Save your house from foreclosure and sue the banks for mortgage fraud with FRAUD STOPPERS PMA
Boilerplate Answers to Discovery Won’t Cut It. If Plaintiff does it, they lose the claim. If Defendant does it, they lose the defense.
Posted by Neil Garfield
I have been writing, lecturing, and just saying the same thing since 2006. Homeowners don’t need to prove anything. The objective in Foreclosure Defense is to prevent the claimant from pursuing their claim. If you are not willing to do all the necessary work and to make certain you have it right, then you are not litigating, you are complaining. The strategy is accomplished by using the following tactics:
- Wordsmithing the right very specific questions and demands that go right to the heart of the case — the existence and ownership of the debt (loan account). Both lawyers and homeowners seem to be shy about doing this because they are afraid of receiving an answer they won’t like. No such response it will be forthcoming. In fact no answer will be forthcoming and that is the point. The most they can ever do is obscure and evade. They do this with objections or with the responses that are meaningless and boiler plate.
- File a motion to compel along with a memorandum of law citing to relevant cases that are exactly on point.
- Get a hearing on the motion to compel. At the same time get a hearing on objections raised by your opposition. Prepare an order in advance of the hearing so the judge can see exactly what you’re asking for. The order should NOT specify punishment. It should only say that your motion is granted, that the following questions must be answered, and that the “bank” must respond to following requests for production must with the documents requested within ___ days. Prepare for the hearing in a mock presentation.
- Assuming you win on your motion to compel, having a lawyer in the courtroom representing the homeowner will greatly improve the chances that your lawyer will literally write the findings and rulings of the court. This will decrease the amount of wiggle room that the opposing attorney will try to insert.
- You might consider a motion to strike whatever response they file as being unresponsive to the discovery demanded, and contrary to the rules of civil procedure.
- There will still be no response — or no meaningful response. All they have are presumptions (not actual facts). You are entitled to rebut those presumptions by asking for facts. They must answer — but they won’t because they can’t.
- File a motion for sanctions. along with a memorandum of law citing to relevant cases that are exactly on point.
- Get a hearing on the motion for sanctions. At the same time get a hearing on any new objections raised by your opposition. Prepare an order in advance of the hearing so the judge can see exactly what you’re asking for. The order should specify punishments including (a) striking the pleadings (b) dismissing the foreclosure (c) raising the inference or presumption that the loan account does not exist for purposes of this proceeding (“law of the case”) (d) raising the inference or presumption that the ownership of the loan account cannot be established for purposes of this proceeding (“law of the case”) and (e) awarding the homeowner with costs and fees associated with the discovery dispute. It should say that your motion is granted, recite the history of bad behavior, and give them one more chance to purge themselves of contempt that by compliance with the order on the motion to compel within ___ days. Prepare for the hearing in a mock presentation.
- There will still be no response — or no meaningful response. All they have are presumptions (not actual facts). You are entitled to rebut those presumptions by asking for facts. They must answer — but they won’t because they can’t.
- File a motion for contempt of court along with a memorandum of law citing to relevant cases that are exactly on point.
- Get a hearing on the motion for contempt. At the same time get a hearing on any new objections raised by your opposition. Prepare an order in advance of the hearing so the judge can see exactly what you’re asking for. The order should specify punishments including (a) striking the pleadings (b) dismissing the foreclosure (c) raising the inference or presumption that the loan account does not exist for purposes of this proceeding (“law of the case”) (d) raising the inference or presumption that the ownership of the loan account cannot be established for purposes of this proceeding (“law of the case”). It should say that your motion is granted, recite the history of bad behavior, and give them one more chance to purge themselves of contempt by compliance with the order on the motion to compel within ___ days. Prepare for the hearing in a mock presentation.
- File a motion in limine along with a memorandum of law citing to relevant cases that are exactly on point.
- Get a hearing on the motion for in limine. At the same time get a hearing on any new objections raised by your opposition. Prepare an order in advance of the hearing so the judge can see exactly what you’re asking for. The order should specify that the claimant is barred from introducing evidence on the status or ownership of the debt and barred from introducing any evidence (testimony or exhibits) from which the court might apply presumptions of ownership, loss, right to enforce. It should say that your motion is granted, recite the history of bad behavior. Prepare for the hearing in a mock presentation.
- File a motion for summary judgment along with a memorandum of law citing to relevant cases that are exactly on point.
- Get a hearing on the motion for summary judgment. At the same time get a hearing on any new objections raised by your opposition. Prepare an order in advance of the hearing so the judge can see exactly what you’re asking for. The order should specify that judgment is entered because the claimant is barred from introducing evidence on the status or ownership of the debt and barred from introducing any evidence (testimony or exhibits) from which the court might apply presumptions of ownership, loss, right to enforce. It should say that your motion is granted, recite the history of bad behavior. Prepare for the hearing in a mock presentation.
FRAUD STOPPERS Foreclosure News Daily update ⋅ October 2, 2020 |
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Foreclosure Rescue Scam Alert
The following information and viewpoint is a personal opinion and deeply held religious belief of the author; and is shared with the sole intent to help homeowners & borrowers who may be facing foreclosure or who are currently experiencing financial hardship or difficulty with a mortgage avoid foreclosure traps, pitfalls, and swindles.
Avoid Storm (Norman) Bradford of the Mortgage Fraud Examiners At All Cost
Leading industry sources report that Storm (Norman) Bradford of the Mortgage Fraud Examiners and other get rich quick scam websites has been discovered to be the biggest conman and scam artist scamming innocent homeowners by selling a worthless appraisal fraud audit, for as much as $7500, that cannot be used in a court of law. Sources say that Storm (Norman) Bradford of the Mortgage Fraud Examiners is a known charlatan scam Storm (Norman) Bradford of the Mortgage Fraud Examiners and that he has been caught red handed pretending to be a lawyer.
Storm Bradford has spread lies and rumors about FRAUD STOPPERS stating that FRAUD STOPPERS is scamming homeowners with lies and disinformation, and this is the reason FRAUD STOPPERS is forced to respond to this known scammer and his smear campaign.
Storm (Norman) Bradford of the Mortgage Fraud Examiners has been reported to the Rip-off Report and to the Virginia Bar Association and the Virginia Attorney Generals office for perpetrating this ongoing fraud to scam homeowners. If you live in or you have a Foreclosure do not risk losing your home and your money by getting scammed by Storm (Norman) Bradford of the Mortgage Fraud Examiners.
Storm (Norman) Bradford of the Mortgage Fraud Examiners is a known banking shill who makes money buying and selling securitized mortgages and reverse mortgages to and from the too-big-to-fail-banks that have defrauded millions of American homeowners out of their live savings and the properties, while he simultaneously spread lies and misinformation about companies trying to help homeowners fight to save their homes from foreclosure.
Storm (Norman) Bradford of the Mortgage Fraud Examiners have been caught racketeering and blackmailing competitors for money in exchange to stop spreading lies and rumors about them. Storm (Norman) Bradford of the Mortgage Fraud Examiners not only bad mouths all of his competitors, and spreads lies and disinformation about them, but even more disturbing is that he then tries to blackmail them for money to stop his hate campaign.
Storm Bradford and the Mortgage Fraud Examiners are not the only scams to avoid, however they are among the most expensive foreclosure rescue scams to avoid.
Storming Scamming Bradford of the Mortgage Fraud Examiners is scamming homeowners with lies and disinformation, while profiteering from buying and selling securitized mortgages and reverse mortgages to and from the too-big-to-fail-banks. His side business appears to be peddling a mortgage transaction analysis to unsuspecting homeowners. FRAUD STOPPERS and other leading industry experts recommend that you avoid this suspected scam artist at all cost. If you are currently experiencing difficultly with a mortgage or foreclosure we FRAUD STOPPERS recommends that you get the help of a local competent attorney, and you invest the time to get formal legal education to protect yourself from scammers like Storm Bradford of the Mortgage Fraud Examiners.
To get instant access to an affordable local attorney click here
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