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N. Ann Piwinski, Plaintiff v Wells Fargo Bank Na. and China Brown Defendants

N. Ann Piwinski, Plaintiff v Wells Fargo Bank Na. and China Brown Defendants

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Published by Foreclosure Fraud
4closureFraud.org
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Categories:Types, Research, Law
Published by: Foreclosure Fraud on Nov 03, 2010
Copyright:Attribution Non-commercial

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04/28/2013

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INTHE
FAIRFIELD
COUNTY
COURT
OF
COMMON
PLEAS
CVL
DIVISION
N
ANN
PIWINSKI
CASE
NO
1470
Mill
ParkDrive
Marysville
Ohio
43040
JUDGE
Plaintiff
V
CIVIL
COMPLAINT
WELLS
FARGO
BANK
NA
c
sc
Lawyers
Incorporating
Service
JURY
DEMAND
ENDORSED
HEREON
50
West
Broad
Street
Columbus
Ohio
43215
AND
CHINA
BROWN
c
WellsFargo
Bank
N
A
3476
Stateview
Bvd
Fort
Mill
South
Carolina
29715
Defendants
This
civil
complaint
concerns
Defendant
Wells
Fargo
Bank
NA
s
nd
China
Brown
                                                                                                                                                                 s
Defendants
attempts
to
deceive
this
Court
and
Plaintiff
N
AnnPiwinski
Plaintiff
into
entering
a
default
judgment
granting
foreclosure
in
favor
of
Defendants
andagainst
Plaintiff
in
Fairfield
County
Case
No
007
CV00952
Now
comes
Plaintiff
and
for
her
complaint
against
Defendants
states
as
follows
Parties
1
Plaintiff
is
a
resident
of
Union
County
Ohio
She
formerly
resided
at1928
Wnd
River
Drive
Lancaster
Ohio43130
the
Property
2
Defendant
Wells
Fargo
is
headquartered
at
3476
Stateview
Blvd
Fort
Mill
South
Carolina
29715
1
 
3
DefendantChina
Brown
isand
was
a
Vice
President
of
Loan
Documentation
employed
byDefendant
Wells
Fargo
Jurisdiction
andVenue
4
Defendant
s
onductoccurred
in
Fairfield
County
Ohio
andis
in
violation
of
Ohio
s
Consumer
Sales
Practices
Act
CSPA
R
1345
Ohio
s
aby
RICO
statute
Baby
RCO
R
923
32
nd
the
common
law
5
Jurisdiction
over
this
matter
lies
within
this
Court
pursuant
to
R
1345
04
R
2932
34
ndthe
common
law
6
This
Court
has
venue
to
hear
thismatter
pursuant
to
Civ
R
33
ecause
Defendant
                                                                                                                                                                 s
conduct
which
gave
riseto
Plaintiff
s
rayer
for
relief
inFairfieldCounty
Ohio
7
The
state
court
of
common
pleas
has
original
jurisdiction
over
this
matter
as
the
conduct
which
gave
riseto
Plaintiff
s
rayer
for
relief
occurred
as
a
result
of
Defendant
                                                                                                                                                                 s
iling
of
a
foreclosure
lawsuit
in
Fairfield
County
Ohio
FactualBackground
8
Onorabout
January
192004
Plaintiff
executed
a
mortgageloan
with
respect
to
the
residential
real
estate
located
at1928
WindRiver
Drive
LancasterOhio
43130
the
Property
evidenced
by
a
promissory
note
and
a
mortgage
infavor
of
Dominion
Homes
Financial
Services
Ltd
9
On
August
6
2007
Defendant
filed
a
complaint
for
foreclosure
in
the
Fairfield
County
Court
of
Common
Pleas
seeking
judgment
against
Plaintiff
and
foreclosure
of
the
Property
the
Foreclosure
Action
The
Foreclosure
Action
bore
case
no
2007
CV
00952
A
copy
of
the
complaintin
the
Foreclosure
Action
with
the
note
and
mortgage
is
attachedhereto
as
Exhibit
A
2
 
10
In
the
complaint
in
the
Foreclosure
Action
Wells
Fargo
claimed
it
wasthe
holder
and
owner
of
the
note
Upon
information
and
belief
this
statement
was
blatantly
false
and
was
knownbyWells
Fargo
to
be
false
at
the
time
the
complaint
was
draftedin
that
Wells
Fargo
was
not
the
owner
of
the
note
11
Plaintiff
did
not
file
an
answertothe
foreclosure
complaint
12
On
November
15
2007
Wells
Fargo
filed
a
motion
for
default
judgment
against
Plaintiff
The
motion
for
default
judgment
isattached
hereto
as
Exhibit
B
13
On
November
20
2007
Defendants
caused
to
be
filed
an
Affidavit
of
Status
of
Account
and
Military
Affidavit
the
Affidavit
A
copy
of
the
Affidavit
is
attachedhereto
as
Exhibit
C
14In
the
Affidavit
Defendants
stated
1
Affiant
is
a
VicePresident
of
Loan
Documentation
with
Wells
Fargo
Bank
N
A
n
this
jobpositionaffiant
has
thecustody
of
and
has
personal
knowledge
of
theaccounts
of
said
company
and
specifically
with
the
account
of
PLAINTIFF
defendant
herein
2
Affiant
states
that
this
saidaccount
is
indefault
and
that
plaintiff
has
elected
to
call
the
entire
balance
of
said
accountdueandpayable
in
accordance
with
the
terms
of
thenoteand
mortgage
attached
to
the
Complaint
3
Affiant
states
that
there
is
due
on
saidaccount
a
principal
balance
of
19403
18
ogether
with
interest
thereon
15
On
November
20
2007
based
upon
Defendantsfraudulentcomplaint
andthe
Affidavit
the
Court
granted
Wells
Fargo
s
efault
judgment
andissued
a
Finding
and
Decree
in
Foreclosure
16
It
is
well
documented
that
for
years
Wells
Fargo
has
used
so
called
robo
signers
in
its
mortgage
servicing
division
to
expedite
foreclosures
Robo
signers
are
individuals
whose
sole
job
responsibility
isto
sign
affidavits
assignments
of
mortgage
and
other
3

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