The procedural motion missed by most lawyers is re-orienting the parties. Just because you are initially the plaintiff doesn’t mean you should stay that way. Once it is determined that the party seeking affirmative relief is seeking to sell your personal residence and that all you are doing is defending, they must become the plaintiff […]

Tags: accounting, assignment, Assignment and ASsumption Agreement, BURDEN OF PROOF, civil procedure, cut-off date, default, delivery, discovery, due process, fraud, indorsement, party seeking affirmative relief, Pleading, PSA, re-orienting the parties, third party payments, TILA, transfer, yield spread premium
Posted in Corruption, evidence, foreclosure mill, Motions, Pleading, securities fraud |

OK so you feel a little lost. That is because most of us are jumping in at the end of a long series of events and documents. The most important point for you to make in order to jar the Judge’s thinking is that the closing with the borrower took place in the middle of […]

Tags: acceptance of assignment, assignment, Assignment and ASsumption Agreement, borrower, creditor, DEBTOR, DISCOVERY AND MOTION PRACTICE, execution of assignment, HERS, Motion Practice, Pooling and Servicing Agreement, securitization chain, securitization documentation, status of assignment, trustee
Posted in bubble, Corruption, Eviction, expert witness, foreclosure mill, Modification, securities fraud, Servicer |

SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION – ESSEX VICINAGE ——————————————————————X                Civil Action Deutsche Bank National Trust Company, As Trustee Of Argent Securities, Inc. Asset Backed Pass Through Certificates, Series 2004-PW1 Docket Number: XXX REQUEST FOR INTERROGATORIES Plaintiff(s), vs. XXX; John Doe, Husband Of XXX                                                                            XXX Avenue Rosedale, NY 11422 Defendant(s)/Pro Se ——————————————————————X REQUEST FOR […]

Tags: ability to pay, accounting records, Ameriquest Mortgage Company, Appraisal, Argent Mortgage company, Assignment and ASsumption Agreement, certificate holder, Depositor, Deutsch Bank, disocvery, Essex County, forensic analysis, FRCP 34(a), interrogatories, Master Servicer, National Trust Company, originator, pooling, PSA, receipt of money, Servicing, Tamara Price, third party payments, underwriting
Posted in bubble, Corruption, Eviction, securities fraud |