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Judicial.notice

Judicial.notice

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Published by Foreclosure Fraud

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Published by: Foreclosure Fraud on Dec 17, 2012
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12/01/2014

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1IN THE CIRCUIT COURT OF THE15
TH
JUDICIAL CIRCUIT IN AND FORPALM BEACH COUNTY, FLORIDACASE NO. 50 2008 CA 022258 XXXMBDIVISION AWDEUTSCHE BANK NATIONAL TRUSTCOMPANY, AS TRUSTEE FOR THECERTIFICATE HOLDERS OFSOUNDVIEW HOME LOAN TRUST2006-OPT2, ASSET-BACKEDCERTIFICATES, SERIES 2006-OPT2,Plaintiff,vs.LYNN E. SZYMONIAK, et al.,Defendants.____________________________________/ 
DEFENDANT SZYMONIAK’S REQUEST FOR JUDICIAL NOTICE OFINFORMATION AND PLEA AGREEMENT OFLORRAINE BROWN
COMES NOW, the Defendant, LYNN SZYMONIAK, by and through her undersignedcounsel and pursuant to Florida Rules of Evidence §90.202 and §90.203, hereby requests thisHonorable Court take Judicial Notice of the documents described herein, and in support states asfollows:1.
 
SZYMONIAK moves this Court to take judicial notice of:
Information regarding Lorraine Brown,
United States of America v. Lorraine Brown
, Case No. 3:12-cr-198-J-25 MCR, (M.D. Fla.)
(attached hereto as“Exhibit A”),
 Plea Agreement of Lorraine Brown,
United States of America v. Lorraine Brown
, Case No. 3:12-cr-198-J-25 MCR, (M.D. Fla.)
(attached hereto as“Exhibit B.”)
 
22.
 
Under Fla. Stat. §90.206(5), the Court may take judicial notice of official actionsof the legislative, executive and judicial departments of the United States. Under Fla. Stat.§90.202(6), the Court may take judicial notice of records of any court in this state or of any courtof record of the United States.3.
 
On November 20, 2012, Lorraine Brown, (“Brown”) a former executive of Lender Processing Services, Inc. (LPS) and DocX LLC, a LPS company, pleaded guilty toconspiracy to commit mail and wire fraud.4.
 
LPS and DocX LLC were involved in the preparation and recordation of mortgage-related documents throughout the country since the 1990s.5.
 
SZYMONIAK moves this Court to take Judicial Notice of Brown’s informationand Plea Agreement because these documents confirm that DocX employees engaged in amassive fraud in the preparation of hundreds of thousands of mortgage-related documents,including Mortgage Assignments, and SZYMONIAK contends that the Mortgage Assignmentprepared and filed by DocX in her case, bearing the purported signature of Linda Green, was onesuch fraudulent mortgage assignment.6.
 
By way of background, DocX was hired by residential mortgage servicers to(among other things) assist in creating and executing mortgage-related documents filed withrecorders’ offices across the country.7.
 
Brown represented to DocX’s clients that DocX had robust quality controlprocedures in place to ensure a thorough and proper signing, notarization, and recordationprocess.8.
 
Only specific personnel at DocX were authorized by clients to sign thedocuments.
 
39.
 
At the direction of Brown, employees of DocX, including those who were notauthorized to sign documents, began forging and falsifying signatures of the mortgage-relateddocuments that they had been hired to prepare and file with property recorders’ offices.10.
 
After these documents were falsely signed and falsely notarized, Brownauthorized DocX employees to file and record them with property records offices across thecountry.11.
 
Brown also hired temporary workers to sign as authorized signatures, and theseworkers worked without the quality control represented by Brown to DocX’s clients.12.
 
Many of DoxX’s temporary employees signed thousands of mortgageassignments each day, often signing the names of other persons on Mortgage Assignments thatwould then be witnessed and notarized. These employees often signed as officers of banks andmortgage companies. These employees signed without reading the documents or in any wayascertaining the truth of the matters presented therein, including the grantor, grantee, and date of the purported transfer.13.
 
Many of the documents, including mortgage assignments and lost note affidavits,were later relied upon in court proceedings including foreclosure proceedings and federalbankruptcy actions.14.
 
Brown admitted she understood that courts, property recorders, title insurers, andhomeowners relied upon the documents as genuine.15.
 
Brown implemented these signing practices at DocX to increase profits.16.
 
Between 2003 and 2009, DocX generated approximately $60 million in grossrevenue.

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