Foreclosure Hamlet

Supporting, Informing & Connecting People in Foreclosure

The Goods (sample pleadings from both sides)

Please come back often. This is a work in progress to be updated frequently.


FOR THE BEST LEGAL BLOG ON JUDICIAL STATE (FL) FORECLOSURE DEFENSE. Visit Matt Weidner's blog and study it thoroughly (including Foreclosure 101)

Fraud Digest's Review of Pleadings!

Sample Pleadings

These documents are all from a judicial foreclosure state. Remember for the purposes of these pleadings Plaintiff = Foreclosing Entity and likewise Defendant = Homeowner.

Motion to Dismiss, Discovery, Interrogatories, Motion to Vacate Summary Judgment, Taking Depositions, Motions to Strike. Sample discovery defense foreclosure actions.


Added late 2010



Insufficient, perjurious verification Robo-verifiers - Full Deposition of Alden Berner of Wells Fargo:


Motion to Dismiss for no verification of amended complaint when original complaint was filed prior to the Feb 11, 2010 effective date for verification here


Motion to Vacate Judgment due to Fraudulent Unrecorded Assignment here


Motion to Set Aside Default due to Dual Track Scam here




Tools to use when defending your home






ICE LEGAL! ICE, ICE, BABY! and and and and

Brian Williams Davies: Plaintiff in a CA foreclosure suit and blog

GRANTED Pinellas Dismissal in Circuit Court
See Comment links and attached files for MTD and Amended MTD by Florida Attorney Matt Weidner

LivingLies July 2008 Posted example of a Florida Motion to Dismiss ...

wm MTD Tygar.pdf

wm MTD ICE.pdf

wm MTD Sherlock.pdf

wm MTD Snyder.pdf

wm MTD Solomon.pdf




WM_Motion to Dismiss Bonfiglio.pdf

Helpful hints for both judicial states (ie: FL) and non-judicial states (ie: CA) with pleadings by Florida Attorney George Gingo.

WM Productions Ferrer.pdf

WM Productions Snyder.pdf



WM Interrogatories to Plaintiff Ferrer.pdf

WM RequestforProductionREMERSTracking.htm.pdf



WM_Request To Produce Bonfiglio.pdf

Admissions, Interrogatories & Productions


Objection to Motion for Summary Judgment Matt Weidner, Esq

wm ER Vacate Sum. Jdgmnt w securitization issues Pro Se.pdf

wm florida-motion-to-vacate-judgment Houk.pdf

wm Notice of Taking Deposition with Documents (Duces Tecum) ICE.pdf

wm Homeowner Defendant's Motion for Summary Judgment ICE(2).pdf

wm MTStrike Affidavits ICE.pdf

Motion for Contemp for Failure to Comply with Order for Discovery.S...


Motion[1].for.57.105 Sanctions..2.1.10.Szymoniak.pdf




Amended Motin to Abate or Dismiss Foreclosure Proceedings.Kline.PDF


Ohio Court of Appeals: WRONGO Bank of New York: Foreclosure reversed and back you go to prove yourself in trial court!


Florida: A Collection of Court Orders and Opinions That Every Advocate MUST READ!

Samples of Appellate Level Work (see links in Matt Weidner Esq's post)


Greg Taylor v. Deutsche Bank- Foreclosure Fighter George Gingo’s Masterpiece




MERS CA Decision:


Judges wondering if inadmissible evidence is adequate to grant summary judgment 0 transcript MSJ 6.9.2010(2).txt





Court Filings by Bank's Counsel

wm Foreclosure Complaint No Note No Mortgage No Problem.pdf

Plaintiff Response to Request for Productions.FDLG.pdf

wm Plaintiff MT Substitute Party Plaintiff FDLG.pdf

Plaintiff's Response to Defendant's Motion to Dismiss

wm Plaintiffs Affidavit of Lost Instuments.pdf


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Comment by Danelle Hills on February 14, 2012 at 5:31pm

Mr. Weidner, do you have attorney friends in the other states that would TAKE these foreclosure defense cases?  If so, could you post a list of them that we may contact?  It is a real problem still in some states, all the lawyers seem to want us homeowners to get modifications of the loans, but make sure we PAY EVERY CENT of the mortgage.  In other words, there is a prejudice against the homeowners.  Can you help?  (I am in North Carolina.)

Comment by JoAnn Kennedy on May 7, 2011 at 8:11pm

I used these in Pennsylvania -- if the judge is already in the pocket of the lawyers, your doomed.

that's what happened to me.   My great Legal advocate stopped sale twice by Motion and got a continuance.  However,  Wells Fargo uses Phalen, Halliman & Schmieg and they are in the pocket of Northampton county.  In fact,  the sheriff gets a commission on all houses foreclosed in addition to his salay

Comment by L on September 12, 2010 at 8:50pm
Ohio Appeals court overturns summary judgment and sends instructs US Bank to prove it's case in trial court
Comment by L on August 25, 2010 at 6:50am
California Victory!
Comment by L on August 22, 2010 at 2:16pm
211. NY Judge: Importance Of Scrutinizing Foreclosing Lenders For Proper Standing In Cases w/Unrepresented Homeowners
Comment by L on August 22, 2010 at 2:11pm
123. FL Ruling: Affidavit was insufficient to establish damages or summary judgment. 35 Fla. L. Weekly D107b
Comment by L on August 22, 2010 at 1:59pm
18. Foreclosure Case Dismissed in Pinellas County Based on Florida Rule of Civil Procedure 1.120(a).
Comment by L on August 21, 2010 at 10:06am
Motion to Disqualify: Justice is dead. Foreclosure Rocket Docket Judge Entering Final Judgments Against Homeowners BEFORE Hearings:

The Motion Every Judge Should Read (And the one the foreclosure mills hoped would never see the light of day!)
Comment by L on August 16, 2010 at 11:42am
Comment by L on July 27, 2010 at 6:42am


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