United States District Court

Southern District of Florida (West Palm Beach)

RE: JANICE WOLK GRENADIER (JWG)1 CASE #: 9:17-cv-80495-KAM

Pro Se Intervener

Consumer Financial Protection Bureau

Vs.

OCWEN Financial Corporation, Inc

OCWEN Loan Servicing L.L.C.
OCWEN Mortgage Servicing Inc.
PHH Mortgage Corporation

RESPONSE TO MOTION DATED JUNE 2, 2022

JOINT RECOMMENDATION PLAN FOR GOING FORWARD
INTERVENER’S NOTICE TO NEGOTIATIONS AS TO NEW EVIDENCE AND DEMAND

CRIMINAL INVESTIGATION INTO INSIDER TRADING

Attached Complaints Filed with SCC and Ignored Exhibit 1
Insider Trading: Bought 4,106,171 stocks for $12,114,662 = SOLD FOR $317,056,930

PROFIT: $304,942,268 on Insider Trading

Ignored by SEC & ALL
COURTS/JUDGES

Law Firms Profits2 OCWEN/PHH et al in the BILLIONS

TO COVER-UP ENTERPRISE / SCHEME

Other Lawyers in this CLUB: Troutman Pepper Hamilton Sanders, McQuireWoods, McCabe
Weisberg Conway, BWW LAW Group, Brock & Scott

1
JWG is Pro Se and doe not have teh electronic means for submitting this Response
2
https://amlegalnews.blogspot.com/2022/04/money-money-money-buys-justice.html
1
 THE INSIDERS BY ALL APPEARANCE WHO ARE MAKING BILLIONS & MILLIONS
INCLUDE LEON COOPERMAN 10% PAST OWNER OF STOCK WHO WENT ON TV, et al
“BUY OCWEN” AND ARE NOT LIMITED TO:
The difference between LEON COOPERMAN and BERNIE MADOFF

BERNIE MADOFF stole from RICH JEWS -SEC took pay-offs for 10+years to stay silent

LEON COOPERMAN steals homes from EVERYDAY AEMRICANS- SEC stays silent --
according to Forbes Cooperman is worth $2.5 Billion top insider trader345

Others who Benefited in harming the Government & the American People:

Glen Glen A. Messina, President, Chief Executive Officer, Director, CEO, Pres &
Director Timothy Yanoti, Executive Vice President, Chief Growth Officer - Scott
Anderson, Executive Vice President and Chief Servicing Officer - Dennis Zeleny,
Executive Vice President, Chief Administrative Officer - June Campbell, Chief
Financial Officer, Executive Vice President, Exec. VP & CFO - Scott William
Anderson, Exec. VP & Chief Servicing Officer - John Britti, Executive Vice President,
Chief Investment Officer, Exec. VP & Chief Investment Officer - Dennis Zeleny, Exec.
VP & Chief Admin. Officer - Arthur Walker, Senior Vice President - Global Tax -
Phyllis Caldwell, Independent Chairman of the Board - Jacques Busquet, Independent
Director Alan Bowers, Independent Director - DeForest Soaries, Independent Director
- Kevin Stein, Independent Director - Jenne Britell, Independent Director - Albert
Celini, Executive Vice President, Chief Compliance and Risk Officer - Francois
Grunenwald, Senior Vice President, Chief Accounting Officer - Joseph Samarias,
Executive Vice President, General Counsel, Company Secretary, Chief Ethics Officer,
Exec. VP, Gen. Counsel & Company Sec. - Alberino J. Celini, Exec. VP, Chief Risk &
Compliance Officer - Stephen C. Swett, Investors Contact - Michael K. Short, VP of
Bus. Devel. and Investor Relations - Francois Grunenwald, Sr. VP & Chief
Accounting Officer - Leon G Cooperman, 10% owner - Park Road Management
Compan..., - Mark S Zeidman, Sr VP, CFO, Chief Invest Offic - Peter Moenickheim,
EVP and Chief Risk Officer - Alberino J Celini, Chief Risk & Compliance - Carol J
Galante, Director - Ronald M Faris, President - Robert J Lipstein, Director -
Ronald J Korn, Director - Timothy M. Hayes, EVP, Gen. Counsel & Secretary - Otto
J Kumbar, EVP, Lending - Robert A Salcetti , Director - John Devaney, 10% owner -
Catherine M Dondzila, SVP & Chief Accounting Officer - Marcelo G Cruz, EVP &
Chief Risk Officer - Capital Partners, - Llc Kings..., - Michael R Jr Bourque,
Executive Vice President & CFO - William B Shepro, Senior Vice President - W
Michael Linn, Director - Robert J Leist, VP & Chief Accounting Officer - Wilbur L
Jr Ross, Director - William H Lacy, Director - Vlack John Patrick Van, EVP, CFO
3
https://amlegalnews.blogspot.com/2022/04/ocwen-phh-insider-stock-trading.html
4
https://www.sec.gov/news/public-statement/statement-leon-cooperman-settling-insider-trading-charges
5
https://judicialpedia.com/listing/sec-v-leon-g-cooperman-and-omega-advisors-inc-in-july-2010-leon-g-cooperma
n-generated-significant-illegal-profits-by-trading-in-the-securities-ofatlas-pipeline-partners-l-p-apl-on-the-basi/
2
 and CAO - Nikhil Malik, CFO, Ocwen Mortgage Servicing - William C Erbey,
Chairman & CEO - Paul A Koches , Exec VP & General Counsel - Barry N Wish,
Director - Kenneth D. Najour, Vice President and CAO - David B Reiner, Director -
David J Gunter, Sr VP & CFO - Martha Clark Goss, Director - W C Martin,
Director - Arthur D Ringwald, Pres/CEO of OTX (sub of OCN) - Herbert B Tasker,
Director - Joseph B Long, EVP, Capital Markets - George T. Henley, EVP & Chief
Growth Officer

The Enterprise and or Scheme for OCWEN/PHH is they are not just a Servicer It is a Smoke &
Mirrors clearing house - Back Door Bank that involves the Government Cover-Up:
1. they create and process Foreclosures on “FAKE” Loans that have no Standing and
2. that were DELIBERATELY PUT INTO “FAKE” Mortgage Back Securities
3. that the public was unaware of until Lynn Szymoniak’s Whistleblower suite
4. then after Foreclosing on the loan
5. pass the loan on to other Servicer’s ie JWG’s appears to have a loan being serviced by
NewREZ a year after the foreclosure receiving a letter from PHH/OCWEN JWG loan had been
moved to a new Servicer
6. so at all times the appearance of the “FAKE” Mortgage Back Security stays on several different
Lender and Servicers Balance Sheets.
7. JWG interviewed several OCWEN/PHH employees who lost their jobs due to operations
moving to INDIA to have a arms length from turning off fax machines, phones, leaving people
on hold, using “FAKE” Bar numbers on documents etc etc etc -
8. This is BANK FRAUD,
The Harm to the Public and laws that are being violated6
Denial of Rights Under Color of Law Violating 18 U.S.C § 242, § 241, 42 U.S.C. 42 U.S.C. § 1983,
State & United States Constitutional Rights while coerce & deceiving citizen in Home Mortgages
18 USC § 371 Conspiracy 18 USC § 1341 Frauds and Swindles 18 USC §1344 Bank Fraud
18 U.S.C. Code § 1961- 1968 RICO 18 USC §1346 Honest Services 18
USC § 1348 Securities and commodities fraud 18 USC §1349 Attempt & Conspiracy
Sarbanes – Oxley Act 18 U.S. Code § 666 - Theft or bribery concerning programs receiving Federal
funds 15 U.S. Code Subchapter V - DEBT COLLECTION PRACTICES § 1692d - Harassment or
abuse
§ 1692e -False or misleading representations § 1692f - Unfair practices
§ 1692g - Validation of debt § 1692j - Furnishing certain deceptive forms
31 U.S.C. § 3729 Federal False Claims Act 18 U.S. Code § 1033 Insurance Fraud
False Advertising - FTC Act, Lanham Act and Dodd-Frank Wall Street Reform, Consumer Protection
Act 18 U.S. Code § 1343 Fraud by wire, radio, or Television

6
https://amlegalnews.blogspot.com/2021/03/the-appearance-of-manipulation-of-stock.html
3
 US Constitution Fifth & 14th Amendment deprived of life, liberty or property without due process of
law Theft by Deceptive Taking 18 USC §4, aka the Misprision Of Felony
42 U.S. Code § 1983 - Civil action for deprivation 18 U.S. Code § 241 & 242
Conspiracy/Deprivation against rights
In JWG CASE:

1. An alleged loan was taken out in the name of JWG, but was BASTERSZED and part of a
California scheme that put OPTION ONE MTG in bankruptcy and created a flow of millions of
loans to be put into “FAKE” Mortgage Back Securities as found in the WhistleBlower suit by
Lynn Szymoniak Attached copy of her list that the Government and Court agreed was FRAUD
in the Court: UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA ROCK
HILL DIVISION Case No. 0:10-cv-01465-JFA (D.S.C. May. 12, 2014)

United States Of America, ex rel. Lynn E. Szymoniak, Relator, v. American Home

Mortgage Servicing, Inc.; Saxon Mortgage Services, Inc.; Lender Processing Services,
Inc.; DocX, LLC; CitiMortgage, Inc., f/k/a Citi Residential Lending, Inc., f/k/a AMC
Mortgage Services, Inc.; Wells Fargo Home Mortgage d/b/a America's Servicing
Company, Bank of America Corporation, as successor-in-interest to LaSalle Bank aka
Bank of America; Bank Of New York Mellon Corporation; Citibank National
Association; Deutsche Bank National Trust Company; Deutsche Bank Trust Company
Americas; HSBC USA National Association; J.P. Morgan Chase Bank National
Association; U.S. Bank National Association; and Wells Fargo Bank National
Association, Defendants.

The Case is being ignored and the same Criminal Enterprise in a Rico & Racketeering Fashion is
being empowered by the courts and the government every day.

2. To Foreclose the Bank must have STANDING it can’t hire a BILLION / MiLLION dollar
law firm to BUY OFF THE JUDGE - yet in the Two-Tier Judicial system in America that is
what is happening.
3. There is proof on the internet of Judges / Lawyers and Legislatures getting SWEET deals from
Banks and loans forgiven by Servicers. This is a Mafia Government run Enterprise and the
Exhibits attached show it.
4. The attorneys have agents with back door deals to buy properties - Syed Moshin Reza
Troutman Pepper Hamilton Sanders and now with Greenberg Traurig - interesting switch - he is
being sued for Ethic in Richmond Virginia.

JANICE WOLK GRENADIER DEMANDS HER HOME

at 15 W. Spring St., Alexandria, VA 22301 7
ILLEGALLY FORECLOSED ON MARCH 31, 2018 in the CITY OF ALEXANDRIA
BE SIGNED BACK OVER TO HER, and FINANCIAL COMPENSATION &
A CRIMINAL INVESTIGATION INTO:
7
https://amlegalnews.blogspot.com/2022/02/wells-fargo-bank-illegal-foreclosure-of.html
4
 BACKGROUND AFTER FORECLOSURE On MARCH 30, 2018
Of 15 W. Spring St., Alexandria, VA 22301
JWG is entitled to the relief for the following reasons:

1. That JWG can show that Wells Fargo Bank N. A. had no standing to foreclose and OCWEN using
Identity Theft, Money Laundering, Insurance Fraud and many other criminal acts foreclosed on
15 W. Spring St., Alexandria, VA 22301
2. That you can hear OCWEN telling Brock & Scott NOT to Foreclose on Spring St. @ Brock and Scott /
OCWEN conversation March 2019 Admits OCWEN had told them to not Foreclose conv starts at
about 6 min and 40 sec https://www.youtube.com/watch?v=00gWnLp11vI&t=1127s

3. That you can then see the Foreclosure taped: The Foreclosure by Wells Fargo NOT OCWEN a
total SCAM March 2018. https://www.youtube.com/watch?v=82tllotwvW0
4. The Deed attached shows the property in the name of Wells Fargo N.A. et al with an odd caveat for
OCWEN.
5. Troutman Sanders then approached JWG on or around April 4, 2019 Troutman Sanders Lawyer S.
Moshin Reza asking JWG to do a short sale on a home that had been foreclosed. That Micheal
Martinez appears to be an agent of Troutman Sanders whose investors in the Foreclosure
properties are located in Florida and New Jersey. Further Mr. Martinez stated “Wells Fargo is easy
to deal with and will do almost anything we want” paraphrase.
6. That in or around November of 2018 both Bank of America and Wells Fargo Bank responded to
subpoenas that neither had any documentation to being a party to a loan on 15 W. Spring Street,
Alexandria, VA 22301. Wells Fargo Bank filed their document directly to the court. Exhibit 18
7. That on or around August 8, 2019 Wells Fargo Bank did a notarized document that they had no
documentation on a loan in JWG name, social security and or address.. Exhibit 19
8. That OCWEN the loan servicer did a fraudulent 1099 to the IRS that is under investigation. The IRS
has stated it was a FRAUD. Exhibit 16
9. That PHH on or around August 26, 2019 sent a Letter stating Loan Servicing Moved to NewRezLLC.
NewRez LLC was created by PHH in or around 2008 and sold prior to PHH moving to OCWEN in
2018 to New Ressidential Investment Corp traded as NRZ. Investors can be seen Exhibit 20 - 24
10. According to insiders of OCWEN: OCWEN is going out of business or into Bankruptcy and is moving
any and all assets. The top 10 investors by CNN on or around Jan 30, 2020 of Wells Fargo Bank,
Bank of America, OCWEN and New Residential Investment Corp.
11. On January 5, 2020 in Wells Fargo’s research they looked towards Mers to show the loan history - they
did not believe me at first this alleged loan is nowhere to be found in Mers (even though they have filed
documents against the home putting it in a Mtg Back Sec that it did not meet the criteria), FNMA,

5
 Freddie Mac, JWG personal credit report since around 2012 show no none ownership of any loan.
Exhibit #
12. The CFPB / JWG have requested documentation that shows OCWEN / Wells Fargo Bank / Bank of
America to give some type of document and all have been denied. The documents provided have had
no substance.

RE: DEMAND to remove the “ILLEGAL, FRAUDULENT FILING” TO MISLEAD on the ownership of a
alleged loan on 15 W. Spring St., Alexandria, VA 22301

The law is clear and included in this letter that three (3) assignments were filed illegally against 15 W. Spring
Street, Alexandria, VA 22301 due to not being prepared properly by a lawyer, but by a lay person acting as a
lawyer and using another's Florida State Bar No. This includes the VA Code that rules the Clerk's Office, as
well as stated in the Virginia State Bars code of Professional Conduct for Practicing Law without a license.

HISTORY OF FRAUDULENT DOCUMENTS AGAINST SPRING ST

Prior to the Foreclosure

1. Filed on or around February 4, 2009 against 15 W. Spring Street, Alexandria, VA 22301 Document
No. 190003603 000551 000075 “Notice of Assignment of Deed of Trust” Virginia fraud on the
court with the basics of Virginia fraud claim requires proof of:

(1) a false representation, that the loan went to a Mtg Back Security that was closed prior to the loan
being created
(2) of a present, material fact, the Assignment was done by a non-lawyer Rob Meharg
(3) made intentionally and knowingly, That Docx person Lorraine Brown went to jail for the “Black
Market” Back Door loans
(4) with intent to mislead, the letter by Bank of America through BWW Law Group shows the intend in
or around December of 2012
(5) reasonable reliance by the party misled, and the Facts that Lorraine Brown went to jail the fact the
Mtg Back Security was closed on or around July 1, 2003 and the alleged loan is dated February of 4,
2005
(6) resulting damage. Illegal Foreclosure on March 30, 2019 EXHIBIT 1

2. Filed on or around June 18, 2009 against 15 W. Spring Street, Alexandria, VA 22301 Document NO.
090012907 000253 000076 “Notice of Assignment of Deed of Trust” Virginia fraud on the court
with the basics of Virginia fraud claim requires proof of:

(1) a false representation, that the loan went to a Mtg Back Security that was closed prior to the loan
being created
(2) of a present, material fact, the Assignment was done by a non-lawyer Rob Meharg
(3) made intentionally and knowingly, That Docx person Lorraine Brown went to jail for the “Black
Market” Back Door Mortgage Back Securities for the “Back Room” for financial gains of Banks and
Servicers

6
(4) with intent to mislead, the letter by Bank of America through BWW Law Group shows the intend in
or around December of 2012
(5) reasonable reliance by the party misled, and the Facts that Lorraine Brown went to jail the fact the
Mtg Back Security was closed on or around July 1, 2003 and the alleged loan is dated February of 4,
2005
(6) resulting damage. Illegal Foreclosure on March 30, 2019 EXHIBIT 2

3. Filed on or around April 22, 2013 against 15 W. Spring Street, Alexandria, VA 22301 Document
No. 130014851 000586, 000587 000071 “Affidavit of Lost Assignment” Virginia fraud on the
court with the basics of Virginia fraud claim requires proof of: EXHIBIT 5

Sister Nora Nash states: OCWEN and Altisource, through a systematically designed process,
induce foreclosures and then sell these foreclosed homes on HUBZU.com so they can earn listing
commissions, Buyer's Premium, Escrow Fees, Web Technology Fee, Property Preservation Fees, Title
Insurance Fees, Closing Coordination Fees and more!

(1) a false representation, After BWW Law Group failed at foreclosure and questions asked, and
evidence of the fraud presented to Servicer and Lawyers they created by a non-lawyer a “Affidavit of
Lost Assignment” using a Judge Donald Alexander in Florida Bar number
(2) of a present, material fact, That Wells Fargo Bank in phone calls and written to CRPB and this
court no ownership or any involvement in any loan with 15 W. Spring St. Alexandria, VA 22301
(3) made intentionally and knowingly, the Facts are clear JWG had disclosed to Howard Bierman of
BWW Law Group the Fraud
(4) with intent to mislead, The filing with the Commissioner, and the foreclosure itself showed
OCWEN et al believe they are above the law as long as there is financial gain for lawyers
(5) reasonable reliance by the party misled, and The foreclosure on March 30, 2018

April 4, 2019 at Prince Georges MD - Courthouse Mohsin Reza of Troutman Sanders asks JWG
“Are you interested in a short sale” JWG stated clearly “NO” and then asked by Mr. Reza “if I had
gotten a recent call about selling the home” you will notice this TEXT sent March 23, 2019. Michael
as he states has contacted me in the past and even had been given my daughters phone number in the
past. The Question Becomes: “BLACK MARKET” by lawyers and WHO ELSE harassing and
forcing short sales on illegal foreclosures

March 29, 2018 Phone call between OCWEN, Janice Wolk

Grenadier and Brock & Scott aka Trustee Services Of
Virginia, LLC., where OCWEN informs Brock & Scott and
Brock & Scott acknowledge that on or around March 22, 2018
they had received notice from OCWEN not to foreclose.
They then received from the Investor that no matter what they
were to foreclose - ignoring whatever OCWEN said.
https://www.youtube.com/watch?v=00gWnLp11vI&t=562s

7
On March 30, 2018 OCWEN Loan Servicing held an illegal foreclosure on 15 W. Spring St., Alexandria VA
22301. The property owner then and legally still today is Janice Wolk Grenadier. Video March 30, 2018 The
foreclosure https://www.youtube.com/watch?v=82tllotwvW0

On or around April 6, 2018 a Trustee Deed was filed on the property that Wells Fargo Bank National
Association, as Trustee for Option One Mortgage Loan Trust 2005-2, Asset Backed Certificates, Series 2005-2
Trustee for Option One (Mtg Back Security does not exist) see attached

On or around December 8, 2018 Wells Fargo Bank N. A. would file in the courthouse of the City of
Alexandria in response to a Subpoena by JWG that they had no interest in this foreclosure or this home - see
attached

On or around February 3, 2019 JWG received from OCWEN a Fraudulent 1099-A Acquisition or
Abandonment of Secured Property Information Returns that stated they “OCWEN” not Servicing, not LLC
only OCWEN is / was the lender on the loan (OCWEN on its own does not exist as an entity). The IRS has
deemed this 1099 from evidence presented to be “FRAUDULENT” and has told Janice Wolk Grenadier to
ignore such 1099 while Criminal Investigation is starting. See attached - It should be noted Janice Wolk
Grenadier is still in home.

OCWEN Entities found: Ocwen Loan Servicing, which is licensed to service mortgages in the state, used
unlicensed affiliate offshore companies to “perform activities considered residential mortgage loan servicing.”
Ocwen Financial Solutions Private Limited, operating out of a location in India, and Ocwen Business
Solutions, operating out of a location in the Philippines, to conduct “servicing” activities on residential
mortgage loans. VA SCC states OCWEN is Licensed as:

F1991993 OCWEN BUSINESS SOLUTIONS, INC. Foreign Corporation Active

F1995820 OCWEN FINANCIAL INSURANCE SERVICES, INC. Foreign Corporation Active

F1564386 OCWEN FINANCIAL SOLUTIONS PRIVATE LIMITED Foreign Corporation Active

T0206161 OCWEN LOAN SERVICING, LLC Foreign Limited Liability Company Active

OCWEN filed a 1099-A Acquisition or Abandonment of Secured Property with the IRS where Ocwen was not
a secured creditor. EXHIBIT 13

Ocwen Financial Corporation is a provider of residential and commercial mortgage loan servicing, special
servicing, and asset management services, which has been described as "essentially debt collectors, collecting
monthly principal and interest from homeowners". Ocwen is headquartered in West Palm Beach, Florida, with
additional offices in Addison, Texas, Orlando, Florida, Houston, Texas, Rancho Cordova, California, St. Croix,
U.S. Virgin Islands, and Washington, D.C. It also has support operations in the Philippines and India.

Ocwen under 26 U.S.C. § 7434 willfully filed fraudulent 1099 information returns with the IRS 26 U.S.C. §

8
7434. Civil damages for fraudulent filing of information returns8. That OCWEN never lent any money to Janice
Wolk Grenadier thus suffered no financial loss and was not a secured creditor under any state property laws.
That the Trustee Deed and OCWEN acting as the Servicer at all times stated clearly that Wells Fargo Bank was
the lender and or Wells Fargo Bank National Association, as Trustee for Option One Mortgage Loan Trust
2005-2, Asset Backed Certificates, Series 2005-2 Trustee for Option One (Mtg Back Security does not exist) see
attached.

Banks: All Banks state in writing to Janice Wolk Grenadier and the CFPB they have no knowledge, no
information and no involvement in or on a loan against Janice Wolk Grenadier and or 15 W. Spring St.,
Alexandria VA 22301

● Bank of America aka LaSalle Bank

● Wells Fargo

That on or around April 3, 2019 Wells Fargo Bank N. A. made it clear they are cooperating and most likely
working with OCWEN and supporting the “Black Market” Mortgage Back Securities and the “FRAUD”

(6) resulting damage. The foreclosure on March 30, 2019 was and is Common law theories of
negligence, gross negligence, payment by mistake, unjust enrichment, money had and received, breach
of fiduciary duty, breach of contract, misrepresentation, deceit, fraud, and aiding and abetting,
Retaliation and Retribution, RICO & Racketeering, the cruelty of the acts and actions are and where
willful acts were malicious, violent, oppressive, fraudulent, wanton or grossly reckless, any of the
foregoing all acts and actions have been knowledgeable by lawyers, banks and Servicers et al ;

The VSB: https://www.vsb.org/pro-guidelines/index.php/unauthorized-practice-rules/rule-6/

Violating Unauthorized Practice of Law Rule 6 Real Estate Practice 6-1010 (B) (C),UPR 6-102 (A), UPR
6-103 (A) (B) UPR 6-106 UPC 6-1 UPC 6-2 UPC 6-4 UPC 6-8

JWG asked for a response prior to May 1, 2019 due to a court hearing on May 6, 2019 in regard to the
Commissioners Case CASE NO. CW 1800 1465 where I have filed a Motion for the Judge to remove the
Assignments and I would appreciate your support of such actions. I WAS IGNORED.

13. That in May June of 2020 the home was listed for Sale the home with the wrong address for Wells Fargo
Bank and claiming Wells Fargo Bank was the owner of the home on HudForeclosed. Stated contact
Wells Fargo Bank at 800 S Broad St. Meriden, CT 6450 Tel 860-368-3400 or 860-368-3400 all
Fraudulent Nos. The principle a California Lawyer not practicing stated the information came from the
8
26 USC § 7434. Civil damages for fraudulent filing of information returns(a) In general If any person willfully files a fraudulent information return
with respect to payments purported to be made to any other person, such other person may bring a civil action for damages against the person so filing
such return.(b) Damages In any action brought under subsection (a), upon a finding of liability on the part of the defendant, the defendant shall be liable to
the plaintiff in an amount equal to the greater of $5,000 or the sum of—(1) any actual damages sustained by the plaintiff as a proximate result of the filing
of the fraudulent information return (including any costs attributable to resolving deficiencies asserted as a result of such filing),(2) the costs of the action,
and(3) in the court’s discretion, reasonable attorneys’ fees.(c) Period for bringing action Notwithstanding any other provision of law, an action to enforce
the liability created under this section may be brought without regard to the amount in controversy and may be brought only within the later of—(1) 6
years after the date of the filing of the fraudulent information return, or(2) 1 year after the date such fraudulent information return would have been
discovered by exercise of reasonable care.(d) Copy of complaint filed with IRS Any person bringing an action under subsection (a) shall provide a copy
of the complaint to the Internal Revenue Service upon the filing of such complaint with the court.(e) Finding of court to include correct amount of
payment The decision of the court awarding damages in an action brought under subsection (a) shall include a finding of the correct amount which should
have been reported in the information return.(f) Information return For purposes of this section, the term “information return” means any statement
described in section 6724(d)(1)(A).(Added Pub. L. 104-168, title VI, § 601(a), July 30, 1996, 110 Stat. 1462; amended Pub. L. 105-206, title VI, §
6023(29), July 22, 1998, 112 Stat. 826.) A prior section 7434 was renumbered 7437 of this title. 1998—Subsec. (b)(3). Pub. L. 105-206 substituted
“attorneys’ fees” for “attorneys fees”. Pub. L. 104-168, title VI, § 601(c), July 30, 1996, 110 Stat. 1462, provided that: “The amendments made by this
section [enacting this section and renumbering former section 7434 as 7435 of this title] shall apply to fraudulent information returns filed after the date of
the enactment of this Act [July 30, 1996].”

9
 Bank. the Bank denies any knowledge of such a listing especially since they don’t own such a home.
On around May / June of 2020
14. That on June of 2022 Troutman Pepper Hamilton Sanders Filed in the City of Alexandria General
District Court to evict JWG that Wells Fargo Bank NA. That this is a criminal action. That Wells Fargo
BAnk has stated clearly in the court that it has no ownership of such loan. Moshin Reza was then
moved from Troutman to Greenberg Traurig, LLP -
15. To harass and try to embarrass Plaintiff the beginning of May 2020 this MeMe was put on the internet -
This is the pattern and practice to just keep throwing things at one
person to see if you can break them and shut them up? Or maybe
your goal and this “GANG” is hoping I will commit suicide. I will
not. Or maybe you think I will become afraid of you - You can go to
my blog VALaw2010.blogspot.com or to the new website I have
founded JudicialPedia.com to see I am not running. I am Standing
Up and Speaking Out against the corruption

BACKGROUND PRIOR TO FORECLOSURE

Plaintiff incorporates herein by reference all of the allegations

contained in the above Paragraphs of this Complaint

On February 4, 2005 JWG took out an alleged loan from Mortgage and Equity Funding Corporation. The
alleged loan in question went immediately to Option One Mortgage Corporation for servicing.

Option One was allegedly purchased by American Home Mortgage Servicing Inc. on or around May 17,
2008 AHMS Inc. was purchased by Homeward Residential on or around February 17, 2012.

Homeward Residential transferred to OCWEN and JWG’s alleged loan was transferred Tuesday
February 19, 2013 (the day prior Monday February 18, 2013 was a Federal Holiday for Presidents day with the
Banking industry closed.)

On or around December 18, 2012 BWW-Law Group sent JWG a letter stating that Bank of America
owned her loan. BWW-Law was sending the letter under an obligation under Section IV.D.6 of the National
Mortgage Settlement, which Wells Fargo was not a party to.

Robo-Signers. On or around December 28 of 2012 Bank of America representatives denied ever owning such a
loan. Bank of America purchased LaSalle Bank October 1, 2007. February 24, 2009 and February June 18,
2009 Bank of America f/k/a LaSalle Bank filing - Notice of Assignment of Deed of Trust using nationally
known Robo-signers Linda Green (VP) [Ex 5], Tywannia Thomas ( Asst. VP ), and Korell Harp (VP). Exhibit 2
is both Assignments

10
 Linda Green. It was proven in the USA and Lynn E. Szymoniak vs. American Home Mtg et al that
Linda Green was not employed by American Home Serving, Inc. and did not have any authority to sign.

Tywannia Thomas. She did not sign all of the documents that her name is affixed on the DOCX –
prepared assignments. The use of several different corporate titles exists.

Korell Harp. Also did not sign all the documents to which his name is affixed.

Affixing or submitting false signatures on a mortgage document is a violation of federal and state law, and
those signatures are without authority to complete the transaction. According to a mortgage fraud notice
prepared jointly by the Federal Bureau of Investigation and the Mortgage Bankers Association, submitting false
mortgage assignments and forging signatures violates potentially eight federal criminal statutes. Specifically: (1)
18 U.S.C. §1001 – Statements or entries generally; (2) 18 U.S.C. § 1010 - HUD and Federal Housing
Administration transactions; (3) 18 U.S.C. § 1014 – Loan and credit applications generally; (4) 18 U.S.C. § 1028
– Fraud and related activity in connection with identification documents; (5) 18 U.S.C. § 1341 – Frauds and
swindles by mail; (6) 18 U.S.C. § 1342 – Fictitious name or address; (7) 18 U.S.C. § 1343 – Fraud by wire; and
(8) 18 U.S.C. § 1344 10 – Bank Fraud. See FBI Mortgage Fraud Notice (available at
http://www.mbaa.org/FBIMortgageFraudWarning.htm); see, also, Truth in Lending Act, title 1 of the Consumer
Credit Protection Act, as amended 15 U.S.C. § 1601 et seq. ; Mortgage Fraud.

False or fraudulent notary acknowledgements are also a violation.

The signatures contained on the assignments filed in Foreclosure are fraudulent, in violation of Federal and
Virginia law, and therefore they do not serve to assign the note and mortgage properly, they lack the essential
authority for Defendants to act on note and mortgage and Defendants cannot foreclose.

The practice of fraudulent mortgage assignments is widespread across the United States. Defendants have the
knowledge of the serious problems of their fraudulent actions to cover up / conceal this problem. That nothing
has changed since 2010.

Defendants Use of Fake Documents, False Officer Titles and Forged Signatures violates Federal Lending
Law, State Mortgage Fraud law and Notary Fraud law.

Title. On or around December 28 / 31, 2012 JWG called BWWLaw Group and asked who owned the loan on 15
W. Spring Street? According to a letter on December 18, 2012, the owner was Bank of America –but Bank of
America denied such ownership. BWWLaw group referred JWG back to the Homeward Residential that BWW
Law Group had no knowledge who owned the loan.

Plaintiff / JWG was in the process of applying for the Government Independent Foreclosure Review and learned
about the possibility of this break in the chain of title.

The HAMP Program. In 2008 and thereafter, JWG Homeward on a Deed Mortification thru the programs
offered by Congress. The Servicers reaped excessive false rewards for losing/processing refinance documents
because of a flaw in a financial incentive for servicers document handling, motivating Servicers to delay, loose
paperwork etc. Servicers of loans such as they did on JWG’s, received money per application /and document/

11
but not per person, creating a reward for negligent and fraudulent corporate/organizational bad behaviors that
deprived or deterred homeowner refinancing, such as occurred here.

Improper interference with Plaintiff's HAMP Application. On or around January 28, 2013, Homeward
Mortgage sent JWG a Notice of Servicing Transfer (RESPA) and Welcome to OCWEN Loan Servicing, LLC [
Ex 8 ]

Homeward Mortgage servicing was the servicer of JWG loan till February 18, 2013. February 19, 2013
OCWEN became the servicer. Homeward Mortgage supervisor had advised Plaintiff on three different occasions
that all documents were in place for the HAMP Modification. Homeward then kept coming back with issues that
JWG had been told by Homeward that they were cleared up. Homeward supervisor had left JWG a message that
the foreclosure of her home had been stayed.

February 19, 2013 JWG phoned OCWEN to confirm that there had not been any issue that the foreclosure had
been stayed as the BWW Law Group still showed it active on BWW Law website. OCWEN informed JWG she
would need to re-submit documents for the HAMP Program – but to “ignore the foreclosure date because a
“foreclosure sale cannot be conducted” until after the evaluation of the HAMP program is complete and a
borrower found ineligible. As long as Plaintiff was being considered for the HAMP the foreclosure could not go
forward” Plaintiff went over this statement three times with the agent at OCWEN. OCWEN could not have been
more helpful and was reassuring about the foreclosure not going ahead. The phone conversation was close to an
hour going over everything. BWW Law Group refused to postpone even knowing they had no idea who owned
the loan -

February 20, 2013 JWG phoned OCWEN again and went through the fact the foreclosure was still on the
website schedule of BWWLaw Group, and would OCWEN please contact BWWLaw? OCWEN again reassured
Plaintiff they could not foreclose as the process had begun with OCWEN and it was illegal to foreclose.

February 20, 2013 JWG sent emails to BWW Law Group after being unable to reach BWWLaw group on the
phone about the pending foreclosure. BWWLaw Group informed Plaintiff that the alleged owner of the loan
(Equity Trustees) had made the decision and planned to move forward to foreclose on Plaintiff's property. In
December 2012 (two months earlier) BWWLaw Group had no idea who owned Plaintiff’s loan or who
had the original note.

Plaintiff continued to try to contact BWWLaw Group through phone calls and emails. through the end of
business February 20, 2013.

JWG made phone calls to OCWEN and supervisors at OCWEN, who were at a loss as to how to help JWG.
OCWEN claimed to have never seen a situation like this. OCWEN kept informing Plaintiff that BWW Law
group could not foreclose prior to or on April 17, 2013 and only thereafter if JWGs’ documents had not been
received by OCWEN. Phone calls are taped

With no other recourse, and based on BWWLaw Group bad faith, JWG was forced to file involuntary
Bankruptcy February 21, 2013 to protect her interest in the property. Video available

On February 21, 2013 JWG could not get through to a voice-mail or anyone at BWWLaw group, which at
times blocked JWGs calls and emails. JWG took a copy of the receipt for the bankruptcy to the address of the

12
alleged “owner” of the loan (according to BWWLaw Group – was “Equity Trustees” with an address of 2020
14th Street N., Suite 250 Arlington Va 22201. Plaintiff delivered the bankruptcy receipt in person, because on
the website for BWWLaw, showed only addresses in Richmond, VA and Bethesda, Md.

February 21, 2013. JWG was shocked to discover that BWW Law group and Equity Trustees LLC ``shared”
the same office! The actions of BWW Law (by refusing to turn over a copy of Plaintiff’s original note and other
information) but/while concealing that they ‘sharing’ offices with the foreclosure trustee, indicates egregious
self-interest and malicious intent to defraud Plaintiff. Here, they actively (by omission and affirmative acts)
intentionally interfered and violated Plaintiffs rights to participate and reap the rewards of the Government
backed HAMP program, by actively setting her up for foreclosure in violation of law.. These Actions of Equity
Trustees LLC, BWWLaw Group and other defendants were and are willful acts that are self-interest, malicious,
violent, oppressive, fraudulent, wanton, and grossly reckless in light of the fiduciary nature of the
law/firm/trustee duties.

On February 22, 2013 JWG e-mailed Allison Melton, an associate at BWW Law requesting a copy of the
Spring Street original note, and Allison (an associate with BWW Law Group) denied her request

On March 1, 2013 JWG returned to the offices of BWW- Law Group and Equity Trustees, LLC to hand deliver
a “qualified written request” under the Federal Servicer Act, which is a part of the Real Estate Settlement
Procedures Act, 12 U.S.C. 2605 (e). Requesting by law the information JWG had been denied by Defendants.

The letter at page 4, reminds Equity Trustees of the mandatory duty to acknowledge receipt of this qualified
written request within 20 business days, pursuant to 12 U.S.C. Section 2605 (e) (1)(A) and Reg. X Section
2500.21 (e)(1). Equity Trustees LLC “shares” offices with BWWLaw Group, and is owned by lawyers, who are
expected to be cognizant of the federal and state laws regarding their “specialty.” Here self-interest and greed
seem to 13 have motivated the law firm/lawyers to violate federal law/rights and fiduciary duties owed to JWG
because they controlled the documents and intentionally kept them from JWG.

JWG is an Entrepreneur and as a result of Defendant’s improper interference JWG lost funding because BWW
Law advertised her home for foreclosure February 7, 2013. JWG worked diligently with Homeward and
OCWEN to prevent foreclosure and by filing for Bankruptcy lost everything.

BWW-Law group f/k/a Bierman, Geesing, Ward & Wood, LLC acted in its own best interest by putting it’s own
best interests and that of the other lawyers, before the best interest of JWG for personal financial gain..

Robo-Signers. Jacob Geesing is a partner of BWW Law Group and since October 13, 2010 is publicly known
as “The Robo Trustee.”

Attorney Howard N. Bierman, also of BWW Law Group is also publicly known as a Robo Signer includes in
4 different signatures on JWGs forged documents by the BWW Law Group.

Documents filed against 15 W. Spring St. by BWWLaw Group Deed of Appointment of substitute Trustee June
2, 2006 Deed of appointment of Substitute Trustee prepared by BWW- Law Group on or around March 23,
2012 – but, not signed by BWW-Law Group – Signed by April King VP reading – Wells Fargo Bank, N.A.
as Trustee for Option One Mortgage Loans Trust 2005-2 Asset Backed Certificates, Series 2005-2 ( Option

13
One Mortgage shuts down and is sold on or around May 17, 2008 to AHMSI) [Ex 18 ] By: American
Home Mortgage Servicing Inc. (AHMSI)

The absence of any valid promissory note( necessary for enforcement on a secured interest), and the recent
Wells Fargo CEO/office representation that there is no bank interest, and that Wells Fargo is not involved in the
lawyer collection/foreclosure/auction process – demonstrate improper Defendant actions on a loan which is
no longer enforceable or supported in law.

BWW-Law Group and Equity Trustees LLC acted in bad faith and apparent self interest when both ignored all
correspondence from JWG.

On or Around May 17, 2012 JWG learned Mark R. Galbraith was representing Wells Fargo. 14

JWGreached out to Mr. Galbraith by phone and e-mail. Mr. Galbraith also refused to answer any questions in
regard if Wells Fargo had the original Note for 15 West Spring Street, Alexandria, Va. 22301.

Other Documents filed in Court-- February 4, 2005 – Deed of Trust – Mortgage Equity Funding Corp July 9,
2007 - Corporation Assignment of Deed of Trust – Prepared by Option One Mortgage Corp December 18, 2007
– Loan Mortification Agreement – Option One Mortgage

Lawyer overcompensation based on unacceptable and inappropriate practices. It has been well
documented in U.S. Congressional oversight that lawyer practices, such as the lawyer/trustees in
this case ( who ignored the Servicing Companies conversations with this homeowner) – are
unethical practices lawyers engage in who are afraid of losing foreclosure income and assets
payable to their law firm - practices involving foreclosure, banks, eviction or closing, including
Robo-signing.

The U.S. House Committee on Oversight and Government Relations, in response to inquiry from Congressman
Elijah Cummings, wrote from theFederal Housing Finance Agency on May 13, 201, a letter which establishes (
as improper practices) the acquisition of real estate using illegitimate foreclosure practices - a lawyer practice of
self-interest, such as occurred in this case. Page 3 describes as “Attorney Misconduct”, self-dealing and
inappropriate practices, which itemizes the practices in this case as “unacceptable” and shows Forms 104DC
submitted to Freddie Mac by the Servicers that S & B (Shapiro & Burson LLP) were paid to the lawyers - 2009 -
$ 3,369,146.14 By – FREDDIE MAC’S SERVICERS 2010 - $ 6,342,051.30 By - FdREDDIE MAC’S
SERVICERS In the First quarter of 2011 - $ 1,746,816.13 By – FREDDIE MAC’S SERVICERS The amounts
are not broken out into separate categories for the type of matter handled, but include payments for services
provided for foreclosures, bankruptcies, eviction, and closings in Maryland and Virginia.

The Question then becomes what is the difference between BWW-Law Group f/k/a BIERMAN, GEESING,
WARD & Wood, LLC and Shapiro & Burson LLP and now McCabe Weisberg and Conway? When you search
the Internet for Maryland and Virginia you see no difference in the criminal activities of both law firms. The
answer will come after a FOIA request for the 104DC will be submitted to Freddie Mac.

On or around Judge James Clark of the City of Alexandria for “Friendship” and other illegal reasons give
Divorce lawyer Ilona Ely Freedman Grenadier the right to foreclose on 15 W. Spring St, Alexandria VA 22301 –
This Fraud included the help of DiMuroGinsberg, Troutman Sanders aka Mays & Valentine (1990 stole $30,000

14
from plaintiff to help cover up thefts of lawyer Ilona Grenadier Heckman and James Arthur with false and
fraudulent, misleading information) and K

Once again forcing Janice Wolk Grenadier into Bankruptcy.

What this does is show the FORECLOSURE MILLS / LAWYERS collusion to make it a pattern and practice to
ensure the MURDER of and or the homeless of Janice Wolk Grenadier who continues to STAND UP and
SPEAK OUT of the corruption with even illegally jailing her and holding her in solitary confinement for 14
days. October 22, 2014 – November 12, 2014 – 22 days JWG illegally jailed and tortured in the City of
Alexandria, Solitary Confinement till 5pm on Election day Tuesday, November 4, 2014. Illegally Jailed to:

1. Silence her and stop exposure of e-mails between herself and Mark Warner’s office on the corruption
in the Judiciary. Janice went to Mark Warner for help instead he had her jailed, at the same time it was
exposed his “Pay to Play '' with a Federal Judgeship for a favor. Being ignored by the Senate Ethics
Committee.

2. To Bully / scare her into either committing Suicide or to turning the other check of the corruption and
not holding Virginia and the Federal Judiciary, the Government and Elected Officials accountable, as
well as the criminal acts and actions of the Old Boys Network in Virginia That the law is very clear:
That Judge Clarks actions have turned back time. Giving me less rights than a slave. Taking someone
under Title 42 US Code 1994 and Title 18 US Code 1581(a): Whoever holds or returns any person to a
condition of PEONAGE, shall be fined under this title for imprisoned not more than 20 years or both.

3. That on October 22, 2014 I was placed in jail for failure to pay legal fees in 30 days which is a
violation of my Thirteenth Amendment "Neither Slavery not involuntary servitude, except as
punishment for a crime where of the party shall have duly convicted, shall exist within the United
States, or any subject to their Jurisdiction". Furthermore the right by placing me 16 "under" a state
Peonage / Involuntary Servitude violating the Fourth Amendment right by malicious prosecution, false
imprisonment and unconstitutional arrest. This violation of my Eighth Amendment Right as to
Excessive Bail which in this case constitutes "Restitution Bail" which further shows the knowledgeable
malicious intent to silence me till the election was over on November 4th. 2014. Bias, Retaliation and
Retribution to further line the Lawyers pockets by Judge Clark. Further: The system is one where the
Lawyers and Judges have set it up to protect each other and line each other's pockets with Cash.

That the lack of duty of care, fair dealing and Good Faith when dealing with homeowners as the Big
Banks negotiated their way out of Jail and paid the United States Government $251 Billion Dollars should
not be ignored. The questions are does the $251 Billion compel improper for influence or favor of the
Judiciary? Further that vested by the Constitution and the Oath of Office taken by the Judiciary, the Government
and the Elected Officials are bound by the unique Oath of Office that they take to “preserve, protect and defend
the Constitution of the United States of America” and ensure Due Process in our courts.

That despite disclaimers and legal arguments, banks can’t walk away from their duty of due care and good faith.
That the documents filed against 15 W. Spring Street, have been forged in conflict with the law to enhance the
balance sheet of Bank of America aka LaSalle Bank, Wells Fargo, Option One and Equity Trustees that this
alone should be a concern of all Judges. That it shows an illegal conversion of loans to enhance the balance
sheet, while harming the title of the home at the same time. A loss that occurred because of their failure to

15
perform those duties is a loss to the bank – not the customer / homeowner who knew nothing about the
“problem” Hence the arguments of servicers (and the undisclosed principals for whom they act), banks and
trustees of REMIC Trusts and even trustees on deeds of trust and self proclaimed mortgagees and beneficiaries
on deeds of trust should be rejected if the homeowner has alleged, based upon ultimate facts upon which relief
could be granted, that the entity failed to act in good faith and due care.

That the Exhibits filed with this case showed the lack of care taken in legal documents filed against the home.

The court has an obligation to a pro se “poor person” of care, fair dealing and Good Faith.

That the Banks and Lawyers also had a duty of care, fair dealing and Good Faith.

Troutman Pepper Hamilton Sanders aka Troutman Sanders aka Mays & Valentine swindled with the help of
Divorce Lawyer Ilona Grenadier Heckman $30,000. For monies Divorce Lawyer Ilona admitted in 2008 of
stealing out of her law firm from using a forged Trust Addendum to the Sonia Grenadier Trust (mother of the
late Judge Albert Grenadier her 2nd husband and her third husband Judge Grenadier’s 1 st cousin c. 9 months
after his death by all appearance colluded with her). The Note for the money “borrowed” is still with the
Grenadier Starace Duffett & Levi Law firm due after 30 years in 2020. The only copy demanded as my lawyer
sits in Ilona’s safe according to Ilona who stated at the time “Let me keep this for safe keeping” who Janice /
Plaintiff was naive and trusted.

Wells Fargo and OCWEN lawyers colluded with Divorce Lawyer Ilona Grenadier Heckman in the City of
Alexandria Case No. CL1500 – 3661 to ensure and help Lawyer Ilona deny Plaintiff, all Plaintiff rights and
monies owed to Janice from being divorced without a Property Settlement. The settlement would have resolved
this case. That TroutmanSanders aka Mays & Valentine has a real fright of being held accountable for collusion
of the thefts from JWG.

The following e-mail states clearly how Troutman Sanders relationships with Judges are how they ignore the
law.

From: Reza, Mohsin [mailto:mohsin.reza@troutmansanders.com]

Sent: Thursday, January 28, 2016 12:21 PM
To: Heba Girgis <HGirgis@pskfirm.com>; Andrea Moseley <amoseley@dimuro.com>
Cc: Uria, Andy <Andy.Uria@troutmansanders.com>; Thompson, Ashley
<Ashley.Thompson@troutmansanders.com>
Subject: Grenadier, et al. v. Grenadier, et al. - Case No. CL15003661

Hello, Heba and Andrea:

I just received Janice’s written statement though it appears to have been mailed on
December 28. Are you all going to note an objection or just let Judge Clark deal with it?

Thanks,

16
 S. Mohsin Reza | TROUTMAN SANDERS LLP
1850 Towers Crescent Plaza, Suite 500, Tysons Corner, Virginia 22182
Tel: (703) 734-4351 | Fax: (703) 448-6510
mohsin.reza@troutmansanders.com

The lawyers did not show up in court. They did not have to file anything. JUDGE JAMES
CLARK was on their side as stated in the below links:

Further Mohsin Reza profile on the Troutman Sanders states he is an expert at: Mohsin Reza’s practice
focusing on representing corporate clients in complex litigation in state and federal courts. Mohsin represents
financial institutions in various commercial, consumer, and lender liability disputes, including lawsuits
involving claims brought under the Fair Credit Reporting Act, the Fair Debt Collection Practices Act, the Equal
Credit Opportunity Act, the Truth-in-Lending Act, the Telephone Consumer Protection Act, the Real Estate
Settlement Procedures Act, the Uniform Commercial Code, and state consumer protection statutes. Mohsin also
represents small and large businesses in defending against and asserting claims of negligence, breach of
contract, fraud, civil conspiracy, and business torts. Furthermore, he has experience representing clients in estate
litigation and probate matters. Mohsin Reza has moved law firms to Greenberg Traurig, LLP

That Wells Fargo, Option One, Equity Trustees, Bank of America all in one way or another have
claimed ownership of a loan. BWW Law Group, Howard Bierman and several bad actors from
McCabe Weisberg & Conway, Michael Weiser ESQ, DiMuroGinsberg, Parker Simon & Kokolis LLC,
McQuireWoods, TroutmanSanders LLP, Grenadier Starace duffett & Levi PC, Hunoval Law, OCWEN
have all acted as Debt collectors under the “FDCPA” Fair Debt Collection Practices Act. And the
“CFPB” Consumer Financial Protection Act of 2010 which has independent litigating authority to
commence civil actions to address violations of the “Federal Consumer Financial Laws”, with DOJ,
FTC and others having additional oversight.

Violating: all the 15 U.S. Code Subchapter V - DEBT COLLECTION PRACTICES Current through
Pub. L. 114-38. (See Public Laws for the current Congress.) 15 SC § 1692 - § 1692d - Harassment or
abuse § 1692e - False or misleading representations § 1692f - Unfair practices § 1692g - Validation of
debts § 1692j - Furnishing certain deceptive forms

Further Violating with Knowledgeable intent: FDCPA Laws & Guidelines of the Fair Debt Collection
Act and debt collection services in your area. Table of Contents 801 Short title 804 Acquisition of
location information 805 Communication in connection with debt collection 806 Harassment or abuse
807 False or misleading representations 808 Unfair practices 809 Validation of debts 812 Furnishing
certain deceptive forms 801 15 USC 1601 note 801. Short Title This title may be cited as the "Fair Debt
Collection Practices Act." 802. Congressional findings and declaration of purpose (a) There is abundant
evidence of the use of abusive, deceptive, and unfair debt collection practices by many debt collectors.
Abusive debt collection practices contribute to the number of personal bankruptcies, to marital
instability, to the loss of jobs, and to invasions of individual privacy. (b) Existing laws and procedures
for redressing these injuries are inadequate to protect consumers. As Lawyers the Defendants and others
know their wrong doing. (c) Means other than misrepresentation or other abusive debt collection
practices are available for the effective collection of debts. (d) Abusive debt collection practices are
carried on to a substantial extent in interstate commerce and through means and instrumentalities of

17
 such commerce. Even where abusive debt collection practices are purely intrastate in character, they
nevertheless directly affect interstate commerce. (e) It is the purpose of this title to eliminate abusive
debt collection practices by debt collectors, to insure that those debt collectors who refrain from using
abusive debt collection practices are not competitively disadvantaged, and to promote consistent State
action to protect consumers against debt collection abuses.

That OCWEN uses the name and Scheme as WELLS FARGO BANK as their employee has shopped lawyers
and now hired McCabe Weisberg and Conway/ Brock & Scott to ignore suits and Foreclose. On or around May
17, 2017 a letter was received by them that stated clearly that Wells Fargo had no instruments that should have
been standing, which is what Plaintiff has been claiming.

Which would be followed with a letter to Foreclose on July 20, 2017.

On or around July 9, 2017 a Motion to Stay Foreclosure by Wells Fargo, OCWEN by McCabe Weisberg &
Conway was filed by Janice with this court as an Emergency Stay due to the shopping of a law firm that would
Foreclose while still in court. The following Documents filed with it should be incorporated herein. (That a
Reconsideration and EnBanc has been filed)

That MCW letter dated July 18, 2017 from McCabe Weisberg & Conway LLC which was received on the 21st
of July 2017.

The Letter seemed misleading and with all the above had been done to deny Janice and Janice’s Constitutional
Rights Janice created a Trust and on July 25, 2017 did a Quick Claim Deed of 15 W. Spring Street, Alexandria
VA 22301 into the Trust. Janice mailed a copy to OCWEN.

On or around Friday July 28, 2017 Janice would receive Occupant; Homeowner and Janice Wolk Grenadier
letters stop your foreclosure.

On or around Tuesday August 1, 2017 Janice would receive a letter from McCabe Weisberg & Conway LLC
that they were foreclosing on 15 W. Spring St., Alexandria VA 22301 on August 17, 2017. That with
such a misleading letter on or around May 21, 2017 the research of the misleading and appearance of criminal
acts and actions of many sent Janice to learn that the SEC which forwarded Janice to CRPB, the DOJ, the FTC,
15 USC 1692 and the FDCPA protected Janice from PREDATORY ACTS and ACTIONS of Wells Fargo,
Option One, Equity Trustees, Bank of America all in one way or another have claimed ownership of a loan.
BWW Law Group, Howard Bierman and several bad actors from McCabe Weisberg & Conway, Michael Weiser
ESQ, DiMuroGinsberg, Parker Simon & Kokolis LLC, McQuireWoods, TroutmanSanders LLP, Grenadier
Starace duffett & Levi PC, Hunoval Law and OCWEN.

Virginia has no regulations for Deceptive and Abusive practices by debt collectors so Janice is protected by the
Federal Fair Debt Collection Practices Act (FDCPA).

The Statute of Limitations to collect on a debt is 3 – 5 years from the last payment accepted.

According to OCWEN the last payment not returned was 3, 152 days from June 16, 2017, with the last
payment in 2008 that the Statute of Limitations on Collection had run out.

18
That JWG did the Trust / Quick Claim Deed due to the Predatory acts and actions of Defendants, Defendants
lawyers and others.

JWG moved the property prior to any notification of the new foreclosure date (which according to the FDCPA
and others the date is illegally done) and or a Judgment that a Re-Consideration with an EN BANC, and Oral
Arguments is filed.

That on August 9, 2017 JWG would receive a phone call from OCWEN that the Foreclosure had been canceled
as of August 4, 2017 – Phone conversations is taped and can be heard

That on August 11, 2017 after sending email and several unreturned phone calls from McCabe (Remember this
scheme and artifice of OCWEN to say one thing and do another Janice was and still is a VICTIM Of with BWW
Law Group. The McCabe et al would not return calls to confirm Foreclosure was removed from their schedule.

On August 11, 2017 from OCWEN she learned that the foreclosure was never removed, that OCWEN and
McCabe had schemed no differently illegally and in collusion to try and deceive JWG that the Foreclosure had
been removed from the schedule. That this illegal practice by OCWEN and Lawyers acting as Foreclosure Mills
to further line their pockets is a pattern and practice all across America.

On August 11, 2017 JWG would call the CEO of Wells Fargo’s office to ensure he was aware of the
CRIMINAL ACTIVITY of his Servicer and Lawyers. JWG would learn in a taped conversation that Wells
Fargo has no loan under the Loan No. given by OCWEN, under her name as Janice Wolk Grenadier or Janice
Wolk-Grenadier or under her Social Security No.

That JWG on several occasions offered to settle and why should opposing sides settle or consider a settlement
when they know with or without the Truth the duty of care, fair dealing and Good Faith the Judges will ignore
all criminal acts and actions by the Banks and Lawyers as shown in the above e-mail.

That JWG is still willing to try and settle this matter. At this point the home is in a Trust and protected by the
law / Statute of Limitations of Collections on a loan.

On August 17, 2017 at or around 10:00 am JWG would receive notice from MWC that the FRAUD allegations
have been taken seriously and the foreclosure put on hold.

That immediately a new foreclosure date of October 5, 2017 would be rescheduled with no information
requested on who the employee of OCWEN is.

CAUSES OF ACTION

Count 1
18 USC § 371 Conspiracy, Federal False Claims Act, 31 U.S.C. § 3729 (a)(1)(A); 31 U. S. C. § 3729
(a)1(B); 31 U.S.C. § (a)(1)(C) 18 USC §1349 Attempt and Conspiracy forms Fair Debt. Collection Act
(FDCPA) § 806 Harassment, § 807 False and misleading, § 808 Unfair practices, § 809 Validation of debts,
§ 812 Furnishing deceptive forms, et al

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint.

19
Defendants and others known and unknown did knowingly and unlawfully combine, conspire, confederate, and
agree to commit the following offenses against Janice Wolk Grenadier a. to, directly and indirectly, corruptly
give, offer, and promise a thing of value, that is, among other things, cash or cash equivalents, with intent to
influence illegal acts, to commit and aid in committing, and to collude in, and allow fraud, and make opportunity
for the commission of any fraud, on the United States,

PURPOSES OF THE CONSPIRACY to ensure the COVER UP of Divorce Lawyer Ilona Grenadier
Hackman’s crimes as attached in Exhibit Criminal Complaint filed with the Department of Justice et al.

Manner and Means of the Conspiracy: Includes Elected Officials, the Government and the Judiciary to protect
one of their own.

OVERT ACTS: That divorce lawyer Ilona Grenadier Heckman has been on a Criminal Spree stealing out of
her law firm that Janice can document starting on or around November of 1983 with the forgery of Sonia
Grenadier Heckman. That the defendants are two of many USED to try and silence, mislead and act criminally
to protect the accountable $30 MILLION if not more that Ilona stole through her law firm from Sonia Grenadier
the mother of the late Judge Albert Grenadier and then Janice Wolk Grenadier which by the Banks, the Servicers
lawyers involvement has created the scheme and artifice to prevent Janice any type of financial where for all.

This is a claim for treble damages and forfeitures under the False Claims Act, 31 U.S.C. § 3729 et seq. 2

The Defendants created, sold or participated in Mortgage backed securities. The Mortgage backed Securities
were composed of mortgages bundled to create the securities in which the mortgages lacked the requisites to
create a secured, real estate debt obligation, namely:

The legally binding assignments from the originating bank to the securities trust and, and finally, to the
foreclosure agent

Recording of Title in the Cities Clerk's office

Original Note and Mortgage, signed by both borrower and lender. The prospectus for each mortgage-backed
securities trust, and other public statements, falsely represented that the trust held good title to the mortgages and
notes bundled in the securities.

By Virtue of the wrongful conduct alleged here including, but not limited to, the false signatures used in
manufactured mortgage assignments, or stating the person had POWER OF ATTORNEY which does not exist
each of the mortgage-backed securities sold to the Treasury, or other entity funded by the U.S. government,
violated state and federal laws and furthered an effort to transfer impaired securities to the Treasury, or other
government funded entity. Defendants and their agents and employees falsely represented that they held good
title to 15 W. Spring Street. Defendants received millions of dollars in U.S. government funds to provide
services involving fraudulent mortgage assignments. Accordingly, the Defendants and their agents and
employees knowingly presented or caused to be presented a false or fraudulent claim for payment or approval
from the government entity purchasing the mortgage-backed securities.

20
Defendants and their agents and employees falsely represented that they had good title to 15 W. Spring Street.
When in Fact they had in their knowledgeable fraudulent actions created a cloud on the Title making the home
unsellable.

Defendants acted in concert to create fraudulent legal documentation to conceal that the trust was missing title to
the asset, thus impairing the value of the security sold to the treasury, or other government funded entity. Each of
the mortgage-backed securities sold to the Treasury, or other government funded entity, was in violation of state
and federal law.

THE GOVERNMENT (AG Eric Holder, Ben Bernanke & )

SELLS OUT THE AMERICAN PEOPLE

The Financial Crisis Inquiry Report: Final report of the National Commission on the Causes of the Financial
Economic Crisis in the United State of America
https://www.govinfo.gov/content/pkg/GPO-FCIC/pdf/GPO-FCIC.pdf - This link will take you to the Official
Government Edition.

Some of the Banks that received the SECRET Bail out through AIG

Bank of America $ 1,535,002,662,031

Citi $ 1,535,002,662,031
Goldman Sachs $ 874,552,426,455
JP Morgan Chase $ 460,982,382,326
Morgan Stanley $ 2,287,966,932,941
Wells Fargo $ 198,712,559,776

Then 5,000. of the Executives received at least $1 MILLION in bonus each

CASES YOU CAN’T Or Shouldn’t ignore IGNORE

Other then the Two CFPB Cases Above:

BEAR STEARNS MORTGAGE PASS-THROUGH CERTIFICATES LITIGATION / : 850

Securities/Commodities Date September 18, 2008 City/County New York Type of Case 850
Securities/Commodities Class Action Complaint for Violation of the Securities Act of 1933
https://judicialpedia.com/listing/bear-stearns-mortgage-pass-through-certificates-litigation-850-securitie
s-commodities/

Case Number 1:09-cv-06172-LTS Lead case: 1:08-cv-08093-LTS Member case: (View Member
Case) Related Case: 1:08-cv-08093-LTS Cause: 15:78m(a) Securities Exchange Act
Judges Judge Laura Taylor Swain Read More:
https://judicialpedia.com/listing/bear-stearns-mortgage-pass-through-certificates-litigation-850-securitie
s-commodities/

BEAR STEARNS MORTGAGE PASS-THROUGH CERTIFICATES LITIGATION / : 850

Securities/Commodities Date September 18, 2008 City/County New York Type of Case 850
Securities/Commodities Class Action Complaint for Violation of the Securities Act of 1933 Case

21
Number 1:09-cv-06172-LTS Lead case: 1:08-cv-08093-LTS Member case: (View Member Case)
Related Case: 1:08-cv-08093-LTS Cause: 15:78m(a) Securities Exchange Act Judges Judge Laura
Taylor Swain
https://judicialpedia.com/listing/bear-stearns-mortgage-pass-through-certificates-litigation-850-securitie
s-commodities/

Carvelli v OCWEN Financial Who Regulates Whom? Who's Regulating the BANKS & SERVICER'S?
FORECLOSURE COMPLAINTS UP STATES THE CFPB Date April 21, 2017 City/County West
Palm Beach Type of Case Cause: 15:0077 Securities Fraud Nature of Suit: 850
Securities/Commodities
https://judicialpedia.com/listing/carvelli-v-ocwen-financial-who-regulates-whom-whos-regulating-the-b
anks-servicers-foreclosure-complaints-up-states-the-cfpb/

Federal Housing Finance Agency v. JPMorgan Chase & Co. et al Nature of Suit: 850
Securities/Commodities Were you told to not make payments by your Servicer? Date September
2, 2011 City/County New York City Type of Case Cause: 15:77 Securities Fraud / 850
Securities/Commodities Jurisdiction: U.S. Government Plaintiff
https://judicialpedia.com/listing/federal-housing-finance-agency-v-jpmorgan-chase-co-et-al-nature-of-su
it-850-securities-commodities-were-you-told-to-not-make-payments-by-your-servicer/

In Re: BEAR STEARNS MORTGAGE PASS-THROUGH CERTIFICATES LITIGATION / 850

Securities/Commodities Jurisdiction: Federal Question / Date September 18, 2008 City/County New
York Type of Case 850 Securities / Commodities Case Number 1:08-cv-08093-LTS - Related Case:
1:09-cv-06172-LTS Related Case No. 1:09-cv-06172-LTS Case in other court: Supreme Court-County
of New York, 602426- 08 Judges Judge Laura Taylor Swain
https://judicialpedia.com/listing/in-re-bear-stearns-mortgage-pass-through-certificates-litigation-850-sec
urities-commodities-jurisdiction-federal-question/

John Hancock Life Insurance Company (U.S.A.) et al v. JP Morgan Chase & Co / 850
Securities/Commodities
Date April 23, 2012 City/County New York City Type of Case 850 Securities/Commodities
Case Number 1;12-cv-03184- RJS Case in other court: Supreme Court- New York County,
650195-12 Cause: 28:1441nr Notice of Removal Judges Judge Richard J. Sullivan
https://judicialpedia.com/listing/john-hancock-life-insurance-company-u-s-a-et-al-v-jp-morgan-cha
se-co-850-securities-commodities/

LYNN E SZYMONIAK "HERO" Whistleblower ILLEGAL FORECLOSURE STILL

HAPPENING WITH "FAKE" MORTGAGE BACK SECURITIES Date June 4, 2010
City/County Rock Hill Type of Case FORECLOSURE Case Number 0:10-cv-01465-JFA Related
Cases 0:15-mc-000062-JFA 0:13-cv-00464-JFA Judges Judge Joseph F. Anderson, Jr
https://judicialpedia.com/listing/lynn-e-szymoniak-hero-whistleblower-illegal-foreclosure-still-happenin
g-with-fake-mortgage-back-securities/

Stichting Pensioenfonds ABP v. JPMorgan Chase & Co. et al / 850 Securities/Commodities

Date February 24, 2013 City/County New York City Type of Case : 850
Securities/Commodities case is hereby designated for inclusion in the Pilot Project Regarding Case
Management Techniques for Complex Civil Cases in the Southern District of New York (the Pilot
Project), Case Number 1:12-cv-01398-LAK Case in other court: State Court- Supreme,
653383-11 Cause: 28:1441nr Notice of Removal Judges Judge Lewis A. Kaplan

22
 https://judicialpedia.com/listing/stichting-pensioenfonds-abp-v-jpmorgan-chase-co-et-al-850-securities-
commodities/

Powell et al v. Ocwen Financial Corporation et al 29 U.S. Code § 1109.Liability for breach of

fiduciary duty Date March 5, 2018 City/County New York Type of Case Cause: 29:1109 Breach
of Fiduciary Duties, Nature of Suit: 791 Labor: E.R.I.S.A, Jurisdiction: Federal Question
Case Number 1:18-cv-01951-VSB-SDA Judges Assigned to: Judge Vernon S. Broderick Referred
to: Magistrate Judge Stewart D. Aaron
https://judicialpedia.com/listing/powell-et-al-v-ocwen-financial-corporation-et-al-29-u-s-code-%c2%a7
%e2%80%af1109-liability-for-breach-of-fiduciary-duty/

COUNT 2
Breach of Contract – Implied Covenant of Good Faith and Fair Dealing –
Breach of Contractual Duty of Good Faith and Fair Dealing Honest Services 18 U.S.C. § 1346

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

By virtue of the facts stated above, defendants have violated their contractual duty of good faith and fair dealing.
Honest Service under 18 U.S.C. § 1346 the Defendants schemed to foreclose on Plaintiff’s home with forged
documents, with knowledgeable intent of Fraud.

The above defendants and defendant’s representatives breached their contractual duty of good faith and fair
dealing when they refused to provide the requested original Note.

The above defendants Breach of Contract includes not limited to their involvement with breaking the chain of
title and creating a situation where JWG could not sell the home . The documents speak for themselves that the
defendants were aware of these breaches.

JWG through implied covenant of good faith and Fair Dealing continued to work with the different Servicing
groups even after they continued to lose paperwork, and make false claims, and advertise her home for a
Foreclosure Sale.

The defendant’s “flagrantly violated” their Fiduciary responsibility to JWG to deal in Good Faith while JWG
continued to deal in Good Faith.

That a Breach of Contract was created when the documents by Wells Fargo, Bank of America were forged, by
known robo signers.

Now Wells Fargo Bank and Bank of America claim no alleged ownership while a Servicer needs an employer to
foreclose – needs a contract to show it has any type of STANDING. OCWEN has used its own employees to
fraudulently sign rights over to Surety Trustees who must know as it states right on it – OCWEN employees. AS
Debt Collectors that they state clearly they are, they need to ensure that the debt they are collecting is a
legitimate debt and owned by OCWEN. MCW was informed that it was not a legitimate debt owned by
OCWEN.

Count 3
Violation of the Fair Debt Collection Practices Act (FDCPA)

23
 (15 U.S.C 1692, ET SEQ.) § 1692e - False or misleading representations § 1692f - Unfair practices §
1692g - Validation of debt § 1692j - Furnishing certain deceptive forms forms Fair Debt. Collection Act
(FDCPA) § 806 Harassment, § 807 False and misleading, § 808 Unfair practices, § 809 Validation of debts,
§ 812 Furnishing deceptive forms, et al

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

That there is no debt as the statute of limitations for collection has run out, the banks Wells Fargo and Bank of
America have stated they have no loan that they can account for.

Defendants used unfair/unconscionable means to try and foreclose illegally and unethically on 15 West Spring
Street while JWG was under the production of the HAMP program as described in paragraph

That the statute of limitations to collect on any type of debt has passed

That the documents filed against t the home by OCWEN, BWW Law Group, Brock and Scott, MCW are
fraudulent as Wells Fargo in a taped conversation out of the CEO’s Executive office states very clearly they have
no loan under the Loan No. of OCWEN, under the name Janice Wolk Grenadier or Janice Wolk – Grenadier or
under Janice’s social security No.

Further Stating that Evette Morales who signed as Attorney in Fact for Wells Fargo Bank does not have a Power
of Attorney to do such act for 15 W. Spring St. Alexandria VA 22301.

Further to ignore the STAY as issued by the 4th Circuit is in direct conflict of the lawyers Professional Code of
Ethics Cinder with the court 3.3 Further a self reporting group Lawyers and Judges have an obligation to report
criminal activity by Servicers and Banks. The appearance is OCWEN, BWW Law Group, Brock and Scott and
MCW is further lining their pockets as well as being a party to the Cover Up of Divorce Lawyer Ilona Grenadier
Heckman’s Criminal Spree.

Further even the Attorney General's Office has stated to OCWEN this Foreclosure should not take place as an
investigation is underway.

Count 4
Wrongful Foreclosure Threat and Foreclosure – Failure to Comply with HAMP rules

JWG incorporates herein by reference all of the allegations contained in the above a. Paragraphs of this
Complaint

HAMP PROHIBITS A PARTICIPATING server from taking several actions including the following:

Proceeding with a foreclosure sale. Any foreclosure sale must be suspended and no new foreclosure action may
be initiated during the trial period, and until the borrower has been considered and found ineligible for other
available foreclosure prevention options.

Requiring a borrower to make an initial contribution payment pending the processing of the trial period plan
before the plan starts.

24
Soliciting borrowers to opt out of consideration for HAMP during the temporary review period.

Reporting borrowers as delinquent to credit reporting bureaus without explanation. For borrowers who are
current when they enter a trial period, the servicer should report the borrower current but on modified payment if
the borrower makes timely payments during the trial period. For borrowers who are delinquent when they enter
the trial period, the servicer should report in such a manner that accurately reflects the borrower’s current
workout status.

Assessing prepayment penalties for full or partial prepayment as part of the modification.

The HAMP rules were expressed to JWG several times by AHMSI, Homeward and OCWEN - that you
could not be foreclosed on while you were being considered for the program.

It is documented that lawyers are nervous of losing the financial gain of Foreclosures stopping due to their
illegal and unethical practices. That if the homeowner gets into the HAMP program and an adjustment is made
to the loan – the lawyer loses an extra $50,000 or more. he gets from a foreclosure.

BWW Law group and now McCabe Weisberg and Conway, Brock and Scott Pllc had no other motivation to
foreclose on Plaintiff except for personal financial gain, greed and the exposure of their illegal and unethical
practices and for COVER UP of others criminal activity as stated in the CFPB Complaint of

The attached emails will back up these intentions being malicious, violent, oppressive, fraudulent,
wanton, or grossly reckless.

JWG after Defendants lawyers Troutman Sanders aka Mays & Valentine attached themselves to the Cover Up
of Divorce Lawyer Ilona Grenadier Heckman’s Criminal Spree to help deny Janice any and all Justice in the
courts in collecting her monies owed her from the THEFT of Ilona she is unable to if there was a loan qualify.

That the defendants have impeded with their lawyers the ability for Janice to earn a living

The BWW Law Group, the MCW, PARKER, SIMON & KOKOLIS LLC, the Brock and Scott Lawyers
attached Exhibits back up their intentions being malicious, violent, oppressive, fraudulent, wanton, or
grossly reckless.

Count 5
Consumer Protection Act

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

Bank of America and Wells Fargo used representatives to use unfair or deceptive acts or practices in forgery and
robo signing / FORGERIES of documents were deliberate with knowledgeable acts and actions to COVER UP
criminal behavior.

The deceptive acts of BWW Law Group, MCW, Brock and Scott, PARKER, SIMON & KOKOLIS LLC, and
Troutman Sanders aka Mays & Valentine lawyers for OCWEN have caused JWG the loss of Funding for her

25
company, and monies due her from her divorce and the opportunity to meet the guidelines needed for the Hamp
Loan.

That the defendants OCWEN is directly involved in helping to cover up the Criminal spree of divorce lawyer
Ilona Grenadier Heckman and now with the help of MCW LLC, BWW Law Group and Brock and Scott PLLC

Count 6
Breach of Fiduciary Duty - Unjust Enrichment/Constructive Trust

JWG incorporates herein by reference all of the allegations contained in the above a. Paragraphs of this
Complaint

BWW Law, MCW, PARKER, SIMON & KOKOLIS LLC, and Brock & Scott breached their Fiduciary Duty
when it put its financial gain above the law and the rights of Plaintiff.

BWW Law, MCW, PARKER, SIMON & KOKOLIS LLC, and Brock & Scott breached its Fiduciary Duty
when it ignored the HAMP rules for financial gain and greed.

Bank of America and its representatives breached its Fiduciary Duty with the Robo Signing / forgery of
documents breaking the chain of title on 15 West Spring Street.

Wells Fargo and its representative breached its Fiduciary Duty with the Robo Signing / forgery of documents
breaking the chain of title on 15 West Spring Street.

MCW LLP, PARKER SIMON & KOKOLIS LLC, BWW Law Group, Howard Bierman, and Mark Galbraith,
Brock & Scott breached their Fiduciary Duty with the refusal of production of the original Note or any proof of
the right to Foreclose on 15 West Spring Street.

OCWEN and the above as well as BWW Law, MCW, PARKER SIMON & KOKOLIS LLC, and Brock & Scott
have and had a responsibility of good faith and fair dealings that they have ignored.

Further the double dipping and filing of fraudulent documents against 15 W. Spring St with their Trustee
company

That documentation from JWG since on or around 2010 has been requested and ignored.

Stating that Wells Fargo is the Note Holder while Wells Fargo informs CFPB they have nothing to do with a
loan at 15 W. Spring St., Alexandria VA 22301 and or with Janice Wolk Grenadier. See Exhibits

Defendant lack of standing. That on or around 2013, Defendant OCWEN became aware of its lack of standing
to pursue any type of foreclosure action on JWG’s home, located at 15 W. Spring Street, Alexandria VA 2230,
but they nevertheless, for their own financial profit and gain, pursued illegal collection remedies that have
wrongfully harmed this JWG.

That Evette Morales who signed as attorney in Fact for Wells Fargo Bank is an employee of OCWEN. The
person who notarized the document that gave Surety Trustee aka McCabe Weisberg and Conway the right to

26
Foreclose has the same title as Evette Morales and seems to be office mates. Further Wells Fargo Bank denies
ever giving Evette Morales any type of POWER OF ATTORNEY to decide who has foreclosure POWER.
Evette is a Contract Management Coordinator at OCWEN Financial Corporation. This job advertises for a salary
of $30,000 - $36,000 approx.

That in or around December 2013 - 2014 OCWEN to avoid any criminal charges – no different then in the past
with Wells Fargo Bank and Bank of America did a consent ORDER to cease and desist the criminal activity.

That OCWEN has violated the CONSENT ORDER that was also signed by the Attorney General of Virginia.
That the OAG’s of the State of Virginia’s office has requested this illegal Foreclosure be put on HOLD For
further investigation.

That the CFPB filed this Complaint against OCWEN on or around April 20, 2017: in the USDC of the Southern
District of Florida West Palm Beach Division Case No. 9:17 –cv- 80495 - CFPB v. OCWEN FINANCIAL
CORPORATION a Florida Corporation , OCWEN MORTGAGE SERVING, INC, a US Virgin Islands
corporation AND OCWEN LOAN SERVICING LLC a Delaware Corporation - Defendants Page 2 Paragraph 2
States: The bureau brings this action against the Defendants under: (1)Sections 1031 and 1036 of the CFPA , 12
USC §§ 5531, 5536; (2) Sections 807 (2)(a), 807(10), and 808 of the Fair Debt Collection Practices Act, 15 USC
§§ 1692e(2)(a), 1692e(10), and 1692f (the “FDCPA”); (3) Section 6 and 19 of the Real Estate Settlement
Procedures Act (RESPA), 12 USC §§ 2605, 2617, and the regulations, promulgated 29 thereunder at Regulation
X, 12 C.F.R. part 1024 (“Regulation X”); (4) Section 105(a) of the Truth and Lending Act (“TILA”), 15 USC §
1604(a), and the regulations promulgated thereunder act Regulation Z, 12 C.F.R. part 1026 (“Regulation Z”):
and (5) Section 3(b) of Homeowners Protection Act of 1998, 12 USC § 4902(b)(the “HPA”).

This complaint shows that CFPB knew the acts and actions of OCWEN and that they had UNCLEAN
HANDS and yet allowed the foreclosure shows the COVER UP criminal activity. That JWG as an
Intervener should be allowed.

The Government and this Court is aware of the UNCLEAN hands and have supported the Banks and Servicers
criminal activity ignoring the American Citizen.

The scheme and artifice between the Defendants who intentionally and willfully scheme to defraud JWG, was
for the purpose of using color of law and misuse of the Trustee function, to obtain money, attorney fees, and
plaintiffs property for their own benefit by materially false and fraudulent pretense, representations and
promises, by intentionally defrauding both JwG and Wells Fargo Bank by collecting on a nonexistent loan,
which they knew was not collectible, was written off by the bank, and which they interfered with refinancing to
cause harm to Plaintiff and opportunity for themselves..

Count 7
Injunctive / Declaratory Relief

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

That JWG now needs to pray that this court grants temporary or permanent injunctive relief as JWG resides in
the property and as Defendants are seeking, through illegal and unlawful means and without satisfying the

27
necessary legal standing requirements to institute a foreclosure, take possession, custody, and control of the
Property.
Count 8
Common Law Fraud12 U.S.C 1972

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this
Complaint.

On several occasions JWG sent money to the Servicing agency of Wells Fargo and Bank of America to only
have funds returned and agreement squashed.

It is very well documented that the Mortgage Servicer’s were instructed to not take any payments and to "work
with you" only after borrowers fall behind in payments. Once borrowers fall behind on purpose and at the
lender's request, foreclosure proceedings begin in earnest. The Foreclosure lawyers and their friends are the
beneficiary in the game, as is seen above with the amount of money Shapiro and Burson have reported making
from being one of Freddie Mac Servicers.

The defendants or their representatives on several occasions made false statements of material facts. ie OCWEN
– “Ignore the Foreclosure it is illegal for them to as you are in the HAMP program process”

The defendants and or their representatives making these statements knew or should have known it to be untrue;

JWG to whom the statement was made had a right to rely on the statement; but, fortunately knew how deceitful
the defendants had been in the past.

JWG relied on the statement for as long as time permitted.

JWG believes the statement was made for the purpose of inducing the other party to be able to Foreclose on
JWG’s home and gain financially.

JWG relied on the Banks and their representatives at Homeward and OCWEN to not foreclose and to give
JWG's legal right to the opportunity to get Funding for her company and the opportunity to keep her home.

These statements made – created a situation that Plaintiff was not able to get the funding needed for her
company, giving her the income to qualify for a loan.

Count 9
Negligence – the negligent infliction of emotional distress;
the intentional infliction of emotional distress

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

The defendant’s had a legal duty to use reasonable care to protect the Chain of Title to the property at 15 West
Spring Street. By not doing this simple act the defendant’s malicious actions caused great emotional distress to
JWG.

28
That Evette Morales who claims to have a Power of Attorney from Wells Fargo Bank and signs as Attorney in
Fact, OCWEN and its attorneys have shown no employee contract with Wells Fargo on alleged loan as Wells
Fargo and Bank of America have claimed no ownership in alleged loan and further Wells Fargo Bank claims
never to have given such Power of Attorney.

The actions of the actors to cause this emotional distress were malicious, violent, oppressive, fraudulent,
wanton, or grossly reckless.

The defendants failed in their duty and unreasonably caused emotional distress to JWG with intentional
infliction of emotional distress. The negligence is sufficient to support this cause of action.

The defendants were negligent in all actions against JWG and 15 West Spring Street not following the law and
the Rules of the HAMP program.

The defendants had a Fiduciary Duty to JWG, the public and 15 West Spring Street.

Count 10
Constructive Fraud,,18 USC § 1341
Frauds and Swindles 18 USC § 1343 Fraud by Wire, 18 USC §1344
Bank Fraud 18 USC §1346 Honest Services 18 USC § 1348 Securities and Commodities fraud

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

The defendants were deceptive of material misrepresentations of past and existing facts and remained silent
when a duty to speak existed.

That in 2014 OCWEN in a consent ORDER was commanded to cease and desist all criminal activity and in
return would not be pressed with criminal charges. OCWEN did not follow the Consent Order and continued
illegal foreclosures.

On or around April 20, 2017 the CFPB filed a new suit in the USDC of Southern District of Florida West Palm
Beach Division Case No. 937-cv- 80495 which claims it has not stopped their criminal activities.

The CFPB has on its site:

COMPLAINTS:

Option One Showing 27,176 matches out of 1,744,719 total complaints

American Home Mortgage Servicing Showing 18,754 matches out of 1,744,719 total complaints
PHH Mortgage Showing 3,261 matches out of 1,744,719 total complaints
OCWEN Mortgage Showing 3 0,219 matches out of 1,744,719 total complaints
Wells Fargo Bank Showing 80,785 matches out of 1,744,719 total complaints
Bank of America Showing 119,746 matches out of 1,744,719 total complaints

29
The CFPB further States:
Mortgage Servicer’s Widespread Errors, Shortcuts, and Runarounds Cost Borrowers Money, Homes

APR 20, 2017

WASHINGTON, D.C. — The Consumer Financial Protection Bureau (CFPB) today sued one of the
country’s largest nonbank mortgage loan servicers, Ocwen Financial Corporation, and its subsidiaries for
failing borrowers at every stage of the mortgage servicing process. The Bureau alleges that Ocwen’s years of
widespread errors, shortcuts, and runarounds cost some borrowers money and others their homes. Ocwen allegedly
botched basic functions like sending accurate monthly statements, properly crediting payments, and handling taxes
and insurance. Allegedly, Ocwen also illegally foreclosed on struggling borrowers, ignored customer complaints,
and sold off the servicing rights to loans without fully disclosing the mistakes it made in borrowers’ records. The
Florida Attorney General took a similar action against Ocwen today in a separate lawsuit. Many state financial
regulators are also independently issuing cease-and-desist and license revocation orders against Ocwen for escrow
management and licensing issues today.

"Ocwen has repeatedly made mistakes and taken shortcuts at every stage of the mortgage servicing process,
costing some consumers money and others their homes," said CFPB Director Richard Cordray. "Borrowers have
no say over who services their mortgage, so the Bureau will remain vigilant to ensure they get fair treatment."

Ocwen, headquartered in West Palm Beach, Fla., is one of the nation’s largest nonbank mortgage servicers. As of
Dec. 31, 2016, Ocwen serviced almost 1.4 million loans with an aggregate unpaid principal balance of $209
billion. It services loans for borrowers in all 50 states and the District of Columbia. A mortgage servicer collects
payments from the mortgage borrower and forwards those payments to the owner of the loan. It handles customer
service, collections, loan modifications, and foreclosures. Ocwen specializes in servicing subprime or delinquent
loans.

The CFPB uncovered substantial evidence that Ocwen has engaged in significant and systemic misconduct at
nearly every stage of the mortgage servicing process. The CFPB is charged with enforcing the Dodd-Frank Wall
Street Reform and Consumer Protection Act, which protects consumers from unfair, deceptive, or abusive acts or
practices, and other federal consumer financial laws. In addition, the Bureau adopted common-sense rules for the
mortgage servicing market that first took effect in January 2014. The CFPB’s mortgage servicing rules require that
servicers promptly credit payments and correct errors on request. The rules also include strong protections for
struggling homeowners, including those facing foreclosure. In its lawsuit, the CFPB alleges that Ocwen:

● Serviced loans using error-riddled information: Ocwen uses a proprietary system called REALServicing
to process and apply borrower payments, communicate payment information to borrowers, and maintain
loan balance information. Ocwen allegedly loaded inaccurate and incomplete information into its
REALServicing system. And even when data was accurate, REALServicing generated errors because of
system failures and deficient programming. To manage this risk, Ocwen tried manual workarounds, but
they often failed to correct inaccuracies and produced still more errors. Ocwen then used this faulty
information to service borrowers’ loans. In 2014, Ocwen’s head of servicing described its system as
“ridiculous” and a “train wreck.”

● Illegally foreclosed on homeowners: Ocwen has long touted its ability to service and modify loans for
troubled borrowers. But allegedly, Ocwen has failed to deliver required foreclosure protections. As a
result, the Bureau alleges that Ocwen has wrongfully initiated foreclosure proceedings on at least 1,000
people, and has wrongfully held foreclosure sales. Among other illegal practices, Ocwen has initiated the
foreclosure process before completing a review of borrowers’ loss mitigation applications. In other

30
 instances, Ocwen has asked borrowers to submit additional information within 30 days, but foreclosed on
the borrowers before the deadline. Ocwen has also foreclosed on borrowers who were fulfilling their
obligations under a loss mitigation agreement.

● Failed to credit borrowers’ payments: Ocwen has allegedly failed to appropriately credit payments made
by numerous borrowers. Ocwen has also failed to send borrowers accurate periodic statements detailing
the amount due, how payments were applied, total payments received, and other information. Ocwen has
also failed to correct billing and payment errors.

● Botched escrow accounts: Ocwen manages escrow accounts for over 75 percent of the loans it services.
Ocwen has allegedly botched basic tasks in managing these borrower accounts. Because of system
breakdowns and an over-reliance on manually entering information, Ocwen has allegedly failed to
conduct escrow analyses and sent some borrowers’ escrow statements late or not at all. Ocwen also
allegedly failed to properly account for and apply payments by borrowers to address escrow shortages,
such as changes in the account when property taxes go up. One result of this failure has been that some
borrowers have paid inaccurate amounts.

● Mishandled hazard insurance: If a servicer administers an escrow account for a borrower, a servicer must
make timely insurance and/or tax payments on behalf of the borrower. Ocwen, however, has allegedly
failed to make timely insurance payments to pay for borrowers’ home insurance premiums. Ocwen’s
failures led to the lapse of homeowners’ insurance coverage for more than 10,000 borrowers. Some
borrowers were pushed into force-placed insurance.

● Bungled borrowers’ private mortgage insurance: Ocwen allegedly failed to cancel borrowers’ private
mortgage insurance, or PMI, in a timely way, causing consumers to overpay. Generally, borrowers must
purchase PMI when they obtain a mortgage with a down payment of less than 20 percent, or when they
refinance their mortgage with less than 20 percent equity in their property. Servicers must end a
borrower’s requirement to pay PMI when the principal balance of the mortgage reaches 78 percent of the
property’s original value. Since 2014, Ocwen has failed to end borrowers’ PMI on time after learning
information in its REALServicing system was unreliable or missing altogether. Ocwen ultimately
overcharged borrowers about $1.2 million for PMI premiums, and refunded this money only after the
fact.

● Deceptively signed up and charged borrowers for add-on products: When servicing borrowers’ mortgage
loans, Ocwen allegedly enrolled some consumers in add-on products through deceptive solicitations and
without their consent. Ocwen then billed and collected payments from these consumers.

● Failed to assist heirs seeking foreclosure alternatives: Ocwen allegedly mishandled accounts for
successors-in-interest, or heirs, to a deceased borrower. These consumers included widows, children, and
other relatives. As a result, Ocwen failed to properly recognize individuals as heirs, and thereby denied
assistance to help avoid foreclosure. In some instances, Ocwen foreclosed on individuals who may have
been eligible to save these homes through a loan modification or other loss mitigation option.

● Failed to adequately investigate and respond to borrower complaints: If an error is made in the servicing
of a mortgage loan, a servicer must generally either correct the error identified by the borrower, called a
notice of error, or investigate the alleged error. Since 2014, Ocwen has allegedly routinely failed to
properly acknowledge and investigate complaints, or make necessary corrections. Ocwen changed its
policy in April 2015 to address the difficulty its call center had in recognizing and escalating complaints,
but these changes fell short. Under its new policy, borrowers still have to complain at least five times in
nine days before Ocwen automatically escalates their complaint to be resolved. Since April 2015, Ocwen
has received more than 580,000 notices of error and complaints from more than 300,000 different
borrowers.

31
 ● Failed to provide complete and accurate loan information to new servicers: Ocwen has allegedly failed to
include complete and accurate borrower information when it sold its rights to service thousands of loans
to new mortgage servicers. This has hampered the new servicers’ efforts to comply with laws and
investor guidelines.

The Bureau also alleges that Ocwen has failed to remediate borrowers for the harm it has caused, including the
problems it has created for struggling borrowers who were in default on their loans or who had filed for
bankruptcy. For these groups of borrowers, Ocwen’s servicing errors have been particularly costly.

Through its complaint, filed in federal district court for the Southern District of Florida, the CFPB seeks a court
order requiring Ocwen to follow mortgage servicing law, provide relief for consumers, and pay penalties. The
complaint is not a finding or ruling that the defendants have actually violated the law.
The lawsuit is available at:
https://files.consumerfinance.gov/f/documents/20170420_cfpb_Ocwen-Complaint.pdf

The CFPB has ignored the criminal activity of OCWEN / PHH Mortgage. That not only should a civil suit but a
criminal investigation from what the insiders have stated should be immediately filed

The defendant’s actions were Arbitrary and Capricious absent a rational connection between the facts found and
the choice’s made, made choices that were not in accordance with the law.

Count 11
Civil Conspiracy, Theft by deceptive taking Illegal Conversion of Real Estate

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

The Collusion of the Defendants to prevent JWG from the chance at the HAMP refinance of the loan for her
company, was done with malicious, violent, oppressive, fraudulent, wanton, or grossly reckless intentions.

Defendants Civil Conspiracy to Commit Tortious Interference with Contractual Relations abuse of process,
intentional infliction of emotional distress,

Civil conspiracy to commit injurious falsehood by advertising 15 West Spring St in the newspaper for a
Foreclosure Sale that violated the Law and Rules of HAMP. That Wells Fargo Bank has an alleged loan that
Wells Fargo Bank denies.

That the foreclosure now leaves a cloud on the title for life.. One that was illegally, fraudulently offered for Sale
by BWW Law Group, MCW, PARKER, SIMON & KOKOLIS LLC, AND AKA Surety Trustees, and
OCWEN. That the title is riddled with defects from Judges, lawyers and Banks.

205. That the apparent Conversion would be for Personal Financial Gain of lawyers, Servicers that had no Bank
Authority to sell such property, and to COVER UP criminal activity as established in The 2013 – 2014 Consent
Order by OCWEN where it is called to Cease and Desist from criminal fraudulent violations by the CFPB.

32
That all knowledgeable ACTS and ACTIONS by the Defendants and others were for deceptive, malicious acts
for illegal taking of Real Estate.

Defendants were in collusion of civil conspiracy to intentionally inflict emotional distress.

Count 12
18 U.S. Code § 666 – Theft or bribery concerning programs receiving Federal funds

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

The clients of OCWEN Bank of America aka LaSalle Bank, Wells Fargo all received by appearance monies in
bailouts, while paying in the Billions to the DOJ for executives to not go to jail.

That indirectly or directly through clients have received Federal Funds by all appearances.

That payday’s to Lawyers are ensured prior to anyone else being paid in the scheme and 33 artifice of fraud on
homeowners as Lawyers and as Trustees

Count 13
Sarbanes – Oxley Act

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

That OCWEN and their lawyers had a responsibility to act in a timely manner that information that Plaintiff has
requested since 2012 Plaintiff has still to this date not received.

The “Corporate and Auditing Accountability, Responsibility, and Transparency Act: that set new United States
Federal Law that expanded requirements for all U.S. Public company boards, management and public
accounting firms. There are also a number of provisions of the act that also apply to privately held companies.

That JWG believes under this act the accounting of OCWEN, Wells Fargo, Bank of America and others in this
Complaint failed.

That in or around the Trust Assignment Fraud Letter to SEC , Posted on July 14, 2010 Which you can see
nothing has changed since her suit was won. That the allegations in this suit and the facts are no different than
what was happening in 2010 –

1. OCWEN was Ordered to Cease and Desist in the 2014 Consent Order between OCWEN and the CFPB
and 48 other States
2. CFPB in a new Suit against OCWEN alleges the same criminal behavior of FRAUD - WHEN DO THE
JUDGES STAND UP AND SPEAK OUT FOR THE AMERICAN CITIZEN? STOPPING THE
ILLEGAL ACTS AND ACTIONS OF THE SERVICERS, THE BANKS AND THE LAWYERS
3. The Banks were given Bail outs, the Servicers the opportunity to follow the law all have instead
continued the criminal activity, Frauds through today.

33
 This is not the complete letter but you can see that Plaintiff had the same Robo-Signers on documents
against Spring St. and Trust is listed as a “VOID” trust under Whistleblower Lynn E. Szymoniak Esq

April 15, 2010 LYNN E. SZYMONIAK, ESQ. in a letter to Mary L. Schapiro, Chairman
Robert S. Khuzami, Director, Division of Enforcement / Securities & Exchange Commission
100 F Street, NE Washington, D.C. 20549 enforcement@sec.gov

Re: Mortgage-Backed Trusts Missing Critical Documents

Dear Chairman Schapiro and Director Khuzami:

This is a report of suspected fraud involving mortgage-back securities. Certain mortgage

backed trusts have been using forged and fraudulent mortgage assignments in foreclosure
actions in Florida, and throughout the United States. These assignments are most often produced
by employees of Lender Processing Services, Inc., (“LPS”), a mortgage default management
company located in Jacksonville, FL. LPS produced several million Mortgage Assignments,
using its own employees to sign as if they were officers of the original lenders The fraud
includes:

● Mortgage assignments with forged signatures of the individuals signing on behalf of the
grantors, and forged signatures of the witnesses and the notaries;

● Mortgage assignments with signatures of individuals signing as corporate officers for

corporations that never employed them in any such capacity;

● Mortgage assignments prepared and signed by individuals as corporate officers of

mortgage companies that had been dissolved by bankruptcy years prior to the Assignment;

● Mortgage assignments prepared with purported effective dates unrelated to the date of any
actual or attempted transfer (and in the case of trusts, years after the closing date of the
trusts);

● Mortgage assignments prepared on behalf of grantors who had never themselves acquired
ownership of the mortgages and notes by a valid transfer, including numerous such
assignments where the grantor was identified as “Bogus Assignee for Intervening
Assignments;” and

● Mortgage assignments notarized by notaries who never witnessed the signatures that they
notarized. Trust officers used these fraudulent mortgage assignments to conceal the fact
that the trusts are missing critical documents, namely, the mortgage assignments that were
supposed to have been delivered to the trusts at the inception of the trust.

These trusts suffered the following economic harm:

The Trusts paid substantial fees to the Trustees for Document Custodial Services including fees
for obtaining and retaining a Mortgage Assignment for each of the properties in the trust. The
Assignment was supposed to have been “in recordable form” – that is, legally sufficient to allow
the Trustee to foreclose in the event of default. These services were never provided. In each

34
trust identified herein, many if not all of the Mortgage Assignments were never obtained, or
were obtained and lost.

Because the Assignments were not obtained and/or retained, the Trusts incurred significant
additional expenses:

i) each Trust paid, and will continue to pay, hundreds of thousands of dollars in fees to mortgage
servicers, document preparation companies and law firms to prepare and record “Replacement
Assignments” including Assignments that were prepared with false information regarding dates
and signers;

ii) each Trust paid, and will continue to pay, hundreds of thousands of dollars in fees to the
default management company and to law firms retained by the mortgage servicing companies
and/or default management company (usually, Lender Processing Services) to litigate the issue
of the standing of the trust to file the foreclosure action because the Assignment to the Trust that
established standing was missing or never obtained. 35 In many cases, because the Assignments
were not obtained and/or retained, the Trust could not successfully foreclose when loans in the
Trust defaulted.

In many cases, where the Trust has successfully foreclosed, it has no legal right to do so and the
Trust has been or will be exposed to claims for wrongful foreclosure by former homeowners
and claims of fraud by subsequent purchasers. In many cases, where mortgage servicing
companies or law firms representing the Trust attempted to collect amounts due from defaulting
homeowners of properties in the trust, the debt collection activities violated the Federal Fair
Debt Collection Practices Act because the Trust had no right to pursue collection or foreclosure
where it lacked a valid Assignment.

In many cases, particularly where the loan originator is a mortgage company that is no longer in
existence, it may not be possible to ever obtain a valid Assignment to the Trust. Long after the
Trustees and Servicers became aware that critical documents, the Assignments, were missing,
the Trustees and Servicers failed to disclose that information to the Certificate Holders and to
the SEC.

Attached hereto are examples of fraudulent Assignments. Many (over 100,000) of these are
signed by Linda Green. From an examination of the signatures, it is apparent that many
different employees signed the name Linda Green. Job Titles attributed to Green include
the following:

• Vice President, Loan Documentation, Wells Fargo Bank, N.A., successor by merger to Wells
Fargo Home Mortgage, Inc.;

• Vice President, Mortgage Electronic Registration Systems, Inc., as nominee for American Home
Mortgage Acceptance, Inc.;

• Vice President, American Home Mortgage Servicing as successor-in interest to Option One
Mortgage Corporation; • Vice President, Mortgage Electronic Registration Systems, Inc., as
nominee for American Brokers Conduit;

35
 • Vice President & Asst. Secretary, American Home Mortgage Servicing, Inc., as servicer for
Ameriquest Mortgage Corporation; • Vice President, Option One Mortgage Corporation;

• Vice President, Mortgage Electronic Registration Systems, Inc., as nominee for HLB Mortgage;

• Vice President, American Home Mortgage Servicing, Inc.;

• Vice President, Mortgage Electronic Registration Systems, Inc., as nominee for Family Lending
Services, Inc.;

• Vice President, American Home Mortgage Servicing, Inc. as successor-in-interest to Option One
Mortgage Corporation;

• Vice President, Argent Mortgage Company, LLC by Citi Residential Lending Inc.,
attorney-in-fact; • Vice President, Sand Canyon Corporation f/k/a Option One Mortgage
Corporation;

• Vice President, Amtrust Funsing (sic) Services, Inc., by American Home Mortgage Servicing, Inc.
as Attorney-in fact; and

• Vice President, Seattle Mortgage Company.

Other LPS employees similarly used many different job titles and claimed to be officers of
many different mortgage companies on Mortgage Assignments. Korell Harp and Tywanna
Thomas used a variety of conflicting job titles on Assignments of Mortgages in 2008 and 2009,
holding themselves out to be officers of numerous different banks and mortgage-related entities,
often using numerous conflicting titles in the same week.

Titles attributed to Korell Harp include Vice President of American Home Mortgage
Servicing, Inc. as successor-in-interest to Option One Mortgage Corporation; Vice President of
American Brokers Conduit; Vice President of Argent Mortgage Company, LLC; and Vice
President of Mortgage Electronic Registration Systems, Inc. Titles attributed to Tywanna
Thomas include Assistant Vice President of Option One Mortgage Corporation, Assistant
Vice President of American Home Mortgage Servicing, Assistant Vice President of Mortgage
Electronic Registration Systems, Assistant vice President of Argent Mortgage Company, LLC,
Assistant Vice President of Deutsche Bank National Trust Company, Assistant Vice President of
Sand Canyon Corporation and Assistant Vice President of American Home Mortgage
Acceptance.

The above letter further points out and shows that this criminal activity has been going on
for a long time. That Banks, the Servicers and the Lawyers have been given chance after
chance to clean up their act, but find it cheaper to pay off the Government, Government
agencies who by all appearance take the money and pocket it for personal use.

Count 14
Title 26, U.S. Code. The Internal Revenue Code (IRC)
is the body of law that codifies all federal tax laws, including income, estate, gift, excise, alcohol, tobacco,
and employment taxes. U.S. tax laws began to be codified in 1874, but there was no central,
comprehensive source for them at that time

Material false claims under SEC enforced 1122 AB

36
26 U.S.C. § Section 61 A (1), 26 U.S.C. § Section 108 (i), 26 U.S.C. § Section 451, 26 U.S.C. § Section 1033,
U.S.C Section 1.751, CFR 1.752, SEC Rule 1122 AB
Regs. Sec. 1.707-3(b)(2) Disguised sales of property to partnership

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint.

CAUSES:

[1] Disguised Sale Rule under the IRC title 26 used in manipulative method and means for ill gotten gains

[2] Violations of the Federal rules on partnerships and pass through taxable income in a constructive liquidation

● where denying the pass through investor a proration distribution credited as a earn out over a set
term
● The mortgagor is a pass through for the amounts booked at settlement and not disbursement
● Resulting in the attribution of ordinary and causal to compelled abandonment under tax payer
form 1099 A

[3] Deceptive Practices that succeed by failing to properly disclose the correct character of the subject matter
transaction.

● Whereas parties are foreclosing on the good faith understanding of default by mortgagor in
default
● Wherefore the good faith understanding is lost under the doctrine of extinguishment
● Where by the instruments are cancelled for ORDINARY INCOME and title transferred under
the the instruments TRANSFER RIGHTS IN THE PROPERTY
● TRANSFER IS AFFIRMED at the origination the TRUSTEE sale whereby GRANTEE paid to
TRUSTEE CONSIDERATION
● The Consideration is for a credit back from date of the reversion [fictitious foreclosure ]
backdating ot the date of the orginal loans settlement

[4] For material violations by way of willful avoidance of a pass through right and entitlement to disclosures
mandated by assignment Pro Tanto

● Including life estate contracted by irrevocable transfers of the title for which the mortgagor is
TRANSFEROR under a QUALIFIED INVESTMENT
● Whereas the Qualified Property is by Transferors holding the reversion upon all properties
having been argued and amortized to a basis in asset of zero
● A sale for assets held in a constructive liquidation at zero is taxable to the attribution as 1099 A
recipient treated as ordinary at time of disposition .

[5] Material false claims under SEC enforced 1122 AB

● Government actor withheld as indispensable parties under the vendors understanding holding in
1122 AB
● Material false claims made under the FDCPA Federal debt collections practices act used for
assessing consumers in conventional foreclosures
● Using the state in the role of tax gather for the IRS to satisfy state budget liabilities

37
[6] Public sector entering the private side and violating the the taking provisions and "no capitation" guarantees
afforded on the fifth and fourteenth amendments

● DUE PROCESS denied where the trier of fact is a beneficial interest under a NOMINEE
● Whereas MERS conceals the government obligations owed to its depositors as Qualified
Investments
● Wherefore the title secured Qualified deposits levered against the benefits payable to its state
Municipal Employees Retirement System.

[7] Violations of GAAP and Non Recognition Rules for final sale accounting rule barring a subsequent recovery
on a default using the accrual method of accounting.

● Whereas the consumer is a Mortgagor for a debt converted into a reversionary interest as equity
and
● Lender , lender's successors and successor of lender are the seller for title transferred into trust to
a third party as trustee under the installment method.
● In violation of IRC Title 26 by tax matter partnerships to satisfy third party antecedent debt
assigned to mortgagors prorated shares of third party commercial obligations owed as
"receivables to offshore financial institutions.

When OCWEN Fraudulently did the 1099 on JWG, and then sold the loan to NEWREZ LLC it violated
§ 1.707-3 Disguised sales of property to partnership; general rules.

Count 15
26 CFR § 1.707-3 - Disguised sales of property to partnership; general rules.
A disguised sale Regs. Sec. 1.707-3(b)(2)
JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint.

The partnership has incurred or is obligated to incur debt to acquire the money or other consideration necessary
to permit it to make the transfer, taking into account the likelihood that the partnership will be able to incur the
debt (considering such factors as whether any person has agreed to guarantee or otherwise assume personal
responsibility for the debt);

The partnership holds money or other liquid assets, beyond the reasonable needs of the business, which are
expected to be available to make the transfer (taking into account the income that will be earned from those
assets);

Partnership distributions, partnership allocations, or control of partnership operations is designed to effect an

exchange of the burdens and benefits of property ownership;

The transfer of money or other consideration by the partnership to the partner is disproportionately large in
relationship to the partner's general and continuing interest in partnership profits;or

The partner has no obligation to return or repay the money or other consideration to the partnership or has such
an obligation but it is likely to become due at such a distant point in the future that the present value of that

38
obligation is small in relation to the amount of money or other consideration transferred by the partnership to the
partner.

Caution: Note that the disguised sale regulations apply to deemed sales from the partner to the partnership, from
the partnership to a partner, and among the partners.

KNOW A MORTGAGE FROM A DISGUISED SALE

The partnership has incurred or is obligated to incur debt to acquire the money or other consideration
necessary to permit it to make the transfer, taking into account the likelihood that the partnership will be
able to incur the debt (considering such factors as whether any person has agreed to guarantee or
otherwise assume personal responsibility for the debt);

The partnership holds money or other liquid assets, beyond the reasonable needs of the business, which
are expected to be available to make the transfer (taking into account the income that will be earned
from those assets);

Partnership distributions, partnership allocations, or control of partnership operations is designed to

effect an exchange of the burdens and benefits of property ownership;

The transfer of money or other consideration by the partnership to the partner is disproportionately large
in relationship to the partner's general and continuing interest in partnership profits;or

The partner has no obligation to return or repay the money or other consideration to the partnership or
has such an obligation but it is likely to become due at such a distant point in the future that the present
value of that obligation is small in relation to the amount of money or other consideration transferred by
the partnership to the partner.

Caution: Note that the disguised sale regulations apply to deemed sales from the partner to the partnership, from
the partnership to a partner, and among the partners.

The following facts and circumstances may prove the existence of a disguised sale (Regs. Sec. 1.707-3(b)(2)):

● The timing and amount of a subsequent transfer are determinable with reasonable certainty at the time
of the earlier transfer;
● The transferor has a legally enforceable right to the subsequent transfer;
● The partner's right to receive the transfer of money or other consideration is secured in any manner
(taking into account the period during which it is secured);
● Any person has made or is legally obligated to make contributions to the partnership to permit the
partnership to make the transfer of money or other consideration;
● Any person has loaned or has agreed to loan the partnership the money or other consideration necessary
to permit it to make the transfers, taking into account whether any such lending obligation is subject to
contingencies related to the results of partnership operations;

Count 16
18 U.S. Code § 1033 Insurance Fraud
False Advertising - FTC Act, Lanham Act and Dodd-Frank Wall Street Reform, Consumer Protection
Act
US Constitution Fifth & 14th Amendment deprived of life, liberty or property without due process of law

39
 Theft by Deceptive taking - 18 USC §4, aka the Misprision Of Felony Statute,

The defendants have violated JWG United States Constitutional rights to Due process and are trying to deprive
her of her home of 32 years with falsified documents and a Scheme that is for personal financial gain. That this
is Theft by deceptive taking by all.

That not disclosing the issues with the title to the public violates the Consumer Protection Act and the
Professional Code of Conduct.
A Pro Se Litigant

The law is very clear a pro se litigant is to be given equal treatment if not special treatment, especially in a case
where the intervening Person is a lawyer and has the financial ability to bring in as many powerful unscrupulous
lawyers to defend her criminal actions.

"Pro se plaintiffs are often unfamiliar with the formalities of pleading requirements. Recognizing this, the
Supreme Court has instructed the district courts to construe pro se complaints liberally and to apply a more
flexible standard in determining the sufficiency of a pro se complaint than they would in reviewing a pleading
submitted by counsel. See e.g., Hughes v. Rowe, 449 U.S. 5, 9-10, 101 S.Ct. 173, 175-76, 66 L.Ed.2d 163 (1980)
(per curiam); Haines v. Kerner, 404 U.S. 519, 520-21, 92 S.Ct. 594, 595-96, 30 L.Ed.2d 652 (1972) (per
curiam); see also Elliott v. Bronson, 872 F.2d 20, 21 (2d Cir.1989) (per curiam). In order to justify the dismissal
of a pro se complaint, it must be " 'beyond doubt that the plaintiff can prove no set of facts in support of his
claim which would entitle him to relief.' " Haines v. Kerner, 404 U.S. at 521, 92 S.Ct. at 594 (quoting Conley v.
Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)).
“Fairness of course requires an absence of actual bias in the trial of cases. But our system of law has always
endeavored to prevent even the probability of unfairness. “In re Murchinson, 349 U.S. 133, 136 (1955)”
No officer of the law may set that law at defiance with impunity. All the officers of the government from the
highest to the lowest, are creatures of the law, and are bound to obey it.” Butz v. Economou, 98 S.Ct. 2894
(1978); United States v. Lee, 106 U.S. at 220, 1 S.Ct. at 261 (1882)” “Further it is the obligation of every Judge
to honor, abide by, and uphold not only the Constitution and laws of the State, but they are bound by the laws
and Constitution of the United States as well.” State courts, like federal courts, have a constitutional obligation
to safeguard personal liberties and to uphold federal law.” Stone v Powell, 428 US 465, 483 n 35, 96 S. Ct 3037,
49 L Ed. 2d 1067 (1976)”
PRAYER FOR RELIEF
WHEREFORE, JWG requests that this Court:

1. Return of 15 W. Spring St., Alexandria, VA 22301 to Janice Wolk Grenadier at 15 West Spring Street,
Alexandria Virginia 22301 and any other relief this courts fills acceptable
2. Criminal Investigation into the: CFPB, SEC, FTC, and or DOJ and FBI investigation of criminal acts
involving defendants in this matter or further order of the Court,
3. Award JWG compensatory, punitive, xplorie damages against defendants jointly of $39 million dollars
to send a strong message of deterrence for this type of attorney / trustee / banks / servicers behavior.
4. Award JWG reasonable attorney fees and costs if an attorney is appointed by the court or will take case
on contingency.

40
 5. Grant to JWG such other and further relief as The Honorable Court may find just and proper under the
circumstances, including but not limited to appropriate injunctive relief

DATE: June 20, 2022

Respectfully Submitted,
_________________________________________
Janice Wolk Grenadier
15 W. Spring Street
Alexandria, Virginia 22301
202-368-7178
jwgrenadier@gmail.com

CERTIFICATION: I declare under penalty and perjury: That No attorney has prepared or assisted in
the preparation of this document. Janice Wolk Grenadier - Name of Pro Se Party.
____________________________________________
Janice Wolk Grenadier,
June 20, 2022

Certificate of Service

I certify that on or around June 20, 2022 a copy of this was emailed, or hand delivered or sent
through the USPS is placed in a postage-paid envelope addressed to the USDC Florida
Paul G. Rogers Federal Building and U.S. Courthouse
701 Clematis Street, Room 202
West Palm Beach, FL 33401
(561) 803-3400

defendant's attorney, at the address stated below:

Consumer Financial Protection Bureau: Represented by: Jean Marie Heale

Email: jean.healey@cfpb.gov Jack Douglas Wilson Email:
Adam Harris Cohen Email: doug.wilson@cfpb.gov
adam.cohen@cfpb.gov James Joseph Savage Email:
Amanda Christine Roberson Email: james.savage@cfpb.gov
amanda.roberson@cfpb.gov Jan Edwards Singelmann Email:
Atur Ravi Desai Email: atur.desai@cfpb.gov jan.singelmann@cfpb.gov
Erin Mary Kelly Email: erin.kelly@cfpb.gov Lawrence DeMille-Wagman Email:
Gregory Ryan Nodler Email: lawrence.wagman@cfpb.gov
Greg.Nodler@CFPB.gov Michael Posner Email:
michael.posner@cfpb.gov

41
Shirley T. Chiu Email: shirley.chiu@cfpb.gov Tianna Elise Baez Email:
Stephanie C. Brenowitz Email: tianna.baez@cfpb.gov
stephanie.brenowitz@cfpb.gov

Consol Plaintiff: Office of the Attorney General State of Florida, Department of Legal Affairs
Blaine H Winship Email: Scott Ray Fransen Email:
Blaine.winship@myfloridalegal.com scott.fransen@flofr.com
Jennifer Hayes Pinder Email: Catalina E Azuero Email:
jennifer.pinder@myfloridalegal.com CAzuero@goodwinlaw.com
Sasha Funk Granai
Email:Sasha.Granai@myfloridalegal.com

Consol Plaintiff: Office of Financial Regulation State of Florida, Division of Consumer Finance
Jennifer Hayes Pinder, Sasha Funk Granai, Scott Ray Fransen, Catalina E Azuero (See above for
address)
Joaquin Alvarez Email: joaquin.alvarez@flofr.com

Intervenor Plaintiff: Robynne Fauley 09/2018, 12125 SE Laughing Water, Sandy, OR 97055 -
PRO SE
Intervenor Plaintiff: Denise Subramaniam 9/20/18, 13865 SW Walker Road, Beaverton, OR
97005 - PRO SE

DEFENDANTS: OCWEN Financial Corporation (a Florida corporation), OCWEN Loan

Servicing, LLC ( a Delaware Limited Liability Company), OCWEN Mortgage Servicing Inc. (
a U.S. Virgin Islands Corporation)
Bridget Ann Berry Email: BerryB@gtlaw.com Laura S. Craven Email:
Matthew P. Previn Email: LCraven@goodwinlaw.com
mprevin@buckleysandler.com Laura Stoll Email: lstoll@goodwinlaw.com
Sabrina M. Rose-Smith Email: Matthew L. Riffee Email:
srosesmith@goodwinlaw.com MRiffee@goodwinlaw.com
Thomas M. Hefferon Email: Matthew S. Sheldon Email:
thefferon@goodwinlaw.com msheldon@goodwinlaw.com
Amanda B. Protess Email: Tierney E. Smith Email:
AProtess@goodwinlaw.com TierneySmith@goodwinlaw.com
Andrew Stuart Wein Email: W. Kyle Tayman Email:
weina@gtlaw.com KTayman@goodwinlaw.com
Catalina E Azuero Email:
CAzuero@goodwinlaw.com

PHH Mortgage Corporation

Andrew Stuart Wein, Bridget Ann Berry, Catalina E Azuero, (See above for address)

42
June 20, 2022
_______________________________________
Janice Wolk Grenadier
Pro Se Intervener

43