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The Curlee C.

Dennis Irrevocable Trust

13763 Campus Drive Oakland CA 94605
(510) 638- 2077

Trustor: Beneficiaries:
Curlee C. Dennis
Curlee C. Dennis/Descendents
Tanya D. Dennis/Descendents
Brenda Harris/Descendents
Tanya D. Dennis
Brenda Harris

January 4, 2011
An Emergency Civil Complaint
Appellant Curlee C. Dennis respectfully submits her civil complaint and

requests immediate enforcement by the Attorney General as a result of a

series of “material breaches of the terms and conditions of the Assurance
Agreement by Wells Fargo et al, and the California Attorney General dated
December 16, 2010 and effective as of December 18, 2010. The material
breaches by Wells Fargo will cause irreparable harm to the appellant and
her family if the pending foreclosure occurs on January 31, 2011 on her
Pick-a-Pay Loan Mortgage dated October 16, 2007 is allowed to occur
(Exhibit A) Appellant’s home is located at 13763 Campus Drive, Oakland
Ca 94605.

Assistance requested from the Attorney General’s office:

 Order Wells Fargo, Cal-Western Reconveyance, Christopher Carr, Attorney for the
Appellee, and any other John and Jane Does to cease and desist all actions
pertaining to foreclosure, unlawful detainer, auction, or any other means of
depriving Appellant from her residence until review and action on her proposed
Pick-A-Payment mortgage modification can occur, pursuant to the stipulations of
the Assurance Contract between the Attorney General Office and Wells Fargo et al.
(Exhibit B).
 Request Wells Fargo to submit proof of standing to foreclose. (Exhibit C) Appellant
has a forensic loan audit that substantiates the fact that Wells Fargo is not the
holder in due course. (Ref. BAP case # 09-1396- [ Fawn Ridek Partners LP appellant
v BAC Home Loan servicing LP . Ref. (Exhibit D)..
 Assure that Wells Fargo works with Appellant within the terms of the Assurance
Agreement and desist from any further court action until such agreement is


 Appellant filed a Verified Complaint in Federal Court, Federal Judge Phyllis

Hamilton would not grant a temporary restraining order or Preliminary Injunction
the Appellant was forced to file Bankruptcy. (Exhibit E)
 The Honorable Bankruptcy Judge Jellen refused to look at her evidence and
dismissed her Chapter 11 (Exhibit F)
 Appellant them filed an Adversarial Pleading in Bankruptcy Court requesting that
Wells Fargo prove that they are the holder in due course (Exhibit G) Before that
Motion could be heard the Appellant’ Motion was dismissed by Judge Jellen.
(Exhibit H)
 Appellant filed a motion for reconsideration with the submission of a forensic audit
statement that Wells Fargo has no standing. The Motion for Reconsideration was
 Appellant has now appealed her case to the US District Court. (Exhibit I). And a
Motion to Stay of any action against her property until her Appeal is adjudicated.
 Appellant also filed a motion to set-aside the Dismissal of her Chapter 11
Bankruptcy pending appeal.
 Appellant has filed in Superior Court, Federal Court, and Bankruptcy Court, filed
an Adversarial Pleading and is now in Appeals Court. The merits of her case have
still not been given a fair hearing.
Appellant is requesting that pursuant to the Assurance Agreement dated Dec. 16, 2010,
that Wells Fargo et al consider appellant for a MAP2R modification pursuant to the terms
in section VB of the Assurance Agreement.

Respectfully Submitted

Curlee C. Dennis