UNITED STATES OF BANKRUPTCY COURT EASTERN DIVISION OF VIRGINIA ALEXANDRIA DIVISION IN RE: JANICE WOLK GRENADIER Pro Se Debtor / Plaintiff Chapter 13 Case No. 23-10904-KHK v. Case No. Wells Fargo Bank N. A. (WFB) aka CAUSES OF ACTION WELLS FARGO BANK NA. FRAUD a as Trustee for Option OneMortgage Loan Trust 2005-2, MISREPRESENTATION ‘Asset-Backed Cettificates, Series 2005-2 (WFB) REPLEVIN 420 Montgomery Street WIRE FRAUD San Francisco, CA94104 TEMPORARY RESTRAINING ORDER SECURITIES FRAUD BETH BELFIELD (possible) aka THEFT BY DECEPTION TAKING Beth Mayr, Patricia Elizabeth Belfield ILLEGAL CONVERSION OF REAL ESTATE 313 Sunshine Way, Westminster, MD 21157 Jane Doe Defendants How Wells Fargo Bank N.A. in aA “false front” playing Three Card Monty? With MORTGAGE BACK SECURITIES Using the word Bank for credibility The *False Front’ of Computershare aka CTS’aka CTSLinks COMES NOW JWG complains against Defendants and reserves the right to Amend and Add other Defendants and acid to the above and below Causes of Action: 18 USC § 371 Conspiracy 18 USC § 4 Misprision Of Felony Statute, 18 USC § 1341 Frauds and Swindles 18 USC § 1343 Fraud by Wire, 1A Sse front” bling from the Old West. Tous bil fle rots tomake the tou lok more substantial au prosperous than ‘really teas. a game tratitionally associated with con men, in which the dealer shows the player three cards then maves them around ‘awe-down, the player being bie to pick the specified card from among the three. 4" co Wells Fargo Bank Minnesota, N.A., 3062 Old Annapolis Road, Columbia, MD 21045 {(Adatess of principal executive offices) (Zip Code) Registrants telephone number, including area code: (410) 884-2000 >" By: Wells Fargo Bank Minnesota, N.A. as Securiles ‘Administrator By: /s/ Beth Belfield as Assistant Vice President By. Beth Belfield as Assistant Vice President Contact Customer Service - CTSLInk Wells Fargo Bank Minnesota, N.A. ‘Securities Administration Services 7485 New Horizon Way Frederick, MO 21703 Telephone: (901) 815-6600 Fax: (01) 615-666018 USC §1344 Bank Fraud 18 USC 81346 Honest Services 18 USC § 1348 Securities and commodities fraud 18 USC §1349 Attempt and Conspiracy 18 U.S. Code § 241 & 242 Conspiracy/Deprivation against rights 42.U.S. Code § 1983 - Civil action for deprivation of rights Sarbanes - Oxley Act 48 U.S, Code § 668 - Thett or bribery concerning programs receiving Federal funds 18 U.S. Code Subchapter V - DEBT COLLECTION PRACTICES § 1692d -Harassment of abuse § 16826 -False or misleading representations § 1682f - Unfair practices 16829 -Validation of debt § 1682) - Furnishing certain deceptive forms Fair Debt. Collection Act (FDCPA) § 806 Harassment, § 807 False and misleading, § 808 Unfair prac § 809 Valiciation of debts, § 812 Furnishing deceptive forms, et al 31U.S.C. § 3729 Federal False Claims Act Violation of the Consent Order in 2014 with the DOJ and 48 states including Virginia. CFPB has fited new sult USDC Souther District of Florida West Palm Beach Diy Case No. 9:17 ~cv-80. That the Defendants colludediconspired and now have created A defective title A title that is impaired with a lien or other defect. Defective titles are considered unmarketable, so the asset in question cannot be transferred or sold legally. Any encumbrances on a defective title must be cleared before the owner can sell the asset. Now comes Plaintiff/Debtor Janice Wolk Grenadier (JWG) complaint against Defendants and shows that Defendants worked hand in hand to ignore the law, colluded with acts and actions to harm Plaintiff for years for personal professional self dealing financial/personal gains. That the United States Constitution states clearly in the Sth and 14th Amendment that no one shall be “deprived of lite, liberty or property without due process of law.” That Plaintiff has attached Exhibits to show the scheme that appears to have started in 2006 and documents filed against the home in 2009 put the property 15 W. Spring St., Alexandria VA 22301 on the balance sheet of Wells Fargo Bank and Bank of ‘America aka LaSalle Bank. Ayear after the foreclosure OCWEN sent a 1099 A with OCWEN as the owner along with past Insurance Statements that state OCWEN the Server as Owner. The Server can be the owner but, you have to disclose such ownership. ALL Lawyers have stated it was Wells Fargo Bank NA along with OCWEN that Wells Fargo Bank NA is the owner. That this is a “false front" of ownership of the Note/ Loan ‘That American Home Mortgage* destroyed all documents. That the documents used are documents that | filed in the courts by all appearances.Wells Fargo Bank from 2012 has stated it has no ownership of 15 W. Spring St. nor any loans and or interest in any loans with Janice Wolk Grenadier, 15 W. Spring St. and or under Social Security No. Wells Fargo Bank filed this in the City of Alexandria Court and then put itn a Notarized Letter. It should be noted and a concern to all that Wells Fargo Bank N.A, owned Norwest, Computershare and CTSLinks using the name Wells Fargo Bank N.A. giving credibility because the word “Bank” was included. 1. The documents show Beth Belfield involved in signing documents like a “Robo Signer” but these documents did not just affect JWG - they affected the entire Mortgage Back Securities system. The Mortgage Back securities that Spring St. has been claimed to be a part of are: 2. Bank of America aka LaSalle Bank National Association, as Trustee for Structured Asset Investment Loan Trust Mortgage Pass-Through Certificates, Series 2003-BC6 3. Wells Fargo Bank N.A. as Trustee for Structured Asset Investment Loan Trust Mortgage Pass-Through Certificates, Series 2003-BC6 4. WELLS FARGO Bank NATIONAL ASSOCIATION, as Trustee for Option One Mortgage Loan Trust 2005-2, Asset- Backed Certificates, Series 2005-2 ‘aka Computershare and or CTSLINKS and or NORWEST aka Nonwest Equity Partners, Norwest Venture Partners, Norwest Mezzanine Partners used as a “False Front” in the came of 3 Card Monte / Ponzi Scheme. Wells Fargo Bank N.A. The owner of Computershare and CTSLinks stated clearly and has filed in the court they have no information regarding any loan. That further researching the loan in Mers which shows no documentation under JWG SSi#, address, or name for any loan on 15 W. Spring St., Alexandria, VA 22301 the same with Fannie Mae and Freddie Mac ‘The appearance is 3 Card Monte and or a Ponzi Scheme to defraud homeowners and investors by moving their mortgage from one MBS to another - with no real reporting and or oversight by the SEC, the ‘Treasury and or anyother government agency. This is done by all appearances to show a “False Front” on all balance sheets of MBS and the Banks. ‘The Foreclosure was on March 30, 2018 and was then put on the open market which Debtor was never notified of, and no where in the listing does it state the Title is tainted and will stay tainted for life as the Foreclosure was created on Falsified documents with the support and help of the Defendants Lawyers ‘Troutman Pepper Hamilton Sanders. After a Foreclosure your loan should go away - Plaintiff will show that OCWEN/PHH kept such loan on their books and by all appearance and transferred it to NEWRez who also had it on its balance sheet. That the documents attached will show an unbelievable Scheme / Enterprise of the Banks, Servicers and Lawyers for personal financial/professional gain. The Listing states Bank owned property - yet the Bank has declared this a lie. 3Mers, Fannie Mae, Freddie Mac have no information on any alleged loan on 15 W. Spring St., Alexandria, VA 22201, The scheme appears to be headed by Troutman Pepper Hamilton Sanders aka Mays & Valentine who has a conflict as they with others swindled $30,000. From Plaintiff September of 1990 - ta Cover-Up Trust monies stolen from the Sonia Grenadier Trust. This court Case No. 1:93-cr-00302-CMH - You can Read More: For ABUSE AND FRAUDULENT PROCESS by Officers of the Court acting wrongly to take real estate of the Petitioner located at 15 Spring Street, Alexandria, Virginia 22301, under color of law and fraudulent trustee process, to intimidate and cause a wrongful auction. The wrongfully taking of JWG's real estate without right established by AUTHentic DOCUMENTS as REQUIRED BY LAW THEFT BY DECEPTIVE taking: the attorney and trustee acts, under color of law, are intentionally designed to harass and intimidate plaintiff to wrongfully deprive her of the United States ‘Constitutional Rights of Due Process under the Sth and 14th Amendment “deprived of life, liberty or property without due process of law.” by a court and judge with jurisdiction, That Wells Fargo Bank N.A. appears to have owned Computershare linked to CTSLInks which appears to be used as 3 Card Monte with the link of Beth Belfield involved in the Two Different Mortgage Back Securities. The appearance is that Loans are moved around to the Security that has a need. JURISDICTION This Court has Jurisdiction over this case as an adversary proceeding pursuant to 18 U.S.C. § 1343 (Wire Fraud) and § 152(4). (Introducing False Documents onto the Court Record for Financial Gain). Janice Wolk Grenadier has standing to bring this action PARTIES JANICE WOLK GRENADIER (JWG) is today the rightful owner of 15 W. Spring St., Alexandria, VA 22301. That she is the Victim of this court and other courts to protect one of their own. This turned into a "Hate Crime" by the acts and actions with knowledgeable intent to harm by Judges and others. WELLS FARGO NATIONAL ASSOCIATION, as Trustee for Option One Mortgage Loan Trust 2005-2, Asset- Backed Certificates, Series 2005-2 aka ComputerShare and or CTSLINKS and or NORWEST aka Norwest Equity Partners, Norwest Venture Partners, Norwest Mezzanine Partners used as a “False Front” in the came of 3 Card Monte / Ponzi Scheme. Has stated clearly and has filed in the court they have noinformation regarding any loan. That further researched it in Mers which shows no documentation under JWG SSi#, address, or name for any loan on 15 W. Spring St,, Alexandria, VA 22301 BETH BELFIELD (possible) aka Beth Mayr, Patricia Elizabeth Belfield, Patricia Elizabeth Mayr, today appears to be a Client Service Consultant at Wells Fargo & Company and or Account Manager for Wells, Fargo Bank in Maryland since around 2014. Prior to that she worked for ComputerShare aka CTSLinks aka Norwest.com also a Partner to Wells Fargo Bank N. A., signing documents that went to the SEC in both Mortgage Sack Securities that the Debtor's alleged loan is in Jane Doe STATEMENT OF FACTS 1, That Real Estate Property 15 W. Spring St., Alexandria, VA was illegally Foreclosed on March 30 of 2018 and the title is tainted by the collusion and cover-up of defendants / mostly lawyers who have knoviedge of the facts and ignored them for personal and professional selt-dealing husy/imuy voulube,com/warch2ve8ztiotw/W0 Link to taped foreclosure with Wells Fargo Bank buying the property back? 2. The Documents prior to the foreclosure will show that fraudulentfalsified documents filed against the home put it on the Balance Sheet of Bank of America aka Lasalle Bank and Wells Fargo Bank by Lorraine Brown of Dox who went to jail. 3. That a letter from BWW Law Group shows it was still on the Bank of America et al and included in a Federal Settlement - this turned out to be false 4. That a Corrected Lost Assignment filed was done by a Robo-Signer who | have interviewed and stated and gave several hours of disclosure of the corruption. The State of Virginia requires a review of such documents by a lawyer - the BAR NO. on the document belongs to a Judge in Florida. No such number exists in Virginia. According to OCWEN/PHH employees, this is a pattern and practice not to use lawyers and add "FAKE" Bar Numbers. 5. Conversations with Wells Fargo Bank and OCWEN on home which shows it was known by all the scheme to foreclose on falsified documents and that Wells Fargo Bank had no knowledge August 10, 2017, Emily with Wells Fargo 8 10 2017 video 27m50s webcamera io Wells Fargo btins:tivoutu.belel0n-EDvel k August 10, 2017, Emily with Wells Fargo OCWEN 8 9 2017 video 26m26s webcamera io fites.divoutu.be/2U_JPawSsDQAugust 11, 2017 OCWEN 8 11 2017 video 10mi5s, webcamera io httaastiveutu.belienTOakstik August 11, 2017 OCWEN 2 Video Fri 8012 2017 video 39m22s webcamera io hitps:llvoutus be/SKZ0WosXiUK August 11, 2017 OCWEN No 3 video 34m10s webcamera io hitos:/voutes.beliwelIBXHWt8 Friday, August 11, 2017, OCWEN No 4 Legal Brenda video 12m34s webcamera io hitps:/ivouty belaXtvS4bvClo 6. Brook & Scott who foreclosed were told by OCWEN not to. It appears that Troutman Pepper Hamilton Sanders demanded the foreclosure for personal financial gain. 7. Troutman Pepper Hamitiong Sanders aka Mays & Valentine has @ conflict as they with others swindled $30,000. From Plaintiff September of 1990 - to Cover-Up Trust monies stolen from Sonia Grenadier. This court Case No. 1:93-ct-00302-CMH - You can Read More: udicialpe inalerimi by-lawyer-ii mays-valenting-cover-up-of trust-theft-by-divor law & March 29, 2018 - Brock and Scott/OCWEN conversation admits OCWEN had told Brock & Scott to not Foreclose conv starts at about 6 min and 40 sec bttnsdiow.veutube.comiva: 9. The illegal Foreclosure took place on March 30, 2048, with the bank Wells Fargo Bank purchasing the home - Plaintiff is stil in the property hitas:#wmaxoutube.comlwatch 2vc82tllotwy W/o, 10, On April 6, 2018, Brock and Scott filed a Deed that Wells Fargo Bank was the Owner of the Loan. ‘The lawyers have stated in several documents and in court that Wells Fargo Bank is the lender. 11. On or around April 4 2019 Troutman Pepper Hamilton Sanders Lawyer S. Mohsin Reza exposes that he and his “Friend” want me to short sell my home to them. That his friend states they can get ‘Wells Fargo to do whatever they want - There are taped conversations 12. On March 31, 2019, Plaintiff received 1098 stating the owner was OCWEN - the IRS finds this to be a fraud and the complaint is being moved to the Tax Court in Washington DC 13. On August 26,2019 Plaintiff received a letter from OCWEN / PHH is transfer to new servicer after the foreclosure NewRez 14, On October 1, 2019 Exhibit 1 Copy of Computer - print out for NewRez loan 15, On or around February 10, 2020 Exhibits 22 - 24 Servicer for Loan No. 7143312465 Plaintiff received a letters from New Rez they now had a loan on property 15 W. Spring St. The home was foreclosed on March of 2018 and in 2020 JWG is getting letter from a new Servicer? 16. That the documents from signing into accounts will show now after the foreclosure Plaintiff still had a loan with Two Servicers. yer-iionaely-free17. Bank of America has always taken a stand they had no ownership and or an interest in a loan on 15 \W. Spring St., but never took the corrective steps to ensure Plaintiff was not harmed by lawyers et a. 18. On April 4, 2020 Troutman Pepper Hamilton Sanders Reza Moushin asked Plaintiff to agree to sell the property - knowing the Tite of the property was tainted. He would then go on to harass me and ‘my daughters by giving out our phone numbers by all appearances to his friend Micheal Martinez \who several taped conversations will show the intent and the insider relationship. 19. On or around Nov 18, 2018 Wells Fargo Bank answered discovery and stated they had no loan on 15 W. Spring St. and filed it directly in the City of Alexandria court. They also had no knowledge that Troutman Pepper Hamilton Sanders was representing them. 20. Wells Fargo Bank answered discovery on August 6, 2019 and August 7, 2019 with a Notarized Letter that they had no loan or ownership of 15 W. Spring St., Alexandria, VA 22301. Again Wells Fargo Bank had no knowledge of lawyers Troutman Pepper Hamilton Sanders 21. That in or around 2024 the home without notification to Plaintiff was put on the market for Sale by Altisource, Houbzu, REALHOME SERVICES AND SOLUTIONS, INC. aka Altisource, and MLS BRIGHT the problem is nowhere on the listing did they disclose the tainted title. Misleading the public of a home that was illegally foreclosed on, 22. That the majority of those involved are Lawyers, Realtors and have an obligation under the prot sional code of ethics and the law to report s ich corruption and collusion. 22. They have a responsibilty to the public to protect it from such a fraud and the very least to disclose it in any listing to the public that they will pay over $1. million for a property thet the bank has tainted the ttle with the fing of there document in the court that they have no interest in such property. BACKGROUND AFTER FORECLOSURE On MARCH 30, 2018 Of 15 W. Spring St, Alexandria, VA 22301 Complainant is entitled to the relief and REPLEVIN for the following reasons: Ie ‘That Plaintiff can show that the Defendant 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, ‘That you can hear OCWEN telling Brock & Scott NOTto Foreclose on Spring St. @ Brock and Scott / OCWEN conversation March 2019 Admits OCWEN had told them to not Foreciose conv starts at about 6 min and 40 sec https:/ivww youtube, comwatch2v200gWALDLIVIKI=1I27. ‘That you can then see the Foreclosure taped: The Foreclosure by Wells Fargo NOT OCWEN a total SCAM March 2018. httns./mwew.youtube. comlwatch 2v=szttiotwviWva The Deed attached shows the property in the name of Wells Fargo N.A. et al with an odd caveat for OCWEN, ‘Troutman Sanders then approached JWG on or around April 4, 2019 Troutman Sanders Lawyer S. Moshin Reza asked JWG to do a short sale on a home that had been foreclosed. Micheal Martinez10. 12. di 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 will be easy to deal with and will do almost anything we want” paraphrase. 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 16 W. Spring Street, Alexandria, VA 22301 Exhibit (On or around August 8, 2019 Wells Fargo Bank did a notarized document that they had no documentation, Exhibit ‘That OCWEN the loan servicer did a fraudulent 1099 to the IRS that is under investigation. Exhibit ‘That PHH on of 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 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 20, 2020 of Wells Fargo Bank, Bank of America, OCWEN and New Residential Investment Corp. ‘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, Freddie Mac, my personal credit report since around 2012 show no none ownership of any loan. Exhibit # ‘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, lawyer Well as stated in the Virginia State Bars code of Professional Conduct for Practicing Law without a license. Alexandria, VA 22301 due to not being prepared properly by a lawyer, but by a lay person acting as a and using anothers Florida State Bar No. This includes the VA Code that rules the Clerk's Office, as HISTORY OF FRAUDULENT DOCUMENTS AGAINST SPRING ST 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) @ false representation, that the loan went to a Mtg Back Security that was closed prior to the loan being created (2) of a present, materia! 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 Mig Back Security was closed on or around July 1, 2003 and the alleged loan is dated February of 4, 2008 (6) resulting damage. tllegal Foreclosure on March 30, 2019 . 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 @ present, material fact, the Assignment was done by a non-lawyer Rob Meharg (3) made intentionally and knowingly, That Doox 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, (4) with intent to mislead, the letter by Bank of America through BWW Law Group shows the intend in ot around December of 2012 (6) reasonable reliance by the party misled, and the Facts that Lorraine Brown went to jail the fact the Mig Back Security was closed on or around July 1, 2003 and the alleged loan is dated February of 4, 2008 (6) resulting damage. tliegal Foreclosure on March 30, 2019 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: Sister Nora Nash states: OCWEN and Aitisource, 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 (8) made intentionally and knowingly, the Facts are clear JWG had disclosed to Howard Bierman of BWW Law Group the Fraud (4) with intent to mistead, The filing with the Commissioner, and the foreclosure itself showed OCWEN etal 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 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 sraorap7aeae fe SERS Sm Sadie March 28, 2018 Phone call between OCWEN, Janice Wolk Grenadier and Brock & Scott aka Trustee Services Of oe Virginia, LLC., where OCWEN informs Brock & Scott and Brock squpepggeee © Scottacknowledge that on or around March 22, 2018 they oe a = had received notice from OCWEN not to foreclose. They then @ Cy > received from the Investor that no matter what they were to = a i foreclose - ignoring whatever OCWEN said. 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 foreciosure httas umm youtube comvwatch ves 2th On or around April 6, 208 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 Secutity 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 Janice 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, unlicensed affiliate offshore companies to “perform activities consicered residential morigage loan ser ‘Qewen Financial Solutions Private Limited, operating out of a location in tadia, and Ocwen Business — Solutions, operating out of a location in the Philippines, to conduct “servicing” activities on residential mortgage loans. VA SCG states OCWEN is Licensed as’ 10QOWEN BUSING Foreign Corporation Active Foreign Corporation Active EQ Foreign Corporation Active QCWEN LOAN, 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. owen 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 fled fraudulent 1099 information returns with the IRS 26 U.S.C. § 7434. Civil damages for fraudulent filing of information returns*. 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 Morigage 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, * 25 USC 5 7494. Ci damages for faucet fing of information etums(a) Im general fay person wiifly files fraudulent informant wih pect ‘© payseets pups tobe ade tay ther pose, such athe pers may bunga tilaxan for daragrs asin the prs so lig such et) Damages ‘asin buh wey ssc (a). yp a ing aby athe aco he dena, deena shall be ve othe pat aan aout eel the {geste of $3,990 or th oun: of) a actual damage aad by the plata promaeresuk ofthe ils of te ral nkorntin ear nla Costs asl eolving defen aero a arene of sich ing (2) te cot ofthe Stan nd) inthe cours eserein esrb ator fees 6). 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Pub 105-206 sbetd attare "fs" for “anes fees, Pub, Y04-168, ule VI, § 601), July 30, 196,110 Sta. 1452, provided Cut "Te amends made by tis ection (enactag de secan and eben Ie seein 24 3 7585 oft ie) sh apply Poudule.nfematon etm: fer he eof the enaeet ofthe et ly 3819 a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: hias./www.vsb.org/nro-quidelnes/index phoiunauthonzed-practice-culesinie-6) Violating Unauthorized Practice of Law Rule 6 Real Estate Practice _ 6-1010 (B) (C),UPR 6-102 (A), UPR 6-103 (A) (B) UPR6-106 UPC6-1 UPC6-2 UPC6-4 UPC6-8 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 | have filed a Motion for the Judge to remove the Assignments and | would appreciate your support of such actions. | WAS IGNORED. 13, 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 of a California Lawyer not practicing stated the information came from the 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, To harass and try to embarrass Plaintiff at 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 | will commit suicide. 1 will not. Or maybe you think | will become afraid of you - You can go to my blog VALaw2010 blogspot.com or to the new website | have founded JudicialPedia.com to see | am not running. | am Standing Up and Speaking Out against the corruption FACTS PRIOR TO FORECLOSURE Plaintiff incorporates herein by reference all of the allegations contained in the above Paragraphs of this, Complaint ‘That it was never disclosed such loan would be used in a Ponzi or 2 Card Monte scheme On or around December 18, 2012 BWW-Law Group sent Plaintif 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 aloan. Bank of America purchased LaSalle Bank October 1, 2007. February 24, 2009 and February June 18, 2009 Bank of America fik/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 12Linda Green. it was proven in the USA and Lynn E. Szymoniak vs. American Home Mig 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: (4) 18 U.S.C. §1001 ~ Statements or entries generally; (2) 18 U.S.C. § 1010 - HUD and Federal Housing Administration tansactions; (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:/taww.mbaa.org/FBIMorgageFraudWaring.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 Plaintif back to the Homeward Residential that BWW Law Group had no knowledge who owned the loan. Plaintiff / 3G was in the process of applying for the Government Independent Foreclosure Review and leamed about the possibility of this break in the chain of title. The HAMP Program. in 2008 and thereafter, Plaintif Homeward on a Deed Mortification through 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 the Plaintiffs, received money per application Jand document/ but not 13er person, creating a reward for negligent and fraudulent corporateforganizational bad behaviors that deprived or deterred homeowner refinancing, such as occurred here. Improper interference with Plaintif's HAMP Application. On or around January 28, 2013, Homeward Mortgage sent Plaintiff a Notice of Servicing Transfer (RESPA) and Welcome to OCWEN Loan Servicing, LLC [ x8] Homeward Mortgage servicing was the servicer of Plaintiff loan till February 18, 2013. February 19, 2013 OCWEN became the servicer. The 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 Plaintiff had been told by Homeward that they were cleared up. The Homeward supervisor had left Plaintiff a message that the foreclosure of her home had been stayed. February 19, 2013 Plaintiff phoned OCWEN to confirm that there had not been any issue that the foreclosure had been stayed as the BWW Law Group stil showed it active on BWW Law website. OCWEN informed Plaintiff 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. February 20, 2013 Plaintiff 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 Plaintiff 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 Plaintif’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. ‘She made phone calls to OCWEN and supervisors at OCWEN, who were at a loss as to how to help Plaintiff. OCWEN claimed to have never seen a situation like this. OCWEN kept informing Plaintiff that BWW Law group could not foreciose prior to or on April 17, 2013 and only thereafter if Plaintiffs’ documients had not been received by OCWEN. Phone calls are taped With no other recourse, and based on BWWLaw Group bad faith, Plaintiff was forced to file involuntary Bankruptcy February 21, 2013 to protect her interest in the property. Video available (On February 21, 2013 Plaintiff/ JWG could not get through to a voice-mail or anyone at BWWLaw group, which at times blocked Plaintiffs calls and emails. Plaintiff took a copy of the receipt for the bankruptey to the address of the alleged “owner” of the loan (according to IBWWLaw Group — was “Equity Trustees’ with an 14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. Plaintiff / 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 Plaintif. 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 wilful acts that are self-interest, malicious, violent, oppressive, fraudulent, wanton, and grossly reckless in light of the fiduciary nature of the lawirmitrustee duties. “On February 22, 2013 Plaintiff 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 Plaintiff 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 (¢). Requesting by law the information Plaintiff 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/awyers to violate federal law/rights and fiduciary duties owed to the Plaintiff because they controlled the documents and intentionally kept them from the Plaintiff. Plaintiff is an Entrepreneur and as a result of Defendant's improper interference she lost funding because BWW Law advertised her home for foreclosure February 7, 2013. Plaintiff worked diligently with Homeward and OCWENt o prevent foreclosure and by fling for Bankruptcy. BWW-Law group fik/a Bierman, Geesing, Ward & Wood, LLC acted in its own best interest by putting its own best interests and that of the other lawyers, before the best interest of the Plaintiff. 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 included in 4 different signatures on Plaintiffs 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 BW-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 One Mortgage shuts down and is sold on or around May 17, 2008 to AHMSI) [Ex 18] By: American Home Mortgage Servicing inc. (AHMS!) 15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 Plaintift. (On or Around May 17, 2012 Plaintiff leaned Mark R. Galbraith was representing Wells Fargo. 14 Plaintiff reached out to Mr. Galbraith by phone and email. Mr. Galbraith also refused to answer any questions in regard to whether 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 "Atiorney 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 - FAREDDIE 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 fik/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 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. 16‘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 Janice illegally jailed and tortured in the City of Alexandria, Solitary Confinement tll Spm 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 tuming the other check of the corruption and ot 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 Titie 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 JWG was placed in jail for failure to pay legal fees in 30 days which is Violation of my Thirteenth Amendment "Neither Slavery nor 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 tile of the home at the same time. A loss that occurred because of their failure to 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 mortgages 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. 17‘That the Exhibits filed with this case showed the lack of care taken in legal documents filed against the home. Since this lawsuit was filed Defendant OCWEN in the original suit has ignored the rules of the Fourth Circuit Court, and have never filed a response or properly put notice into the Court as to the appearance of the lawyers without badgering from the court. 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 llona 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 stil with the Grenadier Starace Duffett & Levi Law firm due after 30 years in 2020. The only copy demanded as my lawyer sits in llona’s safe according to llona 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 llona Grenadier Heckman in the City of ‘Alexandria Case No. CL1500 ~ 3661 to ensure and help Lawyer llona deny Plaintiff, all Plaintf 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 Plaintiff / Janice. The following e-mail states clearly how Troutman Sanders relationships with Judges are how they ignore the law, But this E-mail of January 28, 2016 may say it Detter then anything Prowm: Rex, Motain Esse raragbuoeimanaander cory Seow Thursday. forwisry 28. 2046 1223 9M You teem tatrgie oF ‘piri Anateea Naossintiny casrvens ase Ge: Uirle, Andy ~Arscly Oneiartroaamincmanaiers.corine trompaon, Aabiey S. Mohsin Reza | TROUTMAN SANDERS LLP L8SO Towers Crescent Plaza, Guile SOO, TyHONS Comer. Virginia Yet (78a) A884 | Bax (70S) 448-830 cetera sete ed arabaanes ‘The Lawyers di not show up in court. They did not have to file anything ~ Judge James Clark was na their side as stated fn the betow Finks 18.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. 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, MeQuireWoods, ‘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 "CFP" 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 § 1692) - 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 tile 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. (@) Abusive debt collection practices are carried on to a substantial extent in interstate commerce and through means and instrumentalities of such commerce. Even where abusive debt collection practices are purely intrastate in character, they nevertheless directly affect interstate commerce. (e) Itis 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 Slate 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 19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) n 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 FOCPA 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. Janice / Plaintiff 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 Janice 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 unretumed 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 14, 2017 from OCWEN she leamed that the foreclosure was never removed, that OCWEN and McCabe had schemed no differently illegally and in collusion to try and deceive Janice that the Foreclosure had been removed from the schedule. That ths 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 Janice would call the CEO of Wells Fargo’s office to ensure he was aware of the CRIMINAL ACTIVITY of his Servicer and Lawyers. Janice 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. 20‘That Janice / Plaintiff 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 the Defendant WFB is now through OCWEN sending people to her home to harass her into trying to sell the home. CAUSES OF ACTION Count 1 118 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. 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 io ensure the COVER UP of Divorce Lawyer llona 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 llona 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 llona 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 24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 tite 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 Treasuty, 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. 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 tite 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 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 bts diwew.govinfo cow pkalGPO-Fe! Government Edition. Jeonts ~ This link will take you to the Official ‘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’ Other then the Two CFPB Cases Above: ignore IGNORE 22BEAR STEARNS MORTGAGE PASS-THROUGH CERTIFICATES LITIGATION I: 850 Securities/Commodities Date September 18, 2008 CitylCounty New York Type of Case 850 Securtes/Commodites Class Action Complaint for Violation of the Secures Act of 1933 ina/bear-stearns- mortage: omen 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 vonvlisting/bear-steatns.- moriaage-pass:-throunh-certficates-tiaath 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 Number 1:09-cv-06172-LTS Lead case: 1:08-cv-08093-LTS Member case: (View Member Case) Related Case: 1:08-cv-O609-LTS Cause: 15:78m(a) Securities Exchange Act Judges Judge Laura Taylor Swain idiciainedia comlstingiear-steams-mortaage pass-through s 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 : 15:0077 Secures Fraud Neture of Suit 850 Securties/Commodties Jates-whom.wh puosulee 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 ciaibedia comlistings veczcommodiies 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-cy-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 23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- RUS Case in other court: Supreme Court- New York County, 650195-12 Cause: 28:1441n1 Notice of Removal Judges Judge Richard J. Sulivan 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-me-000062-JFA 0:13-cv-00464- Judges Judge Joseph F: Anderson, Jt Stichting Pensioenfonds ABP v. JPMorgan Chase & Co. et al / 850 SecuritiesiCommodities Date February 24, 2013 City/County New York City Type of Case : 850 Securities/Commotities 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: 28:144inr Notice of Removal Judges Judge Lewis A. Keplan lis ning: nensiogtfonds-abp-v-iomoroan-chasec fisting 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.LS.A, Jurisdiction: Federal Question Case Number 1:18-cv-01951-VS8-SDA Judges Assigned to: Judge Vernon S. Broderick Referred to: Magistrate Judge Stewart D. Aaron sary-culyl 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, 2a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, 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) (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. Colles (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 Plaintiff was under the production of the HAMP program as described in paragraph That the statute of imitations 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 secutity 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. 25Further to ignore the STAY as issued by the 4th Circuit is in direct conflict of the lawyers Professional Coda.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 llona 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 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. Itis 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. BW Law group and now McCabe Weisberg and Conway, Brack and Scott Pllc had no other motivation to foreclose on Plaintif 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. 26JWG after Defendants lawyers Troutman Sanders aka Mays & Valentine attached themselves to the Cover Up of Divorce Lawyer llona 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 llona 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 ‘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 llona 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 EnrichmentiConstructive 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. ar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 Foreciose 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 responsibilty 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, Alexandra VA 2230, but they nevertheless, for their own financial profit and gain, pursued illegal collection remedies that have \wrongfully harmed this JWG. 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 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 “FOCPA’); (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.FR. part 1026 (Regulation 2’): and (5) Section 3(b) of Homeowners Protection Act of 1998, 12 USC § 4902(b)(the "HPA"). 28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 wilfully scheme to defraud Plaintiff, 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 necessary legal standing requirements to institute a foreclosure, take possession, custody, and control of the Property. Count 8 ‘Common Law Fraudi2 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. Itis 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 eamest. 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 itis illegal for them to as you are in the HAMP program process” ‘The defendants and ot their representatives making these statements knew or should have known it to be untru 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. 29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 foreciose 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 WG 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 Plaintiff ‘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 Joan as Wells Fargo and Bank of America have claimed no ownership in alleged loan and further Wells Fargo Bank claims ever 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 retum 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 The CFPB further States: Mortgage Servicer's Widespread Errors, Shortcuts, and Runarounds Cost Borrowers Money, Homes WASHINGTON, D.C. -- The Consumer Financial Protection Bureau (CFPB) today sued one of the country's largest nonbank morigage loan servicers, Oowen Financial Corporation, and its subsidiaries for failing borrowers at every stage af the mortgage servicing process. The Bureau alleges that Oowen’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, propetiy crediting payments, and handling taxes and insurance. Allegedly, Ocwen also illegally forectosed 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 Attomey General took a similar action against Ocwen today in a separate iawsuit, Many state financial regulators are also independently issuing cease-and-desist and license revocation ‘orders against Oowen for escrow management and licensing issues today. “Ocwen has repeatedly made mistakes and taken shortcuts at every stage of the mortgage servicing process, sting 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.” Gowen, headquartered in West Paim Beach, Fla., is one of the nation’s largest nonbank mortgage servicers. 31, 2016, Ocwen serviced almost 1.4 milion loans with an aggregate unpaid principal balance of $2089 billion. ft services loans for borrowers in all 50 states and the District of Columbia, A mortgage servicer 31collects payments from the mortgage borrower ane! forwards those payments to the owner of the loan. tt handles customer service, collections, loan modifications, and foreclosures. Ocwen specializes subprime or delinquent loans. servicing The CFPB uncovered substantial evidence that Oowen has engaged in significant and systemic misconduct at nearly every stage of the mortgage servicing process. The CFPS is charged with enforcing the odd-Frank Wall Street Reform and Consumer Protection Act, which protects consumers from unfair, deceptive, or abusive acis 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 morgage servicing rules require that servicers promptly credit payments and correct errors on request. The tules also include sitong protections for struggling homeowners, including those facing foreclosure. in its lawsuit, the CFPB alleges that Oowen: ced loans using ertor-riddled information: Ocwen uses a proprietary system called REAI.Servicing to process and epply borrower payments, communicate payment information to borrowers, and maintain loan balance information, Oowen allegedly foaded inaccurate and incomplete information into its REALServicing system, And even when data was accurate, REALServicing generated errors because of system failures and deficient programming. Te manage 3k, Cowen tried manual workarounds, but they often faifed to correct inaccuracies and produced stil more errors. Cowen then sed this faulty information to service borrowers’ loans, In 2014, Ocwen's head of servicing described its system as “ridiculous” and a “tain wreck." ‘¢ Hlegally foreclosed on homeowmers: Ocwen has long touted its ability to service and modify loans for troubled bortowers, But allegedly, Ocwen has failed to deliver required foreclosure protections. As a result, the Bureau alleges that Oowen has wrongfully initiated foreclosure proceedings on at feast 1,000 people, and has wrongfully held forectosure sales, Among other illegal practices, Ocwen has initiated the forectosure process before completing a review of borrowers’ loss mitigation applications. In other instances, Ocwen has asked borrowers to submit additional information within 20 days, but foreclosed on the borrowers before the deadline. Cowen has also forectosed on borrowers who were fulfting their obligations under a loss mitigation agreement. * Failed to credit borrowers’ payments. Ocwen has allegedly failed to appropriately credit payments macle by numerous borrowers. owen has also failed to send borrowers accurate periodic stateme detailing the amount due, how payments were applied, total payments received, and other information. Cowen has also failed to correct billing ancl payment errors, ‘+ Botched escrow accounts: Qowen manages escrow accounts for over 75 percent of the loans it services. Oewen has allegedly botched basic tasks in managing these borrower accounts. Because of system breakdowns and an over-reliance on manuaily entering information, Ocwen has allegedly failed to conduct escrow analyses and sent some borrowers’ escrow statements late of not at all. Cowen also allegedly failed to properly account for arid apply payments by borrowers to adkiress escrow shortages, such as changes in the account when property taxes go up. One result ofthis faiture has been that some hotrowers have paid inaccurate amounts, Mishandled hazard insurance: Ifa servicer administers an esctow 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, CQowen’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: Oawen allegedly faifed to cancel borrowers’ private mortgage insurance, or PMi, in a timely way, causing consumers to averpay. Generally, borrowers must Purchase PMI when they obtain a morigage with a down payment of fess than 20 percent, or when they 2refinance their mortgage with less than 20 percent equity in their property. Servicers must end a borrower's requitement to pay PMI when the principal balance of the mortgage reaches 78 percent of the property’s original valtie. Since 2014, Cowen has failed to end borrowers’ PM on time after learning information in its REAL Servicing system was unreliable or missing altogether. Ocwen uttimaiely overcharged borrowers about $1.2 million for PMI premiums, and refunded this money only after the tact * Deceptively signed up and charged borrowers for add-on products: When servicing borrowers’ mortgage loans, owen allegedly enrolled some consumers in add-on products through deceptive solicitations and without their consent, Gowen then billed and collected payments from these consumers. i heirs seeking foreclosure alternatives: Oowen allegedly mishandied accounts for successors-in-interesi, or heirs, to a deceased borrower. These consumers included widows, children, nd other relatives. AS a result, Ocwen failed to properly recognize individuals as heirs, and thereby denied assistance to help avoid forectosure. 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, oF investigate the alleged error. Since 2014, Ocwen has allegedly routinely failed to properly acknowledge and investigate complaints, or make necessary corrections. ‘Oewen changed its policy in April 2015 to ackress 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 $80,000 notices of error and complaints from more than 200,000 different borrowers. * Failed to provide complete and accurate loan information to new servicers: Ocwen has allegedly failed to inciude 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 Oowen has failed to remediate borrowers for the harm it has caused, incliding the problems it has created for struggling borrowers who were in default on thair loans of who had fled for bankruptcy. For these groups of borrowers, Ocwen's servicing errors have been particularly costly. Through its compiaint, fled in federal district court for the Souther District of Florida, the CFPB seeks a court order requiting Cowen 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 avaitable at: ites. consumerfinance. govilidocuments/2 70420 cfpb_Ocwen-Complaint.paf ‘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WG 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 tile 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 itis called to Cease and Desist from criminal fraudulent violations by the CFPB. 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 Due to Fraud and Misrepresentation 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 - Fraud and Misrepresentation JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this ComplaintThat OCWEN and their lawyers had a responsibilty to act in a timely manner that information that Plaintiff has requested since 2012 Plaintiff has stil 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 ate 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. This is not the complete letter but you can see that Plaintiff had the same Robo-Signers on documents against Spring St. and Trustis listed as a “VOID” trust under Whistieblower Lynn E. Szymoniak Esq April 15, 2010 LYNN E. SZYMONIAK, ESQ. inaletter 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; ‘* Mortage assignments with signatures of individuals signing as corporate officers for corporations that never employed them in any such capacity;© Mortgage assi luals 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 humerous 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 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 forectosure where it lacked a valid Assignment. 36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 followin + 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; + 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 Funding (sic) Services, Inc., by American Home Mortgage Servicing, Ine, 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 37‘Sand Canyon Corporation and Assistant Vice President of American Home Mortgage Acceptance. The above joints out and shows thé iminal activity has beet ‘on fora long time. 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 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 tite 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 canceled 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 original 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 38