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153 SECOND AMENDED COMPLAINT FOR LACK OF STANDING, VOID CONTRACT, DAMAGES FOR FRAUD, FALSE REPRESENTATION, PREDATORY LENDING, QUIET TITLE, INJUNCTIVE RELIEF

153 SECOND AMENDED COMPLAINT FOR LACK OF STANDING, VOID CONTRACT, DAMAGES FOR FRAUD, FALSE REPRESENTATION, PREDATORY LENDING, QUIET TITLE, INJUNCTIVE RELIEF

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SECOND
AMENDED COMPLAINT
FOR LACK OF STANDING,
VOID CONTRACT,
DAMAGES FOR FRAUD,
FALSE REPRESENTATION, PREDATORY LENDING,
QUIET TITLE,
INJUNCTIVE RELIEF

ANDREW C. BAILEY
Plaintiff


vs
WELLS FARGO BANK NA a/k/a WELLS FARGO HOME MORTGAGE
(WELLS); US BANK NA AS TRUSTEE FOR WFMBS 2006-AR2 (US BANK); LEHMAN BROTHERS INC a/k/a LEHMAN BROTHERS BANK FSB (LEHMAN), and all persons claiming by, through, or under such person, all persons unknown, claiming any legal or equitable right, title, estate, lien, or interest in the property described in the complaint adverse to Plaintiff’s title thereto; and JOHN DOES "1-10"inclusive.
Defendants
SECOND
AMENDED COMPLAINT
FOR LACK OF STANDING,
VOID CONTRACT,
DAMAGES FOR FRAUD,
FALSE REPRESENTATION, PREDATORY LENDING,
QUIET TITLE,
INJUNCTIVE RELIEF

ANDREW C. BAILEY
Plaintiff


vs
WELLS FARGO BANK NA a/k/a WELLS FARGO HOME MORTGAGE
(WELLS); US BANK NA AS TRUSTEE FOR WFMBS 2006-AR2 (US BANK); LEHMAN BROTHERS INC a/k/a LEHMAN BROTHERS BANK FSB (LEHMAN), and all persons claiming by, through, or under such person, all persons unknown, claiming any legal or equitable right, title, estate, lien, or interest in the property described in the complaint adverse to Plaintiff’s title thereto; and JOHN DOES "1-10"inclusive.
Defendants

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Published by: Andrew Cameron Bailey on Nov 13, 2010
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05/31/2013

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ANDREW C. BAILEY
 2500 N. Page Springs RdCornville, AZ 86325928 634-4335
Self-Represented Litigant 
IN THE UNITED STATES BANKRUPTCY COURTFOR THE DISTRICT OF ARIZONA
 _________________________________________________________________________ 
ANDREW C. BAILEY
Plaintiff vs
 WELLS FARGO BANK NA a/k/a WELLSFARGO HOME MORTGAGE(WELLS); US BANK NA AS TRUSTEE FOR
 WFMBS 2006-AR2 (US BANK)
;
LEHMANBROTHERS INC a/k/a
LEHMANBROTHERS BANK
FSB (LEHMAN), and all persons claiming by, through, or under such person, all persons unknown, claiming anylegal or equitable right, title, estate, lien, or interest in the property described in thecomplaint adverse to Plaintiff’s title thereto;and
 
JOHN DOES "1-10"inclusive.
 
Defendants
Chapter 11BK Case #: 2:09-bk-06979-PHX-RTBPAP Case #: 2:09
ap
01727
RTBP
SECOND AMENDED COMPLAINTFOR LACK OF STANDING,VOID CONTRACT,DAMAGES FOR FRAUD,FALSE REPRESENTATION,PREDATORY LENDING,QUIET TITLE,INJUNCTIVE RELIEF
 
Plaintiff Andrew C. Bailey, in pro per, alleges:
1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 1334 and 157.2. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409.
 
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Parties
3. There are multiple parties known and unknown who claim or may claim an interest inPlaintiff’s property.
 
4. Plaintiff is a resident of the State of California living in and otherwise using andoccupying his home located at 153 Western Avenue, Glendale, CA 91201(the Property).5. Defendant
WELLS
is and was, at all times material, a corporation organized in the Stateof Delaware doing business in the State of California. Wells
 
is and was, at all times materialhereto, the "loan originator" and "servicer" of the “subject loan”.6. Defendant
US BANK, NA
is and was, at all times material, a corporation organized in theState of Minnesota doing business in the State of California.7. Defendant
LEHMAN
(which changed its name to Aurora Bank, FSB in April 2009)
 
is andwas, at all times material, a corporation organized in the State of Delaware doing businessin the State of California.8.
The JOHN
DOES are securitization parties: undisclosed, unnamed and unknowninvestors, participants, corporate or other entities, conduits, trustees, servicers, custodiansand others in a complex mortgage securitization scheme that involved the Defendants andother known and unknown parties.9. The term “Defendant” hearinafter refers to each and all of the above-named defendantscollectively and individually.
 
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1234567891011121314151617181920212223242510. The parties claim or may claim an interest in the property as a result of the securitizationof an alleged “mortgage loan transaction” between Plaintiff and Defendant WELLS.11. Plaintiff has the right to know who the parties are and whether they are parties ininterest.12. Plaintiff has the right to know who these parties are and whether they are creditors.13. Plaintiff has the right to a full accounting of all debits and credits to his alleged accountwith the parties.
Procedural History
14. On April 8th, 2009 three of Plaintiff's unsecured creditors filed an involuntary petitionagainst the Plaintiff for relief under Chapter 7 of title 11 of the United States Code (the“Bankruptcy Code”).15. On May 28th, 2009 (the “Petition Date”) this Court entered an order granting Plaintiff'smotion to convert to Chapter11 thereby commencing the above-captioned lead case.16. On December 23, 2009, Plaintiff filed the instant adversary complaint. This pleading isthe second amendment to that complaint.
Background Material Facts

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