonge filed on October 17, 2008 is a sham
on
its face as it allegedly assigned the res to itself, was not filed with the Complaint,
and the
Plaintiff can not be allowed to amend the record with exhibits that did not exist
when the action was filed.
WHEREFORE, the Defendant, John Smith , respectfully moves this court to
strike the alleged "original note" along with the allonges filed therewith on
October 17, 2008.
Respectfully submitted on this day of March, 2010.
John Smith
MEMORANDUM OF LAW
Regarding the note and allonges in this instant case: while there is generous
room on the
Note itself for indorsement, there is no indorsement on the Note, and the allonges
were not
previously affixed to the note. Further the indorsements on the allonges were
never verified by affidavit or testimony, were undated and unauthenticated by any
corporate seal or stamp.
Even if the alleged "original note" filed by the Plaintiff on October 17, 2008 is
ruled to be authentic, it remains unenforceable because the alleged allonges are
rendered invalid for violation of the rule of affixation to the note and authentication
pursuant to F.S. § 673.2041(1) and Booker v.Sarasota Inc., 707 So.2d 886
(Fla.App. Dist.1 03/06/1998):
[17] Contrary to other arguments now advanced by Sarasota, Inc., the trial court
could not simply assume that Sarasota, Inc. held the note, or that the photocopy
of an
allonge, filed after the hearing on the motion for summary judgment, was of
appropriate evidentiary value. Booker has correctly pointed out that in order to be
the
real party in interest on a promissory note, the plaintiff must be the holder of the
note. See Troupe v. Redner, 652 So. 2d 394, 395-396 (Fla. 2d DCA 1995).
Here, the allonge, attached to the complaint, and referred to by Sarasota Inc.'s
affidavit in
support of its motion for summary judgment, showed an assignment of the note
from
an institution other than Citizens and Builders. The allonge, ultimately filed with
the
court had never previously been verified by affidavit or testimony, nor had it been
provided to the court or to Booker in the form of an amended complaint. A Florida
court may not consider an unauthenticated document in ruling on a motion for
summary judgment, even where it appears that the such document, if properly
authenticated, may have been dispositive. See Tunnell v. Hicks, 574 So. 2d 264,
266
(Fla. 1st DCA 1991).
[34] A holder in due course must take the instrument for value, in good faith,
and without notice that it is overdue, that it has been dishonored, or that a claim
or
defense to it exists on the part of any person. See U.C.C. § 3-302(1). But
preliminarily, a person seeking to become a holder in due course must satisfy the
threshold requirements for becoming a "holder," the critical issue on this appeal.
[35] The Code defines a holder as one 'who is in possession of . . . an
instrument . . . drawn, issued or indorsed to him or to his order." U.C.C. § 1-
Defendant's Motion to Strike Note and Allonges - page 5 of 6
PLAINTIFF,
v.
STANDARD OF REVIEW
a. LegalStandards
to read
See also Muss v. Lennar Florida Partners L L.P., 673 So. 2d 84 (Fla. 4th
DCA 1996).
b. Argument
1. 110(b);
CERTIFICATE OF SERVICE
l'\.F'J-J..
MATTHEW
Defendant name
Defendants.
_______________________________________/
Rule 1.190, Fla. R. Civ. P., requires that ―leave of court [to amend
pleadings] shall be given freely when justice so requires,‖ and that
the court may permit a pleading to be amended ―at any time in
furtherance of justice.‖ Fla. R. Civ. P. 1.190(a), (e) (emphasis
added). Indeed, Florida‘s well reasoned public policy
overwhelmingly favors the liberal amendment of pleadings so that
cases may be decided on their merits. Craig v. East Pasco Med.
Ctr., Inc., 650 So. 2d 179 (Fla. 2d DCA 1995). All doubts must be
resolved in favor of allowing amendment of pleadings. Thompson v.
Publix Supermarkets, Inc., 615 So. 2d 796 (Fla. 1st DCA 1993).
The failure to permit amendment constitutes an abuse of discretion
unless it clearly appears that the amendment would prejudice the
opposing party, the privilege to amend has been abused, or
amendment would be futile. Carter v. Ferrell, 666 So. 2d 556 (Fla.
2d DCA 1995).
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and complete copy of the foregoing
has been furnished via facsimile 305-296-1580 and U.S. Mail
to xxxx Esq., Post Office Box 370, Key West, Florida 33041 this
____day of February 2005.
___________________
Here is the text of an additional argument that you can add to your MTD. I’ve
raised it a few times now, and no mill has responded to it yet:
Defendant, ________, (“_________”) by and through undersigned
counsel, and pursuant to Rule 1.140, Florida Rules of Civil Procedure, file
declare that I have read the foregoing, and the facts alleged therein
1.110(b).
be dismissed with prejudice and for such other relief as this Court deems
F. 407-264-6288
ortlawfirm.com
REQUEST FOR
INTERROGATORIES
Plaintiff(s),
vs.
Rosedale, NY 11422
Defendant(s)/Pro Se
------------------------------------------------------------------X
REQUEST FOR DISCOVERY: INTERROGATORIES
i). Defendant, XXX, serves these interrogatories on Deutsche Bank
National Trust Company, as authorized by Case Management Order
dated September 30, 2009, and by the Federal Rule of Civil
Procedure 33. Deutsche Bank National Trust Company must serve
an answer to each interrogatory separately and fully, in writing and
under oath within 30 days after service to: XXX, XXX Ave.,
Rosedale, NY 11422.
INSTRUCTIONS
ii). These requests for interrogatories are directed toward all
information known or available to Deutsche Bank National Trust
Company - not its lawyer, Ralph F. Casale, Esq. - including
information contained in the records and documents in Deutsche
Bank National Trust Company‘s custody or control or available to
Deutsche Bank National Trust Company upon reasonable inquiry.
iii). Each request for interrogatory is to be deemed a continuing
one. If, after serving an answer, you obtain or become aware of
any further information pertaining to that request, you are
requested to serve a supplemental answer setting forth such
information.
iv). As to every request for interrogatory which an authorized
officer of Deutsche Bank National Trust Company fails to answer in
whole or in part, the subject matter of that request will be deemed
confessed and stipulated as fact to the Court.
v). Kindly attach additional sheets as required identifying the
Interrogatory being answered. You have a continuing obligation to
update the information in these Interrogatories as you acquire new
information. If no such update is provided in a reasonable period of
time that you acquired such information, it may be excluded at trial
or hearing.
DEFINITIONS
vi). ―You‖ and ―your‖ include Deutsche Bank National Trust
Company and any and all persons acting for or in concert with
Deutsche Bank National Trust Company.
vii). ―Document‖ is synonymous in meaning and equal in scope to
the usage of this term in Federal Rule of Civil Procedure 34(a) and
includes computer records in any format. A draft or non-identical
copy is a separate document within the meaning of this term. The
term ―document‖ also includes any ―tangible things‖ as that term is
used in Rule 34(a).
viii). Parties. The term ―plaintiff‖ or ―defendant‖, as well as a
party‘s full or abbreviated name or a pronoun referring to a party,
means the party and, where applicable, (his/her/its) agents,
representatives, officers, directors, employees, partners, corporate
parent, subsidiaries, or affiliates.
ix). Identify (person). When referring to a person, ―identify‖ means
to give, to the extent known, the person‘s full name, present or last
known address, telephone number, and when referring to a natural
person, the present or last known place of employment. Once a
person has been identified in compliance with this paragraph, only
the name of that person needs to be listed in response to later
discovery requesting the identification of that person.
x). Identify (document). When referring to a document, ―identify‖
means to give, to the extent known, the following information: (a)
the type of document; (b) the general subject matter of the
document; (c) the date of the document; (d) the authors, address,
and recipients of the document; (e) the location of the document;
(f) the identity of the person who has custody of the document;
and (g) whether the document has been destroyed, and if so, (i)
the date of its destruction, (ii) the reason for its destruction, and
(iii) the identity of the person who destroyed it.
xi). Relating. The term ―relating‖ means concerning, referring,
describing, evidencing, or constituting, directly or indirectly.
xii). Any. The term ―any‖ should be understood in either its most or
its least inclusive sense as necessary to bring within the scope of
the discovery request all reasons that might otherwise be construed
to be outside of its scope.
2. For each of the above persons please state whether they have
personal knowledge regarding the subject loan transaction.
ANSWER:
3. Please state the date of the first contact between Deutsche Bank
National Trust Company and the borrower in the subject loan
transaction, the name, address and telephone number of the
person(s) in your company who was/were involved in that contact.
ANSWER:
6. Please identify any person(s) who had any contact with any third
party regarding the securitization, sale, transfer, assignment,
hypothecation or any document or agreement, oral, written or
otherwise, that would effect the funding, closing, or the receipt of
money from a third party in a transaction that referred to the
subject loan.
ANSWER:
12. Other than people identified above, identify any and all persons
who have or had personal knowledge of the subject loan
transaction, underwriting of the subject loan transaction,
securitization, sale, transfer, assignment or hypothecation of the
subject loan transaction, or the decision to enforce the note or
mortgage in the subject loan transaction.
ANSWER:
14. Please state the date on which Argent Mortgage Company, LLC
(originator) sold the mortgage loan to Ameriquest Mortgage
Company (Seller and Master Servicer).
ANSWER:
17. If yes, please describe and itemize each and every form of
compensation, fee, commission, payment, rebate or other financial
consideration paid to Argent Mortgage Company, LLC, the
originator or previous servicers of this account by Ameriquest or
any affiliate, or from the trust fund.
ANSWER:
19. Please identify the custodian of the records that would show all
entries regarding the flow of funds for the subject loan transaction
prior to and after closing of the loan. (Flow of funds, means any
record of money received, any record of money paid out and any
bookkeeping or accounting entry, general ledger and accounting
treatment of the subject loan transaction at your company or any
affiliate including but not limited to whether the subject loan
transaction was ever entered into any category on the balance
sheet at any time or times, whether any reserve for default was
ever entered on the balance sheet, and whether any entry, report
or calculation was made regarding the effect of this loan transaction
on the capital reserve requirements of your company or any
affiliate.)
ANSWER:
21. Please identify any attorney with whom you consulted or who
rendered an opinion regarding the subject loan transaction or any
pattern of securitization that may have effected the subject loan
transaction directly or indirectly.
ANSWER:
CERTIFICATE OF SERVICE
I, I, XXX certify that on this 29th day of the month of October,
2009.
1. A true copy of the 10-page Request for Interrogatories was
served on The New Superior Court of New Jersey, Chancery
Division – Essex Vincinage, at 212 Wasington Street, Eighth Floor,
Newark, New Jersey.
2. A copy of the foregoing was mailed on , 2009 to
REQUEST FOR
Plaintiff(s), PRODUCTION OF
DOCUMENTS
vs.
INSTRUCTIONS
i). These requests for production of documents are directed toward
all information known or available to Deutsche Bank National Trust
Company – not its lawyers with no firsthand knowledge of the
records in this instant case – including information contained in the
records and documents in Deutsche Bank National Trust Company‘s
custody, control or available to Deutsche Bank National Trust
Company upon reasonable inquiry. Where requests for documents
cannot be answered in full, they shall be answered as completely as
possible. No answer or an incomplete answer shall be accompanied
by a specification of the reasons for the lack of answer and the
incompleteness of the answer and of whatever actual knowledge is
possessed with respect to each unanswered or incompletely
answered Request for Documents. Please state the name(s) of the
senior officer(s) having firsthand knowledge of the facts herein and
their title answering this request.
v). For each document that Deutsche Bank National Bank Trust
Company claims is not discoverable, state (1) the information
required by the definition of ―document‖ below, (2) the author‘s job
title and address, (3) the recipient‘s job title and address, (4) the
name and job title of all persons to whom it was circulated or who
saw it, (5) the name, job title, and address of the person now in
possession of the document, and (6) the document‘s present
location.
DEFINITIONS
xxi). The term ―equity in the original note‖ refers to the fact that
not only does Deutsche Bank National Trust Company have physical
possession of the original promissory note and custody like a
fiduciary, but must have also vested financial interest in such: it
legally belongs to Deutsche Bank National Trust Company.
DOCUMENTS REQUESTED
1) Please identify the true owner of this obligation pursuant to 15
U.S.C. § 1641(f)(2) and describe your relationship to this entity.
RESPONSE:
11) Produce certified copies, front and back, of all checks or wire
transfer confirmation obtained or issued by Argent Mortgage
Company, LLC and used to fund and purchase this obligation,
including all copies of checks or wire transfers paid as third-party
fees at the closing by Argent Mortgage, LLC;
RESPONSE:
15) Any request for exemption or No-action letters from SEC with
respect to their securities and all ACTS and certified copies of the
application filed with the SEC for exempt status and the order
issued by the SEC granting exempt relief from the appropriate
provisions;
RESPONSE:
17) The Tax Equity and Fiscal Responsibility Act of 1982 (―TEFRA‖)
Pub. L. 97-248, 96 Stat. 324, a bearer debt security generally must
be issued under arrangements reasonably designed to ensure that
such obligation will be sold only to a person who is not a United
States person and must satisfy certain other conditions identified in
the Tax Code § 163(f)(2)(B), and as such please provide:
a) The Identify of all parties with ownership interest who have met
the criteria as adopted by Treasury Regulation § 1.163-5(c)(i)(D)
―TEFRA D‖ and § 1.163-5(c)(i)(C) ―TEFRA C‖
RESPONSE:
c) All information statements and returns filed with the IRS which
identifies the name and address of all recipients of interest and
original issue discount that meets the provisions of a U.S. obligor
making payments to a foreign person under the Tax Code §§
871(a)(1), 881(a), 1441(a), 1442(a) and § 6049
RESPONSE:
CERTIFICATE OF SERVICE
I, XXX certify that on this 29th day of the month of October, 2009.
1. A true copy of the 12-page Request for Production Of Documents
was served on The New Superior Court of New Jersey, Chancery
Division – Essex Vincinage, at 212 Wasington Street, Eighth Floor,
Newark, New Jersey.
ii. Newly discovered evidence which by due diligence could not have
been
have been both fraud and misrepresentation in this case and other
eases which LBNA and
December 12. 2008; award this defendant all other relief to which
this defendant proves himself entitled
I HEREBY CERTIFY that a true and correct copy of the foregoing has
been furnished by regular Il.S, Mail and facsimile to
___________________. of January, 2009.
Respectfully submitted. _;~
FACTS
[i]f it appears to the satisfaction of the court at any time that any
of the affidavits presented pursuant to this rule are presented in
bad faith or solely for the purpose of delay, the court shall forthwith
order the party employing them to pay to the other party the
amount of the reasonable expenses which the filing of the affidavits
caused the other party to incur, including reasonable attorneys‘
fees, and any offending party or attorney may be adjudged guilty of
contempt. Emphasis added.
[3] Id.
FACTS
Plaintiff lacks standing as they are not holder in due course with
rights to enforce.
17. The Foreclosure Mill - Bryan Bly has signed many other county
record filings exposing some of Bryan Bly‘s other bogus titles as
well as his service as a Notary Public for Nationwide Title Clearing
Inc. in violation of Florida Notary laws. Some of these other filings
and a news publication describing this process are incorporated
herein by reference for all purposes. See attached exhibits J and O.
================================
PRAYER
WHEREFORE, PREMISES CONSIDERED, Defendant prays that
Plaintiffs be denied their request to foreclose. As the plaintiffs have
failed to establish the authority of this court and as a result of the
fraud that they have committed, they will never be able to obtain
the jurisdiction of this court. Therefore this Honorable Court lacks
jurisdiction to hear this case at hand and at a minimum should
dismiss this case with prejudice. Plaintiff respectfully requests this
Court permanently restrain Plaintiffs and any other relief this Court
deems equitable and just.
================================
ATTACHED EXHIBITS
A. Codilis & Stawiarski Acceleration Letter
B. letter to Codilis & Stawiarski - dispute
C. title search
D. record assignments (chart)
E. pooling and servicing agreement excerpts
F. prospectus excerpts
G. MEETING OF THE TASK FORCE ON JUDICIAL FORECLOSURE
RULES
H. original enote (chart)
I. why the original (chart)
J. assignment fraud (other assignments - Brian Bly and Bobbie Jo
Stoltd signatures etc.)
K. limited power of attorney D207376789
L. signature (chart)
M. required assignments (chart)
N. complaint to Florida notary section
O. notice of assignment D209045468 - Argent Deutsche
P. letter (package) received from Codilis 8/20/09
Q. letter to Codilis 09/10/09
R. complaint to FTC
S. Fraud or Fraudulent (chart)
T. letter (package) received from Codilis 9/9/09
U. CD with prospectus and pooling and servicing agreement in full,
all exhibits in .pdf
=================================
Respectfully submitted by:
__________________________________________
Geoffrey Anson Wilner - Defendant, pro se
6311 Avanti Dr.
Arlington, Texas
76001
817 467 7478
CERTIFICATE OF SERVICE
I hereby certify that a correct copy of the foregoing was served on
the following counsel of record on September ___, 2009, via
certified mail, return receipt.
_________________________________
Geoffrey Anson Wilner Codilis & Stawiarski, P.C.
6311 Avanti Dr. 650 N. Sam Houston Parkway, East
Arlington, Texas Suite 450
76001 Houston, Texas
817 467 7478 77060
Defendant, pro se ATTORNEY FOR THE PLAINTIFFS
Unquote
Atlantic City, NJ
On the Brief
LEGAL ARGUMENT
238 N.J. Super 279 (Ch.Div. 1989) in alleged support of its request to
misplaced, as the cited portion plainly states that the “pattern” involves
The second cited portion of the Sternberg opinion states that “many of
the answers and defenses proffered are legally insufficient as they fail
the Plaintiff‟s very standing to foreclose and thus its right to seek the
remedy of foreclosure ab initio and as set forth more fully herein.
(N.J. Super A.D. 1975), wherein it was held that “R.4:6-2 requires that
are “germane” if they arise out of the subject matter of the mortgage
The sixth Separate Defense of the Defendants states that Plaintiff was
not, at the time of the filing of the Complaint and in view of the
of the real property the subject of this action based on the lack of legal
denied.
a foreclosure action, and has also failed to cite a single case which
interest in the mortgage and note at the time of the filing of the
case “on point”, the Courts of New Jersey have utilized opinions from
other jurisdictions for guidance. (See, e.g., Greate Bay Hotel & Casino,
Inc. v. City of Atlantic City, 264 N.J.Super. 213, 217-218, 624 A.2d
New York have been repeatedly presented with the legal standing
held that when there is no proof that the foreclosing party had the
requisite legal interest in the mortgage and note at the time that it filed
100 NY2d 801, 812 [2003], cert denied 540 US 1017 [2003]; Caprer v.
Nussbaum, 36 AD3d 176, 181 [2d Dept 2006]; Stark v. Goldberg, 297
foreclosure action, is the holder of the mortgage and note or took physical
delivery of the mortgage and note or that same were conveyed by written
assignment, the plaintiff did not have standing to institute the action. New
50175(U) (N.Y. Sup. Ct. 2/2/09), citing Deutsche Bank Trust Co. Ams. V.
plaintiff does not have the requisite ownership interest at the time of filing.
9/4/2007), citing Katz v. East-Ville Realty Co., 249 AD2d 243, 672
NYS2d 308 [1st Dept 1998] and Kluge v. Fugazy, 145 AD2d 537, 536
foreclose on the mortgage and note as it did not own the mortgage and
note on the day that the Complaint was filed. IndyMac, as Plaintiff has
done here, attempted to assign the mortgage and note two days after filing
demonstrate that Plaintiff did not own the note and mortgage on December
24, 2007 (the day that the Complaint was filed), having only [purportedly]
come into such ownership, at the earliest, some three days thereafter, that
was not even recorded by the Atlantic County Clerk until almost a year
foreclosure action ab initio. This issue of material fact warrants not only
the denial of Plaintiff‟s Motion for Summary Judgment, but also supports
the entry of summary judgment in favor of the Fairhurst Defendants on
the Plaintiff‟s legal standing including the chain of title to the mortgage
and note which are factual issues material to not only the Plaintiff‟s claim
absence of factual issues at this early stage of the proceedings where the
v. Colgate-Palmolive Company, Inc., 109 N.J. 189, 193, 536 A.2d 237
(N.J. 1987):
109 N.J. at 193, citing United Rental Equip.Co. v. Aetna Life and Casualty
Ins. Co., 74 N.J. 92, 99, 376 A.2d 1183 (1977)(citing Robins v. Jersey
City, 23 N.J. 229, 240-41, 128 A.2d 673 (1957), and Martin v. Educational
Testing Serv., Inc., 179 N.J. Super 317, 326, 431 A.2d 868 (Ch.Div.1981).
In cases where a suit is in an early state and not fully developed, the
is from the standpoint of whether there is any basis upon which the
citing Bilotti v. Accurate Forming Corp., 39 N.J. 184, 193, 188 A.2d 24
(1963). As the Plaintiff herein did not have the legal standing to institute
this foreclosure action ab initio, Plaintiff cannot proceed any further, and
Plaintiff also attempts to support its Motion for Summary Judgment with
the Certification of Richard P. Haber, Esq., who is counsel for the Plaintiff
information and belief. See., e.g., Wang v. Allstate Ins. Co., 125 N.J. 2, 16
(1991); Lamb v. Global Landfill Reclaiming, 111 N.J. 134, 153 (1988).
note or mortgage at the time that the Complaint was filed, and raises
genuine issues of material fact as to when (if ever) Plaintiff came into any
ownership rights of either the Note or the Mortgage. Plaintiff‟s Motion for
CONCLUSION
Plaintiff has, by its very submissions, demonstrated that there are genuine
demonstrate that there is no genuine issue of material fact that Plaintiff did
not have any legal interest in either the note or the mortgage at the time it
filed this foreclosure action, and has thus demonstrated that it was without
Respectfully submitted,
(counsel)
PJ 2 ANN, and all out there , is there a limit on the number and or
time frame of QWR's a mortgage holder can submit to a "pretender
02/18/10 at lender" servicer, or aka ever shifting Foreclosing "agent". It seems
05:55 PM to me that every day brings yet more evidence of perpetration of
fraud on the American people and our system raising new
question's to be answered and raised.
2. Does anyone have some advice on how to copy and paste these
terrific pleadings in this thread, so they do not have the blue/ gray
background...
thanks,
Tom
In the event that the loan goes into foreclosure at a later date, the
then-current owner of the loan files the foreclosure and sells the
property to a new owner, often at auction. The land records would
show a deed of transfer from the investment bank to the new
owner. This creates a break in the chain of ownership of the
mortgage rights. In many cases, the transfer of ownership
of the mortgage loan has gone from the original lender,
through several owners, and then to the foreclosing bank,
none of which is recorded on the property title history.
Technically, the foreclosing bank has no recorded title rights
to foreclose in the first place. Owners of the loan normally do
not publicly record each of the transfers out of expediency, and
cost. Filing a document of transfer (called an assignment) in the
land records incurs a substantial fee paid to the county clerk.
4closureFraud
http://www.4closureFraud.org
Then at some point, the Bank will file Motion for Summary
Judgment . Now it is the tough part. The Homeowner can file more
discovery if necessary. Homeowner can depose the Bank, the
Servicer etc. Then he has to file Motion to Oppose Summary
Judgment before the Hearing date . An experienced lawyer is
strongly recommended at this point. Unless the Homeowner knows
to defend himself very well, he may lose the case at the hearing
and the Juge will schedule the sale of the house. Try to negotiate
with Plaintiff lawyer to delay the Hearing date and look for a good
lawyer.
If Homeowner can't afford a lawyer, then file a Motion to Oppose
Summary Judgment, an Affidavit and/or Memorandum of Law to
Support Motion to Oppose Summary Judgement. Start to research
on Bankruptcy options at the same time.
REMOVE THE BLOCKS FROM THE BASE OF THE PYRAMIDS AND THE
ENSLAVING POWER THE PHAROHS HAVE OVER US WILL CRUMBLE
& FALL
Docket(s)
Image Effective Date Count Description
4/12/2007 ORDR GRNTING MT FOR ATTY‘S FEES & COSTS & FOR
MULTIPLIER RECVD- FWD TO FORECLOSURE CLERK
4/12/2007 ORDER GRANTING DEFEN MO/FOR ATTYY‘S FEES AND
COSR AND MULTIPLIER
4/12/2007 ORDER GRANT DEF MTN FOR ATTRNY FEE/COSTS, OR
BK 13931 PG 477 (6)
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