Amelia Sauceda: Verification of Complaint Expose for June of 2010

Lee County Florida, 20th Circuit Foreclosure Court; MAY 1, 2011

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Amelia Sauceda: Verification of Complaint Expose for June of 2010
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Amelia Sauceda: Verification of Complaint Expose for June of 2010
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Final Comments on the “MEET WATSON” Verification of Complaint Boiler Plate Form

1. In Paragraph one the affiant, Amelia Sauceda uses the term, “personally familiar”. It avers that
as an employee of BAC Home Loan Servicing, L.P. F/K/A Countrywide Home Loans Servicing, L.P.,
she is familiar with the loan. If true then she is also familiar with loans from a half dozen other financial
institutions and holders of MBS’s etc. The language in each separate affidavit in support of these
foreclosure complaints contradicts one another, thus rendering each one invalid as the contents of the
exhibits control over allegations.

2. In Paragraph one the affiant, Amelia Sauceda avers that she has read the Complaint. Does
anyone know how long it would take to read and verify a complaint of average length? Does anyone
know how many VOC affidavits she signed on any given day? After reading the complaint which
database would she access to verify the complaint with what she just read? It probably depends on the
bank she is verifying for; BAC, U.S. Bank, NY Mellon, Wells etc.

3. In Paragraph two the affiant, Amelia Sauceda avers that, “The Plaintiff is entitled to enforce
the subject loan.” If Amelia Sauceda had read and understood the Plaintiffs Complaint and she was
familiar with Florida Law, specifically, The MORTGAGE FORECLOSURE FORM 1.944 of the Florida
Rules of Civil Procedure provides specific requirements for submitting a mortgage foreclosure complaint
to the court. The Florida Rules of Civil Procedure 1.944(3) state that the Plaintiff must allege that the
“Plaintiff owns and holds the note and mortgage.” This was not the case in 10-ca-056111, but she signed
the affidavit anyway. Furthermore, by not attaching the written authorization of the true party with
standing to bring suit, a failure to comply with 1.130(a) of the Florida Rules of Civil Procedure occurs.
The appearance of haste to sign all these affidavits is evident in her short curved squiggle she uses as a
signature.

4. In Paragraph three the affiant, Amelia Sauceda avers that, “A payment default has occurred and
no subsequent payments have been made.” Complaints often are filed without the necessary payment log
documentation attachments as required by Florida Rules of Civil Procedure 1.130(a), but this doesn’t
slow down the Rocket Docket or Amelia in signing these affidavits.

5. In Paragraph four the affiant, Amelia Sauceda avers that, “All conditions precedent have been
“MEET” prior to the institution of this action.” Pardon the typo and focus on the intent of this statement.
It intends to claim all the Florida Rules of Civil Procedure have been met in accordance with the filing of
the complaint she is verifying. I won’t bore you with an exhaustive critique of this averment as plainly in
many cases there are obvious omissions and false claims.

6. Finally, In Paragraph five the affiant, Amelia Sauceda avers that, “Plaintiff has obligated itself
to pay the Law Offices of Marshall C. Watson…” Who is she averring will pay Marshall C. Watson?
FNMA, the one authorized to bring suit or BAC the servicer who is listed on the Complaint as Plaintiff?

If anyone has any affidavits signed by Amelia Sauceda or any information about her job duties or
who she really works for that seem legally problematic, post them and maybe we’ll get to the bottom of
this fraud.

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