US DISTRICT COURT Subramaniam v D. Andrew Beal, JPMorgan Chase, James Dimon

COMPLAINT Page 1 of 37 Revised: July 20, 2010

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON PORTLAND DIVISION

Denise Subramaniam, pro se Civil Case No. ____________ “ex rel.” on behalf of the Unites States (to be assigned by Clerk of the Court) (Enter Full name of plaintiff(s))

Plaintiff(s), COMPLAINT Jury Trial Demanded

v. Yes No D. Andrew Beal, Jacob Cherner, Molly Curl, MGC Mortgage, LVN Corporation, William Mynatt, David Allison, Ian Benedict, Mary Przybyla, Dovenmuehle Mortgage Inc., Beal Bank, Beal FInancial, et al; Ally Financial et al, Bruce Pardis, Tom Donatacci, Michael Carpenter, Mark F. Bole, Masse Adjety, Rosalyn Hall, Mary K. Olson, Diane M. Meistad, Minnesota Office of Secretary of State, Laura Herrera, Texas Office of the Secretary of State, Greg Sullins, Docx LLC, IBM Lender Business Process Services Inc, Seterus Inc. Virginia M Rometty, IBM et al, Lloyd Craig Blankfein, Goldman Sachs & Co. et al, Fidelity National Title Company, Fidelity National Financial, et al Litton Loan Servicing LP, Ocwen Financial Corporation et al, Debra Lyman, Betty Wright, Larry B. Litton Sr., Larry B. Litton Jr., Quality Loan Service et al, Suzanne Eaton, John Kee, Pamela Campbell, Cal-Western Reconveyance Corporation et al, Prommis Solutions et al, Lorrie Womack, Monica Mora, Tina Jones, Josh Magnuson, Stephen A. Feinberg, John W. Snow, Cerberus Capital Management L.P., Greg Sullins, Sanford I. Weill, Phil Gramm, James E. Cayne, James Dimon, EMC Mortage, Bear Stearns, JP Morgan Chase et al, Kevin R. McCarthy, Theresa Russell, Stephen Routh, David E. Fennell, Northwest Trustee Services Inc et al, James Danforth Quayle, CT Corporation, CT Corporation Systems, Nancy McKinstry, Wolters Kluwer et al; Bernadette McDonnell; Lori Beddard; B. Bernadine; Enedina O. Sanchez; KATU TV Portland, American Broadcasting Company (ABC); Unnamed/yet unknown parties (Enter Full name of ALL defendant(s))

Defendant(s),

X


I. PARTIES

List your name, address, and telephone number below, and the same information for each defendant. Make sure that the defendant(s) listed below are identical to those contained in the caption of the complaint. Attach additional sheets of paper if necessary.

Plaintiff Name: _________________________________________________________

Street Address: _____________________________________________

City, State & Zip Code: _______________________________________

Telephone No. ______________________________________________

Defendant No. 1 Name: _________________________________________________________

Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________

Denise Subramaniam

13865 SW Walker Rd

Beaverton, OR 97005

503-764-5300

D. Andrew Beal

6000 Legacy Drive Plano, TX 75024

Plano, TX 75024

6000 Legacy Drive

469-467-5000

469-467-5000

Jacob Cherner

Molly Curl


469-467-5000

Ian Benedict


469-467-5000

Beal Bank, Beal Financial, et al


469-467-5000



Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________

City, State & Zip Code: ________________________________________

Telephone No. ______________________________________________

David Allison

1 Corporate Drive, Suite 360

Lake Zurich, IL 60047

847-550-7300

200 Renaissance Court

Detroit, MI 48243

313-556-5000 or 646-781-2692

Plano, TX 75024

6000 Legacy Drive

469-467-5000

MGC Mortgage, et al



847-550-7550

LVN Corporation, et al



847-550-7400

William A. Mynatt, Jr.

Dovenmuehle Mortgage Inc., et al



847-550-7300

Mary Przybyla



847-550-7300

Ally Financial Inc., et al



Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________

Defendant No. 17 Name: __________________________________________________________

Street Address: ______________________________________________


Telephone No. ______________________________________________

Defendant No. 18 Name: ___________________________________________________________

Street Address: ______________________________________________


Telephone No. ______________________________________________

Defendant No. 19 Name: ___________________________________________________________

Street Address: ______________________________________________


Telephone No. ______________________________________________

Michael Carpenter, c/o Ally Financial Inc.

Seterus Inc., et al

14523 SW Millikan Way, Ste 200

Beaverton, OR 97005

866-578-5277

7645 Lyndale Ave. S., Suite 250

Minneapolis, MN 55423

612-230-4020

Bruce Pardis c/o Homeownership Preservation Foundation


Detroit, MI 48243

313-556-5000

Mark F. Bole, c/o Ally Financial Inc.


Detroit, MI 48243

313-556-5000

Masse Adjety c/o Ally Financial Inc.


Detroit, MI 48243

313-556-5000

14523 SW Millikan Way, Ste 200

Beaverton, OR 97005

866-578-5277

Laura Herrera, c/o Seterus Inc.

100 Beard Sawmill Rd. Suite 200

Shelton, CT 06484

203-926-5600

Tom Donatacci, c/o Clayton Holdings LLC



Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. _______________________________________________

1100 South Congress Avenue # 1E 8

512-463-5555

Laura Herrera, c/o Texas Secretary of State Notary Division

Austin, TX 78704

Diane M. Meistad, c/o Minnesota Office of the Secretary of State

60 Empire Drive, Suite 100

St Paul, MN 55103

651-296-2803

1100 South Congress Avenue # 1E 8

512-463-5555

Texas Secretary of State Notary Division

Austin, TX 78704

Mary K. Olsen, c/o Minnesota Office of the Secretary of State


St Paul, MN 55103

651-296-2803

Minnesota Office of the Secretary of State


St Paul, MN 55103

651-296-2803

875 Third Avenue

New York, NY 10022

212-891-2100

Cerberus Capital Management L.P., et al

James Danforth Quayle, c/o Cerberus Capital Management L.P.

875 Third Avenue

212-891-2100

New York, NY 10022



Street Address: ______________________________________________


Telephone No. _______________________________________________


Street Address: ______________________________________________


Telephone No. _______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________

3213 Union Power Way

Monroe, North Carolina 28110

704-288-1967

Virginia M Rometty, c/o IBM

1 New Orchard Road

Armonk, NY 10504

914-499-1900

Greg Sullins, c/o Classic Auto Rides, LLC

Stephen A. Feinberg, c/o Cerberus Capital Management L.P

875 Third Avenue

212-891-2100

New York, NY 10022

Lloyd Craig Blankfein, c/o Goldman Sachs & Co.

200 West Street

New York, NY 10282

212-902-1000

Goldman Sachs & Co.

200 West Street

New York, NY 10282

212-902-1000

Litton Loan Servicing, Ocwen Financial Corporation, et al

1661 Worthington Road, Suite 100

West Palm Beach, FL 33409

561-682-8000

John W. Snow, c/o Cerberus Capital Management L.P

875 Third Avenue

212-891-2100

New York, NY 10022



Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________

Defendant No. 38 Name: _____________________________________________________

Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________

525 East Main Street, P.O. Box 22004

El Cajon, CA 92022-9004

(619) 590-9200

Cal-Western Reconveyance Corporation, et al

Houston, TX 77027

713-960-9676, 713-839-9100, 800-548-8665

Larry B. Litton Sr. c/o Litton Loan Servicing LP

4828 Loop Central Dr.

Houston, TX 77027

713-960-9676, 713-839-9100, 800-548-8665

Larry B. Litton Jr. c/o Litton Loan Servicing LP


Houston, TX 77027

713-960-9676, 713-839-9100, 800-548-8665

Debra Lyman c/o Litton Loan Servicing LP


Houston, TX 77027

713-960-9676, 713-839-9100, 800-548-8665

Betty Wright c/o Litton Loan Servicing LP


Lorrie Womack, c/o Cal-Western Reconveyance Corporation


El Cajon, CA 92022-9004

(619) 590-9200



Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________

400 Northridge Road

Atlanta, GA 30350

800-642-0257

Tina Jones, c/o Prommis Solutions et al

400 Northridge Road

Atlanta, GA 30350

800-642-0257

Prommis Solutions, et al

Suzanne Eaton, c/o Cal-Western Reconveyance Corporation


El Cajon, CA 92022-9004

(619) 590-9200

John Kee, c/o Cal-Western Reconveyance Corporation


El Cajon, CA 92022-9004

(619) 590-9200

Pamela Campbell, c/o Cal-Western Reconveyance Corporation


El Cajon, CA 92022-9004

(619) 590-9200

Monica Mora, c/o Prommis Solutions

400 Northridge Road

Atlanta, GA 30350

800-642-0257



Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________

Defendant No. 52 Name: _________________________________________________________ Street Address: _____________________________________________


Telephone No. ______________________________________________

1177 Avenue of the Americas

New York, NY 10036

212-715-8000

James E. Cayne, c/o David S. Frankel, KRAMER LEVIN NAFTALIS & FRANKEL

13555 SE 36th St, Suite 100

Bellevue, WA 98006

425-586-1900

David E. Fennell, c/o Northwest Trustee Services Inc.

270 Park Avenue

New York, NY 10017

212-270-6000

JP Morgan Chase, et al

Josh Magnuson, c/o Prommis Solutions et al

400 Northridge Road

Atlanta, GA 30350

800-642-0257

270 Park Avenue

New York, NY 10017

212-270-6000

James Dimon, c/o JP Morgan Chase


Bellevue, WA 98006

425-586-1900

Northwest Trustee Services Inc et al, Inc


Bellevue, WA 98006

425-586-1900

Stephen Routh, c/o Northwest Trustee Services Inc et al, Inc.



Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________

2141 Fifth Ave.

San Diego, California 92101

619-645-7711, 866-645-7711

388 STATE ST, STE 420

SALEM, OR 97301

503-566-6883

Quality Loan Service Corporation, et al

CT Corporation, CT Corporation Systems, et al

2141 Fifth Ave.


619-645-7711, 866-645-7711

Kevin R McCarthy, c/o Quality Loan Service

2141 Fifth Ave.


619-645-7711, 866-645-7711

Theresa Russell, c/o Quality Loan Service


SALEM, OR 97301

503-566-6883

Nancy McKinstry , c/o CT Corporation


SALEM, OR 97301

503-566-6883

Wolters Kluwer International Holding bv, c/o CT Corporation

1150 17th St NW

Washington, DC 20036

202-862-5800

Phil Gramm, c/o American Enterprise Institute



Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: ______________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________


Street Address: _____________________________________________


Telephone No. ______________________________________________

2153 N.E. Sandy Blvd.

Portland, OR 97232

503-231-4222

KATU TV Portland, American Broadcasting Company (ABC)

601 Riverside Avenue

Jacksonville, FL 32204

904-854-8100

Fidelity National Title Company, Fidelity National Financial, et al

15 Central Park West, Sixth Floor

New York, NY 10023

212-489-1500

Sanford I. Weill

2141 Fifth Ave.


619-645-7711, 866-645-7711

B. Bernadine c/o Quality Loan Service Corporation

2141 Fifth Ave.


619-645-7711, 866-645-7711

Enedina O. Sanchez c/o Quality Loan Service Corporation



847-550-7550

Bernadette McDonnell c/o LVN Corporation



847-550-7550

Lori Beddard c/o LVN Corporation


II. JURISDICTION Federal courts are courts of limited jurisdiction. Only two types of cases can be heard in federal

court: cases involving a federal question and cases involving diversity of citizenship of the parties. A case involving the United States Constitution or federal laws or treaties is a federal question case. A case in which a citizen of one state sues a citizen of another state and the amount in damages claimed is more than $75,000 is a diversity of citizenship case. A. What is the basis for federal court jurisdiction (check all that apply)

Federal Question Diversity of Citizenship

B. If the basis for jurisdiction is Federal Question, what federal Constitutional, statutory, or

treaty right is at issue?

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

C. If the basis for jurisdiction is Diversity of Citizenship, what is the state of citizenship of

each party?

Plaintiff(s) state of citizenship ___________________________________________

Defendant(s) state(s) of citizenship _______________________________________

____________________________________________________________________

X X

12 U.S.C. 27 et seq. (RESPA); 15 U.S.C. 1601 et seq. (Consumer Credit Protection and Truth in Lending

Acts); 31 USC § 3729-3733 et seq. (Federal False Claims Act); 18 USC 47 et seq. (Fraud and False

Statements); 18 USC § 1348 et seq. (Securities and Commodities Fraud); 15 U.S.C. § 77a, et seq

(Securities Act of 1933); 18 USC Chapter 11 (Bribery, Graft, and Conflicts of Interest); 18 USC § 1961,

(Racketeer Influenced and Corrupt Organizations Act); Fifth Amendment to the United States

Constitution; The United Nation’s Universal Declaration of Human Rights; ORS § 162.065; Oregon §

164.085; Oregon § 164.172; Oregon § 164.17

Oregon

New York, Illinois, Texas, Florida, Michigan, Georgia

North Carolina, Minnesota, California, Washington, Oregon, Nederlands

Subramaniam v. Beal, Chase, Goldman Sachs Page 13 of 37


III. BACKGROUND 1

In February 2004 Plaintiff refinanced her house with People’s Choice Home Loan Inc., hereafter referred 2 to as PCHL. She agreed to terms of a 6.99% fixed rate with no early pre-payment penalty. She retained 3 considerable equity in her home. 4

Plaintiff had to leave the country for six months on a business trip. PCHL was aware of this. The closing 5 was supposed to be two weeks before her departure, but was continuously delayed by PCHL. 6

Plaintiff’s air tickets were already purchased and a postponement would be expensive, still Plaintiff 7 wanted to postpone her trip. PCHL insisted there was no need. The closing occurred on the afternoon of 8 the same day Plaintiff’s plane departed. 9

Within two months Plaintiff’s U.S. office manager sent her an urgent email; her insurance agent needed 10 her to call him immediately. He told Plaintiff EMC Mortgage, hereafter referred to as EMC was giving 11 him a difficult time over proof of home owners insurance. He said he researched EMC and had serious 12 concerns about them and asked how she got mixed up with them. 13

Plaintiff was dumbfounded. She had no idea how EMC was involved since she refinanced with PCHL. 14

After Plaintiff returned home from overseas in or around August 2004, she reviewed the mortgage 15 documents she’d signed the day she left the U.S. and discovered the terms of the mortgage had been 16 switched. The first few pages of the contract correctly stated the terms, but PCHL inserted later pages that 17 stated different terms. Due to PCHL’s delay of the closing until the same day she left the country Plaintiff 18 was in duress when she signed the mortgage contract and did not notice these changed terms. The 19 switched terms included an ARM rather than a fixed rate and an early pre-payment penalty which expired 20 in February 2006. The documents actually contain multiple terms. 21

Plaintiff phoned an attorney, but was told because six months had already passed there was nothing she 22 could do. Disgusted and feeling ashamed that she was tricked like this; Plaintiff put the mortgage contract 23 in the back of a file drawer where they were forgotten until November 2011. 24

Due to ongoing problems with EMC’s handling of Plaintiff’s payments she phoned EMC in or around 25 August 2005 and threatened to refinance her mortgage as soon as it was possible. Within days of making 26 this threat, and in spite of a phone confirmation in August 2005 that she was current on her mortgage, she 27 received a mailed notice that she was in default on her mortgage in September 2005. 28

EMC told Plaintiff she had to sign a forbearance agreement that included an extra $300/month payment to 29 make up the alleged deficiency or they would start foreclosure proceedings. Although she knew she had 30 not missed payments Plaintiff felt pressured to sign the agreement and did so, but wrote in the margins 31 that she did not agree that she had missed any payments. 32

The economy began a downturn in 2005, so to pay the extra $300/month that EMC demanded Plaintiff 33 had to stop paying her $350/month Cobra payments to retain her health insurance. 34

Plaintiff requested a full accounting of EMC’s payment history for her mortgage to reconcile with hers. 35 EMC failed to provide this. 36

Plaintiff persisted in her attempts to get EMC’s records, and in or around January 2006 she began 37 phoning EMC daily. When EMC finally returned her calls they claimed to have “sold” her mortgage to 38 GMAC. EMC provided no written communication regarding this sale or transfer as per RESPA statutes. 39

Plaintiff immediately phoned GMAC and was told they did not have her mortgage. She wrote a letter to 40 the Tom Donatacci, Vice President of GMAC to verify this. 41

Plaintiff then sought help from various government regulatory agencies only to be told that EMC was not 42 regulated. The Federal Trade Commission, FTC, was investigating EMC and Bear Stearns for violations 43



of the Fair Credit Reporting, the Fair Debt Collection Practices Acts and the Truth in Lending Act and 1 requested Plaintiff’s records regarding EMC’s handling of her mortgage. 2

The FTC later used Plaintiff’s records along with records from hundreds of thousands of other consumers 3 to file a lawsuit against EMC and Bear Stearns. In September 2008 the FTC won a $28 Million settlement 4 with EMC and Bear Stearns. The FTC sent the Plaintiff a check for $11.00, She never cashed it because it 5 made her feel as if her government just poured salt into an open wound because by this time Plaintiff had 6 suffered hundreds of thousands of dollars in damages and years of pain and suffering caused by the 7 continued stress of battling mortgage and foreclosure fraud. 8

The FTC website contains information regarding its lawsuit and the settlement with EMC and Bear 9 Stearns. It is attached as Exhibit A. 10

The FTC told Plaintiff to personally sue EMC and Bear Stearns for restitution of her damages because 11 they did not represent individual consumers. This proved impossible. From 2007 to 2010 Plaintiff 12 contacted numerous attorneys about suing EMC and Litton for damages, but was told that her case was 13 made complex by the number of times her mortgage had been “transferred” or “sold”; and that the parties 14 involved, Bear Stearns, Chase, Goldman Sachs, were “deep pockets.” It was the experience of these 15 attorneys that such defendants would use their vast wealth to delay any case brought against them and 16 would do everything possible to cause their opponents to incur huge expenses until they no longer had 17 financial resources to continue to fight. Therefore these attorneys were unwilling to take such a case on 18 contingency and told Plaintiff she’d need financial resources equal to the defendant’s for the long haul to 19 have any chance of winning against such “deep pockets” no matter how good the merits of her case. 20

In April 2006 Plaintiff received a letter from GMAC’s CEO Tom Donatacci’s office dated April 3, 2006 21 stating that they did not and never had “serviced” her mortgage. At that time the word “serviced” had no 22 meaning to Plaintiff. The letter further stated that it appeared “Homecomings Financial” was at one time 23 the “servicer” of her mortgage; and it appeared the current “servicer” was Litton Loan Servicing, 24 hereafter referred to as Litton. Plaintiff never made a single payment to “Homecomings Financial” so the 25 mention of them as a “servicer” in this letter did not convey to the Plaintiff that a “servicer” had anything 26 to do with the collection of mortgage payments. 27

The State of Oregon Department of Consumer and Business Services, one of the many government 28 regulatory agencies where Plaintiff filed complaints, received a letter from EMC dated April 18, 2006 29 stating that the Plaintiff’s mortgage was “transferred to GMAC-RFC/Homecomings (GMAC) on 30 February 9, 2006.” This letter also stated that EMC had acquired Plaintiff’s mortgage on May 1, 2004. 31

GMAC in its letter to Plaintiff failed to inform Plaintiff that Homecomings Financial was in fact a 32 division or subsidiary of GMAC. GMAC’s letter was written to deceive Plaintiff into thinking there was 33 no connection between Homecomings Financial and GMAC; and they succeeded in deceiving Plaintiff 34 because in 2006 she did not realize that the GMAC-RFC/Homecomings (GMAC) referred to in the one 35 letter was the same as the “Homecomings Financial” referred to in the other letter. 36

Why was there so much confusion regarding who “owned” Plaintiff’s mortgage between May 2004 and 37 August 2006 and to whom Plaintiff was supposed to make payments and/or where her payments went? 38

In or around October 2011 Plaintiff had a deed audit performed and discovered that GMAC and its 39 subsidiaries had fraudulently fabricated a “Substitution of Trustee” and an “Assignment of Deed of Trust” 40 and filed them with Washington County Oregon on June 28, 2006 along with a “Notice of Default and 41 Election to Sell” document. 42

These documents were fraudulently fabricated with intent to deceive Washington County Oregon and the 43 courts into believing Plaintiff’s deed of trust was legally transferred from PCHL to GMAC and/or its 44 subsidiaries and/or Litton, when in fact no such legal transfer occurred. These documents were 45



fraudulently fabricated with intent to give the appearance that GMAC and/or its subsidiaries and/or Litton 1 had a legal right to sell Plaintiff’s property, when they did not. 2

Copies of these fraudulently fabricated legal instruments/documents are contained within Exhibit B along 3 with documentary evidence that demonstrates that they were indeed fraudulently fabricated. 4

In or around May 2006 defendant Litton mailed Plaintiff a letter stating they had her mortgage and she 5 was to make payments to them. 6

Litton and/or GMAC filed a trustee’s sale notice in Washington County Oregon on June 28, 2006 on 7 Plaintiff’s property. 8

Plaintiff hired an attorney who finally was able to acquire EMC’s payment history of her loan through 9 Litton. Records produced by EMC showed scattered missed payments throughout 2004 and 2005. 10

If EMC used standard accounting practices missed payments in May 2004, July 2004, September 2004, 11 October 2004, March 2005 etc would never have been “forgotten” then suddenly “remembered” in 12 September 2005. 13

Plaintiff produced bank records and other receipts to prove through her attorney that every payment EMC 14 claimed she missed was in fact paid. Her attorney asked Litton to postpone their trustee sale to: 1.) correct 15 EMC’s inaccurate accounting of Plaintiff’s payments; 2.) correct their inaccurate credit reporting about 16 Plaintiff and; 3.) give her an accurate pay-off balance so she could refinance with a reputable lender. (At 17 that time Plaintiff was naïve enough to still believe such a thing existed.) 18

On October 10, 2006 Plaintiff’s attorney sent a letter to the three major credit reporting agencies 19 explaining that EMC’s and Litton’s reporting of Plaintiff’s payment history was in dispute and requested 20 that the inaccurate reporting of Plaintiff’s credit history by these defendants be removed from her 21 consumer credit report. The major credit reporting agencies did not do so because EMC and Litton 22 asserted their reporting of Plaintiff’s credit history was accurate. 23

Litton refused to postpone the trustee sale even though they knew Plaintiff was not in default. Plaintiff’s 24 attorney told her, “The SOBs have no intention of voluntarily postponing the trustee sale; they want to 25 steal your equity.” (In or around November 2011 Plaintiff requested a copy of this attorney’ records 26 regarding Plaintiff’s case and discovered written documentation exists to substantiate this claim.) 27

Plaintiff had considerable equity in her home, more than 60% of its market value at that time; 28 approximately $170,000. 29

With the trustee sale only a week away Plaintiff’s attorney not knowing what else to do because Plaintiff 30 had become financially drained from the ordeal herein described advised her to file for bankruptcy to 31 protect her home. 32

At that time few people knew about the graft and corruption rampant in the banking and financial 33 industry. Plaintiff did as advised, feeling defeated and that she had no choice; she’d already proved she 34 was not in default, but this didn’t change anything. What else could she do? 35

Plaintiff was forced to file Chapter 13 bankruptcy in 2006/2007 to protect her home from the fraudulent 36 foreclosure attempt hereby described. The bankruptcy remained in force until March 2010. 37

Plaintiff made mortgage payments to defendant Litton from 2006 into 2009 until she received a 38 delinquent property tax notice from Washington County Oregon. Litton failed to pay her property taxes as 39 per her mortgage escrow agreement for the 2007 to 2008 tax year. The taxes were due in June 2008. 40 Plaintiff paid the delinquent property taxes of $2,555.28 by check. 41

Plaintiff had received no communication from Litton as per Federal RESPA statutes (12 U.S.C. 27 et 42 seq.) regarding the sale or transfer of her mortgage away from them. Due to the longstanding history of 43



inaccuracy and fraud in the handling of her mortgage payments since 2004, Plaintiff’s bankruptcy 1 attorney advised her to stop making payments to Litton. 2

Litton also dropped Plaintiff homeowners insurance and she was unable to get a new policy. No insurance 3 company would underwrite her home because it had been more than six months since Litton dropped her 4 homeowner’s policy. 5

Around March 2009 MGC Mortgage, hereafter referred to as MGC, sent a letter to Plaintiff claiming they 6 had acquired her mortgage. The letter contained no information about where to make payments or how 7 the payments Plaintiff already made to the Goldman Enterprise had been applied to her mortgage. 8

Plaintiff’s attorney sent MGC a letter requesting a complete itemization of her payment history from 9 February 2004. MGC failed to reply. Plaintiff’s attorney wrote several more letters over the next few 10 months, specifically stating he was making a qualified RESPA request. RESPA provides for a 30 day 11 response period, yet MGC still failed to reply. Even Plaintiff’s Congressman wrote a letter to MGC to no 12 avail. 13

Plaintiff did an online investigation of MGC in or around May 2009 and the only information she could 14 find was that it was a securities holding company. 15

Plaintiff’s attorney finally received a reply from MGC in 2010. The financial records they provided were 16 the same false and inaccurate records provided by EMC and Litton in 2006. 17

Around the time Litton failed to pay Plaintiff’s property taxes and home owner’s insurance, MGC and 18 their cohorts fraudulently fabricated two additional “Corporate Assignment of Deed of Trust” documents 19 and filed both of them with Washington County on August 27, 2008. 20

On February 24, 2011 MGC and/or Litton and/or Cal-Western filed a “Rescission of Notice of Default” 21 documents with Washington County Oregon. This document states: “notice hereby is given that CAL-22 WESTERN RECONVEYANCE CORPORATION the undersigned trustee, does hereby rescind, cancel 23 and withdraw said notice of default and election to sell; such trust deed and all obligations secured 24 thereby hereby are reinstated and shall remain in force and effect the same as if no acceleration had 25 occurred and as if said notice of default had not been given…” 26

Yet on April 22 2011 MGC and their cohorts filed it a fraudulently fabricated “Appointment of Successor 27 Trustee” document and another “Notice of Default and Election to Sell” document with Washington 28 County Oregon. 29

The horrific stress Plaintiff felt when she thought about unjustly losing her home caused her physical and 30 mental health to become so deteriorated that throughout 2010 and 2011 she spent weeks and months in 31 bed too ill to function. Plaintiff was so ill she could do little to respond to the looming trustee’s sale. 32 While sick Plaintiff lost track of the time and she completely forgot the date trustee’s sale. When she 33 looked it up she discovered it was days away. In a panic she phoned her bankruptcy attorney who 34 immediately filed a Chapter 7 bankruptcy to prevent the fraudulent sale of her home on Plaintiff’s 35 birthday September 16, 2011. 36

In or around October 2011 Plaintiff connected with victim support groups and was encouraged to gather 37 all the records pertaining to her years of struggle with her mortgage into one place and review them 38 carefully. This is also when she ordered a preliminary deed audit. 39

In May 2012, MGC and two other Beal subsidiaries, defendants LVN Corporation, hereafter referred to as 40 LVN, and Dovenmuehle Mortgage, Inc., hereafter referred to as Dovenmuehle, along with defendants 41 Northwest Trustee Services, Inc., hereafter referred to as NTS fraudulently fabricated a new set of deed of 42 trustee documents and filed them in Washington County Oregon to once again initiate a fraudulent 43 trustee’s sale of Plaintiff’s home in September 2012. 44



IV. DEFENDANTS 1

Summary of the 2006 Fraudulent Foreclosure Attempt and Defendants Involved 2

The fraudulently fabricated legal instruments filed with Washington County Oregon on June 28, 2006 3 were produced by the defendants named below working in collusion with each other. 4

They are all signed by proven Litton robo-signers claiming to be top executive officers of financial 5 institutions where they were neither employed nor held such top executive positions. Defendant Debra 6 Lyman signed the substitution of trustee for Plaintiff’s property as the Vice President of Homecomings 7 Financial Network Inc. with a date of March 18, 2006. 8

On February10, 2006 she signed another foreclosure document as the Vice President of Deutche Bank 9 National Trust Company, as Trustee for a MBS Trust. 10

On November 28, 2005 Debra Lyman signed as Vice President Litton Loan Servicing, LC, as Attorney-11 in-fact for The Providnet Bank. The document was filed with Pottawattamie County, IA, on 1/6/2006 and 12 was a Quit Claim Deed in favor of Deutsche Bank National Trust Company as Trustee for a Morgan 13 Stanley MBS Trust. 14

On July 30, 2010 Debra Lyman signed as Assistant Secretary MERS Inc, solely as nominee for Counsil 15 Bluffs Savings Bank a Division of Carroll County State Bank. The document was filed with 16 Pottawattamie County, IA on 9/21/2010 The document was a Quit Claim Deed in favor of Litton as 17 Trustee for a Morgan Stanley MBS Trust. 18

Defendant Debra Lyman’s 2011 LinkedIn profile shows her as a Litton employee. Her Spoke profile also 19 indentifies her as a Litton employee. And she is on a list of authorized signers and attorneys-of-fact for 20 Litton; and she is on lists of known robo-signers for Litton. 21

Defendant Laura Herrera, or a Doe forging her signature as a Notary commissioned in Harris County 22 Texas, notarized the substitution of trustee for Plaintiff’s property, stating that Debra Lyman “personally 23 appeared” before her, yet the date by her signature is March 20, 2006 two days after Debra Lyman signed 24 the document. Laura Herrera notarized numerous foreclosure documents and the signatures appear to be 25 made by different people. 26

Plaintiff attempted to validate is notarization with a copy of Notary Laura Herrera’s log book page for 27 March 20, 2006. She sent a certified letter requesting such to the address on file for Laura Herrera with 28 the Texas Secretary of State Notary Division as instructed, the letter was returned as undeliverable. The 29 Texas Secretary of State Notary Division told Plaintiff that Texas requires their notaries to keep log 30 books, if a commission is not renewed the notary is supposed to send their office the log, but no legal 31 requirement exists for them to do so; consequently many do not. Plaintiff checked with the Harris County 32 Clerk’s warehouse and Laura Herrara’s logs have not been turned in to them. Notaries are commissioned 33 for four years at a time, and no further validation is done regarding the information provided by the 34 person being commissioned. Plaintiff was able to secure Laura Herrara’s 2008 notary application. The 35 signature is similar to the used to notarize the substitution of trustee for Plaintiff’s property; but enough 36 differences exist to indicate someone may have forged the signature. 37

Plaintiff confirmed that a Laura Herrera works for Seterus Inc., formerly named IBM Lender Business 38 Process Services Inc., hereafter referred to as LBP, located in Beaverton Oregon. However without court 39 subpoenas to release the Texas notary’s social security number and the Seterus employee’s social security 40 number it is impossible to determine if they are in fact the same person. 41

Lax policies at the Texas Secretary of State Notary Division make it difficult for consumers who have 42 been victimized and have suffered damages caused by perjured or forged notarization of legal documents, 43 such as those used in foreclosures, including the Plaintiff’s to investigate and obtain documentation to 44 prove fraud in a court. Texas does not require the notary’s commission number to appear on their stamp 45



(notaries have their own stamps made at any office supply store, like Office Depot) and this also make it 1 more difficult to trace a particular notary. No law requires notaries to turn in their logs when their 2 commission expires. 3

Statements on these documents claim they are prepared by First American Title Insurance Company in 4 Portland Oregon, when in fact they were not. The State Manager, at First American Title verified in 5 writing on November 2, 2011 that it was highly unlikely his company prepared the documents. 6 Defendants gleaned First American Title’s name from the original Deed of Trust filed in March 2004 to 7 give their fraudulent deed documents the look of authenticity with intent to deceive Plaintiff, government 8 officials and the courts. 9

The deed assignment was similarly fabricated with apparently forged signatures; and or signatures of 10 people claiming to be employed in an executive role when they were not. Unfortunately it was not 11 possible to trace the current employment or whereabouts of these signers. 12

Copies of these fraudulently fabricated legal instruments are attached as part of Exhibit B. 13

Defendant EMC was a direct subsidiary of The Bear Stearns Companies, Inc. (i.e. defendant Bear Stearns 14 et al). In 2008 JP Morgan Chase, hereafter referred to as Chase, bought Bear Stearns. Chase thus became 15 the ultimate corporate parent of EMC. Chase is the successor in interest to Bear Sterns and is jointly and 16 severally liable for the misstatements and omissions of material fact and fraud alleged herein. 17

Defendant James (Jamie) Dimon is the chairman, president and chief executive officer of JPMorgan 18 Chase. Dimon has also served as a “class A director” of the Board of Directors of the New York Federal 19 Reserve since January 2007. Jamie Dimon has worked and continually works to undermine financial 20 reforms and permit continued de-regulation of our banking and financial intuitions; additionally Chase 21 pays million to billions of dollars to lobbyists for this purpose; such de-regulation has caused Plaintiff 22 excessive personal harm and financial damages. This group of defendants referred to herein and in the 23 previous paragraph are hereafter referred to collectively as the Chase Enterprise. 24

Homecomings Financial, LLC was formerly known as Homecomings Financial Network, Inc. and is/was 25 based in Minneapolis, Minnesota. Homecomings Financial, LLC is/was a subsidiary of GMAC ResCap, 26 Inc. GMAC ResCap (Residential Capital) was part of GMAC which was then taken over by Ally 27 Financial Inc. Its subsidiaries include GMAC Mortgage. 28

Defendant Ally Financial Inc. (formerly GMAC Inc.), hereafter referred to as Ally, is the successor in 29 interest to GMAC and all its afore named subsidiaries and is jointly and severally liable for the 30 misstatements and omissions of material fact and fraud alleged herein. 31

Tom Donatacci, was the former Vice President of GMAC and Senior Vice President Subservicing, 32 GMAC ResCap. Michael A. Carpenter and Mark F. Bole are/were executive officers for GMAC. Michael 33 A. Carpenter is the CEO of Ally. Bruce Pardis was the CEO of Homecomings Financial, LLC, f/k/a 34 Homecomings Financial Network, Inc. Masse Adjety and Betty Wright are/were employed by GMAC 35 and/or their subsidiaries or predecessors. In 2006 General Motors sold 50% ownership of GMAC to 36 defendant Cerberus Capital Management L.P., hereafter referred to as Cerberus. 37

Defendants former Vice President J. Danforth Quayle, Stephen A. Feinberg and John W. Snow, former 38 Treasury Secretary under former President George W. Bush, are executive officers and/or board members 39 of Cerberus as well as investors in Cerberus. They along with unknown Cerberus investors have worked 40 and continually work with reverently to undermine financial reforms and permit continued de-regulation 41 of our banking and financial intuitions; and such de-regulation has caused Plaintiff excessive personal 42 harm and financial damages. This group of defendants will hereafter be collectively referred to the 43 Ally/GMAC/Cerberus Enterprise. 44

Defendant Litton Loan Servicing LP was a direct subsidiary of defendant Goldman Sachs & Co. 45 Defendant Lloyd Craig Blankfein has been the CEO of Goldman Sachs since May 31, 2006. Defendants 46



Larry B. Litton Sr., and Larry B. Litton Jr. are senior executive officers at Litton Loan Servicing LP. 1 Defendants Debra Lyman and Betty Wright are infamous Litton robo-signers. 2

In September 2011 Goldman Sachs sold Litton to Ocwen Financial Corporation with reprimands from 3 government regulators because Goldman Sachs was attempting to free themselves of liability for Litton’s 4 wrongdoings which had come under the scrutiny of government regulators. Goldman Sachs paid and 5 continues to pay multi-billions of dollars yearly to lobbyists to undermine financial reforms and permit 6 continued de-regulation of our banking and financial intuitions; and such de-regulation has caused 7 Plaintiff excessive personal harm and financial damages. This group of defendants will hereafter be 8 collectively referred to as the Goldman Enterprise. 9

The fraudulently fabricated deed of trust documents filed in 2006 were prepared by defendants Fidelity 10 National Title Company and Cal-Western Reconveyance Corporation, hereafter referred to as Cal-11 Western; and Docx LLC, also named IBM Lender Business Process Services Inc, and now re-named 12 Seterus Inc. (The still commit fraud when preparing foreclosure documents; they change their names 13 frequently, but not their criminal practices.) 14

Fidelity National Title Group (FNTG) is a subsidiary of Fidelity National Financial, hereafter referred to 15 as Fidelity. The FNTG website claims that the group underwriters issue approximately half of the title 16 insurance contracts in the United States. Although LSI Title Company of Oregon, LLC, hereafter referred 17 to as LSI wasn’t named on a fraudulently fabricated foreclosure document until 2011, the Oregon 18 Secretary of State Corporation Division records show the address for LSI as 601 Riverside Avenue 19 Jacksonville, FL 32204. This is the corporate address for Fidelity National Financial; so they are also a 20 subsidiary of Fidelity. LSI’s Oregon Corporation Registry number is 238928-96 and its “REGISTERED 21 AGENT” is CT Corporation. 22

Seterus Inc.et al, formerly LBP, formerly DocX, is one of the largest trustee companies in the nation. The 23 parent corporation of LBP is IBM. The CEO of IBM is defendant Virginia M Rometty. Defendant Greg 24 Sullins was Executive Director of IBM Lender Business Process Services, Inc. and a Member of Board 25 for IBM Lender Business Process Services, Inc. This referenced group of defendants will hereafter be 26 referred to collectively as the IBM/LBP/Fidelity Enterprise. 27

Cal-Western is a Prommis Solutions company, according to Prommis’ website, http://www.prommis.com, 28 which states that Cal-Western is: “One of the largest trustee companies in the nation, Cal-Western 29 Reconveyance Corporation, a subsidiary of Prommis Solutions provides non-judicial foreclosure services 30 to mortgage servicers, investors and law firms in Alaska, Arizona, California, Hawaii, Idaho, Nevada, 31 Oregon, Texas, Utah & Washington.” 32

Defendants Monica Mora, Tina Jones, Josh Magnuson, Suzanne Eaton, John Kee are executive officers of 33 Cal-Western and Prommis. The group of above named defendants will hereafter be referred to 34 collectively as the Prommis Enterprise. 35

Summary of the 2008 Fraudulent Assignment of Deed of Trust and Defendants Involved 36

On August 27, 2008 two additional fraudulently fabricated “Corporate Assignment of Deed of Trust” 37 documents were filed with Washington County by MGC and their cohorts. These fraudulently fabricated 38 documents were signed by defendants Masse Adjetey, Mary K. Olson, Betty Wright and Diane M. 39 Meistad. 40

Lax policies at the Minnesota Secretary of State Notary Division, just like with the Texas Secretary of 41 State Notary Division make it difficult for consumers who have been victimized and have suffered 42 damages caused by perjured or forged notarization of legal documents, such as those used in foreclosures, 43 including the Plaintiff’s to investigate and obtain documentation to prove fraud in a court. Due to these 44 lax policies it was impossible for Plaintiff to obtain an official signature for Minnesota notaries Mary K. 45 Olson and Diane M. Meistad for authentication. 46

http://www.prommis.com/�



Defendant MGC Mortgage is owned by defendant D. Andrew Beal (Andy Beal). Andy Beal is a Texas 1 billionaire with close ties to both former Presidents Bush and former Vice President Richard Bruce 2 "Dick" Cheney. Andy Beal is also a renowned international gambler and tax evader. He along with 3 defendants Jacob Cherner, Molly Curl, William Mynatt, David Allison hold top executive offices for Beal 4 Bank, MGC, LVN, and Dovenmuehle. This referenced group of defendants is hereafter referred to 5 collectively as the Beal Enterprise. 6

The Beal Enterprise has had thousands of “affiliated” business entities and/or subsidiaries created for as 7 subsidiaries or other related business entities by defendants CT Corporation and/or CT Corporation 8 Systems. 9

Summary of the 2011 fraudulent foreclosure attempt and defendants involved 10

The fraudulently fabricated Rescission of Notice of Default filed with Washington County Oregon on 11 February 24, 2011 was signed by defendants Pamela Campbell and Rosalyn Hall. These defendants 12 committed perjury and/or forgery and other acts of fraud in preparing these documents in behalf of 13 defendants the Goldman Enterprise and the Beal Enterprise. 14

The fraudulently fabricated “Appointment of Successor Trustee” filed with Washington County Oregon 15 on April 22, 2011 naming LSI as the “Successor Trustee” was signed by defendants Bernadette 16 McDonnell and Lori Beddard; and the “Notice of Default and Election to Sell” also filed with 17 Washington County Oregon on April 22, 2011 was signed by defendants B. Bernadine and Enedina O. 18 Sanchez in behalf of Quality Loan Service Corporation, hereafter referred to as QLS. 19

QLS, is an Arizona corporation (File Number: F-0806418-6) and has listed as its foreign address: 2141 20 5TH AVE, SAN DIEGO, CA 92101. This is the same address stated on the foreclosure document 21 described below. 22

The President and CEO of QLS is defendant Kevin R. McCarthy. The Chairman of QLS is Thomas J. 23 Holthus. The Vice President of QLS is 24

The Beal Enterprise conspired and colluded with defendants QLS and LSI to fraudulently fabricate these 25 above named documents. 26

As with the earlier deed of trust documents filed with Washington County, the documents are signed by 27 proven robo-signers claiming to be top executive officers of financial institutions where they were neither 28 employed nor held such top executive positions. These documents were fraudulently notarized by 29 individuals who were not the commissioned notary and/or by notaries committing perjury. These 30 documents make additional false claims intended to give the appearance of authenticity with intent to 31 defraud Plaintiff, Oregon government officials and courts. Copies of these fraudulently fabricated legal 32 instruments/documents are also included in Exhibit B. 33

Defendants involved in the 2012 active fraudulent foreclosure 34

The Beal Enterprise was the primary beneficiary of this fraudulent foreclosure attempt. 35

The Beal Enterprise again colluded and conspired with other named defendants to fraudulently fabricate a 36 new set of deed of trustee documents and file them in Washington County Oregon to once again initiate a 37 fraudulent trustee’s sale of Plaintiff’s home. 38

The named trustees and/or servicers and/or preparers in this fraudulent foreclosure attempt are: 1) LIS; 2) 39 QLS; and 3) NTS. 40

Defendant David Fennell, a lawyer, is a principal owner of NTS, which by its own account has handled 41 more than 250,000 foreclosures. He along with defendant Stephen Routh, also an attorney, and a principal 42 owner of NTS, created numerous “affiliated” companies for the purpose of deceiving and defrauding 43 homeowners, including the Plaintiff; government agencies, including Washington County Oregon; the 44



courts; and law enforcement into believing they have a legal right to foreclose on real properties in behalf 1 of their clients when they in fact do not. 2

Defendants David Fennell, Stephen Routh and NTS, hereafter referred to collectively as the NTS 3 Enterprise. 4

Numerous “affiliated” business entities and subsidiaries have been created for the NTS Enterprise by 5 defendants CT Corporation and/or CT Corporation Systems. Just like with NTS, LSI, and the 6 LBP/Fidelity Enterprise and the Beal Enterprise and other defendants in this complaint have had 7 numerous “affiliated” business entities and subsidiaries created for them by defendants CT Corporation 8 and/or CT Corporation Systems 9

CT Corporation provides a service that clouds transparency and allows individuals, corporations and other 10 business entities who want to hide their identity as an owner of and/or their involvement with other 11 business entities to do so easily. 12

Companies that intend to commit fraud or engage in illegal activities, such as money laundering and tax 13 evasion are much more likely to use such services than honest business owners with nothing to hide. 14

The corporate parent of CT Corporation and/or CT Corporation Systems is Wolters Kluwer, Nederland 15 bv, Wolters Kluwer International Holding bv, and Wolters Kluwer et al. Wolters Kluwer is the largest 16 investment firm in the world. Defendant Nancy McKinstry is the CEO of Wolters Kluwer. This group of 17 defendants is hereafter referred to collectively as the CT Enterprise. 18

All these defendants conspired and colluded with each other to deceive and defraud the Plaintiff, 19 Washington County Oregon, the courts and law enforcement; and by doing so caused Plaintiff significant 20 financial damages and personal injury beginning in 2006 and continuing into the present. 21

Furthermore they have done the same with hundreds of thousands of other U.S. homeowners, and have 22 turned their banks and financial institutions into criminal enterprises as defined by 18 USC § 1961, the 23 Racketeer Influenced and Corrupt Organizations Act. These defendants unjustly enrich themselves 24 through their criminal activities with no concern for the horrendous personal injury they cause their 25 victims. 26



IV. STATEMENT OF CLAIMS 1

Claim I 2

State here as briefly as possible the facts of your case. Describe how each defendant was involved, when 3 the conduct occurred, and any injuries you have suffered as a result. It is not necessary to give any legal arguments 4 or cite any cases or statutes. 5

The Oregon Trust Deed Act, ORS 86.735(1), requires certain statutory requirements be met before a 6 foreclosure and trustee's sale can take place. Not only must the original trust deed be recorded, but all 7 successive assignments of that trust deed, must be recorded as well. Without this “chain of title,” there is 8 no way to know if the entity conducting the foreclosure has any right to do so. Without knowing the 9 “genealogy” of the entire loan (i.e. who had owned it), from start to finish, it is impossible to know who 10 has the legal right of foreclosure today. 11

In or around November 2011 Plaintiff discovered that the Goldman Enterprise and/or the Prommis 12 Enterprise had no legal standing to foreclose on her deed of trust in 2006. 13

Only the original deed of trust on Plaintiff’s property filed by PCHL on March 1, 2004, in Washington 14 County, Oregon, as record number 2004-019937 is legally valid. All subsequent assignments, substitution 15 of trustee documents and trustee sale notices filed after March 1, 2004 have been fraudulently fabricated 16 with intent to deceive and are therefore invalid and void by law. 17

No assignment of deed of trust was ever filed from PCHL to EMC or its corporate parent, Bear Stearns. 18 This constitutes a break in the “chain of title.” EMC had no legal right to “sell” Plaintiff’s deed of trust 19 when no legal transfer occurred from PCHL to EMC. 20

PCHL was the only legal beneficiary, besides the Plaintiff, of said deed of trust. PCHL filed Chapter 11 in 21 March 2007 and the company was dissolved shortly thereafter. Therefore Plaintiff and her heirs are the 22 only remaining beneficiaries of the deed of trust on her property. 23

All the fraudulently fabricated foreclosure documents filed with Washington County are signed by 24 infamous robo-signers claiming to be top executive officers of financial institutions where they were 25 neither employed nor held such top executive positions. These documents were fraudulently notarized by 26 individuals who were not the commissioned notary and/or by notaries committing perjury. These 27 documents make additional false claims intended to give the appearance of authenticity with intent to 28 defraud Plaintiff, Oregon government officials and courts. 29

Robo-signed falsifications ARE MEANT FOR USE IN COURT, whether or not a State has judicial or 30 non- judicial foreclosures. A necessary purpose for these documents, AFTER the non judicial foreclosure, 31 is the eviction of the rightful owners afterward. Even when foreclosures are non-judicial, evictions 32 afterwards still are conducted in court. The process moves quickly as these foreclosures are most often 33 "rubber stamped" by skeptical judges causing American citizens to be wrongly and criminally evicted 34 from their homes. Once these documents make it into court, the bank officers and their lawyers become 35 guilty of FELONIES. 36

The signature of a qualified bank or mortgage official on legal documents such as these is supposed to 37 guarantee that the information they contain is accurate. The paper trail that ensures a legal chain of title 38 on a property has been the backbone of U.S. property ownership for more than 300 years. 39

The "robo-signing of affidavits and assignments of mortgage and all other mortgage foreclosure 40 documents that began to appear in public records after the year 2000 served to cover up the fact that loan 41 servicers cannot demonstrate the facts required to conduct a lawful foreclosure. Robo-signers who sign 42 off on loans without review commit fraud by claiming knowledge of a financial matter of which they had 43 no personal knowledge. 44



Notarization is a recording requirement for many of these documents. These documents are not 1 recordable without good notarization. The reason these documents are notarized in the first place is 2 because otherwise they will not be accepted by the county recorder. 3

Robo-signers are illegal because fraud cannot be the basis of clear title; trustee's deeds following robo-4 signed sales are void as a matter of law. Notarization done with deliberate perjury and forgery, as was 5 done in Plaintiff’s case and in many hundreds of thousands of other cases, is FRAUD. A notary who 6 helps commit real estate fraud is liable for damages. 7

Clear title may not derive from a fraud (including a bona fide purchaser for value). 8

In the case of a fraudulent transaction the law is well settled. Numerous authorities have established the 9 rule that an instrument wholly void, such as an undelivered deed, a forged instrument, or a deed in blank, 10 cannot be made the foundation of a good title, even under the equitable doctrine of bona fide purchase. 11

Consequently, the fact that a purchaser acted in good faith in dealing with persons who apparently held 12 legal title, when they in fact did not, is not in itself sufficient basis for relief. 13

It is the general rule that courts have power to vacate a foreclosure sale where there has been fraud in the 14 procurement of the foreclosure decree or where the sale has been improperly, unfairly or unlawfully 15 conducted, or is tainted by fraud, or where there has been such a mistake that to allow it to stand would be 16 inequitable to purchaser and parties. 17

Hence, if forged Robo-signed signatures are used to obtain the foreclosure, it CERTAINLY makes a 18 difference in non-judicial foreclosure states, like Oregon, as well as in judicial states. 19

Therefore, neither the Ally/GMAC/Cerberus Enterprise, nor the Goldman Enterprise had legal standing to 20 foreclose on Plaintiff’s deed of trust in 2006. Nor did they have legal standing to “sell” a deed of trust on 21 Plaintiff’s property to the Beal Enterprise. Nor did they ever have any legal right to collect payments from 22 Plaintiff. 23

The Beal Enterprise had no legal standing to foreclose on Plaintiff’s deed of trust in 2011 and still has no 24 legal standing to do so in 2012 because none of the transfers or assignment of trust deed, substitution of 25 trustee, or notice of default, or notice of intent to sell instruments filed with Washington County by their 26 predecessors were legal. 27

The defendants named in Plaintiff’s complaint are plaintiffs in eviction cases following successful 28 foreclosures. When such foreclosures are achieved through use of fraud then the Doctrine of Unclean 29 Hands provides that plaintiff's misconduct in a matter before a court makes his hands "unclean" and he 30 may not hold with them the pristine remedy of injunctive relief. The unclean hands rule requires that the 31 plaintiff not cheat, and behave fairly. The plaintiff must come into court with clean hands, and keep them 32 clean, or he or she will be denied relief, regardless of the merits of the claim. 33

Verified eviction complaints, perjured motions for summary judgment, and all other eviction paperwork 34 after robo signed non judicial foreclosures are illegal and void. The paper work itself is void. The sale is 35 void. 36

The only way to clean up the hundreds of thousands of effected titles is through litigation, because even 37 now the big banks and financial institutions, their subsidiaries and cohorts (all defendants named in this 38 case) will simply not do the right thing of their own accord. 39

Contract breach nullifies the contract 40

Even if the deed of trust assignments in Plaintiff’s case were legal, and they clearly are not, any mortgage 41 contract that once existed between PCHL and the Plaintiff was breached long ago by MGC’s predecessors 42 and in such an egregious manner as to make that contract null and void. 43



A mortgage is a contract; and as with all contracts it carries with it an expectation of performance by both 1 parties. Every mortgager or borrower enters into a loan or mortgage contract with the expectation that 2 when he/she makes payments the mortgagee or lender will properly account for those payments and apply 3 them to the loan principal. If the mortgagee/lender makes a mistake and the borrower proves the lender 4 made a mistake, the borrower has the reasonable expectation that the lender will correct the mistake. This 5 did not happen in Plaintiff’s case. 6

Plaintiff in 2006 proved to EMC’s self proclaimed successor, Litton, that she did not miss any payments 7 and was not in default; yet EMC and Litton refused to correct their mistakes and postpone their trustee’s 8 sale in 2006. 9

Every mortgager or borrower enters into a loan or mortgage contract that includes an escrow agreement 10 with the expectation that the mortgagee or lender will pay the property taxes and home owner’s insurance 11 on time. This did not happen in Plaintiff’s case. Litton defaulted on Plaintiff’s property taxes and caused 12 her to be put into a situation where she was thereafter unable to insure her property. 13

FURTHERMORE defendants’ refusal to correct their mistakes caused Plaintiff to suffer significant 14 financial damages and personal injury. Restitution for the financial damages thus caused to the Plaintiff 15 by the defendants far exceeds any amount the defendants might claim against her had the contract not 16 been made null and void by their breach. 17

Claim II 18

Willful Destruction of Plaintiff’s Consumer Credit for Unjust Financial Gain 19

Plaintiff’s high equity value in her home in 2006 was not the only reason defendants “had no incentive” to 20 right the wrong they perpetrated against her. Plaintiff recently learned that her credit was willfully 21 damaged by defendants the Chase Enterprise, the Ally/GMAC/Cerberus Enterprise and the Goldman 22 Enterprise and their co-conspirators because the value of a mortgage backed security (MBS) is based on 23 an average. Wall Street banks needed to include a few high value mortgages in each MBS that included 24 mostly toxic loans to skew its value to deceive investors. To do this they targeted senior homeowners 25 with a lot of equity in their homes, including the Plaintiff. 26

Once these high value mortgages are included in a MBS pool banks need to prevent them from leaving 27 the pool through refinance or early payoff; hence defendants were highly motivated to make fraudulent 28 claims of missed payments; create artificially inflated payoff balances through exorbitant and frivolous 29 fees; and to abuse consumer credit reporting by providing false negative reporting to prevent these older 30 homeowners, including the Plaintiff, from refinancing their mortgage or being able to sell their homes. 31 This is a violation of 15 U.S.C. 1601 et seq., the Consumer Credit Protection and Truth in Lending Acts. 32

Furthermore defendants the Chase Enterprise, the Ally/GMAC/Cerberus Enterprise, the Goldman 33 Enterprise, the Beal Enterprise and their co-conspirators had incentive to fraudulently claim Plaintiff was 34 in default on her mortgage so they could cash in on their credit default swaps. (See Claim VII.) 35

The credit reporting industry has become the modern day purveyor of one’s public reputation. It is an 36 industry created by and for banks. A person’s credit rating determines how much they pay for insurance 37 and health care, for housing, for financing and for education. It can bar a person from a job, or from 38 having a checking account. It can bar a small business owner from competing in government and private 39 bids for work contracts. It can have especially dire consequences for the success of small business 40 enterprises, and many have folded causing jobs to be lost. The resulting economic crash and economic 41 hardship it causes to Plaintiff and other formerly employed Americans further perpetrates a negative 42 effect on consumer credit reports and predicates that the defendants will ultimately force homeowners 43 into foreclosure and siege their property. They thus create the very circumstances that allow them to 44 unjustly enrich themselves. 45



The defendants and their co-conspirers have subjected Plaintiff and millions of other American citizens to 1 arbitrary interference with their privacy, their families, their employment and their homes and have 2 attacked their honor and reputation through willful abuses of the credit reporting industry. 3

False negative reporting effects consumer credit for at least seven years and bankruptcy destroys a 4 consumer’s credit for ten years. Given the Plaintiff’s age and disabilities it is impossible for her during the 5 remainder of her lifetime to regain the credit worthiness she once enjoyed before the defendants willfully 6 destroyed her credit rating. The cost of bad credit is estimated by legal professionals to be at least 7 $500,000. 8

Damaged credit has had a profound impact on the quality of Plaintiff’s life since 2006. She was unable to 9 get health insurance due to her destroyed credit. A policy with a $5,000 per year deductible would cost 10 her $1,200 per month; while a policy with a $500 per year deductible would have cost her only $350 per 11 month had her credit not been destroyed by the defendants. 12

Plaintiff paid nearly $50,000 out-of-pocket for medical care and diagnostic tests in 2008 and 2009. Had 13 her credit not been willfully destroyed by defendants she would have instead paid $9,900 for health 14 insurance premiums and deductibles during this same time. 15

Plaintiff has been diagnosed with chronic medical conditions resulting in permanent disabilities that have 16 prevented her from working since October 2009. Now since she has a pre-existing chronic condition she 17 will never be able to afford health insurance. Professional estimates for the cost of lifelong medical care 18 for someone with her medical conditions average $3 million. 19

Plaintiff has had no access to medical care or to viable treatment since October 2009 as a result she was 20 forced to endure horrific chronic pain and physical suffering, neurological dysfunction, loss of mobility, 21 deformity of joints and bones that would have been preventable if she had access to health care. 22

Plaintiff must also pay much higher premiums for automobile and homeowners insurance (if she could 23 get a homeowners policy) because the cost of all insurance is based on consumer credit reports. 24

Plaintiff is unable to finance needed repairs on her home and this causes a reduction in its fair market 25 value. She is unable to finance renewable energy solutions that would over time reduce her cost of living. 26

Plaintiff has been denied employment and her company has been denied contract opportunities because of 27 her credit willfully damaged by the defendants. Plaintiff has suffered significant loss of income from the 28 defendants’ willful destruction of their credit and from the defendants’ willful destruction of our 29 economy. 30

Claim III 31

Personal Injury caused to Plaintiff’s by Defendants’ Fraud 32

Long-term stress and anxiety caused by the constant fear of losing her home to fraud affected the 33 Plaintiff’s health. She began to suffer from frequent infections, migraines, light sensitivity, fatigue, 34 insomnia, breathing problems, acute sensitivities to chemicals, balance problems, muscle weakness, 35 chronic pain and neurological damage and problems with concentration and memory starting in late 2005 36 and continuing into the present. 37

Plaintiff’s medical records give evidence to the fact that her health was severely damaged by the intense 38 and prolonged stress caused by the fraud perpetrated against her by the defendants. 39

Her poor health affected her ability to earn income. Extended bouts with unemployment due to failing 40 health caused Plaintiff significant loss of both past and future income. 41

Defendants’ fraud and willful destruction of Plaintiff’s credit made it impossible for her to obtain health 42 insurance and effectively denied her access to medical care and as a result she was forced to endure years 43



of horrific physical pain and mental suffering, neurological dysfunction, loss of mobility, deformity of 1 joints and bones. This damage is likely not reversible and Plaintiff now suffers from permanent 2 disabilities as a result. 3

In addition defendants’ criminal activities perpetrated against the Plaintiff and against hundreds of 4 thousands of other U.S. homeowners and against the U.S. and individual State governments brought on an 5 economic crisis that caused the loss of 95% of the value of Plaintiff’s 401K retirement plan amounting to 6 a loss of approximately $150,000. 7

Financial compensation can provide Plaintiff with counseling and pain relief treatments as well as with 8 appropriate medical treatments to prevent further physical damage. Financial compensation can also ease 9 Plaintiff’s stress and provide her with medical and technological devices that can improve the quality of 10 her life and allow her to live more independently with her disabilities moving forward. 11

Claim IV 12

Plaintiff denied due process in violation of the Fifth Amendment to the United States Constitution 13

Plaintiff contacted several attorneys in 2008 through 2011 and was told it would be exceptionally difficult 14 to win a case against deep pockets like Bear Stearns/Chase and Goldman Sachs such defendants use their 15 vast wealth to increase legal costs for their adversaries beyond their ability to pay so they are thereby 16 forced them to give up their fight for justice. 17

This is a deliberate abuse of wealth acquired by these defendants through unjust enrichment to prevent the 18 homeowners they have victimized from seeking and receiving due process of the law. 19

Furthermore these defendants have abused their wealth acquired through their criminal activities and 20 resultant unjust enrichment to bribe or otherwise unduly influence members of Congress, officers or 21 employees of agencies of the United States, and other executive, legislative, or judicial branches of the 22 United States Government to enact laws that are advantageous to the continuation of their criminal 23 activities to the detriment of Plaintiff and other citizens of the United States attempting to seek legal 24 redress for their injuries; and/or to cause such government officers and agencies to look away and fail to 25 take action to hold these defendants accountable for their criminal activities. This is a violation of 18 USC 26 § 203. 27

The corruption of members of Congress, officers or employees of agencies of the United States, and other 28 executive, legislative, or judicial branches of the United States Government by these defendants has 29 become so entrenched that the United States Government is an accomplice in depriving Plaintiff and 30 countless other United States citizens of their property, without due process of law. 31

Defendant former Texas Senator Phil Gramm was the primary author and proponent of the Gramm–32 Leach–Bliley Act that effectively repealed the Glass–Steagall Act, and the Commodity Futures 33 Modernization Act of 2000 which kept derivatives transactions, including those involving credit default 34 swaps, free of government regulation. This legislation upended the sensible restraints on finance capital 35 and opened the door to the massive bank fraud that caused Plaintiff to suffer financial damage and 36 personal injury. Phil Gramm was rewarded with an executive position with USB Bank and a multi-37 million dollar salary. 38

Defendant former Vice President James Danforth Quayle (Quayle) who also served as United States 39 Congressman and Senator from the State of Indiana, was rewarded for his support of bank de-regulation 40 legislation that caused Plaintiff to suffer financial damage and personal injury with a multi-million dollar 41 per year salary as Chairman of Cerberus Global Investments LLC and Cerberus Capital Management, 42 L.P., a multi-billion dollar private equity firm. He’s also served as director of Aozora Bank, Tokyo, Japan 43 a subsidiary of Cerberus, and is a member of the Board of Directors of Nippon Credit Bank in Tokyo. 44



Such overseas subsidiaries and/or affiliate enterprises provides a means for the named defendant 1 Enterprises to launder their ill gotten wealth and avoid paying their fair share of taxes, thus over 2 burdening Plaintiff and other less wealthy citizens with a disproportionate share of the cost of military 3 services, public safety programs, social service programs and national infrastructure projects required to 4 maintain a civilized nation. 5

Defendant John W. Snow (Snow) former Treasury Secretary under former President George W. Bush was 6 also rewarded with a top executive position with defendant Cerberus for his support of bank de-regulation 7 legislation that caused Plaintiff to suffer financial damage and personal injury. 8

Bribery of public officials and witnesses and compensation to Members of Congress, officers, and others 9 in matters affecting the Government are violations of 18 USC Chapter 11. 10

Snow has personally lobbied then Treasury Secretary Henry M. Paulson and others for a federal rescue 11 that would salvage Cerberus’s investments in Detroit.” A housing bailout passed in 2008, contained a tax 12 write-off provision inserted in the form of a depreciation credit against taxes that was drafted so that it 13 could only possibly apply to Cerberus, in an amount up to $30,000,000 a year! 14

This was a violation of 18 USC Chapter 11 § 208. 15

The New York Times wrote on July 16th: “ In retrospect, Congress felt bullied by Mr. Paulson last 16 year. Many of them fervently believed they should not prop up the banks that had led us to this crisis — 17 yet they were pushed by Mr. Paulson and Mr. Bernanke into passing the $700 billion TARP, which was 18 then used to bail out those very banks.” 19

Mr. Ben Bernanke is the Federal Reserve Chairman. The Federal Reserve Board is dominated by CEOs of 20 big Wall Street Banks. 21

On July 17, 2012 US Federal Reserve chairman, Ben Bernanke, said the process for setting the rate was 22 “structurally flawed” and that he could not guarantee its reliability. Mervyn King, the Bank of England 23 governor, said that deliberately rigging the Libor rate for private gain is “my definition of fraud.” 24

On June 12, 2012, the eve of Senate testimony by JPMorgan Chase CEO Jamie Dimon, Senator Bernie 25 Sanders (I-Vt.) released to the public the detailed findings on Dimon and other Fed board members whose 26 banks and businesses benefited from Fed actions. 27

Government Accountability Office records that shows more than $4 trillion in near zero-interest Federal 28 Reserve loans and other financial assistance went to the banks and businesses of at least 18 current and 29 former Federal Reserve regional bank directors in the aftermath of the 2008 financial collapse. 30

"This report reveals the inherent conflicts of interest that exist at the Federal Reserve. At a time when 31 small businesses could not get affordable loans to create jobs, the Fed was providing trillions in secret 32 loans to some of the largest banks and corporations in America that were well represented on the boards 33 of the Federal Reserve Banks. These conflicts must end," Sanders said. 34

The GAO study found that allowing members of the banking industry to both elect and serve on the 35 Federal Reserve's board of directors creates "an appearance of a conflict of interest" and poses 36 "reputational risks" to the Federal Reserve System. 37

In Dimon's case, JPMorgan received some $391 billion of the $4 trillion in emergency Fed funds at the 38 same time his bank was used by the Fed as a clearinghouse for emergency lending programs. In March of 39 2008, the Fed provided JPMorgan with $29 billion in financing to acquire Bear Stearns. Dimon also got 40 the Fed to provide JPMorgan Chase with an 18-month exemption from risk-based leverage and capital 41 requirements. And he convinced the Fed to take risky mortgage-related assets off of Bear Stearns balance 42 sheet before JP Morgan Chase acquired the troubled investment bank. 43

Another high-profile conflict involved Stephen Friedman, the former chairman of the New York Fed's 44 board of directors. Late in 2008, the New York Fed approved an application from Goldman Sachs to 45



become a bank holding company giving it access to cheap loans from the Federal Reserve. During that 1 period, Friedman sat on the Goldman Sachs board. He also owned Goldman stock, something that was 2 prohibited by Federal Reserve conflict of interest regulations. Although it was not publicly disclosed at 3 the time, Friedman received a waiver from the Fed's conflict of interest rules in late 2008. Unbeknownst 4 to the Fed, Friedman continued to purchase shares in Goldman from November 2008 through January of 5 2009, according to the GAO. 6

Defendant James Dimon served as a class “A” Director of the Board of Directors of the New York 7 Federal Reserve since January 2007, while also serving as the CEO and chairman of JP Morgan Chase. 8 How is this not a conflict of interest? 9

The Federal Reserve provided $29 billion to help facilitate Chase's 2008 acquisition of Bear Stearns for 10 $10 per share. Wall Street insiders consider the bringing down of Bear Stearns the biggest financial crime 11 ever perpetuated. Veteran Wall Streeters believe that Bear was the victim of a malicious attack to 12 deliberately drop its stock price fueled by people who had an interest in the fall of Bear Stearns. 13

James Dimon and Chase profited the most from the fall of Bear Stearns. Chase’s acquisition of Bear 14 Stearns helped make it the largest bank in the United States by assets and market capitalization. It is 15 arguably now the most influential financial institution in the world. 16

As Chase's Chairman, President and CEO, James Dimon oversaw the transfer of $25 billion in bailout 17 funds from the U.S. Treasury Department to Chase in October 2008, via the Troubled Asset Relief 18 Program (TARP) to help troubled assets related to residential mortgages. Chase played a central role in 19 the subprime disaster that caused much misery to many Americans, including the Plaintiff. 20

Plaintiff endured the humiliation and frustration of extreme poverty for years because of public policy 21 that favors the very wealthy at the expense of hard working Americans like her. James Dimon uses his 22 lavish public relations budget to obtain flattering media exposure to sway public opinion and to influence 23 our elected representatives in Congress, the Senate and the White House. He's uses his public platform 24 for, among other things, arguing for unwise public policy and against bank regulation; thus forcing the 25 American people to suffer financial hardships while Dimon, his colleagues and other criminal co-26 conspirators, including defendant Lloyd Craig Blankfein, continue to draw multi-million dollar yearly 27 salaries and use their ill-gotten wealth to exhort undue influence to write legislation and shape public 28 policy so they can continue to siphon taxpayer funds into their corrupt criminal financial institutions and 29 their own personal pockets. 30

Defendant Sandy Weill, former CEO and chairman of Citigroup in 1999 convinced former President Bill 31 Clinton to sign off on the Republican-sponsored Gramm–Leach–Bliley Act. In his memoir Weill brags 32 that he and Republican Senator Phil Gramm joked that it should have been called the Weill-Gramm-33 Leach-Bliley Act. Informally, it was called "the Citigroup Authorization Act" because in 1998 Citicorp (a 34 commercial bank holding company) merged with Travelers Group (an insurance company) to form the 35 conglomerate Citigroup, a corporation combining banking, securities and insurance services. This $76 36 billion merger completed in October 1998 was in violation of the Glass-Steagall Act. 37

Citigroup under Weill financed frauds like Worldcom and Enron without a second thought. Its stock 38 market analyst Jack Grubman, who was supposed to be dispensing unbiased advice to investors, 39 moonlighted as an investment banker, thus raking in fees from companies whose shares he was touting to 40 unsuspecting investors. 41

Weill himself prodded Grubman to upgrade shares of AT&T, where he was a board member. He did it at 42 a time when the firm was vying for a lucrative role as an AT&T underwriter. When Grubman did as he 43 suggested, and his bankers won the deal, he then got Grubman's kids into a fancy pre-school in 44 Manhattan, which Grubman once lamented was harder to get into than "Harvard." 45



In 1999 Weill was the highest paid CEO in the country with a salary of $230 million. Citigroup went on 1 to be a major purveyor of toxic mortgage-based securities that required $45 billion in direct government 2 investment and a $300 billion guarantee of its bad assets in order to avoid bankruptcy. Weill bailed out of 3 Citigroup before the crash and went “laughing all the way to the bank.” Like his 1929 predecessors Weill 4 cashed out leaving hard working American taxpayers, including the Plaintiff, to suffer the consequences. 5

Justice in the United States is not supposed to be for sale to the highest bidder. 6

Due to these blatant occurrences of fraud that have been and continue to be perpetrated against the 7 Plaintiff and other American citizens; and Plaintiff’s State of Oregon and other U.S. States; and Plaintiff’s 8 County of Washington and other local governments by the named defendants as banks and other financial 9 institutions; as employees of these defendant banks and other financial institutions; and as mangers and 10 top executive officers of these defendant banks and other financial institutions, it must be concluded that 11 the United States Government has been and is an accomplice in the attempted confiscation of Plaintiff’s 12 property, and the confiscation of property belonging to hundreds of thousands of other U.S. citizens 13 without due process of the law in violation of their Fifth Amendment rights. 14

This is the only logical conclusion that can be inferred when these of crimes of fraud including robo-15 signing, fraudulent foreclosures, investor fraud, rigging of libor, etc have been made public as far back as 16 2008 yet none of the men and women perpetrating these crimes or their financial institutions have been 17 held accountable for their crimes by the United States Government. These individuals are still 18 perpetrating the same crimes and pocketing Trillions of dollars when they belong in prison! 19

They are not yet in prison because they have paid off members of our U.S. Congress, Senate, our former 20 Presidents and other elected government officials and agencies. 21

Although Plaintiff is filing this complaint pro-se she knows she is doing so at a horrific disadvantage, but 22 she is helpless to do otherwise. Most of the defendants’ other victims do not have the education or 23 capacity to even attempt to represent their cases pro-se. 24

According to The National Center for State Courts, courts are continuing to see an increase in the 25 numbers of litigants who represent themselves and statistics regarding pro-se litigants are very disturbing 26 for those who know the issues regarding the courts and legal counsel in this country. 27

Slightly over 88% of judges surveyed believed that the extent to which litigants committed procedural 28 errors was a problem for pro se litigation. 29

Studies of the trends in pro-se litigants show that the vast majority of them have modest incomes. 30

The website for The National Center for State Courts: 31 http://www.ncsconline.org/wc/publications/memos/prosestatsmemo.htm 32

Most of the homeowners victimized by defendants the Beal Enterprises, the Goldman Enterprises, the 33 Chase Enterprises, the Ally/GMAC/Cerberus Enterprise and other large financial Enterprises like them, 34 have no choice but to litigate pro-se because the very actions perpetrated against them by these defendants 35 and for which they seek legal redress have caused them to become impoverished. 36

These cases are all very complex; made so deliberately by the criminal activities of the defendants with 37 intent to thwart consumers’ ability to seek legal redress and to prevent them from prevailing whenever 38 they do. Even trained attorneys struggle to adequately represent their clients’ rights in such cases; yet pro-39 se litigants must take on these very complex cases without training in the law and without confidence in 40 their ability to adequately present their case or follow expected procedures. 41

42

http://www.ncsconline.org/wc/publications/memos/prosestatsmemo.htm�



Claim V 1

Furthermore the United Nation’s Universal Declaration of Human Rights Article 25 (1) states “Everyone 2 has the right to a standard of living adequate for the health and well-being of himself and of his family, 3 including food, clothing, housing and medical care and necessary social services, and the right to security 4 in the event of unemployment, sickness, disability, widowhood, old age or other lack of livelihood in 5 circumstances beyond his control.” 6

Article 8 of the United Nation’s Universal Declaration of Human Rights Article states: “Everyone has the 7 right to an effective remedy by the competent national tribunals for acts violating the fundamental rights 8 granted him by the constitution or by law.” 9

Article 17(2) of the United Nation’s Universal Declaration of Human Rights Article states: “No one shall 10 be arbitrarily deprived of his property.” 11

The defendants have in their unrelenting pursuit of personal wealth at all costs and through all means, 12 including criminal activity, have deprived the Plaintiff and millions of other humans across the globe our 13 very basic of human rights. 14

The United States Government condemns other countries for violations of human rights while the human 15 rights of millions of its own citizens are violated daily and it supports the perpetrators of crimes against 16 humanity, the big Wall Street Banks and their co-conspirators in crime, by failing to take action to stop 17 their crimes or to hold those responsible accountable for their crimes. The trillions of dollars stolen from 18 the American people, including the Plaintiff, would be returned if the ill-gotten wealth of these defendants 19 was confiscated and returned to the people. 20

Claim VI 21

Plaintiff learned in 2011 and 2012 that the value of a mortgage backed security, hereafter referred to as 22 MBS, is based on an average. Wall Street banks needed to include a few high value mortgages in each 23 MBS with mostly toxic loans to skew its value to deceive investors. 24

To do this they targeted older homeowners with a lot of equity in their homes and good credit, including 25 the Plaintiff. 26

Once these high value mortgages are included in a MBS banks need to prevent them from leaving through 27 refinance or early payoff; hence they were highly motivated to make fraudulent claims of missed 28 payments; create artificially inflated payoff balances through exorbitant and frivolous fees; and to abuse 29 false negative consumer credit reporting to prevent these older homeowners, including the Plaintiff, from 30 refinancing their mortgage or being able to sell their homes. 31

In essence the defendants identified as “Enterprises” have conspired to hold the Plaintiff’s home 32 (property) hostage as long as it serves their profit needs. While they have done this she has been unable to 33 sell her home. Property values have since plummeted and Plaintiff’s property lost at least $70,000 of its 34 market value. 35

Defendants targeted Plaintiff’s property for a fraudulent mortgage and conspired with each other in order 36 to skew the value of a securitization with intent to deceive investors in a violation of 18 USC § 1348 et 37 seq. 38

39



Claim VII 1

Credit Default Swaps, hereafter referred to as CDSs, are at the heart of the global financial crisis. 2

CDSs are completely unregulated by our government because until recently the government knew almost 3 nothing about them due to the cunning manner in which they were created by the defendants and their co-4 conspirators. 5

CDSs are like insurance policies on company debt. When a big business wants to raise money it can sell a 6 corporate bond or IOU. An investor buys the bond then buys a CDS as insurance. The swap seller 7 promises to pay the value of the bond if the company goes bust. 8

CDSs started out as a way for investors, including banks, to lower their risk in the marketplace, but these 9 days most buyers of CDSs don't invest in the original companies. They just buy them in the hope the 10 company will fail. 11

Defendant Enterprises named in this complaint and their bosses, and their co-conspirators insured their 12 mortgage backed securities (MBSs) with CDSs. This caused a scenario that is the same as if everyone on 13 your block could buy insurance on your house in the hopes it collapses or catches fire. This scenario 14 creates tremendous incentive for those “investors” who are truly “gamblers” to cause the destruction of 15 your home so they can collect on the insurance pay-out. 16

CDSs are essentially a giant Ponzi scheme destined to collapse because the earnings, if any, are less than 17 the payments to investors. The defendants and their co-conspirators know this, and ultimately they have 18 created hedge funds and other financial instruments structured to deceive the FDIC into believing they 19 meet requirements for FDIC insurance. American taxpayers will ultimately be left holding the bag when 20 the defendants’ Ponzi scheme collapses causing U.S. citizens, including Plaintiff and her heirs, and 21 citizens of countries all across the globe, tier children and their grandchildren for many generations to be 22 thrust into perpetual debt slavery. 23

The defendants have recklessly gambled with the Plaintiff’s life and property with callous disregard for 24 the serious personal injury, pain and suffering they have caused her. 25

Defendants and their co-conspirators created corporations and other business entities structured to legally 26 avoid government regulation and to thwart discovery of the real owners and beneficiaries of their illegal 27 businesses and activities. 28

Defendants Dimon and Blankfiend and other top executives at Chase, Goldman Sachs and the CEOs of 29 other “too big to fail” banks and their top executives will walk away with trillions of dollars funneled 30 directly into their personal pockets as a result of their giant Ponzi scheme; at the expense of all other 31 Americans. In 2008 some $60 trillion worth of CDSs existed, now in 2012 this figure likely exceeds $800 32 trillion. 33

34



Claim VIII 1

Just like with all organized crime families the defendant organizations named in this complaint: the Chase 2 Enterprise; the Ally/GMAC/Cerberus Enterprise; the Goldman Enterprise; the Prommis Enterprise; the 3 Beal Enterprise; the NTS Enterprise; the IBM/LBP/Fidelity Enterprise and the CT Enterprise use their 4 peons or soldiers to actually commit the crimes. These soldiers will do any job asked of them by their 5 captain or the boss or underboss. 6

The next position of the family is caporegime (or captain). A caporegime is in charge of a group of 7 worker soldiers. The underboss of the family is in charge of the caporegimes. The underboss is the person 8 who actually runs the family. He is boss over all the other members except the actual boss. 9

The Boss of the family controls everything that goes on in the crime family. Every worker and lower 10 ranking boss works for him. The boss gets money from all of his workers and therefore is the richest 11 person in his crime family. 12

Defendants Lorrie Womack, Tammy J. Wilde, Debra Lyman, Laura Herrera, Betty Wright, Diane M. 13 Meistad, Masse Adjetey, Mary K. Olson, Pamela Campbell, Rosalyn Hall, Bernadette McDonnell, Lori 14 Beddard, B. Bernadine and Enedina O. Sanchez and tens of thousands of workers like them are the 15 soldiers in the criminal organizations or enterprises named in this complaint. 16

Any law abiding American citizen knows it is illegal to forge someone else’s signature on a document 17 meant to be used in a court or for legal purposes; to sign such a legal document purporting to be someone 18 you are not; to fabricate documents that look authentic when they not. These peons of their crime families 19 took orders from their captains and underbosses and committed criminal actions without question. 20

Defendants Tom Donatacci, Larry B. Litton Sr., Larry B. Litton Jr., Bruce Pardis, Stephen A. Feinberg, 21 John W. Snow, Greg Sullins, Michael A. Carpenter, Mark F. Bole, Monica Mora, Tina Jones, Josh 22 Magnuson, Suzanne Eaton, John Kee, Jacob Cherner, Molly Curl, William Mynatt, David Allison, Kevin 23 R. McCarthy, David Fennell, Stephen Routh and Thomas J. Holthus were the captains and underbosses of 24 their crime families. They kept a significant portion of the pillage and plunder they commanded. 25

Defendants Lloyd Craig Blankfein, Jamie Dimon and J. Danforth Quayle, Virginia M Rometty, Nancy 26 McKinstry and Andy Beal are the big bosses of their respective crime families; they keep the largest share 27 of the pillage and plunder, multi-million dollar payouts per year. 28

Quoted from a online article by the Republic Report published on May 19, 2012 and written by Zaid 29 Jilani: http://www.republicreport.org/2012/gephardt-lobbying-doddfrank/ 30

The fate of Dodd-Frank over the past two years is an object lesson in the government’s 31 inability to institute even the simplest and most obvious reforms, especially if those 32 reforms happen to clash with powerful financial interests. 33

From the moment it was signed into law, lobbyists and lawyers have fought regulators 34 over every line in the rulemaking process. Congressmen and presidents may be able to 35 get a law passed once in a while – but they can no longer make sure it stays passed. 36 You win the modern financial-regulation game by filing the most motions, attending the 37 most hearings, giving the most money to the most politicians and, above all, by keeping 38 at it, day after day, year after fiscal year, until stealing is legal again. “It’s like a 39 scorched-earth policy,” says Michael Greenberger, a former regulator who was 40 heavily involved with the drafting of Dodd-Frank. “It requires constant combat. And it 41 never, ever ends.” 42

These defendants colluded and conspired with each other members of our Congress, Senate and other 43 government agencies to turn our banking and financial institutions into criminal enterprises. They have 44

http://www.republicreport.org/2012/gephardt-lobbying-doddfrank/�



operated and continue to operate a financial racket, as defined by 18 USC § 1961, Racketeer Influenced 1 and Corrupt Organizations Act. 2

Claim IX 3

On or around August 6, 2008 Plaintiff became distressed while she watched the morning news on KATU 4 TV Portland. Alicia Jackson is another elder victim of mortgage fraud, similarly targeted as Plaintiff was. 5 She was fraudulently evicted from her home and on May Day 2012 several community non-profits, 6 including We Are Oregon and Occupy Portland, along with hundreds of members of the community held 7 a community event to move Jackson back into her home. 8

Jackson's double lot was bought by investment group Fox Capital after she was evicted based on the 9 fraudulent foreclosure. The company kept Jackson's home empty, but built a new duplex on the lot that 10 has remained empty. In August protesters decided to claim this empty building, that they believe 11 rightfully belongs to Jackson, for a community center and a community garden. 12

Defendant KATU TV Portland, a subsidiary of American Broadcasting Company (ABC), failed to cover 13 this event in a fair and objective manner. They made it appear as if the protestors caused serious damage 14 to the property when in fact they did not. They failed to cover how this building came to be built on 15 Jackson’s property after fraud deprived her of it, and that Jackson has an active lawsuit regarding the 16 fraudulent foreclosure of her property and its subsequent illegal sale to Fox Capital. 17

Plaintiff knows Alicia Jackson and became extremely depressed after watching the slanted coverage of 18 this event on KATU TV. For years Plaintiff has attempted to get media coverage regarding her fight with 19 mortgage fraud to no avail. An entire group of vulnerable Americans have been targeted for mortgage 20 fraud and mainstream media, including KATU TV, has consistently refused to cover their stories. 21

Media is not supposed to slant news to the public based on monetary considerations. A free press was 22 considered so essential to democracy that the very First Amendment to our Constitution drafted by the 23 forefathers of our great nation was to assure freedom of the press. 24

American Broadcasting Company (ABC) and a handful of other large media corporations have 25 systematically purchased most small broadcasting and print media companies, so they now control a vast 26 majority of information delivered to the public. These media defendants are accomplices with the other 27 named Enterprise defendants and taint public opinion regarding the plight of the Plaintiff and Jackson and 28 hundreds of other older homeowners targeted for mortgage fraud. 29

They deliberately hide the extent of damages caused to Plaintiff and to most Americans through the 30 illegal siphoning of public funds by defendants named in this complaint and into their personal assets. 31 They deliberately hide the extent to which the defendants named in this complaint control our 32 government. They fail to provide Americans with truthful coverage regarding the money trail (who has 33 personally benefited from criminalization of our banks and financial intuitions). Where is the balanced 34 and unbiased investigative reporting? 35

These media defendants and their lack of balanced reporting have caused the Plaintiff, and many other 36 victims of mortgage fraud, to endure public taunts of being a “deadbeat.” Opinion of the masses has been 37 shaped by they see on the news; and because of this public opinion is negative toward the Plaintiff. 38

The lack of balanced reporting by these media defendants also delays justice for victims because they 39 struggle in isolation when they could be working together to fight the fraud perpetrated against them. 40

41



V. RELIEF 1

Claim I 2

Plaintiff is the only legal and rightful beneficiary of her property and any deed of trust associated with it. 3

THEREFORE she prays the Court will order an immediate and permanent injunction against the sale of 4 her home by Trustee and forever end the nightmare of fear she has forced to live with since 2006. 5

Plaintiff prays the Court order a quiet title be made with her as the sole beneficiary, so she may forever be 6 free of a muddied title and any possibility of future false claims against her property. 7

Plaintiff further prays the Court order that any and all costs associated with the legal filing of such quiet 8 title be born by defendants the Beal Enterprise and/or their predecessors. 9

Plaintiff prays the Court award actual damages of $7,000 in restitution for attorney fees she paid from 10 2006 to 2011. 11

Plaintiff prays the Court order each of the named defendants who are natural persons and who 12 individually and collectively participated in criminal activities of fraud against Plaintiff for their own 13 and/or their “bosses” unjust personal enrichment to pay Plaintiff punitive damages in the amount of no 14 less than 5% of the total compensation paid to them by their employers who are also named as defendants 15 in this complaint from February 2004 until the present time. 16

Plaintiff prays the Court order each of the named defendants that are corporations or other business 17 entities and are not natural persons to pay Plaintiff punitive damages in an amount equaling no less than 18 5% of their total gross profits from February 2004 until the present time. 19

Claim II 20

Plaintiff prays the Court order defendants the Chase Enterprise and the Goldman Enterprise to pay 21 restitution for actual damages caused to Plaintiff by their willful false reporting of her mortgage payment 22 history to the three major credit reporting agencies; and their refusal to correct this false reporting in 2006 23 after Plaintiff’s attorney proved EMC’s claims of missed payments were false; and thereby forcing 24 Plaintiff to file an otherwise unnecessary bankruptcy to prevent fraudulent foreclosure on her home. 25

Actual Damages caused to Plaintiff by Defendants’ Willful Abuse of her Consumer Credit Reports 26

Cost of damage to credit $500,000 27 Difference between medical costs with vs. without insurance $40,100 28 Estimated costs of lifelong medical care $3,000,000 29 Loss of past earned income $200,000 30 Loss of future earned income $1,000,000 31 $4,740,100 32 NOTE: this is only a partial list 33

Plaintiff prays the Court order defendants JP Morgan Chase and Goldman Sachs to pay punitive damages 34 in an amount equaling 10% of their total gross profits from February 2004 until the present time. 35



Claim III 1

Restitution for Personal Injury caused to Plaintiff by Defendants 2

Plaintiff prays the Court order each of the named defendants who are natural persons and who 3 individually and collectively participated in criminal activities of fraud against Plaintiff that caused her to 4 suffer personal injury to pay restitution for pain and suffering to Plaintiff in an amount equal to 10% of 5 the total compensation paid to them by their employers who are also named as defendants in this 6 complaint from February 2004 until the present time. 7

Plaintiff prays the Court order each of the named defendants that is a corporation or other business entity, 8 and is not a natural person, and that caused her to suffer personal injury to pay restitution for pain and 9 suffering to Plaintiff in an amount equaling 10% of their total gross profits from February 2004 until the 10 present time. 11

Claim IV 12

Equal Access to Justice and the Judicial System 13

Plaintiff prays the Court order each of the named defendants individually and collectively that 14 participated in criminal activities of fraud against Plaintiff to participate in professional mediation 15 services to attempt to reach an out-of-court settlement; and if a fee is charged for such services the Court 16 order such fee to be paid by the defendants. 17

Plaintiff prays that if such mediators report to the court that the defendants are unreasonable or that they 18 are not acting in good faith during the mediation process the Court will order such defendants to pay 19 treble all damages (i.e. actual, punitive and damages for pain and suffering) that might be awarded by the 20 judge and/or the jury at the conclusion of a trial. 21

Claim V 22

Basic Human Rights Violations 23

Plaintiff prays the Court order the Chase Enterprise, the Ally/GMAC/Cerberus Enterprise, the Goldman 24 Enterprise, and the Beal Enterprise to de-securitize all home mortgages and to pledge never to securitize 25 home mortgages again. Family homes are not commodities to be bought and sold on the stock exchange. 26

Defendants have caused more than a decade of financial damages to the State of Oregon and its citizens 27

Claim VI 28

Plaintiff prays the Court order the Chase Enterprise, the Ally/GMAC/Cerberus Enterprise, the Goldman 29 Enterprise, and the Beal Enterprise to pay to her 100% of all earnings they received from retaining her 30 mortgage in their securitized pool. 31

Claim VII 32

Plaintiff prays the Court order the Chase Enterprise, the Ally/GMAC/Cerberus Enterprise, the Goldman 33 Enterprise, and the Beal Enterprise to pay to her 100% of all earnings they received from Credit Default 34 Swaps by fraudulently placing her mortgage into default. 35



Claim VIII 1

Plaintiff prays the Court order the defendants to pay treble actual damages they caused to her by their 2 racketeering activities. 3

In addition, defendants have caused more than a decade of financial damages to the State of Oregon and 4 its citizens including the Plaintiff. Plaintiff waited three years for the Oregon Health Plan that is forced to 5 approve economically qualified applicants on a lottery system due to lack of public funding. 6

Plaintiff was denied Social Security Disability (SSD) benefits, as 85% of all applicants are, in spite of 7 paying at least 25% of her income for nearly 30 years into the Social Security (SS) program and has had 8 to wait nearly three years while struggling to survive on less than $800/month earned through renting 9 rooms in her home and selling her personal property, without any regularity. This caused Plaintiff severe 10 stress each month as she had to negotiate with utility providers to prevent shut-off of services and/or to 11 restore services that were shut-off. This is again due to a general lack of public funding caused by 12 defendants’ illegal siphoning of public funds into their personal assets. 13

Plaintiff prays the court order defendants the Chase Enterprise, the Ally/GMAC/Cerberus Enterprise, the 14 Goldman Enterprise, and the Beal Enterprise to pay restitution for damages and punitive damages in the 15 amount of $2 Trillion each to be placed into a trust fund under the control of the Plaintiff and a board of 16 multi and non-partisan advisors of her choosing that will include, but not be limited to: 17

• Oregon Congresswoman, Suzanne Bonamici 18 • Oregon Senator, Jeff Merkley 19 • Oregon governor, John Kitzhaber 20 • Mayors of Oregon’s principle cities 21 • Leaders in Oregon’s rural communities 22 • Oregon legislators and elected officials who have not supported, participated in or profited from 23

the defendant’s criminal activities 24 • Oregon law enforcement 25 • Representatives from Oregon’s media 26 • Leaders and member of Oregon’s minority communities 27 • Leaders of various non-profit organizations that assist the defendants’ victims 28 • Leaders of various non-profit organizations that assist Oregon’s disabled and senior citizens, and 29

individuals who are disabled or seniors 30 • Leaders of various non-profit organizations and state agencies that promote sustainable energy 31

and environment preservation 32 • Representatives from Oregon’s top private companies that have not supported, participated in or 33

illegally profited from the defendant’s criminal activities 34 • Representatives from Oregon’s small businesses and small business owners 35 • Representatives from Oregon’s farming industry 36 • Representatives from Oregon’s health care industry, including chiropractors and alternative 37

health practitioners 38 • Representatives of Oregon’s public and private schools and parents of children these schools 39 • Representatives of Oregon’s religious and spiritual communities 40 • Representatives from Oregon’s labor unions and State Employment Department 41

This board in cooperation with and consent of the Plaintiff will distribute the funds in the trust so as to: 42

1. Compensate Oregon counties for their losses and damages during the past decade caused by the 43 defendant’s of criminal activities 44

2. Restore and improve Oregon’s public services 45



3. Address Oregon’s educational needs 1 4. Address crime prevention needs in Oregon 2 5. Provide funding for public works projects, such as highway and bridge maintenance and building 3

of alternative energy services such as EV charging stations. 4 6. Address Oregon’s energy needs 5 7. In short provide Oregon with an adequate budget for the next decade. 6

Claim IX 7

Plaintiff 8

Plaintiff prays the Court order defendant KATU TV Portland and American Broadcasting Company 9 (ABC) to pay 10% of their budget into a fund to support media not controlled by the big media 10 corporations. This fund will be used to award grants for equipment and to pay expenses of independent 11 journalists researching investigative news pieces. 12

Exhibit A –Subramaniam vs D. Andrew Beal, Goldman Sachs Page 1 of 3

For Release: September 9, 2008

Bear Stearns and EMC Mortgage to Pay $28 Million to Settle FTC Charges of Unlawful Mortgage Servicing and Debt Collection Practices

The Bear Stearns Companies, LLC and its subsidiary, EMC Mortgage Corporation, have agreed to pay $28 million to settle Federal Trade Commission charges that they engaged in unlawful practices in servicing consumers’ home mortgage loans. The companies allegedly misrepresented the amounts borrowers owed, charged unauthorized fees, such as late fees, property inspection fees, and loan modification fees, and engaged in unlawful and abusive collection practices. Under the proposed settlement they will stop the alleged illegal practices and institute a data integrity program to ensure the accuracy and completeness of consumers’ loan information.

“Like other companies that send a bill, mortgage servicers must make sure that the amount they say is due really is the amount due,” said Lydia B. Parnes, Director of the FTC’s Bureau of Consumer Protection. “Consumers have the right to expect accuracy from the company that collects their mortgage payments.”

As stated in the FTC’s complaint, Bear Stearns and EMC have played a prominent role in the secondary market for residential mortgage loans. During the explosive growth of the mortgage industry in recent years, they acquired and securitized loans at a rapid pace, but they allegedly paid inadequate attention to the integrity of consumers’ loan information and to sound servicing practices. As a result, in servicing consumers’ loans, they neglected to obtain timely and accurate information on consumers’ loans, made inaccurate claims to consumers, and engaged in unlawful collection and servicing practices. These practices occurred prior to JP Morgan Chase & Co.’s acquisition of Bear Stearns, which became effective on May 30, 2008.

According to the complaint, EMC is the mortgage servicer for many of the loans Bear Stearns and EMC acquired. Many of these loans are subprime or “Alt-A” (less than prime) loans, including nontraditional mortgages such as pay option adjustable rate mortgages (“pick-a-payment” loans), interest-only mortgages, negative amortization loans, and loans made with little or no income or asset documentation. EMC’s loan servicing portfolio has grown significantly in recent years; as of September 2007, it serviced more than 475,000 mortgage loans with a total unpaid balance of about $80 billion.

THE FTC COMPLAINT

The complaint charges Bear Stearns and EMC with violating the FTC Act, the Fair Debt Collection Practices Act (FDCPA), the Fair Credit Reporting Act (FCRA), and the Truth in Lending Act’s (TILA) Regulation Z.


FTC Act Violations: The defendants are charged with unfair and deceptive loan servicing practices in violation of the FTC Act. They allegedly misrepresented the amounts consumers owed; assessed and collected unauthorized fees, such as late fees, property inspection fees, and loan modification fees; and misrepresented that they possessed and relied upon a reasonable basis for their representations about consumers’ loans.

Fair Debt Collection Practices Act Violations: The defendants allegedly violated several provisions of the FDCPA in collecting loans that were in default when they obtained them. They also allegedly made harassing collection calls; falsely represented the character, amount, or legal status of consumers’ debts; and failed to communicate that debts were disputed. In addition, they allegedly used false representations or deceptive means to collect, and failed to send consumers a validation notice containing the amount of the debt and the consumer’s right to dispute the debt and obtain verification of the debt.

Fair Credit Reporting Act Violations: The FTC alleges that the defendants furnished information about consumers’ payment status to credit reporting agencies (CRAs). When consumers informed the defendants that they disputed the completeness or accuracy of the reported information, the defendants failed to report the dispute to the CRAs as required by the FCRA.

Truth in Lending Act’s Regulation Z Violations: The complaint also states that the defendants charged borrowers a loan modification fee, typically $500, and automatically added the fee to the modified loan’s principal balance. In doing so, the defendants failed to provide the borrowers with required TILA disclosures.

THE SETTLEMENT

The proposed settlement requires Bear Stearns and EMC to pay $28 million to redress consumers who have been injured by the illegal practices alleged in the complaint. In addition, the settlement bars the defendants from future law violations and imposes new restrictions and requirements on their business practices. Specifically, the settlement:

• bars the defendants from misrepresenting amounts due and any other loan terms; • requires them to possess and rely upon competent and reliable evidence to support claims made to

consumers about their loans; • bars them from charging unauthorized fees, and places specific limits on property inspection fees

even if they are authorized by the contract; • prohibits them from initiating a foreclosure action, or charging any foreclosure fees, unless they

have reviewed all available records to verify that the consumer is in material default, confirmed that the defendants have not subjected the consumer to any illegal practices, and investigated and resolved any consumer disputes; and

• prohibits the defendants from violating the FDCPA, FCRA, and TILA.

The proposed settlement further requires Bear Stearns and EMC to establish and maintain a comprehensive data integrity program to ensure the accuracy and completeness of data and other information that they obtain about consumers’ loan accounts, before servicing those accounts. The defendants must obtain an assessment from a qualified, independent, third-party professional within six months and then every two years, for the next eight years, to assure that their data integrity program meets the standards of the order.


The proposed settlement also contains record-keeping and reporting provisions to allow the FTC to monitor compliance with the order.

The Commission vote to authorize staff to file the complaint and proposed stipulated final order was 4-0. The documents were filed in the U.S. District Court for the Eastern District of Texas.

Including the case announced today, the Commission has brought 23 actions in the past decade alleging deceptive or unfair practices by mortgage brokers, lenders, and servicers. Several of these landmark cases have resulted in large monetary judgments that have returned more than $320 million to consumers.

CONSUMER HOTLINE: If the court approves the settlement, consumers who are eligible for redress will be contacted by mail. The Commission’s consumer hotline regarding the settlement is 1-877-787-3941. Consumers who have changed their address recently may provide updated contact information by calling the hotline. Consumers also can find information about the settlement on the FTC’s Web site at http://www.ftc.gov.

NOTE: The Commission files a complaint when it has “reason to believe” that the law has been or is being violated, and it appears to the Commission that a proceeding is in the public interest. The complaint is not a finding or ruling that the defendants have actually violated the law. The stipulated final order is for settlement purposes only and does not constitute an admission by the defendants of a law violation. A stipulated final order requires approval by the court and has the force of law when signed by the judge.

The Federal Trade Commission works for consumers to prevent fraudulent, deceptive, and unfair business practices and to provide information to help spot, stop, and avoid them. To file a complaint in English or Spanish, visit the FTC's online Complaint Assistant or call 1-877-FTC-HELP (1-877-382-4357). The FTC enters complaints into Consumer Sentinel, a secure, online database available to more than 1,500 civil and criminal law enforcement agencies in the U.S. and abroad. The FTC's Web site provides free information on a variety of consumer topics.

MEDIA CONTACT:

Frank Dorman, Office of Public Affairs 202-326-2674

STAFF CONTACT:

Lucy Morris, Bureau of Consumer Protection 202-326-3224

(FTC File No.0623031) (EMC)

SOURCE:

http://www.ftc.gov/opa/2008/09/emc.shtm

http://www.ftc.gov/�

https://www.ftccomplaintassistant.gov/�

http://www.ftc.gov/consumer�

http://www.ftc.gov/opa/2008/09/emc.shtm�

Exhibit B Fraudulently Fabricated Deed Assignments Page 1 of 22 US District Court District of Oregon: Subramaniam vs. Beal, Goldman Sachs, Chase et al…

People’s Choice Home Loan, Inc. recorded a Trust Deed in Washington County Oregon on 3/1/2004. Notice that I, Denise Subramaniam, am the direct party and People’s Choice is the indirect party.

On 6/28/2006 fraudulently prepared documents (shown on pages 2 and 3) were filed to support a fraudulent foreclosure attempt in 2006 with intent to steal the considerable equity I’d built into my home defendants the Ally/GMAC/Cerberus and the Goldman Enterprises.

In 2008, and then again in 2011 fraudulent documents were filed in behalf of defendant the Beal Enterprise. These documents have been deliberately fabricated to deceive. They contain forgeries and falsified statements.

This is done intentionally to give the appearance of authority and/or ownership when none exists in order to take possession of real property belonging to Plaintiff. They have committed forgery and perjury with intent to deceive. This is fraud.


On 6/28/06 at 3:24:13 PM this two page document titled, “Substitution of Trustee,” was filed with Washington County.

It fraudulently substitutes the original trustee, Paul S. Cosgrove, and the original “Beneficiary,” People’s Choice Home Loan, Inc., to give the appearance of authenticity for a fraudulent assignment of deed of trust to Homecomings Financial Network Inc. filed the same day. They did this to initiate a fraudulent foreclosure and trustee’s sale.

Debra Lyman, a known robo-signer for Litton, signed this document as Vice President of Homecomings Financial Network, Inc. Her signature is dated 3/18.2006.

Laura Herrera, a Harris County Texas notary, claims Debra Lyman “personally appeared” before her. This is unlikely; if Debra Lyman was Vice President of Homecomings Financial Network, Inc. she would have been in Minnesota.

Laura Herrera signed this document in Texas on March 20, 2006 two days after Debra Lyman signed it. She didn’t witness the signature.

If Debra Lyman was “personally known” to Laura Herrera, then she knew Debra Lyman was not the Vice President of Homecomings Financial Network, Inc. Laura Herrera committed perjury.

Perjury is a Class C felony in Oregon. (ORS § 162.065)

Debra Lyman is named as a defendant in several lawsuits involving fraudulent foreclosures. She is a Litton employee and a notorious Robo signer: http://frauddigest.com/pdfs/20July11SigningNow.pdf

More information about Debra Lyman’s activities is on the following page.

An SEC filing by Fidelity National Title Co., stamped here, connects them with LSI Title Company of Oregon, LLC.

Evidence exists that Laura Herrera works for a loan servicing company, Seterus Inc., formerly Lender Business Process Services located at 14523 SW Millikan Way, Ste 200, Beaverton, OR 97005.

LSI Title Company of Oregon, LLC operates as a subsidiary of Lender Business Process Services; and in 2011 another fraudulent substitution of trustee for my property was filed in favor of LSI Title Company of Oregon, LLC. (http://investing.businessweek.com/research/stocks/private/snapshot.asp?privcapId=47780480)

http://frauddigest.com/pdfs/20July11SigningNow.pdf�

http://files.shareholder.com/downloads/FNT/1486799823x0xS892569-05-991/1331875/filing.pdflsi-sec-filing.pdf�

http://files.shareholder.com/downloads/FNT/1486799823x0xS892569-05-991/1331875/filing.pdflsi-sec-filing.pdf�

http://investing.businessweek.com/research/stocks/private/snapshot.asp?privcapId=47780480�





Debra Lyman and other Litton robo-signers fabricate documents for mortgage-backed trusts when the originals can't be found. Litton's robo-signers, Marti Noriega, Denise Bailey and Debra Lyman all fabricated mortgage assignments for GSAMP Trusts i.e. Goldman Sachs Alternative Mortgage Products. They’ve signed as officers for numerous mortgage companies listed in the article to transfer mortgages and notes (years past the trust deadline dates) to GSAMP trusts. Sources: http://www.foreclosurehamlet.org/profiles/blogs/false-statements-goldman http://en.wikipedia.org/wiki/Goldman_Sachs

On 7/30/2010 Debra Lyman signed as Assistant Secretary MERS Inc, solely as nominee for Counsil Bluffs Savings Bank a Division of Carroll County State Bank. The document was filed with Pottawattamie County, IA on 9/21/2010 The document was a Quit Claim Deed in favor of Litton as Trustee for a Morgan Stanley MBS Trust.

On 11/28/2005 Debra Lyman signed as Vice President Litton Loan Servicing, LC, as Attorney-in-fact for The Providnet Bank. The document was filed with Pottawattamie County, IA, on 1/6/2006 and was a Quit Claim Deed in favor of Deutsche Bank National Trust Company as Trustee for a Morgan Stanley MBS Trust.

Shown are examples of Debra Lyman signing as an officer of different financial organizations. On 2/10/2006 Debra Lyman signed as Vice President of Deutsche Bank National Trust Company, as Trustee for a MBS Trust.

Debra Lyman’s LinkedIn profile shows her as a Litton employee, (http://www.linkedin.com/pub/debra-lyman-wk/10/90b/353). Her Spoke profile also indentifies her as a Litton employee (http://www.spoke.com/info/pDr5Ewh/DebraLyman). And she is on a list of authorized signers and attorneys-of-fact for Litton, (http://deeds.desotocountyms.gov/P/P00092-00450.pdf). Shouldn’t attorneys who commit fraud be disbarred?

http://www.foreclosurehamlet.org/profiles/blogs/false-statements-goldman�

http://en.wikipedia.org/wiki/Goldman_Sachs�

http://www.linkedin.com/pub/debra-lyman-wk/10/90b/353�

http://www.spoke.com/info/pDr5Ewh/DebraLyman�

http://deeds.desotocountyms.gov/P/P00092-00450.pdf�


Denise Bailey, another Litton robo-signer on the same lists as Debra Lyman, signed as Vice President of MERS Inc. on a Deed Assignment filed in Skagit County, WA. (She signed as Asst. Secretary for Deutsche Bank and Debra Lyman signed as Vice President on a document shown on the previous page.)

If you compare Denise Bailey’s signatures they are not the same. More than one person is signing as Denise Bailey. This is blatant fraud.

The Notary on this document was Texas notary Laura Herrera who also signed the Substitution of Trust on my property on 3/18/2006. Again, the signatures are not the same, nor are the notary stamps. Multiple people are signing Laura Herrera’s signature and using her Notary stamp. This is fraud and perjury.

This document was a Deed Assignment in favor of HSBC Bank USA as Trustee for a MBS Trust.

Click for Full Document

The differences in the signatures indicate that more than one person used the notary stamp for Laura Herrera and signed documents as if they were her by forging her signature. This is fraud. (A notary commission is valid for four years in Texas and no one checks during that time whether the person commissioned is still located at the address on their application for notary.) It is perjury if Laura Herrera indeed works/worked for Lender Business Process Services, (now Seterus Inc.), in Beaverton, Oregon and used a Texas notary stamp to sign legal documents and/or allowed her Texas notary stamp to be used by other people signing as her.

The signature on the right is from my document above. Notice in this signature the pen starts at the top of the first leg of the “H”, at the bottom of the leg it then swoops upwards without lifting the pen to cross over and down to form the right leg, then from the bottom of the second leg it swings left to cross the legs of the “H”. The pen leaves the paper and the lower case “e” starts as a new pen stroke.

Notice that here the left most or first leg of the “H” is a separate line. The second leg of the “H” starts as a new line from the top. At the bottom of the second leg the stroke crosses over from right to left and loops around in an upwards stroke then downwards to swoop under the “H” then swoops upwards to form the lower case “e” without leaving the paper.

The notary stamps are different too.

http://voice4americans.org/bank-fraud-my-story/debra-lyman-signed-doc-1.pdf�


Next an assignment of deed was fabricated. The filing date is 6/28/06 at 3:24:13 PM. This is the exact same date and time the Substitution of Trustee was filed.

Notice this assignment requests that the record be returned to GMAC-RFC (Litton is handwritten at the bottom.) Notice GMAC-RFC has the same address as Homecomings Financial Network, Inc. on this document.

Dishonesty and fraud is rampant with GMAC. Homecomings Financial Network Inc. is a subsidiary of Residential Funding Corporation (GMAC-RFC). In November 2006 General Motors sold 51% ownership of its subsidiary, the General Motors Acceptance Corporation (GMAC) to Cerebus Capital Management. Cerberus Capital Management, L.P. is one of the largest private equity investment firms in the United States.

On October 19, 2006, John W. Snow, President George W. Bush's second Treasury Secretary, was named chairman of Cerberus. Snow’s Gabriel Fund was a feeder fund for Bernard L. Madoff (http://en.wikipedia.org/wiki/Bernard_Madoff). Investment Securities LLC. Federal authorities arrested Madoff on December 11, 2008 (http://en.wikipedia.org/wiki/Madoff_investment_scandal) and he pled guilty to 11 federal crimes and admitted to operating the largest Ponzi scheme in history.) In January 2009 the Federal Reserve granted GMAC bank holding company status, so it could get access to the bailout money, (http://lunaticoutpost.com/Topic-Who-Runs-the-World-%E2%80%93-Network-Analysis-Reveals-%E2%80%98Super-Entity%E2%80%99-Global-Corporate-Ctrl?page=8). On December 29, 2008, the U.S. Treasury gave GMAC $5 billion from its $700 billion Troubled Asset Relief Program (TARP). On May 21, 2009, the U.S. Treasury department announced it would invest an additional $7.5 billion in GMAC, and on December 30, 2009, the U.S. Treasury department said that they would invest another $3.8 billion in GMAC because the company had been unable to raise additional funds in the private sector. The total government bailout to GMAC was $16.3 billion.

Both GMAC-RFC and Homecomings Financial Network, Inc. are subsidiaries of GMAC.

Why wasn’t an assignment recorded from People’s Choice to EMC or its parent company Bear Stearns?

EMC by its own admission in the letter dated 4/18/2006 “acquired” my mortgage from People’s Choice on 5/1/2004, yet there is no assignment showing this.

I made 2 ½ years of mortgage payments to EMC.

http://en.wikipedia.org/wiki/Bernard_Madoff�

http://en.wikipedia.org/wiki/Madoff_investment_scandal�

http://lunaticoutpost.com/Topic-Who-Runs-the-World-%E2%80%93-Network-Analysis-Reveals-%E2%80%98Super-Entity%E2%80%99-Global-Corporate-Ctrl?page=8�

http://lunaticoutpost.com/Topic-Who-Runs-the-World-%E2%80%93-Network-Analysis-Reveals-%E2%80%98Super-Entity%E2%80%99-Global-Corporate-Ctrl?page=8�


Dana Lantry appears to have been an employee of People’s Choice Home Loan, Inc., but she was not an Asst. Vice President; she worked in their Loss Mitigation department. Her name is on a loss mitigation form for UBS AG New York Branch which shared an address with People’s Choice Home Loan, Inc.

The date above Dana’s signature is 12/29/05 and it is written in the same handwriting as the one above the notary’s signature. It also states that the document was prepared by First American Title Insurance Company in Portland OR. The phone number, 503-790-7890, is disconnected.

First American Title Insurance Company’s name was gleaned from the original Deed of Trust filed in 2004. The same is true for Paul S. Cosgrove. This was done to give the fabricated documents an appearance of authenticity.

I spoke with Mitch Steeves, State Manager, at First American Title on 11/2/11 and emailed this assignment of deed of trust to him for review. He told me it is highly unlikely his company prepared this document. His email response is below:

A letter dated 4/3/06 was sent to me in from GMAC referencing a letter I wrote to their Vice President, Tom Donattacci, stated that GMAC do not own my mortgage.

A letter dated 4/18/2006 from EMC Mortgage stated GMAC had acquired my loan.

The problems I’m pointing out here are NOT just careless mistakes – they are deliberate attempts to deceive, i.e. FRAUD!

http://www.firstam.com/title/or/index.html�


Again here they name People’s Choice and Paul S. Cosgrove even though they file a substitution of trustee and assignment of deed of trust on the same day.

The way this document is written it appears that Paul S. Cosgrove is acting in behalf of People’s Choice, yet Cal-Western Reconveyance Corporation is added as a trustee too.

This was done to give the fabricated documents an appearance of authenticity.

They filed an amended trustee’s sale on 2/20/07….

Here they only claim I missed one month, when EMC had falsely claimed I missed five months; and they told my attorney it would take some $36,000 to reinstate the mortgage.


Lorrie Womack also signed foreclosure documents as an Asst Secretary, on behalf of MERS as nominee for Aurora Loan Services.

She is named as a defendant in other lawsuits in regards to her part in perpetrating fraudulent foreclosures throughout the western United States.


Tammy J. Wilde is the named “Trustee Sale Officer” on the 2007 amended trustee sale notice pertaining to Plaintiff’s property.

She is also named on numerous property sales records as a “Seller” along with Financial Networks Homecomings and JP Morgan Chase Bank.

This is further proof of collusion between the defendants to perpetrate fraudulent foreclosures as a cooperative criminal conspiracy.


On 8/27/2008 two more fabricated and fraudulent deed assignments were filed. This was during the time that Litton failed to pay my property taxes and home owner’s insurance as per the escrow agreement. I’d received a delinquent property notice and paid my taxes up to date.

Notice that “True and Actual Consideration” for this transfer is only $10.00.

Notice once again that this assignment is from People’s Choice to another GMAC subsidiary, Residential Funding Company, LLC.

Masse Adjetey signed as Vice President of Homecomings Financial Network, Inc. without a date. Masse Adjetey’s LinkedIn profile on the next page bears out more deceit and fraud.

This address for MGC Mortgage, 7195 Dallas Parkway, Plano, TX was an empty lot in 2008. Currently a building is being built there. Mail sent to this address is “force” delivered around the corner to 6000 Legacy Dr, Plano, TX 75024, the address for Beal Bank, Beal Financial Corp. and LVN Corp. Letters from the Plano Postmaster prove this.

MGC Mortgage is a subsidiary of Beal Bank/Beal Financial Corp.

MGC Mortgage has another address: 1 Corporate Dr., Ste 360, Lake Zurich, IL 60047-8945. This is the same address as Dovenmuehle Mortgage, Inc., a company that often shows up on trustee sale notices for MGC foreclosures. MGC doesn’t have an IRS tax id number.

D. Andrew Beal is a multi-billionaire gambler from Texas who is renowned for tax evasion and deceptive business practices. He has created 1000s of shelter or front corporations to launder his ill gotten funds. It’s speculated that he is a major shareholder of GMAC. He backed George W. Bush’s campaign for the presidency and is “in” with the Texas aristocrats. It isn’t by chance that Texas is hosts a majority of the notoriously nasty sub-prime lenders that have used unethical, deceptive, fraudulent and illegal business tactics.

People’s Choice Home Loan Inc. filed Chapter 11 in March 2007 and the company was dissolved long before 8/27/2008.

http://www.manta.com/c/mm05nd2/beal-financial-corporation�

http://dallas.citysearch.com/profile/map/36868830/plano_tx/beal_financial_corp.html�



http://www.manta.com/c/mtp5ddh/l-n-v-corp�

http://www.mortgagelendersearch.net/company/il/lake/lake-zurich/dovenmuehle-mortgage-inc/�


Masse Adjetey’s LinkedIn profile shows him as a Quality Technician for RytWay from August 2008 to October 2009, while at the same time he’s Mortgage Loan Specialist for Wells Fargo Home Mortgage.

I phoned RytWay and spoke with Peggy Anderson in their HR Department at 952-469-1417. She confirmed Masse Adjety-Adjevi was an employee and provided the following information:

His hire date was: 8/18/08 His termination date was: 5/15/09 His position was Quality Tech Level 1 and this is a medium skill level position where he tested the quality of food products.

Why would a person work full time testing the quality of food when at the same time he was employed as the “Vice President” of financial institution? Masse doesn’t mention working as the Vice President for Homecomings Financial Network, Inc. in his LinkedIn profile. I’m sure he wouldn’t have left this out of his profile if it were valid work history.

Homecomings Financial Network, Inc. is a GMAC subsidiary, and Masse claims to be an Operation Supervisor for GMAC Rescap, but this was from December 2000 to December 2007, so he was no longer working for GMAC in 2008.

Masse Adjetey shows up in many legal documents online as a robo-signer for MERS and Wells Fargo from 2009 to into 2011. He’s currently still the named contact for Wells Fargo on the MERS website:

I phoned the number provided here and in many other documents online on 10/31/11 in an attempt to speak with Masse Adjetey to confirm his authority to sign a deed assignment instrument for my home, but got a recorded message with a female voice saying that I’d reached the MERS desk at Wells Fargo. Two other phone numbers for

Masse Adjetey are available online, but one, (651-460-3592), has been disconnected, No one answers the second number, (651-463-4119), and there is no voice mail.


Betty Wright is another known robo signer working for Litton. And the notary who signed this document, Diane M. Meistad is a Partylite Consultant according to her WhitePages lisitng , but she works for GMAC-Rescap on her LinkedIn profile and other information about her available online shows her as being 74 years old. Both names show up on numerous deed assignments and other foreclosure related documents across the country.

People’s Choice Home Loan Inc. filed for Chapter 11 bankruptcy in March 2007 and the company was dissolved shortly thereafter.

Numerous such assignments were filed across the country with the Betty Wright and Diane M. Meistad signatures and/or notarized by Diane M. Meistad.

Notice the 3/10/2008 date on the notarization. On the following page are two more corporation deed assignments in favor of LVN signed on the same day.

Here is another Betty Wright signature with Diane M. Meistad signing as the notary. Notice here that Betty Wright’s title is “Limited Signing Officer.”

Copies of numerous other legal documents with the signatures of these women representing themselves as employees of different companies with different job titles are on the following page. Betty Wright is on many online lists of Robo signers working for GMAC and/or Litton.

Notice once again that this assignment is from People’s Choice, this time to LVN an Andy Beal subsidiary.

This assignment was filed the same date as the other one on 8/27/2008

NNoottiiccee tthhaatt ““TTrruuee aanndd AAccttuuaall CCoonnssiiddeerraattiioonn”” ffoorr tthhiiss ttrraannssffeerr iiss oonnllyy $$1100..0000..

http://www.corporationwiki.com/Texas/Plano/lnv-corporation/28474028.aspx�




Notice the 3/10/2008 date on the notarization. Many more examples of these two women’s signatures on foreclosure documents across the country prepared with this same date exist.

Michael Mead is on a list of known robo signers. Diane M. Meistad is the notary on many documents signed by him as well; and again many contain the date 3/10/2008.


Diane M. Meistad’s LinkedIn profile is curious because she is listed as a Sr. Post Funding Specialist with GMAC-Recap, but she has only has 1 connection and no previous work experience. This is odd for someone with a senior level position. Compare her profile with Betty Wright’s profile that is typical for a mature career professional.

It’s possible that Diane Meistad’s LinkedIn profile was created by someone other than her to deceive anyone who might investigate her notary information.

Notice that in her PeekYou profile Daine M. Meistad is listed as being 74 years old. If this is true then she was 70 years old when she signed the deed assignment documents for my property.

Diane M. Meistad is a Partylite Consultant according to her White Pages listing.


This is a very interesting document. The emergence of these rescission notices in Oregon foreclosures is an attempt to get around Oregon laws: Read this article to better understand what’s going on here.

Foreclosure Sale Rescissions in Oregon? http://www.q-law.com/?p=2228

ORS 86.735(1) requires that in order to foreclose, not only must the original trust deed be recorded, but all successive assignments of that trust deed, must be recorded as well. Without this “chain of title,” there is no way to know if the entity conducting the foreclosure has any right to do so. Without knowing the “genealogy” of the entire loan (i.e. who had owned it), from start to finish, it is impossible to know who has the legal right of foreclosure today.

This chain of title is definitely broken in my case; and every assignment that was filed is blatant fraud!

On 2/24/11 they file a recession of default. They filed the 2006 fraudulent notice of default although there was no default.

In 2008 two assignment of deeds were filed on the SAME DAY both assigning deed from People’s Choice Home Loan, Inc (a company that was dissolved in 2007) to in one assignment Residential Funding Company, LLC., and in the other assignment LVN Corporation. In both cases the “True and Actual Consideration” was $10.

Very interesting that Litton has re-emerged in these documents.

http://www.q-law.com/?p=2228�

http://www.q-law.com/?p=2228�


Both Pamela Campbell and Rosalyn Hall are notorious Robo-signers. Lots of information about them is available online. What’s even more important, though, is that their signatures are forgeries.

They may, or may not, be real people. What is clear from comparing their signatures is that multiple people are signing their names on documents. They deliberately and routinely forge signatures like this to fabricate documents that appear legal with intent steal people’s homes.

It does not take a handwriting expert to see that the various signatures here for Rosalyn Hall are not made by the same person. Hyperlinks to the documents with these signatures are below.

Pamela Campbell signs as an officer of Cal-Western Reconveyance Corp.; MERS Inc., Wells Fargo and other banks; and she also signs as a notary. Her signatures and hyperlinks to documents with her signature are on the next page.

It’s intentional fraud when you forge signatures and claim to be someone you are not.


This is a copy of Rosalyn Hall’s signature on her Notary Public Oath on file with the San Diego County Clerk’s Office. This can be verified at 619-237-0502.

It is clear the Rosalyn Hall signature on the fraudulently fabricated Recession of Notice of Default in my case does not match this official signature.

The Notary Public Section of the California Secretary of State told me they have received several complaints of notary stamps being used by parties other than the commissioned notary.

Using another person’s notary commission stamp and forging their signature is a crime.

Forgery is fraud.

Full documents with Rosyln Hall’s signatures will be presented to the court: Notice of Default Klamath County OR: http://voice4americans.org/bank-fraud-my-story/rosalyn-hall-notary-signature1.pdf Notice of Default Josephine County OR: http://voice4americans.org/bank-fraud-my-story/rosalyn-hall-notary-signature2.pdf Notice of Default Polk County OR: http://voice4americans.org/bank-fraud-my-story/rosalyn-hall-notary-signature3.pdf Notice of Default Jackson County OR: http://voice4americans.org/bank-fraud-my-story/rosalyn-hall-notary-signature4.pdf Trustee’s Deed Skagit County WA: http://voice4americans.org/bank-fraud-my-story/rosalyn-hall-notary-signature5.pdf Another Notice of Default Polk County OR: http://voice4americans.org/bank-fraud-my-story/rosalyn-hall-notary-signature6.pdf Another Trustee’s Deed Skagit County WA: http://voice4americans.org/bank-fraud-my-story/rosalyn-hall-notary-signature7.pdf

http://voice4americans.org/bank-fraud-my-story/rosalyn-hall-notary-signature1.pdf�








This is the signature on the Rescission of Notice of Default for my property.

Who is Pamela Campbell, really? These signatures look like a deliberate attempt to deceive and create the appearance of two or more individuals named Pamela Campbell signing documents under different roles.

Hyperlinks to full documents with Pamela Campbell’s signatures:

Assignment of Mortgage - Pottawattamie County IA: http://voice4americans.org/bank-fraud-my-story/pamela-campbell-104-27838.pdf

Loan Modification Agreement - Pottawattamie County IA http://voice4americans.org/bank-fraud-my-story/pamela-campbell-notary-104-22375.pdf

Appointment of Successor Trustee - Skagit County WA: http://voice4americans.org/bank-fraud-my-story/pamela-campbell-signed-doc-not-notary.pdf

http://voice4americans.org/bank-fraud-my-story/pamela-campbell-104-27838.pdf�

http://voice4americans.org/bank-fraud-my-story/pamela-campbell-104-27838.pdf�

http://voice4americans.org/bank-fraud-my-story/pamela-campbell-notary-104-22375.pdf�

http://voice4americans.org/bank-fraud-my-story/pamela-campbell-notary-104-22375.pdf�

http://voice4americans.org/bank-fraud-my-story/pamela-campbell-signed-doc-not-notary.pdf�

http://voice4americans.org/bank-fraud-my-story/pamela-campbell-signed-doc-not-notary.pdf�


On 4/22/11, two months after filing the rescission of default they file a new trustee successor appointment and on the same day they file a new notice of default and intention to sell which is on the following page.

On this document I’m named as the “Grantor” and I can guarantee I am not granting anything to them.

Again they name Paul S. Cosgrove as the trustee and People’s Choice Home Loan, Inc. as “the beneficiary under that certain deed dated 2/10/2004 and recorded 3/1/2004…” They then claim the undersigned; LVN Corporation is the present beneficiary under the trust deed with Bernadette McDonnell as their authorized singer. On the next page is Bernadette’s signature as the Vice President of Dovenmeuhle Mortgage. The notary on this document, Lori

Beddard, like the others she is a known robo-signer. Comparisons of her signatures are on the next page.

Why is a notary from Illinois signing these documents? LVN Corporation is a Texas Corporation: http://www.powerprofiles.com/profile/00005139706978/LVN+CORPORATION-HOUSTON-TX

It’s another Andy Beal subsidiary, Like MGC Mortgage. Click on Jacob Cherner and you’ll see a few of Beal’s web of companies.

Bernadette’s signature on the left is where she signed as VP of Dovenmuehle, the signature on the right is from my document.

The way the B is formed in each signature is very different. The M is also formed differently in each signature. These signatures appear to be made by two different people.

http://www.powerprofiles.com/profile/00005139706978/LVN+CORPORATION-HOUSTON-TX�







http://www.corporationwiki.com/graphs/roamer.aspx?id=28679417�




On the left the pen stroke starts at the lower loop of the B sweeps upward to form both loops then with a continuous downward sweep forms the stem then loops up to form the other letters in one sweep moving up from the right, down on the left.

The signature on the left is from my document.

In the signature on the right the pen stroke begins at the stem of the B swoops upward then down to form the loops. These signatures appear to be made by two different people.

Once again People’s Choice Home Loan, Inc. was dissolved after bankruptcy in 2007 so LSI Title Company of Oregon, LLC cannot be a successor trustee in favor of PCHLI.

Now some new third party (or reinvented old party) is attempting to claim a default in behalf of a company that hasn’t existed for four years. There has been no legal assignment of the trust deed to them. They claim I missed 50 payments. This is a false and fraudulent claim.


All these defendants are still forging signatures of people who may, or may not be, the officer they are represented as on these documents.

A B. Burdine signed this default notice on 4/20/11 and her/his signature was authorized by Orange County California notary Enedina O. Sanchez on 4/21/11. (How can a notary verify the person who signed a day later?)

Below are signatures from two other similar documents I found online with the signatures of these same two people. Notice the signatures are not the same as the ones on the notice of default for my property.

A comparison of these signatures and links to the full documents they came from are on the following page.


It does not take a handwriting expert to see that the various signatures here for B. Burdine are not made by the same person. Hyperlinks to the documents with these signatures are below.

The variations in the signatures here for Enedina O. Sanchez are more subtle than the differences in the signatures for B. Burdine above, but even if the same person did make these signatures a notary is sworn to validate other people’s signatures and this notary swore to the validity of three obviously different people making forged signatures. This is fraud.

Hyperlinks to the documents with these signatures are below:

Benton County, Oregon– Notice of Default – signed by both B. Burdine and Enedina O. Sanchez Skagit County, Washington – Trustee’s Deed – signed by Enedina O. Sanchez Clark County, Nevada – Notice of Default and Sale – signed by Enedina O. Sanchez Polk County, Oregon – Notice of Default and Sale – signed by both B. Burdine and Enedina O. Sanchez Klamath County, Oregon – Notice of Default and Sale – signed by Enedina O. Sanchez Jackson County, Oregon – Notice of Default and Sale – signed by Enedina O. Sanchez Jackson County, Oregon – Notice of Default and Sale – signed by Enedina O. Sanchez NOTE: Almost all these fabricated legal instruments involve LSI Title Company of Oregon, LLC as trustee and Quality Loan Service Corp. According to Bloomberg BusinessWeek LSI Title Company of Oregon, LLC operates as a subsidiary of Lender Processing Services, Inc. The Beal network of companies contains some 200 sham corporations created to deceive for purposes of tax evasion and the fabrication of fraudulent documents meant to deceive with intent to steal real estate properties.

Theft by deception, Oregon § 164.085, laundering a monetary instrument, Oregon § 164.170, and engaging in a financial transaction in property derived from unlawful activity, Oregon § 164.172, are felony offenses.

http://voice4americans.org/bank-fraud-my-story/enedina-o-sanchez-b-bardhe.pdf�

http://voice4americans.org/bank-fraud-my-story/enedina-o-sanchez-signature2.pdf�


http://voice4americans.org/bank-fraud-my-story/enedina-o-sanchez-b-bardhe-signature4.pdf�



http://voice4americans.org/bank-fraud-my-story/enedina-o-sanchez-signature.pdf�


US DISTRICT COURT Subramaniam v D. Andrew Beal, JPMorgan Chase, James Dimon

Documents

Transcript of US DISTRICT COURT Subramaniam v D. Andrew Beal, JPMorgan Chase, James Dimon