DMB-20181130-AFFIDAVIT OF TRUTH

IN THE COUNTY COURT OF THE 2ND JUDICIAL DISTRICT OF JONES COUNTY

IN AND FOR THE REPUBLIC OF MISSISSIPPI

ALLY CAPITAL CORP. ET AL.,

Plaintiff,

v. Case Number: 2018-489

DENISE MOFFETT BROWN, ET AL.

AFFIDAVIT OF TRUTH
REQUEST FOR WITNESS AT TRIAL

COMES NOW, Denise Moffett Brown (Hereinafter “Affiant”), over the age of 21 years

and competent to speak the truth in the above referenced matter; state as follows:

Affiant is aware that on October 30, 2018; Plaintiff(s) filed STATEMENT OF

ACCOUNT AND BUSINESS RECORDS AFFIDAVIT into the above referenced matter and

Affiant hereby answers as follows:

1. DENIED. Affiant has no relation and has never conducted business with one Blong

Nikki Vang; who presented an Affidavit on behalf of Ally Capital Corp. which stated

said individual has “personal knowledge of matters contained in this affidavit.”

2. DENIED. Affiant is not aware of any individual “employed by Ally Capital Corp, in the

position of Replevin Specialist,” and/or is “authorized to execute affidavits for and on

behalf of Ally Capital Corp.”

3. DENIED. Affiant has no contract with Ally Capital Corp. and has never conducted

business with Ally Capital Corp.

4. DENIED. Affiant has never executed a contract with Ally Capital Corp.

5. DENIED. Affiant has never defaulted with Ally Capital Corp because Affiant has no

contract with privately owned and foreign Ally Capital Corp.

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STATEMENT OF FACTS FOR THE RECORD

1. The fraudulent Affidavit presented by the Plaintiff(s) is yet another clear indication that

said Affiant, Blong Nikki Vang; has no “personal knowledge” of the facts of this matter because

the matter does not exist. Blong Nikki Vang is the Notary Public of the said Affidavit for which

one Janine Johnstone executed. The opening paragraph which stated that Blong Nikki Vang has

“personal knowledge” could not possibly be a mistake if in fact the Affidavit coming forth were

true and accurate. Despite all of the information that Affiant has submitted into this Court, for

the Record; this Court has neglected to acknowledge that Affiant has no contract with Ally

Capital Corp. nor has Affiant ever conducted business with privately owned, foreign Ally Capital

Corp.

2. Affiant takes offense to the fact that Plaintiff(s) admit this as a mere mistake. An

Affidavit of any type is a reflection of one who makes a statement under oath and in this

particular instance, if this were sincere; there would have been no mistake committed.

3. Under the circumstances presented by and through this Affidavit of Truth and in regard to

the “mistakes” committed by the Plaintiff(s); Affiant requests that this Court issue a Subpoena to

one Blong Nikki Vang and Janine Johnstone to bring forth their personal knowledge to the Trial

for this matter. Affiant reserves the right to question both mentioned individuals in regard to

their personal knowledge of the matter and in the instance that this request is not granted, Affiant

reserves the right to appeal this decision to a higher authority.

Affiant, hereby attests, affirms, ascribes, and declares that Affiant has firsthand

knowledge of the information presented herein, that Affiant is competent to make such claims,

and the Affiant states the aforementioned is accurate under penalty of state/Republic of

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Mississippi Constitution and the United States of America Constitution on this November 30,

2018, so help me Yahweh.

DENISE MOFFETT BROWN

_____________________________________
Denise Moffett Brown
November 30, 2018

ACKNOWLEDGMENT

STATE OF Mississippi
COUNTY OF Jones
On November _____, 2018; before me _____________________________ Notary
Public, personally stood Denise Moffett Brown who proved to me on the basis of satisfactory
evidence to be the person whose name is subscribed to the within instrument and acknowledged
to me that she executed the same in her authorized capacity and that by her signature on this
instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the
instrument.
I certify under PENALTY OF PERJURY under the laws of the State of Mississippi that the
foregoing paragraph is true and correct.

_____________________________________________
Notary Signature

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