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Sample Request for Judicial Notice of Five Related Cases/Reports with Exhibits for Loan Fraud, Robosigning, Document Fraud, Appraisal Fraud, and Predatory Lending

Sample Request for Judicial Notice of Five Related Cases/Reports with Exhibits for Loan Fraud, Robosigning, Document Fraud, Appraisal Fraud, and Predatory Lending

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Published by Barry Fagan Esq.
REQUEST FOR JUDICIAL NOTICE
Pursuant to the provisions of California Evidence Code §§ 451, 452, and 453, it is a matter of judicial notice that that Defendant WELLS FARGO has an established pattern and practice (modus operandi) of falsifying real property documents including recorded instruments, and of submitting such falsified documents to courts in an effort to commit intentional fraud upon said courts. Defendant WELLS FARGO has heretofore submitted altered, and hence false and fraudulent, documents and recorded instruments to this Court in the course of this action, with the intention that the Court be deceived and misled thereby. For purposes of judicial notice, the court’s attention is directed to the following:
A. REQUEST FOR JUDICIAL NOTICE OF A RELATED CASE/REPORT OFFICE OF THE ASSESSOR-RECORDER SAN FRANCISCO REPORT AS SPONSORED BY PHIL TING ASSESSOR-RECORDER FOR SAN FRANCISCO ENTITLED FORECLOSURE IN CALIFORNIA A CRISIS OF COMPLIANCE SAN FRANCISCO | FEBRUARY 2012 (As filed with the court on February 21, 2012 on file herein and attached as “Exhibit M”)
B. REQUEST FOR JUDICIAL NOTICE OF THE RECORDED NOTICE OF PENDENCY OF ACTION WITH EXPERT OPINION EVIDENCE OF DOCUMENT FRAUD. (As filed with the court on December 19, 2011 on file herein and attached as “Exhibit L”)
C. Request for Judicial Notice of the Federal Reserve $87,000,000 Consent Decree against Wells Fargo Bank for employees falsifying borrowers loan applications. (As filed with the court on July 22, 2011 on file herein and attached as “Exhibit K”)
D. Request for Judicial Notice of the OCC Consent Decree dated April 13, 2011. (As filed with the Court on April 21, 2011 on file herein and attached as “Exhibit J”)
E. Request for Judicial Notice of U.S. Department of Housing and Urban Development Office of Inspector General, Region IV Office of Audit MEMORANDUM NO. 2012-AT-1801. (As filed with the Court on March 15, 2012 on file herein and attached as “Exhibit N”)
REQUEST FOR JUDICIAL NOTICE
Pursuant to the provisions of California Evidence Code §§ 451, 452, and 453, it is a matter of judicial notice that that Defendant WELLS FARGO has an established pattern and practice (modus operandi) of falsifying real property documents including recorded instruments, and of submitting such falsified documents to courts in an effort to commit intentional fraud upon said courts. Defendant WELLS FARGO has heretofore submitted altered, and hence false and fraudulent, documents and recorded instruments to this Court in the course of this action, with the intention that the Court be deceived and misled thereby. For purposes of judicial notice, the court’s attention is directed to the following:
A. REQUEST FOR JUDICIAL NOTICE OF A RELATED CASE/REPORT OFFICE OF THE ASSESSOR-RECORDER SAN FRANCISCO REPORT AS SPONSORED BY PHIL TING ASSESSOR-RECORDER FOR SAN FRANCISCO ENTITLED FORECLOSURE IN CALIFORNIA A CRISIS OF COMPLIANCE SAN FRANCISCO | FEBRUARY 2012 (As filed with the court on February 21, 2012 on file herein and attached as “Exhibit M”)
B. REQUEST FOR JUDICIAL NOTICE OF THE RECORDED NOTICE OF PENDENCY OF ACTION WITH EXPERT OPINION EVIDENCE OF DOCUMENT FRAUD. (As filed with the court on December 19, 2011 on file herein and attached as “Exhibit L”)
C. Request for Judicial Notice of the Federal Reserve $87,000,000 Consent Decree against Wells Fargo Bank for employees falsifying borrowers loan applications. (As filed with the court on July 22, 2011 on file herein and attached as “Exhibit K”)
D. Request for Judicial Notice of the OCC Consent Decree dated April 13, 2011. (As filed with the Court on April 21, 2011 on file herein and attached as “Exhibit J”)
E. Request for Judicial Notice of U.S. Department of Housing and Urban Development Office of Inspector General, Region IV Office of Audit MEMORANDUM NO. 2012-AT-1801. (As filed with the Court on March 15, 2012 on file herein and attached as “Exhibit N”)

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Published by: Barry Fagan Esq. on Mar 24, 2012
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