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EXHIBIT 77
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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
----------- ----------- ----------- ----- X
Mortgage Resolution Servicing, LLC, 1st
Fidelity Loan Servicing, LLC, and S&A Capital
Partners, Inc.,

Plaintiffs, 1:15-cv-00293 (LTS) (JCF)

-against-

JPMorgan Chase Bank, N.A., Chase Home

Finance LLC, and JPMorgan Chase & Co.,

Defendants.
---------- - ----------- ----------- ----- X

DECLARATION OF LAURENCE SCHNEIDER

LAURENCE SCHNEIDER, pursuant to 28 U.S.C. § 1746, declares the following

under penalty of perjury:

1. I am the President and shareholder of S&A Capital Partners, Inc. ("S&A"),

the President and managing member of 1st Fidelity Loan Servicing, LLC ("1st Fidelity"), and the

President and managing member of Mortgage Resolution Servicing, LLC ("MRS") (collectively,

"Plaintiffs" or the "Schneider Entities"). I am a real estate specialist and I work and reside in Boca

Raton, Florida.

2. I submit this declaration in support of Plaintiffs' Motion for a Temporary

Restraining Order and a Preliminary Injunction.

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November 2008 Data Tape and lacked information that Exhibit A was required to contain. In fact,

the lack of information on this February 25, 2009 schedule made it impossible for me to cross-

reference it with the November 2008 Data Tape and verify that the mortgage loans supposedly

sold to MRS according to this schedule were on the November 2008 Data Tape.

C. Problems Plaintiffs Have Faced Because of Chase's Misconduct

13. Because Chase refused to produce original loan files and a myriad of other

documents about each of the loans sold to the Schneider Entities (documents Chase was required

to produce to the Schneider Entities before this lawsuit was filed), the Schneider Entities have

faced obstacle after obstacle to building up their business and working out payment plans with

their borrowers. Since MRS signed the MLP A with Chase, Chase engaged in a protracted pattern

of misconduct in which Chase would do the following:

(a) make false representations to borrowers that Chase or its collection agency

was the authorized servicer or owner of the loans and that borrowers should make payments

directly to Chase or the collection agency, even though Chase had previously sold the loans at

issue to the Schneider Entities;

(b) collect, and refuse to remit, mortgage and insurance payments related to

loans it sold to the Schneider Entities, whether the collection was done in-house or by

authorized collection agencies;

(c) approve short sales on properties subject to loans that Chase sold to the

Schneider Entities;

(d) make false representations to enforcement agencies that the Schneider

Entities were responsible for Chase's servicing violations;

(e) make false representation to certain borrowers that their loans had been

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transferred to one of the Schneider Entities, prompting those borrowers to file complaints with

various state and federal agencies leading to loss of reputation and impeding the ability of the

Schneider Entities to generate new business;

(f) mail debt forgiveness letters (the "Forgiveness Letters") to thousands of

borrowers, including borrowers whose loans Chase had previously sold to the Schneider

Entities;

(g) wrongfully release and discharge liens, through third-party agents such as

Nationwide Title Clearing, Inc. ("NTC") and PiersonPatterson LLP ("PiersonPatterson"), on

properties that served as collateral for loans Chase had already sold to the Schneider Entities

when these liens were released, which lien releases appear to have been "robo-signed" by

certain Chase employees, and/or their authorized third-party agents, such as NTC and

PiersonPatterson, in that they appear to have been mass-produced and signed by persons

without knowledge of the facts to which their signature attests (a composite of representative

Deeds of Release, Release of Lien, Satisfaction of Mortgage, Discharge of Mortgage, Release

of Mortgage lien releases that occurred after loans had been sold by Chase to the Schneider

Entities is attached hereto as Exhibit 2);

(h) attempt unsuccessfully to restore the Schneider Entities' position on the

loans for which Chase wrongfully released the liens by filing documents that purport to vacate

those lien releases (a composite ofrepresentative Vacation and Rescission documents signed

by Ingrid Whitty, purportedly a Chase Vice-President, is attached hereto as Exhibit 3); and

(i) communicate with the Schneider Entities to get them to sign documents

pertaining to the loans that were purportedly sold by Chase once a borrower would contact

Chase, even though Chase never gave the Schneider Entities any of these documents when the

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loans were initially sold to the Schneider Entities, ostensibly to shift the liability for Chase's

mishandling of these loans to the Schneider Entities.

D. Problems the Schneider Entities Are Still Facing Because of Chase's Actions.

14. If the Schneider Entities could have assurances that the issues that they face

with borrowers would end while this litigation is pending, that would provide me with some

measure of comfort that the Schneider Entities will be able to survive and eventually thrive once

more. However, the Schneider Entities continue to deal with problems with numerous borrowers

on the loans that the Schneider Entities thought they had bought from Chase, but for which loans

they never received the full documentation and ownership rights to the loans.

15. Compounding the problems caused by the issuance of lien releases are

Chase's mailing of wrongful Forgiveness Letters and statements via Chase's representatives that

borrowers no longer owe money to the Schneider Entities or that their loans were "charged off."

One such example is Joseph Davis. Mr. Davis contacted the Schneider Entities in February 2015

after having first contacted Chase, who told him that they sold the loan to the Schneider Entities.

While the Schneider Entities expressed to Mr. Davis that they would be willing to work with him,

they advised him that nothing could be done until and unless Chase prepared and filed an

assignment of the mortgage to MRS. MRS repeatedly contacted Chase to get the assignment, to

no avail. However, in October 2015, Mr. Davis infonned MRS that Chase provided him with a

copy of the recorded assignment of mortgage, even though no such recorded assignment was sent

to the Schneider Entities. Chase never sent this documentation directly to the Schneider Entities.

By January 2016, the borrower filed a complaint against the Schneider Entities with the Illinois

and Florida Attorney Generals' Offices. Because Chase refuses to acknowledge which loans it

sold to the Schneider Entities, the Schneider Entities now stand in the unenviable position of

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asked for a further summary of the Schneider Entities' claims and demands, the June 27 th letter

was sent to Chase. In this letter, the Schneider Entities' legal counsel reminded Chase's counsel

that "[t]he scope of harm caused by [Chase's] actions is mushrooming," and further detailed how

Chase's lien releases and attempts "to 'revive' recordings of the liens whose releases [Chase]

recorded" were exposing the Schneider Entities to liability under various laws. A true and correct

copy of this June 27, 2014 letter is attached hereto as Exhibit 14.

Pursuant to 28 U.S.C. §1746, I declare under penalty of perjury that the foregoing

is true and correct.

Dated: Coconut Creek, Florida

June I~ , 2017

&fperso,, ci//v ky')o l,Jf" Laurence Schneider

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EXPIRES May 07 , 2021

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