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Donnie R. DunnPlaintiff in Pro perP.O. Box 231Free Union, VA 22940(434) 973-4257
SUPERIOR COURT OF VIRGINIACOUNTY OF ABLEMARLE
Donnie R. DUNN )
CASE NO.
)Plaintiff, ) COMPLAINT FOR DAMAGES AND)vs. ) 1. Negligence Misrepresentation) 2. Enterprise LiabilityMERIDIAN MORTGAGE ) 3. Anticipatory RepudiationDOES 1 TO 50 ) (Breach)Defendants )________________________)
COMPLAINT
COMES NOW, Plaintiff Donnie R. Dunn, In Pro per who complainsand alleges as follows:1.Plaintiff Donnie R. Dunn at all times herein is or wasThe owner of real property commonly known as:34.73 Acres situated on State Route 601 Known as FreeUnion Road, Free Union, VA. ALL THAT CERTAIN TRACT OR PARCEL OF LAND WITH IMPROVEMENTSTHEREON AND OPPURTENANCE THEREUNTO BELONGING, SITUATED IN THE1
 
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WHITE HALL MAGISTERIAL DISTRICT OF ALBEMARLE COUNTY, VIRGINIA,THE WEST SIDE OF STATE ROUTE 601, CONTAINING 34.73 ACRES, MORELESS, BEING DESCRIBED AS LOT 1 PLAT G.V. KIRK HUGHES. LAND OWNEDBY BERNICE AND ORLANDO DUNN CONTAINING 34.73 ACRES, WHITE HALLDISTRICT, ABLEMARLE COUNTY, VIRGINIA,”OF RECORD IN THE CLERK’SOFFICE OF THE CIRCUIT OF ABLEMARLE COUNTY, VIRGINIA, IN DEED114,PAGES 315 AND 316.2.Defendant MERIDIAN MORTGAGE, hereinafter referred to as“MERIDIAN,” is a company who on information and beliefis conducting business in the State of Virginia.3.The true name of defendants named herein as DOES 1through50, whether individual, corporate, associate or otherwise,are presently unknown to plaintiff who therefore sues saiddefendants by such fictitious names; Plaintiff is informedand believe and thereon allege that each of the Defendantsso designated herein proximately caused and contributed tothe facts herein alleged, and Plaintiff will ask to leave ofcourt to amend the Complaint to insert the true names andcapacity of DOES 1 through 50 when the same have beenascertained and to join such Defendants4.Plaintiff is informed and believes and thereon alleges2
 
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that at all times herein mentioned each of the Defendantssued herein in relation to the property they claim aninterest in was the agent of each of the remainingDefendants and at all times was acting within the purposeand scope of such agency employment.5.On or about September 22
nd
, 2006, Plaintiff executed an “adjustable Rate Note” promising to pay Meridian Mortgagethe sum of #380,000.00 by monthly payments.6.The Adjustable Rate Note was base upon a six-month“LIBOR” adjustable rate.7.Plaintiff alleges that Defendants an each of them did notExplain the working of the interest rate, how it isComputed or its inherent volatility or interest only note.8.Further, on information and belief, Plaintiff allegesthat Defendants charged and obtained improper fees for theplacement of their loan as “sub-prime” when Plaintiffqualified for a prime rate mortgage which would havegenerated less in fees and interest.9.On information and belief, Plaintiff alleges that theservice of the purported note was, without Plaintiffsknowledge, by some means had transferred from or by3
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