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Denise SubramaniamSelf-represented13865 SW Walker RdBeaverton OR 97005503-764-5300
UNITED STATES DISTRICT COURT
DISTRICT OF OREGON
PORTLAND DIVISION
LNV CORPORATION Civil Case No. 3:14-cv-01836
Plaintiff,
v. DEFENDANT’S MOTION TO
DENISE SUBRAMANIAM COMPEL PLAINTIFF TO
pro per PRODUCE NEVADA BUSINESS
Defendant LICENSE AND AGREEMENT
MOTION TO COMPEL PLAINTIFF TO PRODUCE NEVADA BUSINESS LICENSE
AND AGREEMENT BETWEEN GMAC-RFC AND PLAINTIFF SPECIFIC TO ITS
CLAIM OF PURCHASE OF DEFENDANT’S DEED OF TRUST
Defendant incorporates herein all her pleadings in this case; her Notice of Directly Related
Cases; her Notice of Constitutional Questions as well as the Notices of Constitutional Questions
filed by the other LNV/Beal victims in the noticed related cases; and in her noticed related cases;
and moves this court pursuant to Federal Rule 12 and Federal Rule 903(11) and Rule 803(6) and
Rule 803(7) (and/or any other Rules to which Defendant as a pro-se litigant may not be aware) to
compel Plaintiff to produce the following records of a regularly conducted activity:
1. Plaintiff LNV Corporation’s (“LNV”) Nevada business license.
2. Plaintiff LNV’s purchase agreement with GMAC’s Residential Funding Corporation
(“GMAC-RFC”) specific to the purchase in which it alleges to have acquired Defendant’s
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deed of trust and the deeds of trust/mortgages of the other LNV/MGC/Beal victims in
Defendant’s Notice of Directly Related Cases.
Contrary to LNV’s objection claims specified in the letter LNV’s Counsel Gabrielle Richards
sent to Defendant attached hereto as Exhibit A page 17. These documents are within the scope
of Defendant’s discovery as ordered by Honorable Judge Michael Mosman. At the status
conference hearing where Judge Mosman granted Defendant discovery she specified that she
would need the purchase agreement between LNV and GMAC-RFC.
As LNV’s Counsel Gabrielle Richards pointed out at the status hearing, in Oregon the Note
follows the deed. If the purported conveyance by assignment of deed never occurred or illegally
occurred then LNV cannot be the holder of the Note and LNV has no authority to foreclose on
Defendant’s property by executing the deed of trust to enforce the Note.
Defendant has claimed both that the Note is forged; and that the assignment or conveyance of the
deed never legally occurred. (The Note is forged and Defendant will provide the court with
evidence of this with her objection to LNV’s motion for summary judgment.) However Judge
Mosman specifically said at the status hearing the scope of Defendant’s discovery included
evidence that the conveyance of the deed did not or could not have occurred. In addition to the
securitization audit completed by Bill Paatalo in November 2012, who provided the court with a
sworn declaration specific to his findings which substantiate Defendant’s claim that LNV’s
alleged conveyance of Defendant’s deed never occurred; such conveyance could not have legally
occurred because LNV was not licensed by the State of Nevada to conduct business until after
the March 10, 2008 execution date on the assignment of deed of trust in question.
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Nevada corporation statues govern Nevada corporations and Plaintiff LNV by its own admission
is a Nevada corporation. NRS 76.100(1) states:
“A person shall not conduct a business in this State unless and until the person obtains a
state business license issued by the Secretary of State. If the person is: (a) An entityrequired to file an initial or annual list with the Secretary of State pursuant to this title, the person must obtain the state business license at the time of filing the initial or annuallist.”
LNV Corporation is an entity “required to file an initial or annual list with the Secretary of State”
and LNV Corporation was not incorporated until March 17, 2008, so it could not have filed its
first annual list with the Secretary of State prior to this date, and in fact it did not.
LNV could not have obtained a business license prior to its date of incorporation so it could not
have been in compliance with NRS 76.100(1) until after March 17, 2008. Hence the March 10,
2008 corporate assignment of deed of trust alleging to transfer beneficial interest in the
Defendant’s deed of trust to LNV was illegally transacted by LNV in violation of NRS
76.100(1).
If LNV transacted business without a valid Nevada business license in violation of NRS
76.100(1) then this fact is material as to whether this Honorable Court has jurisdiction to grant
Plaintiff LNV the relief it seeks based on an illegally transacted instrument; and it is material as
to whether a legal conveyance of deed occurred.
LNV’S NEVADA BUSINESS LICENSE IS NEEDED TO DETERMINE IF ACONVEYANCE OF THE DEED TO LNV EVER LEGALLY OCCURRED
Plaintiff’s business license is material as to whether or not LNV transacted a conveyance of the
deed of trust to Defendant’s property in violation of NRS 76.100(1). According to JoAnn Larson
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from the Nevada Secretary of State (“Nevada SOS”) office a copy of LNV’s business license
would need to be obtained directly from LNV.
LNV’s business license states the date of its issuance and if that date is after March 10, 2008
then the only conclusion that could be inferred from this fact would be that the conveyance of
Defendant’s deed of trust to LNV on March 10, 2008 violated NRS 76.100(1) and was therefore
an illegal business transaction.
The doctrine of unclean hands bars relief to a party who has engaged in inequitable behavior
(including fraud, deceit, unconscionability or bad faith) related to the subject matter of that
party's claim (see Soc'y of Lloyd's v. Shields, 118 F. App'x. 12, 15 (6th Cir. 2004)). The US
Supreme Court in Keystone Driller Co. v. General Excavator Co., 290 U.S. 240, 244–45 (1933)
articulated unclean hands as follows:
“[T]hat whenever a party who, as actor, seeks to set the judicial machinery in motion andobtain some remedy, has violated conscience, or good faith, or other equitable principle,in his prior conduct, then the doors of the court will be shut against him in limine; the
court will refuse to interfere on his behalf, to acknowledge his right, or to award him anyremedy.”
In a later case, the Supreme Court explained the rationale of unclean hands: “That doctrine is
rooted in the historical concept of court of equity as a vehicle for affirmatively enforcing the
requirements of conscience and good faith. This presupposes a refusal on its part to be ‘the
abetter of iniquity.’” Id. at 814 (quoting Bein v. Heath, 47 U.S. (6 How.) 228, 247 (1848)).
The assignment of Defendant’s deed of trust which falsely purports to convey beneficial interest
from GMAC-RFC to LNV is endorsed by GMAC-RFC employee Betty Wright and notarized by
GMAC-RFC employee Diane M. Meistad and it was executed on March 10, 2008. The
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assignments of deed of trust/mortgage to LNV in the noticed related cases were also endorsed by
GMAC-RFC employee Betty Wright or GMAC-RFC employee Michael Mead and are all
notarized by GMAC-RFC employee Diane M. Meistad. Copies of these assignments executed
on March 10, 2008 are included with a copy of the assignment specific to Defendant’s deed of
trust in Exhibit B page 20 attached hereto. In addition to those assignments specific to the six
LNV/MGC/Beal victims named in the noticed related cases at least twenty (20) other
assignments to LNV executed on March 10, 2008 are included in this exhibit. The sworn
Affidavit testimony of Terry Howard, another LNV/MGC/Beal victim who witnessed a phone
conversation between Diane M. Meistad and Defendant, supports the fact that Betty Wright,
Michael Mead and Diane M. Meistad were all in fact GMAC and/or GMAC-RFC employees.
Diane M. Meistad also explained that GMAC had a big deal with LNV and how she and the
others signed documents for this transaction for many weeks.
The fact that the parties endorsing these instruments were all GMAC-RFC employees gives
evidences to, and supports what Diane M. Meistad told Defendant and Terry Howard on the
phone; a single transaction occurred between Plaintiff LNV and GMAC-RFC on or before
March 10, 2008 prior to the time in which LNV was licensed to do business in Nevada.
The purchase agreement between GMAC-RFC and LNV and the circumstances in which these
documents were endorsed and by whom they were endorsed and whether the parties so endorsing
these documents had the requisite authority to make such endorsements and/or whether they
themselves made the signatures or whether some other individual made them or they were
computer generated is material to any factual determination as to whether LNV has standing to
foreclose on Defendant’s property; but just as importantly this Honorable Court has an obligation
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to the public and to the United States Constitution to protect the equity and property rights of the
other LNV/MGC/Beal victims with deed/mortgage assignments dated March 10, 2008 which
LNV has targeted for foreclosure.
THE PURCHASE AGREEMENT BETWEEN LNV AND GMAC-RFC IS MATERIAL
TO WHETHER THE CONVEYANCE OF THE DEED LEGALLY OCCURRED
The purchase agreement between LNV and GMAC-RFC is material as to a determination of
whether or not a legal conveyance to LNV of beneficial interest in Defendant’s deed of trust
from GMAC-RFC ever occurred. It is therefore within the scope of Defendant’s discovery as
ordered by Honorable Judge Mosman.
LNV’s alleged conveyance of Defendant’s March 10, 2008 assignment and the March 10, 2008
assignments of deed of trust/mortgage to LNV specific to the real property of the other noticed
related victims of LNV/MGC/Beal and endorsed by GMAC-RFC employees Betty Wright or
Michael Mead and Diane M. Meistad are in the opinion of LNV’s Counsel Gabrielle Richards
acts of “frivolous discovery” which she claims she voiced concerns about at the status
conference hearing.
Defendant recalls Your Honorable Judge Mosman asking LNV’s Counsel Gabrielle Richards
three times whether a forged Note would be material to her client’s standing to foreclose. She
evaded the question the first time, she claimed she didn’t believe the Note was forged the second
time, and finally after a reprimand by Your Honor she agreed that it would.
As an indigent disabled pro se litigant (made so by years of paying attorney fees and of suffering
mental anguish defending against numerous fraudulent foreclosure attempts on her property)
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Defendant cannot afford to pay the $95 fee required for the transcript of the status conference
hearing at this time. She distinctly recalls Your Honor saying her discovery scope included
evidence that would show that the conveyance of her deed of trust to LNV did not or could not
have occurred.
The purchase agreement between LNV and GMAC-RFC is material as to whether or not
Defendant and the other LNV/MGC/Beal victims including but not limited to the victims named
in the noticed related cases have been victims of racketeering activities and as such are entitled to
treble damages pursuant to 18 U.S. Code § 1961 et seq. (Racketeer Influenced and Corrupt
Organizations Act or “RICO”). Whether or not D. Andrew Beal has promoted and engaged in a
conspiracy to interfere with the civil rights of Defendant and the other LNV/MGC/Beal victims
pursuant to 42 U.S. Code § 1985 et seq. through a pattern of willful fraud upon courts and abuse
of judicial process for personal gain is and should be a concern for this court and the other courts
hearing foreclosure cases involving the property of the other LNV/MGC/Beal victims. Beal’s
personal gain is at the expense of his victims and is achieved via his corrupt enterprise consisting
of numerous shell corporations, like LNV. He deprives his victims of their property, of their
liberty to enjoy or make beneficial financial decisions regarding their investment in their
property, and of their life quality. He does this under color of law. And the pattern of fraud and
judicial abuse he willfully engages in deprives his victims of their due process.
MGC Mortgage Inc. (“MGC”) is a purported mortgage servicer for Plaintiff LNV, Counsel for
LNV has admitted as much in an email communication with the court specific to MGC’s now
former employee Bret Maloney. MGC misappropriates mortgage payments as evidenced by
LNV/MGC/Beal victim Catherine Gebhardt’s six thousand dollar ($6,000) cashier’s check made
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payable to MGC but paid to Beal Bank SSB on October 29, 2008. (See Defendant’s Exhibit C
page 61 attached herein) and by the numerous consumer complaints filed with the Texas
Attorney General’s office about MGC misappropriating their payments or by MGC’s refusal to
accept payments. (Copies of these letters are attached as Exhibit B-1 and B-2 to Defendant’s
Notice of Related Cases [doc 59-1].) The pattern of misappropriated payment is the same for all
these LNV/MGC/Beal victims.
Defendant also claims that she never defaulted on her mortgage but was a victim of a trumped up
false default claim made by EMC Mortgage in 2005; and which Litton Loan Servicing (“Litton”)
used to attempt a fraudulent foreclosure on her property in 2006. In 2006 the fact that Litton was
attempting to foreclose on Defendant’s property in behalf of GMAC-RFC was concealed from
Defendant and her attorney. Litton was unable to perfect this 2006 foreclosure action, which
they had proceeded with in spite of Defendant’s attorney proving she had satisfactorily made all
her mortgage payments, and in spite of her attorney’s request for Litton to cancel the sale and
clean up their false credit reporting so Defendant could refinance. Litton’s stated reason was that
their client had “no incentive” because of the amount of equity Defendant had in her property.
LNV is now attempting to perpetrate its own fraud on Defendant in this new foreclosure action.
Beal Financial Corporation, Beal Service Corporation, Beal Bank SSB, Beal Bank USA and
hundreds of shell sham corporations created by D. Andrew Beal to shield him from personal
liability to the victims of his crimes; and designed to deceive the government and prevent
regulators and other government authorities from detecting his corrupt enterprise racketeering
activities. The Beal organization’s parts interact to produce a joint effect that is greater than the
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sum of the parts acting alone. The illusion D. Andrew Beal creates of a division between his
many corporate entities is a willful deception.
A TRANSACTION WILLFULLY EXECUTED IN VIOLATION OF STATUE IS NOTENTITLED TO COURT PROTECTION OR SANCTION
Nevada statute bars a Nevada corporation from transacting business prior to its date of
incorporation and bars a Nevada corporation from engaging in any business activity without a
Nevada business license.
Defendant’s Exhibit D page 68 attached hereto is a certified copy of LNV’s Articles of
Incorporation obtained from the Nevada Secretary of State which shows that LNV was not
incorporated until March 17, 2008. LNV’s Articles of Incorporation state on page one (1) that it
is organized under the “General Corporation Law of the State of Nevada.” However NRS
78.020(2) states:
“No trust company, savings and loan association, thrift company or corporationorganized for the purpose of conducting a banking business may be organized under thischapter.”
LNV via its foreclosure complaint against Defendant is attempting to enforce a promissory note
to a mortgage contract via an assignment of deed of trust which was executed on March 10,
2008, seven (7) days prior to LNV’s legal existence as a corporate entity and prior to it acquiring
a Nevada business license.
Plaintiff LNV is in fact “organized for the purpose of conducting a banking business” dealing in
mortgages as evidenced by its own foreclosure complaint in the present case and in its
foreclosure complaints against the other LNV/MGC/Beal victims identified herein and in
Defendant’s Exhibit B.
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Nevada Attorney General Opinion 709 (12-17-1948) states:
“Foreign trust company must qualify under banking law to deal in mortgages. Foreigntrust company, in order to buy, sell mortgages on real estate in Nevada, must qualifyunder banking laws rather than general corporation laws.”
Because LNV deals in mortgages it is required by Nevada statute to qualify under banking laws.
By incorporating LNV pursuant to NRS 78.020(2) D. Andrew Beal violated Nevada statues and
is operating LNV illegally.
LNV was illegally incorporated because its Articles of Incorporation fail to disclose its true
business purpose; which was most certainly known to its president and director, D. Andrew Beal.
The fact that D. Andrew Beal is the president and director of LNV is stated in the Nevada SOS
business details for LNV attached hereto as Exhibit E on page 78.
D. Andrew Beal’s deception about the true nature of his LNV Corporation’s business activities
was willful with intent to create a chain of shell corporations which he uses to shield himself
from personal liability for his unlawful activities.
D. Andrew Beal is also president, director and secretary of Beal Bank USA (the Nevada
corporate parent of LNV according to LNV’s Corporate Disclosure); D. Andrew Beal is the
president and director of Beal Nevada Corp.; D. Andrew Beal is the director of Beal Nevada
Service Corporation; D. Andrew Beal is the president and director of Beal Leasing Corporation;
and D. Andrew Beal is the president and director of Beal Savings Investment Corporation. None
of these Beal corporations are publically traded and all are fully controlled by D. Andrew Beal.
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LNV Corporation is merely an “alter ego” for D. Andrew Beal. Beal’s other business entities he
incorporated in Nevada (see Exhibit E attached herein) are similarly “alter egos” for D. Andrew
Beal. NRS 78.747(3) states:
“The question of whether a stockholder, director or officer acts as the alter ego of acorporation must be determined by the court as a matter of law.”
LNV Corporation is according to LNV’s corporate disclosure wholly owned by Beal Bank USA,
which is wholly owned by Beal Financial Corporation, none of which are publically traded. In
fact Daniel Andrew “Andy” Beal aka D. Andrew Beal is the primary or sole “shareholder.”
D. Andrew Beal alone influences, governs and controls all these corporate entities and is fully
responsible for their corporate actions. LNV Corporation is inseparable from Beal Bank USA,
which is inseparable from Beal Financial Corporation; which are also all inseparable from Beal
Bank SSB; MGC Mortgage Inc.; LPP Mortgage LTD; CLMG Corporation, CXA Corporation;
and hundreds of other shell sham corporations created for D. Andrew Beal. A shell corporation is
a company which serves as a vehicle for business transactions without itself having any
significant assets or operations. A sham is a thing that is not what it is purported to be. It’s
something bogus or false.
These shell sham corporations owned by D. Andrew Beal, including LNV Corporation and MGC
commingle assets as evidenced by LNV/MGC/Beal victim Catherine Gebhardt’s six thousand
dollar ($6,000) cashier’s check made payable to MGC but paid to Beal Bank SSB on October 29,
2008. (See Defendant’s Exhibit C attached herein.) Not only did this check made payable to
MGC get paid into an account for Beal Bank SSB but MGC claimed this payment made by
Gebhardt was never received and MGC’s false claim as to its not receiving this check and other
checks Gebhardt paid to MGC was used as the basis for LNV to foreclose on Gebhardt’s
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property. When LNV failed at foreclosure it brought a “breach of contract” suit against Gebhardt
in federal court. LNV Corporation v. Gebhardt, Case No. 3:12-CV-468-TAV-HBG, U.S. District
Court Eastern District of Tennessee at Knoxville.
Beal Bank SSB, a Texas corporation, is different from Beal Bank USA, a Nevada corporation.
As per LNV’s Corporate Statement Beal Bank USA is the parent corporation for Plaintiff LNV
but a Beal entity incorporated in Texas, Beal Bank SSB, received the funds from Gebhardt’s
cashier’s check made payable to MGC Mortgage; so the comingling of funds and assets is not
just between child and parent corporations.
There is no real separation between the various Beal corporations and each other or their owner,
D. Andrew Beal. This court can and should pursuant to NRS 78.747(3) find that Plaintiff LNV
Corporation is just a sham (i.e. D. Andrew Beal’s alter ego.) Another court has already
adjudicated similar facts specific to other Beal shell corporations and made conclusions that
these shell corporations were created as sham tax shelters. (See Southgate Master Fund, LLC v.
United States, 659 F. 3d 466 - Court of Appeals, 5th Circuit 2011 and Bemont Investments,
L.L.C. v. United States, 679 F.3d 339 (5th Cir. 2012).)
Beal’s shell corporations (including but not limited to LNV, MGC and LPP) are false fronts to
shield D. Andrew Beal from legal liability for his fraudulent and criminal activities. NRS
78.030(1) states:
“A person shall not establish a corporation for any illegal purpose or with the fraudulentintent to conceal any business activity, or lack thereof, from another person or agovernmental agency.”
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The numerous consumer complaint letters written to the Texas Attorney General about Beal’s
MGC and attached as an exhibit it Defendant’s Notice of Related Cases shows that MGC is not a
“mortgage servicer” as it purports to be but that D. Andrew Beal incorporated MGC for the
purpose of putting homeowners into false defaults so Beal’s sham LNV or LPP can then
foreclosure using forged documents so that D. Andrew Beal can conceal these activities and his
personal proceeds derived from these activities from the government.
D. Andrew Beal uses his sham shell corporations to deprive citizens of the United States,
including Defendant, of their real property; their liberty to enjoy their real property or to make
beneficial financial decisions about their investment in their real property. D. Andrew Beal
conspires with others to deprive his targets/victims of their civil rights and their property under
color of law.
NRS 78.747(1) provides an exception for individual liability of a stockholder, director or officer
of a corporation when he acts as the alter ego of the corporation. NRS 78.747(2) states: “A
stockholder, director or officer acts as the alter ego of a corporation if:
(a) The corporation is influenced and governed by the stockholder, director or officer;
(b) There is such unity of interest and ownership that the corporation and thestockholder, director or officer are inseparable from each other; and
(c) Adherence to the corporate fiction of a separate entity would sanction fraud or promote a manifest injustice.”
LNV Corporation i.e. D. Andrew Beal appears to be operating a corrupt business enterprise
engaging in several racketeering activities as defined by 18 U.S. Code § 1961 et seq. and appears
to be using his enterprise of shell sham corporations to conspire with others to fraudulently
deprive Defendant and his other targets/victims of their civil right pursuant to 42 U.S. Code §
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1985 et seq. and of their property in violation of their rights pursuant to the United States
Constitution.
D. Andrew Beal doesn’t want the targets of his crimes (Defendant and the other noticed related
LNV/MGC/Beal victims) to consolidate their cases and to show judges and other government
authorities their collective evidence of the criminality of his activities because this would
establish a pattern of racketeering activities as defined by 18 U.S. Code § 1961 et seq. that may
result in criminal charges. This is the reason he so vehemently fights discovery. Evidence from
all the LNV/MGC/Beal victims cases when added together constitute a pattern of criminal acts
extending over many years which when reviewed collectively demonstrate, at the very least, the
appearance that D. Andrew Beal is operating a corrupt enterprise and conspiring with others to
perpetrate a racketeering scheme and artifice to defraud and is engaged in monetary transactions
in property derived from specified unlawful activity pursuant to 18 U.S. Code § 1957; engaged
in mail fraud pursuant to 18 U.S. Code § 1341 (what Lorraine Brown was convicted of for
forging mortgage related documents and mailing them to county land recorders offices); engaged
in money laundering in violation of 18 U.S. Code § 1956; engaged in bribery of judges and
counsel for opposing parties pursuant to 18 U.S. Code § 201 (See LNV Corporation v. Gebhardt
on appeal as Case No. 14-5605 in the United States Court of Appeals for the Sixth Circuit;
Breitlings v. LNV ; Case No. 3:15-CV-00703, U.S. District Court for the Northern District of
Texas Dallas Division; and the bankruptcy case of Christopher and Marcia Swift Case No. 12-
35690 In the United States Bankruptcy Court for the Northern District of Illinois, Eastern
Division.) These are all “racketeering activities” as defined by 18 U.S. Code § 1961 et seq. A
criminal investigation is warranted.
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Title 18 U.S.C. § 4 – Misprision of a Felony – states:
“Whoever, having knowledge of the actual commission of a felony cognizable by a courtof the United States, conceals and does not as soon as possible make known the same tosome judge or other person in civil or military authority under the United States, shall be
fined under this title or imprisoned not more than three years, or both.”
Defendant hereby informs the Honorable Judge Mosman that she and the other LNV/MGC/Beal
victims have knowledge of the actual commission of a felony cognizable by a court of the United
States specific to Plaintiff LNV and its owner D. Andrew Beal and LNV’s/Beal’s agents.
Defendant moves this court and Judge Mosman, if he hasn’t already done so, to report these
crimes to the FBI and to the United States Attorney General and to any other law enforcement
agency with authority to investigate these criminal activities pursuant to 18 U.S. Code § 4.
Defendant and the other LNV/MGC/Beal victims are not complaining about LNV and MGC
being “bad” companies; we are proving evidence to this court and to other courts that they are
part of a corrupt business enterprise controlled by D. Andrew Beal for his own personal gain and
engaged in “racketeering activities” as defined by 18 U.S. Code § 1961 et seq.
PLEADINGS OF PRO SE LITIGANTS HELD AT A LESS STRINGENT STANDARD
As a pro se litigant Defendant is disadvantaged in the discovery process because she doesn’t
have education in law and is learning as she goes. This is why the United States Supreme Court
has set precedence requiring courts to hold pleadings of the pro se litigant to a less stringent
standard. “Rule 8(f) provides that 'pleadings shall be so construed as to do substantial justice.'
We frequently have stated that pro se pleadings are to be given a liberal construction.” Estelle,
Corrections Director, et al. v. Gample 29 U.S. 97, 97 S. Ct. 285, 50 L. Ed. 2d 251.
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Defendant’ Motion to Consolidate Directly Related Cases Page 17 of 23
Due to being pro se Defendant did not know it is not proper procedure to subpoena an opposing
party. Counsel for LNV has exhibited a hostile attitude towards Defendant and has on several
occasions taken advantage of her disadvantaged position as a pro se litigant and of her medical
condition to thwart her rights to due process. Defendant also knows because of her continuous
interactions with the other LNV/MGC/Beal victims (some who are represented by counsel) that
LNV and other Beal corporate entities ferociously fight discovery, and even when ordered by a
court to produce certain documents they fail to do so. This certainly gives the appearance that
they have something to hide. As a result Defendant hesitated in serving LNV subpoenas but in
the end decided she had no choice not knowing this was not proper procedure.
PRAYER
Defendant prays this Honorable Court orders LNV to produce its Nevada business license and its
agreement with GMAC-RFC through which it allegedly obtained the assignments of deed of
trust/mortgage (including those pertaining to Defendant’s and the other LNV/MGC/Beal victims’
properties) dated / executed on March 10, 2008 and endorsed by GMAC-RFC employees Betty
Wright, Michael Mead and Diane Meistad.
Respectfully Submitted,
_________________________________________Denise Subramaniam
/s/ Denise Subramaniam
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing document was
served upon all counsel of record, pro-se parties and the United States Attorney General and the
Attorney General of the State of Oregon via the Court’s CM/ECF system, email, and/or regular
mail, and/or certified mail with return receipt requested.
U.S. Department of JusticeLoretta Lynch,U. S. Attorney General
950 Pennsylvania Avenue, NWWashington, DC 20530-0001202-514-2000
Gabrielle D. Richards | Perkins Coie LLP1120 NW Couch Street10th FloorPortland, Oregon 97209-4128D. +1.503.727.2255F. [email protected]
Respectfully Submitted,
_________________________________________Denise Subramaniam
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s Denise Subramaniam
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Exhibit A
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Exhibit B
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1 o f
1)
l D4.0
st.5 r s
1 5 6 5 6 6
LI8ER ~ o m P GE m
. $10.00
MISC RECORDING
H. 00 REttoHUilEtlT TI 11
'08/22/201)8
0 1 : z 1 : 5 ~ P.M.
RECE'IPH
7 3 ~ 8 5
PAID RECORDED - OAKlAtlO COUNTY
RUTH JOHHSOII.
CLERK/REGISTER
OF t<EEDS
Dated: 3/10/2008 CORPORATION ASSIGNMENT ofMORTGAGE
After Recording Return
to:
MGC Mortgage Inc
Document Control, Allison Martin
7195 Dallas Parkway
Plano, Texas 75024
RFC
Loan Nuinber:-ion7180
Seller Loan Number: 2006050 I 00428 l C.
:
(.,1 1 3' 3<;
11111111111111111111111111111111111111111111111111
MIN: 100175200003079665 MERS Phone: 1-888-679-6377
FOR VALUE
RECEIVED,
'(MERS) Mortgage Electronic Registration Systems, Inc,'
P-0.130V t1{)J .ot f l t n ~ , ~
l
~ 5 0 1 - OO d(,p
the undersigned hereby grants, assigns and transfers to
LNV Corporation
7195
Dallas
Parkway
Plano, Texas 75024
all beneficial interest under that certain Mortgage dated 9/25/2006 .
executed by MICHAEL SADLER .......
. t ' T < : . r i ' \ ~ H
.... S . l ler, h v s ~ < ; ~ v f .
...,.
M:
{6 96zl
ami recorded
in Bookn.aw._.9_n
Page 4 ~ ~ .. as Instrument No.
, ~ S S <t.2.B
on
O ~
of official Records in the County Recorder's Office of
Q{+
/c:./c;,..,
d
County, M chigan.
L c . ~ < - 1 :
l.&.
.. J...
,;.
- t k G-4y o{ 5 o J t ~ t . ~ l d C
0
.,.._
1
{
o,fc.f<.,_.J,
<;;+
fr.
• { fill, J : j
.
• P , • e ~ o o J /l1« S o > t . J • v • > l • ' - ' ~ <s ol <-<.o.n:/.r,l - •k r { 0 ~ , P '-S<- { P .. r,
MORTGAGE
AMOUNT: $145,000.00 o ..k-( ......_{ C . o . - ~ 1 / R.c.c.onl r
PROPERTY
ADDRESS: 17499 WEST THIRTEEN MILE ROAD SOUTHFIELD, Ml 48076
TOGETHER with the note or notes therein described or referred to, the money due and to become due thereon
with interest, and all rights accrued
or to
accrue under said Mortgage.
pIN # 9..'1-l).
-41 00}....
(MERS)Mortgage Electronic Registration Systems, Inc.'
/ )::3>
B Y ~
STATE
OF
COUNTY OF
Minnesota)
Hennepin)
NAME: Michael Mead '
TITLE: Assistant Vice President
On 3/10/2008 before me, the undersigned, a Notary Public in and for said State personally appeared Michael
Mead, Assistant Vice President of'(MERS) Mortgage Electronic Registration Systems, Inc.' personally known
to me
to
be the person whose name is subscribed
to
the within instrument and acknowledged to me that slhe
executed the same in his/her authorized capacity, and that by his/her signature on the instrument the entity upon
behalfof which the person acted, executed the instrument. WITNESS my hand and official seal.
Prepared 3/10/2008 by Diane Meistad, Residential
Funding Company, LLC, One Meridian Crossings,
Suite 100, Minneapolis, MN 55423, (952) 979-4000.
DIANE M. MEISTAO
NOTARY PUBLIC-MINNESOTA
IIJ CommllliCiflEqirlo JM.
31.2010
oJ .-LG
@
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Exhibit C
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Exhibit D
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Exhibit E
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y Details - Secretary of State, Nevada
nvsos.gov/SOSEntitySearch/CorpDetails.aspx?lx8nvq=Ljyliw%252bxIqnp3exaL0fiuw%253d%253d&nt7=0[8/30/2015 6:41:24 PM]
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LNV CORPORATION
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Business Entity Information
Status: Active File Date: 3/17/2008
Type: Domestic Corporation Entity Number: E0169702008-8
Qualifying State: NV List of Officers Due: 3/31/2016
Managed By: Expiration Date:
NV Business ID: NV20081614653 Business License Exp: 3/31/2016
Registered Agent Information
Name:THE CORPORATION TRUSTCOMPANY OF NEVADA
Address 1: 311 S DIVISION ST
Address 2: City: CARSON CITY
State: NV Zip Code: 89703
Phone: Fax:
Mailing Address 1: Mailing Address 2:
Mailing City: Mailing State: NV
Mailing Zip Code:
Agent Type: Commercial Registered Agent - Corporation
Jurisdiction: NEVADA Status: Active
View all business entities under this registered agent
Financial Information
No Par Share Count: 0 Capital Amount: $ 100.00
Par Share Count: 10,000.00 Par Share Value: $ 0.01
Officers Include Inactive Officers
President - D ANDREW BEAL
Address 1: 7195 DALLAS PARKWAY Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
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y Details - Secretary of State, Nevada
nvsos.gov/SOSEntitySearch/CorpDetails.aspx?lx8nvq=Ljyliw%252bxIqnp3exaL0fiuw%253d%253d&nt7=0[8/30/2015 6:41:24 PM]
Director - D ANDREW BEAL
Address 1: 7195 DALLAS PARKWAY Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
Secretary - TIM H TAYLOR
Address 1: 7195 DALLAS PARKWAY Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
Actions\Amendments
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y Details - Secretary of State, Nevada
/nvsos.gov/sosentitysearch/CorpDetails.aspx?lx8nvq=WiQ%252bNZZz9SFVNsoIcIj08Q%253d%253d&nt7=0[8/30/2015 7:51:01 PM]
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BEAL BANK USA
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Business Entity Information
Status: Active File Date: 7/27/2004
Type: Domestic Corporation Entity Number: C19892-2004
Qualifying State: NV List of Officers Due: 7/31/2016
Managed By: Expiration Date:
NV Business ID: NV20041538284 Business License Exp: 7/31/2016
Registered Agent Information
Name:THE CORPORATION TRUSTCOMPANY OF NEVADA
Address 1: 311 S DIVISION ST
Address 2: City: CARSON CITY
State: NV Zip Code: 89703
Phone: Fax:
Mailing Address 1: Mailing Address 2:
Mailing City: Mailing State: NV
Mailing Zip Code:
Agent Type: Commercial Registered Agent - Corporation
Jurisdiction: NEVADA Status: Active
View all business entities under this registered agent
Financial Information
No Par Share Count: 0 Capital Amount: $ 3,000,000.00
Par Share Count: 3,000,000.00 Par Share Value: $ 1.00
Officers Include Inactive Officers
President - D. ANDREW BEAL
Address 1: 6000 LEGACY DR Address 2:
City: PLANO State: TX
Zip Code: 75024 Country: USA
Status: Active Email:
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y Details - Secretary of State, Nevada
/nvsos.gov/sosentitysearch/CorpDetails.aspx?lx8nvq=WiQ%252bNZZz9SFVNsoIcIj08Q%253d%253d&nt7=0[8/30/2015 7:51:01 PM]
Director - D. ANDREW BEAL
Address 1: 6000 LEGACY DR Address 2:
City: PLANO State: TX
Zip Code: 75024 Country: USA
Status: Active Email:
Secretary - D. ANDREW BEAL
Address 1: 6000 LEGACY DR Address 2:
City: PLANO State: TX
Zip Code: 75024 Country: USA
Status: Active Email:
Actions\Amendments
Click here to view 19 actions\amendments associated with this company
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01 N Carson Street Suite 3 Carson City, NV 89701 | (775) 684-5708© 2010 All Rights Reserved. Privacy Policy and Disclaimer | About This Site
Case 3:14-cv-01836-MO Document 89 Filed 09/02/15 Page 84 of 93
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y Details - Secretary of State, Nevada
/nvsos.gov/sosentitysearch/CorpDetails.aspx?lx8nvq=0VlmXtVW9gN1QD%252fp0dh9QQ%253d%253d&nt7=0[8/30/2015 6:53:48 PM]
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BEAL NEVADA CORP.
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Business Entity Information
Status: Active File Date: 8/28/1997
Type: Domestic Corporation Entity Number: C18509-1997
Qualifying State: NV List of Officers Due: 8/31/2016
Managed By: Expiration Date:
NV Business ID: NV19971253976 Business License Exp: 8/31/2016
Registered Agent Information
Name:THE CORPORATION TRUSTCOMPANY OF NEVADA
Address 1: 311 S DIVISION ST
Address 2: City: CARSON CITY
State: NV Zip Code: 89703
Phone: Fax:
Mailing Address 1: Mailing Address 2:
Mailing City: Mailing State: NV
Mailing Zip Code:
Agent Type: Commercial Registered Agent - Corporation
Jurisdiction: NEVADA Status: Active
View all business entities under this registered agent
Financial Information
No Par Share Count: 0 Capital Amount: $ 1,000.00
Par Share Count: 1,000.00 Par Share Value: $ 1.00
Officers Include Inactive Officers
President - D. ANDREW BEAL
Address 1: 6000 LEGACY DRIVE Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
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y Details - Secretary of State, Nevada
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Director - D. ANDREW BEAL
Address 1: 6000 LEGACY DRIVE Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
Treasurer - JAMES W LEWIS JR
Address 1: 6000 LEGACY DRIVE Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
Secretary - TIM H TAYLOR
Address 1: 6000 LEGACY DRIVE Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
Actions\Amendments
Click here to view 22 actions\amendments associated with this company
nformation Center | Election Center | Business Center | Licensing Center | Securities Center | Online Services | Contact Us | Site
01 N Carson Street Suite 3 Carson City, NV 89701 | (775) 684-5708© 2010 All Rights Reserved. Privacy Policy and Disclaimer | About This Site
Case 3:14-cv-01836-MO Document 89 Filed 09/02/15 Page 86 of 93
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y Details - Secretary of State, Nevada
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BEAL NEVADA SERVICE CORPORATION
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Business Entity Information
Status: Active File Date: 4/5/2005
Type: Foreign Corporation Entity Number: E0180652005-3
Qualifying State: TX List of Officers Due: 4/30/2016
Managed By: Expiration Date:
NV Business ID: NV20051071880 Business License Exp: 4/30/2016
Registered Agent Information
Name:THE CORPORATION TRUSTCOMPANY OF NEVADA
Address 1: 311 S DIVISION ST
Address 2: City: CARSON CITY
State: NV Zip Code: 89703
Phone: Fax:
Mailing Address 1: Mailing Address 2:
Mailing City: Mailing State: NV
Mailing Zip Code:
Agent Type: Commercial Registered Agent - Corporation
Jurisdiction: NEVADA Status: Active
View all business entities under this registered agent
Financial Information
No Par Share Count: 0 Capital Amount: $ 3,000,000.00
Par Share Count: 3,000,000.00 Par Share Value: $ 1.00
Officers Include Inactive Officers
Director - D. ANDREW BEAL
Address 1: 6000 LEGACY DRIVE Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
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y Details - Secretary of State, Nevada
/nvsos.gov/sosentitysearch/CorpDetails.aspx?lx8nvq=03o9vAv6M8xaZoL24WPgrw%253d%253d&nt7=0[8/30/2015 6:55:00 PM]
President - JACOB CHERNER
Address 1: 6000 LEGACY DRIVE Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
Treasurer - CRAIG SINGER
Address 1: 6000 LEGACY DRIVE Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
Secretary - TIM H TAYLOR
Address 1: 6000 LEGACY DRIVE Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
Actions\Amendments
Click here to view 14 actions\amendments associated with this company
nformation Center | Election Center | Business Center | Licensing Center | Securities Center | Online Services | Contact Us | Site
01 N Carson Street Suite 3 Carson City, NV 89701 | (775) 684-5708© 2010 All Rights Reserved. Privacy Policy and Disclaimer | About This Site
Case 3:14-cv-01836-MO Document 89 Filed 09/02/15 Page 88 of 93
8/17/2019 DC 89 Denise's Motion to Compel LNV to Produce
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y Details - Secretary of State, Nevada
/nvsos.gov/sosentitysearch/CorpDetails.aspx?lx8nvq=WeuvYfu4K0dXULmXIF8%252ftQ%253d%253d&nt7=0[8/30/2015 6:52:42 PM]
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BEAL LEASING CORPORATION
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Business Entity Information
Status: Active File Date: 4/6/2005
Type: Domestic Corporation Entity Number: E0192292005-3
Qualifying State: NV List of Officers Due: 4/30/2016
Managed By: Expiration Date:
NV Business ID: NV20051106790 Business License Exp: 4/30/2016
Registered Agent Information
Name:THE CORPORATION TRUSTCOMPANY OF NEVADA
Address 1: 311 S DIVISION ST
Address 2: City: CARSON CITY
State: NV Zip Code: 89703
Phone: Fax:
Mailing Address 1: Mailing Address 2:
Mailing City: Mailing State: NV
Mailing Zip Code:
Agent Type: Commercial Registered Agent - Corporation
Jurisdiction: NEVADA Status: Active
View all business entities under this registered agent
Financial Information
No Par Share Count: 0 Capital Amount: $ 3,000,000.00
Par Share Count: 3,000,000.00 Par Share Value: $ 1.00
Officers Include Inactive Officers
President - D. ANDREW BEAL
Address 1: 6000 LEGACY DR Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
Home | About Barbara | Calendar | News | FAQ | Forms | Con
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Case 3:14-cv-01836-MO Document 89 Filed 09/02/15 Page 89 of 93
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y Details - Secretary of State, Nevada
/nvsos.gov/sosentitysearch/CorpDetails.aspx?lx8nvq=WeuvYfu4K0dXULmXIF8%252ftQ%253d%253d&nt7=0[8/30/2015 6:52:42 PM]
Director - D. ANDREW BEAL
Address 1: 6000 LEGACY DR Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
Treasurer - CRAIG SINGER
Address 1: 6000 LEGACY DR Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
Secretary - TIM H TAYLOR
Address 1: 6000 LEGACY DR Address 2:
City: PLANO State: TX
Zip Code: 75024 Country:
Status: Active Email:
Actions\Amendments
Click here to view 14 actions\amendments associated with this company
nformation Center | Election Center | Business Center | Licensing Center | Securities Center | Online Services | Contact Us | Site
01 N Carson Street Suite 3 Carson City, NV 89701 | (775) 684-5708© 2010 All Rights Reserved. Privacy Policy and Disclaimer | About This Site
Case 3:14-cv-01836-MO Document 89 Filed 09/02/15 Page 90 of 93
8/17/2019 DC 89 Denise's Motion to Compel LNV to Produce
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y Details - Secretary of State, Nevada
/nvsos.gov/sosentitysearch/CorpDetails.aspx?lx8nvq=WjcnmX0FycnqN63AZXxy7A%253d%253d&nt7=0[8/30/2015 6:58:04 PM]
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BEAL SAVINGS INVESTMENT CORPORATION
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Business Entity Information
Status: Active File Date: 7/27/2004
Type: Domestic Corporation Entity Number: C19897-2004
Qualifying State: NV List of Officers Due: 7/31/2016
Managed By: Expiration Date:
NV Business ID: NV20041538330 Business License Exp: 7/31/2016
Registered Agent Information
Name:THE CORPORATION TRUSTCOMPANY OF NEVADA
Address 1: 311 S DIVISION ST
Address 2: City: CARSON CITY
State: NV Zip Code: 89703
Phone: Fax:
Mailing Address 1: Mailing Address 2:
Mailing City: Mailing State: NV
Mailing Zip Code:
Agent Type: Commercial Registered Agent - Corporation
Jurisdiction: NEVADA Status: Active
View all business entities under this registered agent
Financial Information
No Par Share Count: 0 Capital Amount: $ 3,000,000.00
Par Share Count: 3,000,000.00 Par Share Value: $ 1.00
Officers Include Inactive Officers
Director - D. ANDREW BEAL
Address 1: 6000 LEGACY DRIVE Address 2:
City: PLANO State: TX
Zip Code: 75024 Country: USA
Status: Active Email:
Home | About Barbara | Calendar | News | FAQ | Forms | Con
LicCommercial RecordingsMy Data Reports
Case 3:14-cv-01836-MO Document 89 Filed 09/02/15 Page 91 of 93
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8/17/2019 DC 89 Denise's Motion to Compel LNV to Produce
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y Details - Secretary of State, Nevada
/nvsos.gov/sosentitysearch/CorpDetails.aspx?lx8nvq=WjcnmX0FycnqN63AZXxy7A%253d%253d&nt7=0[8/30/2015 6:58:04 PM]
President - D. ANDREW BEAL
Address 1: 6000 LEGACY DRIVE Address 2:
City: PLANO State: TX
Zip Code: 75024 Country: USA
Status: Active Email:
Treasurer - CRAIG SINGER
Address 1: 6000 LEGACY DRIVE Address 2:
City: PLANO State: TX
Zip Code: 75024 Country: USA
Status: Active Email:
Secretary - TIM H TAYLOR
Address 1: 6000 LEGACY DRIVE Address 2:
City: PLANO State: TX
Zip Code: 75024 Country: USA
Status: Active Email:
Actions\Amendments
Click here to view 15 actions\amendments associated with this company
nformation Center | Election Center | Business Center | Licensing Center | Securities Center | Online Services | Contact Us | Site
01 N Carson Street Suite 3 Carson City, NV 89701 | (775) 684-5708© 2010 All Rights Reserved. Privacy Policy and Disclaimer | About This Site
Case 3:14-cv-01836-MO Document 89 Filed 09/02/15 Page 92 of 93
8/17/2019 DC 89 Denise's Motion to Compel LNV to Produce
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Exhibit F
Case 3:14-cv-01836-MO Document 89 Filed 09/02/15 Page 93 of 93
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