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Quiet Title

Quiet Title



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Published by boathook
Amended complaint for Quiet Title
Amended complaint for Quiet Title

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Published by: boathook on Jun 29, 2012
Copyright:Attribution Non-commercial


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Complaint Page 1 of 35
Percy Newby c/o12924 E Marginal Way STukwila, Washington
SUPERIOR COURT OF THE STATE OF WASHINGTONFOR THE COUNTY OF KINGPercy Newby, as Trustee for 13001 41stAvenue South Trust
 _________________________________ )))))))))))))))))))))))))CASE NO. 12-2-07994-3 KNTAMENDED COMPLAINT TOQUIET TITLE TO REALPROPERTY.1 Plaintiff is proceeding without assistance of counsel unschooled in law,
Complaint Page 2 of 35
pro se, requesting the court accept direction from Haines v. Kerner, 404 U.S. 519(1972), Boag v. MacDougall, 545 US 360 (1982), Puckett v. Cox 456 F2d 233(1972 Sixth Circuit USCA), and Conely v. Gibson, 355 US 41 at 48(1957),ESTELLE, CORRECTIONS DIRECTOR, ET AL. v. GAMBLE 29 U.S. 97, 97 S.Ct. 285, 50 L. Ed. 2d 251, WILLIAM MCNEIL, PETITIONER v. UNITED STATES113 S. Ct. 1980, 124 L. Ed. 2d 21, 61 U.S.L.W. 4468, BALDWIN COUNTYWELCOME CENTER v. BROWN 466 U.S. 147, 104 S. Ct. 1723, 80 L. Ed. 2d196, 52 U.S.L.W. 3751, wherein the court has directed those who areunschooled in law making pleadings shall have the court look to the substance ofthe pleadings rather than the form. Pro se pleadings are to be considered withoutregard to technicality; pro se litigants' pleadings are not to be held to the samehigh standards of perfection as lawyers. Maty v. Grasselli Chemical Co., 303 U.S.197 (1938), B. Platsky v. CIA, 953 F.2d 25, 26 28 (2nd Cir. 1991), "Court errs ifcourt dismisses pro se litigant without instruction of how pleadings are deficientand how to repair pleadings."2. Plaintiff reserves the right to amend this complaint as new evidencecomes to light and complains and for causes of action alleges as follows:
 3. This is a dispute over defendants right to claim a valid foreclosure saleunder the applicable laws of the State of Washington and to Quiet Title andenjoin Defendants, from claiming any estate, right, title or interest in the subjectproperty located at 13001 41st Avenue South Tukwila, Washington 98168 and tohold Defendants accountable for their unfair and deceptive trade practices. 2.2 
Defendants‟ contention is that they
had a right to foreclose on the propertyin question and the Plaintiffs contention is that Defendants
inter alia intentionallyconstructed, operated and participated together in a fraudulent scheme tounjustly enrich themselves and to steal the estate described below.4. Upon information and belief, Aztec Foreclosure Corporation ofWashington, HSBC Bank USA, N.A., Mortgage Electronic Registration Systems,Inc., Renaissance Home Equity Loan Trust 2006-4, Ocwen Loan Servicing, LLC,Delta Funding Corporation
and Gary‟s Process S
ervice, (hereinafter
Complaint Page 3 of 35
Defendants,) have conspired and acted both in concert and individually to
maliciously and fraudulently proceed against Plaintiff‟s real property, causing a
Notice of default, Notice of Foreclosure and their intent to sell the property atauction to be posted on the property and their subsequent alleged auction andalleged transfer to occur.5. Defendants have caused and continue to cause Plaintiff to suffer damagesin an amount to be determined by the Trier of fact herein.6. Plaintiff is informed and believes and thereupon alleges that Defendants,and each of them, claim an interest in the property adverse to plaintiff herein.However, the claims of said Defendants are without any right whatsoever, andsaid defendants have no legal or equitable right, claim, or interest in saidproperty as they have violated the Unfair business practices, breached their Trustand subsequently have lost the chain of Title to the aforesaid property.
7. On April 13, 2011 the Federal Reserve Board signed and published twelve
consent orders (the “Federal Reserve Consent Orders”), which found that the
named entities; (Bank of America, N.A., Citibank, N.A., HSBC Bank USA, N.A. (aPlaintiff herein), JPMorgan Chase Bank, N.A., MetLife Bank, N.A., PNC Bank,N.A., U.S. Bank National Association, and Wells Fargo Bank, N.A.) engaged in
“unsafe or unsound practices.” In addition, the United States Comptroller of the
Currency entered into consent orders with eight servicers as well as LPS, DocX,MERSCORP, and MERS Inc., (a Plaintiff herein). (T
he “OCC Consent Orders”).
In the OCC Consent Orders the government found that each of the servicers:a. Filed or caused to be filed in state courts and federal courts affidavitsexecuted by its employees or employees of third-party service providers makingvarious assertions, such as the ownership of the mortgage note and mortgage,the amount of principal and interest due, and the fees and expenses chargeableto the borrower, in which the affiant represented that the assertions in theaffidavit were made based on personal knowledge or based on a review by theaffiant of the relevant books and records, when, in many cases, they were notbased on such knowledge or review;b. Filed or caused to be filed in state and federal courts or in the local land

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