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.

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.

Tools to use when defending your home

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

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

Admissions, Interrogatories & Productions

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

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

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

Comment

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Comment by L on March 3, 2010 at 3:33pm: 2nd DCA "ERROR IN SUMMARY JUDGMENT" Reversed & remanded!

Verizzo v Bnk of NY-SJ reversed[1].pdf

Comment by L on February 28, 2010 at 11:05pm: Foreclosure Case Killer- The Subpoena Duces Tecum

THANK YOU MATT WEIDNER, Esq. ANOTHER LAWYER FOR THE PEOPLE!

Comment by L on February 25, 2010 at 12:25am: ICE LEGAL! ICE, ICE, BABY! http://tinyurl.com/yansx5z and http://tinyurl.com/yfe7565

Lynn Szymoniak, Esq. A Lawyer for The People shares her exquisite work.

Comment by L on February 17, 2010 at 1:21pm: Florida: Opinions of the Judicial Ethics Advisory Committee
RE: Disclosure/Recusal/Disqualification

1st DCA allows recusal of judge based on bias towards Countrywide who gave the judge a preferential interest rate. (Pro Se defendant! Opinion Filed 02/05/2010)

Comment by L on February 11, 2010 at 10:34pm: Two other items of interest by Lynn E. Szymoniak, Esq., An Officer of Too Many Banks and another Too Many Jobs – Linda Green, Tywanna Thomas, Korell Harp and Shelly Scheffey.

Comment by L on February 6, 2010 at 8:13pm: An Article by A Non-Lawyer

Declaring the Emperor Naked: The Plain, Simple, Straightforward, Truthful Legal Analysis That None of the Lawyers Could See

A Florida Solution to the MERS Mortgage Foreclosure Crisis & Fiasco and why Every Foreclosure of a MERS Mortgage done in Florida deserves to be reversed (with some applications for other states).

Copyright Richard Plumer II 2009

SolutionMERSMortgageForeclosureCrisis-1.pdf

Comment by L on February 6, 2010 at 5:24pm: April Charney Case Granted Order Denying Plaintiff's Motion to Strike Defendant's Affirmative Defenses, Denying Motion to Dismiss Counterclaims, Denying Plaintiff's Motion to Strike.

Comment by L on February 6, 2010 at 4:09pm: Oh, SHAME ON YOU, Judge Herman Dawson! Allowing those illegal foreclosures in Maryland, evicting those families..http://tinyurl.com/ybuvm82

Comment by L on February 5, 2010 at 8:40pm: Lynn Szymoniak, Esq Expert witness testimony regarding fabricated Docx mortgage assignments and supporting evidence.

Szymoniak Expert Affidavit LS Expert Affdt.doc(2).pdf

KorellHarp Lots of high level jobs.pdf

Comment by L on February 2, 2010 at 5:03am: What we are up against.

A Florida Case

I'm pretty tired, so maybe I got this all mixed up. Looks like a homeowner had a terrible lawyer and lost his house in Circuit court, which was upheld on appeal where he apparently had a better attorney who raised the post-dated assignment issues and also raised for the first time the issues of fraud & securitization standing.

Then, he took his case up to the FL Supreme Court where the following two links show attorney for homeowner's petition and then Plaintiff's counsel Law Office of Marshall Watson's (foreclosure mill attorney) response.

The FL Supreme Court refused to hear this case due to lack of jurisdiction (to the best of my ability to figure out why there was no FL Supreme Court opinion was written).

Homeowner's Attorney's Petition to the Florida Supreme Court

Plaintiff's Foreclosure Mill Attorney's Response