Professional Documents
Culture Documents
115 MRS V JPMC 3rd Amended Complaint-SDNY
115 MRS V JPMC 3rd Amended Complaint-SDNY
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page11ofof190
46
Defendants.
Plaintiffs S&A Capital Partners, Inc. ("S&A"), Mortgage Resolution Servicing, LLC
("MRS"), and 1st Fidelity Loan Servicing, LLC ("1st Fidelity")(together, the "Plaintiffs"), for
their third amended complaint against JPMorgan Chase Bank, N.A., JPMorgan Chase &
Company, and Chase Home Finance LLC (together "JPMC" or the "Defendants"), allege as
follows:
1. This action arises out of the breach by the Defendants of various contracts entered
into with the Plaintiffs including a mortgage loan purchase agreement dated February 25, 2009
THE PARTIES
Plaintiffs:
Florida 33073, whose President is Laurence Schneider. S&A has been acquiring mortgaged
{N0084396 3 }
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page22ofof190
46
loans and pools of loans from numerous lenders, servicers and mortgage insurance companies
since 2003. From 2005 - 2010, S&A purchased approximately 650 first lien and second lien
Coconut Creek, Florida 33073, whose managing member is Real Estate and Finance, Inc., a
Florida corporation whose President is Laurence Schneider. On February 25, 2009, MRS entered
into a purchase agreement to purchase a pool of 3,529 first lien residential mortgage loans from
4. 1st Fidelity is a Florida limited liability company located at 6810 N. State Rd. 7,
Coconut Creek, Florida 33073, whose managing member is Real Estate and Finance, Inc., a
Florida corporation whose President is Laurence Schneider. 1st Fidelity has been acquiring
mortgage loans and pools of loans from numerous lenders, servicers and mortgage insurance
companies since 2008. From 2008 to 2010, 1st Fidelity purchased approximately 350 first lien
Defendants:
5. JPMorgan Chase Bank, N.A. (the "Bank") is a national banking association and a
wholly-owned subsidiary of JPMorgan Chase & Company. The Bank's principal place of
business is at 270 Park Avenue, New York, New York. On September 25, 2008, the Bank
purchased substantially all of the assets and assumed substantially all of the liabilities of
Washington Mutual Bank, F.S.B. pursuant to a Purchase and Assumption Agreement with the
principal place of business at 270 Park Avenue, New York, New York. In July 2004, JPMC
{N0084396 3 } 2
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page33ofof190
46
merged with Bank One. One or more of the Plaintiffs acquired from JPMC residential mortgage
loans that JPMC had acquired from Bank One loans. As owner of the loans sold to the Plaintiffs,
7. Chase Home Finance, LLC ("Chase") was a Delaware limited liability company
that offered mortgage and loan services, with its principal place of business at 343 Thornall
Street, Edison, New Jersey 08837. Prior to May 1, 2011, Chase was qualified to do business in
New Jersey. Effective May 1, 2011, Chase merged into the Bank which now owns and services
the residential mortgage loans previously owned by Chase. The Bank stands in the shoes of
8. This Court has federal question jurisdiction pursuant to 28 U.S.C. § 1331 with
respect to the Racketeer Influenced Corrupt Organizations Act ("RICO"), 18 U.S.C. § 1964(c);
diversity jurisdiction with respect to all of the claims pursuant to 28 U.S.C. § 1332; and
9. This Court has personal jurisdiction over the Defendants pursuant to New York
C.P.L.R. §§ 301 and 302 because the Defendants are registered to do business in the State of
New York and regularly conduct business in the State of New York, including in this District,
and because a substantial part of the events or omissions giving rise to the Plaintiffs' claims
10. Venue is proper under 28 U.S.C. § 1391(b) and (c) because two of the Defendants
maintain their principal place of business in the Southern District of New York.
{N0084396 3 } 3
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page44ofof190
46
11. The Plaintiffs are in the business of buying from financial institutions residential
mortgage loans which are not performing according to their original terms. Each purchase
would include the note, the mortgage or deed of trust, the full collateral file, and the servicing
12. The Plaintiffs’ goal is to work out reasonable and sustainable payment plans with
13. Beginning in April 2005, S&A began regularly purchasing residential mortgage
loans from Bank One, a division of JPMC, pursuant to a Master Mortgage Loan Sale Agreement
14. From April 2005 to June 2010, pursuant to the MMLSA, S&A acquired
approximately 650 first and second lien mortgage loans from Chase, which included delivery to
S&A of an assignment of the note and mortgage or deed of trust (the “S&A Loans”). S&A was
never offered, and never purchased, loans where second mortgages had been extinguished by
first lien foreclosures. Nor had S&A ever been offered or ever purchased, unsecured deficiency
claims owed by borrowers whose mortgages had been foreclosed and the homes sold for less
than the full amount owed. S&A never purchased unsecured loans or deficiencies. A list of the
15. Beginning in 2008, 1st Fidelity began purchasing residential mortgage loans from
Chase and, between May 2008 and November 2010, 1st Fidelity acquired approximately 350
individual first and second lien mortgage loans from Chase (the “1st Fidelity Loans”) through
individual note sale agreements that included the assignment of the mortgage or deed of trust
securing the loan. 1st Fidelity never purchased unsecured loans or deficiencies. 1st Fidelity was
never offered, and never purchased, loans where second mortgages had been extinguished by
{N0084396 3 } 4
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page55ofof190
46
first lien foreclosures. Nor had 1st Fidelity ever been offered, or ever purchased, unsecured
deficiency claims owed by borrowers whose mortgages had been foreclosed and the homes sold
for less than the full amount owed1st Fidelity never purchased unsecured loans or deficiencies.
16. With respect to both the S&A Loans and the 1st Fidelity Loans, Chase provided to
S&A and 1st Fidelity, shortly after the closing, pursuant to the requirements of the MMLSA, all
of the files and records in Seller’s possession evidencing or relating to each purchased loan
17. Through September 2008, S&A and 1st Fidelity purchased hundreds of first and
second lien residential mortgage loans from the Defendants without any significant problems.
These entities were able provide borrowers with flexible and tailor made repayment
arrangements, which Chase representatives were unable to provide, thus allowing for the
Plaintiffs to profit from their relationship with the homeowners through affordable and
18. Indeed, one month before MRS’ purchase of the pool of loans pursuant to the
MLPA, in a letter written in January 2009, Eddie S. Guerrero, Chase's Loss Recovery
Supervisor, wrote a recommendation letter for S&A to HSBC Bank Consumer Lending in which
Guerrero stated that "S&A Capital Partners continues to exceed our expectations" and that many
of Chase's former customers have contacted Chase regarding "the great experience that they have
had with S&A Capital Partners." The recommendation letter was submitted to HSBC in support
19. In 2008, Guerrero informed Schneider that Chase was interested in selling a
portfolio of "First Lien Walks," that is, closed-end first lien residential mortgage loans, which
{N0084396 3 } 5
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page66ofof190
46
Chase had determined, based upon a cost-benefit analysis, it no longer made sense from a
business perspective to continue to own. Guerrero told Schneider that the "highest levels of
management" had made it an urgent priority to get rid of this portfolio which consisted of low-
valued properties, mostly in parts of the country hardest hit by the housing crisis, such as Detroit
and Flint, Michigan, and St. Louis and Ferguson, Missouri, Baltimore, Maryland and numerous
cities in upstate New York. Guerrero told Schneider that, in view of the dramatic increase in the
volume of defaulted loans, Chase had set new thresholds in determining whether a particular first
lien loan was worth foreclosing, resulting in a higher volume of "First Lien Walks" that Chase
wanted to sell.
20. In order to encourage Schneider to buy the proposed loan package, Guerrero told
Schneider that the proposed loan package included some "cherries," (valuable loans) that were
erroneously “charged off”, removed from its primary System of Records (“SOR”) and ported to
21. In mid-October 2008, Mr. Guerrero advised Mr. Schneider that he should be
expecting a call from Jason Oquendo, to complete the application process for the purchase of
loan pools from Defendant. Mr. Oquendo communicated with Mr. Schneider and Mr. Schneider
provided Mr. Oquendo all of the information required in order to be approved for bulk loan sale
bidding.
22. In October 2008, Guerrero sent Schneider an email attaching the preliminary tape
for the "First Lien Walks" available for sale. However, this tape was useless from a due
diligence perspective as it did not even include borrowers' names, the addresses of the underlying
{N0084396 3 } 6
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page77ofof190
46
23. Guerrero informed Schneider that the proposed sale was to be made through a
24. In November 2008, Guerrero sent Schneider an email attaching a second data tape
(the "November 2008 Data Tape") which clearly identified a data field indicating all the loans as
first lien mortgages. Although information was substantially incomplete on some of the loans,
including the borrowers' names and collateral addresses, Guerrero said he would provide the
information shortly. The spreadsheet within the November 2008 Tape contained a total
population of approximately 5,785 mortgage loans, with an aggregate "charge off" balance of
approximately $230 million, all represented to be first lien residential mortgage loans.
25. Schneider began to perform due diligence on the November 2008 Data Tape by
sorting the loans by highest balance. The largest two loans were the Ali Sayed and Ricardo
Salinas loans, both of which had balances in excess of $500,000 and both were located in areas
which Schneider knew contained homes valued in excess of $1M. Upon a search of the public
records, which confirmed recorded mortgages on the subject properties which coincided with the
amount Guerrero represented in the data tape, Schneider immediately realized that the “cherries”
to which Guerrero had referred were fully secured and would yield over $1 million in liquidation
value.
26. Schneider asked Guerrero why there were so many names and addresses missing
from the November 2008 Data Tape. Guerrero responded that Chase had all of the information
but it was not yet accessible because Chase had just acquired Washington Mutual, Inc. and had
not yet completed the lengthy process of converting the data from Washington Mutual's system
to Chase's system.
{N0084396 3 } 7
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page88ofof190
46
27. Guerrero assured Schneider that Chase was in possession of all the data and
would supply all the necessary borrower information and collateral files, as it had consistently
done pursuant to the contractual terms between the parties set forth in the 2005 MMLPA and the
past protocol established in hundreds of individual note sale agreements with S&A and 1st
Fidelity.
28. Guerrero told Schneider the loan sale had to close by the end of the year so that
29. In December 2008, Schneider informed Guerrero that he would not be bidding on
the MLPA loan pool. Despite the “cherries” which Schneider confirmed existed within the
population of potential loans being offered, Schneider was not interested in making a competitive
bid for several reasons, including the fact that MRS was in the final stages of consummating the
30. Shortly thereafter, Guerrero called Schneider and indicated that Chase would sell
the portfolio of loans to Schneider for only $200,000, as the sale had to close prior to the end of
the year and Chase knew that Schneider would honor his commitment, as he had on hundreds of
occasions in the past. Based on his evaluation of the “cherries,” Schneider said that he would
buy the portfolio listed on the November 2008 Data Tape for $200,000.
31. On December 22, 2008, Guerrero sent Schneider an email urging him to prepare,
instead of a competitive bid letter, a letter "reiterating your acceptance of our offer," to purchase
32. On December 22, 2008, Schneider sent a letter to Victor B. Fox, Vice President,
Real Estate Recovery for Chase Home Finance in which he made a formal offer to purchase
{N0084396 3 } 8
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page99ofof190
46
payable to Chase in the amount of $200,000 for payment in full for the Non-Performing Closed
end First Lien Mortgage Loan Portfolio. The memo on the cashier's check said "1st Lien Pool,"
based on Guerrero's representation that all of the loans were first lien mortgage loans. The
cashier’s check was sent via FedEx to Chase, attention Eddie Guerrero.
34. The $200,000 purchase price represented a fraction of the amount of money MRS
committed to expend by acquiring ownership of the portfolio of loans because MRS was
contractually and legally required to service the loans in accordance with the same mortgage
servicing and consumer protection requirements of “federally related mortgage loans” as defined
by the Federal Deposit Insurance Act with which Chase was required to comply. MRS intended
to utilize a staff of approximately ten people plus outsourced resources in order to service the
portfolio.
35. It was not until February 4, 2009 that Schneider received an email from Guerrero
attaching the Mortgage Loan Purchase Agreement (the "MLPA") for Schneider's review and
signature, with a placeholder for inclusion of Exhibit A as the list of mortgage loans being sold
pursuant to the MLPA. The MLPA provided for sale of 4,271 loans with an outstanding
principal balance of $172,093,033.13. This was $72,093,033.13 more than Schneider had been
informed would be included in the pool. Yet Chase did not ask for any additional funds. The list
was to be drawn from the November 2008 Data Tape but Schneider was not provided with a
copy of the data tape which purportedly was to be the Exhibit A to the MLPA.
36. Schneider requested that Chase provide him with the final data tape so that he
could review it before signing the MLPA. Chase told Schneider it would provide him with the
{N0084396 3 } 9
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page10
10ofof190
46
37. In reliance upon his long-standing relationship with Guerrero and Chase,
Schneider signed the MLPA on behalf of MRS, despite the fact that he had not received Exhibit
A to the MLPA, and MRS paid the full consideration required under the MLPA.
38. On February 25, 2009, Victor Fox, Vice President of Chase faxed to Schneider
the fully-executed MLPA which provided for the sale to MRS of 3,529 "nonperforming and/or
impaired closed end first lien mortgage loans that are or have been delinquent for 180 days or
more and have been or may otherwise be in default" (the "MRS Loans"), with an outstanding
39. After receiving the fully-executed MLPA, Chase emailed to Schneider a data tape
40. Although MRS had originally agreed to Chase’s offer to purchase approximately
$100 million of loans for $200,000, Chase did not ask for any additional consideration for the
50% increase in the loans actually sold. The reason for Chase’s conduct is that Chase knew, but
Schneider did not, that the MRS Loans represented an enormous liability to Chase for Chase’s
violation of statutory and regulatory requirements owed to these borrowers, to state and federal
regulatory agencies tasked with oversight of consumer protection, and to federal agencies that
oversee the safety and soundness of financial institutions. Chase knew, and Schneider did not,
that the increase in loans sold simply transferred a substantially increased liability from Chase to
MRS.
41. Ultimately, Schneider learned that Chase used the MLPA as a dumping ground
for the enormous liabilities it transferred to MRS based on Chase’s systematic violations of state
and federal law. Chase knowingly and deliberately violated the representation and warranty in
the MLPA that it had fully complied with all applicable law.
{N0084396 3 } 10
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page11
11ofof190
46
42. Pursuant to the MLPA, Chase sold the Mortgage Loans to MRS "AS IS with no
43. However, in the MLPA, Chase made the following representations and
warranties:
(i) The information set forth on the data tape provided by Seller to
Purchaser with respect to the Mortgage Loans is true and correct in
all material respects as of the date such data tape was compiled;
(ii) Seller is the sole owner of the Mortgage loans and has full
right to transfer and sell the Mortgage Loans to Purchaser; and
(iii) Each Mortgage Loan complies in all material respects with all
applicable federal, state, or local laws, including, without
limitation, the Federal Truth in Lending Act of 1969, the Federal
Equal Credit Opportunity Act, the Federal Real Estate Settlement
Procedures Act of 1974, and state and federal usury, consumer
credit protection and privacy, predatory and abusive lending laws
applicable to the Mortgage Loans.
Exhibit 3 § 6.
44. The MLPA contains the following provision with respect to its survival:
Exhibit 3 § 11.
{N0084396 3 } 11
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page12
12ofof190
46
Exhibit 3 § 15.
46. While the MLPA refers to an attached schedule of purchased mortgage loans,
Schneider received the fully executed MLPA from Chase, signed by Victor Fox, Vice President,
on behalf of Chase, without Exhibit A. Later that same day, Guerrero emailed the purported data
tape to Schneider which constituted Exhibit A. However, the Exhibit A Schneider received on
February 25, 2009 (the "Corrupted List") was grossly deficient in that it did not include basic
information such as borrower names and phone numbers, addresses of the mortgaged properties,
current outstanding balance of each loan, the status of the property as occupied or vacant and
47. Guerrero assured Schneider that he would supplement the information on Exhibit
A but he never did so. Each time Schneider raised the issue with Guerrero, Guerrero claimed
that the delay in providing the tape was caused by the difficulty of converting information from
48. In fact, as MRS ultimately learned, none of the MRS Loans was originated by
Washington Mutual.
49. Because of the inadequacy of Exhibit A, MRS was forced to invest an enormous
amount of personnel time to research borrower identities, property locations, and occupancy
status from a review of public records and internet searches. None of these expenses would have
been incurred by MRS if Chase had fulfilled its contractual obligation to provide a complete
Exhibit A to MRS.
{N0084396 3 } 12
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page13
13ofof190
46
50. Contrary to its obligation to sell MRS "closed end first lien mortgage loans," a
significant portion of the loans sold to MRS were unsecured mortgage deficiency claims
51. In many instances, the properties were occupied by people who had purchased the
52. In many instances, collection of the deficiency claims was barred by applicable
state law.
53. Nevertheless, Chase sold these loans to MRS as first lien mortgage loans.
54. Schneider promptly and repeatedly reported this situation to Defendants but they
55. Despite its representation and warranty that Chase “is the owner of the Mortgage
Loans and has full right to transfer the Mortgage Loans,” a significant portion of the loans listed
56. Many of the loans were owned by RMBS trusts with which Chase had a servicing
contract. Despite the fact that Chase did not own these loans, it transferred them to MRS in
order to avoid non-reimbursable advances and expenses. The unlawful transfer of these loans to
MRS as part of the portfolio of loans sold under the MLPA aided the Defendants in concealing
{N0084396 3 } 13
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page14
14ofof190
46
59. Contrary to its representation and warranty that "Each Mortgage Loan complies in
all material respects with all applicable federal, state, or local laws," MRS discovered that Chase
had failed to comply with nearly all such laws. MRS later discovered that Chase’s desire to
escape the consequences of its long-running violations was the primary motivation for Chase to
60. Chase committed, inter alia, the following violations of law with respect to the
multiple unlicensed and unregulated debt collection agencies which lacked the
mortgage servicing platforms to account for or service the borrowers’ loan with
federal disclosures and good faith estimates, thus putting MRS in a position where
mortgage loans that Defendants knew had been foreclosed and sold to third
parties.
{N0084396 3 } 14
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page15
15ofof190
46
loans from its primary record-keeping platform and creating an entry in its RCV1
SOR. This had the effect of denying the borrowers their rights concerning
federally-related mortgages yet allowed Chase to retain the lien and the benefit of
numerous valuable loans sold to MRS after the MLPA had been fully executed
and in force. This allowed Chase to accept payments from borrowers whose
loans had been sold to MRS without its own records disclosing the wrongful
61. The MLPA specifies that Chase sold to MRS 3,259 closed-end first lien mortgage
loans with a total principal balance of $156,324,613.80 as set forth on Exhibit A. In fact, Exhibit
A contained at least 685 duplicate loans with an approximate value of $22 million. Thus, Exhibit
62. In addition, of the duplicate loans, Exhibit A shows different amounts owed for
{N0084396 3 } 15
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page16
16ofof190
46
64. The MLPA states that the aggregate principal balance of the sold loans was
$156,324,613.80. However, the Corrupted List totaling $156,324,613.80 did not reveal the
principal balance of each loan. Instead, it listed the amount Chase charged off, which included
the principal balance, the unpaid interest, late fees, property tax advances, and customary default
servicing fees. Thus, aside from the fact that Exhibit A over-stated the value of the sold loans by
$22,542,260 because of duplications, Exhibit A over-stated the value of the sold loans by
g. Chase failed to provide MRS with assignments of the notes and mortgages
65. Chase breached the MLPA by failing to provide MRS with assignments of the
66. By refusing to provide assignments of the notes and mortgages, Chase prevented
67. Chase’s failure to provide the assignments of the notes and mortgages was not an
act of negligence. As events unfolded, it became clear that Chase failed to provide the
assignments of the notes and mortgages because it wanted, in selective instances, to continue to
68. Despite its sale to MRS of the loans listed on the Corrupted List, after those loans
were sold to MRS, Chase sent letters to borrowers whose loans were sold, and had collection
agencies send letters to borrowers whose loans were sold, directing the borrowers to make
payments to Chase. In these letters, Chase represented directly, or through the collection agency,
that it owned the loan and/or was the authorized servicer of the loan.
{N0084396 3 } 16
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page17
17ofof190
46
mortgaged properties. For example, one of the loans that Chase sold to MRS under the MLPA
on February 25, 2009 was a purported first mortgage loan to Vahe Kevorkyants. However, on
June 27, 2008, seven months earlier, Chase had filed a title insurance claim with XL Insurance
America (“XL”) claiming that it was insured for a first mortgage but, in fact, its mortgage was in
third position.
70. In the fall of 2009, after Chase had sold the loan and all interests to MRS, Chase
was paid $250,000 by XL. Chase refused to turn over this money to MRS.
71. In March and April 2009, Chase notified MRS that it was "recalling" a number of
loans, including the most valuable loans in the loan pool – the “cherries” that Guerrero used to
72. When Schneider objected, Chase claimed that these loans were included by
mistake and Chase personnel represented to Schneider that Chase would pay for the recall of the
73. As of this time, Chase had still not delivered to MRS any of the original loan
documentation. Hence, MRS was powerless to prevent Chase from recalling these loans.
74. This was a direct violation of the MLPA which prohibits buybacks. See Exhibit 3
Section 6(c).
75. On October 31, 2009, Guerrero passed away mysteriously at the age of 29. Prior
to his death, Guerrero had told Schneider he was putting together an updated Exhibit A to the
MLPA which would correct all the errors in the Corrupted List and reimburse MRS for the loans
it recalled.
{N0084396 3 } 17
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page18
18ofof190
46
76. Under New York law, a party that breaches a contractual representation or
warranty is liable to the injured party for the difference in the value of the contract between what
the contract would have been worth, but for the breach of warranty, and what the contract was
77. MRS purchased from Chase 3,529 loans. S&A and 1st Fidelity had a track record
of realizing an average of $700 per month profit on each loan they had purchased from Chase or
78. S&A and 1st Fidelity had a track record of keeping the loans they purchased from
Chase performing for an average of ten years. Thus, MRS reasonably anticipated that it would
earn an average of $84,000 on each purchased loan over a ten-year period ($700/month x 12
months x 10 years).
79. MRS reasonably anticipated that – if Chase had complied with the express
warranties in the MLPA – MRS would have realized $84,000 on each of the 3,529 purchased
80. On November 13, 2009, Schneider sent an email to Mark Davis, Senior Vice
President of Recovery for Chase and Chad Paxton, Vice President of Relationship Management
at Chase. In this email, Schneider explained that approximately 2/3 of the loans listed on the
Corrupted List were coded incorrectly and were mortgage deficiencies, not first mortgage loans.
Schneider urged Davis and Paxton to reimburse MRS adequately for these loans and the
expenses and liabilities MRS had incurred as a result of the inaccuracies on the Corrupted List.
81. Schneider received a response to his emails from Patrick "Mike" Boyle, Vice
President of Loss Mitigation Recovery, who explained that he had recently assumed leadership
{N0084396 3 } 18
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page19
19ofof190
46
for recovery operations and he wanted to get "a full understanding of the efforts . . . underway
they had regarding Chase's exposure to potential liability as a result of its mishandling of certain
defaulted loans.
83. In December 2009, Chase sent MRS a Post-MLPA List that purported to include
an additional 850 loans "sold" to MRS. However, the additional 850 loans were loans where
Chase had acted in violation of law and, apparently, was seeking to off-load its liability onto
MRS.
84. In addition to its breaches of the MLPA set forth above, subsequent to the
execution of the MLPA, Defendants engaged in a series of actions which violated MRS' rights
under the MLPA. These actions include but are not limited to the following:
85. In some instances, Chase contacted borrowers and told them that Chase had
reacquired the loan and that the borrowers had to make payments to Chase.
86. After the execution of the MLPA, Chase continued to use collection agencies to
collect payments from borrowers on the loans it had sold to MRS. In many cases it retained all
such payments.
87. In order to conceal its theft, after the execution of the MLPA, Chase changed the
loan numbers of valuable loans that had been sold to MRS, where the borrowers were making
monthly payments.After the execution of the MLPA, Chase continued to assert its right to
proceeds of paid title insurance claims it had purchased on the mortgaged premises as
{N0084396 3 } 19
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page20
20ofof190
46
investigate Chase's conduct with respect to loans it had purportedly sold to MRS, Chase told the
investigate Chase's conduct regarding violations with respect to loans which Chase still owned,
and had not sold to MRS, Chase falsely told the agencies to contact MRS as the responsible
party.
90. In situations where there were patent violations of law, Chase falsely represented
to borrowers that their loans had been purchased by one of the Plaintiffs so as to deflect action by
91. When Plaintiffs tried to speak with Chase representatives to resolve these matters,
92. In March 2012, after a lengthy investigation, the United States Government, along
with numerous States (the “States”),1 filed a complaint against Chase and the other banks
responsible for the fraudulent and unfair mortgage practices that cost consumers, the
Government, and the States tens of billions of dollars. The Government alleged that Chase, as
origination, mortgage servicing, and foreclosures, including, but not limited to, irresponsible and
1
States of Alabama, Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, Florida, Georgia,
Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Louisiana, Maine, Maryland, Michigan, Minnesota, Mississippi,
Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina,
North Dakota, Ohio, Oregon, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont,
Washington, West Virginia, Wisconsin, Wyoming, the Commonwealths of Kentucky, MasS & Ahusetts,
Pennsylvania and Virginia, and the District of Columbia.
{N0084396 3 } 20
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page21
21ofof190
46
93. These improper practices had previously been the focus of several administrative
enforcement actions by various government agencies, including the Office of the Controller of
the Currency (the “OCC”) and the Federal Reserve Bank (the “FRB”), which resulted in Consent
94. On March 12, 2012, the Federal Government, 49 individual States,2 and the
District of Columbia jointly filed a complaint against numerous banks and loan servicing
companies, including Chase, for misconduct related to their origination and servicing of single
95. The National Mortgage Complaint was the capstone on a series of enforcement
actions brought against Chase and other servicers for certain deficiencies and unsafe or unsound
practices in residential mortgage servicing. These actions were brought by a wide variety of
regulatory agencies including the OCC, the Federal Reserve Bank, the FDIC, the Office of Thrift
Supervision (the “OTS”), and others. These prior actions resulted in various settlements and
96. The National Mortgage Complaint, among other things, alleged that the
misconduct of the defendants "resulted in the issuance of improper mortgages, premature and
unauthorized foreclosures, violation of service members' and other homeowners' rights and
protections, the use of false and deceptive affidavits and other documents, and the waste and
abuse of taxpayer funds." The National Mortgage Complaint also contained several allegations
2
Alabama, Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, Florida, Georgia, Hawaii,
Idaho, Illinois, Indiana, Iowa, Kansas, Louisiana, Maine, Maryland, Michigan, Minnesota, Mississippi, Missouri,
Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, North Dakota,
Ohio, Oregon, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Washington, West
Virginia, Wisconsin, and Wyoming; the Commonwealths of Kentucky, MasS & Ahusetts, Pennsylvania and
Virginia.
{N0084396 3 } 21
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page22
22ofof190
46
concerning unfair and deceptive trade practices engaged in by Chase and other financial
institutions.
97. In April 2012, the United States District Court for the District of Columbia
approved a settlement between the Government, the States, JPMorgan Chase, and four other
banks, which resulted in the National Mortgage Settlement Agreement (the “NMS”), reflected in
a consent judgment (the “NMS Consent Judgment”). The NMS Consent Judgment contains both
federal and state releases to the financial institutions in exchange for their agreement, among
other things, to adhere to specified servicing standards and to provide consumer relief to
borrowers.
98. Exhibit A to the NMS Consent Judgment contains Servicing Standards that were
intended to be used to test general compliance including timeline requirements during the loss
mitigation process. The Servicing Standards were mapped to various "metrics" which were
designed to gain public confidence in the mortgage servicing industry and improve upon the lack
99. The Servicing Standards were a general framework for the underlying HAMP
requirements pursuant to Chase’s Servicer Participation Agreement with the U.S. Treasury (the
“SPA”) and the underlying federal and state, mortgage servicing and consumer protection laws.
100. As set forth in Exhibits D and D-1 of the NMS Consent Judgment (the “NMS
Consumer Relief Provisions”), Chase was required to provide $4.2 billion in consumer relief to
borrowers whose loans it owns and/or serviced and would receive "credits" towards its consumer
relief obligations for various forms of loan modifications. The process for the loan modifications
is clearly set forth and defined in the HAMP Handbook with which Chase is required to fully
{N0084396 3 } 22
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page23
23ofof190
46
101. As set forth in Exhibit F of the NMS Consent Judgment, the United States of
America fully released Defendants from all servicing related “covered conduct” as of 11:59
102. Compliance with the Consent Judgment was overseen by an independent Monitor,
paid by the banks and whose reports were based on self-reported information from the banks.
103. With the obvious intent of fulfilling its consumer relief obligations under the
NMS Consent Judgment, on September 13, 2012, the Bank mailed 33,456 unsolicited debt
forgiveness letters (the "Forgiveness Letters") to borrowers with non-performing 2nd lien loans.
These letters stated in bold: "WE ARE CANCELLING THE REMAINING AMOUNT YOU
OWE CHASE! . . . as a result of a recent mortgage servicing settlement reached with the states
and federal government." The letter continued: "This means you owe nothing more on the
loan and your debt will be cancelled. You don't need to sign or return anything for this to
happen."
104. On December 13, 2012, the Bank sent another 10,000 Forgiveness Letters and, on
January 13, 2013, the Bank sent another 8,000 Forgiveness Letters. In total, the Bank sent over
50,000 Forgiveness Letters between September 2012 and January 2013. All of these letters were
105. The Bank did not own the loans of thousands of the recipients of the Forgiveness
Letters, scores of whose loans had been acquired by the Plaintiffs long before 2012. Annexed
hereto as Exhibit 4 are copies of the Forgiveness Letters S&A knows were sent to borrowers
whose loans it had purchased. Annexed hereto as Exhibit 5 are copies of the Forgiveness Letters
1st Fidelity knows were sent to borrowers whose loans it had purchased.
{N0084396 3 } 23
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page24
24ofof190
46
106. With respect to each of the forgiven loans, including the loans previously sold to
Plaintiffs, the Bank intended to and in some cases took credit towards the $4.2 billion consumer
relief requirement in the NMS Consent Judgment for the total indebtedness due under the loan
107. Plaintiffs do not know the identity of each of the borrowers whose loans they
owned who received Forgiveness Letters from Chase. Despite repeated requests, the Bank has
never made available to the Plaintiffs the full list of borrowers that received the Forgiveness
Letters.
108. Many of the S&A and 1st Fidelity borrowers whose loans Plaintiffs had
purchased from Chase and who received the Forgiveness Letter refused to make further
payments to the Plaintiffs because they had received a Forgiveness Letter from the Bank.
109. When Schneider first confronted Bank personnel with the fact that it had forgiven
loans it had previously sold to the Plaintiffs, the Bank refused to admit what it had done. As
more and more borrowers received Forgiveness Letters, Chase acknowledged there was an error
but could not quantify the number of affected borrowers. Chase then asked for an entire list of
loans which its entities had sold to the Plaintiffs since 2005 so that it could attempt to determine
the number of affected borrowers whose loans had been sold to the Plaintiffs. Finally, in
November 2012, Chase offered to buy back the loans it had forgiven of which the Plaintiffs were
aware.
110. On December 5, 2012, the Bank sent Schneider two letters offering to buy back
over 20 mortgages that had been sold to Plaintiffs and, thereafter, forgiven by Chase. These
letters stated:
{N0084396 3 } 24
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page25
25ofof190
46
111. Plaintiffs agreed to sell back to the Bank some of the loans for which borrowers
were sent Forgiveness Letters but only on the condition that the Bank would send retraction
letters to the other affected borrowers indicating that the Bank made an error and, as a result, the
112. 1st Fidelity did not agree to sell back most of the affected loans because Chase did
113. The borrowers on some of the loans that 1st Fidelity did not agree to sell back to
Chase filed complaints against 1st Fidelity with various governmental agencies on the ground
114. For example, Chase had sold to 1st Fidelity, on September 24, 2009, a second
mortgage on property owned by Robert W. Warwick and Lauren D. Warwick. Chase executed
an assignment of mortgage to 1st Fidelity which was recorded on December 11, 2009. The
borrowers entered into a payment plan with 1st Fidelity and were making monthly payments in
{N0084396 3 } 25
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page26
26ofof190
46
115. On September 13, 2012, 34 months after selling the loan to 1st Fidelity, Chase
sent the Warwicks a letter extinguishing the second mortgage and canceling the debt in the
116. 1st Fidelity pleaded with Omar Kassem, Portfolio Manager at Chase, to issue a
retraction letter to each of the borrowers whose debt Chase had wrongfully forgiven but Chase
refused to do so.
117. On October 5, 2012, Schneider notified Kassem that the Warwicks had ceased
making payments to 1st Fidelity and he asked Kassem to send a retraction letter to the Warwicks.
118. On December 12, 2012, 1st Fidelity received a letter from the State of Maryland,
Department of Labor, Licensing and Regulation, Division of Financial Regulation stating that the
Warwicks had filed a complaint against Chase and requesting that 1st Fidelity cease all collection
activity until the investigation was completed. Enclosed with the letter was a statement by an
investigator for the State of Maryland questioning “whether Chase is somehow getting credit
from a write off they never actually have to honor.” See Exhibit 8 hereto.
119. On January 28, 2013, Chase agreed to repurchase from 1st Fidelity, the Warwick
second mortgage loan along with two other loans with similar circumstances for their full face
120. In other instances, Chase refused to buy back the loans even though it had
wrongfully sent a forgiveness letter to a borrower on a loan that it had sold to the Plaintiffs. For
example, in September 2012, 1st Fidelity was in the process of foreclosing on a second mortgage
{N0084396 3 } 26
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page27
27ofof190
46
executed by Saleh Ahmed and Beverly Ahmed that 1st Fidelity had acquired from Chase in
October 2009.
121. On September 13, 2012, Chase issued a Forgiveness Letter to the Ahmeds
notifying them that Chase was cancelling their debt of $42,543.97 as a result of the NMS
Consent Judgment.
122. On October 5, 2012, Schneider notified Kassem that the Ahmeds were threatening
to report 1st Fidelity to the Attorney General of Oklahoma for seeking to wrongfully recover a
cancelled debt. Kassem refused to take any action to rectify the situation.
123. In December 2012, Schneider informed Kassem that 1st Fidelity had to postpone a
foreclosure sale and he continued to plead with Kassem to have Chase buy back the loan at full
face value to prevent further harm to 1st Fidelity and the affected borrower.
124. By February 2013, Chase made it clear to Schneider that it would not
125. On January 9, 2014, the Ahmeds filed an answer in the foreclosure action in
which they asserted as a defense that the loan was used by Chase to satisfy the consumer relief
requirements in the NMS Consent Judgment. See Exhibit 9 hereto. Yet, to date, Chase has
126. On August 27, 2009, 1st Fidelity purchased a loan from Chase that was secured by
assignment of the second mortgage on November 4, 2009 which was recorded on August 26,
2010. Hancock-Roberts entered into a payment plan with 1st Fidelity and performed consistent
{N0084396 3 } 27
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page28
28ofof190
46
cancelling a debt of $28,209.15 as a result of the NMS Consent Judgment. See Exhibit 10
hereto.
128. Hancock-Roberts stopped paying 1st Fidelity after she received the debt
forgiveness letter.
129. Schneider pleaded with Chase to send a retraction letter to Hancock-Roberts but
130. Hancock-Roberts filed a complaint against 1st Fidelity with the State of
Connecticut Department of Banking which was forwarded to the Federal Trade Commission and
131. Hancock-Roberts has not made any further payments to 1st Fidelity and has
threatened to file additional complaints if any collection attempts are pursued by 1st Fidelity.
Chase’s fraudulent 1st Lien Alternative Foreclosure Process was intended to avoid liability
for anti-blight expenses under the NMS Consent Judgment
132. The NMS Consent Judgment addressed Chase’s requirement to implement anti-
blight programs with respect to mortgages it held in poverty stricken cities. In order to avoid the
expense required for compliance with the anti-blight programs, Chase engaged in a practice of
releasing liens on properties that served as collateral for loans which Chase had owned or
contractually serviced for others. This included loans that Chase had sold to Plaintiff in the
133. As explained by Chase employee, Kimberly Cowman, Chase had received notices
regarding certain properties from municipal authorities. Ms. Cowman feared that "the city could
fine Chase daily or charge [Chase] with all cost of repairs/demolition if the city did the work."
{N0084396 3 } 28
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page29
29ofof190
46
Hence, Ms. Cowman urged that Chase release liens in "order to not have a judgment filed on
The Pre DOJ Lien Release Project:The massive purge of anti blight responsibilities.
134. In October 2013, Chase established the “Pre DOJ Lien Release Project” pursuant
to which it released liens on thousands of properties where it had abandoned its servicing
responsibilities despite local, state and federal requirements to properly service first lien
federally related mortgage loans and despite its responsibility to offer government sponsored
loan modification programs. Chase did this by quietly releasing thousands of liens, without the
knowledge of the borrowers whose liens were released, and despite the fact that hundreds of
these loans had been sold several years earlier to the Plaintiffs. Despite releasing these liens to
avoid its legal responsibilities, Chase created blight and continued to collect on the debt of these
borrowers.
138. The lien releases were obviously "robo-signed," that is, signed by persons lacking
any knowledge as to the relevant facts concerning each lien, as hundreds of these loans were
owned by the Plaintiffs. These lien releases were attested to under penalty of perjury.
139. The signatures of the notaries who executed the lien releases are significantly
140. In its eagerness to avoid liability for urban blight, Chase released liens on
{N0084396 3 } 29
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page30
30ofof190
46
141. Some borrowers who became aware of these lien releases then refused to continue
making payments to Plaintiffs because they claimed the liens had been released. This caused
Plaintiffs to lose the revenue on the loans where the liens had been released and, in many
instances, exposed the Plaintiffs to litigation from the borrowers whose loans Plaintiffs had
142. For example, S&A purchased from Chase a first mortgage loan to Patricia B.
King. Chase executed an assignment of mortgage on February 16, 2010 which was recorded on
March 15, 2010. See Exhibit 11 hereto. On October 25, 2013, S&A commenced foreclosure
proceedings because King was in default. On November 6, 2013, Chase executed a discharge of
the first mortgage and recorded the discharge on November 19, 2013 despite the fact that Chase
143. Similarly, 1st Fidelity purchased from Chase a first mortgage loan to Mark
Damstra. Chase executed an assignment of the mortgage on October 22, 2010 and the
assignment was recorded in the appropriate registry of deeds on November 15, 2010. On
November 21, 2011, 1st Fidelity, through counsel, sent a notice of intent to foreclose on the
mortgage to Damstra and, thereafter, instituted foreclosure proceedings. On October 23, 2013,
Chase executed a discharge of the first mortgage sold by Chase to 1st Fidelity, which was
recorded in the appropriate registry of deeds on November 13, 2013. This made it impossible for
144. A review of public records reveals tens of thousands of similar robo-signed lien
releases executed by Chase on or after mid-October 2013. The release of liens previously sold
{N0084396 3 } 30
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page31
31ofof190
46
145. All of Chase's conduct, as described above, has destroyed the Plaintiffs’
relationships with the borrowers whose loans Plaintiffs had purchased; caused substantial
damage to the Plaintiffs' business reputation; forced the Plaintiffs to face the ire of governmental
entities seeking to enforce property maintenance obligations against mortgage holders; and
exposed plaintiffs to accusations of predatory lending despite the fact that the Plaintiffs only
sought to collect what they were legally entitled to collect from borrowers whose loans Plaintiffs
had purchased from Chase. Chase, on the other hand, not only received payment for the loans
from the Plaintiffs but escaped liability for community blight which it had incurred.
146. On November 19, 2013, the Department of Justice (“DOJ”) announced a $13
billion settlement with JPMC to resolve “federal and state civil claims arising out of the
JPMC, Bear Stearns and Washington Mutual prior to Jan. 1, 2009” (the “RMBS
Settlement”). JPMC agreed to pay $13 billion in exchange for complete civil immunity. The
{N0084396 3 } 31
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page32
32ofof190
46
Delaware
$13,000,000,000 Total
147. Before the RMBS Settlement was entered into, Chase had sold a significant
volume of its mortgages to individual investors like the Plaintiffs. After the RMBS Settlement
was entered into, Chase claimed credit towards its requirement to provide $4 billion of consumer
relief to borrowers by, inter alia, including the full indebtedness owed by borrowers whose loans
149. The MLPA is a valid and binding contract between MRS and Chase.
150. MRS has fully performed its obligations under the MLPA.
151. Chase has breached the warranties made to MRS under the MLPA, inter alia, in
the following ways (a) Chase sold non-conforming deficiency claims in place of first lien
mortgage loans; (b) Chase withheld information and documents concerning the loans it sold to
MRS; (c) Chase sold loans to MRS where Chase had violated applicable law in its dealings with
the borrowers; (d) Chase sold loans to MRS where Chase sought MRS an uncorrupted data tape
{N0084396 3 } 32
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page33
33ofof190
46
as Exhibit A to the MLPA, substantially in the format of the November 2008 Data Tape Chase
had provided to MRS; (f) Chase accepted and retained payments it received from borrowers
and/or insurance companies on loans it had sold to MRS; and (g) Chase changed the loans sold,
after the sale, by pulling valuable loans back and adding loans that violated loan servicing and
152. Chase has further breached the MLPA and the implied obligation of good faith
and fair dealing by forgiving the debt owed by borrowers on loans sold to MRS or releasing the
liens securing loans sold to MRS, in order to falsely satisfy its obligations under the NMSA
153. Chase is liable to MRS for all of the damages caused by its breach of the MLPA
and the obligation of good faith and fair dealing implied in every contract governed by New
York law.
155. S&A purchased loans from Chase pursuant to valid and binding contracts
156. S&A has fully performed its obligations under its agreements with Chase.
157. Chase has breached the contracts it had with S&A by, inter alia, (a) releasing
mortgage liens securing loans previously sold to S&A; (b) forgiving loans it had previously sold
to S&A; and (f) accepting and retaining payments it received from borrowers and/or insurance
{N0084396 3 } 33
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page34
34ofof190
46
158. Chase is liable to S&A for all of the damages caused by its breach of contract and
the obligation of good faith and fair dealing implied in every contract governed by New York
law.
160. 1st Fidelity purchased loans from Chase pursuant to valid and binding contracts
161. 1st Fidelity has fully performed its obligations under its agreements with Chase.
162. Chase has breached the contracts it had with 1st Fidelity by, inter alia, (a)
releasing mortgage liens securing loans previously sold to 1st Fidelity; (b) forgiving loans it had
previously sold to 1st Fidelity; and (c) accepting and retaining payments it received from
163. Chase is liable to 1st Fidelity for all of the damages caused by its breach of
contract and the obligation of good faith and fair dealing implied in every contract governed by
165. Under the MLPA, Chase sold to MRS the loans listed on Exhibit A to the MLPA.
166. Similarly, under the various loan sale agreements Defendants had entered into
with S&A and 1st Fidelity, the Defendants had sold thousands of loans to them from 2005 on.
borrowers of the purchased loans and putting them on payment schedules so that they could
{N0084396 3 } 34
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page35
35ofof190
46
168. With malice and an intent to enrich itself at the expense of the Plaintiffs, Chase
wrote forgiveness letters to borrowers whose loans it had sold to the Plaintiffs and released liens
170. Chase is liable to the Plaintiffs for compensatory and punitive damages for its
172. The Bank and JPMC intentionally and without any justification procured Chase’s
violation of the MLPA and the other loan sale agreements that Chase had entered into with the
Plaintiffs by issuing the forgiveness letters and by releasing the liens on loans Chase had sold to
the Plaintiffs.
173. By sending out forgiveness letters to borrowers whose loans it had sold to the
Plaintiffs, and by releasing liens securing loans it had sold to the Plaintiffs, Chase destroyed the
Plaintiffs’ business reputation and their relationships with the borrowers whose loans they had
purchased from Chase, which reputation Plaintiffs had spent years building.
174. The Defendants had no legitimate basis for taking the actions they took. Instead,
they took those actions in deliberate violation of Chase’s obligations under the MLPA and the
other loan sale agreements, in violation of the Bank’s and JPMC’s obligations under the NMSA
Consent Judgment, and the Defendants’ obligation of good faith and fair dealing.
175. The Bank and JPMC are liable to Plaintiffs for compensatory and punitive
damages.
{N0084396 3 } 35
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page36
36ofof190
46
177. Defendants, by their statements, acts, omissions and conduct, knowingly made
178. Defendants’ statements include those made by Guerrero and others beginning in
October 2008 that (a) misrepresented that Defendants would provide a complete Exhibit A to the
MLPA detailing the full and customary servicing information for all the loans sold under the
MLPA; (b) misrepresented that Defendants would provide all original loan documentation to
MRS relating to the purchased loans; and (c) misrepresented that the loans sold to MRS under
the MLPA consisted of first lien mortgage loans that had been made and serviced in full
179. Defendants knew, at the time those representations were made, that a significant
percentage of the loans included in the portfolio sold to MRS were deficiency claims, not first
lien mortgages, and that the Defendants’ servicing of the loans had violated federal, state, and
local laws.
180. Defendants knew, from inception of the negotiations, that their intention was to
dump on MRS a massive volume of liabilities that Defendants had incurred as a result of their
deliberate failure to comply with state and federal law concerning residential mortgage loans.
181. From February 2009 until November 2010, Guerrero and others repeatedly
misrepresented to Plaintiffs that Defendants were in the process of compiling complete servicing
data for the MLPA portfolio of loans. Following receipt of the Corrupted List, Schneider had
multiple conversations and exchanges of emails with representatives of Chase regarding the
absence of information identifying borrowers and collateral. Each time Schneider raised the
{N0084396 3 } 36
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page37
37ofof190
46
subject, he was assured that Defendants were in the process of assembling it and that the problem
was converting information from Washington Mutual’s system. In fact, as MRS later learned,
Defendants never attempted to provide a complete Exhibit A; they never provided to MRS an
Exhibit A as required by the MLPA; and none of the loans included on Exhibit A were acquired
182. But for the false assurances made by the Defendants, MRS would never have
signed the MLPA and invested the enormous personnel time required to uncover the information
Plaintiffs’ long-standing business relationship with Defendants and the apparent sincerity of the
184. As a result of Defendants’ fraudulent conduct, MRS has incurred and continues to
186. Defendants have, by their statements, acts, omissions and conduct, at the very
least made negligent misrepresentations to MRS about their ability and intention to provide a
187. Defendants had exclusive knowledge of the material facts relating to the loans
sold to MRS under the MLPA and whether or not Defendants had originated and serviced those
{N0084396 3 } 37
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page38
38ofof190
46
188. Defendants knew that MRS could not possibly obtain the facts concerning the
purchased loans prior to signing the MLPA and that, thereafter, MRS could only obtain those
189. Defendants had a duty to be honest and forthright with MRS and to not
negligently misrepresent the condition or nature of the collateral and the quality of the loans.
190. Defendants knew that there were pervasive violations of federal, state and local
misrepresentations and Defendants are liable to MRS for all of the damages resulting therefrom.
194. Defendants have disparaged Plaintiffs’ title to the loans and mortgages purchased
from the Defendants by, inter alia, (a) sending debt forgiveness letters to borrowers whose loans
had been sold to Plaintiffs; (b) recording lien releases of liens that had been transferred to the
Plaintiffs; and (c) falsely informing borrowers, insurance companies, collection agencies and
others, that Defendants own loans when, in fact, the loans had been sold to Plaintiffs.
195. Defendants’ statements and filings have destroyed or impaired the validity of
Plaintiffs’ title to the loans and the collateral securing the loans and have prevented Plaintiffs
from collecting payments from borrowers who received the debt forgiveness letters from the
Defendants or who were badgered by collection agencies, hired by Defendants, to collect debt
{N0084396 3 } 38
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page39
39ofof190
46
196. Defendants acted in clear violation of their contractual obligations with a specific
197. Defendants knew that their conduct would have a devastating impact upon
198. Defendants’ conduct had a devastating impact upon Plaintiffs’ business and
199. Defendants caused borrowers, whose loans Plaintiffs had purchased, to cease
making payments on the loans and to threaten to take, or to take, legal action against the
200. As a direct and proximate result of Defendants’ conduct, Plaintiffs have incurred,
202. At all relevant times, Plaintiffs were “persons” within the meaning of RICO, 18
U.S.C. § 1961(3) and Plaintiffs were each a “person injured in his or her business or property by
203. At all relevant times, Defendants were “persons” within the meaning of RICO, 18
U.S.C. §§ 1961(3) and 1962(c) and were employed by or associated with an “enterprise” within
204. The Defendants and their officers formed an enterprise as described in 18 U.S.C.
§ 1962(c) which included the various debt collection agencies that the Defendants utilized in
connection with the loans sold to the Plaintiffs, the outside services involved in sending out the
thousands of debt forgiveness letters to borrowers whose loans had been sold to Plaintiffs or
{N0084396 3 } 39
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page40
40ofof190
46
other third parties, and the persons employed by other entities who assisted the Defendants in
releasing liens on collateral that had been transferred to the Plaintiffs or other third parties.
205. Each of the Plaintiffs worked closely with homeowners whose mortgage loans
had been transferred to the Plaintiffs from the Defendants so as to establish sustainable payment
plans which allowed the borrowers to build up their credit and stay in their homes and allowed
Consumer Relief Provisions of the NMSA Consent Judgment which required the Defendants to
provide $4.2 billion of Consumer Relief and the RMBS Settlement which required the
Defendants to provide $4 billion of Consumer Relief as part of the Defendants’ $13 billion
207. The Defendants conspired to develop a means of satisfying the Consumer Relief
Provisions which would cost the Defendants nothing and yet provide the Defendants with
documentation which they could show to the DOJ, the Government, and the States, to make them
believe that the Defendants had provided, altogether, $8.2 billion of consumer relief.
208. At all relevant times Defendants conducted and participated in the conduct of the
enterprise’s affairs through a “pattern of racketeering activity” within the meaning of RICO, 18
U.S.C. § 1961(5), in violation of RICO, 18 U.S.C. § 1962(c) by using the interstate wires and
209. The pattern of racketeering activity in which the Defendants engaged through
their enterprise, within the meaning of 18 U.S.C. § 1961(1) included the predicate acts of mail
fraud in violation of 18 U.S.C. § 1341, wire fraud in violation of 18 U.S.C. § 1343, and
obstruction of justice in violation of 18 U.S.C. § 1503. The Defendants used the wires and mails
{N0084396 3 } 40
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page41
41ofof190
46
to make false communications with borrowers, with collection agencies, with municipalities,
210. The goal of the enterprise was to induce the governmental entities who were
parties to the NMSA Consent Judgment and the RMBS Settlement to believe that Defendants
had fulfilled their obligation to provide $8.2 billion of consumer relief when, in fact, the
211. Each of the Defendants committed and/or aided and abetted the commission of
212. The predicate acts include Defendants’ use of interstate mail and wires to make
b. Defendants represented to Schneider that the loans listed in the November 2008 Data
Tape, which Defendants sent to and discussed with Schneider in and around
November 2008, consisted only of “first lien mortgages,” when in fact the tape lacked
sufficient information to make that assertion accurately and—based upon subsequent,
painstaking inquiry by MRS—it was determined that most of the loans on the tape
were deficiency claims, not first lien mortgages.
c. Chase delivered to MRS the “Corrupted List” in February 2009, which Defendants
represented was an updated schedule of the loans MRS was acquiring, but in fact was
materially incomplete, and was designed to lure MRS into falsely believing that
Defendants had transferred the first lien mortgages to MRS as it had warranted it had
done.
d. Defendants’ claimed in and around March of 2009 that the reason why the November
2008 Data Tape and the Corrupted List were deficient was related to logistical delays
associated with converting information from Washington Mutual’s system, when in
{N0084396 3 } 41
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page42
42ofof190
46
fact the sold loans had never been owned by Washington Mutual.
e. Defendants represented in the MLPA that the mortgage loans being acquired by MRS
were in compliance with all federal, state and local laws when, in fact, Defendants
had knowingly failed to comply with virtually all state and federal legal requirements
with respect to residential mortgage loans.
f. Defendants sent a December 2009 e-mail to MRS indicating that they had included an
additional 850 loans in the portfolio that had been sold to MRS, when in fact
Defendants were referencing loans that were not included on the November 2008 data
tape; instead these were loans for which Defendants were seeking to transfer liability
to MRS.
i. Defendants used the mails and the wires to implement the Pre DOJ Lien Release
Project which they knew included the release of liens they did not own.
{N0084396 3 } 42
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page43
43ofof190
46
activity” within the meaning of 18 U.S.C. § 1961(5). These acts allowed Defendants to fulfill
their legal obligations under the consumer relief provisions of the NMSA Consent Judgment and
the RMBS Settlement without expending any money or relinquishing any assets.
215. Defendants’ RICO conspiracy has impacted the Plaintiffs in, inter alia, the
following ways:
a. Plaintiffs have lost revenue from borrowers who ceased making payments, or
disputed the Plaintiffs’ right to collect payments or initiate foreclosure proceedings, after the
borrowers received Forgiveness Letters from, or had liens on the subject properties improperly
released by, the Defendants.
d. Defendants’ acts of mail and wire fraud have harmed Plaintiffs’ reputation and
relationship with borrowers, resulting in the destruction of Plaintiffs’ successful business model,
which converted non-performing loans into sustainable payment plans that provided substantial
streams of income to the Plaintiffs while enabling many borrowers to keep their homes.
e. Defendants’ acts of mail and wire fraud have exposed Plaintiffs to legal liability
for Defendants’ failure to deter community blight, comply with consumer protection laws and
otherwise fulfill their servicing obligations, the scope of which is not yet ascertainable.
216. Plaintiffs have lost the benefit of the bargain under loans purchased from
{N0084396 3 } 43
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page44
44ofof190
46
217. Pursuant to RICO, 18 U.S.C. § 1964(c), Plaintiffs are entitled to recover from
218. The predicate acts are part of a larger effort by Defendants to relieve themselves
of their legal obligations and liabilities and to conceal their improper receipt of credit under, inter
219. Defendants regularly and repeatedly used interstate mail and wires, to defraud the
parties to the NMSA Consent Judgment, the RMBS Settlement, the Plaintiffs, and the borrowers
220. The acts alleged were related to each other by virtue of common participants,
common victims, a common method of commission, and the common purpose and common
result of evading Defendants’ obligations to the Plaintiffs, evading Defendants’ obligations under
anti-blight laws, and allowing Defendants to fraudulently satisfy the consumer relief provisions
contract.
3. On the third claim, awarding 1st Fidelity compensatory and punitive damages for
breach of contract.
4. On the fourth claim, awarding Plaintiffs compensatory and punitive damages for
conversion.
{N0084396 3 } 44
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page45
45ofof190
46
5. On the fifth claim, awarding plaintiffs compensatory and punitive damages for
6. On the sixth claim, awarding Plaintiffs compensatory and punitive damages for
misrepresentation.
9. On the ninth claim, awarding Plaintiffs treble damages for Defendants’ violation
10. And such other relief as the Court deems just and proper.
Lance Gotthoffer
[email protected]
45 Broadway
New York, New York 10006
(212) 599-3322
{N0084396 3 } 45
Case
Case 1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67 Filed
Filed08/05/16
08/24/15 Page
Page46
46ofof190
46
{N0084396 3 } 46
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-1
Filed
Filed
08/05/16
08/24/15
Page
Page
47 of
1 of
190
8
EXHIBIT 1
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
S & A Capital Loan Acquired From Chase Document
Document
115-2
67-1
Filed
Filed
08/05/16
08/24/15
Page
Page
48 of
2 of
190
8
Last Name First Name Address City St. Zip Date Aqcuired Original Assgn Recv'd Collateral File Received
Holcomb Arlene 19111 Shakerwood Drive Warrensville Heights OH 44122 6/1/2005 6/6/2005
Douglas Samuel 531 Church St, SW North Canton OH 44720 6/13/2005 6/17/2005
Allsop Allison 936 Austin Ave Salt Lake City UT 84106 6/1/2005 6/6/2005
Rutter Jeffrey/Debra 13 Conestoga St Washington Boro PA 17582 6/10/2005 6/10/2005
Allen Emanuel 2804 Quail Run Drive Mesquite TX 75149 6/1/2005 6/10/2005
Swantek Michael 14205 South Ave Ext Columbiana OH 44408 6/1/2005 6/10/2005
Gibson Pamela 676 Erickson Ave Columbus OH 43213 6/17/2005 6/17/2005
Turek Stephen 3050 Dalesend Dr Magna UT 84044 6/15/2005 7/5/2005 7/7/2005
Thompson Dale 9932 S Glasgow Drive South Jordan UT 84095 6/17/2005 6/27/2005 7/7/2005
Gitierrez Noe 6313 Garfield Ave Hammond IN 46324 6/17/2005 6/27/2005 7/7/2005
Westborooks Antonio 15420 Ridpath Ave Cleveland OH 44110 6/22/2005 7/5/2005 7/7/2005
Webb Dennis 6039 Blackley Ct Indianapolis IN 46254 6/30/2005 7/25/2005 7/28/2005
Shaw Mable 6464 Postell Drive Hephzibah GA 30815 6/30/2005 7/25/2005 7/28/2005
Phillips Lanette 5208 84th Ct Brooklyn Park MN 55443 6/30/2005 7/12/2005 7/28/2005
Zahler Bruce 2629 Edgewood Ln Eau Claire WI 54703 7/14/2005 7/29/2005 8/25/2005
Sims Charles/Stella 254 Howell Ter, SW Atlanta GA 30331 7/25/2005 8/18/2005 8/17/2005
Sheilds Jackie/Omeca 618 Murph Rd Pauline SC 29374 7/25/2005 8/18/2005 8/25/2005
Hinton/Levasseur Chad/Michelle 6209 Wellington Place Dayton OH 45424 7/25/2005 8/18/2005 8/25/2005
Garner Steve/Stephanie 5029 Kiamesha Way Mesquite TX 75150 7/25/2005 8/18/2005 8/25/2005
Sawastuk William/Audrey 12450 Nelson Parkman RoadGarrettsville OH 44231 7/25/2005 8/18/2005 8/25/2005
Henderson Ricky/Rosalinda 13326 Scenic Glade Drive Houston TX 77059 8/10/2005 9/12/2005 9/28/2005
Lancaster Gerald/Evelyn 6780 Marvin Ave College Hill StationOH 45224 8/16/2005 10/10/2005 8/17/2005
Shultz Alice 707 E 1st Street Whitewater KS 67154 8/22/2005 9/15/2005 10/18/2005
Anderson Eric/Natalie 8804 Splitarrow Dr Austin TX 78717 8/30/2005 10/10/2005 10/19/2005
Newport Richard 3500 Flemming Ave Pittsburg PA 15212 9/6/2005 10/10/2005 10/18/2005
Harshaw Sheila 2227 Miles Road Cincinnati OH 45231 9/6/2005 10/10/2005 10/18/2005
Gaudette/Hankins Anne/Robert 2700 Jackson Highway Chehalis WA 98532 9/26/2005 12/5/2005 12/5/2005
Bolois Stephen 1037 Oak Ave Barberton OH 44203 9/27/2005 11/9/2005 12/21/2005
McNeir/Evans Beverly 331Queen Road Medway OH 45341 9/28/2005 11/4/2005 11/7/2005
Sutton Nina 31503 Acoma Road Pueblo CO 81006 10/10/2005 11/4/2005 11/7/2005
Wallberg Michael/Christy 2218 Harrison Blvd Ogden UT 84401 11/4/2005 1/17/2006 2/3/2006
Meadows Michael/Edwina 3514 Seabrook Ave Columbus OH 43227 11/4/2005 11/25/2005 7/12/2007
Selogy Janet 3151 Buckwalter Dr, SW Massilion OH 44646 11/29/2005 12/21/2005 1/10/2006
King Jeffrey/Crystal 2916 East 112th St Cleveland OH 44104 11/29/2005 12/21/2005 1/10/2006
Guile Ronald / Sandra 3126 Leicester Drive Mathews NC 28104 12/29/2005 1/17/2006 2/3/2006
Hager Clayton 345 N Main Street Crittenden KY 41030 12/29/2005 1/17/2006 2/3/2006
Depkin Derek 295 Overlook Dr Covington GA 30016 1/19/2006 1/17/2006 2/3/2006
Chesnut Randy / Charlena 1376 Chaney Ridge Road London KY 40741 1/30/2006 2/16/2006 1/30/2006
Shifflet/Gillum Misty 2592 Grasmere Ave Columbus OH 43211 1/30/2006 2/16/2006 2/28/2006
Scott / Anders Mary / James 7600 NW 12th St Oklahoma Caity Ok 73127 1/30/2006 2/16/2006 2/28/2006
Hale Richard 813 Meadow Park Dr White Settlement TX 76108 1/30/2006 3/3/2006 3/2/2006
Rinehart Mark 3572 N Lake Shore Drive Jamestown OH 45335 2/25/2006 4/14/2006 4/15/2006
Tweedy Michael 4418 Catamran Dr Columbus OH 43207 4/3/2006 4/14/2006 4/20/2006
Tirado Jose 628 W. Lexiigton Elkhart IN 46514 4/29/2006 5/10/2006 5/18/2006
Hallihan Patrick 281 Heard St. Worcester MA 01603 4/29/2006 5/10/2006 5/18/2006
Spleet Jeffrey T 22211 Dorion St St Clair MI 48082 5/31/2006 6/16/2006 6/29/2006
Jewell Keith & Lydia 16736 W Outer Drive Dearborn heights MI 48127 5/31/2006 6/16/2006 6/29/2006
Solberg Gerald A 10 Charleston Chatham IL 62629 5/31/2006 6/16/2006 6/29/2006
Spaulding George E. & Darlene7144 Trotter Rd Camby IN 46113 6/28/2006 7/21/2006 7/27/2006
Welch Robert L. & Shirley S.
2530 Woodstock Pl Boulder CO 80305 6/28/2006 7/21/2006 7/27/2006
Rayner Mark & Debra 23349 Deziel St Saint Clair MI 48082 7/28/2006 8/24/2006 9/7/2006
Lane Norma & James 2201 Monteith St Flint MI 48504 7/28/2006 8/24/2006 9/7/2006
Brown Eugene & Debra 8225 Longview Dr, NE Warren OH 44484 7/28/2006 8/24/2006 9/7/2006
Archuleta Charles & Tera 11954 Quam Dr Northglenn CO 80233 8/31/2006 11/30/2006 8/31/2006
Thomas Kevin & Angela 16047 Friend Ave Maple Heights OH 44137 8/31/2006 11/30/2006 8/31/2006
Keeton / Laug Garry / Carol 127 Cambell Road Harrison OH 45030 8/31/2006 11/30/2006 12/14/2006
Patton Donald 915 Reber St Green Bay WI 54302 12/13/2006
Antuna John 8880 Brookline Ave Plymouth MI 48170 12/19/2006
Ferst Harold 3188 Village Glen Drive Snellville GA 30039 1/9/2007 2/27/2007 3/8/2007
Cummings Kevin & Michele 344 American School Rd Fombell PA 16123 1/18/2007
Lockwood Constance 1250 Palisades Dr Lewisville TX 75067 1/26/2007
Booker Christopher 114 Bradley Trail Elizabethtown KY 42701 1/31/2007 2/15/2007 2/22/2007
Hearn Jimmie 2658 Anderson St Dallas TX 75215 2/15/2007 3/1/2007 3/1/2007
Waterfield Donald & Connie 601 Bethany Church Road Moore SC 29369 2/20/2007 3/5/2007 5/17/2007
Murray Connie 1816 Beachwood Drive Plainfield IN 46168 2/23/2007 4/2/2007 4/19/2007
Sexton / Springer Michael / Juanita 8698 Lisbon Street E Louisville OH 44641 2/23/2007 3/1/2007 3/8/2007
Goins Amy 5015 Chestnut Drive Sylvania OH 43560 2/23/2007 3/1/2007 3/22/2007
Krumm James 241 Emmit Ave Columbus OH 43228 2/23/2007
McCune Richard D & Julia M13739 W Purdue Ave Morrison CO 80465 2/26/2007 3/13/2007 3/13/2007
Sartor Mark & Lisa 1007 Tanager Trail Howell MI 48843 2/26/2007 3/13/2007 3/22/2007
Foster Mae 1139 Wing Street Cincinnati OH 45204 2/27/2007 4/2/2007 4/5/2007
Vinet Craig 801 Randolph Ave Harahan LA 70123 2/28/2007 3/16/2007 3/16/2007
Rugg Steven & Marsha 2295 Palnleaf Ct Columbus OH 43235 2/28/2007 4/2/2007 4/2/2007
Mariola Annamaria 695 Singley Ave Akron OH 44310 2/28/2007 4/2/2007 4/4/2007
Elzholz Mark & Susan 48 East Mapledale Ave Akron OH 44301 2/28/2007 4/2/2007 4/4/2007
Hambleton Carrie 339 Cline Street Huntington IN 46750 2/28/2007 3/16/2007 3/29/2007
Anderson Blake 9623 Silver Lake Road Linden MI 48451 2/28/2007 3/16/2007 3/22/2007
Stewart Anita 3382 Camelia St Zachary LA 70791 2/28/2007 3/8/2007 3/22/2007
Frech / Dellapenna John / Wanda 8743 Wawick Road, SE Warren OH 44484 2/28/2007 3/13/2007 4/5/2007
Clausing Susan 440 Grant Ave Ogden UT 84404 2/28/2007 4/19/2007 4/19/2007
Martinez Mario 1215 E Kalama Ave Madison Heights MI 48071 2/28/2007 4/2/2007 4/5/2007
Dennison Harold 2700 Newbanks Road Parkersburg WV 26104 2/28/2007 4/2/2007 4/5/2007
Kelly Scott & Michelle 6142 Rising Sun Dr Grove City OH 43123 2/28/2007 4/2/2007 4/5/2007
Willis Mark 17775 Beckfield Ave Baton Rouge LA 70817 2/28/2007 4/2/2007 4/5/2007
Good Richard 12719 Kirton Ave Cleveland OH 44135 2/28/2007 4/2/2007 4/5/2007
Fowee David & Susan 3859 Carrington Way Hamilton OH 45011 3/16/2007 3/29/2007 4/5/2007
Ferguson William & Deborah 3763 Louisa Street Pittsburgh PA 15227 3/20/2007 4/4/2007 4/5/2007
Lutz Toni 3339 Felicity Dr Cincinnati OH 45211 3/21/2007 4/4/2007 4/5/2007
Edmonson Desiree 1430 Cedar Ave Cincinnati OH 45224 3/23/2007 4/4/2007 4/5/2007
Mitchell Michael 2812 Mitchell Drive Cheboygan MI 49721 3/27/2007 4/30/2007 5/3/2007
Heard Mary 859 Brandy Oaks Lane Stone Mountain GA 30088 3/28/2007 5/1/2007 5/1/2007
Stiles Dewey 74 Horseshoe Loop Kingston GA 30145 3/28/2007 4/9/2007 4/9/2007
Robinson Jackie 3663 Judy Lane Dayton OH 45405 3/28/2007 4/11/2007 4/11/2007
Jackson Jana 127 Jennifer Lane Lilburn GA 30047 3/28/2007 4/11/2007 4/19/2007
Vaqera Reymundo 3808 Hogan Drive Lorain OH 44053 3/29/2007 4/19/2007 4/19/2007
Coleman Travis & Rosalind 721 N 70th Street St Louis IL 62203 3/29/2007 4/19/2007 4/19/2007
Campos Jorge & Lourdes 960 N Bankerd Ave Nogales AZ 85621 3/30/2007 4/19/2007 4/24/2007
Wallace David 6377 LedgebrookDrive Brookpark OH 44142 3/30/2007 4/19/2007 4/19/2007
Haynes Daniel 2409 Ring Necked Dr Indianapolis IN 46234 3/30/2007 5/9/2007 5/15/2007
Knierien Joe 5707 Bayberry Way Sugarland TX 77479 3/30/2007 4/19/2007 4/19/2007
Autry Rex 190 Stallion Run Dallas GA 30132 3/30/2007 4/11/2007 4/9/2007
Randall Doug 5182 County Road 44 South Haven MN 55382 3/30/2007 4/19/2007 4/19/2007
Evans Steven 1414 Millridge Drive Greenwood IN 46143 1 of3/30/2007
7 4/19/2007 5/17/2007
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
S & A Capital Loan Acquired From Chase Document
Document
115-2
67-1
Filed
Filed
08/05/16
08/24/15
Page
Page
49 of
3 of
190
8
Last Name First Name Address City St. Zip Date Aqcuired Original Assgn Recv'd Collateral File Received
Browner Kevin 1229 Blanchard Ave Cincinnati OH 45205 3/30/2007 4/30/2007 5/3/2007
Helton Charles 4452 Harston Ave Columbus OH 43207 3/30/2007 4/19/2007 5/3/2007
Vukusich Brian E 7761 Mountain View RoadMessemer MI 49911 3/30/2007 4/11/2007 4/19/2007
Hagadorn Thomas & Linda 2430 Logan Ave Superior Wi 54880 3/30/2007 4/19/2007 4/19/2007
Brooks Patricia Lynn 8133 S. Old Union Church Rd
English IN 47118 4/17/2007 4/30/2007 4/30/2007
Warren Billy 4524 Lincoln Street Gary IN 46408 4/17/2007 5/8/2007 5/9/2007
Spence Richard & Tammi 324 East Main Street Eaton OH 45320 4/17/2007 4/30/2007 5/3/2007
McCrary Doris 2298 Dresden Street Columbus OH 43211 4/17/2007 4/30/2007 5/3/2007
Quiroz Raymond 2126 Des Jardines Street Houston TX 77023 4/17/2007
Fedrick Gregory/Wendy 1643 Burketts Ferry Road Hazlehurst GA 31539 4/24/2007 5/3/2007 5/4/2007
Voland (2) Eric 8705 Jefferies Ave Cleveland OH 44105 4/24/2007 5/3/2007 5/3/2007
Meidinger Sandy 26357 County Road 9 Verndale MN 56481 4/24/2007 4/30/2007 5/3/2007
Bracey Damita 1334 Jenks Street Port Huron MI 48060 4/24/2007 5/3/2007 5/17/2007
Wilson Keith 9019 Volta Street Lanham MD 20706 4/24/2007 5/11/2007 5/17/2007
Babnik Richard 1754 Kinsman Road North Bloomfield OH 44450 4/24/2007
Blake Roger & Debra JeanHC 61 Box 115A New Martinsville WV 26155 4/24/2007
Andrews Stan 2690 Ashley Downs Lane College Park GA 30349 4/30/2007 5/9/2007 5/15/2007
Woods Christopher & Renee608 Shamrock Circle Ponca City OK 74601 4/30/2007 5/8/2007 5/9/2007
Greggerson Nicholas 312 Pearhill Drive West Carrolton OH 45449 4/30/2007 5/8/2007 5/9/2007
Person Dawn 8912 Edwardson Lane Austin TX 78749 4/30/2007 5/11/2007 5/17/2007
Craver Floyd/Melinda 136 N 7th Street Middletown IN 47356 4/30/2007 5/9/2007 5/31/2007
Brown Mary 464 Speigle Street Lexington KY 40508 4/30/2007 5/11/2007 5/17/2007
Woods James 3512 East Maxwell Drive Oklahoma City OK 73121 4/30/2007 5/9/2007 5/17/2007
Beckham Mona 35757 West 146th Street Gardner KS 66030 4/30/2007 7/2/2007 7/2/2007
Uecker Deanna 7942 W Coldspring Road Greenfield WI 53220 4/30/2007 5/8/2007 5/17/2007
Badeaux Reginald /Erin 107 East 7th Ave Covington LA 70433 4/30/2007 5/8/2007 5/17/2007
Bodine Claude 420 West Haller Street Lima OH 45801 4/30/2007 5/8/2007 5/17/2007
Craver Floyd/Melinda 136 N 7th Street Middletown IN 47356 4/30/2007 5/9/2007 5/31/2007
Hader Christopher 4019 Central Street Evans CO 80620 4/30/2007 5/9/2007 5/17/2007
Stoltenberg Kenneth 13111 Colfax Street Cedar Lake IN 46303 4/30/2007
Michaels Christopher 1259 Main Street Lakemore OH 44250 5/7/2007 5/15/2007 5/17/2007
Wilbanks Donald & Patsy 1614 Robinson Road Gastonia NC 28056 5/7/2007 5/24/2007 5/24/2007
Caley Robert/Nancy 6320 Peerless Farms RoadPeyton CO 80831 5/24/2007 6/8/2007 6/8/2007
Strozier Robert 3200 Earlham Dr Dayton OH 45406 5/24/2007 5/29/2007 5/31/2007
Nolen Sharon 3573 Kenoak Lane Cincinnati OH 45213 5/24/2007 6/6/2007 6/14/2007
Bedard Lowell 1698 Galion Ave Cleveland OH 44109 5/24/2007 6/6/2007 6/14/2007
Henderson Spencer & Patricia 179 Westridge Drive Henderson NC 27536 5/24/2007 5/24/2007 5/31/2007
Lucio Anne 8612 Nebraska Ave Toledo OH 43617 5/24/2007 5/24/2007 5/31/2007
Simon Jeffrey 3014 Lower Huntington Rd.Fort Wayne IN 46809 5/31/2007 6/22/2007 7/2/2007
Brown Charles 8308 S Constance Ave. Chicago IL 60617 5/31/2007 7/20/2007 8/2/2007
Deal Richard 8303 Roanoke Dr. Fort Wayne IN 46835 5/31/2007 6/28/2007 7/2/2007
Specht Richard 1200 30th Street Rd Greeley CO 80631 5/31/2007 6/22/2007 7/2/2007
Lewis Joseph 721 Hendrix St. Altus AR 72821 5/31/2007 6/28/2007 7/2/2007
Poole Wayne/Margarett 4440 Old State Rd. Brandenburg KY 40108 5/31/2007 6/8/2007 6/14/2007
Griffin John 1565 Van Dorn St. Mobile AL 36605 5/31/2007 7/6/2007 7/12/2007
Butler Cynthia 1500 Forsythe Ave. Monroe LA 71021 5/31/2007 6/22/2007 6/28/2007
Narm Michael 322 Mill St. New Lexington OH 43764 5/31/2007 7/11/2007 7/12/2007
Frater Converse 5 Hankin Loop Poughkeepsie NY 12601 5/31/2007 6/28/2007 7/26/2007
Spears (Baruxes) Christy 9038 NW Blacklick Eastern Pickerington
Rd OH 43147 5/31/2007 6/29/2007 7/26/2007
Newton Jennifer 6600 S Newland Cir Littleton CO 80123 5/31/2007 7/6/2007 7/12/2007
Knowles Paul 403 2nd Ave. Holcomb IL 61043 5/31/2007 6/22/2007 6/28/2007
Escalante Eduardo 6533 Jason Ct. Portage IN 46368 5/31/2007 7/11/2007 7/12/2007
Harrell Hilton 437 W Clinton St. Elmira NY 14901 5/31/2007 7/13/2007 9/10/2007
Goldberg Greg 952 Mystic Lane Troy OH 45373 6/29/2007 7/3/2007 7/6/2007
Bednarz Timothy 2025 Main Street Stevens Point WI 54481 6/29/2007 7/6/2007 7/6/2007
Steere Benjamin 1423 Pinehurst Ct Columbus OH 43223 6/29/2007 8/28/2007 8/28/2007
Mayer Brett/Jennifer 2930 Big Timber Cir GreeN Bay WI 54313 6/29/2007 7/18/2003 8/6/2007
Noble Craig 6699 South Dahlia Circle Lilleton CO 80121 6/29/2007 7/26/2007 8/6/2007
Burroughs Beatrice 222 Flair Dr Montgomery AL 36110 6/29/2007 7/18/2007 8/6/2007
Ellington Robert E. 8310 Locust Ave. Gary IN 46403 6/29/2007 7/24/2007 8/6/2007
Alderte Ronald 8115 Mandarin PL NW Alburquerque NM 87120 6/29/2007 8/28/2007 8/31/2007
Skaggs Freddy 6565 S 300 W. Shelbyville IN 46176 6/29/2007 8/7/2007 8/7/2007
Blanc Rebecca L. 4506 Cedarweed Blvd. Pueblo CO 81001 6/29/2007 7/18/2007 8/2/2007
Miller Dennis 1150 Old Vincennes Trl O Fallon IL 62269 6/29/2007 8/1/2007 8/1/2007
Williams Richard 952 Amsterdam Dr. Colorado Springs CO 80907 6/29/2007 7/6/2007 7/12/2007
Price Kari 764 E. 350 N. Payson UT 84651 6/29/2007 8/31/2007 9/6/2007
Harding Rex L 8979 3rd St.203 Baroda MI 49101 6/29/2007 7/26/2007 7/26/2007
Hughes William 1779 Creekhill Road Columbus OH 43223 6/29/2007 7/3/2007 7/12/2007
Guilbeaux Charlotte 772 Highway 171 Lake Charles LA 70611 6/29/2007 7/18/2007 7/26/2007
Beymer Brad 120 Cedarlawn Dr. Dayton OH 45415 6/29/2007 7/18/2007 7/26/2007
Romano Alice K. 11590 Shipwatch Dr. # 502 Largo FL 33774 6/29/2007 7/13/2007 7/26/2007
Freeman Gary D 1909 Arlington Rd. Lafayette IN 47904 6/29/2007 7/18/2007 7/26/2007
Moore Paul 4174 Bowling Green Road Franklin KY 42164 6/29/2007 7/18/2007 7/26/2007
Breakwell Kerry L 201 Edgewood Dr. Sarver PA 16055 6/29/2007 8/14/2007 8/23/2007
Dayhuff Janice 58810 Klumbis Rd Dowagiac MI 49047 6/29/2007 7/6/2007 7/12/2007
Powell Frank C. 5615 Stone Path Dr. Middletown OH 45042 6/29/2007 7/18/2007 7/26/2007
Armstrong David 262 S Arlington Ave. Indianapolis IN 46219 6/29/2007 7/11/2007 7/12/2007
Shelstad Scott 12875 Hillcrest Dr. Longmont CO 80504 6/29/2007
Harrison Rodney 85 Delmer Lane Corydon IN 47112 6/30/2007 7/20/2007 7/26/2007
Chhe Kowa 61 Teneyck Ave Greenwood Lake NY 10925 7/10/2007 7/24/2007 8/6/2007
Muse Lionel 2433 Colonial Blvd New Orleans LA 70092 7/10/2007 7/24/2007 8/6/2007
Roney Nancy 1104 N 8th Ave E Newton IA 50208 7/11/2007 8/7/2007 8/7/2007
Khan Humayoon/Sharla 2112 Smokymill Road Dublin OH 43016 7/11/2007 7/24/2007 7/26/2007
Freyberg Scott 350 Firestone Dr. Delaware OH 43015 7/13/2007 8/15/2007 8/15/2007
Garcia Victor/Cheryl 3199 Arlene St Portage IN 46368 7/13/2007 8/9/2007 8/9/2007
Chambers Jeffery 706 Aspen St Hebron IN 46341 7/13/2007
Sindiong Marygane 119 Pigeon Lp Lafayette LA 70508 7/31/2007 9/19/2007 9/20/2007
Cage Earnest 2595 Clearpark Cove Memphis TN 38127 7/31/2007 8/21/2007 8/31/2007
Scoby Jacquelyne 158 Edwards Rd. West Monroe LA 71292 7/31/2007 8/13/2007 8/13/2007
Bickham Jerry 142 S Cherrywood Ln Pear River LA 70452 7/31/2007 8/21/2007 8/21/2007
Evans Darrell/Martha 6402 20th NE Tulalip WA 98271 7/31/2007 9/10/2007 8/31/2007
Voland (3) Eric 8705 Jeffries Cleveland OH 44105 7/31/2007 9/19/2007 9/20/2007
Baker Curtis 660 HW EE Winfield MO 63389 7/31/2007 8/16/2007 8/16/2007
Vest II Edwin 5240 Clematis Way West Jordan UT 84084 7/31/2007 8/16/2007 8/16/2007
McCowan Eileen 3433 Stanford Rd Danville KY 40422 7/31/2007 8/15/2007 8/15/2007
Bratsch Travis 310 Center Ave E Clara City MN 56222 7/31/2007 8/15/2007 8/15/2007
Gross Robin 5757 Cotner Rd Lima OH 45807 7/31/2007 8/15/2007 8/23/2007
Olin Arthur 6652 Harlan St Arvada CO 80003 7/31/2007 8/9/2007 8/9/2007
Boggs Michael R 5365 Red River Indianapolis IN 46221 7/31/2007 8/21/2007 8/23/2007
Toon Mary E. 47230 Lincoln Ave Lexington Park MD 20653 7/31/2007 8/16/2007 9/6/2007
Wilson Robert 939 Udell St. Lancaster OH 43130 7/31/2007 10/23/2007 11/15/2007
Bell Kenneth 1900 Piety St. New Orleans LA 70117 7/31/2007 8/16/2007 11/18/2010
Hammond Terry/Donna 312 E. 41st Ct. Loveland CO 80538 7/31/2007 8/14/2007 8/23/2007
Lakes Kathy A 324 S Broadway St. Trotwood OH 45426 7/31/2007 8/15/2007 8/23/2007
Legnon Angelina 627 W. 25th Ave Covington LA 70433 7/31/2007 8/21/2297 11/1/2007
Pothoff Paul 233 Oakdale Prudenville MI 48651 7/31/2007 8/21/2007 8/23/2007
Mcalister Robert M 10 Chandon Court Mandeville LA 70448 7/31/2007
Page Larry 2674 General Collins Dr New Orleans LA 70114 8/15/2007 9/4/2007 9/20/2007
Luevano Jose 375 Fir Ln Broomfield CO 80020 2 of8/15/2007
7 8/31/2007 9/6/2007
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
S & A Capital Loan Acquired From Chase Document
Document
115-2
67-1
Filed
Filed
08/05/16
08/24/15
Page
Page
50 of
4 of
190
8
Last Name First Name Address City St. Zip Date Aqcuired Original Assgn Recv'd Collateral File Received
Muntz Dennis 765 Prosper Hill Rd Jamestown NY 14701 8/15/2007 8/31/2007 9/6/2007
Milner John 100 Tauton Ct Garner NC 27529 8/15/2007 9/7/2007 9/20/2007
Smith Cherylee 123 West Park Lane Summerville SC 29483 8/16/2007 8/31/2007 8/31/2007
Westphal Terry/Marianne 448 Mcintosh Almont MI 48003 8/16/2007 9/6/2007 9/20/2007
Hensley Jackie 5079 Tilbury Rd Huber Heights OH 45424 8/16/2007 9/4/2007 9/6/2007
Crane Mary 3369 Franklin Street Rd. Auburn NY 13021 8/16/2007 9/7/2007 11/16/2007
Bartz David 10651 Eudora Way Thorton CO 80233 8/20/2007 9/7/2007 9/7/2007
King III Clifford 633 Utah St., Toledo OH 43605 8/20/2007 9/7/2007 9/20/2007
Cropsey Dwayne 613 6th Ave Rock Falls OH 61071 8/21/2007 9/6/2007 9/20/2007
Hoque Sirajul 2089 Riverlanding Circle Lawrenceville GA 30045 8/24/2007 9/17/2007 9/24/2007
Buckner Ingrid 573 Fay Drive Colorado Springs CO 80911 8/24/2007 9/10/2007 9/11/2007
Schantz Bruce/Carol 3631 Woodview Ave, SW Wyoming MI 49509 8/24/2007 9/26/2007 9/26/2007
Hoque Sirajul 2089 Riverlanding Circle Lawrenceville GA 30045 8/24/2007 9/17/2007 9/20/2007
Truitt Kanya/Thomas 8 Croyden Road Mays Landing NJ 83303 8/24/2007 9/26/2007 10/18/2007
Martin Geoffrey/LaRae 11003 N Myrtle Street Huntley IL 60142 8/24/2007 9/10/2007 9/20/2007
Simpson Michael/Tomeka 9822 Owen Parkway Jonesboro GA 30238 8/29/2007 9/17/2007 9/17/2007
John Bertie/Linda 1590 Lewisville Vienna Road
Pfafftown NC 27040 8/29/2007 9/7/2007 9/7/2007
Harris Paul 22 Rock St Coolville OH 45723 8/29/2007 9/19/2007 9/20/2007
Fuchs James 5425 Maureen Dr, NW Canton OH 44718 8/29/2007 9/19/2007 9/20/2007
Estes Jeffrey/Tamyra 207 White St Box 13 Shirley IN 47384 8/29/2007 9/26/2007 10/4/2007
Pennell Albert/Ellen 722 Western Ave, SW Canton OH 44710 8/29/2007 9/19/2007 9/20/2007
Skipper Maleather 7 Hendricks Court Sayreville NJ 08872 8/29/2007 9/20/2007 9/20/2007
Cortez Kent 800 Sellers Road Longville LA 70652 8/29/2007 9/10/2007 9/20/2007
Kuchar Thomas 19553 South Oakly Road Oakley MI 48649 8/30/2007 9/17/2007 9/17/2007
Lonicki Charles Jr./Lori 222 Lightning Wood Ct Fort Wayne IN 46804 8/30/2007 9/20/2007 9/20/2007
Buttermore Robert 2568 3rd Ave East North Saint Paul MN 55109 8/30/2007 9/20/2007 9/20/2007
Wells Yong/Louis 1732 Gregory Jarvis Dr El Paso TX 79936 8/30/2007 9/26/2007 9/26/2007
Taynor Jeffrey/Mary 5748 Blanton Park Drive Galloway OH 43119 8/30/2007 9/26/2007 10/4/2007
Tedford Joyce 205 North Summit Street Prarie grove AR 72753 8/30/2007 9/26/2007 10/4/2007
Graft Brendon/Wannie 265 Lochinvar Drive Pontotoc MS 38863 8/30/2007 9/26/2007 10/4/2007
Underwood John/Gina 202 Hillside Drive Nitro WV 25143 8/30/2007 9/17/2007 9/20/2007
Wauford Wallace 381 Wimpole Drive Nashville TN 37211 8/30/2007 10/1/2007 10/15/2007
Powers Christine 700 Stoval Drive White House TN 37188 8/30/2007 9/20/2007 9/20/2007
Dietrich Thomas 3520 Gailyinn Dr. Cincinnati OH 45211 8/31/2007 9/19/2007 9/20/2007
Cinea Kim 2632 Danbury Dr. Longmont CO 80503 8/31/2007 9/19/2007 9/20/2007
Riggie Samuel 4851 Webb Rd. Perry OH 44081 8/31/2007 9/17/2007 9/17/2007
Perkins Cassey 6227 Oakpass Dr. Houston TX 77091 8/31/2007 9/17/2007 9/17/2007
Bishop Juan 10356 Greenville Saint Marys
Versailles
Rd.. OH 45380 8/31/2007 10/1/2007 10/1/2007
Williams Terry 2435 S Prospect Ave Springfield MO 65804 8/31/2007 9/26/2007 9/26/2007
Latona Vincent 146 Fortescue Rd Newport NJ 83452 8/31/2007 10/1/2007 10/8/2007
Williams/Bradshaw Joyce/Angela 4715 Winona Terrace Cincinnati OH 45227 8/31/2007 9/26/2007 9/26/2007
Frederick Joseph 5659 Southland Dr. Stone Mountain GA 30087 8/31/2007 10/1/2007 10/26/2007
McCollum Richard 1013 Ridgefield Dr. La Place LA 70068 8/31/2007 9/26/2007 10/4/2007
Hillebrecht Nancy 104 State St. Henderson IL 61439 8/31/2007 9/17/2007 9/20/2007
Campbell Laverne 213 Kensington Cir Warner Robins GA 31093 8/31/2007 9/26/2007 10/4/2007
Clarkson Steven 8164 N Co Rd. 575 W Russelville IN 46175 8/31/2007 9/19/2007 9/20/2007
Wangle Jeffrey 1560 Panther Creek Rd Luthersville GA 30251 8/31/2007 9/19/2007 9/20/2007
Mayo Thomas 231 W William St. Corning NY 14830 8/31/2007 9/26/2007 10/19/2007
Townsend Danny 90 South St. Sedalia OH 43151 8/31/2007 9/17/2007 9/20/2007
Nolan Paul 812 Mcanear St. Clerburne TX 76033 8/31/2007 9/17/2007 9/20/2007
Botts Heather 2707 N 200 E North Logan UT 84341 8/31/2007 9/17/2007 9/20/2007
Frazier Randy 2524 Pendergrass Ln Ellenwood GA 30294 8/31/2007 9/20/2007 9/20/2007
Bradley Allen 235 N Concept Dr. Lima OH 45807 8/31/2007 9/17/2007 9/20/2007
Perline Ralph 125 Haviland Dr. Youngstown OH 44505 8/31/2007 9/17/2007 9/20/2007
Wagers Timothy 122 Canal Ct, New Richmond OH 45157 8/31/2007 9/20/2007 9/20/2007
Celestine Burtland 1104 Louisianna Ave Lafayette LA 70501 9/17/2007 10/18/2007 10/18/2007
Phan Toan 735 Rock Rose Way Richmond CA 94806 9/17/2007 10/18/2007 10/18/2007
Wesberry Floyd/Lori 33 Sugden Waurika OK 73573 9/17/2007 11/11/2007 11/15/2007
Grimm Jerry 7031 Wyandotte Dr Cincinnati OH 45233 9/18/2007 10/1/2007 10/4/2007
Little Harry 110 Brinton St. Buffalo NY 14214 9/19/2007 11/11/2007 11/11/2007
Purvis Carl/Suzette 4727 Trojan Street North Port FL 34286 9/19/2007 10/1/2007 10/4/2007
Hicks Susan/Steven 204 Croft Dr Kings Mountain NC 28086 9/19/2007 10/1/2007 10/8/2007
Dohner Kimberly/Scott 4226 Briar Ridge Road Mt. Eden KY 40046 9/20/2007 10/2/2007 10/8/2007
Jones Artie 210 Oak Street Marksville LA 71351 9/20/2007 11/11/2007 11/11/2007
Morris Shirley 1729 Piety Street New Orleans LA 70117 9/20/2007 11/11/2007 11/11/2007
Jeppsen Dennis/Elizabeth 394 W Young Street Morgan UT 84050 9/20/2007 10/17/2007 10/18/2007
Lightner Benjamin/Denna 1722 W 8760 S West Jordan UT 84088 9/20/2007 10/24/2007 11/1/2007
Zimmerman Duane 801 Water Street Baraboo WI 53913 9/20/2007 10/18/2007 10/18/2007
Paas Marcina/Kimberly 5609 Sims Road Groveport OH 43125 9/20/2007 10/2/2007 10/4/2007
Cox James/Jacquelyn 14749 Wittwer Road South Beloit IL 61080 9/20/2007 10/29/2007 11/1/2007
Bernard III Reuben 4425 Lafaye Street New Orleans LA 70122 9/20/2007 10/2/2007 11/18/2010
Cosey Samuel/Peggy 14202 Barkerview Ct Houston TX 77084 9/20/2007 10/2/2007 10/8/2007
Demske/Yockey Frank/Barbara 265 N Almont Ave Imlay MI 48444 9/20/2007 10/2/2007 10/18/2007
Gammon Melinda/David 1347 E 72nd Street Indianapolis IN 46240 9/20/2007 10/2/2007 10/4/2007
Perez Carlos 8795 SW 18th Street Miami FL 33165 9/27/2007 10/4/2007 10/8/2007
Kelly Paul 41 Old Highway 119 Cumberland KY 40823 9/27/2007 10/4/2007 10/8/2007
Poling Clifford 7561 Utz Road Lewisburg OH 45338 9/27/2007 10/10/2007 10/10/2007
Wyllie Frank 1799 Randolph Road Rochester NY 12308 9/27/2007 11/1/2007 11/15/2007
Davis Ronald 830 Sycamore Vista Dr Chino Valley AZ 86323 9/27/2007 10/15/2007 10/18/2007
Simon Joe 12 Tower Road Conway AR 72032 9/27/2007 10/10/2007 10/18/2007
Joson Michael 5940 Ralston Indianapolis IN 46220 9/28/2007 10/18/2007 10/18/2007
Guthrie William 1157 Victoria Drive McCalla Al 35111 9/28/2007 10/10/2007 10/10/2007
Harms Grace 18621 Palmer Circle Homewood IL 60430 9/28/2007 10/10/2007 10/10/2007
Guyton Sherman 326 Grate Road Anderson SC 29625 9/28/2007 10/29/2007 10/29/2007
Harmon Kevin Rr Box 198 Wyoming IL 61491 9/28/2007 10/19/2007 10/19/2007
Brooks La Troysha 1642 16th St Des Moines IA 50314 9/28/2007 10/29/2007 10/29/2007
Lee Kenneth 4732 Old Countryside Circle,
Stone
S Mountain GA 30083 9/28/2007 10/29/2007 10/29/2007
Briggs John/Theresa 1914 Hideaway Ct. Tallahassee FL 32303 9/28/2007 10/18/2007 10/24/2007
Reuter Lori 1512 4th St. E Hastings MN 55033 9/28/2007 10/15/2007 10/15/2007
Stochla Rebecca L. 189 Virginia Ave Staten Island NY 10305 9/28/2007 10/15/2007 10/18/2007
Jones Larry 1027 Vancouver Dr Port Allen LA 70767 9/28/2007 11/11/2007 11/15/2007
Carlson Reina 1604 St Christopher Drive Slidell LA 70460 9/28/2007 10/18/2007 10/18/2007
Doremus Brad 4110 Wyncote South Euclid OH 44121 9/28/2007 10/10/2007 10/18/2007
Cooper Mary 16184 N County Road 1800Havana
E IL 62644 9/28/2007 10/10/2007 10/18/2007
Reedy Aaron/Sandra 112 Fairview Ave Sardinia OH 45171 9/28/2007 10/15/2007 10/18/2007
Rehart Charles 2600 Hopewell TWP 76 Somerset OH 43783 9/28/2007 10/29/2007 11/1/2007
Stochla Rebecca L. 189 Virginia Ave Staten Island NY 10305 9/28/2007 10/15/2007 10/18/2007
Hairston Phillip 4113 Carnation Dr Winston Salem NC 27105 9/28/2007 10/18/2007 10/18/2007
Irby Renee 8097 Mahogany Lane Lithonia GA 30058 9/28/2007 10/15/2007 10/18/2007
Byrne Chris/Denise 1725 Twin Lakes Cir Loveland CO 80538 9/28/2007 10/10/2007 10/18/2007
Sanders Gary/Marica 395 W Old Inland Emp HwyProsser WA 99350 9/28/2007 10/15/2007 10/18/2007
Mendoza Ernesto 904 Indiana Ave Mendota IL 61342 9/28/2007 10/23/2007 11/15/2007
Abner Phillip 105 Boys Ave Franklin OH 45005 9/28/2007 10/10/2007 10/18/2007
3 of 7
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
S & A Capital Loan Acquired From Chase Document
Document
115-2
67-1
Filed
Filed
08/05/16
08/24/15
Page
Page
51 of
5 of
190
8
Last Name First Name Address City St. Zip Date Aqcuired Original Assgn Recv'd Collateral File Received
Prejean Jason 106 Amaunt Street Lafayette LA 70501 9/28/2007 10/18/2007 11/18/2010
Nichols Harold 59460 Hwy 26 Mount Vernon OR 97865 10/26/2007 12/3/2007 12/19/2007
Troche Leslie 19 Poplar Circle Peekskill NY 10566 10/26/2007 11/1/2007 11/1/2007
Tyler Timothy 5264 Eisenhower Road Columbus OH 43229 10/26/2007 11/1/2007 11/1/2007
Fusco David 588 7th Ave Liverpool OH 43920 10/26/2007 11/14/2007 11/14/2007
Lopez Jose 627 Rae Drive Lawrenceville GA 30044 10/26/2007 12/3/2007 12/19/2007
Hopkins Andrew 795 Premiera Dr Tallmadge OH 44278 10/26/2007 11/1/2007 11/15/2007
Taylor Cynthia 2670 Ann Circle Shakopee MN 55379 10/26/2007 11/1/2007 11/15/2007
Johnson Deborah 8470 129th Street, Apt 2J Kew Gardens NY 11415 10/31/2007 12/3/2007 11/5/2007
Criss Lillian 571 Maplewood Ave Sheffield Lake OH 44054 10/31/2007 11/12/2007 11/12/2007
Halawi Khaled 14156 Houghton St Livonia MI 48154 10/31/2007 11/14/2007 11/15/2007
Russell Forrest/Julie 1932 Gnell Drive Saint Bernanrd LA 70085 10/31/2007 12/3/2007 12/19/2007
Marzouk Faik 24775 Ross Drive Redford MI 48239 10/31/2007 12/3/2007 12/7/2007
Justus Carol 369 Lancelot Drive Franklin IN 46131 10/31/2007 11/19/2007 11/20/2007
Klecha Steven 31200 Counrty Way Farmington Hills MI 48331 10/31/2007 11/19/2007 11/20/2007
Sterling Linda 735 Havana St. Aurora CO 80010 10/31/2007 11/19/2007 11/29/2007
Taylor Tara 5 Maywind Court Woodlands TX 77381 10/31/2007 11/12/2007 11/15/2007
Taylor Steven 3203 N Lawndale Ave Indianapolis IN 46224 10/31/2007 11/14/2007 11/15/2007
Beasley Clifford 506 Glendora Ave Akron OH 44320 10/31/2007 12/3/2007 12/19/2007
Greene Kenneth 606 Stratford Drive Harahan LA 70123 10/31/2007 11/19/2007 11/29/2007
Forester Thomas 6812 Vara Drive Pittsburgh PA 15236 10/31/2007 11/19/2007 11/29/2007
Ibarbo Laura 4613 Gabriel Drive El Paso TX 79924 10/31/2007 12/3/2007 12/19/2007
Matthews James 1134 N Robert Drive Peoria IL 61611 10/31/2007 11/12/2007 11/15/2007
Griner Brenda 252 East lake Street Toledo OH 43608 10/31/2007 12/6/2007 12/19/2007
Carroll Jeffrey 5810 Luelda Ave Parma OH 44129 10/31/2007 12/3/2007 12/19/2007
Puckett Diane 1808 The Meadow Road Louisville KY 40223 10/31/2007 11/12/2007 11/15/2007
Stroud Katrina 9154 E State Highway D Rogersville MO 65742 10/31/2007 11/19/2007 11/29/2007
Baker James 706 N Capitol Ave Corydon IN 47112 10/31/2007 12/3/2007 12/19/2007
Robertson Greg 100A Crystal Lake Lane Brunswick GA 31525 10/31/2007 11/15/2007 11/15/2007
Marcellino Stephen 16 Matthes Rd Briarcliff Manor NY 10510 11/13/2007 11/15/2007 11/15/2007
Rocha John 16196 Sun View Lane Conroe TX 77302 11/20/2007 2/42008 2/42008
Hendrix Robert 9291 Sussex Drive Olmsted Falls OH 44138 11/20/2007 12/6/2007 12/19/2007
Coleman Tina 1617 SW 127th Place Oklahoma City OK 73170 11/20/2007 12/6/2007 12/19/2007
Barnard Richard 5860 Marvin Street Taylor MI 48180 11/20/2007 12/12/2007 12/19/2007
Cavalcante James 54152 Ash Road # 213 Osceola IN 46561 11/20/2007 1/28/2007 2/8/2008
Seagraves Gregory/Catheryne 737 County Rd. 59 Chesapeake OH 45619 11/30/2007 12/21/2007 1/8/2008
Brown Theodore 5210 W Caven St Indianapolis IN 46241 11/30/2007 12/21/2007 1/8/2008
Naegele Sherra & Joel 613 Twin View St Trockwall TX 75032 11/30/2007 1/8/2008 1/18/2008
Parson Patricia D 3734 Tomlinson St. Bonita Springs FL 34134 11/30/2007 1/17/2008 1/18/2008
Taylor Angela M 195 N Union St Battle Creek MI 49017 11/30/2007 12/21/2007 1/18/2008
Clegg Kenneth & Theresa 8112 N Palmyra Rd Canfield OH 44406 11/30/2007 1/8/2008 1/8/2008
Farmer Sheila 300 Ciecle Ave, Apt 1A Forest Park IL 60130 11/30/2007 12/12/2007 12/18/2007
Fala Alan D 6101 Blue Hen Pl Westerville OH 43801 11/30/2007 1/14/2008 1/22/2008
Mitchell Gerald & Veronica 19800 Goulburn St Detroit MI 48205 11/30/2007 1/8/2008 1/10/2008
Mella David, Debra 56 Mountain Rd Granby CT 6060 11/30/2007 12/21/2007 12/28/2007
Bush Daniel & Sarah 23955 S Navajo Dr. Channahon IL 60410 11/30/2007 12/12/2007 12/19/2007
Montgomery Brian 6445 Faust Ave Detroit MI 48228 11/30/2007 1/7/2008 1/10/2008
Ray Egidio L 6531 Linville Dr. Brighton MI 48116 11/30/2007 1/7/2008 1/10/2008
Jasper Loretta C 5321 Beechwood Dr. Somerset KY 42501 11/30/2007 1/14/2008 1/22/2008
Catrett H.B. 325 Sellers Rd Pelham GA 31779 11/30/2007 1/7/2008 1/10/2008
Kramer Joanne M 223 Mason Ave Rochester NY 14626 11/30/2007 1/7/2008 1/10/2008
O'Donnell Kelly M 9043 Butternut Rd Whitmore Lake MI 48189 11/30/2007 1/7/2008 1/28/2008
Rauch Ricky J & Jeannine 6064 Memphis St. New Orleans LA 70124 11/30/2007 1/28/2007 2/8/2008
Elliott George 1576 Myrtle Ave. Madison Heights MI 48071 11/30/2007 12/14/2007 12/19/2007
Betancourt Jeffery & Heidi 4049 S Santa Llucia Ave Sierra Vista AZ 85650 11/30/2007 1/14/2008 1/22/2008
Kesler Timothy/Emma 2625 George St. Logansport IN 46947 11/30/2007 1/7/2008 1/10/2008
Lumpkin Yolonda M 9334 Barrow Dr. Cordova TN 38016 11/30/2007 1/14/2008 2/8/2008
Ulrich Justin 304 Medinah Ave. Johnstown CO 80534 11/30/2007 1/7/2008 1/10/2008
(Ward)Monroe Tina A 2967 Lake Park Dr. Columbus OH 43232 12/3/2007 1/14/2008 1/22/2008
Washington Sean L 229 E Merrill Ave Gilbert AZ 85234 12/12/2007 1/7/2008 1/8/2008
Porter James L & Sarah K 3191 Hunters Crossing PointeLithonia GA 30038 12/13/2007 1/7/2008 1/8/2008
Powell Patricia 106 Miracle St. Barbourville KY 40906 12/13/2007 1/14/2008 1/18/2008
Holmes Curtis L 2856 Acre Hill # 298 Brighton MI 48114 12/13/2007 1/28/2008 1/30/2008
Walsh Matthew J 19 Harrison Street Taunton MA 2780 12/18/2007 1/14/2008 1/18/2008
Brown Donna 7798 Dayton St. Detroit MI 48210 12/18/2007 1/14/2008 1/18/2008
Spirito Monica 37 Madisonville Rd Basking Ridge NY 07920 12/19/2007 1/14/2008 1/18/2008
Watson Frank 819 W 2nd Street Grandfield OK 73546 12/19/2007 1/14/2008 1/22/2008
Littlejohn Gregory 6050 Robertdale Rd. Oakwood Village OH 44146 12/27/2007 1/14/2008 1/18/2008
Cox Theodore 12865 SW 49th Court Miramar FL 33027 12/27/2007 1/14/2008 1/18/2008
Gutierrez Abel 29920 Illinios Street Elsinois CA 92530 12/27/2007 1/14/2008 2/8/2008
Baez Raul 139 Highview Avenue New Britain CT 06053 12/27/2007 1/25/2008 2/8/2008
O'Neil Susan/Kevin 221 Emmans Rd. Flanders NJ 07836 12/27/2007 1/29/2007 2/7/2008
Dozier Lorettea 3609 W Nortgate #215 Irving TX 75062 12/28/2007 1/14/2008 1/18/2008
Lambert Jill 57818 Cider Mill Drive New Hudson MI 48165 12/28/2007 1/14/2008 1/8/2008
McDermott Mark 412 Vandergrift Lane Vandergrift PA 15629 12/28/2007 1/28/2008 2/8/2008
Clark Diana/Stephen 22045 Bates Road Minerva OH 44657 12/28/2007 1/25/2008 1/25/2008
Hunt Susan 5342 NW 99th Lane Coral Springs FL 33076 12/28/2007 1/28/2008 2/8/2008
Reukema Myles 1808 West Cliff Ct Carlsbad CA 92008 12/28/2007 1/14/2008 1/22/2008
Ogburn Dianna 10610 Ashville Pk Lot 39 Lockbourne OH 43137 12/28/2007 1/28/2008 2/8/2008
East Regina 89-00 170 Street apt. 7N Jamaica NY 11432 12/31/2007 1/14/2008 3/7/2008
Sohn David 9298 N Bayfield Drive McCordsville IN 46055 12/31/2007 1/25/2008 2/8/2008
Lafleur Tilman 104 Glaze Court Schriever LA 70395 12/31/2007 1/25/2008 2/8/2008
Bright Cynthia 1210 15th Street Greenley CO 80631 12/31/2007 1/25/2008 2/8/2008
Globensky Paul 126 Galena Court Drake CO 80515 1/11/2008 2/1/2008 2/8/2008
Kingery Kathy 434 Dean Ct Canton IL 61520 1/11/2008 1/14/2008 1/22/2008
Terzak Connie G 1921 Academy Blvd. Cape Coral FL 33990 1/24/2008 2/26/2008 2/26/2008
Clayburn /Young Reginald / Mary 704 Glacier Ave. Capitol Heights MD 20743 1/24/2008 2/1/2008 3/31/2008
Slate Donald/Patsy 7532 Perilla Ct. Indianapolis IN 46237 1/24/2008 1/28/2008 2/21/2008
Miller Milton 61168 State Rd 15 Goshen IN 46526 1/31/2008 2/14/2008 2/14/2008
McCray Ricky B 2620 27th Ave Parkersburg WV 26101 1/31/2008 2/26/2008 2/26/2008
Gayden Jeffrey/Michelle 9200 Stout St. Detroit MI 48228 1/31/2008 2/14/2008 2/14/2008
Elmore Jessie Alton 25 Glendale Drive Monroe LA 71202 1/31/2008 2/20/2008 2/20/2008
Hill Maurice / Lacecila 241 Ruthledge Dr Winder GA 30680 1/31/2008 2/14/2008 2/14/2008
Miller Jennifer 415 Boyd St Oshkosh WI 54901 1/31/2008 2/8/2008 2/8/2008
Nutter Dennis / Phyllis 4039 Virginia Circle E Columbus OH 43213 1/31/2008 2/4/2008 2/4/2008
Merriman Karen 253 Inverness Ln Temperence MI 48182 1/31/2008 2/20/2008 2/21/2008
Simmons Christopher / Lisa 11670 Brush Creek Ct. Reno NV 89506 1/31/2008 3/3/2008 3/20/2008
Schulze /Pung Virginia A/ Roy Leo 4680 Atkins Rd Clyde MI 48049 1/31/2008 2/10/2008 2/21/2008
Zeisler John 3625 Skyline Dr. Columbus OH 43235 1/31/2008 2/26/2008 3/7/2008
Cole Roger Eugene 6923 Edith St Cincinnti OH 45244 1/31/2008 2/20/2008 2/21/2008
Carter Paul / Shirley 925 Russell St Birstol VA 24201 1/31/2008 2/26/2008 3/7/2008
Golubosky Daniel /Berverly Rt 1, Box 281ee Fayeteville NC 28301 1/31/2008 2/21/2008 3/7/2008
Horacek John 108 Pleasant St North Freedom WI 53951 1/31/2008 2/20/2008 2/21/2008
Terrio/Ellinger Melissa / Carl 57341 Cypress Ave Slidell LA 70461 2/13/2008 2/26/2008 2/26/2008
Reese Delia 376 Brookside Mnr Goshen IN 46526 2/13/2008 4/2/2008 4/2/2008
Goodman Michael 4390 Savole Trail West Bloomfield MI 48322 2/25/2008 3/12/2008 4/2/2008
Morris Alfred/Cynthia 1213 Tree Ridge Road Richmond VA 23231 4 of2/28/2008
7 3/28/2008 3/28/2008
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
S & A Capital Loan Acquired From Chase Document
Document
115-2
67-1
Filed
Filed
08/05/16
08/24/15
Page
Page
52 of
6 of
190
8
Last Name First Name Address City St. Zip Date Aqcuired Original Assgn Recv'd Collateral File Received
Parris Eula/Walter 2338 Amsterdam Drive Augusta GA 30906 2/28/2008 3/31/2008 3/31/2008
Harper Pat, P 214 E 57th PL N Tulsa OK 74126 2/28/2008 3/27/2008 3/27/2008
Chambers Angela M/ Raymond12454 N 75th LN Royal Palm Beach FL 33412 2/28/2008 5/8/2008 4/4/2008
Everts Paul J/Daniel 2268 Marathon Ave Neenah WI 54956 2/28/2008 3/27/2008 3/27/2008
Zielsdorf Kenneth / Donna 646 Sunbird Cir Indianapolis IN 46231 2/28/2008 3/28/2008 3/28/2008
Brinkerhoff Christopher, J 5784 Manchester Ave NW North Lawrence OH 44666 2/28/2008 3/12/2008 3/12/2008
Thatcher Shane, W 90 Vine Street Seaman OH 45679 2/28/2008 3/27/2008 3/27/2008
Christopher Vincent / Jem 127 Glendale Dr Trenton NJ 08618 2/28/2008 3/28/2008 3/28/2008
Negley Robert 1023 Rt 908 Natrona Heights PA 15065 2/28/2008 4/2/2008 4/4/2008
Newlun Richard /Pamela 4415 Par Drive Indianapolis IN 46268 2/28/2008 3/27/2008 3/27/2008
Padilla Robert 406 N 76th Ave Duluth MN 55807 2/28/2008 4/2/2008 3/31/2008
Foster Joy 477 Capital View Dr Columbus OH 43203 2/28/2008 3/27/2008 3/27/2008
Answorth Cecilia 25118 Pembroke Ave Redford MI 48240 2/28/2008 3/27/2008 3/27/2008
Pendergraft Mindy 132 West Oak Street Washington Courthouse
OH 43160 2/28/2008 4/4/2008 4/4/2008
Mulheron William 1330 Nottingham Road Grosse Pointe ParkMI 48230 2/28/2008 3/27/2008 3/27/2008
Robinson Seymore 104 East 13th Street Front Royal VA 22630 2/28/2008 3/27/2008 3/27/2008
Maynard Leona 15 Maynard Hollow Turkey Creek KY 41514 2/28/2008 4/10/2008 4/10/2008
Bruner Kevin, G 546 Tionda Dr N Vandilia OH 45377 2/28/2008 4/16/2008 4/16/2008
Gayken Dawn 12535 Longmire Lakeview Conroe TX 77304 2/28/2008 3/27/2008 4/1/2008
Cruz Maria 1656 N Primrose Ave Rialto CA 92376 2/28/2008 3/28/2008 4/2/2008
Williams Roderick 2936 Evaline Street Hamtramck MI 48212 2/28/2008 3/27/2008 4/2/2008
Fields James 2173 S Hawkins Ave Akron OH 44314 2/28/2008 3/27/2008 4/2/2008
Bhones Olee & Brendetta 4601 Sharon Drive La Palma CA 90623 2/28/2008 3/27/2008 4/2/2008
Burkhead Lois 6156 Windsor Indianapolis IN 46219 2/28/2008 3/27/2008 4/2/2008
Buchko Laura 214 Central Ave South Charlston WV 25303 2/28/2008 3/27/2008 4/2/2008
Steinmiller Shiotsie/William 2142 42nd Ave Greenley CO 80634 2/28/2008 3/14/2008 3/20/2008
Wittwer Michael / Krista 2737 113th Street Chippewa Falls WI 54729 2/28/2008 4/8/2008 5/8/2008
Sfameni Charlene 333 NE 7th Ave Del Rey Fl 33483 2/28/2008 3/27/2008 5/8/2008
Pollock Kimberly, D 4790 Galvinston Ave Beaumont TX 77703 2/28/2008 3/31/2008 4/2/2008
Abraham Allie, H 4852 Chase Dearborn MI 48126 2/28/2008 3/14/2008 3/20/2008
Weldon Julius 106 Elizabeth Street Chester SC 29706 2/28/2008 3/27/2008 4/2/2008
Stewart Earl 1341 Island Ave McKees Rocks PA 15136 2/28/2008 4/2/2008 4/17/2008
Mugar Macario 2904 Orchard Park Way Modesto CA 95355 2/28/2008 3/27/2008 5/8/2008
Mitchell Marty Leon 7326 State Toute 19 Unit 5215
Mount Gilead OH 43338 2/28/2008 3/28/2008 4/2/2008
Lorenzen Gregory 12799 Hutton Dr Walton KY 41094 2/28/2008 3/14/2008 3/20/2008
Wilson Clyde 3950 CourvilleStreet Detroit MI 48224 2/28/2008 3/27/2008 4/2/2008
Carreto David /Irma 657 S Birch Ave Indianapolis IN 46221 2/28/2008 4/11/2008 4/17/2008
Bergstrom Mark 161 Ardsley Circle Brockton MA 02302 2/28/2008 3/27/2008 4/2/2008
Pettit Vanessa 157 TWP Road 346 South Point OH 45680 3/11/2008 4/2/2008 4/17/2008
Lube Tina 332 W Aurora Street Ironwood MI 49938 3/11/2008 4/17/2008 4/17/2008
Jones Sharon 3570 Bremen St Columbus OH 43224 3/31/2008 4/16/2008 4/17/2008
Jusiak-Calovine Grace 35 Tudor Lane Trumbull CT 06611 3/31/2008 4/11/2008 4/14/2008
Pasley, Jr Willie /Carrolin 3 Kristen Court New Orleans LA 70128 3/31/2008 4/11/2008 4/16/2008
Robles-Barrios Rony 928 Burton Street, SW Wyoming MI 49509 3/31/2008 4/4/2008 4/4/2008
Tena Gilberto 43198 Matera Court Temecula CA 92592 3/31/2008 4/17/2008 5/8/2008
Reynolds Albert/Violet 608 Brown Station Road Bedford IN 47421 3/31/2008 4/14/2008 4/16/2008
Medina Gerardo 604 Westwood Dr San Antonio TX 78212 3/31/2008 4/16/2008 4/16/2008
Nelson Shawn 702 Maywood Ave Clendenin WV 25045 3/31/2008 4/16/2008 4/16/2008
England David 112 South Stanley Street Bellefontaine OH 43311 3/31/2008 4/16/2008 4/16/2008
Eckiwaudah Leander 103 Prarie Village Ave Anadarko OK 73005 4/25/2008 5/1/2008 5/5/2008
Dettmer Joshua 4721 Arlington Ave Fort Wayne IN 46807 4/25/2008 5/5/2008 5/5/2008
Gajate Fernando 5361 SW 8th Street Plantation Fl 33317 4/25/2008 5/1/2008 5/7/2008
Bond Gregory 530 East Lake Street Toledo OH 43608 4/25/2008 5/1/2008 5/8/2008
Sydnor James 680 Jacob Drive Williamstown KY 41097 4/25/2008 5/1/2008 5/7/2008
Schrock Michael 4471 Nantucket Road Harrisburg PA 17112 4/25/2008 6/4/2008 6/9/2008
Landeros Osbaldo 4027 Santa Fe Way North Highlands CA 95660 4/25/2008 5/5/2008 5/8/2008
Alexander Mary 430 W Home Ave Flint MI 48505 4/25/2008 5/1/2008 5/8/2008
Stewart Anthony Wayne 817 Avenue C Kentwood LA 70444 4/25/2008 6/3/2008 6/13/2008
Williams Saddie 114 Willard Street Baltimore MD 21223 4/30/2008 5/19/2008 5/21/2008
Sibley Robert / Kareena 3015 Columbia Road Medina OH 44256 4/30/2008 5/7/2008 5/8/2008
Cerchiaro Danny/Lisa 136 Wood Ave Islein NJ 08830 4/30/2008 5/7/2008 5/13/2008
Taylor Ezell 1507 South Union Lima OH 45804 4/30/2008 5/30/2008 6/9/2008
Fielder Terence 1809 Mesa Cir Safford AZ 85546 4/30/2008 5/30/2008 6/9/2008
Barber Jacqueline 122 N 2nd Street Allegany NY 14706 4/30/2008 5/7/2008 5/8/2008
Adams Burlie/Shana 9695 Highway 30 Jackson KY 41339 4/30/2008 5/7/2008 5/8/2008
Kerr Edwin/Angela 16367 88th Rd, N Loxahatchee FL 33470 4/30/2008 5/7/2008 5/8/2008
Husk Steve/Marjorie 117 Haines St Elyria OH 44035 4/30/2008 5/7/2008 5/8/2008
Moore Bobby 2697 FM 1157 Ganado TX 77962 4/30/2008 5/30/2008 6/13/2008
Hoch Thomas/Terri 252 Lake Street Lancaster OH 43130 4/30/2008 5/7/2008 5/8/2008
Ortega Jamie 3605 South Saint Clair St Oklahoma City OK 73119 5/20/2008 5/30/2008 6/9/2008
Anderson Matthew 3872 Cinnbar Drive Eagan MN 55122 5/20/2008 5/30/2008 6/9/2008
Cuyos Eduardo 35612 Loggins Court Winchester CA 32596 5/20/2008 5/30/2008 6/13/2008
Handzel Anthony 406 N Thornwood Drive McHenry IL 60050 5/21/2008 6/4/2008 6/9/2008
Billingsley Douglas 3756 Wilson Ave Wellington CO 80549 5/21/2008 6/4/2008 6/13/2008
Garcia Diana 605 N Broadway Street Tipton OK 73570 5/27/2008 6/4/2008 6/9/2008
Hoxworth Tina 1251 Nestor Ave Akron OH 44314 5/27/2008 6/13/2008 6/11/2008
Jerusalem/Schroeder
Betty/Dennis 2822 W. Glen parker Drive Appleton WI 54914 5/30/2008 6/12/2008 6/13/2008
Taylor Austin 1129 Shearwater Drive Patterson CA 95363 6/11/2008 6/26/2008 6/26/2008
Lareau Pamela 31 Sparks St Dracut MA 01826 6/13/2008 6/26/2008 6/26/2008
Busza Diana 41 TownHouse LN Little Egg harbor NJ 08087 6/13/2008 6/26/2008 6/26/2008
Jones/Thompson Darryl /Carolyn 614 Northcliff Dr Rockville MD 20850 6/20/2008 6/30/2008 7/9/2008
Ginzel, Jr. William 11320 Bryce Road Emmett MI 48022 6/24/2008 7/9/2008 7/9/2008
Muse Catherine 8211 Harrison Drive Indianapolis IN 46226 6/24/2008 7/9/2008 7/9/2008
Evans Castella 881 Eva Ave Akron OH 44306 6/30/2008 7/23/2008 7/25/2008
Schumann Fred 1516 King Street Saginaw MI 48602 6/30/2008 8/7/2008 8/13/2008
Wickersham Richard/Linda 175 Elm Street Hollansburg OH 45332 6/30/2008 7/15/2008 7/22/2008
Nielsen Peter 29577 Georgetown Road Salem OH 44460 6/30/2008 7/15/2008 7/28/2008
Grabowski Joseph 104 2nd Street Shady Springs WV 25918 6/30/2008 7/14/2008 7/28/2008
Huff Darrell 7325 Gleason Road Shawnee KS 66227 6/30/2008 7/15/2008 7/23/2008
Flores Rodolfo 10103 Chris Drive Indianapolis IN 46229 6/30/2008 7/14/2008 7/23/2008
Shoemaker John 418 Elder Street Buffalo MO 65622 6/30/2008 7/11/2008 7/23/2008
Rounds Dennis 6208 Krandon Dr Raleigh NC 27603 6/30/2008 7/14/2008 7/23/2008
Tedesco Mary 174 Metcalfe Street Buffalo NY 14206 6/30/2008 8/21/2008 8/21/2008
Oman Mark 3420 Kent Street Shoreview MN 55126 6/30/2008 7/15/2008 7/23/2008
Green Angela 705 SE 12th Terr Lees Summit MO 64081 7/28/2008 8/13/2008 8/21/2008
Warren Phillip 2715 Mariner Ave Youngstown OH 44505 7/30/2008 8/13/2008 8/21/2008
Stewart Marsha 476 14th St Brooklyn NY 11215 7/30/2008 9/23/2008 10/2/2008
Mills Joel 6039 Jackson Ave St. Louis MO 63134 7/31/2008 8/21/2008 8/21/2008
Patterson Christopher 3695 Woodyhill Dr Lithonia GA 30038 7/31/2008 8/26/2008 9/11/2008
Harper Thomas 4999 Bud Street Southport NC 28461 7/31/2008 8/26/2008 9/4/2008
Bowling Randy 2458 Mansfiled-Lucas RoadLucas OH 44843 7/31/2008 12/3/2008 12/3/2008
Lampese Victoria 52 West Lakewood Street Patchogue NY 11772 8/28/2008 11/10/2008 11/10/2008
Dunlap Garland 1400 Crest Lake Court Lithonia GA 30058 8/29/2008 10/20/2008 10/30/2008
Shearer Scott & Kelley 86 Rodgers Drive Coraopolis PA 15108 8/29/2008 10/20/2008 10/30/2008
Millett Corey 31 Andrews Hill Road Woodstock ME 4219 9/29/2008 10/20/2008 10/30/2008
Correa Francisco 2231 Silver Oak Drive Corona CA 92882 10/3/2008 10/24/2008 11/13/2008
Barnes Paula 1602 Spout Springs Irvine KY 40336 5 10/16/2008
of 7 10/24/2008 11/13/2008
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
S & A Capital Loan Acquired From Chase Document
Document
115-2
67-1
Filed
Filed
08/05/16
08/24/15
Page
Page
53 of
7 of
190
8
Last Name First Name Address City St. Zip Date Aqcuired Original Assgn Recv'd Collateral File Received
Chambers (1) Thomas 131 Cedar Tree Lane Rossville GA 30741 10/31/2008 11/17/2008 11/24/2008
Chambers (2) Thomas 131 Cedar Tree Lane Rossville GA 30741 10/31/2008 11/17/2008 11/24/2008
Gaub Timothy 5650 S Thompson Ave Tacoma WA 98408 10/31/2008 11/12/2008 11/13/2008
Elwood Jonathan 49508 Sakatah Lane Waterville MN 56096 10/31/2008 11/12/2008 11/13/2008
Minshew Florence 7111 Louisville Street New Orleans LA 70124 10/31/2008 11/12/2008 11/13/2008
Ortiz David 6214 S Menard Ave Chicago IL 60638 10/31/2008 11/12/2008 11/13/2008
Sobotka Raymond 5087 Waycroft Ct Hilliard OH 43026 10/31/2008 11/12/2008 11/13/2008
Seibel Lawrence 610 Wall Ave Pitcairn PA 15140 12/15/2008 4/2/2009 4/2/2009
Anifowoshe Oladipupo 4001 Cambridge Drive Caountry Club Hill IL 60478 12/15/2008 4/2/2009 4/15/2009
Bessick Lori 21401 Gardenview Drive Maple Heights OH 44137 12/15/2008 4/2/2009 4/10/2009
Smith Richard 227 West Elm Street Wauseon OH 43567 12/15/2008 2/6/2009 2/6/2009
Bradford Jimmie 4709 Majorie Lane New Orleans LA 70122 12/15/2008 1/13/2009 1/13/2009
Delacruz Juan/Wendy 54 Turner Street Yonkers NY 10704 3/1/2009 4/2/2009 4/2/2009
Macey Robert 4482 Hemlock Drive Burtchville MI 48059 3/1/2009 3/12/2009 3/13/2009
Crotzer Mark 3280 Creamery Road Nashport OH 43830 3/1/2009 3/4/2009 3/4/2009
Barton Debra 4011 Parkcove Drive Gahanna OH 43230 3/1/2009 3/31/2009 4/2/2009
Shearer Charles 5947 Baypointe Blvd #87 Clarkstone MI 48346 3/1/2009 3/4/2009 3/19/2009
Steinbach John 2412 Scott Drive Wooster OH 44691 3/1/2009 3/12/2009 3/19/2009
Malah Liliana 9835 Brassie Way Gaithersburg MD 20886 3/19/2009 4/2/2009 4/2/2009
Randazzo Nancy 1624 Yeoman Drive Concord CA 94521 3/19/2009 4/2/2009 4/16/2008
Emerson Christopher/Johnnie735 S 26th Street Lafayette IN 47904 3/24/2009 4/20/2009 4/20/2009
Slanika Donald 57 Sawmill Road Brick NJ 08724 3/26/2009 4/15/2009 4/16/2009
Johns Kevin 4053 West College AvenueMilwaukee WI 53221 3/26/2009 4/15/2009 4/16/2009
Crawford Steven/Zeta 46 Mcauliffe Road Randolph MA 02368 3/26/2009 4/16/2009 4/16/2009
Gittel Jay/nancy 9410 West Arch Avenue Milwaukee WI 53224 3/26/2009 4/15/2009 4/16/2008
Terry Paul 8807 Point Ave Niagara Falls NY 14304 3/27/2009 4/15/2009 4/16/2009
Phillips Kenneth 31 South Main Street Oak City UT 84649 3/27/2009 5/12/2009 5/18/2009
Horne Charlotte 15720 SW 92nd Ave Vilage of Palmetto Bay
FL 33157 3/27/2009 4/15/2009 4/16/2009
Cigarrero Mauro 804 Cathedral Drive Aptos CA 95003 3/27/2009 4/15/2009 4/16/2008
Embras Phyllis 5436 Hunter Avenue Cincinnti OH 45212 3/27/2009 4/20/2009 4/20/2009
Brennan James 22-24 Rockne Avenue Dorchester MA 02124 3/27/2009 4/29/2009 4/29/2009
Radke Larry 3059 E 1825 Road Ottawa IL 61350 3/27/2009 4/24/2009 4/24/2009
Thomas William P. 151 Delta Esates Road Hardeeville SC 29927 3/27/2009 4/15/2009 4/16/2008
Laverty Ronald 38 Vaughn Ave Wheatland PA 16161 3/27/2009 4/15/2009 4/16/2008
Leznik Faina 5034 Dantes View Drive Agoura Hills CA 91301 3/31/2009 5/20/2009 5/20/2009
Walker Dominique 232 Schmidt Court Mansfield OH 44902 4/15/2009 5/18/2009 5/18/2009
Beals Steven 429 3rd Ave Garnett KS 66032 4/15/2009 5/6/2009 5/14/2009
Andrews Frank 848 Stadlemen Ave Akron OH 44320 4/29/2009 6/3/2009 6/3/2009
Singleton Peggy 6000 East 5th Street Panama City FL 32404 4/29/2009 5/26/2009 5/28/2009
Wilson Michael 225 S Counts Street Troy OH 45373 4/30/2009 5/6/2009 5/7/2009
Garcia Gary 6927 San Bruno Court Fontana CA 92336 4/30/2009 5/19/2009 5/19/2009
Ibrahim Mohamed 1907 N Wilton Place Los Angeles CA 90068 4/30/2009 5/12/2009 5/12/2009
Gilson Robert 3148 East Gable Circle Mesa AZ 85204 4/30/2009 6/3/2009 6/3/2009
Bentley James H. 612 N Elizabeth Street Sapulpa OK 74066 4/30/2009 5/18/2009 5/18/2009
Zauner Jonathan E. 3016 Harrison Street Fort Wayne IN 46807 4/30/2009 6/8/2009 6/8/2009
Jenkins Mary G. 1938 W Airdrie Street Philadelphia PA 19140 4/30/2009 5/20/2009 5/20/2009
Hernandez Antonio 8540 Passons Blvd Pico Rivera CA 90660 4/30/2009 5/20/2009 5/20/2009
Lawler Lee 1231 Pine Creek Way #E Concord CA 94520 4/30/2009 5/20/2009 5/20/2009
Awoleke Samual 293 shepard Ave Jamaica NY 11430 4/30/2009 7/30/2009 7/30/2009
Nieto Andres 265 Milford Ave New Milford NJ 07646 4/30/2009 5/20/2009 5/20/2009
Moore Vincent Lee 4877 Marlborough Street Detroit MI 48215 4/30/2009 5/20/2009 5/20/2009
Svichov Valera 1764 Pickwick Lane Glenview IL 60026 4/30/2009 5/20/2009 5/28/2009
Roberts Bryan 139 College Street Somerset KY 42501 4/30/2009 6/8/2009 7/9/2009
Sullivan Sheila 334 Aurthur Street Gary IN 46408 4/30/2009 5/20/2009 5/28/2009
McGee Bret 7508 Wykes Street Detroit MI 48210 4/30/2009 5/19/2009 5/28/2009
Holmes Jonnair 3717 Julia Street Memphis TN 38127 4/30/2009 6/18/2008 7/9/2009
Gilbert Robert 82921 Tyler Court Indio CA 92201 4/30/2009 5/20/2009 7/9/2009
Steptoe Charlesett 6425 Ava Court Fort Worth TX 76112 4/30/2009 5/26/2009 5/28/2009
Schmidt Richard 402 Broadway Coventry CT 06238 4/30/2009 5/20/2009 5/28/2009
Muno Kevin 1880 Marlowe Street Thousand Oaks CA 91360 4/30/2009 5/20/2009 7/9/2009
Winchester Mytrice S 242 City View Drive Fort Lauderdale FL 33311 5/29/2009 6/18/2009 6/18/2009
Schryver Dennis 455 Norton Ave Taunton MA 02780 5/29/2009 6/18/2009 6/18/2009
Franklin Bibi 10810 103rd Ave South Richmond HillNY 11419 5/29/2009 7/30/2009 7/30/2009
Pratt Ismah 11012 Dodge Road Montrose MI 48457 5/29/2009 6/18/2008 6/10/2009
Gibson Sylvia 3750 Grosvenor Road South Euclid OH 44118 5/29/2009 6/18/2008 6/10/2009
Codrington Lauretta 3426 Baldwin Street Detroit MI 48214 5/29/2009 6/18/2008 7/9/2009
Yourno Martha 806 Pleastview Avenue Scotia NY 12302 6/22/2009 8/28/2009 9/3/2009
Cabalona Genia 7553 N Maplewood Ave, AptChicago
A IL 60645 6/30/2009 7/8/2009 7/8/2009
Lossow Steven/Deborah 2 Sunset Road Maynard MA 01754 6/30/2009 8/5/2009 7/23/2009
Norman Jennifer 4777 Normandy Drive Galena OH 43021 6/30/2009 7/20/2009 7/20/2009
Mock William 2717 Forrest view Court, N Puyallup WA 98374 6/30/2009 8/5/2009 7/23/2009
James Joanne 1063 North Nash Ave Clovis CA 93611 6/30/2009 7/8/2009 7/8/2009
Chesonis Matthew 404 NE Trenton Blvd Trenton FL 32693 6/30/2009 8/5/2009 8/7/2009
Howell Thomas 4 Jacobs Street Peabody MA 01960 6/30/2009 7/8/2009 7/23/2009
Fabian Lillian/Anton 10255 Agate Ave Mentone CA 92359 6/30/2009 7/20/2009 7/23/2009
Burns Jason 9457 Wickham Drive Brewerton NY 13029 6/30/2009 7/8/2009 7/23/2009
Neill Robert/Mary 1697 Bent Tree Trail Ocean Isle Beach NC 28469 6/30/2009 7/8/2009 7/23/2009
Aeppli Joan 2646 S Athena Mesa AZ 85209 7/1/2009 7/10/2009 7/10/2009
Garrison James 941 Mount Zion Rd Falkville AL 35622 7/6/2009 8/5/2009 8/20/2009
Wharton Virginia 3216 Central Avenue Indianapolis IN 46205 7/9/2009 9/8/2009 9/17/2009
Hadlock Christopher/Dawn 6600 Crystal Blvd El Dorado CA 95623 7/14/2009 7/30/2009 8/7/2009
Pezella Tomothy/Patricia 17 Colby Drive Kings Park NY 11754 7/20/2009 8/25/2009 8/24/2009
White John Thomas 5434 Regent Street Philadelphia PA 19143 7/29/2009 8/10/2009 8/20/2009
Pierrvil Marie 230 182nd Terrace Miami FL 33169 1/12/2010 2/22/2010 2/18/2010
Preis Maureen 3081 Green Valley Road Newton Square PA 19073 1/14/2010 1/26/2010 1/26/2010
Mullen/Schreiner Margie 1626 West Highland Ave Wooster OH 44691 1/14/2010 1/26/2010 2/11/2010
O'Connor James 2207 NW 34 Street Winterhaven FL 33881 1/20/2010 2/22/2010 3/11/2010
Sutor Piper 6408 Interbay Blvd Tampa FL 33611 1/27/2010 2/22/2010 3/11/2010
Vance Dorothy 40 Leyland lane Harpers Ferry WV 25425 1/28/2010 2/22/2010 10/5/2010
King Patricia 5092 Dundee Ave De Leon Springs FL 32130 1/28/2010 2/22/2010 3/11/2010
Young Vivian 10614 West Clairmont, 106F Tamarac FL 33321 1/29/2010 2/22/2010 2/18/2010
Mojica Juventino 540 north Addison Road Villa Park IL 60181 1/29/2010 2/22/2010 2/18/2010
Black Damon 1591 Sunnyacres Road Copley OH 44321 1/29/2010 2/22/2010 2/18/2010
Metcalf Robert 2245 Tanglewood Drive Salem OH 44460 1/29/2010 2/22/2010 2/18/2010
Fonseca Jose 9404 Bit Street Bakersfield CA 93307 1/29/2010 2/22/2010 2/18/2010
Ausch Abraham 6 Mezabish Place #301 Monroe NY 10950 1/29/2010 2/22/2010 2/18/2010
Dahl Jeffrey 4513 North 71st Ave Pheonix AZ 85033 1/29/2010 2/22/2010 2/18/2010
White Marshall 1573 Sheridan Ave, NE Warren OH 44483 1/29/2010 2/22/2010 2/18/2010
Tovar Ernst 604 West Sutherland StreetAltus OK 73521 1/29/2010 2/22/2010 3/11/2010
Sedykh (Kushner) Olga 18708 East 52nd Ave Denver CO 80249 1/29/2010 3/4/2010 3/11/2010
Brimah Abdul 1015 East 61st Street Chicago IL 60637 1/31/2010 2/22/2010 2/18/2010
Harris Leonard 2832 Avenue I, NW Winter Haven FL 33881 1/31/2010 4/5/2010 4/5/2010
Ciddio Mark 10870 Cherry Ridge Road Sebastopol PA 95472 2/19/2010 3/4/2010 3/4/2010
Goodwin Dianna 5056 Arbor Glen Road The Colony TX 75056 2/22/2010 3/24/2010 3/25/2010
Levy Josef 6581 NW 22nd Street Sunrise FL 33313 2/22/2010 3/4/2010 3/11/2010
McCombs Louis 6118 S. Lakewood Ave Tulsa OK 74136 3/11/2010 4/5/2010 4/5/2010
Atwater Gregory 2301 Resterstown Road Baltimore MD 21217 6 of4/19/2010
7 5/5/2010 5/6/2010
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
S & A Capital Loan Acquired From Chase Document
Document
115-2
67-1
Filed
Filed
08/05/16
08/24/15
Page
Page
54 of
8 of
190
8
Last Name First Name Address City St. Zip Date Aqcuired Original Assgn Recv'd Collateral File Received
De LA Cruz Elena 616 South Keenan Ave Los Angeles CA 90022 5/10/2010 6/2/2010 6/4/2010
Kuzma Lawrence 12 Tom Gray Court Forked River NJ 08732 5/12/2010 6/2/2010 6/4/2010
Baldwin Angela 25 Kirk Street West Orange NJ 07052 5/25/2010 6/9/2010 6/9/2010
Carter Ruth 1800 NW 86th Terrace Miami FL 33147 5/25/2010 6/9/2010 6/9/2010
Hermida Maria 100 NW 204th Street, Apt #G4
Miami FL 33169 5/25/2010 6/9/2010 6/17/2010
Stanson Ronald 2924 N 24th Street Philadelhia PA 19132 5/27/2010 6/15/2010 6/9/2010
Mendoza David 26784 Santa Rosa Drive Moreno Valley CA 92555 5/27/2010 6/15/2010 6/17/2010
Emden Michael 3107 E 25th Ave Tampa FL 33605 5/27/2010 6/15/2010 6/29/2010
Beato Tomas 7656 Ft Sumter Drive Orlando FL 32822 5/27/2010 7/12/2010 7/15/2010
Croft Derrick 5973 Velvet Loop Lakeland FL 33811 6/16/2010 6/22/2010 6/22/2010
Smith Kevin 107 Dillon Road Marquette Heights IL 61554 6/22/2010 7/6/2010 7/6/2010
Kemler Roxie 1110 Helena Ave Vancouver WA 98661 6/24/2010 7/6/2010 7/6/2010
Williams Mark 1270 NE 42 Street Pompano Beach FL 33064 6/24/2010 8/6/2010 8/13/2010
Lam Hai 221 North Marion St #2C Oak Park IL 60302 6/28/2010 7/12/2010 7/12/2010
Akers/Altman Christine /Patricia 1240 Valley Road Twin lakes WI 53181 6/28/2010 7/12/2010 7/12/2010
Thornton Gary 2976 Sunset Drive Mariana GA 32448 6/28/2010 7/16/2010 7/16/2010
Notestine Mary 1015 Rozell Street Rogers AR 72756 6/28/2010 7/12/2010 7/12/2010
Lubin Michel 117 SW Twig Ave Port Saint Lucie FL 34983 6/28/2010 7/27/2010 8/6/2010
Thomas Phyliss 881 Lyons Circle, NW Palm Bay FL 32907 6/28/2010 7/28/2010 7/28/2010
Hernandez Sonia 2320 Montego Drive Miramar FL 33023 9/30/2010 10/26/2010 11/3/2010
7 of 7
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-2
Filed
Filed
08/05/16
08/24/15
Page
Page
55 of
1 of
190
4
EXHIBIT 2
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
1st Fidelity Loan Servicing Acquired From Chase 2009-2010 Document
Document
115-2
67-2
Filed
Filed
08/05/16
08/24/15
Page
Page
56 of
2 of
190
4
Last Name First Name City St. Zip Date Aqcuired Original Assgn Recv'd File Received
1 Carson Lynetta 1143 N Fulton Ave Baltimore MD 21217 5/29/2009 8/24/2009 7/5/2009
2 Russano Richard 123 Soundview Ter Northport NY 11768 5/29/2009 6/23/2009 8/7/2009
3 Fleming Anthony 312 S Eastern Ave Joliet IL 60433 6/8/2009 8/7/2009 8/7/2009
4 Kennedy Antoine R 123 S Regency Dr Apt 106 Decatur IL 62522 6/30/2009 8/7/2009 8/7/2009
5 Zoldock Jr John 220 STANFORD DR Gerea OH 44017 6/30/2009 6/30/2009 7/10/2009
6 Perl Moishe 1381 E 26TH ST Brooklyn NY 11230 6/30/2009 6/30/2009 7/15/2009
7 Hodges Jeff P.O. Box 6311 Springfield MA 01109 7/1/2009 7/1/2009 7/25/2009
8 Zackery Michelle Elizabeth 1900 King George Ln Atlanta GA 30331 7/1/2009 7/1/2009 7/12/2009
9 Foote Phyllis M 8022 Cobble Hill Rd Houston TX 77050 7/28/2009 8/28/2009 8/28/2009
10 Wilder Charles & Pamela 179 Grumman Ave Newark NJ 07112 7/28/2009 8/18/2009 8/18/2009
11 Silva James A 38 Robinson St Brentwood MI 03833 7/31/2009 8/18/2009 8/18/2009
12 Whalen Richard J & Jacqueline N P.O. Box 216 Grandview WA 98930 7/31/2009 8/28/2009 8/31/2009
13 Winstrand Randall E 2025 178th St Lansing IL 60438 7/31/2009 8/18/2009 8/18/2009
14 Calobrisi James R 73 Hiawatha Dr Brightwaters NY 11718 7/31/2009 8/18/2009 8/18/2009
15 Zapata Marcelino & Baldo 6217 County Rd 165 Genoa OH 43430 7/31/2009 8/24/2009 8/24/2009
16 Williams Gregory 659-661 Morrow Ave Macon GA 31217 7/31/2009 8/18/2009 8/18/2009
17 Alvarez Frances S 31741 Loire Dr Winchester CA 92596 7/31/2009 8/18/2009 8/18/2009
18 Tam David K & Jacqueline 657 Inder Ln Yuba City CA 95993 7/31/2009 8/28/2009 8/28/2009
19 Persaud Balwan & Amy 545 Oakley Ave Elmont NY 11003 7/31/2009 8/18/2009 8/18/2009
20 Mohamed Mohamed 567 SPRUCE LN Franklin Lakes NJ 07417 7/31/2009 8/18/2009 8/18/2009
21 Peet Shirley 415 Shore Drive Joppa MD 21085 8/18/2009 8/28/2009 8/28/2009
22 Mirabile Margaret 903 North Green Street McHenry IL 60050 8/18/2009 9/8/2009 9/8/2009
23 Placide Lyla 298 Skidmore Road Deer Park NY 11729 8/18/2009 9/8/2009 9/8/2009
24 Robinson Vanessa 133 SW Lancelot Gln Lake City Fl 32024 8/26/2009 9/30/2009 9/30/2009
25 Durnin Terry / Angela 502 W First Street Monona IA 52159 8/26/2009 11/9/2009 11/9/2009
26 Lombrana Jose/Debora 1841 Darby Lane Ceres CA 95307 8/26/2009 9/11/2009 9/11/2009
27 Carr James 10 Royal Palm Way Boca Raton FL 33432 8/26/2009 9/8/2009 9/8/2009
28 Pena Magda 8 Hanford Place Tarrytown NY 10591 8/28/2009 9/30/2009 9/30/2009
29 Smith Margaret 11 Taylor Court Staten Island NY 10310 8/28/2009 9/30/2009 9/30/2009
30 Gonzales Santiago 3055 17th Street Highland CA 92346 8/28/2009 9/21/2009 9/21/2009
31 Rowe-Lewis Anne & Lansing 16 Dryden Ave Pawtucket RI 02860 8/28/2009 9/30/2009 9/30/2009
32 Himaia Fayeza 674 Paxson Ave Mercerville NJ 8619 8/31/2009 9/30/2009 9/30/2009
33 Rudy Frankie 2402 S 17th Ave Broadview IL 60153 8/31/2009 9/30/2009 9/30/2009
34 Duley Frederick 105 Landman St Chesterton IN 46304 8/31/2009 9/21/2009 9/21/2009
35 Flores Damazo 1516 Willever St Plainfield NJ 07063 8/31/2009 9/30/2009 9/30/2009
36 Hoffmann Richard & Frances 3272 College Ave Grand Rapids MI 49525 8/31/2009 9/30/2009 9/30/2009
37 Martin Amber 4748 Black Hollow Dublin VA 24084 8/31/2009 9/30/2009 9/30/2009
38 Nanthavong Kim 1263 Ryan Road Springfield OH 45503 8/31/2009 10/19/2009 10/19/2009
39 Nashid Salahuddin 2848 Burchill Road N Ft Worth TX 76105 8/31/2009 9/30/2009 9/30/2009
40 Santiago Jocelyn 45112 Greenbriar Dr Belleville MI 48111 8/31/2009 10/21/2009 10/21/2009
41 Warf Johnny 4808 Ina Lane Walkertown NC 27051 8/31/2009 9/30/2009 9/30/2009
42 Granberg Andrew 5537 Xerxes Ave S Minneapolis MN 55410 8/31/2009 9/21/2009 9/21/2009
43 Lucio Benito 1786 Settler Dr Fort Myers FL 33905 8/31/2009 10/19/2009 10/16/2009
44 Hrych II Gary 62 Flatrock Rd Elizabethtown KY 42701 8/31/2009 9/25/2009 9/25/2009
45 Villella/ Guiley Leslie 2148 E Foothill Dr Phoenix AZ 85024 8/31/2009 9/30/2009 9/30/2009
46 McLeod Candace 16113 E Burns Dr Loxahatchee FL 33470 8/31/2009 9/30/2009 9/30/2009
47 Strutzenberg Vern 2207 Primrose Dr Plainfield IL 60586 8/31/2009 9/30/2009 9/30/2009
48 Castillo Diego 1985 Barnhill Dr Mundelein IL 60060 8/31/2009 9/30/2009 9/30/2009
49 Morgan Robert 4154 E 104th St Cleveland OH 44105 8/31/2009 10/19/2009 10/19/2009
50 Stewart Rosa 8700 SW 83rd Ct Miami FL 33143 8/31/2009 10/21/2009 10/21/2009
51 Williams David 3971 Caseman Ave San Diego CA 92154 8/31/2009 9/30/2009 9/30/2009
52 Ruiz Doris 3219-3221 34th Ave S Minneapolis MN 55406 8/31/2009 10/28/2009 10/28/2009
53 Dubniczki Peter 11543 65th Ave N Seminole FL 33772 8/31/2009 10/19/2009 10/19/2009
54 McPherson Denyce 12815 Riad St Detroit MI 48224 8/31/2009 9/30/2009 9/30/2009
55 Miller Randall 4725 Verona St NW Warren OH 44483 8/31/2009 9/21/2009 9/21/2009
56 Romero Edna 1661 Heather Ridge Rd N Las Vegas NV 89031 8/31/2009 10/21/2009 10/21/2009
57 Morris Carroll 10730 W Clover Way Avondale AZ 85392 8/31/2009 9/30/2009 9/30/2009
58 Clark Tim 26936 Upper Pleasant Wilder ID 83676 8/31/2009 9/30/2009 9/30/2009
59 Parra Alfonso 18332 NW 68 Ave #A Miami FL 33015 8/31/2009 9/30/2009 9/30/2009
60 Swartvagher Pierre 100 Brandy Lane Wappingers NY 12590 9/8/2009 11/11/2009 11/11/2009
61 Cornish, jr. Marvin 14636 London Lane Bowie MD 20715 9/19/2009 10/28/2009 10/28/2009
62 Jarvis Forrest 8405 Suncoast Dr Ft Myers FL 33917 9/29/2009 10/28/2009 10/28/2009
63 Ortiz Ramiro 411 Kentucky St Tavares FL 32778 9/29/2009 10/28/2009 10/28/2009
64 Derosa Vito 2801 SW Montego Terr Stuart FL 34997 9/29/2009 11/17/2009 11/24/2009
65 Warwick Robert 801 Vacation Drive Odenton MD 21113 9/29/2009 11/11/2009 11/11/2009
66 Jones-Kirkland Desiree 3456 E 123 St St Cleveland OH 44120 9/30/2009 10/28/2009 10/28/2009
67 Francis Harvey 319 S Temple Ave Indianapolis IN 46201 9/30/2009 11/17/2009 11/24/2009
68 Hernandez Joel 1413 W El Monte PL Chandler AZ 85241 9/30/2009 10/28/2009 10/28/2009
69 Phipps Curtis 606 Forstall St New Orleans LA 70117 9/30/2009 11/17/2009 11/24/2009
70 Di Minno Matthew 5805 Herzman Dr Evergreen CO 80439 9/30/2009 10/28/2009 10/28/2009
71 Estes Michael 4345 Ridgemoor Dr N Palm Harbor FL 34685 9/30/2009 10/28/2009 10/28/2009
72 Featherstone Timothy 2 Pheasant Run Oakdale CT 6370 9/30/2009 10/28/2009 10/28/2009
73 Parra Alfonso 18332 NW 68 Av #A Miami FL 33015 9/30/2009 11/5/2009 11/5/2009
74 Dunn Kathleen 535 Olive Av Modesto CA 95350 9/30/2009 10/28/2009 10/28/2009
75 Ford Thelma 5048 Orinoco St Pittsburgh PA 15207 9/30/2009 10/28/2009 10/28/2009
76 Rossatto Jacob 1334 W Smith St Orlando FL 32804 9/30/2009 11/17/2009 11/23/2009
77 Hutchison Michael 722 Edinburgh St San Francisco CA 94112 9/30/2009 10/28/2009 10/28/2009
78 Thawley Michael 115 Oak Knoll Av San Anselmo CA 94960 9/30/2009 10/28/2009 10/28/2009
79 Chavez Magdaleno 6019 S 41st Av Phoenix AZ 85041 9/30/2009 10/28/2009 10/28/2009
80 Lisowski Jennifer 7260 17th Lane N St Petersburg FL 33702 9/30/2009 10/28/2009 10/28/2009
81 Belle Cheryl 125 E 45 St Jacksonville FL 32208 9/30/2009 10/28/2009 10/28/2009
82 Ortiz Santos 4602 Elderberry Dr Orlando FL 32809 9/30/2009 10/28/2009 10/28/2009
83 Johnson Will 257 Central St Springfield MA 01105 9/30/2009 10/28/2009 10/28/2009
84 Williams Irene 6045 N 40th St Paradise Valley AZ 85253 9/30/2009 11/17/2009 11/19/2009
85 Miller Robin 2209 Forest Hill Av SE Grand Rapids MI 49546 9/30/2009 10/28/2009 10/28/2009
86 Harrity Yvonne 16445 El Centro St Hesperia CA 92345 9/30/2009 10/28/2009 10/28/2009
87 Mays Della 240 W Knox Dr Tucson AZ 85705 9/30/2009 10/28/2009 10/28/2009
88 Ahmed Saleh 321 S English St Moore OK 73160 9/30/2009 10/28/2009 10/28/2009
89 Duhan Mark 7 Mountain View Dr New Milford CT 06776 9/30/2009 10/28/2009 10/28/2009
90 Walker Michael 2833 181 PL NW Stanwood WA 98292 9/30/2009 10/28/2009 10/28/2009
91 Sharps Elly 63 Sand Hill Rd Gilford NH 03249 10/30/2009 11/17/2009 11/19/2009
92 Bitzer Jini 1303 Campbell Ave Lynchburg VA 24501 10/30/2009 11/17/2009 11/27/2009
93 Heathcott David 814 Olive St Murray KY 42071 10/30/2009 11/18/2009 11/24/2009
94 Nava Martin 1333 Pacific St Las Vegas NV 89104 10/30/2009 11/17/2009 11/27/2009
95 Spence William 634 Nesting Lane Middletown DE 19709 10/30/2009 11/17/2009 11/18/2009
96 Hancock Teresa 204 New Haven Ave #8E Derby CT 06418 10/30/2009 11/9/2009 11/27/2009
97 Berdolt Kellyanne 110 Center Bay Dr West Islip NY 11795 10/30/2009 11/9/2009 11/27/2009
98 Garcia Sofia 3212 Stone Meadows Dr Bakersfield CA 93313 10/30/2009 11/18/2009 11/24/2009
99 Tommasiello Michael 3408 Deerhaunt St Yorktown Heights NY 10598 10/30/2009 11/17/2009 11/24/2009
100 McKernan Shawn 6332 Stanwin Dr Apopka FL 32712 10/30/2009 12/16/2009 12/9/2009
101 Ayaz Fatma 5250 Las Verdes Cir #1210 Delray Beach FL 33484 10/30/2009 11/10/2009 11/18/2009
102 Donnat Arnold 4006 Barwood Dr Orlando FL 32839 10/30/2009 11/10/2009 11/27/2009
103 Molina Nitza 5561 NW 9th Ave Miami FL 33127 10/30/2009 11/9/2009 1/12/2010
104 Benjamin Tiffani 37 Eugenie Ct New Orleans LA 70131 10/30/2009 11/20/2009 11/24/2009
105 Johnson/Delano Renata/Bartolo 4222 Inverrary Blvd Lauderhill FL 33319 10/30/2009 11/17/2009 11/24/2009
106 McFarland Vanessa 18768 Avon St Detroit MI 48219 10/30/2009 11/17/2009 11/27/2009
107 Cartwright William 715 Lincoln St Indianapolis IN 46208 10/30/2009 11/18/2009 11/24/2009
108 Kouznetsova Janna 6171 N Sheridan Rd #1603 Chicago IL 60660 10/30/2009 11/17/2009 11/27/2009
109 Kouznetsova Janna 6171 N Sheridan Rd #1603 Chicago IL 60660 10/30/2009 11/17/2009 11/27/2009
110 Wood Marshall 227 Crestwood Lane Williamsville NY 14221 10/30/2009 11/20/2009 11/24/2009
111 Tercero Julio 2328 Bristol View Ct Las Vegas NV 89108 10/30/2009 11/20/2009 11/24/2009
112 Vera Jesus 16804 145th Court SW Miami FL 33177 10/30/2009 11/20/2009 11/24/2009
113 Agledor Almette 534 Washington St Daytona 1 FL
of 3 32114 10/30/2009 11/18/2009 11/24/2009
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
1st Fidelity Loan Servicing Acquired From Chase 2009-2010 Document
Document
115-2
67-2
Filed
Filed
08/05/16
08/24/15
Page
Page
57 of
3 of
190
4
Last Name First Name City St. Zip Date Aqcuired Original Assgn Recv'd File Received
114 Yim Kyongo 364 High St Norwood NJ 07648 10/30/2009 11/18/2009 11/24/2009
115 Dent Mary 380 Hudson St Rossville GA 30741 10/30/2009 11/18/2009 11/24/2009
116 Smith Jeffrey 1627 N. 26th Ave St. Patersburgh FL 33713 10/30/2009 11/17/2009 11/18/2009
117 Johnson Cecil (Eddie or Anne Marie?) 1959 Spring Dr Jacksonville FL 32209 10/30/2009 11/17/2009 11/18/2009
118 Margate Marcelino 1615 Grace Ave Ft. Myers FL 33901 10/30/2009 11/17/2009 11/27/2009
119 Mora Nellie 113 Independence Ave Babylon NY 11702 10/30/2009 11/17/2009 11/27/2009
120 Leavitt Douglas J 827 26th Ave Ogden UT 84401 10/30/2009 12/15/2009 12/16/2009
121 Dickey Royce & Carolyn 3126 Oak Point Dr Garland TX 75044 11/4/2009 1/20/2010 1/20/2010
122 Kelly Laurence 2929 SE Ocean Blvd, Unit K7 Stewart FL 34996 11/23/2009 1/4/2010 12/30/2009
123 Lewis (Reece) Winetta 4729 Block Island Lane Clermont FL 34714 11/25/2009 12/15/2006 12/9/2009
124 Underwood Ashley 625 Wiegand Drive Ridge City LA 70094 11/25/2009 1/7/2010 1/7/2010
125 Murphy Jack 356 Kennard Street Johnstown PA 15906 11/25/2009 1/20/2010 3/8/2010
126 Dickinson William 3015 Major Road Chewelah WA 99109 11/25/2009 12/9/2009 12/9/2009
127 Despaigne Daniel 6005 W Golden Lane Glendale AZ 85302 11/25/2009 1/4/2010 12/30/2009
128 Gonzalez Julio 3166 W 79th Place Hialeah FL 33018 11/30/2009 2/26/2010 2/26/2010
129 Matuszewski Robert 3516 Cranston Ave Wilmington DE 19808 11/30/2009 12/15/2009 12/16/2009
130 Ware John 502 A Street St. Augustine FL 32080 11/30/2009 12/15/2009 12/16/2009
131 Quintero Carlos 10317 NW 9th St Miami FL 33172 11/30/2009 12/15/2009 12/16/2009
132 Schiwietz Kirk 4604 W Hawthorne Rd Tampa FL 33611 11/30/2009 12/16/2009 12/16/2009
133 Mandator Charles 617 Lathrop St Columbus OH 43206 11/30/2009 12/16/2009 12/16/2009
134 Garay David 14709 Clark St Baldwin Park CA 91706 11/30/2009 12/29/2009 12/29/2009
135 Tarter Tom 6333 E Kerr Creek Bloomington IN 47408 11/30/2009 12/15/2009 12/16/2009
136 Nagaytsev Oleg 12034 96th Ave NE #531 Kirkland WA 98034 11/30/2009 12/29/2009 12/29/2009
137 Provoznik Patrick 922 Wadsworth Rd B-1 Medina OH 44256 11/30/2009 1/4/2010 12/30/2009
138 Le Trong 3673 15th Ave SE Largo FL 33771 11/30/2009 12/16/2009 12/16/2009
139 Kang Kyung 416 Ustilago Court San Ramon CA 94582 11/30/2009 2/22/2010 2/22/2010
140 Meekins Lula 159 Orlando Meekins Ln Kill Devil Hills NC 27948 11/30/2009 12/16/2009 12/16/2009
141 Bouchard Suzanne 9 Knollwood Dr Freeville NY 13068 11/30/2009 1/5/2010 1/4/2010
142 Sanchez Alfredo 1517 E Lambright St Tampa FL 33610 11/30/2009 1/4/2010 12/30/2009
143 Garner John 5515 NE 17th Ave Portland OR 97211 12/17/2009 1/22/2010 1/22/2010
144 Martinez Angel 18906 Cathedral Dr Gaithersburg MD 20879 12/17/2009 1/20/2010 1/20/2010
145 Mensen Mark 906 N Maiden Lane Joplin MO 64801 12/22/2009 1/20/2010 1/20/2010
146 Reyes Candida 38 Rowland Street Newark NJ 07104 12/22/2009 1/20/2010 1/20/2010
147 Gammon Dwight 2021 Ingalls Main Stillwater OK 74074 12/22/2009 1/20/2010 1/20/2010
148 Buswell Chris 35 W Broad St #105 Stamford CT 06902 12/22/2009 1/20/2010 1/20/2010
149 Nabozny Linda 879 Farmington Ave Pottstown PA 19464 12/28/2009 1/20/2010 1/20/2010
150 Lawrence Susan Lee 18657 E 40th Place Denver CO 80249 12/28/2009 1/20/2010 1/20/2010
151 Kelly Helen 8225 Fairmount Dr #A Denver CO 80247 12/28/2009 1/20/2010 1/20/2010
152 Siglin Allen 5555 Mariposa Avenue Palms CA 92277 12/28/2009 2/22/2010 2/22/2010
153 Terry Richard 104 Iberia Circle West Monroe LA 71291 12/28/2009 1/20/2010 1/20/2010
154 Sheldon Scott 10442 Sunrise Lakes Sunrise FL 33322 12/28/2009 1/22/2010 1/22/2010
155 Machado Natalia 7129 Fairfax Dr San Bernardino CA 92404 12/28/2009 1/20/2010 1/20/2010
156 Freer Patrick 2 Jenyfer Ct Shelton CT 06484 12/28/2009 1/20/2010 1/20/2010
157 Wright Henri 1029 Abbott Lane Park Forest IL 60466 12/28/2009 1/20/2010 1/20/2010
158 Lawwill George 2090 Kylemore Dr Xenia OH 45385 12/28/2009 1/20/2010 1/20/2010
159 Melkonyan Lusine 12605 Barbara Ann St #B N Hollywood CA 91605 12/28/2009 1/20/2010 1/20/2010
160 Lentz George 965 La Croix Ave Green Bay WI 54304 12/28/2009 1/20/2010 1/20/2010
161 Benigno Danielle 2337 NW 89 Dr #607-6 Coral Springs FL 33065 12/28/2009 1/20/2010 1/20/2010
162 Theodore Thomas 14640 Minerva Ave Dolton IL 60419 12/28/2009 1/20/2010 1/20/2010
163 Guzzino Warren 23841 Via La Coruna Mission Viejo CA 92691 12/28/2009 2/26/2010 2/26/2010
164 Hernandez Ramon 3028 N Gardena St San Bernardino CA 92407 12/28/2009 1/22/2010 1/22/2010
165 Pirus Lee Anne 7806 Stratton Way Madison WI 53719 12/28/2009 2/22/2010 2/22/2010
166 Mejia Lucita 1742 Tassel Fern Ave Las Vegas NV 89183 12/28/2009 1/22/2010 1/22/2010
167 Yergler Ronald 820 N 1200 E Rd Cissna Park IL 60924 12/28/2009 2/22/2010 2/22/2010
168 Zumwalt Willis 28439 Copper Creek Dr Coarsegold CA 93614 12/28/2009 1/20/2010 1/20/2010
169 Guthrie Gina 2934 Louise Ave Salt Lake City UT 84109 12/28/2009 1/22/2010 1/22/2010
170 Mendoza Arthur 16011 Wake Court La Puente CA 91744 1/12/2010 3/4/2010 3/4/2010
171 Citronenbaum Chaim 11 Jay Court Monsey NY 10952 1/28/2010 2/4/2010 2/4/2010
172 Hamill III James 16031 81st Street Howard Beach NY 11414 2/22/2010 2/26/2010 2/26/2010
173 Bradley Patricia 5391 Pine Ridge Dr Elizabeth CO 80107 2/25/2010 3/4/2010 3/4/2010
174 Papikyan Mariam 450 Via Luneto Montebello CA 90640 2/26/2010 3/11/2010 3/11/2010
175 Weller Carol 2800 NW 56th Ave G308 Lauderhill FL 33313 2/26/2010 3/12/2010 3/12/2010
176 Serrano Cruz Anita 4155 W Alta Vista Rd Phoenix AZ 85041 2/26/2010 3/12/2010 3/12/2010
177 Bastian Andrew 10 Pine St Wellsville NY 14895 2/26/2010 3/12/2010 3/12/2010
178 Shirley Ronald 3513 Jackson Dr Holiday FL 34691 2/26/2010 3/26/2010 3/26/2010
179 Guzman Frank 1825 7th St Denver CO 80631 2/26/2010 3/11/2010 3/11/2010
180 Campbell Alphonso 9715 Scottdale Dr Saint Louis MO 63436 2/26/2010 3/12/2010 3/12/2010
181 Beans Mary Ann 237 W Virginia Ave Peoria IL 61604 2/26/2010 3/12/2010 3/12/2010
182 Scott Linda 3946 Pauger St New Orleans LA 70122 2/26/2010 3/12/2010 3/12/2010
183 Anderson Norma-Jean 41 Quaker Ln Brewster MA 2631 2/26/2010 3/12/2010 3/12/2010
184 Williams Mary 381-383 Genesee St Rochester NY 14611 2/26/2010 3/12/2010 3/12/2010
185 Williams Herman 11902 Southview St Houston TX 77047 2/26/2010 3/12/2010 3/12/2010
186 Jeter Mark 1023 NE 6th St Ocala FL 34470 2/26/2010 3/12/2010 3/12/2010
187 Chester Shirley A 517 Wallace St Daytona Beach FL 32114 2/26/2010 3/26/2010 3/26/2010
188 St. Jean Jean 5008 Donny Boy Cir Orlando FL 32808 2/26/2010 3/12/2010 3/12/2010
189 Gray Jason 13 Dinsmore St Skowhegan ME 04976 2/26/2010 3/12/2010 3/12/2010
190 Chesley Shannon 91 W Main St Cuba NY 14727 2/26/2010 3/12/2010 3/12/2010
191 Davis Sarah 1037 W 115th St Chicago IL 60645 2/26/2010 3/12/2010 3/12/2010
192 Madrigal Leonel S 1351 Picard Ln Turlock CA 95380 3/31/2010 4/22/2010 4/22/2010
193 Murray Raymond John 203 Angeloz St Lafayette LA 70501 3/31/2010 4/22/2010 4/22/2010
194 Philpot Jerome 8174 Thompston St Douglasville GA 30134 3/31/2010 4/22/2010 4/22/2010
195 Piscopo John 400 Tilford S Deerfield Beach FL 33442 3/31/2010 4/22/2010 4/22/2010
196 Culverhouse Bryce 622 S 11th St Lafayette IN 47905 3/31/2010 4/22/2010 4/22/2010
197 Kpan Alex 483 Broadway Staten Island NY 10310 3/31/2010 4/22/2010 4/22/2010
198 Villa Rogelio 22 S Pardee St San Diego CA 92113 3/31/2010 4/22/2010 4/22/2010
199 Marques Roberto S 9412 SW 2nd St Boca Raton FL 33428 3/31/2010 4/22/2010 4/22/2010
200 Martina Michael C 100 Kings Pl Mullica Hill NJ 08062 3/31/2010 4/22/2010 4/22/2010
201 White Troy L 163 Bayferry Rd Earle AR 72331 3/31/2010 4/22/2010 4/22/2010
202 Soto Maria 13024 Bender Dr Moreno Valley CA 92553 3/31/2010 4/22/2010 4/22/2010
203 Vasquez Tamara E 11841 SW 117th Ct Miami FL 33186 3/31/2010 4/22/2010 4/22/2010
204 Miller Gary B 6402 1st Ave W Bradenton FL 34209 3/31/2010 4/22/2010 4/22/2010
205 Williams Andre 2218 S Park St Little Rock AR 72202 4/12/2010 5/5/2010 5/5/2010
206 Faulkner Eric 540758 Lem Turner Rd Callahan FL 32001 4/12/2010 5/5/2010 5/5/2010
207 Aparicio Alfredo 5545 W Almeria Rd Phoenix AZ 85035 4/15/2010 6/14/2010 6/14/2010
208 Zappa Anthony J 21 Kendall St Gardner MA 01440 4/30/2010 6/2/2010 6/2/2010
209 Cunha Geraldo 420 SE 2nd Ave #24-B Deerfield Beach FL 33441 4/27/2010 6/14/2010 6/14/2010
210 Vega Alfredo 1026 Champion Ave Lehigh Acres FL 33971 4/30/2010 6/2/2010 6/2/2010
211 Cardoso Vinicius 420 SE 2nd Ave #B Deerfield Beach FL 33441 4/30/2010 6/2/2010 6/2/2010
212 Barnett Dwight C 7602 Brookline Ave Fort Pierce FL 34951 4/28/2010 5/13/2010 5/13/2010
213 Chavez Cheri L 12506 223rd Ave E Sumner WA 98390 4/29/2010 6/14/2010 6/14/2010
214 Duran Juan C 2779 Peso St Las Vegas NV 89121 4/29/2010 5/24/2010 5/24/2010
215 Davis Ryan J 926 Sylvia Dr Lodi CA 95240 4/29/2010 6/2/2010 6/2/2010
216 McCool Daniel 97 River Bank Dr Roebling NJ 08554 4/30/2010 5/24/2010 5/24/2010
217 Wilcox Linda 4501 E 14 Ave Tampa FL 33605 4/30/2010 5/24/2010 5/24/2010
218 Falaise Pierre 24 Pierson PL Montclair NJ 07028 4/30/2010 6/2/2010 6/2/2010
219 Lewis Krae 1360 SW Hoytsville Rd Coalville UT 84017 4/30/2010 5/24/2010 5/24/2010
220 Jones (deceased) Malissa L 1210 Cascade Rd Atlanta GA 30311 4/30/2010 5/24/2010 5/24/2010
221 Patz Joshua 6365 Rancho Mission Rd San Diego CA 92108 4/30/2010 6/2/2010 6/2/2010
222 Hodges-Opper Melissa A 13837 54th Ln N West Palm Bch FL 33411 4/30/2010 5/24/2010 5/24/2010
223 Tate Linda Faye 1523 N Menard Ave Chicago IL 60651 4/30/2010 6/8/2010 6/8/2010
224 Hollie Ronald Lee 1143 Pinder Ln DeQuincy LA 70633 4/30/2010 6/2/2010 6/2/2010
225 Hernandez Ernesto J 10304 SW 20th St Miami FL 33165 4/30/2010 6/2/2010 6/2/2010
226 Schmutzer George 245 Manalapan Rd Spotswood NJ 08884 4/30/2010 6/8/2010 6/8/2010
2 of 3
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
1st Fidelity Loan Servicing Acquired From Chase 2009-2010Document
Document
115-2
67-2
Filed
Filed
08/05/16
08/24/15
Page
Page
58 of
4 of
190
4
Last Name First Name City St. Zip Date Aqcuired Original Assgn Recv'd File Received
227 Pugh Linda Ann 7608 Liberty St Shreveport LA 71106 4/30/2010 6/14/2010 6/14/2010
228 Condie John J 1118 2nd St Kirkland WA 98033 5/25/2010 6/18/2010 6/14/2010
229 Bedoya Alberto M 3779 Burgundy Q 7790 Delray Beach FL 33484 5/28/2010 6/14/2010 6/14/2010
230 Martin Bruce L 319 Savannah Holly Ln Sanford FL 32771 5/28/2010 6/18/2010 6/20/2010
231 Yother Patsy 2516 Ellijay Drive, NE Atlanta GA 30319 6/24/2010 7/7/2010 7/7/2010
232 Rivers Clarisse 506 East 9th Street Michigan City IN 46360 6/24/2010 7/7/2010 7/7/2010
233 Rhodes Keith 27 Pinewood Drive Cabot AR 72023 6/24/2010 7/7/2010 7/7/2010
234 Bahena Efrain 400 Richmond Dr Romeoville IL 60446 6/28/2010 7/12/2010 7/12/2010
235 Santana Martina 314 Paulison Ave Passaic NJ 07055 6/28/2010 7/21/2010 7/21/2010
236 Pfeifer Thomas 6 Anchor CT West Babylon NY 11704 6/28/2010 7/21/2010 7/21/2010
237 Bradley Ursula 3278 Highland Forge Trail Dacula GA 30019 6/28/2010 NA 7/21/2010
238 Watson Sabrina 11125 East Golf Drive Miami FL 33167 6/28/2010 7/22/2010 7/21/2010
239 Dabrowski Lucien 3636 Indios Ave Las Vegas NV 89121 6/28/2010 7/12/2010 7/12/2010
240 Marinos Leon 15 Latern Lane Plymouth MA 02360 6/28/2010 7/12/2010 7/12/2010
241 Plante Gilery 18111 NW 2nd Court Miami FL 33169 6/28/2010 7/21/2010 7/21/2010
242 Jerez Humberto 10124 Dean Chase Blvd Orlando FL 32825 6/28/2010 8/2/2010 8/4/2010
243 Thurman Willie 3276 North Seacrest Blvd Boynton Beach FL 33435 6/28/2010 7/21/2010 7/21/2010
244 Morgan Paul M 6653 Cloister Cliff Road Middeltown OH 45042 6/28/2010 8/13/2010 8/13/2010
245 Buzzeo Michael A 7 Royal Pine Drive Danbury CT 06811 7/30/2010 8/13/2010 8/13/2010
246 Guarino Michael & Mimi 148 Sussex H 148 West Palm Bch FL 33417 7/30/2010 8/13/2010 8/13/2010
247 McKenna Mark 306 E Ambassador Dr Tempe AZ 85281 7/30/2010 8/13/2010 8/13/2010
248 Sakalis Theo 4 Consulate Drive 2A Tuckahoe NY 10707 7/30/2010 8/13/2010 8/13/2010
249 Alfano Stephanie 15 Chelsea Drive Smithtown NY 11787 7/30/2010 8/13/2010 8/13/2010
250 Deese Larry 2600 Cleinview Apt 15 Cincinnati OH 45206 7/30/2010 8/13/2010 8/13/2010
251 Thomassie Rhonda Ann 4912 Fairfield Street Metairie LA 70006 7/30/2010 8/13/2010 8/13/2010
252 Rodriguez Orlando & Zenaida 2450 SW 88th Avenue Miami FL 33165 7/30/2010 8/13/2010 8/13/2010
253 Gamez Dilma Adriana 618 Meadowbrook Rd Uniondale NY 11553 8/3/2010 8/27/2010 8/27/2010
254 Frizalone Danette M 5134 Tangelo Dr New Port Richey FL 34652 8/31/2010 9/24/2010 9/24/2010
255 Szymanska Barbara 1182 E Nichols Rd Unit 5B Palatine IL 60074 8/30/2010 9/9/2010 9/9/2010
256 Davey Donald J 1060 Falcon Nest Ct Mesquite NV 89027 8/30/2010 9/9/2010 9/9/2010
257 Smith Gilbert & Rose M 4403 W Orchid Ln Glendale AZ 85302 8/31/2010 9/15/2010 9/15/2010
258 Steymatskiy Gennadiy 1318 Gail Dr Buffalo Grove IL 60089 8/30/2010 9/9/2010 9/9/2010
259 Musillo Sarafina 226 Holton Ave Staten Island NY 10309 8/31/2010 9/15/2010 9/15/2010
260 Spencer Robert R & Arlene T 16 W 1050 N Chesterton IN 46304 8/31/2010 9/15/2010 9/15/2010
261 Dubois Gregg & Marjan 21015 Plum Ranch Rd Garden Ridge TX 78266 8/31/2010 9/15/2010 9/15/2010
262 Henriquez Carlos E 5615 Bear Meadow Ln Katy TX 77449 8/31/2010 9/15/2010 9/15/2010
263 Johnson Michael R 19836 Burlington Path Farmington MN 55024 9/20/2010 10/6/2010 10/6/2010
264 Dulansey David G 2425 Brandywine Ln York PA 17404 9/20/2010 10/6/2010 10/6/2010
265 Miller Lamar R 2683 Woodstock Ave Pittsburgh PA 15218 9/20/2010 10/29/2010 10/29/2010
266 Jackson Patrick 801 Jarmilla Ln Fort Myers FL 33905 9/23/2010 10/26/2010 10/26/2010
267 Farrell Keylla S 890 Country Club Rd Kankakee IL 60901 9/23/2010 10/19/2010 10/19/2010
268 Meighan Shane & Carolyn 45 Erlanger Blvd North Babylon NY 11703 9/28/2010 10/25/2010 10/25/2010
269 Reed Shirley A 8237 Anchor Point Dr Reno NV 89506 9/28/2010 10/25/2010 10/25/2010
270 Oliveira Francisco 2915 Winkler Ave Apt 816 Fort Myers FL 33916 9/28/2010 10/25/2010 10/25/2010
271 Jagdip Glenn 8 E Hudson St Long Beach NY 11561 9/29/2010 10/25/2010 10/25/2010
272 Kish Robert W 341 Ballewtown Rd Blue Ridge GA 30513 9/28/2010 11/16/2010 11/16/2010
273 Hurtado Kathleen 1318 Palm Ave Martinez CA 94553 9/28/2010 10/19/2010 10/19/2010
274 Irfan Rana M 224 County Rd 39 Southampton NY 11968 9/28/2010 10/25/2010 10/25/2010
275 Delacruz Cleotilde 1413 S 50th Ct Cicero IL 60804 9/28/2010 10/19/2010 10/19/2010
276 Eaton Paulette H 206 S Chicago St Rossville IL 60963 9/28/2010 10/29/2010 10/29/2010
277 Rodriguez Walter 2865 12th Ave NE Naples FL 34120 9/28/2010 11/16/2010 11/16/2010
278 Kalidas Kamlawatie & Jewan 10718 95th Ave Jamaica NY 11416 9/29/2010 10/19/2010 10/19/2010
279 Velasquez Faudicano J 992 York View Ct Gypsum CO 81637 9/29/2010 10/25/2010 10/25/2010
280 Hansen Roger L 844 44th St Lincoln NE 68503 9/29/2010 10/26/2010 10/26/2010
281 Lannie Leonard 2170 Bailey Ave Buffalo NY 14211 9/29/2010 10/19/2010 10/19/2010
282 Erb John 41 Osborne St Peabody MA 01960 9/30/2010 10/25/2010 10/25/2010
283 Aker Shawn 1272 Quarry Commons Yardley PA 19067 9/29/2010 10/25/2010 10/25/2010
284 Neyhart Leanne 2937 Miami St Lake Station IN 46405 9/30/2010 10/25/2010 10/25/2010
285 Ghebreab Saba 329 Westmeade Dr Gretna LA 70056 9/30/2010 11/16/2010 11/16/2010
286 Heredia Arturo 129 Mill St New Britain CT 06051 9/30/2010 10/25/2010 10/25/2010
287 McLaughlin Richard & Linda 5 Squire Ave Mansfield MA 02048 9/30/2010 10/25/2010 10/25/2010
288 Apple Janet L 8 Meadow Dr Troy NY 12180 9/30/2010 10/25/2010 10/25/2010
289 Greene Barbara & Timothy 8645 El Rico Dr Indianapolis IN 46240 9/30/2010 10/26/2010 10/26/2010
290 Andersson Lorraine A 15178 S Carus Rd Oregon City OR 97045 9/30/2010 10/25/2010 10/25/2010
291 Iniguez Francisco L 46347 S Trumbull Ave Chicago IL 60632 9/30/2010 10/25/2010 10/25/2010
292 Damstra Mark R 328 Madison St Unit 3 Hoboken NJ 07030 9/30/2010 n/a 10/27/2010
293 Wilson Gregory 443 Cleveland St Brooklyn NY 11208 9/30/2010 10/25/2010 10/25/2010
294 Harris Rebecca & Stephen 18162 E Dorado Ave Aurora CO 80015 9/30/2010 10/25/2010 10/25/2010
295 Hauptman Christopher M 9074 Gemini Rd Bloomington IL 61705 9/30/2010 10/25/2010 10/25/2010
296 Kessler Joel A 12323 Riverfalls Ct Boca Raton FL 33428 9/30/2010 10/28/2010 10/28/2010
297 Browne Everton S 1213 Dolsontown Rd Middletown NY 10940 9/30/2010 10/25/2010 10/25/2010
298 Smith Mark E 6960 Glen Arbor Dr Florence KY 41042 10/4/2010 10/25/2010 10/25/2010
299 Thompson Janice 6685 Raquet Club Dr Fort Lauderdale FL 33319 10/13/2010 11/19/2010 11/19/2010
300 Chung Ji Yeon 4068 E Championship Dr Annandale VA 22003 10/22/2010 11/16/2010 11/16/2010
301 Guzman Bosco J & Doris M 20014 NW 79th PL Hialeah FL 33015 10/22/2010 11/16/2010 11/16/2010
302 Carrick Kellyanne 67 Cannas Ct Cheektowaga NY 14227 10/26/2010 11/16/2010 11/16/2010
303 Spiridigliozzi Vincent 1198 Union Ave Newburgh NY 12550 10/26/2010 11/16/2010 12/15/2010
304 Sandoval Arthur A 4347 E Acoma Dr Phoenix AZ 85032 10/28/2010 11/16/2010 11/16/2010
305 Marchong Noel 824 Meehan Ave Far Rockaway NY 11691 10/27/2010 11/16/2010 11/16/2010
306 Durham Robert W 2092 Wildcat Creek Rd Rock Hill SC 29730 10/28/2010 11/16/2010 11/16/2010
307 Samnang Setha 724 Bristol Utica NY 13502 10/28/2010 11/16/2010 11/16/2010
308 Bui Trinh T 23942 SE 7th Ln Sammamish WA 98074 10/28/2010 11/19/2010 11/19/2010
309 Martin Victoria A & William M 2534 E John Cabot Rd Phoenix AZ 85032 10/28/2010 11/16/2010 11/16/2010
310 Taylor Danylle N & Devlin 24842 Sertic Rd Veneta OR 97487 10/29/2010 11/16/2010 11/16/2010
311 Bellina Andrew C 4211 Harper St Perry OH 44081 10/29/2010 11/16/2010 11/16/2010
312 Haughton Lemuel L 331 NW 183 St Miami FL 33169 10/29/2010 11/16/2010 11/16/2010
313 Wein Jason C 139 Nashville Rd Bethel CT 06801 10/29/2010 11/16/2010 11/16/2010
314 Pridgen Vickie A 3320 Jason Dr Rocky Mount NC 27803 10/29/2010 11/16/2010 11/16/2010
315 Pikiell Allison 23 Shirley St Waterbury CT 06708 10/29/2010 11/16/2010 11/16/2010
316 Flynn Paul & Jane 24 Observatory Waye Marshfield MA 02050 10/27/2010 11/19/2010 11/19/2010
317 Sarkisyan Mikhail 10220 Via Hibiscus Apt 4 Boca Raton FL 33428 10/29/2010 11/16/2010 11/16/2010
318 Torres Danica 7205 SW 149th Ct Miami FL 33193 10/29/2010 11/19/2010 11/19/2010
319 Huff William W 781 W Main St Bellevue OH 44811 10/29/2010 11/16/2010 11/16/2010
320 Cruz Virginia C 4948 SW 195th Ter Miramar FL 33029 10/29/2010 na 11/16/2010
3 of 3
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-3
Filed
Filed
08/05/16
08/24/15
Page
Page
59 of
1 of
190
9
EXHIBIT 3
CHASE Fax Filed
972-dd3-5734 Feb Page
25 60
2009 of
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-3 Filed
08/05/16
08/24/15
Page 210:00am
of 9 P001/008
190
ft '
Guerrero/JPMCHASE
02125/2009 08:45 AM
cc
bee
Subject Re: ~
Thanks,
Eddie Gueffero, Recovery Supervisor I Raal Estate Recovery I 11' 602-627-8140 I Iii E-Fax: 6C2·580-1i 52i t8i
AZ1-2557
Victor B Fox/JPMCHASE
Victor B Fox/JPMCHASE
02/25/2009 07:40 AM
Here is the electronic version, What fax number do you want me to send the slgnec! c:opy t:.J? Vic
Victor B. Fox
Vice President
Real Estate Recovery i
Chase Home Finance
8333 Ridgepoint Drive
,/ , <.,. . _,_
Irving, TX 75063
Office • 972-443-2767
e-FAX-469-519-9527
;--
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document Fax
115-2
67-3972-dd3-57
FiledFiled3408/24/15
08/05/16 Feb
Page25 2009
Page61 of
3 of
1909 P002/008
10:00aa
between
and
February JS
company (the"
.;2~,
This Mortgage Loan Purchase Agreement (the "Agreement") is entered in,:.:: as of
by and among Chase Horne Finance: LLC, a Delaware hr:uteci liability
' ') and Mortgage Resolution Servicing, LLC, a H.t.J.~ _ limited
liability company having an office at 210 l NW Corporate Boulevard, Suite 320 . .Boca Raton, FL
33431 ("Purchaser").
Seller agrees to sel~ and Purchaser agrees to purchase, on the tenns and ~011ditions
described below, certain nonperforming andior impaired closed end first lien mon~age icaos that
axe or have been delinquent for 180 days or more and have been or may othervtise b~ :n default
(individually a "Mortgage Loan" and collectively the ''Mortgage Loans"), all as cescribed herein
Seller intends to and shall sell the .Mortgage Loans to Purchaser on a servi~:ng released
basis on the Closing Date.
Seller and Purchaser, in consideration of the prem1ses and the mutual ~gre~oents set forth
herein and other good and valuable consideration, agree as follows:
SECTION 2. Mortgage Loan Schedule. Seller and Purchaser hereby agree that :he
Mortgage Loans to be purchased under this Agreement are described in the schedule (tht
"Mortgage Loan Schedule") attached hereto as Exhibit A. The Mortgage Loan Sch~ciule shall set
forth for each Mortgage Loan the outstanding principal balance thereof as of the Cut-off Date (in
each case, the "Cut-off Date Principal Balance'l
Purchaser shall be entitled to all proceeds arising out of the Mortgage Lca~s ~eccived
after the Cut-off Date which are not included in the Post Cut-Off Payments. Pwcha~er shall have
no obligation to reimburse Seller for negative escrow balances or negative susper:;s~ balances and
shall be entitled to all positive escrow balances and po5itive suspense balances as ofthe Cut-Off
Date. Seller shall not offset the negative escrow balances against the positive esc:ov,s balances.
CHASE Fax Filed
972-d43-5734 Feb 25 2009
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-3 Filed
08/05/16
08/24/15
PagePage
63 of510:01am
of
1909 P004/008
Purchaser shall have no obligation to reimburse Seller for any expense, paid or ur.paid, b:lled or
not billed, incurred by Seller prior to the Cut-Off Date. Seller shall be liable for aU expenses,
costs, charges and advances incurred prior to the Cut-Off Date, including any attorneys' foes, real
estate tax.es and servicer advances. Purchaser shall be liable for all expenses, costs, charges and
advances incurred after the Cut-Off Date, including any attorney's fees and servicer ad,,ances.
SECTION 5. Closing. The closing of the purchase and sale of the Mortgage :.,oar,.s
identified on the Mortgage Loan Schedule shall take place on or before Februarv...25 2009, or
such other date as the parties may mutually agree (the "Closing Date'').
(i) The information set forth on the data tape provided by Seller to Pu:.·cr,aser vrith
respect to the Mortgage Loans is true and correct in all material respec·is as of the
date such data tape was compiled;
(ii) Seller is the sole owner of the Mortgage Loans and has full right tQ :ransfer and
sell the Mortgage Loans to Purchaser; and
(iii) Each Mortgage Loan complies in all material respects with all applicabie fuderal,
state, or local laws, including: without limitation, the Federal Trutl: in I.ending
Act of 1969, the Federal Equal Credit Opportunity Act, the Federal Real Estate
Settlement Procedures Act of 1974, and state and federal USU.")\ consumer credit
protection and privacy, predatory aod abusive lending laws app:icabk to the
Mortgage Loans.
(i) Purchaser's structure, capitalization, funding and all other matters Lncidentz.l to its
involvement in the transaction contemplated herein, including, without iimjtation,
the purchase of the Mortgage Loans, comply with all applicable sxuci:.les laws
and regulations;
CHASE Fax 972-d43-573d Feb 25 2009 10;01am
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-3Filed
Filed
08/05/16
08/24/15
PagePage64 of
6 of 9 POOS/008
190
(ii) Purchaser hereby covenants that it will, upon Seller's request, provide such legal
opinions as to such laws and regulations as Seller may request, Purchase will also
provide to Seller such additional information as Seller may requesr. bdudi:ig
information regarding Purchaser's relationships with its investing ~nc funding
sources for the transaction contemplated herein; and
(iii) Purcha~er will indemnify and hold Seller and its affiliates harmless fro!ll ar.d
against an)' and all losses, costs, expenses, damages, claims, and fees (including
attorney's fees and court costs) that may be incurred as the resuit of a breach or
alleged breach by Purchaser of such securities laws.
c. Except as otherwise expressly provided herein, each Mortgage Loan 1s oeing soid
by Seller with NO REPRESENTATIONS OR WARR.Al\'TIES of, by or on beha!f of Seiler and
on an "AS IS, \.VHERE IS. \\TITH ALL FAULTS" basis with NO RECOURSE WHATSOEVER
and, without in any way limiting the foregoing, WITH NO REPURCHASE ORB LY BACK
OBLIGATIONS WHATSOEVER.
SECTION 9. Confidentiality. Seller and Purchaser each hereby agree~ ~n ft:lly c,:,mply
with all applicable laws, niles and regulations governing the confidentiality of any information
acquired from or concerning the mortgagors.
SECTION 10. Brokers. Each party to th.is Agreement hereby represents and w;;.r.ra.."lts to
the other pany that it either (i) has not made any agreement to pay any agent, finder. broker or
any other person any fee or commission in the nature of a finders or originator's fee arising OU! of
or in connection with the transaction contemplated by this Agreement, or (i1) has made such an
agreement and will indemnify and hold the other party harmless from all claims and demands
made by any person under such agreement.
Case
Case1:14-cv-01047-RMC
CHASE
1:15-cv-00293-LTS-JCF
Document
Document Fax Filed
115-2
67-3972-443-5734
Filed
08/05/16 Feb 25
08/24/15
Page 2009
Page
65 of710:01am
of
1909 POOS/008
SECTION 11. Survival of Aneement. This Agreement includes prcvis:o!ls \~·hich the
parties hereto intead will remain in effect after the closing of the transaction com:cm~lated by this
Agreement. Accordingly, this Agreement shall surviYe and remain in effect afte: su~n closing.
S:ECTION 12. Notices. All demands: notices and communications unc.er ihis
Agreement shail be in writing and shall be deemed to have been duly given if maiieci by
registered or certified mail, return receipt requested, or by overnight delivery service, ad.dressed
to the appropriate party hereto at the address stated in the introduction to this Agreement in the
case of the Purchaser, Mortgage Resolution Servicing, LLC, 2101 ~ Corporate fsoulevard"
Suite 320>Boca Raton, FL 3.3431 and in the case of the Seller, to JPMorgan Chase Bank, N.A.,
194 Wood Avenue South, Iselin, NJ 08830, ·with a copy to JPMorgan Chase Ba.'lk. ~.A., 194
Wood Avenue South, Iselin, NJ 08830, attention, General Counsel. Any such deml:l.nd, notice or
communication shall be deemed to haYe been received on the date delivered to or ;:-e:;cived at the
premises of the addressee (as evidenced by the date noted on the return receipt C!' ov;::might
delivery receipt).
SECTION 13. Separability Clause. Any part, provision, representation \':- warranty of
this Agreement which is prohibited or wienfo1;ceable or is held to be void or unen.rorceable in any
jurisdiction shall: as to such jurisdiction, be ineffective to the extent of such prohibition or
unenforceability without invalidating the remajning provisions hereof, a..'1.d any .such prohibition
or unenforceability in any jurisdiction shall not invalidate or render unenforceable .St.ich provision
in any other jurisdiction. To the extent permitted by applicable law, the parties hereto waive any
provision of law which prohibits or renders void or unenforceable any provision hereof.
SECTION 14. Counterparts. For the purpose of facilitating the execution of this
Agreement, and for other purposes, this Agreement may be executed simultanecusiy i;:i any
number of counterparts. Each counterpart shall be deemed to be an original, and aH such
counterparts shall constitute one and the same instrument.
SECTION 15. Place ofDeliverv and GoverniJJ.g Law. This Agreement s},all be
deemed to have been rnade in the State of New York. The Agreement shall be construed in
accordance witb. the laws of the State of New York and the obligations, ri~11ts and re~ed:es of
the parties hereunder shall be determined in accordance with the laws ofthe State of :-J'ew York,
excluding conflict of laws issues. The parties hereby agree that all disputes a:ising hereunder
shall be submitted to and hereby subject themselves to thejurisdjction of the courts o-r' competent
jurisdiction, state and federal, in the State of New York.
SECTION 16. Succcsso.-s and Assigns; Assignment. This Agreement ~hd i bind and
inure to the benefit of and be enforceable by Seller and Purchaser, and their respective permitted
successors and assigns. This Agreement shall not be assigned, pledged or bypothccated by
Purchaser or Seller without the prior written consent of the other party to this Agre~xn~nt.
Case
Case1:14-cv-01047-RMC CHASE
1:15-cv-00293-LTS-JCF
Document
Document Fax 972-d43-57
115-2
67-3Filed
Filed 3408/24/15
08/05/16 Feb 25
Page 2009
Page66 of of 9 P007/008
810:01a1
190
be
SECTlO ='f 17. Amendments. Neither this Agreement nor any provisio n n~reofmay
changed, waived, discharged or terminat ed orally, but only by a wntten instrume nt signed by
both Seller and Purchaser.
SECTION 18. Interpretation. For all purpose s of this Agreem ent, initia;I) cap:talized
terms used herem have the meaning s ascribed hereto in the Agreem ent. Except as expre3si
y
otherwise provided herein or unless the context otherwis e requires, for pu..TJ)Oses of this
Agreement the words "herein," "hereto, " ''hereof' and "hereunder" and other words of si□iiar
effect shall refer to this Agreement as a whole and not to any particular provision.
JN WITNESS WHEREOFt Seller and Purchaser have caused their names ~o cc signed
hereto by their respective authoriz ed officers as of the date first above w:ritten.
SELLER:
CHASE HOME FINANCE, LLC
PURCH ASER :
MORTGAGE RESOLUTION SERVICING, LLC
Case
Case1:14-cv-01047-RMC CHASE
1:15-cv-00293-LTS-JCF
Document
Document Fax 972-d43-5734
115-2
67-3Filed
Filed
08/05/16 Feb 25
08/24/15
Page 2009
Page 910;01am
67 of of
1909 POOB/008
~iXHIBIT A
A-1
Case 1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-4Filed
Filed
08/05/16
08/24/15Page
Page
681ofof190
41
EXHIBIT 4
Case 1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-4Filed
Filed
08/05/16
08/24/15Page
Page
692ofof190
41
CHASE O
We are writing to let you know that we are cancelling the amount owed to Chase on the loan referenced
below, totaling $23,237.48, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means nothing more is owed on the loan and the debt will be cancelled. Nothing needs
to be signed or returned for this to happen.
• Report the cancellation of the debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on the property if this was part of the mortgage.
The escrow account as well as any optional insurance product will close.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
• Pay any taxes and/or insurance premiums associated with the property.
• Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
they will forward future bills and correspondence directly to your address.
Sincerely,
Your account number:
Patrick Boyle
Vice President
Please see important disclosures on the next page.
this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's
name, address and telephone number.
lo the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. · 713 1-DOJ-RtC-RF}33 BK
Case 1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-4Filed
Filed
08/05/16
08/24/15Page
Page
714ofof190
41
CHASE O
CHASE O
We are writing to let you know that we are cancelling the amount owed to Chase on the loan referenced
below, totaling $15,069.11, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means nothing more is owed on the loan and the debt will be cancelled. Nothing needs
to be signed or returned for this to happen.
Sincerely,
Your account number:
100500439800892659
Patrick Boyle
Vice President
Please see important disclosures on the next page.
Keep this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney’s
name, address and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
CHASE O
17131-DOJ-REC-RR738 FAQ
CHASE O
We are writing to let you know that we are cancelling the amount owed to Chase on the loan referenced
below, totaling $17,482.63, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means nothing more is owed on the loan and the debt will be cancelled. Nothing needs
to be signed or returned for this to happen.
• Report the cancellation of the debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on the property if this was part of the mortgage.
The escrow account as well as any optional insurance product will close.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
• Pay any taxes and/or insurance premiums associated with the property.
• Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
they will forward future bills and correspondence directly to your address.
Sincerely,
Your account number:
Patrick Boyle
Vice President
Please see important disclosures on the next page.
this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's
name, address and telephone number.
lo the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. · 713 1-DOJ-RtC-RF}33 BK
Case
Case1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-4Filed
Filed
08/05/16
08/24/15Page
Page7912
ofof
19041
CHASE O
CHASE O
We are writing to let you know that we are cancelling the amount owed to Chase on the loan referenced
below, totaling $99,016.03, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means nothing more is owed on the loan and the debt will be cancelled. Nothing needs
to be signed or returned for this to happen.
• Report the cancellation of the debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on the property if this was part of the mortgage.
The escrow account as well as any optional insurance product will close.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
• Pay any taxes and/or insurance premiums associated with the property.
• Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
they will forward future bills and correspondence directly to your address.
Sincerely,
Your account number:
Patrick Boyle
Vice President
Please see important disclosures on the next page.
this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's
name, address and telephone number.
lo the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. · 713 1-DOJ-RtC-RF}33 BK
Case
Case1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-4Filed
Filed
08/05/16
08/24/15Page
Page8316
ofof
19041
CHASE O
CHASE O
We are writing to let you know that we are cancelling the amount you owe Chase on the loan referenced
below, totaling $88,434.21, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means you will owe nothing more on the loan and your debt will be cancelled. You don’t
need to sign or return anything for this to happen.
Sincerely,
Your account number:
100900426370399018
Patrick Boyle
Vice President
Please see important disclosures on the next page.
Keep this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney’s
name, address and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
(§)
EOUAlltOUSING
LENDER 2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131-DOJ-REC-RR736
Case
Case1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-4Filed
Filed
08/05/16
08/24/15Page
Page8720
ofof
19041
CHASE O
17131-DOJ-REC-RR736 FAQ
CHASE O
We are writing to let you know that we are cancelling the amount owed to Chase on the loan referenced
below, totaling $5,642.62, as a result of a recent mortgage servicing settlement reached with the states
and federal government.
This means nothing more is owed on the loan and the debt will be cancelled. Nothing needs
to be signed or returned for this to happen.
Sincerely,
Your account number:
100900426380031490
Patrick Boyle
Vice President
Please see important disclosures on the next page.
Keep this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney’s
name, address and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
CHASE O
17131-DOJ-REC-RR738 FAQ
CHASE O
We are writing to let you know that we are cancelling the amount you owe Chase on the loan referenced
below, totaling $15,226.58, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means you will owe nothing more on the loan and your debt will be cancelled. You don’t
need to sign or return anything for this to happen.
Sincerely,
Your account number:
100001414011078913
Patrick Boyle
Vice President
Please see important disclosures on the next page.
Keep this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney’s
name, address and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
(§)
EOUAlltOUSING
LENDER 2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131-DOJ-REC-RR736
Case
Case1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-4Filed
Filed
08/05/16
08/24/15Page
Page9528
ofof
19041
CHASE O
17131-DOJ-REC-RR736 FAQ
CHASE O
We are writing to let you know that we are cancelling the amount owed to Chase on the loan referenced
below, totaling $38,265.85, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means nothing more is owed on the loan and the debt will be cancelled. Nothing needs
to be signed or returned for this to happen.
Sincerely,
Your account number:
100500430521175187
Patrick Boyle
Vice President
Please see important disclosures on the next page.
Keep this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney’s
name, address and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
CHASE O
17131-DOJ-REC-RR738 FAQ
CHASE O
We are writing to let you know that we are cancelling the amount owed to Chase on the loan referenced
below, totaling $14,144.01, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means nothing more is owed on the loan and the debt will be cancelled. Nothing needs
to be signed or returned for this to happen.
Sincerely,
Your account number:
100500439900055099
Patrick Boyle
Vice President
Please see important disclosures on the next page.
Keep this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney’s
name, address and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
CHASE O
17131-DOJ-REC-RR738 FAQ
CHASE O
We are writing to let you know that we are cancelling the amount owed to Chase on the loan referenced
below, totaling $22,435.90, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means nothing more is owed on the loan and the debt will be cancelled. Nothing needs
to be signed or returned for this to happen.
Sincerely,
Your account number:
100900426360246451
Patrick Boyle
Vice President
Please see important disclosures on the next page.
Keep this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney’s
name, address and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
CHASE O
17131-DOJ-REC-RR738 FAQ
EXHIBIT 5
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-5
Filed
Filed
08/05/16
08/24/15
Page
Page
1102of
of190
49
CHASE O
We are writing to let you know that we are cancelling the amount you owe Chase on the loan referenced
below, totaling $53, 107.82, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means you will owe nothing more on the loan and your debt will be cancelled. You don't
need to sign or return anything for this to happen.
• Report the cancellation of your debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on your behalf if this was part of your mortgage.
Your escrow account as well as any optional insurance product will close.
• Refund any remaining escrow balances on the account you are entitled to.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
• Contact your insurance company and/or taxing authority to make arrangements for paying any
remaining or new amounts due.
• Pay any taxes and/or insurance premiums associated with the property.
• Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
they will forward future bills and correspondence directly to your address.
Sincerely,
Your account number:
Patrick Boyle
Vice President
Please see important disclosures on the next page.
this letter with your other mortgage documents for your records.
If you are represented by an attomey, please refer this letter to your attomey and provide us with the attorney's
name, address and telephone number.
lo the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131-DO,J-REC-RR736
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-5
Filed
Filed
08/05/16
08/24/15
Page
Page
1124of
of190
49
CHASE O
17131-DOJ-REC-RR736 FAQ
CHASE O
We are writing to let you know that we are cancelling the amount owed to Chase on the loan referenced
below, totaling $21,507.66, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means nothing more is owed on the loan and the debt will be cancelled. Nothing needs
to be signed or returned for this to happen.
• Report the cancellation of the debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on the property if this was part of the mortgage.
The escrow account as well as any optional insurance product will close.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
• Pay any taxes and/or insurance premiums associated with the property.
• Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
they will forward future bills and correspondence directly to your address.
Sincerely,
Your account number:
?~<:)~ 100001410011576330
Patrick Boyle
Vice President
Please see important disclosures on the next page.
this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's
name, address and telephone number.
lo the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. · 713 1-DOJ-RtC-RF}33 BK
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-5
Filed
Filed
08/05/16
08/24/15
Page
Page
1168of
of190
49
CHASE O
CHASE O
We are writing to let you know that we are cancelling the amount you owe Chase on the loan referenced
below, totaling $91,562.75, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means you will owe nothing more on the loan and your debt will be cancelled. You don't
need to sign or return anything for this to happen.
• Report the cancellation of your debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on your behalf if this was part of your mortgage.
Your escrow account as well as any optional insurance product will close.
• Refund any remaining escrow balances on the account you are entitled to.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
• Contact your insurance company and/or taxing authority to make arrangements for paying any
remaining or new amounts due.
• Pay any taxes and/or insurance premiums associated with the property.
• Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
they will forward future bills and correspondence directly to your address.
Sincerely,
Your account number:
?~<:)~ 100001415010307608
Patrick Boyle
Vice President
Please see important disclosures on the next page.
this letter with your other mortgage documents for your records.
If you are represented by an attomey, please refer this letter to your attomey and provide us with the attorney's
name, address and telephone number.
lo the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131-DO,J-REC-RR736
Case 1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-5Filed
Filed
08/05/16
08/24/15Page
Page
120
12ofof190
49
CHASE O
17131-DOJ-REC-RR736 FAQ
CHASE O
We are writing to let you know that we are cancelling the amount you owe Chase on the loan referenced
below, totaling $42,543.97, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means you will owe nothing more on the loan and your debt will be cancelled. You don't
need to sign or return anything for this to happen.
• Report the cancellation of your debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on your behalf if this was part of your mortgage.
Your escrow account as well as any optional insurance product will close.
• Refund any remaining escrow balances on the account you are entitled to.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
• Contact your insurance company and/or taxing authority to make arrangements for paying any
remaining or new amounts due.
• Pay any taxes and/or insurance premiums associated with the property.
• Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
they will forward future bills and correspondence directly to your address.
Sincerely,
Your account number:
?~<:)~ 100001416620120938
Patrick Boyle
Vice President
Please see important disclosures on the next page.
this letter with your other mortgage documents for your records.
If you are represented by an attomey, please refer this letter to your attomey and provide us with the attorney's
name, address and telephone number.
lo the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131-DO,J-REC-RR736
Case 1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-5Filed
Filed
08/05/16
08/24/15Page
Page
124
16ofof190
49
CHASE O
17131-DOJ-REC-RR736 FAQ
CHASE O
We are writing to let you know that we are cancelling the amount you owe Chase on the loan referenced
below, totaling $104,249.27, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means you will owe nothing more on the loan and your debt will be cancelled. You don't
need to sign or return anything for this to happen.
• Report the cancellation of your debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on your behalf if this was part of your mortgage.
Your escrow account as well as any optional insurance product will close.
• Refund any remaining escrow balances on the account you are entitled to.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
• Contact your insurance company and/or taxing authority to make arrangements for paying any
remaining or new amounts due.
• Pay any taxes and/or insurance premiums associated with the property.
• Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
they will forward future bills and correspondence directly to your address.
Sincerely,
Your account number:
?~<:)~ 100002449219758811
Patrick Boyle
Vice President
Please see important disclosures on the next page.
this letter with your other mortgage documents for your records.
If you are represented by an attomey, please refer this letter to your attomey and provide us with the attorney's
name, address and telephone number.
lo the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131-DO,J-REC-RR736
Case 1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-5Filed
Filed
08/05/16
08/24/15Page
Page
128
20ofof190
49
CHASE O
17131-DOJ-REC-RR736 FAQ
CHASE O
We are writing to let you know that we are cancelling the amount you owe Chase on the loan referenced
below, totaling $200,089.85, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means you will owe nothing more on the loan and your debt will be cancelled. You don’t
need to sign or return anything for this to happen.
Sincerely,
Your account number:
100900426370383518
Patrick Boyle
Vice President
Please see important disclosures on the next page.
Keep this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney’s
name, address and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
(§)
EOUAlltOUSING
LENDER 2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131-DOJ-REC-RR736
Case 1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-5Filed
Filed
08/05/16
08/24/15Page
Page
132
24ofof190
49
CHASE O
17131-DOJ-REC-RR736 FAQ
CHASE O
We are writing to let you know that we are cancelling the amount you owe Chase on the loan referenced
below, totaling $23,554.43, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means you will owe nothing more on the loan and your debt will be cancelled. You don't
need to sign or return anything for this to happen.
• Report the cancellation of your debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on your behalf if this was part of your mortgage.
Your escrow account as well as any optional insurance product will close.
• Refund any remaining escrow balances on the account you are entitled to.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
• Contact your insurance company and/or taxing authority to make arrangements for paying any
remaining or new amounts due.
• Pay any taxes and/or insurance premiums associated with the property.
• Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
they will forward future bills and correspondence directly to your address.
Sincerely,
Your account number:
?~<:)~ 100900426430034553
Patrick Boyle
Vice President
Please see important disclosures on the next page.
this letter with your other mortgage documents for your records.
If you are represented by an attomey, please refer this letter to your attomey and provide us with the attorney's
name, address and telephone number.
lo the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131-DO,J-REC-RR736
Case 1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-5Filed
Filed
08/05/16
08/24/15Page
Page
136
28ofof190
49
CHASE O
CHASE O
We are writing to let you know that we are cancelling the amount you owe Chase on the loan referenced
below, totaling $167,003.51, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means you will owe nothing more on the loan and your debt will be cancelled. You don't
need to sign or return anything for this to happen.
• Report the cancellation of your debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on your behalf if this was part of your mortgage.
Your escrow account as well as any optional insurance product will close.
• Refund any remaining escrow balances on the account you are entitled to.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
• Contact your insurance company and/or taxing authority to make arrangements for paying any
remaining or new amounts due.
• Pay any taxes and/or insurance premiums associated with the property.
• Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
they will forward future bills and correspondence directly to your address.
Sincerely,
Your account number:
?~<:)~ 100900426430036548
Patrick Boyle
Vice President
Please see important disclosures on the next page.
this letter with your other mortgage documents for your records.
If you are represented by an attomey, please refer this letter to your attomey and provide us with the attorney's
name, address and telephone number.
lo the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131-DO,J-REC-RR736
Case 1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-5Filed
Filed
08/05/16
08/24/15Page
Page
140
32ofof190
49
CHASE O
CHASE O
We are writing to let you know that we are cancelling the amount owed to Chase on the loan referenced
below, totaling $28,209.15, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means nothing more is owed on the loan and the debt will be cancelled. Nothing needs
to be signed or returned for this to happen.
Sincerely,
Your account number:
100900427011269656
Patrick Boyle
Vice President
Please see important disclosures on the next page.
Keep this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney’s
name, address and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
CHASE O
17131-DOJ-REC-RR738 FAQ
CHASE O
We are writing to let you know that we are cancelling the amount owed to Chase on the loan referenced
below, totaling $46,657.96, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means nothing more is owed on the loan and the debt will be cancelled. Nothing needs
to be signed or returned for this to happen.
• Report the cancellation of the debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on the property if this was part of the mortgage.
The escrow account as well as any optional insurance product will close.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
• Pay any taxes and/or insurance premiums associated with the property.
• Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
they will forward future bills and correspondence directly to your address.
Sincerely,
Your account number:
Patrick Boyle
Vice President
Please see important disclosures on the next page.
this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's
name, address and telephone number.
lo the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. · 713 1-DOJ-RtC-RF}33 BK
Case 1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-5Filed
Filed
08/05/16
08/24/15Page
Page
148
40ofof190
49
CHASE O
CHASE O
We are writing to let you know that we are cancelling the amount you owe Chase on the loan referenced
below, totaling $63,430.82, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means you will owe nothing more on the loan and your debt will be cancelled. You don't
need to sign or return anything for this to happen.
• Report the cancellation of your debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on your behalf if this was part of your mortgage.
Your escrow account as well as any optional insurance product will close.
• Refund any remaining escrow balances on the account you are entitled to.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
• Contact your insurance company and/or taxing authority to make arrangements for paying any
remaining or new amounts due.
• Pay any taxes and/or insurance premiums associated with the property.
• Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
they will forward future bills and correspondence directly to your address.
Sincerely,
Your account number:
?~<:)~ 100950429200046714
Patrick Boyle
Vice President
Please see important disclosures on the next page.
this letter with your other mortgage documents for your records.
If you are represented by an attomey, please refer this letter to your attomey and provide us with the attorney's
name, address and telephone number.
lo the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131-DO,J-REC-RR736
Case 1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-5Filed
Filed
08/05/16
08/24/15Page
Page
152
44ofof190
49
CHASE O
17131-DOJ-REC-RR736 FAQ
CHASE O
We are writing to let you know that we are cancelling the amount you owe Chase on the loan referenced
below, totaling $60,960.25, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means you will owe nothing more on the loan and your debt will be cancelled. You don't
need to sign or return anything for this to happen.
• Report the cancellation of your debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on your behalf if this was part of your mortgage.
Your escrow account as well as any optional insurance product will close.
• Refund any remaining escrow balances on the account you are entitled to.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
• Contact your insurance company and/or taxing authority to make arrangements for paying any
remaining or new amounts due.
• Pay any taxes and/or insurance premiums associated with the property.
• Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
they will forward future bills and correspondence directly to your address.
Sincerely,
Your account number:
?~<:)~ 100950429200061358
Patrick Boyle
Vice President
Please see important disclosures on the next page.
this letter with your other mortgage documents for your records.
If you are represented by an attomey, please refer this letter to your attomey and provide us with the attorney's
name, address and telephone number.
lo the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131-DO,J-REC-RR736
Case 1:15-cv-00293-LTS-JCF
1:14-cv-01047-RMC Document
Document
115-2
67-5Filed
Filed
08/05/16
08/24/15Page
Page
156
48ofof190
49
CHASE O
17131-DOJ-REC-RR736 FAQ
EXHIBIT 6
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-267-6
FiledFiled
08/05/16
08/24/15
Page
Page
1592ofof190
5
CHASEO
Chase {AZ1-2557)
1820 E Sky Harbor Circle S, Floor 2
Phoenix, AZ, 85034-4850, United States
December 5, 2012
As part of the recent mortgage servicing settlement reached with the states and federal government,
JPMorgan Chase Bank, N.A. (Chase) elected to participate in a second lien extinguishment program.
Because of this, we sent letters to certain customers notifying them that we were extinguishing their debt
with Chase and releasing the associated lien. However, we subsequently found that several of your
customers received this letter In error because of an incorrect coding entry. These customers and their
respective loans were Identified and are appended to this letter and referenced as "Exhibit A " We
apologize for any inconvenience this may have caused.
To correct this error , please choose one of the following three options:
1) Chase will repurchase any of the subject loans at a premium of 50% of your original purchase
price for such loan. If we repurchase the loans, we will update these customers' accounts to
show a zero balance and release their liens. The payment cutoff date for these transactions will
be 12/6/2012
There are no performance restrictions-you will receive compensation for any loans for which you
elect this option, regardless of whether they are performing or not.
2) Chase will send a retraction letter to the customer on any of the subject loans, including specific
information about your ownership of the loan.
You must respond to this remediation offer by December 10. If we do not hear from you by
December 10, we will send retraction letters to all customers notifying them of the error. If you elect for
Chase to repurchase any loans, the loans are required to be assigned back to Chase within 15 calendar
days.
Again, we apologize for this error. If you have questions, please call me at the telephone numbers listed
below.
Sincerely,
@
l'l'Nffl ©2012 JPMorgan Chase & Co. JPMorgan Chase Bank. NA LC-INVST
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-267-6
FiledFiled
08/05/16
08/24/15
Page
Page
1603ofof190
5
Exhibit A.
Instructions: Please review the following table and confirm your selection between option A and
option B. Confirm your selection by marking an X in the columns referenced . Once you have
confirmed your selection, please fax this page to 602-396-5003 by Monday, December 10.
@
lf'Nffl ©2012 JPMorgan Chase & Co . JPMorgan Chase Bank, NA LC-INVST
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-267-6
FiledFiled
08/05/16
08/24/15
Page
Page
1614ofof190
5
CHASE
Chase (AZ1-2557)
1820 E Sky Harbor Circle S, Floor 2
Phoenix, AZ., 85034-4850, United States
December 5, 2012
As part of the recent mortgage servicing settlement reached with the states and federal government,
JPMorgan Chase Bank, N.A. (Chase) elected to participate in a second lien extinguishment program.
Because of this, we sent letters to certain customers notifying them that we were extinguishing their debt
with Chase and releasing the associated lien. However, we subsequently found that several of your
customers received this letter in error because of an incorrect coding entry. These customers and their
respective loans were identified and are appended to this letter and referenced as ''Exhibit A." We
apologize for any inconvenience this may have caused.
To correct tt,is error, please choose one of the following three options:
1) Chase will repurchase any of the subject loans at a premium of 50% of your original purchase
price for such loan. If we repurchase the loans, we will update these customers' accounts to
show a zero balance and release their liens. The payment cutoff date for these transactions will
be 12/6/2012
There are no performance restrictions-you will receive compensation for any loans for which you
elect this option, regardless of whether they are performing or not.
2) Chase will send a retraction letter to the customer on any of the subject loans, including specific
information about your ownership of the loan.
You must respond to this remediation offer by December 10. If we do not hear from you by
December 10, we will send retraction letters to all customers notifying them of the error. If you elect for
Chase to repurchase any loans, the loans are required to be assigned back to Chase within 15 calendar
days,
Again, we apologize for this error. If you have questions, please call me at the telephone numbers listed
below.
Sincerely,
Omar Kassem, CF A
Vice President / Portfolio Manager
602-627-8661
~ ©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A LC-INVST
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-267-6
FiledFiled
08/05/16
08/24/15
Page
Page
1625ofof190
5
Exhibit A.
Instructions: Please review the following table and confirm your selection between option A and
option B. Confirm your selection by marking an X in the columns referenced. Once you have
confirmed your selection, please fax this page to 602-396-5003 by Monday, December 10.
EXHIBIT 7
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-267-7
FiledFiled
08/05/16
08/24/15
Page
Page
1642ofof190
2
CHA SEO
don't
This means you will owe nothing more on the loan and your debt will be cancelled. You
need to sign or return anything for this to happen.
• Report the cancellation of your debt to various credit bureau reporting agencies.
We do not know what, if any, effect this will have on your credit score.
• Release the lien held by Chase and forward the release to your county records office
for processing. Depending on your county's procedures, this may take several months.
• No longer pay property taxes or insurance on your behalf if this was part of your mortgage.
Your escrow account as well as any optional insurance product will close.
• Refund any remaining escrow balances on the account you are entitled to.
• No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant
• Pay any taxes and/or insurance premiums associated with the property.
so
• Provide your address to your homeowners' insurance agent, as well as your taxing authority,
they will forward future bills and correspond ence directly to your address.
Sincerely,
Your account number:
10090042 64300365 48
?~?(:_
Patrick Boyle
Vice President Please see important disclosures on the next page.
EXHIBIT 8
. '~ [jJ"y:t R
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
G AND REGULATION
FiledFiled
OFFICE
08/05/16
08/24/15
Page
Page
1662ofof190
6
OF THEC6MMISSIONER OF ftNA
NClAL REGULATION
500 N. Calvert Street, Suite 402
Baltimore, MD 2 ! 202-3651
Mark Kaufman, Com mis sio ner
---------------------
E-mail: [email protected]
Subject: Robert and Lau rie Warwi
ck
Complaint# M 13 1150
Laurie Warwick
443 336- 4733 cell
410 695- 2977 hom e
2
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-267-8
FiledFiled
08/05/16
08/24/15
Page
Page
1684ofof190
6
Larry Schneider
From: [email protected]
Sent: Monday, January 07, 2013 3:38 PM
To: [email protected]
· Subject: Robert Warwick - 100900426430035543
Importance: High
Dear Ms Tonkins,
Per our conversation earlier today, I am forwarding the original email that I sent to Chase on September 14th, 2012
which was literally several minutes after we received a copy of the "Debt Cancellation Letter". As you can see by the
date of the email below, we immediately addressed the issue with Chase. We have spent hundreds of hours and have
sent over one hundred pieces of correspondence to Chase trying to resolve this and other similar situations with them
regarding erroneous debt cancellation letters. As I mentioned, I am unable to discuss the particul9r details of any
. related situation with other borrowers' loans which we acquired from J.P. Morgan Chase but I assure you that we are
unaware of any similar problems with loans which are owned by 1 st Fidelity Loan and serviced through BSI Servicing.
At the moment, we still do not have a copy of the "Retraction Letter" that was supposed to be sent out to the
· borrower. In response to your compliance inquiry, I've attached the contact information for representatives at Chase
that should be able to provide you with answers to you inquiry.
· Once again, we truly understand the anger and anguish expressed by the Warwick's due to Chase's erroneous debt
cancellation letter and that they have not acted promptly to remedy the situation. I hope that you can bring this
situation to an expedited and beneficial resolution.
• Patrick M Boyle
Vice-President, Loss Mitigation and Recovery
1820 E. Sky Harbor Circle S
Phoenix, AZ 85034
Mail Code AZl-2514
PH: 602-627-2489
[email protected]
• Mark Davis
1
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-267-8
FiledFiled
08/05/16
08/24/15
Page
Page
1695ofof190
6
• Gary Miller
Senior Vice-President. Default Servicing and Housing
• Steven Hemperly
Senior Vice- President, Default Operations Management
Please let me know 1f I can be of any additional assistance in this matter and advise me of the outcome of your
investigation.
Sincerely,
Larry Schneider
1st Fidelity Loan Servicing
S & A Capital Partners
2901 Clintmoore Road, Suite 410
Boca Raton, FL 33496
. Tel: 561-893-9805 x 204
. Fax: 561-893-9808
Cel: 305-710-4201
sacapitalpartners.com
Hi Omar,
I hope you had a good trip to Vegas. I'm sure your busy with lots or important things but I think we may have another
nd
potential problem on our hands. This is the 2 paying borrower who has received this letter from Chase "Cancelling
Her Debt", signed by Patrick Boyle. She said she is getting an attorney and is no longer going to be sending payments. I
don't necessarily need you to intervene on this particular borrower but I need ~o know if this can potentially affect
hundreds of my borrowers. Was this DOJ scrubbed before being sent out?
If not, I need to know immediately so I can preemptively attempt to remedy the situation for all affected borrowers so
the problem does not become a major legal issue between our entities, Chase and the Department of Justice. As you
know, I've always handled any issues regarding challenging situations that arise in the best interest of Chase and will
continue to do so. However, I do need to know that Chase will handle these as buyback/trade out situations if the
borrowers are adamant about not paying their contractual obligation to us; Please let me know how you would like me
to handle the situation regarding these letters?
2
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-267-8
FiledFiled
08/05/16
08/24/15
Page
Page
1706ofof190
6
,Sincerely,
Larry Schneider
1st Fidelity Loan Servicing
2101 NW Corporate Blvd., Suite 102
Boca Raton, FL 33431
Tel: 561-893-9805 x 204
Fax: 561-893-9808
This email message has been delivered safely and archived online. This email system is managed by DynamiCare E2.
Powered by Mimecast
3
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-9
Filed
Filed
08/05/16
08/24/15
Page
Page
1711of
of190
10
EXHIBIT 9
.. .... .. · ··-··----··-· · ·---- - - - - - - - - - - - - - - - - - - - - - - -
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-9
Filed
Filed
08/05/16
08/24/15
Page
Page
1722of
of190
10
SALEH AHMED,
BEYERLY AHMED,
JOHN DOE, AS OCCUPANT OF THE Case No. CJ-2012-1367
PREMISES,
JANE DOE, AS OCCUPANT OF THE
PREMISES,
JPMORGAN CHASE BANK NA,
CAPITAL ONE BANK (USA) NA,
CAPITAL ONE AUTO FINANCE INC,
OKLAHOMA STATE OF EX REL
OKLAHOMA TAX COMMISSION
Defendants.
COMES NOW, Defendant SALEH AHMED, and Answers the Plaintiffs Petition
as follows:
3. Defendant admits facts of paragraph 3 and clarifies that the Payee was
7. Defendant admits facts of paragraph 7, and adds the claim that the loan is
16. Defendant does not have sufficient information to admit or deny the facts
in paragraph 16.
20. Any items not specifically admitted are presumed to be not admitted.
21. Defendant, Saleh Ahmed, asserts that Defendant, JPMorgan Chase Bank,
NA, forgave and canceled the loan referenced in Plaintiffs petition, and that Defendants
Saleh Ahmed, and Beverly Ahmed, were no longer obligated to perform on the loan.
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-9
Filed
Filed
08/05/16
08/24/15
Page
Page
1744of
of190
10
22. JPMorgan Chase Bank ·also stated that there were no further actions
required on the behalf of Defendants, Saleh Ahmed and Beverly Ahmed, to allow for the
complete cancelation of the loan, and that the cancelation was due to a mortgage
23. The account number appears to correspond with the loan number on the
letter from JPMorgan Chase Bank and the number stated on the documents attached to
Plaintiffs Petition.
24. Defendant Saleh Ahmed relied to his detriment on the letter from
JPMorgan Chase Bank canceling the loan, and did not continue to pay or cure the loan to
DEFENSES:
Defendant Saleh Ahmed asserts that the loan was included in the settlement
agreement that Defendant JPMorgan Chase Bank had with the states and federal
government, and that the loan was canceled as to Defendants Saleh Ahmed and Beverly
Ahmed. In the alternative, Defendant, Saleh Ahmed, asserts that the loan was sold to
Plaintiff at a time when JPMorgan Chase bank knew or should have known that the loan
may qualify under the settlement agreement and by equity should be required to honor
the cancelation of the debt as to Defendants Saleh Ahmed and Beverly Ahmed.
the Defendants named on the cancelation letter from JPMorgan Chase Bank, and in rem
as to the property, and for Judgment against Plaintiff for their costs and fees incurred
herein.
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-9
Filed
Filed
08/05/16
08/24/15
Page
Page
1755of
of190
10
CERTIFICATE OF MAILING
I hereby certify that on this ~ day of J..,_~ , 2014, a true and com:ct copy of
the foregoing Answer to Plaintiffs Petition and Oss Claim was mailed to:
James H. Thiesen
Baer, Timberlake, Coulson & Cates, P.C.
P.O. Box 18486
Oklahoma City, OK 73154-0486
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-9
Filed
Filed
08/05/16
08/24/15
Page
Page
1766of
of190
10
SALEH AHMED,
BEYERLY AHMED,
JOHN DOE, AS OCCUPANT OF THE Case No. CJ-2012-1367
PREMISES,
JANE DOE, AS OCCUPANT OF THE
PREMISES,
JPMORGAN CHASE BANK NA,
CAPITAL ONE BANK (USA) NA,
CAPITAL ONE AUTO FINANCE INC,
OKLAHOMA STATE OF EX REL
OKLAHOMA TAX COMMISSION
Defendants.
COMES NOW, Terrell Monks, and hereby enters his limited entry of appearance
as counsel of record, for SALEH AHMED, Defendant in the above-styled and numbered
action with representation limited to drafting and filing an answer to Plaintiffs Petition,
CERTIFICATE OF MAILING
James H. Thiessen
Baer, Timberlake, Coulson & Cates, P.C.
P.O. Box 18486
Oklahoma City, OK 73154-0486
[email protected]
_...-~
~':'£·• ' .
_J,,AW_OEElCES.OI . . __.,.,,
_ _....,T-=E~J~.RELL MONKS
---
_.,,.,
---
184u S. Doug!as Blvd .. Midwest City, OK 73130
-·
James H. Thiessen
Baer, Timberlake, Coulson & Cates, P.C. <\\A.
P.O. Box 18486 \_\) 1.,\> ·
Oklahoma City, OK 73154-~ ,11\~
EXHIBIT 10
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-10
FiledFiled
08/05/16
08/24/15
PagePage
182 of
2 of
190
5
CHASE O
We are writing to let you know that we are cancelling the amount owed to Chase on the loan referenced
below, totaling $28,209.15, as a result of a recent mortgage servicing settlement reached with the
states and federal government.
This means nothing more is owed on the loan and the debt will be cancelled. Nothing needs
to be signed or returned for this to happen.
Sincerely,
Your account number:
100900427011269656
Patrick Boyle
Vice President
Please see important disclosures on the next page.
Keep this letter with your other mortgage documents for your records.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney’s
name, address and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under
Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does
not constitute an attempt to collect a debt or to impose personal liability for such obligation.
CHASE O
EXHIBIT 11
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-11
FiledFiled
08/05/16
08/24/15 03/15/
PagePage
1872010
of 03:14
2 of 3 PH
190
I~t t# 2010- {5623 # 1
Boo k: 645 5
RECOR DATIO N REQU ESTED BY: Pag e: !:>32
S & A Capita l Partne rs, Inc.
ASSIGNMENT of MORTGAGE
For value receiv ed, the receip t and suffici ency of which are
hereby acknow ledged . JPMORGAN CHASE BANK, N.A.,
hereby grants, assign s and transfers to S & A CAPITAL
PARTNERS, INC., all benefi cial interes t under that certain
Mortg age for $69,390.00 dated Octob er 20, 2007, and
execut ed by PATRICIA B KING, A SINGLE WOMAN,
Granto rs, to CHASE BANK USA, N.A. and record ed
as Docum ent No. 2007-2 46690 , in Book xx, Page xx,
Novem ber 1, 2007, of Officia l Record s in the Count y Record on
er's office of Volusia, State of Florida, as describ ed in
said Mortg age and more comm only known as 5092 Dunde
e Ave, De Leon Springs, FL 32130.
LEGAL DESCR IPTION : SEE ATTACHED LEGAL DESCR
IPTION AS EXHIB IT "A"
JPMOR GAN CHASE BANK, NA. sells to Assignee
all of Assignor's right. title and interest in the Mortgage Loan,
Trust/Mortgage and Note in ".As 11( condition, with all faults, Deed of
without any recourse to Assignor whatsoever and without any
wmTanty expressed or implied, character or nature. JPMOR
GAN CHASE BANK, N.A .. further makes no represe
warranties regarding the Mortgage loan, Note or Deed of Trust/M ntations or
ortgage. Assignee confirms that it has taken such steps as it
deems appropriate with respect to conducting due diligence with
respect to the status and quality of the Mottgage Loan. Note
and Deed of Trust/Mortgage.
~~ o'
PIJ.. Il.a before me, the undersigned Notary Public in and for said County
Lf:tl1J (_~ \,pe rson ally and State, person ally appeared,
known to me (or proved to me on the basis of satisfactory eviden
whose name(s) is subscribed to the within instrument and ce) to be the person(s)
acknowledged to me that he/she/they executed the same in
his/her/their authorized capacity(ies), and that by the signatu
re(s) on the instrument the person(s), or entity upon behalf
which the person acted, e ecuted the instrum ent of
- - - - - - - - - - - --- -----
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-12
FiledFiled
08/05/16
08/24/15
PagePage
189 of
1 of
190
2
EXHIBIT 12
11/19/2013 11:14 AM Instrument # 2013223302 # 1 Book: 6930 Page: 4838
Diane M. Matousek, Volusia County, Clerk of Court
Case
Case1:14-cv-01047-RMC
1:15-cv-00293-LTS-JCF
Document
Document
115-2
67-12FiledFiled
08/05/16
08/24/15 PagePage 190 of 2 of 190
2
Loan#:
RELEASE OF LIEN
KNOW ALL MEN BY THESE PRESENTS, that JPMORGAN CHASE BANK, N.A. is the owner and holder
of a certain Mortgage executed by PATRICIA B. KING in the amount of and recorded in Official Records Book
6148, Page 4414, or Document #••••■ in the office of the Clerk of the Circuit Court of VOLUSIA
County, Florida, hereby authorizes the Recorder to discharge the same of record. The property situated in said
State and County is more fully described in said Mortgage.
IN WITNESS WHEREO..[, 1said owner and holder has caused its presents to be executed by its VICE
PRESIDENT on __j___Lj~2013 (MM/DD/YYYY).
B y , ~
AmyKi t
v1cllEN'f
STA TE OF LOUISIANA
PARJ~F ~HITA
On / 013 (MM/DD/YYYY), before me appeared Amy Kight, to me personally known, who did
say tha he/she/the is/are the VICE PRESIDENT of JPMORGAN CHASE BANK, N.A. and that the instrument
was signed on behalf of the corporation (or association), by authority from its board of directors, and that
he/she/they acknowledged the instrument to be the free act and deed of the corporation (or association).
Bridge _,,,.,,_.._,_
Notary Public - State of LOUISIANA
Commission expires: LIFETIME
T0513113714 [C-1] ..
111111111111 1111111111111111 IIII
. ,,, . ...