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STATE OF WISCONSIN CIRCUIT COURT WAUKESHA COUNTY ______________________________________________________________________________ Bank of America N.A. as servicer for Case No.

11-CV-3333 The Bank of New York Mellon f/k/a The Bank of New York Certificateholders of CWALT, Inc. Alternative Loan Trust 2004-35T2 Mortgage Pass Through Certificates, Series 2004-35T2 7105 Corporate Drive PTX-B-209 Plano, Texas 75024, Putative Plaintiff Case Codes: 30404, 30303, 30201, 30106, 30107 vs. Amy Jo Brown 15945 Ridgefield Court Brookfield, Wisconsin 53005 Unknown Spouse of Amy Jo Brown 15945 Ridgefield Court Brookfield, Wisconsin 53005 Mortgage Electronic Registration Systems, Inc., as nominee for Secured Funding Corp 1901 East Voorhees Street, Suite C Danville, Illinois 61834 HSBC Mortgage Services, Inc. 26525 North Riverwoods Boulevard Mettawa, Illinois 60045 Purported Defendants ______________________________________________________________________________ DEFENDANTS ANSWER, AFFIRMATIVE DEFENSES, NOTICE OF INTENT TO AMEND ANSWER AND FILE INITIAL COUNTERCLAIMS UNDER WIS. STATS. SEC. 805.09 OR BY LEAVE OF COURT WITH RESERVATION OF RIGHTS AND STANDING OBJECTION TO SUBJECT MATTER JURISDICTION OF THE COURT TO GRANT ANY RELIEF ON THE COMPLAINT _____________________________________________________________________________ NOW COMES the purported Defendant (hereinafter for convenience and without waiving her status as the purported Defendant, Defendant) Amy Jo Brown, and, without

waiving her claim that the putative Plaintiff (hereinafter for convenience and, Plaintiff) cannot establish its standing to bring this action, answers, affirmatively defends, brings her initial counterclaims, and brings her third party complaints in this matter [without waiving her rights to seek leave to amend the affirmative defenses, amend and/or bring additional third party complaints within the time allowed by Wis. Stats. sec. 805.09(1) or subsequently upon leave of court upon further discovery through formal or informal means during the pendency of this action or as may conform to the proofs at trial under Wis. Stats. sec. 805.09(2)] and shows the Court: 1. Denies paragraph 1 and, affirmatively alleges, that Bank of America, N.A. is not the the servicer for a loan under which she is obligated to make payment to any party. Upon personal knowledge, affirmatively alleges that she signed a mortgage note in favor of Americas Wholesale Lender. Affirmatively alleges, upon information and belief, that the mortgage note taken by Americas Wholesale Lender is not an enforceable instrument because (a) Americas Wholesale Lender has no capacity to enter into a contract and is a doing business as name for the former Countrywide Financial, Inc. Further affirmatively, upon information and belief, alleges that Americas Wholesale Lender, lacking the capacity to sue, was a business name created to avoid the laws requiring the regulation of mortgage lenders. Further affirmatively alleges that a party without legal capacity to enter into a contract has no legal capacity to have a bank account in any state in the United States nor can it loan money, sue to collect money or enforce any contract. Further affirmatively alleges, upon information and belief, that Americas Wholesale Lender did not loan the purported Defendant any money which she is obliged to repay and that the copy of the mortgage note attached to the Complaint as Exhibit A is a sham and a fraud. Further affirmatively alleges, upon personal knowledge, that she viewed the purported original mortgage note after the proceedings held before the Honorable Judge Donald A. Hassin in Waukesha County Circuit Court, at the Courthouse in Waukesha County, Wisconsin on February 23, 2012 at approximately 2:00 p.m. and that the mortgage note in the possession of counsel for the (purported) Plaintiff is a forgery to which her signature has been reproduced by some form of technology generally called Photoshop technology from the original popular technology, just as the original technology for photocopying was originally known as Xerox machines. Document inspection and expert testimony is required to attempt to determine the most likely type of technology used to create the forgery, but, upon information and belief, the forgery was created with Acrobat Illustrator, the current most popularly used document creation software. Further affirmatively alleges, upon information and belief, that the endorsement in blank purportedly affixed to the reverse side of the mortgage note is a forgery, being a computer-generated photoshopped imported image of the a known robo-stamp used on Bank of America instruments to make it appear that the document was touched by human hands and reviewed by a person with authority to endorse notes on behalf of BAC Home Loan Servicing, LP, which recently merged with its previously concealed parent company, Bank of America, N.A., the purported Plaintiff herein. Affirmatively alleges, upon information and belief, that the purported Plaintiffs attorney, Christina Demakopoulus of BLOOMER PETERMAN, S.C., a Wisconsin lawyer and a Wisconsin professional services corporation, stated that the endorsement in blank on the reverse side of the mortgage note was the reason why the 2

photocopy of the note attached to the Complaint as Exhibit B did not display the endorsement in blank on the second page of Exhibit B. Upon information and belief, affirmatively alleges that the black computer printer ink stamp on the reverse side of the bright white paper and inappropriately aged (newly printed) paper was visible to her when her attorney was initially examining the note and may have been printed in dark enough ink to bleed through as a reverse image on the face of the second page of the computer generated forgery in the hands of her attorney. Affirmatively alleges, upon personal knowledge, could see the black image on the reverse side of the computer-generated note when she was looking at the front of Exhibit B. Affirmatively alleges, upon personal knowledge, that she observed her attorney, in the course of examining the note, applied her moistened finger to test the black ink purported endorsement in blank apparently printed with computer ink and that the ink did not bleed onto the page. Observing this preliminary examination, she heard Ms. Demakopoulus state to her attorney that the reason that the ink imprint did not react to the moisture test was that the document is old. Affirmatively alleges, that the purported Defendant has a banking, real estate and securities background, has worked in the financial industry since 1983 (with periodic leaves of absence to care for her children) and is presently a commercial lender. The purported Defendant has handled countless financial instruments and can state to a certainty that Exhibit A, which purports to be an original mortgage note purported executed in 2004 and on bright white paper legal sized paper (8 inches by 14 inches) is not appropriately aged and was not folded as would be required to mail the instrument in a conventional envelope (at most 9 inches by 12 inches.) The forgery was either transmitted to the firm electronically and printed there or, it is hard to accept but possible, created at the law firm itself, under instructions from the purported servicer. All employees of the firm are identified as possible participants in the receipt and/or creation of the forged mortgage note and some of them are, therefore, material witnesses, along with Ms. Demakopoulos who had the forged note in her hands (this is called uttering a forgery as a genuine instrument. She believes, from observing Ms. Demakopoulos reaction to her attorneys statement that the mortgage note as not the original mortgage note that Ms. Demakopoulos was unaware that she was and may still be unaware that she is holding a forged document in her case file because Ms. Demakopoulos appeared to be genuinely surprised.. A forgery (in this case with a face value of $383,200.00) not only has no value, but the intentional and knowing creation, possession and uttering thereof is a serious felony and poses a risk to the public if it not immediately surrendered to law enforcement. The (purported) Defendant demands the immediate surrender of the forged document from which the copy of Exhibit B was made to the Waukesha County Sheriffs custody pending scientific examination and testing at the direction of the Wisconsin Department of Justice-Division of Criminal Investigation (DOJ-DCI.) The purported Defendant declines to provide the smoking gun evidence of machine known to her for fear that the computer generated forgery will be modified to conform to her proof, and will seek a protective order from having to provide that information until Exhibit B is produced for scientific examination and inspection. She will state, at this time, that she will know immediately if the computer generated forgery displayed to her attorney and in her plain view on February 23, 2012 has been modified or altered to conform to her statements upon personal knowledge herein. Because Ms. Demakopoulos is a chain of custody witness, she and BLOOMER PETERMAN, S.C. must be disqualified from acting as counsel for the purported 3

Plaintiff in this matter under the Wisconsin Code of Professional Conduct SCR 20:3.7. Further, the law firm of BLOMMER PETERMAN, S.C. is disqualified because one of the lawyers associated with the firm created the mortgage assignment from MERS to the Bank of New York (Exhibit D attached to the Complaint) The name of Attorney J. Timothy Lovett appears on the assignment of the mortgage (Exhibit D) with what appears to be a Wisconsin Bar number. Exhibit D shows that it was returned from the Waukesha County Register of Deeds to BLOMMER PETERMAN, S.C. which further makes employees and attorneys at the firm material witnesses to the creation, production or receipt of the void mortgage assignment which may also be a forgery or false business record which was publicly recorded and returned to Bank of America, N.A.s law firm. The mortgage assignment is Exhibit D attached to the Complaint and is one of the documents upon which the Plaintiff(s) rely in attempting to create the appearance of standing before the Court. (See paragraphs 2., 5. and 8., below.) Continuously reserving her objection to the subject matter jurisdiction of this Court for the lack of standing of purported Plaintiff for all the reasons stated above, the purported Defendant states unequivocally that standing to sue cannot be founded upon a forged document, a business name without legal capacity has no standing to enter into contracts, loan money, receive payments or sue for performance. Bank of America, N.A., therefore, has falsely claimed that it collects and tracks payments, distributes collection and pursues legal action when necessary because it has not pleaded that it owns or holds the specific instrument identified as Exhibit B and the mortgage assignment (Exhibit D to the Complaint) is void as pleaded herein. 2. Denies paragraph 2 and affirmatively alleges, upon information and belief, that The Bank of New York Mellon f/k/a The Bank of New York does not appear on its own behalf as trustee for the certificateholders of CWALT, Inc. Alternative loan trust 2004-35T2 mortgage pass through certificates, series 2004-35T2. It appears through its purported servicer on the case caption and if it is a party to this action, it is either not represented by counsel or is represented by counsel additionally disqualified for conflict of interest under the Wisconsin Code of Professional Conduct SCR 20:1.7 because it is facially obvious that the Trustee would either be a party to the crime of forgery, for which it would have to waive conflict of interest for the attempt at dual representation in this paragraph, or is unaware of the forgery, in which case the conflict of interest cannot be waived by a party claiming to have a fiduciary responsibility as Trustee for the Certificateholders of CWALT, Inc. Alternative Loan Trust 2004-35T2 Mortgage Pass Through Certificates, Series 2004-35T2 Further, affirmatively alleges upon personal knowledge, that a fiduciary is prohibited as a matter of law from attempting to administer a trust asset which is founded upon a fraudulent transaction and a forged mortgage note because to do so would be an ultra vires act and a breach of its fiduciary duty and creates unwaivable conflict of interest for dual representation under the Wisconsin Code of Professional Conduct SCR 20:1.7. Further affirmatively alleges, upon information and belief, that an additional unwaivable conflict of interest arises between it and its purported servicer, who has no asset to administer, because the Trust known as the CWALT, Inc. Alternative Loan Trust 2004-35T2 Mortgage Pass Through Certificates, Series 2004-35T2 is required, as a matter of law to operate as a Real Estate Mortgage Investment Trust (REMIC Trust) and is governed by 26 U.S.C. sec. 860D and the Trustee for the CWALT, Inc. Alternative Loan Trust 2004-35T2 Mortgage Pass Through 4

Certificates, Series 2004-35T2 cannot accept assets into the trust which are not transferred within 90 days of the closing date of the trust or such additional grace period as is allowed by law for proper transfer of the asset. According to the trust prospectus, the mortgage note must be endorsed in favor of the trust or endorsed in blank but Exhibit B is a recently created forgery which demonstrates that the original mortgage note was never transferred to the trust. Further discovery would be necessary to ascertain whether or not The Bank of New York Mellon f/k/a The Bank of New York ever authorized the purported servicer to bring this action or retain this conflicted and now material witness counsel to represent it in this action, but that is an unnecessary expense to the victim of the forgery and fraud being perpetrated upon this Court by the putative Plaintiff, Bank of America, N.A., at this time. The (purported) Defendant reserves her right to engage in discovery, should this case not be dismissed with prejudice for the attempted fraud upon the purported Defendant this Court, its own counsel and the investors in the CWALT, Inc. Alternative Loan Trust 2004-35T2 Mortgage Pass Through Certificates, Series 2004-35T2. Not to put too fine a point on the actual relationship between the purported servicer and the purported Trustee of the CWALT, Inc. Alternative Loan Trust 2004-35T2 Mortgage Pass Through Certificates, Series 2004-35T2 for purposes of this allegation purporting to bolster the servicers standing, but REMIC Trusts have proper names which conventionally are capitalized and do not use the redundant language Trustee for the Certificateholders (sic, they are certificate holders or more properly holders of beneficial interests in the trust) and the process created by conflicted, material witness counsel does not capitalize the proper name of the alleged trust and did not use its legal name suggests that disqualified counsel probably has never seen the name of the trust on any document, such as a consent to dual representation, retainer agreement, prospectus or trust agreement. The (purported) Defendant acknowledges that the majority of jurisdictions have held that defendants in otherwise lawful foreclosure do not have standing to assert the rights of the investors under REMIC trust instruments because the purported defendant are generally not held to be third party beneficiaries of the trusts upon which the loan funds are created. That is not the case here. This answering (purported) Defendant is asserting her own rights not to be sued on a note executed in favor of a party with the capacity to enter into a contract, to transact banking whereby funds could have been transmitted to the make the loan, had no capacity to loan money, has no capacity to enter into a transaction whereby her note could be transferred by signed endorsement or endorsement in blank, could not contract to be a member of Mortgage Electronic Registrations Systems, Inc. (MERS) as nominee for purposes of the purported trusts purported acceptance of the mortgage security, which could not own an interest in lands or hold a mortgage thereon in Wisconsin or in any other state in the United States following the Anglo-American system of jurisprudence by statute or common law1 or assign any interest in land by nominee or otherwise. Were the Trustee of the CWALT, Inc. Alternative Loan Trust 2004-35T2 Mortgage Pass Through Certificates, Series 2004-35T2. In addition to requiring that a REMIC trust accept only lawfully endorsed and properly secured
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She does not know the Napoleonic Code, which is followed by Louisiana, but assumes that French law of the 18th Century from which it was derived and as it developed in the United States of America would not permit a nonexistent entity to engage in conduct for which AngloAmerican jurisprudence requires legal capacity. 5

mortgage loans, the timing of the transfer here would require the Trustee to reject the asset as having been assigned too late in time (if it was ever received) or, being an unlawful and void mortgage note and mortgage, would have rejected the same were the Trustee not itself engaging in a void and ultra vires act. Upon the discovery of the true facts of this transaction as understood by the (purported) Defendant, the Trustee would be required to locate the party responsible for transferring the void note and mortgage to the trust under the pleaded common form of ownership or, the trust instrument, require that party to buy back the void attempted transfer and refer the party responsible for making the transfer for criminal fraud. Further, upon her own knowledge, she does not owe any money to Americas Wholesale Lender, its servicing agent or the purported REMIC trust. When the fraudulent asset transfer is set aside by the purported Trustee, acting in its fiduciary capacity, by identification of the party responsible for this fraudulent sale, if it ever took place, the (purported) Defendant will raise the defenses and claims against that party. As a banker, she cannot even be sure that the closing check was ever paid to her the title companys bank for distribution under the closing statement. She knows that it is possible that the instrument could have been a site draft and returned to the issuer of the instrument for payment and the title companys bank may never have been paid in clear funds. This could have resulted in a loss to the capital of whichever bank received the unpaid site draft and could have resulted in a write-off against its capital reserves. The bank taking that loss would then be the real party in interest to recover the funds from her, but the statute of limitations has expired for that recovery, but for an allegation that she participated in the fraud herself, which she did not, having only recently become aware of the frauds in this transaction and having seen the forged mortgage note presented to her counsel in support of the allegation of standing by Ms. Demakopoulus on February 23, 2012. There may be a jurisdiction somewhere on the planet which monetized the mortgage note and is circulating it through the international banking system, perhaps as security for a derivative, but she has no experience in international banking and is incapable of researching international banking fraud. She cannot be required to pay any more on the void mortgage note or lose her home to an international bank fraud scheme. Whatever payments she made on the mortgage note and to whomever those payments were ultimately sent, in the approximate amount of $150,000.00, those payments were procured by upon her and the local bank and should be disgorged by the party responsible for the fraud. She does not know the identity of that party and the Trustee, if it is acting in a fiduciary capacity, has a duty to discover and disclose the fraud to the holder of certificates of beneficial interest. She affirmatively alleges, as a matter of fact and law, that Mortgage Electronic Registration Systems, Inc. (MERS) is a sham organization and front for securitization trusts. Further alleges upon personal knowledge that the mortgage in which MERS was nominated (Exhibit C attached to the Complaint) was made in favor of a party without legal capacity to lend her money, did not lend her any money and could not record an interest on Wisconsin lands, either in its own name or by nomination of MERS as its mortgagee of record. Further affirmatively alleges, upon personal knowledge, that Americas Wholesale Lender is not a member of the MERS system (because it cannot be, having no legal capacity.) Further, she affirmatively alleges, as a matter of law, that the operation of a parallel private recording system is to the duly-elected and constitutionally authorized Registers of Deeds for counties in the State of Wisconsin (cf. Chapter 59 of the Wisconsin Statutes, particularly at Wis. Stats. sec. 59.49, et seq. which preempt the 6

operation of a private recording system for lands in the state of Wisconsin. Further, she affirmatively alleges that MERS violates the sovereignty of the State of Wisconsin and its laws and is further not authorized to do business in the State of Wisconsin as a private corporation and, therefore, cannot hold even a nominal interest in lands in the State of Wisconsin, even if its mortgage interest was created by contract between the (purported) Defendant and a party with legal capacity to enter into a contract, which Americas Wholesale Lender did not have. Therefore, the mortgage interest for which MERS was purportedly nominated is void and the assignment of the mortgage interest is, likewise, void and without any force and effect. 3. Admits paragraph 3. 4. Denies paragraph 4 and affirmatively alleges that she is an unmarried woman. 5. Denies paragraph 5 and affirmatively alleges, as a matter of fact and law, that Mortgage Electronic Registrations System, Inc. (MERS) is a sham organization and front for securitization trusts, the mortgage in which MERS was nominated was in favor of a party without legal capacity to loan money and could not have been and never was a member of the MERS system. Further affirmatively alleges, as a matter of law, that the operation of a parallel private recording system is to the duly-elected and constitutionally authorized Registers of Deeds for counties in the State of Wisconsin (cf. Chapter 59 of the Wisconsin Statutes, particularly at Wis. Stats. sec. 59.49, et seq. which preempts and preclude the legal effect of private recording system for lands in the state of Wisconsin. MERS violates the sovereignty of the State of Wisconsin and its laws and is further not authorized to do business in the State of Wisconsin as a private corporation. The mortgage interest purportedly held by MERS is void and the assignment from MERS is, likewise, void and without any force and effect. 6. Denies paragraph 6. and affirmatively alleges, as a matter of fact and law, that MERS is a sham organization and front for securitization trusts. Further affirmatively alleges, upon information and belief the mortgage in which MERS was nominated was in favor of a party, Secured Funding Corporation, which was without legal capacity to do business in the State of Wisconsin (its lending license had been revoked in the State of California at the time this loan was made) and is not and never was a member of the MERS system and the operation of a parallel private recording system is to the duly-elected and constitutionally authorized Registers of Deeds for counties in the State of Wisconsin (cf. Chapter 59 of the Wisconsin Statutes, particularly at Wis. Stats. sec. 59.49, et seq. which preempt the operation of a private recording system for lands in the state of Wisconsin. MERS violates the sovereignty of the State of Wisconsin and its laws and is further not authorized to do business in the State of Wisconsin as a private corporation. The mortgage interest purportedly held by MERS is void and the assignment from MERS is, likewise, void and without any force and effect. 7. Denies paragraph 7. and affirmatively alleges that Exhibit A is hearsay. Further affirmatively alleges, upon information and belief, that HSBC Mortgage Services, Inc. did not loan her any money as and for a second mortgage on her home. 7

8. Denies paragraph 8. and reincorporates her Answer the Complaint herein at paragraphs 2. and 5., as if fully set forth herein. 9. Denies paragraph 9. and reincorporates her Answer the Complaint herein at paragraphs 2., 5. and 8., as if fully set forth herein. 10. Denies paragraph 10. its entirety, affirmatively alleges, upon personal knowledge, that she owes nothing to the putative Plaintiff whatsoever and that paragraph 10 of the Complaint is a fraud upon her and before this Court. In support of this allegation, she reincorporates her Answer the Complaint herein at paragraphs 2., 5. 8. and 9. as if fully set forth herein. 11. Admits that she received correspondence from Bank of America, N.A., purporting to be a debt collector and made a qualified written request under the Real Estate Settlement Practice Act, 12 U.S.C. sec. 2601, et. seq., to which Bank of America, N.A. responded that it had sent the debt collection letter to her by mistake. Thereafter, she was served with the Summons and Complaint in this matter. 12. Admits paragraph 12 and affirmatively alleges that she admits only that she resides at her homestead located at 15945 Ridgefield Court in Brookfield, Wisconsin and that the legal description of her homestead appears to be correct, without admitting or denying that the legal description is, in fact, correct. She does not admit that the real estate is subject to this action in anyway, continuing to object to the subject matter jurisdiction of this Court to decide any matter related to the putative Plaintiff (or both putative Plaintiffs) by its (their) Complaint for lack of their standing. Both parties have legal capacity to be sued, however, and the purported Defendant accepts their choice of forum and brings her counterclaims limited to the issues raised in the Answer she was required to file in this Court, without accepting the jurisdiction of the Court to grant any remedy to the putative Plaintiffs, because they have voluntarily invoked the in personam jurisdiction of this Court and the purported Defendant accepts the in personam jurisdiction over the matters which she has standing to raise and chooses to raise because the Plaintiff(s) have wasted the time of the Court and her resources by this action bringing false and fraudulent claims against her. There is precedent for this Court to reject subject matter jurisdiction over the claims of the Plaintiff(s) and grant the purported Defendant the limited relief she requests herein,2 reserving her other claims as allowed by the Wisconsin Rules of Civil Procedure, allowing for permissive joinder of claims. Wis. Stats. sec. 803.02. In the alternative, if the Court finds that it must dismiss this action for lack of subject matter jurisdiction and that
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Although voluntarily dismissed, prosecution of improperly venued actions violated the consumer act, and the defendants were prevailing parties under s. 425.308 entitled to attorney fees. Community Credit Plan, Inc. v. Johnson, 228 Wis. 2d 30, 596 N.W.2d 799 (1999), 97-0574. Note: The Wisconsin Consumer Act provides that commencement of an action outside of the consumers county of residence requires dismissal for lack of a subject matter jurisdiction. So it is here, but the subject matter jurisdiction arises from lack of standing under the constitutional authority of the Wisconsin courts. 8

proceeding on the counterclaims could, in any way be deemed to be a waiver of the continuing objection to the Courts subject matter jurisdiction to provide relief to the Plaintiff(s) [which the Defendant does not believe to be the case because even subject matter jurisdiction may be waived if not preserved by motion to dismiss before filing an answer] the Defendant consents to the simultaneous dismissal of her counterclaims to be brought as a Complaint in a new or new actions, subject to her demand for attorneys fees for the commencement and continuation of an action in violation of Wis. Stats. sec. 802.05. 13. Neither admits or denies the statement in paragraph 13 and re-alleges and reincorporates by reference each and every allegation of the foregoing Answer, except for paragraphs 6. and 7. (which are not relevant to the statement in paragraph 13.) as affirmative allegations in the Answer to this paragraph 13., as if fully set forth herein. 14. Denies paragraph 14., lacks sufficient knowledge as to whether the other defendants have been served with process to make them subject to the personal jurisdiction of this Court, affirmatively re-alleges and reincorporates by reference each and every allegation of the all of the foregoing paragraphs in this Answer, as if fully set forth herein, except for the Answer to paragraph 13., which is irrelevant to the Answer to this paragraph 14. AFFIRMATIVE DEFENSES 15. The Court lacks subject matter jurisdiction to grant relief to the Plaintiff(s) because they do not have standing to sue the (purported) Defendant as described in paragraphs 1-12 and paragraph 14, above and this case must be dismissed. 16. Counsel for the (putative) Plaintiff(s) counsel, BLOMMER PETERMAN, S.C. is disqualified from representing the Plaintiff(s) because the law firm Attorney Christina Demalopoulos of BLOMMER PETERMAN, S.C. is a material witness to the production of the forged mortgage note and the void assignment of mortgage upon which the (putative) Plaintiff relies in attempting to establish its standing to sue, a prerequisite to the Court having subject matter jurisdiction in this case was returned from the Waukesha County Register of Deeds Office to BLOMMER PETERMAN. Furthermore, the copy of Exhibit B attached to the Complaint, which is a copy of the forged mortgage note, was transmitted to the law firm for its production at the February 23, 2012 hearing or (may have even been created at the law firm) and the employees of the law firm will be identified through discovery as to their knowledge of the creation, production, receipt, filing, maintenance and other management of Exhibits B and D. Plaintiff(s) counsel is disqualified under Code of Professional Conduct of the Wisconsin Supreme Court SCR 20:3.7. A corporation cannot appear in Wisconsin courts without qualified counsel and this case must be dismissed. 17. Counsel for the (putative) Plaintiff(s) also has a unwaivable conflict of interest under the Wisconsin Code of Professional Conduct SCR 20:1.7 as described in paragraph 2., above. If members of the law firm or employees of the firm are parties to the crime of forgery 9

and filing false public records, a conflict of interest exists between the law firm and the putative Plaintiff(s). A corporation cannot appear in Wisconsin courts without qualified counsel and this case must be dismissed. 18. The putative Plaintiff(s) have unclean hands based upon the conduct described in the foregoing paragraphs 1-12, and 15-17, of the Answer, incorporated by reference as if fully set forth herein and cannot avail itself of any equitable remedies in these proceedings, including, but not limited to foreclosure on real estate, equitable assignment of mortgage interests, or equitable revision of contract and the case must be dismissed. 19. Americas Wholesale Lender does not exist, has no legal capacity to engage in any business transaction whatsoever and the lack of legal capacity cannot be cured by substituting a real party in interest in these proceedings under Wis. Stats. sec. 803.01, without equitable assignment or equitable revision of the contract, which are not available remedies in this case, as set forth in paragraph 18, above, and the case must be dismissed. WHEREFORE, the purported Defendant demands judgment dismissing the Complaint with prejudice as a sanction for fraud upon her and upon the Court, for her actual attorneys fees and costs of defending this action which is founded upon fraud upon her and upon the Court, and for such other relief as may be just and appropriate in these premises. [RIGHTS TO PLEAD COUNTERCLAIMS SPECIFICALLY RESERVED BY TIMELY AMENDMENT OF THIS PLEADING IN ACCORDANCE WITH WIS. STATS. SEC. 805.09(1) OR BY LEAVE OF COURT] WHEREFORE, the purported Defendant demands judgment dismissing the Complaint with prejudice as a sanction for fraud upon the her and upon the Court, for her actual attorneys fees and costs of defending this action which is founded upon fraud upon her and upon the Court, or for such other relief as may be just and appropriate in these premises. JURY TRIAL BY A JURY OF TWELVE PERSONS WILL BE DEMANDED SAFE HARBOR NOTICE TO QUALIFIED COUNSEL FOR THE PLAINTIFF(S): YOU ARE HEREBY NOTIFIED THAT IF YOU DO NOT VOLUNTARILY DISMISS THIS ACTION WITHIN 21 DAYS FROM THE DATE OF THIS NOTICE, DEFENDANTS WILL BRING THEIR MOTION FOR REASONABLE ACTUAL ATTORNEYS FEES, COSTS, DISBURSEMENTS AND EXPENSES PURSUANT TO WIS. STATS. 802.05(3) IN ADDITION TO THE RELIEF REQUESTED ABOVE.

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Dated this 15th day of March, 2012.

/s/ Wendy Alison Nora _____________________________________ Wendy Alison Nora Main Office mailing address:

210 Second Street NE Minneapolis, Minnesota 55413 Central Office Voice (612)333-4144 Central Office FAX (612) 886-2444
accesslegalservices@gmail.com WI BAR # 1017043

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AUTHENTICATION AND VERIFICATION STATE OF WISCONSIN ) ss COUNTY OF WAUKESHA) Amy Jo Brown, being first duly sworn on oath, states that she performed the original research into the claims of the Plaintiffs standing in these proceedings and that she has read, conducted independent investigation and assisted in the preparation of the foregoing answer, affirmative defenses, counterclaims and third party complaints in this matter. She states, upon her own knowledge, that facts stated in the foregoing pleadings are true and correct, to the best of her current personal knowledge, where stated, and according to her information and belief, where so stated. Where answers and affirmative defenses have been interposed are based upon facts and not law, except to the extent that she states that knows banking law and securities law as practiced in the United States of America, she states that the factual statements and statements of lawful practice in securities and banking law are true upon her current knowledge or, where stated upon, information and belief, are believed by her to be true and that this pleading is made in good faith in an effort and by no means to delay these proceedings or to harass or intimidate any party hereto or the attorneys for those parties. In responding to this pleading, she does not waive her right to continue to object to the subject matter of the jurisdiction of the court to proceed on the Complaint of the putative Plaintiff(s), but where the putative Plaintiff has voluntarily subjected itself to the jurisdiction of the Court by filing this Complaint against her, despite its failure to obtain the jurisdiction to the Court for the relief it requests, asserts that the voluntary submission to this Courts jurisdiction by the Plaintiffs constitutes the right to plead counterclaims against it (them) by timely amendment of this pleading in accordance with Wis. Stats. sec. 805.09(1) or by leave of Court and to conform her pleading to the proofs at trial as allowed by law. ____________________________________ Amy Jo Brown Subscribed and sworn to before me this 15th day of March, 2012. ___________________________________ Notary Public. My commission expires:_________________.

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