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! http://ning.it/cTqwM6

Sample Pleadings ForeclosureProSe.com http://www.foreclosureprose.com/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: http://wp.me/pFWnq-48Q

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

FL ORDERS & TRANSCRIPTS http://ning.it/bF27uA

A MASTERPIECE! FRAME THIS AND HANG IT IN A WORLD CLASS MUSEUM! http://ning.it/cs6nQL

GIFTS FROM MATT WEIDNER, ESQ TO ALL OF YOU- MEMOS AND MOTIONS THAT WILL SHUT DOWN THE FORECLOSURE MILLS! -http://tinyurl.com/2g27vnp

ICE LEGAL! ICE, ICE, BABY! http://tinyurl.com/yansx5z and http://tinyurl.com/yfe7565 and http://ning.it/9yz7Ne and
http://tinyurl.com/yz6jgsj and http://tinyurl.com/ygu6apj

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! http://ning.it/8YimGt

Florida: A Collection of Court Orders and Opinions That Every Advocate MUST READ! http://ning.it/9r7ucV

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

Greg Taylor v. Deutsche Bank- Foreclosure Fighter George Gingo’s Masterpiece http://ning.it/9rLEZd

Ohio: http://www.foreclosurehamlet.org/profiles/blogs/11th-hour-rev...

MERS CA Decision: http://mandelman.ml-implode.com/2010/07/california-court-rules-mers...

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 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 http://ning.it/bzqHS7

Comment by L on August 25, 2010 at 6:50am: California Victory! http://ning.it/bkbTSY

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 http://ning.it/bq36BV

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 http://ning.it/68IIHx

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). http://ning.it/6o5PNz

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: http://wp.me/pFWnq-2kZ

The Motion Every Judge Should Read (And the one the foreclosure mills hoped would never see the light of day!)