was not able to trace any chain of title to the Note from HSBC to Bayview. Since the TDwas security for a Note held by a 3
party, Bayview was precluded from exercising itsright of sale under the TD. If tender was made to an entity that did not hold the note thenthe real holder of the Note could sue Grossman. Grossman would be forced to pay thesame Note twice. That is why
Bayview was required to produce the original “inked” Note
to enforce the terms of the TD security. It failed to do so, but Grossman produced the
“Allonge” that assigned the Note to HSBC and Bayview was unable to trace title to the
Note from HSBC. They manufactured an assignment of both the Note and TD by
“forging” a signature of MERS with a “false” notarial acknowledgement. Bayview never
traced the chain of title to the Note from HSBC to MERS.Grossman filed his First Amended and Supplemental Complaint on 11/23/2010,which was verified by Grossman. (CT 778-823 with the verification appearing on CT 823)Grossman alleged on (CT 779) that he intended to seek consolidation with the UD filed
by Pro Value “after the wrongful foreclosure “allegedly” counseled by attorney Schloss.
780) Grossman used the word “allegedly” since he did not have any personal
knowledge of the communications between Schloss and his clients. This was a specialmotion to strike and no deposition was taken of Schloss as he would claim the 5
Amendment privilege as we accused him of a crime, and he would also assert theattorney-client privilege. Grossman alleged an illegal and fraudulent foreclosure with the
subsequent filing of “fraudulent” and “backdated documents” with the County Recorder’s
Grossman filed his lawsuit on 12/4/2009 and recorded in December 2009.
Grossman alleged at (CT 783) “the holder of only
the TD will never experience default