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1. Maryland Statutes and Rules regulate foreclosure proceedings that are initiat-ed by a Trustee or Substitute Trustee under a Deed of Trust. The Maryland Rules re-quire that the Trustee file various documents with the Circuit Court in the County wherethe property is located. The documents required to be filed include an order to docket,an appointment of substitute trustees, if applicable, and a number of affidavits for the
court’s review and consideration in connection with the foreclosure proceeding.
2. This class action addresses the failure of the Maryland attorneys who alsofunction as Substitute Trustees under Deeds of Trust to meet their obligations under
Maryland law. The Defendants’ have had a pattern and practice of filing and supporting
thousands of foreclosures by
multiple documents that state they are executed by theDefendant(s) but are not documents executed by the Defendant(s)
, orders todocket, affidavits, appointments of Substitute Trustees, and trustee deeds. The result
of the Defendants’ conduct was that Defendants intentionally or unintentionally caused
hundreds if not thousands inaccurate documents to be filed as part of foreclosure pro-ceedings before Maryland State Courts to obtain jurisdiction of the state courts overforeclosure proceedings. Defendants, who are Officers of the Court and knew or should
Defendants have consistently stated that the documents contained truthful infor-
mation and therefore were not ―false‖ or ―perjurious.‖ Defendant
s have also stated thatthe documents were executed with the knowledge of the Substitute Trustee and there-fore not forged. However, the documents which state that they are executed by some-one who did not in fact execute the documents are not factually accurate.
Case 8:10-cv-02822-RWT Document 1 Filed 10/13/10 Page 3 of 46