8/2/2019 Answer.counterclaims.reservationofRights.3.14

1/1

examining the note and may have been printed in dark enough ink to bleed through as a reverse

image on the face of the second page of the computer generated forgery in the hands of her

attorney. Affirmatively alleges, upon personal knowledge, could see the black image on the

reverse side of the computer-generated note when she was looking at the front of Exhibit B.

Affirmatively alleges, upon personal knowledge, that she observed her attorney, in the course of

examining the note, applied her moistened finger to test the black ink purported endorsement inblank apparently printed with computer ink and that the ink did not bleed onto the page.

Observing this preliminary examination, she heard Ms. Demakopoulus state to her attorney that

the reason that the ink imprint did not react to the moisture test was that the document is old.

Affirmatively alleges, that the purported Defendant has a banking, real estate and securities

background, has worked in the financial industry since 1983 (with periodic leaves of absence to

care for her children) and is presently a commercial lender. The purported Defendant has

handled countless financial instruments and can state to a certainty that Exhibit A, which

purports to be an original mortgage note purported executed in 2004 and on bright white paper

is not appropriately aged. The purported Defendant declines to provide the smoking gun

evidence of machine known to her for fear that the computer generated forgery will be modified

to conform to her proof, and will seek a protective order from having to provide that informationuntil Exhibit B is produced for scientific examination and inspection. She will state, at this

time, that she will know immediately if the computer generated forgery displayed to her attorney

and in her plain view on February 23, 2012 has been modified or altered to conform to her

statements upon personal knowledge herein. She believes, from observing Ms. Demakopoulos

reaction to her attorneys statement that the mortgage note as not the original mortgage note

that Ms. Demakopoulos was unaware that she was and may still be unaware that she is holding a

forged document in her case file and demands that Exhibit B be surrendered to the Waukesha

County Sheriffs custody pending scientific examination and testing. Because Ms.

Demakopoulos is a chain of custody witness, she and BLOOMER PETERMAN, S.C. must be

disqualified from acting as counsel for the purported Plaintiff in this matter under the Wisconsin

Code of Professional Conduct SCR 20:3.7. Further, the law firm of BLOMMER PETERMAN,S.C. is disqualified because one of the lawyers associated with the firm created the mortgage

assignment from MERS to the Bank of New York and Attorney J. Timothy Lovett is a material

witness to the creation of the void instrument upon which the Plaintiff(s) rely in attempting to

create the appearance of standing before the Court. (See paragraphs 2., 5. and 8., below.)

Continuously reserving her objection to the subject matter jurisdiction of this Court for the lack

of standing of purported Plaintiff for all the reasons stated above, the purported Defendant states

unequivocally that standing to sue cannot be founded upon a forged document, a business name

without legal capacity has no standing to enter into contracts, loan money, receive payments or

sue for performance. Bank of America, N.A., therefore, has falsely claimed that it collects and

tracks payments, distributes collection and pursues legal action when necessary because it has

not pleaded that it owns or holds the specific instrument identified as Exhibit B and this case

must be dismissed as a matter of law.

2. Denies paragraph 2 and affirmatively alleges, upon information and belief, that Bank

of New York Mellon f/k/a Bank of New York does not appear on its own behalf as trustee for

3