4 3 6-3--
Trnd Court Of Massachusetts
Superior Court Department
COMMONWEAL:1.E OF MASSACHUSETTS
[SEE APPENDIX A,
rrORNEY, FIRM NAME, ADDRESS ANDTEM
Amber Anderson Villa, AAG, John M. Stephan, AAG, Sara Cable,
ATVIRNEY (tf known)
Office of the Attorney General
One Ashburton PlaceBoston, MA 02:108617-727-2000
Board otaar ()mum nunttz
647566, 649509, 667084
0 ' !
TYPE OF ACTION AND TRACK DESIGNATION (See reverse side)CODE NO.
YPE OF ACTION (specify)
S THIS AWRY CASE?
and deceptive business
BH2,BG I ,E1J1
ractices in violation nf M. G.
L. c. 93A
The following is a full and detailed statement of the facts on which plaintiff relies to determine eligibility in to
The Business Litigation Session.
action, the Commonwealth of Massachusetts seeks restitution, civil penalties and injunctive relief -for violations of M. G. L. c. 93A arising out Defendants' unfair and deceptive acts during the height of theforeclosure crisis in Massachusetts. The conduct alleged has affected thousands of homeowners throughtheir residential mortgage loans, and includeS, without limitation;
ngagingin unfair and deceptive foreclosure practices by conducting foreclosures when thedefendants lacked the right to do so and misrepresenting to homeowners their roles as mortgagees or asthe holders of the mortgages;
Engaging in false do -
entation practices to facilitate their foreclosure practices;
Deceiving homeowners in the course of servicing mortgage loans by misrepresenting to borrowers
loan modification programs, acting deceptively in implementing loan modifications anddeceiving borrowers regarding foreclosure proceedings; and
Failing tocomply with Massachusetts' registration statute.The Defendants, and their subsidiaries and related entities, are responsible for the vast majority ofunlawful foreclosures that occurred in the Commonwealth in the last four years. Given the scope of theconduct alleged, the complex facts involved, voluminous discovery anticipated, and the likely need forsubstantial case management,
the Commonwealth contends
that determination of this matter
by the BLS
* A Special Tracking Order shall be created by the Presiding Justice of the Business LitigationSession at the Rule 16 Conference,
PLEASE IDENTIFY, BY CASE NUMBER, NAME AND COUNTY, ANY RELATED AMON PENDING INTHE SUPERIOR
"I hereby certify that I have complied with the requirements of Rule 5 of the Supreme Judical Court Uniform Rules onDispute Resolution (SIC Rale 1:18) reqifying that I provide my clients with information about court-connected disputeohition services and discuss with the!fi the, adva
tages of the various methods."
Signature of Attorney of Record
pecember 1, 2011