CALIFORNIA ATTORNEY GENERAL COMPLAINT CALIFORNIA SENATE BILL NO. 1474 RE: CONVENING GRAND JURY FOR MORTGAGE FRAUD

by Barry Fagan
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CALIFORNIA ATTORNEY GENERAL COMPLAINT

CALIFORNIA SENATE BILL NO. 1474 RE: CONVENING GRAND JURY FOR MORTGAGE FRAUD

Barry S Fagan

20475 Roca Chica Dr.

Malibu, California 90265

Complaint Against:

Wells Fargo Bank, N.A.

420 Montgomery Street

San Francisco, California 94104

COMPLAINT

As an Officer of the Court, I am under a continuing obligation to inform both the Court and Law Enforcement of Fraud and Perjury. As a result, I have retained Dr. Laurie Hoeltzel a forensic document examiner with over 20 years of forensic document analysis experience to confirm that three different versions of the same deed of trust exists for my primary residence and on May 11, 2012 I recorded all three versions of the same deed of trust with the Los Angeles Registrar Recorders Office under instrument no. 2012-0711277.

DOCUMENT FRAUD

Wells Fargo Bank has fraudulently altered Barry Fagan's Deed of Trust and the attached expert opinion dated 1/12/2012 from Forensic Document Examiner Dr. Laurie Hoeltzel specifically explains that the handwritten page 4 has been altered on two separate versions of that original Deed of Trust. Dr. Laurie Hoeltzel makes the following findings of fact with respect to the LA Registrar Recorder’s ‘original office record'. “Based upon my initial preliminary analysis of the above items, it appears more than one person authored the number 4 on all three documents, which purports to be the same document.” The recorded Notice of Pendency of Action shows three different versions of that same July 9, 2007 Deed of Trust as originally recorded under instrument no. 2007-1622100 and I have submitted credible evidence from a forensic document examiner with over 20 years of experience that multiple fraudulent alterations have occurred on the “Handwritten Number page 4” which is located on page 3/4 of the Deed of Trust. All of the Deeds of Trust now reflect an entirely different handwritten NUMBER 4, and one of the exhibits also has a snake like line drawn on it, which is not present on the other two exhibits.

ACCOUNTING

C.P.A. Shawn P. Adamo stated: "It is my professional opinion that the altered deed of trust is concealing an irrevocable assignment, and explains why Wells Fargo is unable to produce loan level accounting concerning Mr. Fagan’s loan. Wells Fargo claims that any level of detail relating to Mr. Fagan’s mortgage is non- existent. As a result, CPA Shawn Adamo provided two expert opinions, one an affidavit signed under penalty of perjury dated January 24, 2012 and the other is a Feb. 6, 2012 complaint letter addressed to various regulatory agencies. In those two expert opinions, C.P.A Shawn Adamo explains that Wells Fargo Bank has failed to provide a loan level balance sheet accounting and is concealing the fact that they do not own Barry Fagan's loan.

ROBO-SIGNING

Additionally, forensic document Expert Dr. Laurie Hoeltzel has declared under penalty of perjury on January 2, 2012 that Wells Fargo Bank is robo-signing Discovery Responses by using multiple authors of the name Rhonda Bernard Thomas.

CONCLUSION

Insofar as Wells Fargo Bank, NA is a loan servicer, it cannot enforce the note in its own right in that according to the information in the documents and the information available through discovery and expert opinions, the loan is owned by an undisclosed investor with which Wells Fargo has concealed and not established its relationship too.

Wells Fargo as the alleged servicer must, in addition to establishing the rights of the true holder, identify itself as an authorized agent for the INVESTOR.

If Wells Fargo Bank is compelled by law enforcement to comply with either of the obligations described above, it will subject them (Wells Fargo) to a finding of perjury!

Wells Fargo is a criminal enterprise that is attempting to exercise rights over my primary residence by way of fraudulently altered documents, robo-signed discovery responses, no loan level accounting and Barry Fagan's loan file needs to be investigated at the highest level within your organization to see that a crime has actually occurred!

The law offices of Kutak Rock LLP located in Irvine, California needs to have Barry Fagan's Note and Deed of Trust subpoenaed so that the GRAND JURY can inspect those documents to see that they have indeed been fraudulently altered and photo-shopped.

Barry Fagan Esq.

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