IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
STATE OF DELAWARE, )Plaintiff, ))v. ) C.A. No. ______ )MERSCORP, Inc., a Delaware corporation, and )Mortgage Electronic Registration Systems, Inc., )a Delaware Corporation, )Defendants. )
1.The Plaintiff, the State of Delaware, by and through itsundersigned Attorney General and Deputy Attorneys General, brings this actionagainst Defendants, who created the mortgage registration and foreclosureenterprise known as "MERS." MERS is at the center of the current unprecedentedforeclosure crisis.2.In contrast to its historic rate of roughly 2,000 foreclosures per year, Delaware’s foreclosure rate has tripled to 6,000 foreclosure filings in each of 2009 and 2010, and will likely see a similar number in 2011.
Delaware StateHousing Authority, 2011 State of Delaware Mortgage Complaints,http://www.deforeclosurehelp.org/data.html (last visited Oct. 26, 2011), attached asExh. A. One out of every 753 Delaware homes received a foreclosure filing inSeptember 2011.
RealtyTrac.com, September 2011 Foreclosure Rate Heat