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Gunn, propria persona 2 Old North Road, #502 Dover, DE 19934 Telephone: (302) 218-6407 Facsimile: (888)812-4098 Email: email@example.com
UNITED STATES DISTRICT COURT OF APPEALS FOR THE THIRD CIRCUIT
LA MAR GUNN Appellant -vU.S BANK NATIONAL ASSOCIATION as Trustee for the Holders of the EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES, SERIES 1998-3 and SELECT PORTFOLIO SERVICING, INC., Appellees
APPELLANT’S RESPONSE TO APPELLEES’ REVISED REPLY TO APPELLANT’S MOTION TO DISMISS AND/OR QUASH APPEAL:
COMES NOW, Appellant, LA MAR GUNN (hereinafter “GUNN”), appearing propria
persona, and files this Response to Appellees’ Revised Reply to Appellant’s Motion to Strike and Deny Appellees’ Motion to Dismiss and/or Quash Appeal. In support of the motion, Gunn denies the allegations in Appellees’ previous filings entirely for fraud and now shows as follows:
Jacquard Lace Co. and warrants the most severe sanctions pursuant to the Court’s inherent power. the totality of Davis’ conduct has defrauded countless investors." Milltex Industries Corp. Plaintiffs now proceed against Appellant to delay him .1995) 2. robbed Appellant and his family of their home of 8 years. Davis has successfully influenced the District Court into refusing to consider Appellant’s prima facie/evidential proof in determining facts instead of the existence of disputes. In the instant matter. Further. Dorothy Ann Davis (“Davis”). and to resolve all factual issues in the light most favorable to Davis’ criminal contentions. Pileggi (“Pileggi”). and visited a disruptive and wasteful effect on the limited resources of this Court.X. 4. the District Court failed to require appellees to fulfill their burden of proof as appellees have yet to provide one shred of evidence to support their ill-founded allegations. Davis and Francis G. Ltd. deprived the Internal Revenue Service (IRS) of several million dollars in taxes. is attempting to pull wool over the courts eyes as their claims are "entirely without color" and "motivated by improper purposes. v. 3. 55 F. through Eckert Seamans Cherin & Mellot. 35 (2d Cir. are sheisty and have been allowed to influence court decisions with counterfeit documents that they both use to continuously dance around the truth with legal maneuvers surrounded by unsupported and blatantly false factual and legal contentions.3d 34...1.
the Davis corporate declarations all contain false factual contentions that lack any evidentiary support. 5. Moreover. and then later destroy the original copies/evidence so that she could influence courts to rule in her clients’ favor (Exhibit 1). involves her instructing Nikole Shelton (“Shelton”) to first fabricate mortgage assignments. It is uncontroverted that subject lawsuit stems from a counterfeit Assignment of Mortgage (Exhibit 1 supra) produced and submitted to the court under the direction of Davis. As is the case here. 7. and are submitted for an improper purpose.from seeking compensation for their using forged and counterfeit documents to foreclose on his home. 6. It should shock the court’s conscience that a foreclosure mill attorney would file the instant action after having already succeeded in manipulating state and federal courts to turn a blind’s eyer to the appellees’ widespread path of corruption. One such example of Davis’ participation in fraud. Davis has misrepresented her authority. Davis through a willful commitment to advance a criminal enterprise. Appellant has never owed one penny to the appellees and has never been late on a mortgage payment since purchasing his first home 17 years ago. has perpetrated intentional fraud on the court. . Davis and her interest in the instant action stems from a retaliatory animus against those without the benefit of counsel and who speak out against corrupt attorneys who stop at nothing to win.
subjecting her and her firm to discipline under the authority of this honorable court. No judge or member of the bar of this court would think it appropriate for a lawyer to suggest to the court that it disregard intentional misrepresentations and counterfeit documents submitted in other courts. their conduct has been inimical to the administration of justice. Davis expects this Court to kick the proverbial can down the road or ignore her efforts to further conceal egregious acts of criminal fraud. and misrepresentation in violation of Rule 3.3(a)(3) of the . Davis has engaged in unethical behavior and conduct unbecoming a member of the bar. Shelton. Throughout the pendency of the litigation. or serving as a public official (Exhibit 2). fraud. the person instructed to forge the subject assignment. 11. 9. and has since received a lifetime ban from ever witnessing or notarizing signatures. It seems unfair that Davis has not received one sanction for her role in the robosigning scandal that has rendered millions of minorities homeless. was investigated by the Pennsylvania Attorney General. and only convicted low people on the totem pole such as Shelton. stained the judiciary. 12.8. Moreover. 10. There is no rule of behavior for attorneys that would make the conduct of Davis or Pileggi acceptable. Davis’ conduct in substituting counterfeit mortgage documents to the court is unethical because it involves dishonesty.
which . proves that Davis has brought a fraud on the court since an unrecorded mortgage assignment could never be legally conveyed into the subject trust. Davis has had to reach deep into her bag of legal or illegal tricks. on file with the Securities and Exchange Commission. and for oppressive reasons. Incorporated (“SPS”) f/k/a Fairbanks Capital (“Fairbanks”). proves that she proceeds vexatiously. wantonly.Delaware Lawyers’ Rules of Professional Conduct. 15. trustworthiness. and has substituted an unrecorded and counterfeit assignment to District courts (Exhibit 1 supra). The fact that Davis arrogantly waives an unrecorded assignment in the face of the court. Davis misrepresented her client to be EQCC Home Equity Loan Trust 1998-2 (Exhibit 3). The appellee’s own pooling and servicing agreement (PSA). Series 1998-3. Davis has made intentional misrepresentations to the Court concerning her authority to represent U. Credit Suisse AB. and fitness of Davis as a lawyer.S. In Delaware courts and versus Appellant. and is conduct that adversely reflects on the honesty. As it pertains to real vs fictitious clients. Bank as trustee and the fully indemnified certificateholders of EQCC Home Equity Loan Asset Backed Certificates. it is uncontroverted that Davis’ only client is Select Portfolio Servicing. Further. Davis relies on the Courts’ lack of knowledge as to the financial instrument called securitization. 14. Since Shelton’s lifetime ban. 13. contradicting her statements in this court. Fairbanks is a subsidiary of Swiss Bank.
propria persona Signed reserving all my rights at UCC 1-308 . RESPECTFULLY SUBMITTED this 14th day of August. 16. The Court has a duty to curtail abusive litigation practices by corrupt attorneys as to inure future management of its affairs so as to maintain public confidence in the judiciary. WHEREFORE. Appellant respectfully moves the Court to Strike and Deny the unauthorized and amended reply to appellant’s Motion to Strike and Deny Appellees’ Motion to Dismiss and/or Quash Appeal. the fairness of the proceeding will be prejudiced. 2013. ____________________________________ LA MAR: GUNN. Dorothy Ann Davis and her firm Eckert Seamons Cherin & Mellott are not disqualified.000 for mortgage related fraud.000.changed its name to SPS after being fined by the Federal Trade Commission $40. 17. Gunn argues that if Plaintiffs’ counsel. As stated throughout.
the foregoing Document was sent by ECF to: Francis G. DE 19934 Telephone: (302) 218-6407 Facsimile: (888)812-4098 Email: firstname.lastname@example.org . _________________________________ LA MAR: GUNN. #502 Dover. 2013. propria persona Signed reserving all my rights at UCC 1-308 2 Old North Road. Pileggi Jill Agro Dorothy Davis Eckert Seamans Cherin & Mellott. 2013.X.CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 14th day of August. Suite 1210 Wilmington. LLC 300 Delaware Avenue. DE 19801 facsimile: (302) 425-0432 On this Thursday the 14th day of August.
Dated:____________________ ________________________________ U.S. 13-2310 [proposed] ORDER Upon consideration of the Appellant’s Motion for the Court to Strike and Deny Appellees’ Motion to Dismiss and/or Quash Appeal. SERIES 1998-3 and SELECT PORTFOLIO SERVICING.UNITED STATES DISTRICT COURT OF APPEALS FOR THE THIRD CIRCUIT LA MAR GUNN Appellant -vU. Appellees No. INC. Court of Appeals for the Third Circuit .S BANK NATIONAL ASSOCIATION as Trustee for the Holders of the EQCC HOME EQUITY LOAN ASSET BACKED CERTIFICATES. it is hereby ORDERED that the Appellant’s Motion is GRANTED. IT IS SO ORDERED..
EXHIBIT 1 .
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