Winning a Foreclosure Case. There really should be no need to bankruptcy or frankly even mortgage modification. The key is to fight foreclosure! Now, I want a word here about the technical rules and requirements and about the need to really fight hard and understand exactly what the Florida Rules of Civil Procedure and the rules for defending a foreclosure case are.

The fact is this is a massively complex area that requires not just a reading and understanding of the technical rules for foreclosure defense, but a complex understanding about exactly how they operate.

In short, you need an experienced foreclosure defense attorney to serve your interests properly….but for now, enjoy a few of the basics that are critically important



  1. Admit that Plaintiff was not in possession of the original promissory note at the time this lawsuit was filed.
  2. Admit that no party, at least 30 days prior to the filing of this lawsuit, gave Defendants notice that the Note was assigned to Plaintiff.
  3. Admit that the Copy of the Note attached to the Complaint was an accurate photocopy of the original Note as of the date that the Complaint was filed.
  4. Admit that Plaintiff is not the holder of the Note.
  5. Admit that Plaintiff didn’t send Defendant notice pursuant to section 22 of the Mortgage.
  6. Admit that no document exists that shows Plaintiff received the original note on or before August 11, 2008.
  7. Admit that no document exists that shows Plaintiff held the original note on or before August 11, 2008.
  8. Admit that no document exists that shows Plaintiff was in possession of the original note on or before August 11, 2008.
  9. Admit that Plaintiff is not the nonholder in possession of the note who has the rights of a holder.
  10. Admit that Mortgage Electronic Registration Systems, Inc. (“MERS”) is not a party to the Note.
  11. Admit that these admissions are being answered by Plaintiff’s servicer.
  12. Admit that the note is an obligation of a consumer to pay money arising out of a transaction in which the money or property which are the subject of the transaction are primarily for personal, family or household purposes.
  13. Admit that Kimberly Dawson is an employee or agent of Bank of America, or its subsidiaries.
  14. Admit that Kimberly Dawson is not authorized to sign documents as an employee or agent for Mortgage Electronic Registration Systems Incorporated as nominee for Primelending, a Planscapital Company.
  15. Admit that Countrywide created the Assignment of Mortgage from MERS to Bank of New York.
  16. Admit that the Assignment of Mortgage from MERS to Bank of New York was created for the purposes of litigation.


All documents which are related to the subject loan transaction including but not limited to Note, modification of mortgage, judgment notes, security agreements, mortgages, assignments, allonges, insurance agreements, servicing agreements, pooling and servicing agreements and any and all other documents that relate or reference in any way the loan, or Plaintiff’s ability to service the loan, which is the subject of this instant litigation.
All documents which show the exact date that Plaintiff came into possession of the Note(s) in question.

All documents which show that Plaintiff held, received, or was in possession of the original note prior on or before August 11, 2008.

All agreements, contracts, or other documents which support the responses Plaintiff made to Defendant’s First Set of Interrogatories to the Plaintiff.

All agreements, contracts, or other documents which support the responses Plaintiff made to Defendant’s First Set of Admissions to the Plaintiff.

If the Plaintiff claims that this mortgage and note are held in trust and the Plaintiff is associated with said trust, please produce any relevant mortgage loan schedule which should include the Mortgagor’s name, loan identification number, the property address, etc. Please also produce any exceptions schedule which shows what mortgages were not transferred into the trust.

Any corporate resolution, power of attorney, contract, or document which shows that all parties which are able to act as servicing agent or otherwise authorized to act on behalf of Plaintiff with regard to the note or mortgage attached to the complaint.

All correspondence generated by any party concerning the loan transaction, mortgage or note in question, and instant foreclosure, from the May 1, 2007 until the date of responding to this request.

All telephone log sheets, computer printouts and any other internal memoranda or notes concerning this account.

All executed or unexecuted, recordable or non recordable assignments associated in any way with the subject loan including, but not limited to, assignments, transfers, allonges or any other document that purports to transfer the interest in the subject note and mortgage to any party from the date of its inception until the date of answering these requests for production.

All contracts between the Plaintiff and any person or entity responsible for servicing the mortgage and/or note.

All contracts, agreements and any other documents which show how and when the note and mortgage that are at dispute in this transaction came into possession of the Plaintiff.

All notices sent to Defendant pursuant to the Mortgage.

All documents which show the (1) name of the computer system that holds, processes, creates documents, prepares data, maintain, analysis, and otherwise contain the documents, information, data compilations, codes, and records of Defendant’s purported mortgage, note, payment history,  indebtedness, lender placed insurance, hazard insurance, late charges, appraisal, property inspections, brokers price opinions, title charges, title updates, etc., (2) the date of the system was created, (3) who maintains the system, (4) who developed the system, (5) what tasks the system performs, (6) who has access to the system, (7) how often the system is audited for accuracy, (8) how information is boarded or input into the system, (9) who boards the information into the system, and (10) where the server to the system is located.

Any and all bailee letters or other documents or data compilations which show who owned, held, serviced, or otherwise had any rights to enforce the note or mortgage attached to Plaintiff’s complaint.

All documents that borrower sent to lender, or its successors and assigns, that designates a substitute address by which notices should be sent under the mortgage.

All assignments of mortgage upon which Plaintiff relies on.

All documents that Plaintiff intends to rely on at trial.

A copy of the mortgage loan schedule which reference the instant note or mortgage.

A copy of all Requests for Release of Documents which reference the instant note or mortgage.

All written notices to either Defendant or Defendants which notify them of the assignment of the note at issue to another entity.

Here is more information on Winning Foreclosure Cases: Winning Cases and YALE LAW JOURNAL “In Defense of Free Houses”



Get the best real estate deals first, before they hit the mass market! HOT FORECLOSURE DEALS with one simple search


Search by name, phone, address, or email to confidentially lookup information about people.



The Con

The Con

How to Win in Court in Only 24hrs

Fraud Stoppers How to Win in Court


Identity Protection



FRAUD STOPPERS PMA Mortgage Foreclosure Defense Blog

free fraud analysis

Free Documents

Fight Traffic Tickets

Chicago Foreclosure Help

Free Loan Modifications

Senior Mortgage Modification Upheld: Court Rejects Junior Mortgagee's Attempt to Subordinate Loan in Bankruptcy Case, Exposing Foreclosure and Mortgage Fraud. Discover How FRAUD STOPPERS Can Assist Borrowers in Similar Situations.

Mortgage Refinance

Rule of Law Radio

Rule of Law Radio

Process Service

Free Bankruptcy Documents


Free Fraud Analysis

Free COVID Lawsuit

Mediation Services Requested

Social Media Buttons


face book youtubeg+ twitter

Recent Posts

Attorney Services Request

Pro Bono Attorneys

Free Foreclosure EBook

FRAUD STOPPERS Foreclosure Traps Pitfalls and Swindles

FRAUD STOPPERS Foreclosure Traps Pitfalls and Swindles

Private Attorney Network

Now You Can Unlock the Power of Justice and the Rule of Law with FRAUD STOPPERS


Are you tired of being a victim of financial fraud, seeking the justice and legal remedy you deserve? Look no further – FRAUD STOPPERS is here to empower you with the comprehensive tools and support necessary for success. With a wide range of services tailored to your needs, we are your ultimate ally in the fight against fraud.

FRAUD STOPPERS Arsenal of Solutions includes but is not limited to:

  1. Audits & Investigations: Our team of skilled professionals will meticulously analyze your case, leaving no stone unturned in uncovering the truth. We employ cutting-edge techniques and resources to expose the fraud and gather irrefutable evidence. We are the only organization (to our knowledge) that can provide you with a Full Level 4 Bloomberg Securitization Audit and all the loan level data and trust information for all Government Sponsored Loans (GSE’s) and loan placed in private trust (shipped off shores) that do not report to the Securities and Exchange Commission (SEC).
  1. Expert Witness Affidavits & Testimony: Our network of esteemed experts will provide compelling affidavits and testify on your behalf, lending credibility and authority to your case. Their specialized knowledge and experience will strengthen your position in the legal battle.
  1. Turnkey Litigation Packages: We understand that navigating the complex legal landscape can be overwhelming. That's why we offer comprehensive litigation packages, equipped with all the necessary documents and strategies to mount a strong defense against fraudsters.
  1. Professional Paralegal Support: Our dedicated paralegals are committed to assisting you every step of the way. They will guide you through the process, offer invaluable insights, and provide crucial administrative support to ensure your case is well-prepared.
  1. Nationwide Attorney Networks: We have established a vast network of highly skilled attorneys across the country who specialize in fraud cases. Rest assured, you will be connected with a trusted legal expert who is passionate about seeking justice on your behalf.
  1. Legal Education and Training: At FRAUD STOPPERS, we believe that knowledge is power. That's why we provide comprehensive legal education and training resources, empowering you to understand your rights, navigate the legal system, and make informed decisions throughout your case.
  1. Debt Settlement Negotiations: Our experienced negotiators will engage with creditors on your behalf, striving to reach favorable debt settlement agreements. We will advocate for your interests, aiming to alleviate the financial burden caused by fraud.
  1. Private Lending: If you require financial assistance to support your legal battle, our private lending options can provide the necessary funding. Our trusted lending partners offer competitive rates and flexible terms, ensuring you have the resources to fight for justice.


And much more! Save Time, Money, and Increase Your Odds of Success with FRAUD STOPPERS' Proven Products and Programs

If you're serious about getting the legal remedy you deserve, FRAUD STOPPERS has everything you need to succeed while saving time, money, and increasing your odds of success. Our comprehensive range of proven products and programs is designed to streamline the process, maximize efficiency, and deliver results.

Time is of the essence when it comes to combating fraud, and we understand the importance of expediting your case. With our expertise and resources, we can minimize delays and ensure efficient progress. By leveraging our extensive experience in fraud investigations and legal strategies, you can navigate the complexities of the legal system with confidence, saving valuable time in the process.

We also recognize the financial burden that fraud can impose, and we are committed to providing cost-effective solutions. Our competitive rates for services, private lending options, and expert negotiation skills can help you save money while maximizing the value you receive. Rest assured that we strive to optimize your resources, enabling you to fight fraud without breaking the bank.

Partnering with FRAUD STOPPERS significantly increases your odds of success. Our proven track record and extensive network of experienced professionals ensure that you have the best possible resources at your disposal. From expert witness testimonies to strategic litigation packages and effective debt settlement negotiations, our carefully curated products and programs have a track record of achieving favorable outcomes. With FRAUD STOPPERS by your side, you can maximize your chances of holding fraudsters accountable and obtaining the justice you deserve.

By choosing FRAUD STOPPERS, you can save time, save money, and increase your odds of success. Our proven products and programs, combined with our commitment to your cause, empower you to reclaim your future. Take the first step towards justice by completing the form below.

Remember, with FRAUD STOPPERS, you have a trusted partner dedicated to saving you time, money, and increasing your chances of success. Let us fight by your side and help you put an end to fraud once and for all.

Our commitment to your success knows no bounds. We are constantly expanding our services and partnerships to provide you with the most effective tools in the fight against fraud.

Ready to get started?

Simply complete the form below to begin your journey towards justice. Once submitted, check your email inbox or email spam folder for detailed instructions on how to move your file forward.

Remember, you don't have to face fraud alone – FRAUD STOPPERS is here to champion your cause and bring you the justice you deserve.

Join us in the battle against fraud today!

Complete the form below and then after submission, check your email inbox or spam folder for detailed instructions on how to move your file forward to get the legal remedy you seek and deserve.



Fraud Stoppers Logo

THIS SITE IS NOT INTENDED TO BE MISCONSTRUED AS LEGAL ADVICE. FRAUD STOPPERS is a Private Members Association PMA. FRAUD STOPPERS PMA is NOT a law firm, non-profit organization, or government agency.  FRAUD STOPPERS PMA does not operate in the public sector. Although this website is visible to the public  FRAUD STOPPERS PMA does not intend for any information contained in this website to be considered as legal advise.

The information about Foreclosure law and other legal information provided on this website does not, and is not intended to, constitute legal advice; instead, all information, content, and materials available on this site are for general informational purposes only.  Information on this website may not constitute the most up-to-date legal or other information.  This website contains links to other third-party websites.  Such links are only for the convenience of the reader, user or browser; FRAUD STOPPERS and its members do not recommend or endorse the contents of the third-party sites.

Readers of this website should contact their attorney to obtain advice with respect to any particular legal matter.  No reader, user, or browser of this site should act or refrain from acting on the basis of information on this site without first seeking legal advice from counsel in the relevant jurisdiction.  Only your individual attorney can provide assurances that the information contained herein – and your interpretation of it – is applicable or appropriate to your particular situation.  Use of, and access to, this website or any of the links or resources contained within the site do not create an attorney-client relationship between the reader, user, or browser and website authors, contributors, contributing law firms, or committee members and their respective employers. This site provides “information” about the law and is only designed to help users safely cope with their own legal needs. But legal information is not the same as legal advice — the application of law to an individual’s specific circumstances.

The views expressed at, or through, this site are those of the individual authors writing in their individual capacities only – not those of their respective employers, FRAUD STOPPERS, or committee/task force as a whole.  All liability with respect to actions taken or not taken based on the contents of this site are hereby expressly disclaimed.  The content on this posting is provided “as is;” no representations are made that the content is error-free.

For instant access to an affordable local competent attorney click here


Spread the love