Plaintiff v. U.S. Bank, N.A.; Wells...
My latest masterpiece! :) This action arises out of the wrongful foreclosure of a residential property in Los Angeles County, California. As alleged, the securitized trust did not have standing to foreclose on the property…more
Plaintiff v. JPMorgan Chase, Quality...
This action arises out of one of the thousands of "surprise" foreclosures in California which result from horribly one-sided California foreclosure laws. Specifically, in California, personal notice of a trustee's sale is only…more
Plaintiff v. JPMprgan Chase, Quality...
This Complaint arises out of the wrongful foreclosure of residential property after the foreclosing lender promised that it would not foreclose while a forebearance agreement and loan modification were in place and/or being…more
Plaintiff v. JPMprgan Chase, Quality...
This Complaint arises out of a "surprise" foreclosure after promises had been made by the lender that it would not foreclose. Thereafter, the foreclosure trustee refused to provide the surplus funds from the sale to the former…more
Plaintiff v. U.S. Bank, Specialized...
This Opposition is in response to a Demurrer to a wrongful foreclosure matter. Specifically, it addresses the standing of the foreclosing trustee and alleged beneficiary to foreclose on the property. Here, MERS allegedly…more
Said sample requests are for the loan servicer in a wrongful foreclosure/quiet title matter…more
These requests seek admissions from the loan servicer for a mortgage-backed securities trust as to whether the loan was serviced in compliance with the Pooling and Servicing Agreement ("PSA") of the trust and in accordance with…more
These requests are meant to be propounded to the trustee of a mortgage-backed securities fund to ascertain whether the trustee had standing, i.e., ownership of the note and deed of trust, at the time of foreclosure. Standing is…more
These are sample requests to be served on a loan servicer in an action in which there are issues regarding the accounting of the mortgage loan such as the proper crediting of payments, charging of unnecessary or excessive fees,…more
I recently propounded these requests to obtain documents from a mortgage-backed securities fund with regard to whether the fund had standing to foreclose on the subject property and whether the mortgage note and deed of trust at…more
Plaintiff v. U.S. Bank and Barclays
Here is an opposition to a demurrer filed by the foreclosing defendant which was a trustee for a mortgaged-backed securities fund. The issues were the preemption of the post-foreclosure unlawful detainer judgment, the role of…more
Plaintiff v. U.S. Bank, Credit Suisse,...
This opposition was filed to Defendants' Demurrer to Complaint. The Complaint arises out of the predatory lending and wrongful foreclosure of the Plaintiff's residential property. The causes of action include California…more
This is an opposition to a motion for relief from stay based on the moving parties lack of standing to foreclose or enforce rights with respect to the subject property…more
Khatchatrian v. Continental Casualty...
In this case, the Ninth Circuit upheld the decision of the trial court which ruled in favor of Defendant. The court held that the insured who died as a result of a stroke did not suffer an accidental death under the terms of…more
Sample Complaint against loan servicer, trustee of mortgaged-backed securities fund, MERS and foreclosure trustee for wrongful foreclosure, quiet title, cancellation of trustee's deed upon sale, unfair business practices, fraud…more
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