Professional Documents
Culture Documents
Affidavit - Chris Collins V.P. JPMC-re. Zarro Affadavit, July 27, 2011
Affidavit - Chris Collins V.P. JPMC-re. Zarro Affadavit, July 27, 2011
I IN THE MATTER OF
RESIDENTIAL MORTGAGE
GENERAL EQUITY PART
MERCER COUNTY,
Civil Action
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F I LED
I JUL 2 8 2011
SUPERIOR COURT
I CLERK'S OFFICE
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I AFFIDAVIT OF CHRIS COLLINS
ON BEHALF OF
I JPMORGAN CHASE BANK, N.A.
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I D82/22579035 1
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I STATE OF OHIO )
) SS:
I COUNTY OF FRANKLIN )
I, Chris Collins, being duly sworn, depose and state the following:
foreclosure litigation.
I 2. I have read the affidavits of Michael Zarro dated January 5, 2011
I and April?, 2011, and agree with the content of those affidavits.
showing to the Honorable Ri chard J. Williams, lA.D. (ret.). I address below certain
I cases where Chase acts as servicer of the loan, and in particular, the court cases listed in
I 4. Chase's parent, JPMorgan Chase & Co., acquired The Bear Stearns
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I 6. From the time of the acquisition until April 1,2011, EMC operated
I as a separate legal entity. However, foreclosures of loans serviced by EMC followed the
same general processes, procedures, and document execution practices of Chase and its
to a Delaware limited liability company and changed its name to EMC Mortgage LLC
I ("EMC LLC"). Copies of the Certificate of Formation of EMC Mortgage LLC and
corporation) to EMC Mortgage LLC (a Delaware limited Iiabihty company) are annexed
I Agreement, and related documents, are collectively attached hereto and incorporated
herein as Exhibit C.
I 9. From March 2008 until April 1,2011, records for EMCIEMC LLC
I loans were maintained by EMC under Chase's control, management and superviSIon.
I processes, procedures, and document execution practices outlined in the January 5, 2011
and April 7, 2011 Zarro affidavits have applied to the EMC portfolio since the inception
I of the processes, procedures, and document execution practices.
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I II. All foreclosure related affidavits and certifications executed by
I Chase w ill reflect that the loan is serviced by Chase, and to the extent necessary, all
I 12. The loans formerly serviced by EMC are included in Chase ' s
I the servicer of the residential mortgage loans previously serviced by CHF. Annexed
I and Chase described in Paragraphs 9 and 30 of the April 7, 2011 Zarro affidavit.
Chase will reflect that the loan is serviced by Chase, and to the extent necessary, all
I procedures will be updated to reflect this change.
I 16. The processes and procedures detailed in the January 5, 201 I and
April 7,201 I Zarro affidavits are otherwise unaffected by the merger or CHF into Chase
I and any representations Mr. Zarro made concerning the practices of CHF apply to Chase.
I 17. The loans formerly serviced by CHF are included in the Chase
I Servicer Portfolio.
I DB2/ 2257903 5 1
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I Document Execution, Data Integrity and Third Party Vendors
residential mortgage foreclosures for the Chase Servicer Portfolio are executed "in
I house" by Chase employees. Chase does not outsource its sworn document execution for
individual loan (i.e - Chase has been the servicer s ince the loan's origination, Chase
I acquired the servicing post-origination, Chase acquired the servicing from EMC or CHF);
or (b) who owns the beneficial interest in the loan (Chase, a Government Sponsored
I Enterprise such as Freddie Mac or Fannie Mae, or a private investor), for all loans
I identified in the Chase Servicer Portfolio, Chase is relying on the MSP system described
in the Zarro affidavits to store, retrieve, and otherwise access critical loan data.
I 21. Moreover, all loans identified in the Chase Servicer Portfolio are
I handled through the foreclosure processes and document execution procedures set forth
I the January 5, 2011 and April 7, 2011 Zarro affidavits, and this affidavit . When
documents such as Certifications of Proof of Amount Due are executed, the Chase
Chase document execution employee is currently approximately 5-6 per day. More
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I experienced employees are processing about 10 per day, and the most that have been
I executed by one person in one day under the enhanced procedures described in the Zarro
affidavits is 13 (this was done by a very experienced employee). There are times when a
I a day.
I Chase has approximately 331 pending foreclosure matters in New Jersey based on home
I equity loans. Home equity loan data is maintained on a computer system known as
I Certifications of Proof of Amount Due based on a review of that system. While the
I systems and screens accessed to complete foreclosure documents for home equity loans
are different from those used on first-lien loans, Chase will follow the same general
I processes and procedures previously described to ensure that the Chase employee
I executing the document has personally reviewed the data and has the requisite personal
action either (a) in the context of a forbearance agreement or other loss mitigation plan,
I or (b) outside of such context.
I or other loss mitigation plan, the payment is recorded in MSP . If the forbearance
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I applied to the account will be reflected in the amounts due set forth in the Certification of
I files In the Chase Servicer Portfolio, any forbearance payments that may have been
I applied during the moratorium on accounts where forbearance was unsuccessful will be
captured on the new CPAD. Further, Chase will develop additional procedures to help
I ensure that counsel is advised ifforbearance payments are applied between the time the
(i.e., within 60 days of current status), the foreclosure action will be terminated . If the
I pay ment is less than that amount, Chase will return the funds to the borrower.
I communicate and escalate issues as needed to Chase, including dedicated Chase liaisons
30. Chase has developed the following plan to comply with the
I Supreme Court Order (the "Order") and court rule revisions issued on June 9, 2011.
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I 31. For each pre-judgment file in the Chase Servicer Portfolio, Chase
I intends to execute a new CPAD based on Chase's enhanced processes and procedures,
I the complaint, Chase's systems, the note and the mortgage (and recorded assignments, if
any) to confirm the accuracy of the core facts alleged in the complaint. The reviewer will
I record the results of the review on a written statement. This statement of review will
I contain the name, title and contact information for the reviewer.
33. The written statement of review will be imaged into LPS Desktop
I for counsel's review, and a message confirming the transmission of the image will be
I sent to counsel through LPS Desktop's " intercom" function, an electronic messaging
system that provides for direct, two-way, personal communication between foreclosure
I counsel and the reviewer. Foreclosure counsel will be able to raise any follow-up
I questions, comments or concerns with the reviewer through "intercom" or the contact
information set forth on the statement of review. The communications with counsel will
I be privileged. However, Chase will maintain a copy of the statement of review for
I above as well as a similar review of the CPAD submitted in support of the judgment.
Chase will communicate the results of the review in the same manner described above for
I pre-judgment files .
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I 35. Finally, on a go-forward basis for new cases, a representative of
I Chase will review each complaint and each CPAD, together with Chase ' s records, the
note and the mortgage (and assignments, if any) to confirm the factual accuracy of the
I complaint and CPAD. Again, the results of the review will be communicated through a
written statement transmitted through the LPS Desktop " intercom" function, and Chase
I will provide contact information for the reviewer so that counsel can address any follow-
I up questions.
described above, foreclosure counsel and Chase are in regular communication with each
I other through phone calls, e-mail and the oversight program described below. Thus, to
I the extent any questions arise that cannot be resolved with a reviewer, there are multiple
I bankruptcy management. That team was also responsible for auditing the performance of
I each law firm through on-site visits. In order to exercise greater supervision of our
foreclosure and bankruptcy attorneys, many changes have been made (and continue to be
I made).
team is responsible for managing the overall relationship with foreclosure counsel. This
I group is in constant contact with foreclosure counsel, and questions from counsel can be
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I 39, Second, Chase has established an independent team to conduct on-
I site audit review of foreclosure firms, This group does not report up through foreclosure
I 40, Third, Chase has created a new attorney management group within
I Chase's Legal Department, known as the Attorney Oversight Group ("AOG"). The AOG
conducts its own on-site visits (separate from the audit team), reviews policies and
I foreclosure management
I currently comprised of eight (8) attorneys, plus a supervising attorney and managing
attorney, In addition to these ten (10) attorneys, Chase is currently interviewing and
I plans to add another two (2) to four (4) attorneys in the immediate future.
I 42. Over the past several months, the AOG has developed a robust and
proprietary process for the supervision and oversight of local counsel, which includes
I regular on-site visits several days at a time.
I 43. No practices that Chase will agree to with any regulators will be
I substantially different than what has been set forth in the affidavits filed by Chase in
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1 I declare under penalty of perjury under the laws of the United States of America
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1 that the foregoing Affidavtt is true and correct. Executed on the
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Chris Collins
1 Vice P_ldent
STATE OF OHIO )
1 COUNTY OF FRANKLIN
) SS:
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1 I HEREBY CERTIFY that on this day personally appeared before me, an officer duly
authorized to adminis~er oaths and take acknowled ments in the County aforesaid,
Chris Collins , 0 is ersonally know to me or produced
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1 Melissa Hammock
Notary Public
My commission expires: VV\rui Ll,lOI:>
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MEUSSA HAMMOCK
1 NoIaIy Pub!'1C. Stale 01 Ohio
My Comm. Expires May 4, 2015
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'lJe [awa re PAGE 2
%e ~irst State
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I, JEFFREY W. BULLOCK, SECRETARY OF STATE OF THE STATE OF
I DELAWARE DO HEREBY CERTIFY THAT THE ATTACHED IS A TRUE AND
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I 2242339 8100V AUTHE"",,""'A'I'
DATE· 03-28-11
110344567
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State ox Ll9.1swa.re
I Secretary oX State
Division of Corporations
Delivered 08: Sl AM 03/28/20ll
FILED 08: 47 llH 03/28/2011
SRV 11.0344567 - 2242339 FILE
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CERTIfiCATE OF FORMATION
I OF
I The undersigned, being dul} authorized to ext:Cute and file this Certificate of
FOml:ltion, does hereby certify as follows:
I (the "Comp:lnY-).
I. Nrune The name orthe limited nubility company is EMC Mortgage LLC
I In
2. Registered Office and Registered Agent. The Company's registered office
the State of Delaware is located nt 1209 Orange StreeL CIty of Wilmington, County of New
Castle, State of Delaware, 1980 I. 1l.c I~gistcrcd agent of the Company for service of process at
such address i, The Corp()ration Trust Company.
I 31,2011
3. Effective Time. This Certificate of Fommtion shall be effective 0[1 March
I Formation iU,
IN WITNESS WHEREOF, the undersigned has duly executed this Certificate
of March 24, 20[1.
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I Name: Lauren V. H:Ul1S
A.n Authorized Person
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'lJe [awa re PAGE 1
%e :First State
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I, JEFFREY W. BULLOCK, SECRETARY OF STATE OF THE STATE OF
I DELAWARE DO HEREBY CERTIFY THAT THE ATTACHED IS A TRUE AND
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CORRECT COPY OF THE CERTIFICATE OF CONVERSION OF A DELAWARE
O'CLOCK A.M .
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I 2242339 8100V AUTHEN
jeffrey W Bulloc k. Seuctaf'/ of Sfate
TION · 8653511
DATE : 03-28-11
110344567
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State Delaware
Secretary of Sta te
Divi.sion of Cozporati01l.5
DE>live.red 08:'1 AM 03/28/2011
YIL1lD 08: 47 AK 03/28/2011
SRV 110344!l67 - 2242339 FILl!
I CERTIFICATE OF CONVERSION
CONVERTING
TO
I EMC MORTGAGE LLC
(a Delaware limited liability company)
I lbis Certificate of Conversion is being filed for the purpose of converting EMC
Mortgage Corporation, a Delaware corporation (the "Converting Entity"), to a Delaware limited
I liability company to be named "EMC Mortgage LLC" (the "Company") pursuant to Section 18-
214 of the Delaware Limited Liability Company Act, 6 Del. C. §§ 18-101 el seq. (the "Delaware
LLC Act''), and Section 266 of the General Corporation Law of the State of Delaware, 8 Del C.
§§ 101 el seq. (the "DGCL").
I The undersigned, as an authorized person of the Converting Entity and the
Company, does hereby certify as follows:
I 1. Name of Converting Entity. The name of the Converting Entity when
incorporated was "Southwest Equity Mortgage Corporation" The name of the Converting
I Entity immediately prior to the filing of this Certificate of Conversion was "EMC Mortgage
Corporation."
I Jurisdiction
I nwne set forth in the Certificate of Formation of the Company filed in accordance with Section
18-214(b) of the Delaware LLC Act is "EMC Mortgage LLC."
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March 31, 2011.
Effective TIDIe ThiS C~rtificate of Conv~rsioll shall be effective on
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I IN WITNESS WHEREOF, the undersigned has duly executed this Certificate of
Conversion as of March 24, 2011.
BMCMORTGAGE COlU'ORATION
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I 2852825
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Assignment and Assumption Agreement
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I FOR VALUE RECEIVED. EMC Mortgage LLC ("Seller') hereby ",lis. Jssigns.
delegates and transfels to .IPMorgdll ClIa,c Bank. N./\. ( 'Buyer") all of Sellers nghts
and Jutit-s a~ Sr..:f\'lu:r and/or master scrvicer LInder thos.e ccrtam Pooling and ScrnclIlg
Agreements or other servIcing agreements (each. a "ServIclng Agreement") rclattng to
I those ~ecllntlzation transactions to which Seller is a party. plovided. however. that Sdkr
,hall rctaIn any and all duties. l)bhgatiuns dnd liabIlities (I) relating to any servicing
actiVity "ecurnng pnor to the Effective Date Iii) relating to any IIabIllt} With respect to a
I hrcach of any mortgage loan rcprcscntatlOn or warrant~ or ItS rolt: as ~ponsor or u seller
or the mortgage loans 10 the related ,,,cunt,,ation transaction and (iii) retained by 01
excluded lrom the M,seh sold to Buyel rrom Sdk, pu",uant to or 111 accordance \\ lIh that
I (cl1am Purchase and Sale Agreement between Buyer and 'ieller dated as of the Elfective
Date
I Buyer here b) agree, to ""umc the duties. obligation, and IrabllItle\ or SelicI'
!:tole-I) in ib CapaCIl) dS sc..;I\'lleI ulH..h.:r thl.! rcl..ll~d PSI\ :-.uh.lcc:t lO the plcccding !-.cnh.'IH.:C
to the i.>'\1enl n:quin:d to (:(fCCl tl'(ln . . fl'f ofScllcr"s . . ervlcmg obligatIons under such P';A
I I", WITNE'iS \vHERI~()r. the partie, ha\e c'\eeuted tim !\,slgnlllelli ,lIlel
A,Slllnpl!On Aglecment as 01 ,\pld !. ~O II (the' Llkcl!\'c Date')
I By: I·~~~
Name: -;-',
>
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>'~-' 1,,\
I Title: I.
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I OFFICER'S CERTIFICATE
Oil vlarch :; I. 20 II. I:Me t\1ortga!!c Corpol ation con\ ened Ihe buslllc>s
I ~ On /\pnl 1.20 11 Ithe "Clo;,illg Datc") [, Me shall transfer all rights and
obltgallon, with IcSpetl to the servicing andlor master serv lc lI1g. as appltcahle. (the ''Transfer'')
wilh respect to each Transaction lO Chasl..~
I 3 rhe '1ran,lcr to Chase is pcrml lled hy and cnmplie, \\lth the tcnm ,)1' Ihe
'k:ryi\.lIlg Agn..·CIllClll~ ,mJ Clld~C agret:~ 10 be bOlillU by the term., <1IHJ LUIJ(Jilloll~ or the n.:lalcti
I Scn.lcmg J\grl..!cment
4 As o1'lh(..· Clo,)lIlg Date. the followmg conditions wll' he true and correct
I b. Chase i, qualtfied to ,cn' icc mortgage loans for FallOle Mac and Freddie
~Iac dnd i, 111 good ,tandlllg with FanOlc Mac and Freddie 1I'lal: .
I 5 CapltdiILcd lem" DOl defined herein ,hall ha ve the m,'aning' pro\ ided 10 the
reluted Scrvlc1Ilg Ag.rccmcm
I 1:-.1 W ITI"ESS WIIERf·:OF. the underSIgned h'L, "t his hand hcrcunw thl" day or Apnl I.
20 11.
-:'
I By'
'1'1110 ..
,. '., .:-::'./ ,
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I orFICTR'~ CEJ{ "III ICA I f:
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of
EMC "'lOR IGJ\(,E l LC
Thl ~ C.:nltiCJlt: ,., b\.' lIlg dchva :.:u 1(,1 SNR Dellton l JS I .I .P ("5)\; R Denton ) for rcii :m cc
I h~n.:on by SNR Denton III rendering Jl!- OP lOl\lI1 klll..'1 to \\IIII.. h Ihl~ Certific ate I~ anne~cd ([h~
. Opin 1011 l clter""), rht.' tl nd cr!>i gn~d unJ l: r~t,Ulds. ~ckl1 o ..... lcdgt:!I dIlt.1 d!!on.:"':!1 lildt tIle fact:-. ~t: ( forth
the Opmiol1 I.('licr and tlll~ Ccrtlficat~ dre bClIlg relied upon b) ~NR Demon ill renderlllg the OO!lllon
In
LCltl!f and by each addressee thereof and ot h'.:r p.lrtlC!<I1 0 th e l1an~dcti on~ to \..'hich tht! Opinion Le:lta
I relates In the consummation of those trJ n Sd Ctloll~ Cdpnal,,:ed terms not ddin\.'J herein have rhe
meanings as~" gncd to them III the. 0plJllOn Lt' lIr Tand the Agreements Id entllied in Schedule 2 (the
"Agreements") CO the Opinion Lette r. '( he undersigned hl.:n: b) H,;prc~cnt$ . \\arrants. covenants and
certific .... after reasonable InvestigatIon and re\,IeW and ("ollslIltalion it!> applOprmtc \\ nh ItS at:orncys•
I .1::, follows'
rhc ulldt:r~ign~d I.... H du ly dcctcd o fficer of EMC Mongagc 1.1 C (lhe "Comp.my")
I 2 III 2009. the Com pall) del ive red reqm.''\ts lor consent to I.'..lch 01 lIiI.! p,lnll:" (the
"Rl'LlllIfl'" Partie''; ') rl.:quln:d under IhL' rl'I!Hl'J SL'(tJOrl 01 thl: n..'lalcd Agr.... l·mclll Identtfil'd In Schcdult.!
1. to the OpinIOn Lettt'r n:q uc ':>t lng that ~lIch Keqwrt:'d Pany c.-o nsen! ( Consent ') to the tran<., It:J 01 the
I (. om pd ny ... ..;en Iring. oh hgall clIN ( '",eh tfdn"fer, Ih~' SL'rVIClng. r ran~ rcr ') 10 IP\1organ l h;I'\C' Ha nk
I'\allon:11 A~<;Ol'lmlon und er c.lCh .. \I(h Agrt.!C'menl "\Je h C'<Ul<.,ent" h.\\'c het"1l Tc."cel \cd hy the COlllr.Ul~
frolll each ReqUired Parry
I 3 In 2010, the Compnll) dI'IIH..'led llotllicrH lons lthr' NOlllicatlOlls") to ('u",'il o! the
ReqUIred PanIcs ~t,lIing Ihut tht: Servlcmg Trull~lt! r WJ!> rescheduled to O\.:cur on DL~ccmhcl 3 I 2010
dnel nOfl(vJIIg Ihe ReqUlrl'd Panl"::' ,jMt Ihe ('omp.IIl)o \Va:- Inlcndlllg to rely on the C i,,ln ~Jlts proVIded
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th\.' ReqUIred J'm1 1\'"
I he Comp<ll1: ICLc!ved lklr\'cr~ l onlirm.1I 101l that (,deh Notrlh.H llOlI Wlb l~cC:I\ t!d b~
I 5, A . . o! the ddte here-uL the Company ha~ not rc('cl . . . ..:d <my ObJ c.!'l-tlO!1 frolll (he
ReqUIred Pdnlc!. wIth rc.!'spcci to the Servicing, rransfcr.
6 All of the J{..;quircd Panics WIll be Ilortticd thal lhe ServIc ing rTans fer has occurred
I on or about Arnl I. 20 11
7 On or pncH to the dJl~ hereof ~I! docum ent:; <lI1d other dI!lIVl!lablc~ r\!qulred under
'l-tC r(,latcd h,grcclllC"tlt hzt\'c bc·.:: n dL'!tvcrl'd 10 thl! appllL abk' ~C!PI(,!tH<". I11duJmg all Rt'qlPrcd PartIe:.
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I I~ WI fNESS \VHCHLOF. Ihl .. omCcr'~ Ccrtlfic:lIc h~ls been duly c:\ccUlcd and delivered as
oflh~ I Sld,lyol I\pnl.2011
I l-.MC VlOR'I CAGE I.I.C
.! '_,~____,_..____,_______'. _
I Ilv
"ame' Robert Blanken;hip
Tltk' VIce Prc.;;aicnt
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I 'lJe[aware PAGE 1
COMPANY,
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I 4974675
DATE: 04-28-11
You n:ay ver~fy C1U5 C9IC~fl.Cdt9 onll.ne
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St.4te of Del~W4re
I Secretary of State
Div~sion of Cozpo.rations
Delivered 06.03 PM 04/27/2011
FILeD 06:04 PM 04/27/2011
SRV 110463889 - 3881786 FILE
I (a national banking "ssodation urg.nlfcd under the la"s of the United St.tes of AII.erica)
Pursuant 10 Tille 6. Sectl(ln 18-209 (lJ'the Del,,,,"re 1.,mlled LIl.bJillY ACI anJ pu,, ""n ( (0
I the I"" of Ihe Unilcd States of Amenca. Ihe underSIgned nallonal as,ocwllon .'<cute' Ihe
liJ! !OV.lllg Ccrti licat. of /Viol ger
I FIRST The name ufthe 'UrYlVI lIg elltity IS JPMorgan Chose Bank. NulIUI,.!
A ssoetatlon. 2 nallonal ban"mg as 'OctaUOH organilcd and e",l mg under the laws of the United
States of Amen.a. and (he name of the I,mlled Itablhty compan) being merged Into the surviVing
SECOND The Plan and Agreemcnt of Merger hds been a pproved. adop lcd ccnif1cd
-rHIRD. Tht name ollh" SU[\"'IlIg <HlIl}.s JP:Vj org.m Cha,,, Bank . N.l l.olldl
<1 natIOna l bunkmg us:,oci.:itlOn orgunJD.:d and t:xl.\ting um.Jer the l.:i\-\':-' 01 lh\': UlJltcd
A))oc.;lallUIl.
I State .. of -\mcricu
FOURTH ' The Chaner of JPMorgan Chase lboh . Na llOoa l ""oci.lt loo shall eonllOue
I SIX'III fhe Plan and Agreemenl of Merger" on lile al 194 \\'0,,<1 A venue Soulh.
J!>C IIIl New J(·rsl.!'j OX8 :)O, a place of hU\IIlI!S';; of the ",urv\vlng C'ntlt)'
I SFVri\TH A copy of lhc I'lan and I\ grcemclll of ,\Jerger "'il l be Iurn»bed by .hc
survJvl!lg entll;., lJpOn reyllc~t and Without cost. to an) member of an~ domestic limited ilabllllY
compan) or Jll'y person holdmg an mtert.:st IIJ an)-' othc:r buslll4!~~ entit y \\I1lch tS 10 merge: o!
I consoilCJatc
E1GItTH JPMorgan Ch"e !:Ian!.., /\Jallonal As;o<l al'Qn.lhe ,urv.vmg cnllty "l(rtt;
I thJt It may bl: ~eT\'cd \\Jth process HI the State of Dcld.w.uc.! 111 any (',(lIOn. suJt or proct'cdmg for
the enfl)(ct."meOi of any ohhgalloll of any domeQl1c limited lIablluy company whIch IS to merge
or consollda1e. irrevocably appointing the Dela\\are Secretary ufSt <.l tl.! d:' Its ..tgc:m to accep t
I "crvlce of prot;ess In any such aClJon. suit or proceed mg. and )peclIi~\i [hat a ... opy of "uch
process shall be m,"lcd b) the Secr':l~r) oi'St31C <0 Ihe survl\ing cnut) 31 19,1 W(J()J AV"nue
South. 2,J fin",. [5elm. New JerlC) 08~}()
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I IN WITNESS WHEREOF. said survIVIng <!llIty hdS cau, eu thIS comHcatc
1h
by an authorized officer thlS 27 day of Apr; I. 2011 .
to be SlgJ1Cd
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Lauren V Harn::,. V1C t:' PI cSJdent
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Morgan. lewIs & Bockius llP
i..~iOR COURT OF NJ
502 Carnegie Center
vU,
Morgan Lewis
Pnnceton. NJ 08540
Tel 609.9t96600 REGD COUNSELORS AT LAW
Christopher C. Loeber
6099196072
cloeber@MorganLewls com
Re: In the Matter of ResidentIal Mortgage Foreclosure Pleadings and Document IrregulantIes
Docket No F-059553-IO
Thank you.
~
Christopher C. Loeber
encs.
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Zarro Inference AFFIDAVIT OF CHRIS COLLINS ON BEHALF OF JPMORGAN CHASE BANK, N.A.
[PDF] 1 SUPERIOR COURT OF NEW JERSEY
www.judiciary.state.nj.us/superior/cert_jp_morgan.pdf
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I have read the affidavits of Michael Zarro dated January 5, 201 I and April ... and Chase
described in Paragraphs 9 and 30 of the April 7, 201 l Zarro affidavit. 15
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Zarro Inference MEMORANDUM OF RESPONDENTS JPMORGAN CHASE BANK, N.A. AND CHASE HOME FINANCE LLC IN RESPONSE TO ORDER TO SHOW
CAUSE _ January 5, 2011
[PDF] BPICLO
www.judiciary.state.nj.us/.../January%205, ...
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Jan 5, 2011 – I The facts set forth in this memorandum are supported by the Affidavit of
Michael Zarro, Senior Vice. President in charge of Default Specialty ...
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[PDF] EEIVED
xwww.judiciary.state.nj.us/.../JPMorgan%20Chase%20Response.pdf
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l The facts set forth in this memorandum are supported by the Affidavit of Michael Zarro,
Senior Vice. President in charge of Default Specialty Operations of J ...
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Zarro Inference REPORT OF THE SPECIAL MASTER CONCERNING JPMORGAN CHASE BANK AND CHASE HOME FINANCE
[PDF] August 15, 2011 Report of the Special Master - New Jersey Courts
www.judiciary.state.nj.us/superior/report_jp_morgan.pdf
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Aug 15, 2011 – LLC was accompanied by the affidavit of Michael R Zarro, Senior
Vice... Nineteen exhibits accompanied Mr. Zarro's affidavit, which included: ...
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