The bank playbook is very simple: keep it as complicated as possible. That way the court and even the homeowner will come to rely on what the banks and so-called servicer say about names, places, documents and money. That’s how they sold the initial fraudulent MBS and around 10 million foreclosures. If you had a […]

Tags: financial analyst, interrogatories, Ocwen, Ocwen Financial Corporation, Ocwen Loan Servicing, REQUESTS TO PRODUCE, Sally Torres, TRUTH
Posted in Corruption, discovery, Eviction, evidence, legal standing, Motions, Servicer |

For further information please call 954-495-9867 or 520-405-1688 =========================== see Garmin Factors to Justify Order Compelling Discovery Lawyers Practice Note: Compelling discovery is the most important part of foreclosure defense. The current strategy of the banks is to object to practically everything. Set down their objections for hearing and file a motion to compel. But […]

Tags: compelling discovery, garmin factors, interrogatories, production of documents, request for admissions, request to produce
Posted in Uncategorized |

Responding to specific requests from lawyers and homeowners, the livinglies store has changed its offering. Www.livingliesstore.com You can still get the old Combo of just a title and securitization report, but we have added some levels and services to meet the demand for our services. Of course pricing has been adjusted to reflect the increased […]

Tags: COMBO, consent order, DVL, FOIA, foreclosure defense, GGKW, interrogatories, litigation support, QWR, RESPA 6, Title and Securitization Report
Posted in Corruption, evidence, expert witness, Modification, Motions, Pleading, securities fraud, Servicer |

GET A CONSULT WITH NEIL GARFIELD DENY AND DISCOVER!! INTERROGATORIES: FOLLOWING THE MONEY PLEASE!!! CONSULT WITH ATTORNEY LICENSED IN YOUR JURISDICTION OR THE JURISDICTION IN WHICH THE PROPERTY IS LOCATED BEFORE YOU ACT ON ANYTHING ON THIS BLOG. These need to tweaked to fit your case, but they are a decent first step at getting […]

Tags: Deny and Discover, interrogatories
Posted in bubble, Corruption, Eviction, securities fraud |

why-you-should-attend-the-discovery-and-motion-practice-workshop VISIT LIVINGLIES STORE FOR FREE VIDEOS AND OTHER RESOURCES START WINNING CASES!! May 23-24, 2010 2 days. 9am-5pm. Neil F Garfield. CLE credits pending but not promised. Register Now. Seating limited to 18. INCLUDES LUNCH AND EXTENSIVE MANUAL OF FORMS, NARRATIVE AND CASES. An in-depth look at securitized residential mortgages and deeds of trust. […]

Tags: bankruptcy, BOND, borrowers, CLE, creditors, debtors, DEED OF TRUST ANALYSIS, deeds of trust, DEPOSITIONS UPON WRITTEN QUESTIONS., discovery, DVL, EMERGENCY MOTIONS, evidentiary hearing, EXPERT DECLARATIONS, EXPERT EVIDENCE, FACT EVIDENCE, foreclosure defense and offense, FORENSIC EVIDENCE, FORENSIC REPORTS, FORMS, Garfield Continuum, homeowners, interrogatories, investors, Mortgage, MOTION, MOTION TO COMPEL, MOTION TO DISMISS, motion to lift stay, NEIL GARFIELD, note, Notice of Default, Obligation, QUESTIONS OF FACT, QWR, REAL PARTY IN INTEREST, REMICS, REQUESTS FOR ADMISSIONS, REQUESTS TO PRODUCE, rescission, RESPA, securitization, securitized residential mortgages, splitting note from security instrument, standing, TEMPORARY RESTRAINING ORDERS, TILA, TILA audits, trustee, TRUSTEES, TRUSTS, workshop
Posted in bubble, Corruption, Eviction, securities fraud |

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 |

See AOSC09-54_Foreclosures. A good step in the right directions. I would add that you should be very careful that you don’t get trapped into the “lender narrative.” The Judges are going to very receptive and even enthusiastic about referring these cases to mediation, so don’t annoy them with motions, pleadings or hearings that attempt to […]

Tags: administrative order, discovery, Florida, forensic analysis, intake form, interrogatories, mediation, request to produce, Supreme Court, TILA audit
Posted in bubble, Corruption, Eviction, securities fraud |

  NOW AVAILABLE OF AMAZON/KINDLE! EDITOR’S NOTE:MY WIFE WILL KILL ME IF SHE FINDS OUT I’VE BEEN WORKING. SHHHHHHHHH. This news is irresistible. MERS is all but dead with this single decision (see below). Here are the salient points:   MERS is not a beneficiary even if the mortgage deed or deed of trust states […]

Tags: affifrmative defenses, allonge, assignment, bankrupty, beneficiary, cloud on title, DEED OF TRUST, defenses, discovery, interrogatories, invalid deed of trust, invalid mortgage deed, Investigation, lack of standing, lawsuit, MERS, money judgment, mortgage deed, motion for contempt, motion to lift stay, motion to strike pleadings, motion tocompel, notice of deposition, real financial interest, request for access, request for admissions, request toproduce, RESPA, standing, TILA, unsecured loan, unsecured obligationunsecured note, void deed of trust, void mortgage deed
Posted in bubble, Corruption, Eviction, securities fraud |

Jose wrote: Thanks for the input K, I filed for BK today pro se I was totally unable to find and attorney with the enough guts in Virginia to take on these crooked lenders. There also another issue in our wonderful state, there is a statute that allows for the lenders to provide a lost […]

Tags: affidavit, interrogatories, lost note, request to produce, Virginia
Posted in bubble, Corruption, Eviction, securities fraud |

This is reply to a question which has been posed to us recently by several readers through email and at least one comment. We have advised demanding the alleged lender (the one suing you in foreclosure or who has scheduled the sale) allow you to inspect and provide you copies of original documents so they […]

Tags: deposition duces tecum, foreclosure, foreclosure defense, foreclosure offense, interrogatories, lost document, lost note, Mortgage, original document, request for admissions, request for production
Posted in bubble, Eviction |