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Defendant's Motion to Amend Response to Cross Motion For Summary Judgment

Defendant's Motion to Amend Response to Cross Motion For Summary Judgment

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Published by Kelly L. Hansen
Michael A. Fisher Robo-Signor, MERS Fraudulent Assignment, MetLife Foreclosure
Michael A. Fisher Robo-Signor, MERS Fraudulent Assignment, MetLife Foreclosure

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Published by: Kelly L. Hansen on Feb 10, 2011
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01/13/2014

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CASE NO. 10CV122
DEFENDANT
 
HANSEN¶S
 
AMENDED
 
RESPONSE
 
TO
 
PLAINTIFF¶S
 
CROSS
 
MOTION
 
FOR 
 
SUMMARY
 
JUDGMENT
Kellylhansen143@gmail.com 
Confidential Page 1 2/10/2011
FACSIMILE TRANSMISSION COVER SHEET
 DATE:
Tuesday, February 1, 2011
TO
: Bob Swiss
MARTIN, LEIGH, LAWS & FRITZLIN, PCFAX
: 816-221-1044.
PAGES:
PAGE 1 OF 27
CASE NUMBER:
2010CV122
 
CASE NO. 10CV122
DEFENDANT
 
HANSEN¶S
 
AMENDED
 
RESPONSE
 
TO
 
PLAINTIFF¶S
 
CROSS
 
MOTION
 
FOR 
 
SUMMARY
 
JUDGMENT
Kellylhansen143@gmail.com 
Confidential Page 2 2/10/2011
IN THE DISTRICT COURT OF DOUGLAS COUNTY, KANSASCIVIL COURT DEPARTMENT
 METLIFE HOME LOANS, A DIVISION OF )METLIFE BANK, N.A. )PLAINTIFF, )vs. )) Case No. 2010 CV122
 
C.T. & KELLY L. HANSEN; )WELLSVILLE BANK; ) Hon. Robert W. FairchildUNITED STATES OF AMERICA ) DIV VI ± K.S.A. 60DEFENDANTS and )Counterclaim ) TITLE TO REAL ESTATEPLAINTIFFS, Pro Se ) INVOLVED) MORTGAGE FORECLOSURE
DEFENDANT
 
HANSEN¶S
 
AMENDED
 
RESPONSE
 
TO
 
PLAINTIFF¶S
 
CROSS
 
MOTION
 
FOR 
 
SUMMARY
 
JUDGMENT
COME NOW, Clarence G. Hansen and Kelly L. Hansen (³DEFENDANTS´), Pro Se, and pursuant to K.S.A. 60-215(a) and K.S.A. 60-256(c) do hereby amend their response to Plaintiff¶sCross Motion for Summary Judgment as follows:
AMENDED RESPONSE TO STATEMENT OF UNCONTROVERTED FACTS
1. Paragraph 1 is uncontroverted.2. Paragraph 2 is uncontroverted.3. Paragraph 3 is uncontroverted.4. Paragraph 4 is uncontroverted.5. Paragraph 5 is controverted. ³Said filing was
[not]
 
 prior to the acquisition by any person or defendants herein, of any right, title, interest, equity, or lien in and to the property.´ TheDefendants were living in the property at the time. Defendant Wellsville Bank originated themoney mortgage loan that financed the building of the home.
See
DEFENDANTS Answer,Affirmative Defenses, and Counterclaim, 21.
 
CASE NO. 10CV122
DEFENDANT
 
HANSEN¶S
 
AMENDED
 
RESPONSE
 
TO
 
PLAINTIFF¶S
 
CROSS
 
MOTION
 
FOR 
 
SUMMARY
 
JUDGMENT
Kellylhansen143@gmail.com 
Confidential Page 3 2/10/2011
6. Paragraph 6 is controverted. The Note, Defendant¶s Exhibit B, has been paid infull, to the order of Ohio Savings Bank for the full amount of $168,750.00, without recourse. TheDefendants debt to Sunflower Mortgage Co. is fully satisfied.
See
DEFENDANTS Answer,Affirmative Defenses, and Counterclaim, 15.7. Paragraph 7 is controverted. Plaintiffs Exhibit C is a false affidavit. Plaintiff attempts to confirm Defendants debt by presenting an Affidavit dated January 7, 2011. MetLifefiled its first Petition to Foreclose against Defendants on June 11, 2009. MetLife filed its secondPetition to Foreclose on January 25, 2010. A statement ³on behalf of IBM Lender BusinessProcess Services, Inc. (an entity that has never serviced Defendants mortgage loan), as Servicer for Fannie Mae (³Federal National Mortgage Association´) (³Plaintiff)´, an entity not yet approved by the Court to by a party to this action, sworn to 18 months after the Plaintiff filed its first Petitionto foreclose against Defendants does not satisfy the requirement of ³personal knowledge´ of theDefendants entire mortgage loan history. Defendants request Plaintiffs Exhibit C be strickenfrom the record.8. Paragraph 8 is controverted. Defendants request Plaintiffs Exhibit C be strickenfrom the record.
See
paragraph number 7 above.9. Paragraph 9 is controverted. Plaintiffs Exhibit A fails to establish MetLife has aninterest in Defendants real property. Plaintiffs Exhibit C is a false affidavit. See paragraph 7above.
See
Defendant Hansens Answer, Affirmative Defenses, And Counterclaim 15.10. Paragraph 10 is controverted. Defendant Wellsvilles mortgage interest is only trueinterest in the Defendants real property and in the Defendants Business.
See
Defendant HansensAnswer, Affirmative Defenses, And Counterclaim 23, 24 and Wellsville Answer and Exhibit A.

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