Mortgage Servicing Fraud
occurs post loan origination when mortgage servicers use false statements and book-keeping entries, fabricated assignments, forged signatures and utter counterfeit intangible Notes to take a homeowner's property and equity.
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HOT OFF THE PRESS!!! New York Attorney STOPS foreclosure sale 30 minutes before scheduled sale at 11:30 am on Tuesday, March 9, 2010. Also, in February, another Judge cancelled Sale completely (after sale date was previously scheduled) and vacated his own judgment after same attorney argued on an Order to Show Cause that plaintiff did not have standing; US Bank NA could not prove proper chain of assignment showing ownership of the homeowner’s property. Mr. Donald argued that a fraudulent assignment had been recorded at the City Register. This attorney is running rings around the bank’s lawyers! His name is Farrel Donald, Esq. Call his office at: 646-626-3338 OR 917-526-6556

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More good news!!! Mr. Donald did it again today in Greensboro, NC. Foreclosure sale was scheduled for this morning, March 11, 2010, and based on Mr. Donald’s argument, the judge stopped the sale until oral arguments can be heard in this case later this month!!!! This attorney knows his stuff.. he exposes the fraud… he’s passionate in fighting for the homeowner, and is getting good success. Please call if you have any questions: 646-626-3338 or 917-526-6556.

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Angela, which county in NY, which judge and what law firm is representing US Bank NA? 

Thanks 
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Question, how can this attorney be in New York and NC....sounds questionable!

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PJ, I'm out of town and dont have all the detals.  When I get back will let you have the info.  However, the county is Nassau.

Masters, have you ever heard of Pro Hac Vice? Google it and you can decide how questionable my post is.  Knowledge is a wonderful thing! All States allow an attorney who is licensed in one state to defend a case in another case by Pro Hac Vice admisson.  As a matter of fact, this same attorney answered a summons and complaint in Kansas for another client there, and the attorneys called him and wanted him to take out the fraud counter claim from his answer... he refused, and they gave the case to another attorney in MI.  Then that attorney from MI called wanting to offer his client a modification... he said, no way!


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Ok, PJ, back in the office. It's Nassau County, the law firm is Gess Gess & Scanlon, PC. The hearing should be tomorrow, but the plaintiff's attorneys have asked for an adjournment!!!!!  You know that they got to be scrambling to prove their case!  And you also know that they CANNOT prove anything becuase the fraud has been detected and exposed!!
Oh, sorry if I missopke... plaintiff is not us bank in this case (that plaintiff is for the case in Queens county)... the plaintiff in the nassau county case is "The CIT Group/Consumer Finance, Inc. (NY)"

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Thanks Angela, 

 What firm is representing CIT Group? After what happened to Baum's  NY law firm being sanctioned backed in Feb. it would be very interesting to know which Foreclosure Mill is party to this case. Perhaps some media coverage is in order here.

Notice how the MSM is dead silent these days on the mortgage meltdown effecting so many people in the USA, job loss, under employment, rapid fire fraudulent foreclosures are hitting people once in good standing with good credit and prime mortgages......Perhaps this is what they all had in mind in the first place, community organizers, congressional thugs and their bank rollers on "Wall Street" ready, willing and able to drain all semblance of prosperity and decimate the middle class.

 If you know what date that this case has been adjourned to, and can post it here, there are a few people here in NASSAU COUNTY that would like to attend.
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You are welcome!  The law firm representing CIT is Gess Gess & Scanlon, PC... their office is in Manhattan.  Steven Baum's firm are still terrorizing homeowners!  This whole thing was a set up... have you noticed how many storage facilities popped up all over New York??????? Indeed they planned to wipe out the middle class... but we are not going to let them.
Will keep you posted on the  new date of the hearing if there will be one!  So you are in Nassau County?  Great... I'm in Queens county... so we are neighbors!
Mr. Donald has another hearing in Queens county in April after he did an Order to Show Cause, and the bank's attny asked for more time to produce his proof. The judge warned him that he must prove that the bank owned the ppty BEFORE law suit was filed... guess what? they did NOT. So if you want to attend that hearing too, I'll give you the info.
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Hello you Guys,

Ya'll don't know me but I am a long time reader and poster on msfraud.

I read where you were making headway in NY and I just wanted to wish you the best and tell you to keep fighting.

I'm just putting the finishing touches on my Appellant Brief.  Been out of our home since June 7, 2007 but still fighting and still have HOPE.

I'm appealing in 6th Circuit which is in Cincinnati, Ohio.  I feel I have a chance there.

Good luck and keep all informed.

Bob
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Sara
We hope you will let us know 

S
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Angela, many of us would be very interested in attending that hearing in Queen's. Also it looks like there is a possibility that the S of GG&S may have "associate" law firms in a few other states, which brings to mind they are setting up a network for a newly formed Foreclosure Mill. 

Just an opinion, but one only has to look at the Shapiro Network of Attorneys (Rochester NY & LI) ever expanding nation wide law firm network, hook up with a podunk law firm, an woo-la they have standing to foreclose in that state on behalf of a "trust" that hired them and is most likely registered in Delaware, where guess what, the current Vice President of the US once represented and still resides. So much for Help for Homeowners. Perhaps the American people should supenna Joe to see what he knows about all of this? 

By the way, they,  Shapiro & Di Caro were smacked down in the White Plains ruling this past October 09' along with PHH Mortgage out of NJ another known but mysterious entity with SEC filings as seller, trust originator, servicer, master servicer, trust holder, you name it they do it, all the while being a primary GSE servicer... with Lehman, Goldman and a myrid of companies named in every one of their SEC filings. In one SEC filing they state that over 95% of the loans they orginate, thur there network of REAL ESTATE brokers, Coldwell Banker, etc.. or BUY from local lenders  for the "Secondary Market" are sold to FANNIE MAE!!! The number one recipiant of the largest bailouts by the American Tax payer. O yes Fannie bundled those loans and sold them as MBS, but since they are not a so called "private company" despite being bailed out by the American Taxpayer, disclosure to the  American taxpayer is not "permitted". 

Needless to say proceedings and the final outcome in the White Plains case should prove very interesting indeed.

Just an insight of what is happening in our neck of the woods!


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Kudos to you Bob!  Way to go!  Never give up... fight to the very end... you will prevail.  We must take back what these banksters and white collar criminals have taken from us... we've worked hard all our lives to make a decent living for our families, and these thiefs, behind closed doors, cook up these devices and plans to rob us of our hard earned belongings.  As PJ said, they planned to decimate the middle class, and they are being successful with a lot of folks. However, those of us who are enlightened, let's spread the word, help others and fight back.  We MUST prevail!!!!

PJ, you are so right on the money... these law breakers are setting up shop all over the country and stealing people's homes cause most of the time they are unopposed and as such they get away with it. Buth listen to this... very interesting... last week when our attny went to serve the court order to stop the sale in NC, the guy who was officiating at the sale (we call them referees here in NY) said that he had to call his boss... guess who he called? The attorney at the law firm who was representing the bank!  We believe that the attny firms have a huge stake in these properties... not just a commission to represent banks in court. They probably bought the house pennies in the dollar and selling them for mega profit!!!! The truth will come out one of these days... things are coming to a head real soon!  Enough already!

We have used that White Plains case that John DiCaro lost miserably on behalf of PHH late last year in our briefs!!!  That was a good one... it exposed the fraud big time. We need more of those!

Anyway, keep the faith... keep fighting... will keep you apprised of any court hearings so that you can come hear our attny in action, and watch the bank's attnys fold like a withered leaf!!
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If any of you are going to come on here and "trumpet" winning cases, we ALL (including owners and moderators of site) want to see the court and style no., pleadings, transcripts, and no less than the ORDER the court placed into the files so we can add to our winning files.  Statements are just that, statements without facts and backing are no better that the assignments, allonges, and account histories that the banks provide!
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Hey angela
What is the case in white plains that Dicaro Lose.  Im fighting one there and would love to pull the file and see what happened.
Vito
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Vito, it was in bankruptcy court and PHH Mortgage claimed that they owned the note and mortgage but could not prove that, so Judge Drain wiped out the mortgage completely because he said that he was more than 50% sure that if the homeowner were to pay up the mortgage that the homeowner would not know who to pay it to.

Are you in State Court - supreme court of ny? Why dont you send me an email to my personal email address and I could give you a couple case numbers that we have worked on. We have a number of cases where the Judges stopped foreclosure sales, and are currently pending hearing.  These are all in NY. Don't mind sharing with you cause we are all in the fight together.

angela
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Vito, not so savvy with posting links, but if you google Shapiro & Di Caro, the case comes up, pleadings, transcripts and all.Perhaps someone here can post it for you. The ruling against PHH & Shapiro/DiCaro was handed down in October of 09. It was pretty well documented in the news also.

You should also note that this foreclose mill has associate firms, 24 or 27 in fact all over the country, and they were sanctioned by a judge in Florida as well, Shapiro & Fleischman(?) , in any case that was covered in the press also.

They also are listed as having received "federal funding". Will try to post the link... 

Just as an aside, please urge everyone you know to go to their County Clerks office ASAP and get certified copies of all records pertaining to their mortgage, even if they are not facing foreclosure. Your friends and family will be quite surprised by what they find.










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The Equitable One
I second Nye's comment.

Surely if you are aware of and have read a winning case posting pleadings, orders, etc., should not be a problem.

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I hear you loud and clear, Equitable One... it's just that I have a problem communicating with or even responding to blogs like Nye's. We should treat other bloggers with the uttmost respect.  Even if one owns and maintains this sight, we all need to be respectful to others.

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The Equitable One
Angela,

Should we then all assume you will be posting the pleadings and orders, or case venues and case numbers?

I've been swimming in this pool of unlawful foreclosure and fraud for over 2 years. I absolutely love reading good arguments that are well expressed and that have won.

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Will be more than happy to share case numbers etc on this blog, however, as some of these cases are ongoing, I'd really prefer not to put this information in this forum.  I have promised to advise another blogger of hearing dates in NY as they become due.  Whenever there is a final order, I'll be more than happy to give details of the case.  In a case that we won and have an order,  I'd be happy to fax to you because I dont know how to upload to this site.. I have a hard copy.  Pl send me your fax number and will fax to you.  Also, if Mr Nye Lavalle wants me to fax that order to him I'll gladly do that if he sends me his fax number.  Maybe he knows how to publish on this site.
I also have discovery that I can share... in fact my Request for Interrogatories was published on livinglies by Mr Garfield.  Well, let me post that here now:

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 DISCOVERY: INTERROGATORIES

 

i). Defendant, XXX, serves these interrogatories on Deutsche Bank National Trust Company, as authorized by Case Management Order dated September 30, 2009, and by the Federal Rule of Civil Procedure 33. Deutsche Bank National Trust Company must serve an answer to each interrogatory separately and fully, in writing and under oath within 30 days after service to: XXX, XXX Ave., Rosedale, NY 11422.

 

INSTRUCTIONS

ii). These requests for interrogatories are directed toward all information known or available to Deutsche Bank National Trust Company - not its lawyer, Ralph F. Casale, Esq. - including information contained in the records and documents in Deutsche Bank National Trust Company’s custody or control or available to Deutsche Bank National Trust Company upon reasonable inquiry.

 

iii). Each request for interrogatory is to be deemed a continuing one. If, after serving an answer, you obtain or become aware of any further information pertaining to that request, you are requested to serve a supplemental answer setting forth such information.

 

iv). As to every request for interrogatory which an authorized officer of Deutsche Bank National Trust Company fails to answer in whole or in part, the subject matter of that request will be deemed confessed and stipulated as fact to the Court.

 

v). Kindly attach additional sheets as required identifying the Interrogatory being answered.  You have a continuing obligation to update the information in these Interrogatories as you acquire new information. If no such update is provided in a reasonable period of time that you acquired such information, it may be excluded at trial or hearing.

 

 

DEFINITIONS

vi). “You” and “your” include Deutsche Bank National Trust Company and any and all persons acting for or in concert with Deutsche Bank National Trust Company.

 

vii). “Document” is synonymous in meaning and equal in scope to the usage of this term in Federal Rule of Civil Procedure 34(a) and includes computer records in any format. A draft or non-identical copy is a separate document within the meaning of this term. The term “document” also includes any “tangible things” as that term is used in Rule 34(a).

 

viii). Parties. The term “plaintiff” or “defendant”, as well as a party’s full or abbreviated name or a pronoun referring to a party, means the party and, where applicable, (his/her/its) agents, representatives, officers, directors, employees, partners, corporate parent, subsidiaries, or affiliates.

 

ix). Identify (person). When referring to a person, “identify” means to give, to the extent known, the person’s full name, present or last known address, telephone number, and when referring to a natural person, the present or last known place of employment. Once a person has been identified in compliance with this paragraph, only the name of that person needs to be listed in response to later discovery requesting the identification of that person.

 

x). Identify (document). When referring to a document, “identify” means to give, to the extent known, the following information: (a) the type of document; (b) the general subject matter of the document; (c) the date of the document; (d) the authors, address, and recipients of the document; (e) the location of the document; (f) the identity of the person who has custody of the document; and (g) whether the document has been destroyed, and if so, (i) the date of its destruction, (ii) the reason for its destruction, and (iii) the identity of the person who destroyed it.

 

xi). Relating. The term “relating” means concerning, referring, describing, evidencing, or constituting, directly or indirectly.

 

xii). Any. The term “any” should be understood in either its most or its least inclusive sense as necessary to bring within the scope of the discovery request all reasons that might otherwise be construed to be outside of its scope.

 

 

REQUEST FOR INTERROGATORIES

 

1. Please identify each person who answer these interrogatories and each person (attach pages if necessary) who assisted, including attorneys, accountants, employees of third party entities, or any other person consulted, however briefly, on the content of any answer to these interrogatories.

ANSWER:

 

 

2. For each of the above persons please state whether they have personal knowledge regarding the subject loan transaction.

ANSWER:

 

3. Please state the date of the first contact between Deutsche Bank National Trust Company and the borrower in the subject loan transaction, the name, address and telephone number of the person(s) in your company who was/were involved in that contact.

ANSWER:

 

 

4. Please identify every potential party to this lawsuit.

ANSWER:

 

 

5. Please identify the person(s) involved in the underwriting of the subject loan. "Underwriting" refers to any person who made representations, evaluations or appraisals of value of the home, value of the security instruments, and ability of the borrower to pay.

ANSWER:

 

 

6. Please identify any person(s) who had any contact with any third party regarding the securitization, sale, transfer, assignment, hypothecation or any document or agreement, oral, written or otherwise, that would effect the funding, closing, or the receipt of money from a third party in a transaction that referred to the subject loan.

ANSWER:

 

 

7. Please identify any person(s) known or believed by anyone at Deutsche Bank National Trust Company who had received physical possession of the note and allonges, the mortgage, or any document (including but not limited to assignment, endorsement, allonges, Pooling and Servicing Agreement, Assignment and Assumption Agreement, Trust Agreement,  letters or email or faxes of transmittals  including attachments) that refers to or incorporates terms regarding the securitization, sale, transfer, assignment, hypothecation or any document or agreement, oral, written or otherwise, that would effect the funding, or the receipt of money from a third party in a transaction, and whether such money was allocated to principal, interest or other obligation related to the subject loan.

ANSWER:

 

 

8. Please identify all persons known or believed by anyone in Deutsche Bank National Trust Company or any affiliate to have participated in the securitization of the subject loan including but not limited to mortgage aggregators, mortgage brokers, financial institutions, Structured Investment Vehicles, Special Purpose Vehicles, Trustees, Managers of derivative securities, managers of the company that issued an Asset-backed security, Underwriters, Rating Agency, Credit Enhancement Provider.

ANSWER:

 

 

9. Please identify the person(s) or entities that are entitled, directly or indirectly to the stream of revenue from the borrower in the subject loan.

ANSWER:

 

 

10 Please identify the person(s) in custody of any document that identifies the loan servicer(s) in the subject loan transaction.

ANSWER:

 

 

11. Please identify any person(s) in custody of any document which refers to any instruction or authority to enforce the note or mortgage in the subject loan transaction.

ANSWER:

 

 

12. Other than people identified above, identify any and all persons who have or had personal knowledge of the subject loan transaction, underwriting of the subject loan transaction, securitization, sale, transfer, assignment or hypothecation of the subject loan transaction, or the decision to enforce the note or mortgage in the subject loan transaction.

ANSWER:

 

 

13. Please state address, phone number, and employment history for the past 3 years of Tamara Price, Vice President, Argent Mortgage Company, LLC, “designated as the Assignor” of the mortgage loan to Deutsche Bank National Trust Company (Assignment of Mortgage recorded in Essex County Register’s Office on June 25, 2008).

ANSWER:

 

 

14. Please state the date on which Argent Mortgage Company, LLC (originator) sold the mortgage loan to Ameriquest Mortgage Company (Seller and Master Servicer).

ANSWER:

 

 

15. Please state the date on which Ameriquest Mortgage Company (Seller and Master Servicer) sold the mortgage loan to Argent Securities, Inc. (Depositor).

ANSWER:

 

 

16. Did Argent Mortgage Company, LLC (originator) or previous servicers of this account receive any compensation, fee, commission, payment, rebate or other financial considerations from Ameriquest Mortgage Company (Seller and Master Servicer) or any affiliate or from the trust funds, for handling, processing, originating or administering this loan?

ANSWER:

 

 

17. If yes, please describe and itemize each and every form of compensation, fee, commission, payment, rebate or other financial consideration paid to Argent Mortgage Company, LLC, the originator or previous servicers of this account by Ameriquest or any affiliate, or from the trust fund.

ANSWER:

 

 

18. Please identify any party, person or entity known or suspected by Deutsche Bank National Trust Company or any of your officers, employees, independent contractors or other agents, or servants of your company who might possess or claim rights under the subject loan or mortgage and/or note.

ANSWER:

 

 

19. Please identify the custodian of the records that would show all entries regarding the flow of funds for the subject loan transaction prior to and after closing of the loan. (Flow of funds, means any record of money received, any record of money paid out and any bookkeeping or accounting entry, general ledger and accounting treatment of the subject loan transaction at your company or any affiliate including but not limited to whether the subject loan transaction was ever entered into any category on the balance sheet at any time or times, whether any reserve for default was ever entered on the balance sheet, and whether any entry, report or calculation was made regarding the effect of this loan transaction on the capital reserve requirements of your company or any affiliate.)

ANSWER:

 

 

20. Please identify the auditor and/or accountant of your financial statements or tax returns.

ANSWER:

 

 

21. Please identify any attorney with whom you consulted or who rendered an opinion regarding the subject loan transaction or any pattern of securitization that may have effected the subject loan transaction directly or indirectly.

ANSWER:

 

 

22. Please identify any person who served as an officer or director with Deutsche Bank National Company or Argent Mortgage Company LLC commencing with 6 months prior to closing of the subject loan transaction through the present. (This interrogatory is limited only to those people who had knowledge, responsibility, or otherwise made or received reports regarding information that included the subject loan transaction, and/or the process by which solicitation, underwriting and closing of residential mortgage loans, or the securitization, sale, transfer or assignment or hypothecation of residential mortgage loans to third parties.)

ANSWER:

 

 

23. Did any investor/certificate holder approve or authorize foreclosure proceedings on XXX’s property?

ANSWER:

 

 

24. Please identify the person(s) involved or having knowledge of any insurance policy or product, plan or instrument describing over-collateralization, cross-collateralization or guarantee or other instrument hedging the risk of default as to any person or entity acting as an issuer of any securities or certificates. (Such instrument(s) relate to the composition of a pool, tranche or other aggregation of assets that was created, included or referred to the subject loan and the pool or aggregation was transmitted, transferred, assigned, pledged or hypothecated to any entity or buyer. A person who “transmitted, transferred, assigned, pledged or hypothecated” refers to any person who suggested, approved, received or accepted the composition of the pool or aggregation made or confirmed representations, evaluations or appraisals of value of the home, value of the security instruments, ability of the borrower to pay.)

ANSWER:

 

 

25. Please identify the person(s) involved or having knowledge of any credit default swap or other instrument hedging the risk of default as to any person or entity acting as an issuer of any securities or certificates. (Such instrument(s) relate to the composition of a pool, tranche or other aggregation of assets that was created, included or referred to the subject loan.)

ANSWER:

 

 

 

 

 

                            

                                  Submitted by:  XXX

                                                           XXX  Ave

                                                  Rosedale, NY 11422


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Thank you very much Angela.
Angela has been very helpful to pro-se litigants. She sent me discoveries samples and I posted them in the post Tactical Consideration... in Msfraud and Livinglies. I also gave them to help pro-se homeowners who can't afford lawyer in poor neighborhood in my county. I understand that it is risky to post on-going lawsuits pleadings on the net as we need to protect Homeowners. We don't want the Bank to know our ammunitions  & strategies beforehand so they can counter-attack. Surprise attack is  still the name of the game in foreclosure defense strategies.
I found many other good pleadings at the Court house files, They are public records, you can copy them or bring your digital camera to take pictures of them. 
Thank you again and keep up the good work.
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The Equitable One
Angela,

Thank you for posting.

Has Plaintiff DBNT responded to that propounded discovery?

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OneObserver
I researched Farrel R Donald, the NY attorney. The NYS attorney licensing states:
FARREL R. DONALD

DOUGLAS & ASSOCIATES, P.C.

4517 AVENUE D



When you look up Douglas &Associates PC, it is a website development business.
Very confusing and misleading. Is this a real attorney or someone mining for desperate homeowners?
BROOKLYN, NY 11203-5735


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I looked into his registration on the nys bar site and got this today:

Registration Number:4671574
  

FARREL R. DONALD
25944 148TH AVE
ROSEDALE, NY 11422-2902
United States
(646) 395-0458
  
Year Admitted in NY:2009
Appellate Division Department of Admission:1
Law School:HOFSTRA UNIVERSITY
Registration Status:Currently registered
Next Registration:

So he has been practicing for 2 years?    I saw that the phone number matches the one you gave as his.  Further quick search shows his address as the same one as yours.    Please be forthcoming with any conflicts of interest.  We need to provide full disclosure in our search for the truth!





O2 B Healthy, LLC
We are selling Detox Foot Spas, Detox Foot Patches
Contact Person: Angela Dennis        
Address: 259-44 148th Ave, NY, 11422        
Rosedale, USA        
+1-888-2833869
Paulette Angela Dennis 259-44 148th Ave Rosedale  

Angela Dennis (Agent)
Carrington Group Realty

110-21 Francis Lewis Blvd
Queens Village New York 11429


"The CARRINGTON GROUP  is a team of highly qualified, and motivated Real Estate Professionals waiting to serve you. We would like to assist you in executing your relocation plans and to take some of the stress out of that  effort. Towards that end we can rent or sell your home, or commercial property.
What is our bottom line? is it a big financial reward? Is it a large inventory? The answer to all your questions is Yes. Of course we care about those things.  But more than all we care that you are well represented and that you are happy with the outcome. Integrity First and second to none.  Call on us today for you real estate needs. "


Phone: 718-776-1200 
Mobile: 917-526-6556
Fax: 718-776-1283 
Email: Contact

Ankar Development Corp
Category:
Real Estate Investment & Leather Restoration
Address:
25944 148th Ave Rosedale, NY 11422-2902
Phone:
(718) 341-6595
Contact Name:
Angela Dennis
Contact Title:
President
Website URL:
N/A
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John Lewis

Why did u ??? "I looked into his registration on the nys bar site and got this today"

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Bill
I think it's great the Angela posted this discovery request and some kind of discovery is better then none....but this is NOT a very good example of discovery.

This request has essentially taken the Plaintiff to school and shown them a lot of information that they will need to win the case. 

It is long and cumbersome.  If this went before a judge they MAY have a very good argument that this is oppressive and over burdensome. 

I do think you have several good questions, but you are asking them all at once, showing what direction you are going, and showing your hand. 

It would seem to be far more effective to divide these questions up across 3-4 discovery requests mixed in with less specific questions.  It would also seem to be more effective to give the Plaintiff an OPPORTUNITY TO LIE UNDER OATH. 

Instead of asking when the note was sold to the "seller" then the "depositor" if you had started with questions like when did the trustee get the note and mortgage and from whom you most likely would have received quite a different answer.  These foreclosures are having the strings pulled by the servicers.  They don't know the answers to these questions. 

If you ask a simple question like when did the trustee get the note, you will most likely get a date.   If you asked from whom did they get the note you may very well get the answer that they got it from the originator.  Trust questions are far more potent AFTER you get some basic questions answered and let them box themselves in. 

When you ask about the seller and depositor because they don't know the answer and you show some kind of sophistication they WILL have to get the trust documents and get some dates that jive. 


Why not let them LIE UNDER OATH in an interrogatory a few times then ask very specific questions?

Why don't you post the answers to these discovery request for us?????????

Thanks


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