BREACH OF CONTRACT

OR
IN THE ALTERNATIVE
RESCISSION OF CONTRACT
(Against Defendants Robinson, Lorenzo, and FFF)

106. Plaintiff incorporates here each and every allegation set forth above.

Brokerage Agreement

107. Plaintiff entered into an agreement with Defendants PRIZE, ROBINSON, and
LORENZO, whereby Defendants promised to provide Plaintiff with an affordable loan, fully disclose the
terms of the Loans, and work on Plaintiff’s and Plaintiff agreed to pay a commission.

108. Plaintiff fully performed her duties under the contact with Defendants
ROBINSON, LORENZO, and PRIZE.

109. Defendants ROBINSON, LORENZO, PRINZE, an each of them, breached their

brokerage agreement with Plaintiff two predatory loans with toxic terms and by failing to exercise
reasonable efforts and sue diligence to secure the type of Loans terms promised thus failing to provide
Plaintiff with an affordable loan.

110. Specifically, Defendant ROBINSON overstated the borrower’s income in order

to qualify him for this refinance transaction. The standard housing and debt to income ratios are 33% for
housing and 38% for debt to income. Based on the Plaintiff’s monthly income of $3,310.08 and using the
minimum mortgage payments for both loans of $4,614.33 the housing ratio was 139.40%

111. Defendant ROBINSON advised Plaintiff that she could get her 100% financing
for her residence, and that her loans would be fixed rate loans for 30 years. However, Defendant
ROBINSON actually sold Plaintiff two predatory loans. The first loan, in the amount of $439,200.00
carried a rate of 7.60% based on LIBOR index plus 2.75%, Plaintiff’s initial monthly payments for the
loan were $2,846.04. Plaintiff’s loan carried a large balloon payment due in 30 years, in the amount of
$361,280.14. Plaintiff’s second loan in the amount of $109,800.00 with an interest rate if 11.65%.
Plaintiff’ initial monthly payment for the loan was $1,076.40. Plaintiff’s loan also carried a large balloon
payment due in 15 years, in the amount of $105,838.02.

112. Plaintiff is informed and believes, and thereon alleges that Defendant
ROBINSON received an original fee of $8,235.00 and $4,392.00 in yield spread premiums for a total of
$12,627.00 in yield spread premiums for Plaintiff’s loan.

113. Defendants ROBINSON, LORENZO, and PRINZE breached their agreement

when they failed to refinance as initially promised.

114. Defendants ROBINSON, LORENZO, and PRINZE breached their agreement

by intentionally or negligently failing to obtain payment and interest rates as promised.

115. Defendants ROBINSON, LORENZO, and PRINZE breached their agreement

by intentionally or negligently failing to obtain payment and interest rates as promised.
 116. Defendants ROBINSON, LORENZO, and PRIZE breached their agreement by
failing to submit an accurate loan application.

117. Defendants ROBINSON, LORENZO, and PRIZE breached their agreement by

failing to provide loan documents for Plaintiff’s review prior to closing, and failing to explain the loan
documents to the Plaintiff.

118. Defendants ROBINSON, LORENZO, AND PRIZE further breached their

duties when they failed to provide the mortgage terms as promised.

Breach of Mortgage Loan Agreement

119. Defendant ROBINSON, LORENZO, FFF, and each o them, breached their
agreement with Plaintiff when they sold Plaintiff two predatory loans with toxic terms.

120. Defendant ROBINSON, LORENZO, and FFF breached their agreement with
Plaintiff by failing to exercise reasonable efforts and due diligence as promised, thus failing to provide
Plaintiff with an affordable loan.

121. Defendant ROBINSON, LORENZO, PRINZE, and FFF also breached their
agreement with Plaintiff by committing wrongful acts, including but not limited to, intentionally or
negligently failing to obtain payment and interest rates as promised, failing to submit an accurate loan
application, failing to supervise, failing to provide loan documents for Plaintiff’s review prior to closing,
and failing to explain the loan documents to the Plaintiff.

122. Defendants ROBINSON, LORENZO, FFF, and each of them, further breached
their duties when they failed to refinance the mortgage as promised, which was contrary to the terms
negotiated by the Plaintiff and the named Defendants.