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ALC- Orignal Petition for Wrongful Foreclosure-wFilestamp-09!27!10

ALC- Orignal Petition for Wrongful Foreclosure-wFilestamp-09!27!10

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Published by j mcguire
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Categories:Types, Research, Law
Published by: j mcguire on Sep 27, 2010
Copyright:Attribution Non-commercial

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03/15/2013

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 Original Petition for Wrongful Foreclosure1
 
 Original Petition for Wrongful Foreclosure2
CASE NO. ____________________ALVIE CAMPBELL AND JULIECAMPBELL,PLAINTIFF,V.MORTGAGE ELECTRONICREGISTRATION SYSTEMS, INC.,AS NOMINEE FOR LENDER AND
LENDER’S SUCCESSORS AND
ASSIGNS, AND WELLS FARGOBANK, N.A., AND STEPHEN C.PORTER, AND DAVID SEYBOLD,AND RYAN BOURGEOIS, ANDMATTHEW CUNNINGHAM, ANDJOHN DOE 1-100
 
DEFENDANTS,
 
§
 
IN THE DISTRICT COURT OFWILLIAMSON COUNTY, TEXAS
 
______ JUDICIAL DISTRICTJURY TRIAL REQUESTED
 
§
 
§
 
§
 
§
 
§§§§
 
§§§§§§§§§§PLAINTIFF
S ORIGINAL PETITION FOR WRONGFUL FORECLOSURE ANDAPPLICATION FOR TEMPORARY RESTRAINING ORDER AND INJUNCTIVERELIEFTO THE HONORABLE JUDGE OF SAID COURT:COME NOW
Plaintiffs, Alvie Campbell and Julie Campbell, who files this OriginalPetition for Wrongful Foreclosure And Application For Temporary Restraining Order AndInjunctive Relief, in the interest of justice and fairness, and asks this Honorable Court to find infavor of Plaintiff 
s’
and against Defendants, Mortgage Electronic Registration Systems, Inc., as
 Nominee for Lender and Lender’s Successors and Assigns, and
Wells Fargo Bank, N.A., andStephen C. Porter an individual, and David Seybold an individual, and Ryan Bourgeois anindividual, and Matthew Cunningham an individual, and John Doe 1-100,
regarding Plaintiff’s
claims of Wrongful Foreclosure, as stated herein, and in support thereof show unto the Court thefollowing:
 
 Original Petition for Wrongful Foreclosure3
DISCOVERY CONTROL PLAN LEVEL
 1.
 
Pursuant to Rule 190.1 of the Texas Rules of Civil Procedure, Plaintiff 
s’
intends to conductdiscovery in this case under Level 3.
PARTIES AND SERVICE
 2.
 
Plaintiffs
Alvie Campbell and Julie Campbell are individuals whose mailing address is 250Private Road 947, Taylor, Texas, 76574. The
last three digits of Alvie Campbell’s driver's
license number are 578, and the last three digits of his social security number are 180. The
last three digits of Julie Campbell’s driver's license number are
933, and the last three digitsof her social security number are 938.3.
 
Defendant Mortgage Electronic Registration Systems, Inc., as Nominee for Lender and
Lender’s Successors and Assigns is a Foreign For 
-Profit Corporation and may be served at3300 S.W. 34
th
Avenue, Suite #101, Ocala Florida, 34474-7448. Service on this defendantmay be effected by personal service or Certified Mail Return Receipt Requested.4.
 
Defendant Wells Fargo Bank, N.A., is a National Banking company who may be served byand through its registered agent, CT Corporation System, at 211 E. 7
th
St. Suite 620, Austin,Texas 78701 USA. Service on this defendant may be effected by personal service orCertified Mail Return Receipt Requested.5.
 
Defendant Stephen C. Porter, is an individual who may be served at 15000 Surveyor Blvd,Suite 100, Addison, Texas 75001. Service on this defendant may be effected by personalservice or Certified Mail Return Receipt Requested.6.
 
Defendant David Seybold, is an individual who may be served at 15000 Surveyor Blvd, Suite100, Addison, Texas 75001. Service on this defendant may be effected by personal service orCertified Mail Return Receipt Requested.

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