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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I have been unsuccessful in finding any knowledgeable attys in my State, therefore I have had to finally file a complaint myself for quiet title, fraud/forgery and declaratory judgment.

my alleged "lender" was a non-existent corp.
this corp did not come into existence until after 5 years after any alleged "loan"
this alleged "lender" did not respond to summons and it has been four months.
I state in my complaint that the lender did NOT loan to me any money.  (they could not have as they did not exist, and furthermore, I have the wire info which does not state that any $ was even advanced on their behalf or by them at all)
I also state that the promissory note upon which they rely is NOT any promissory note that I signed (I believe that this note was created by JPM and it bears a signature NOT matching any other documents I have going back 25 years or any other documents that was signed with this non-existent "lender".)

I have stated this in my complaint that was also served upon JPMAC and Bayview Loan Servcg.

I received my first request for discovery from JPMAC.  As my documents are extensive  over a four-year period of my own personal discovery, I have asked them to give me more time to compile these in a manner most understandable to also answer and support their interrogatories.

Their atty is okay for an addt'l two weeks for documents and interrogatory, but asked if I might get the admissions sent to him within the 30 days.

This is in state court. The judge has not set any hearing yet or schedule order and is awaiting my default ppwk on the alleged "lender".

re: admissions for now.  JPM is asking for me to admit or deny that I "borrowed" money to purchase my house.  I do not know if I did because I did not see any $$ personally.  How do I respond to such a question given the issues in my complaint.  Did I borrow $??

Also, with extensive documents, what is the norm for producing such?  JPM attys have already demonstrated that they are tricky.  He just told me that I do not need to request from the court any extension of time to respond to his discovery request.  I am going to anyway so it is on file, but is this even true?

I am probably going to be CRUSHED, but I had no other choice but to file myself due the the statutes of limitation.

Thanks for any help and support is appreciated. [smile]

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I am not an attorney and this is not legal advice.

Discovery is such a touchy thing. Believe it or not your post is too vague for a proper response. When you receive discovery requests you only need to give them exactly what they asked for. It doesn't matter what you have in your extensive collection of documents. They only get what they ask for. You are not trying to prove your case to them in discovery.

As far as admissions go, there are typical responses. Denial, admissions, and qualified denials or admissions. If you think they are asking a tricky question it is because they are. They would like nothing more than an admission that you borrowed money because that is one thing they have to prove. Your admission lets them off the hook. A qualified denial would look something like; Denied for want of knowledge, I never borrowed anything from your client.

Again, this is not legal advice and there is no substitute for a qualified attorney's guidance.
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Thanks for responding.  Yes, 42 admissions, appx 5 or 6 OVERLY BROAD interrogatories, and pretty much a request for all material I have which is seven years worth.  They are even asking for my tax returns for the past seven years. It is them who has no chain of title, a forged promissory note and what appears to be a deed created to look like an original blue ink (Yes,I think that the deed they have is forged).

The original lender was one of these "corporations existing under the laws of New York" when they did not exist, hence they could not enter into a contract nor loan $.  Five years later a corp with their name was created n NY.  They were served and have defaulted to the summons now four months.  I just filed the default and need to fie a default judgment. What does this mean for the other two defendants?
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I'm a little confused. You served 3 parties but are they all named as Defendants? You have discovery requests from JPM but has anyone filed an answer to your complaint? Whom is the default against? It would seem to me that a motion to dismiss or an answer from a Defendant would have to be filed before discovery requests were made since they typically only have a short time to answer or move to dismiss on some grounds.
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