1 Cynthia L.

Brown
P.O. Box 4806
2 Orange, CA 92863
(714) 618-2034
3

4 Defendant, In Pro Per

8 SUPERIOR COURT OF CALIFORNIA

9 COUNTY OF ORANGE

10
THE BANK OF NEW YORK MELLON, ) Case No. 30-2016-00861086-CL-UC-CJC
11
FORMERLY KNOWN AS THE BANK OF ) Judge, Timothy A. Stafford
)
12 NEW YORK AS SUCCESSOR IN )
INTEREST TO JPMORGAN CHASE BANK, )
13 NA AS TRUSTEE FOR STRUCTURED ) DEFENDANT CYNTHIA L. BROWNS
ASSET MORTGAGE INVESTIMENTS II ) ANSWER TO UNLAWFUL DETAINER
14
INC., BEAR STEARNS ALT-A TRUST 2006- )) WITH AFFIRMATIVE DEFENSES
15 2, MORTGAGE PASS-THROUGH )
CERTIFICATES, SERIES 2006-2, )
16 )
Plaintiff, )
17 )
vs. )
18 )
)
19 CYNTHIA L. BROWN, and Does 1 through 5, )
inclusive, )
20 )
)
21 Defendants.

22 ANSWER TO UNLAWFUL DETAINER

23 Defendant, CYNTHIA L. BROWN, (hereinafter referred to as Defendant or BROWN) answers
THE BANK OF NEW YORK MELLON, FORMERLY KNOWN AS THE BANK OF NEW YORK
24 AS SUCCESSOR IN INTEREST TO JPMORGAN CHASE BANK, NA AS TRUSTEE FOR
STRUCTURED ASSET MORTGAGE INVESTIMENTS II INC., BEAR STEARNS ALT-A TRUST
25
2006-2, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-2,
26 (Plaintiff or BSALT-A 2006-2) complaint as follows:

27
1. Defendant generally denies each statement of the complaint.

28

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ANSWER TO UNLAWFUL DETAINER
 1 2. NEW CENTURY MORTGAGE CORPORATION (New Century) a Secretary of State
2 (SOS) and Franchise Tax Board (FTB) suspended, made a loan (Loan) to Brown in November of

3 2005 secured by her residence located at 17841 Lincoln Street, Villa Park, California 92861
(Property). Brown executed a promissory note (Note) to New Century to document the Loan.
4
To secure the Loan, Americas Lending Group a brokerage company executed a deceptive Subprime
5
Loan with Brown, in a four party deed of trust (DOT) among Brown as Borrower, New
6
Century as Lender, FIDELITY NATIONAL TITLE COMPANY as the original Trustee and
7
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. (MERS), AS NOMINEE and
8 beneficiary. On or about November 18, 2005, by instruction of Osmon, Brown rescinded the
9 New Century DOT Loan for $500,000.00 and all its proceeds of $98,000.00 to Bank of America;
10 by wire transfer to Americas Lending Group account (an affiliate broker) by wire transfer to

11 Account No. 06251-08636 at 13:03; those funds were misappropriated, and were not returned to
Originator.
12
3. Instead, Osmon held rescission proceeds in his personal account, and failed to deposit funds
13
to original lender (New Century), keeping those proceeds for his own personal grain. Brown
14
having executed rescission of the subprime loan, Osmon and his partner Craig Ronald Dimond et. al.
15
would (Dimond or PRIVATE FUNDING PARTNERS LLC or PFP) devised another financial
16 investment scheme, to defraud and cause a injury to defendant Brown, by making false
17 misrepresentations of an investment to steer and induce Brown into signing additional documents
18 (Promissory Note and Deed of Trust) that were misrepresented, and later altered, Bait and Switched
19 with forged signatures.

20
The State of California, Department of Business Oversight was made aware of the issues
involving corporate securities fraud of Dimond and his company, and have conduct thorough
21
investigations and findings as such The trust deeds were fraudulent because they were forged and,
22
therefore, did not secure the investments that Dimond said would be safeguarded by the trust deeds.
23
See; Registry of Action (ROA) No. 22, tab No. 1, Request for Judicial Notice, Department of
24
Business Oversight - Desist and Refrain Order (DRO), pg. XX, line XX Dimond crew successfully
25 benefit by stripping the equity value from a million-dollar home with forged instruments Cal Penal
26 Code 115a, by taking unauthorized loans against Browns property in escrow without participation,
27 knowledge, or consent of Brown (Grand Theft - Cal PC 487).

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ANSWER TO UNLAWFUL DETAINER
 1 4. CRAIG RONALD DIMOND and PRIVATE FUNDING PARTNERS LLC (Dimond or
2 PFP) a Secretary of State (SOS) and Franchise Tax Board (FTB) suspended, made an [a]lleged

3 loan (Loan) to Brown on or about December 09, 2005 contending a secured interest by her
residence located at 17841 Lincoln Street, Villa Park, California 92861 (Property). Id. Dimond and
4
his partners (Michael Christopher Osmon Osmon or Unlicensed Broker, Kela Marie Holmes
5
Holmes or Unlicensed Broker, Denise Lynn Anderson Anderson or Licensed Broker , and
6
Christian Todd Fisher Fisher or Fidelity Natl Title Escrow Officer et. al.) aid and abet Dimonds
7
constructive Ponzi scheme to defraud Brown (investor/homeowner) of her property, with use of
8 misrepresentations of fraudulent and forged instruments.
9 THE PROMISSORY NOTE ASSIGNMENT DEED OF TRUST XXXXX, Brown was
10 instructed by Dimond and Holmes to sign documents that were misrepresented; thereby a promissory

11 note (Note) was executed unknowing of the scheme, but never delivered papers to Dimond or any
person alleging an interest. Dimond had his personal Attorney Bruce B. Osterstrom SBN XXX
12
(Osterstrom) to unlawfully record Dimonds forged DOT in Official Records, County of Orange
13
against Brown unbeknownst to her, and have the DOT mailed back to his law firm. Dimond did not
14
consummate a Loan to Brown, therefore an exchange of note for a loan never effectuate. It is still a
15
mystery how Dimond came into possession of the DOT instrument However, Dimonds crew
16 skillfully secured a Loan against Browns property with illegal use of her personal information,
17 leaving unconscionable financial obligation to Brown. (This Loan is fraudulent, forged and
18 misleading).
19 5. HOME LOAN MORTGAGE CORPORATION (Home Loan or HLM) a Secretary of

20
State (SOS) and Franchise Tax Board (FTB) suspended, made an [a]lleged loan (Loan) to Brown
on December 13, 2005 contending a secured interest by her residence located at 17841 Lincoln
21
Street, Villa Park, California 92861 (Property) less than 30 days after the New Century loan.
22
Brown did not execute a promissory note (Note) to HLM to document the Loan. In fact, an
23
Original Note has never been found, witnessed or verified for authenticity. To secure the forged HLM
24
Loan, a second brokerage company Loanleaders of America (LLA) executed a fraudulent and
25 forged four party deed of trust (DOT) among Brown as Borrower, HLM as Lender, FIDELITY
26 NATIONAL TITLE COMPANY as the original Trustee and MORTGAGE ELECTRONIC
27 REGISTRATION SYSTEMS, INC. (MERS), AS NOMINEE and beneficiary. (This Loan is false,

28 misleading and forged, because ALL proceeds from Brown property were given to Craig

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ANSWER TO UNLAWFUL DETAINER
 1 Ronald Dimond in Fidelity National Title Company Escrow No. 705702-CF, Dated 12/20/2005
2 amounting for $364,000.00 USD with discrepancies.)

3 6. LOANLEADERS OF AMERICA (LLA) a brokerage company executed a fraudulent and

forged four party deed of trust (DOT) among Brown as Borrower, HLM as Lender, FIDELITY
4
NATIONAL TITLE COMPANY as the original Trustee and MORTGAGE ELECTRONIC
5
REGISTRATION SYSTEMS, INC. (MERS), AS NOMINEE and beneficiary. LLA created a new
6
forged DOT by combining the rescind loan of New Century DOT with Dimonds forged DOT
7
without authority. [Citation] FORGED DEEDS -TWO DOT COMBINED
8 4. CRAIG RONALD DIMOND and PRIVATE FUNDING PARTNERS LLC (Dimond or
9 PFP) a Secretary of State (SOS) and Franchise Tax Board (FTB) suspended, made an [a]lleged
10 loan (Loan) to Brown on or about December 09, 2005 contending a secured interest by her

11 residence located at 17841 Lincoln Street, Villa Park, California 92861 (Property). Dimond and his
partners (Michael Christopher Osmon Osmon, Kela Marie Holmes Holmes, Denise Lynn
12
Anderson Anderson, and Christian Todd Fisher Fisher et. al.) aid and abet the creation of a Ponzi
13
scheme to defraud Brown of her property with use of forged instruments. Brown was instructed by
14
Dimond and Holmes to sign documents that were misrepresented; thereby a promissory note (Note)
15
would be executed unknowing of the scheme, but never delivered papers to Dimond. Id. Dimond did
16 not consummate a Loan to Brown, therefore an exchange of note for a loan did not effectuate.
17 However, Dimond skillfully secured a Loan with Browns personal information. Id. (The entire Loan
18 transaction is premised on false and misleading Predatory Lending.)
19 5. Hereinafter, [a]lleged loans were made, altered in concealment without written permission,

20
authorization or consent of Brown. It is clear material fact, with certainty, Craig Ronald Dimond and
PRIVATE FUNDING PARTNERS LLC et al. (Dimond or PFP) created and financially profited
21
by issuing forged instruments against defendant Browns property, for his/their personal gain.
22
Dimond and his crew are culprits of Identity Theft.
23
Plaintiffs cannot claim plausible deniability when they were given proper Notices by means
24
of Police Reports, Affidavits of Identity Theft, CFPB Complaints, FTC Complaints, Office
25 Comptroller of Currency Complaint amongst other agencies currently investigating Plaintiffs for
26 Corporate Securities violations in Securities Exchange Commission (SEC). Plaintiffs refuse to
27 acknowledge circumstantial injury verified by preponderance of evidence proven. All information is

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ANSWER TO UNLAWFUL DETAINER
 1 available, in compliance pursuant to the Identity Theft Resolution Act, Civ. Code 1785.16.2 (a)
2 effectively January 01, 2017.

3 Defendant brings compelling discovery supported by Department of Treasury - IRS, including but not
limited to the Fidelity National Title Company, Preliminary Report found in escrow, amongst other
4
incriminating discoveries Plaintiffs refused to produce and is currently in default for failure to
5
provide required discovery. The fraudulent conveyance of title is at issue when note(s) and deed
6
of trust are clear intent to defraud Brown by offerings of a false and forged Lost Note
7
Affidavit notarized by Notary Public Sangita Patel on XXXXX, 2005 (Cal PC 115a). It is
8 only the recording of an instrument entitled to be recorded which constitutes a crime under this
9 section. People v. Webber (1919) 44 Cal App 120, 186 P 406, 1919 Cal App LEXIS 473.; The gist of
10 the offense is the offering for record of a false or forged deed. People v. Standley (1932) 128 CA 739,

11 15 P2d 180, 132 Cal App LEXIS 587. Dimond represented to investors that their funds would go
towards secured investments, including, but not limited to, bridge loans that would generate high
12
rates of return. Furthermore, investors were told that their investments would be secured by deeds of
13
trust. In actuality, the trust deeds were fraudulent because they were forged and, therefore, did not
14
secure the investments that Dimond said would be safeguarded by the trust deeds. See; Registry of
15
Action (ROA) No. 22, tab No. 1, Request for Judicial Notice, Department of Business Oversight -
16 Desist and Refrain Order (DRO), pg. 01, paragraph 4, line 22-26.
17 6. Plaintiffs look to enforce a void HLM DOT created by Dimond, PFP and Loanleaders of
18 America (Pres. Martin B. Foigelman or Denise L. Anderson). The financial scheme involves
19 skilled participation of licensed and unlicensed brokers in real estate offices who created Table

20
Funding Loans in violation of basic principal of public policy and law (RESPA Input code).
During original ownership by Brown the property was secured with substantial equitable value at
21
grave risk with Predatory Lending schemes circulating in 2005-08. Plaintiffs sought to profit from
22
the fruits of a poisonous tree. Plaintiffs are not named parties in the contract, and 2) has self
23
assigned an interest by recording spurious and defective Assignment Deed of Trust in Official
24
Records, in the County of Orange (Document No. 2008000367084) known to be void . Title to
25 property is at issue; Plaintiffs have not met required validation of debt, pursuant to Cal Civ. Code
26 1788.50 and 1788.52 and 1788.17 which is currently in default. However, Plaintiffs rely on
27 summary proceeding in limited jurisdiction Court to waive legal standing arguments by presumption,

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ANSWER TO UNLAWFUL DETAINER
 1 without having to provided validation of a debt or a duly perfected title pursuant to Cal. Civ. Code
2 2924, 2925 or 2953 .

3 Brown is one of seven victims defrauded by Dimond, PFP Ponzi scheme. Beginning in or about
May 2006 and continuing through at least May 2008, Dimond and Private Funding Partners, LLC
4
offered and sold securities in the form of promissory notes in Private Funding Partners, LLC to more
5
than seven investors totaling at least $1,000,000.00. See; Registry of Action (ROA) No. 22, tab No.
6
1, Request for Judicial Notice, Department of Business Oversight - Desist and Refrain Order (DRO),
7
pg. 01, paragraph 3.
8
that is prohibited from California law [Citation] explain., and is commonly reference with criminal
9
activity, conspiracy and racketeering.
10

11 The entire complaint is premised from broker misconduct, altered and forge mortgage instruments
12 that would later be sold in commerce for selling, and trading in secondary markets with Wall Street

13
Secutitization; however, those instruments have been reviewed and determined as fraudulent, forged
and violates Corporate Securities Law of 1968. Knowing New Century Mortgage, Home Loan
14
Mortgage and Wells Fargo Bank practices at the time, it is virtually certain that the loan was
15
immediately subject to CLAIMS of securitization. The hidden problem is that the claims from the
16
REMIC Trust were not true, because Plaintiffs BSALT-A 2006-2 were given Notice a Suspended of
17
Duty to File Reports: Form 15 by the Securities Exchange Commission January 26, 2007, as
18 exhibited in the expert witness Declaration of Pamela Zander; See ROA 52, Notice of Stay
19 Proceedings, Notice and Supplemental Affidavit in Support of Cynthia L Brown; Exhibit A, pg. 5.
20 Plaintiffs trust never fund a loan to Defendant Brown, and never purchased the loan; therefore, a

21 Notice of Default should have never been recorded against property, because it is false.
7. Under the DOT, the Lenders rights regarding the Loan are pervasive. The Lender is entitled
22
to receive all payments under the Note and to enforce the DOT, including the exclusive right to
23
conduct a non-judicial foreclosure. Nowhere in the DOT contract mentions Plaintiffs, nor does it
24
mention Plaintiffs as an entitled interest party to an agreement; thereby makes Plaintiffs intruders to a
25
business transaction.
26 8. MERS had none of these rights under the DOT, and is not even mentioned in the Note.
27 MERS is not given any independent authority to enforce the DOT under its terms and MERSs status
28 as beneficiary under the DOT is only nominal.

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ANSWER TO UNLAWFUL DETAINER
 1 9. There is no lawful assignment of deed of trust assigning any beneficial interest at all in the
2 note and deed of trust from NEW CENTURY to HOME LOAN MORTGAGE CORPORATION

3 (HLM) to WATERFIELD MORTGAGE CORPORATION or The Bank of New York Mellon

(BSALT-A 2006-2). In fact, the HLM DOT is at issue, because it is fraudulent and forged. The HLM
4
DOT a second DOT created by Craig Ronald Dimond and PFP Ponzi-scheme.
5
10. In 2006, Craig Ronald Dimond, president of PRIVATE FUNDING PARTNERS LLC. (a
6
Secretary of State suspended business), Michael C. Osmon, President of START UP BUSINESS
7
CAPITAL LLC. (a Secretary of State suspended business) and Kela M. Holmes, President of
8 CREATIVE BUSINESS ENGINEERS LLC. (a Secretary of State suspended business), deceptively
9 induced defendant Brown into false contracts which never performed, and are related to injurious
10 predatory lending Ponzi schemes which financially targeted Brown that led to an afore thought of

11 identity-theft.
11. Dimond, through Private Funding Partners, LLC, provided to investors short-term
12
promissory notes that ostensibly were secured by deeds of trust. Those promissory notes stated that
13
investors would receive a fixed rate of return between nine percent (9%) and nineteen percent (19%)
14
per annum. Dimond represented to investors that their funds would go towards secured investments,
15
including, but not limited to, bridge loans that would generate high rates of return. Furthermore,
16 investors were told that their investments would be secured by deeds of trust. In actuality, the trust
17 deeds were fraudulent because they were forged and, therefore, did not secure the investments that
18 Dimond said would be safeguarded by the trust deeds. See, DRO, paragraph 4.
19 13. Dimond, through Private Funding Partners, LLC, would convince investors to roll-over their

20
promissory notes upon maturity into new promissory notes. See, DRO, pg.1, paragraph 5, pg. 2, and
line 1-2. Id.
21
14. On October 31, 2014, LSI Title Company recorded a false Notice of Default, claiming that
22
Defendant was in default for her monthly obligation under the promissory note and deed of trust that
23
provided security for the loan alleged above. LSI Title Company had no authority or capacity to
24
declare a default.
25 15. Per the Orange County Recorders Office a Substitution of Trustee executed by CHINA
26 BROWN as Vice President Loan Documentation for Wells Fargo Bank NA as its attorney in fact
27 (Assistant Secretary of MERS), recorded on May 30, 2007, appointing NDEx West LLC as trustee.

28 CHINA BROWN is a well-known robo-signer and has already been deemed a forger in court, XXX

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ANSWER TO UNLAWFUL DETAINER
 1 as trustee. SCOTT W. ANDERSON is a robo-signer and has already been deemed a liar in court,
2 HSBC Bank USA, N.A. v. Valentin N.Y.Sup.,2008.

3 16. Due to a lack of assignment of deed of trust, no entity past who was named on the original
deed of trust had authority to conduct ANY foreclosure against the property. The complete
4
foreclosure is entirely VOID. The deed of trust expressly reserves the right to the Beneficiary to
5
cause the Trustee to execute written notice of the occurrence of an event of default and of Lenders
6
election to cause the Property to be sold. The deed of trust further provides that the Trustee shall give
7
public notice of sale to the persons and in the manner prescribed by applicable law. Theses express
8 provisions of the deed of trust are impossible to comply with amidst the fraud.
9 17. Foreclosing parties lacked power of sale as of the recording of the Notice of Default on
10 October 31, 2014. Per the deed of trust paragraph 22, only the lender can invoke foreclosure, and the

11 foreclosing parties were not the lender, so the Notice of Default is void and of no force or affect. The
power of sale in a non-judicial foreclosure may only be exercised when a valid notice of default has
12
first been recorded. See Cal Civ Code 2924; see also 5-123 California Real Estate Law & Practice
13
123.01. Here, the Notice of Default appears to be void ab initio. Therefore, any foreclosure sale
14
based on a void notice of default is also void. Accordingly, the Plaintiff lacks standing to conduct an
15
unlawful detainer predicated on a void foreclosure sale as a direct result of noncompliance with
16 prerequisites to engage in a foreclosure sale set forth in Cal. Civ. Code 2924 and the Deed of Trust.
17 18. Castillo v. Skoba, Vice President of Aurora Loan Services, LLC 2010 WL 3986953 (N.D.
18 Cal., November 30, 2010), the United States District Court in San Diego held (in granting an
19 injunction to halt a foreclosure sale):

20
Plaintiff is unlikely to succeed on the merits of their claim that neither NDEx West LLC nor
BSALT-A 2006-2 had authority to initiate the foreclosure sale at the time the Notice of Default
21
was entered. Under Cal. Civ. Code 2924(a)(1), the trustee, mortgagee, or beneficiary, or any of
22
their authorized agents (Dimond crew) are unauthorized to file a notice of default. Documents do
23
not support a factual finding that either NDEx West LLC was the trustee or BSALT-A 2006-2 was the
24
beneficiary on October 31, 2014 when the Notice of Default was recorded, and the accounting has
25 severe discrepancies.
26 On a document dated *May 17, 2010, MERS substituted Cal-Western as a trustee under the deed of
27 trust. If NDEx West LLC had been trustee at this time, it would have had authority to conduct the

28 foreclosure process, but it did not. See Cal. Civ.Code 2924(a)(1). However, this document was

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ANSWER TO UNLAWFUL DETAINER
 1 notarized on June 7, 2010, (id.), and thus it appears unlikely that Plaintiff can succeed on a claim that
2 the substitution occurred no earlier than June 7. Similarly, on June 8, 2010, MERS, the beneficiary

3 under the deed of trust, executed an assignment of its beneficial interest to *Aurora, with a
backdated effective date of May 18, 2010. Based on the face of this document, Plaintiff is unlikely
4
to prevail on a claim that Aurora did not have authority to record the Notice of Default on May 20,
5
2010. See Ohlendorf v. Am. Home Mortg. Servicing, No. CIV. S-09-2081, 2010 U.S. Dist. LEXIS
6
31098 (E.D.Cal. Mar. 30, 2010) (recipient of backdated assignment may not have had authority to
7
record Notice of Default). Castillo v. Skoba is a controlling case here, due to the fact that the
8 foreclosing trustee was not the trustee with power of sale as of the recording of the Notice of Default
9 and the fact that securitization research proves that the purported foreclosing beneficiary was not the
10 true lender/beneficiary of the Deed of Trust with power of sale to invoke non-judicial foreclosure.

11 19. Finally, Plaintiff and the Court must be reminded that Cal. Civ. Code 2924 is not triggered
until compliance with the power of sale provisions mandated by the Deed of Trust has been met.
12
Strangers to the transaction and controlling loan documents cannot record spurious documents
13
against the property in the county recorder's office and then oppressively declare that they have
14
complied with Cal. Civ. Code 2924, therefore the foreclosure is invalid.
15
20. In the case of a transaction predicated on a void instrument California law is settled. The
16 Court in This sentiment was clearly echoed in 6 Angels, Inc. v. Stuart-Wright Mortgage, Inc. (2001)
17 85 Cal.App.4th 1279 at 1286 where the court stated: It is the general rule that courts have power
18 to vacate a foreclosure sale where there has been fraud in the procurement of the foreclosure
19 decree or where the sale has been improperly, unfairly or unlawfully conducted, or is tainted by

20
fraud, or where there has been such a mistake that to allow it to stand would be inequitable to
purchaser and parties.
21

22
AFFIRMATIVE DEFENSES
23
FIRST AFFIRMATIVE DEFENSE
24
The complaint and each of its causes of action fail to state facts sufficient to constitute a cause or
25 causes of action because:
26 BSALT-A 2006-2 and their agents failed to comply with or misrepresented their compliance with the
27 requirements under Civil Code 2924

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ANSWER TO UNLAWFUL DETAINER
 1 SECOND AFFIRMATIVE DEFENSE
2 Plaintiff lacks duly perfected title to the property.

3
THIRD AFFIRMATIVE DEFENSE
4
Plaintiffs trustees sale was invalid, Brown has an interest in the Property which vitiates the
5 Unlawful Detainer proceeding.
6 FOURTH AFFIRMATIVE DEFENSE
7 This Court is an unsuitable forum to try complicated ownership issues:

8 California Judges Benchguide: 31.26

9
(8) Title is at issue. The litigation is between a plaintiff-lender and a defendant-homeowner, rather
than between landlord and tenant, and title is at issue. Mehr v Superior Court (1983) 139 CA3d
10
1044, 1049, 189 CR 138 (because of summary nature of unlawful detainer proceedings, it is
11
unsuitable forum to try complicated ownership issues); Asuncion v Superior Court (1980) 108 CA3d
12
141, 145146, 166 CR 306 (eviction of homeowners following foreclosure raises due process issues
13 and must be heard in superior court).
14
FIFTH AFFIRMATIVE DEFENSE
15
Lack of Standing/Real Parties in Interest.
16
Plaintiff was not the Lender with the right to enforce the Deed of Trust.
17

18 SIXTH AFFIRMATIVE DEFENSE

19 Willful Misconduct

20
SEVENTH AFFIRMATIVE DEFENSE
Misjoinder of Parties.
21
EIGHTH AFFIRMATIVE DEFENSE
22
Unclean Hands. California Civil Code 3517.
23

24 NINTH AFFIRMATIVE DEFENSE

25 Fraud.
TENTH AFFIRMATIVE DEFENSE
26
Unconscionability.
27

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ANSWER TO UNLAWFUL DETAINER
 1 ELEVENTH AFFIRMATIVE DEFENSE
2 The complaint and each of its causes of action are barred by the failure of
Plaintiff to comply with all conditions precedent.
3

4
RELIEF REQUESTED
5
DEFENDANT REQUESTS that Plaintiff take nothing requested in the complaint and recovers all
6 expenses for litigation, and wrongful foreclosure.
7

8
Date: January 12, 2017 _________________________________________
9 CYNTHIA L. BROWN
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ANSWER TO UNLAWFUL DETAINER
 1 VERIFICATION
2 I am the defendant in this proceeding and have read this answer. I declare under penalty of perjury

3 under the laws of the State of California that the foregoing is true and correct.

4
Date: January 12, 2017
5
_________________________________________
6 CYNTHIA L. BROWN
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ANSWER TO UNLAWFUL DETAINER
 1 PROOF OF SERVICE
2
I am over the age of 18 and not a party to this action.
3
I am a resident of or employed in the county where the mailing occurred; my
4
business/residence address is:
5
______________________________________________________________________________
6

7
On January 12, 2017 I served the foregoing document(s) described as:
8

9 ANSWER TO UNLAWFUL DETAINER WITH AFFIRMATIVE DEFENSES

10

11 to the following parties:

12 Plaintiffs and their Attorneys;

The Bank of New York Mellon, BSALT-A 2006-2.
13 Leslie M. Klott and Dennis M. OConnell
14 30 Corporate Park
Irvine, CA 92606
15

16 By U.S. Mail I deposited such envelope in the mail at ______________________ , California

17 with postage thereon fully prepaid.

18
I declare under penalty of perjury under the laws of the State of California that the foregoing
19 is true and correct.
20

21 DATED: ______________ _________________________________________

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ANSWER TO UNLAWFUL DETAINER