Malalar All Defendants in this complaint acted in conspiracy, and as agent and assign and on behalf of, each other Defendant in this complaint to protect the privacy no. Further, the Defendants knew at the time of suppression no. Mortgaged-backed securities used merely to shield and hide the movement of assets converted from Plaintiffs outside of the United States instrumentality ; g. BofA, Chase, and Wells Fargo have ratified the bad acts of WAMU, Countrywide, and Wachovia, by intentionally making use of foreign companies to frustrate the Plaintiffs and other borrowers seeking information about their lost money, mortgages and loan modifications. However, its predatory lending practices caused it to fail.
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Gora Further, those Defendants that did not actively perform the acts or omissions described in this Complaint did affirmatively aid and abet the other Defendants in the performance of such acts of omissions, before, during or after the fact. To make matters worse, the Defendants established their concealment network now alleged entity-by-entity in this complaint, and this network has made it impossible to track the negotiation techniques and rights to possession of promissory notes, which are not publicly recordable.
The modus operandi of the various Defendants was to use the numerous methodologies set forth in this Complaint to convert money and property from consumers after the origination of their loan. Apart from all Defendants set forth herein, Exhibit A hereto lists subsequent transferee Defendants affiliated with all Defendants herein and which may be added as Doe defendants in the future should sufficient information exist to do so.
Many of these entities have already been personally served with summons and process of the no. All Defendants have Case 1: Should you have no. This force has also infiltrated almost every internet website to bend the truth and delve out disinformation. This system led to the Defendants making multiple sales of the same promissory notes to multiple MBS pools. Navy aircraft carrier George Washington docked after its arrival at a Manila bay October 24, Defendants knew that their representations regarding their willingness to enter into loan modification agreements were false when they made them.
Such activities represent additional acts of conversion under law. The original lender had already been paid when it transferred the promissory note, so there was no loss to the lender.
The Defendants not only covered up the poor quality of their loans and the liquidity crisis they created, they intentionally misrepresented to the public, in statements and in public filings, the nature of those loans in an effort to further defraud the public into continuing to borrow money and put their assets at risk.
It is impossible for Plaintiffs to know with certainty the exact amount of funds converted because Defendants have provided inconsistent, varying and false accounts of the monies they have received from Plaintiffs herein. Nothing set forth herein, however, should be construed to infer that Plaintiffs agree to deprive the trier of fact of the right to adjudicate whether negotiable instruments pertaining to them were or were not void ab initio, as such a determination will impact the predicate conduct required for an award of punitive damages and may impact other areas of Plaintiffs case such that they are not required to, and do not, in fact, agree to allow such critical issue to avoid scrutiny by the trier of fact in this case.
The fact that the Defendants were motivated to see that each Plaintiff failed to pay their mortgages on time and thus ended up in default so that the Defendants could collect on their CDS side bet has been hidden and suppressed from Plaintiffs by the Defendants.
Defendants, and each of them, have operated and continue to operate the largest Ponzi scheme in world history with a plan that — at its inception — was intended to, did in fact and continues to the present day to have as its object the theft and conversion of billions of dollars from millions of homeowners, including Plaintiffs.
Even IF our actions are not the solution our actions CAN be the catalyst to the solution by encouraging and empowering others to stand up. InWachovia was the fourth-largest bank holding company in the United States. However, the Defendants have hidden and suppressed the fact that they do not own the subject promissory notes and hence have no legal or contractual authority to offer such loan modifications. We all thought that it had them by the ole cajones too, but the suit got vaporized and no one has heard from the attorneys in charge.
At that time, each Defendant or their predecessors adopted a calculated business strategy that transferred ownership of the promissory notes executed by home loan borrowers to persons that were not entitled to receive negotiation thereof under applicable law, and knew it but joined the conspiracy for purposes that amounted to greed.
This Defendant is no. This was all done in order to buy time for Defendants to further secret the conversion of funds practiced against csse Plaintiffs and to support other n. In addition, Defendant BofA has admitted the involvement of co-conspirators a located in countries without treaties with the United States of America and b pursuant to instruments n.
Money was used to get him elected. Defendants used and exploited U. Why has no Bankster been sued or indicted by any of the foregoing public officials, while they concurrently steal trillions of dollars and transfer them to Luxembourg? On information and belief, Defendants receiving money under this Geitner operation were and are Robert Rubin, Valerie Jarrett, Anita Dunn, Robert Bauer, persons resident in, or hailing from, Chicago and closely aligned with the Obama campaign.
They have no chance of winning against the bankers government and the elite In fact, the Dodd-Frank Legislation was passed pursuant to the foregoing RICO enterprise to protect — not prevent — entities deemed too big to fail. Finally, each Defendant herein, named or unnamed, did knowingly derive some form of profit or benefit from the acts and omissions described herein.
Magistrate Judge Robert M. All Defendants no. We allege it was a company that underwrote loans in a manner that layered risk factor upon risk factor, such as reduced documentation. But seeing lawsuits of this size, almost three times the GDP of the United States, the financial collapse must be close. The New York Genesis of the Bankster Enterprise In addition to the detailed jurisdictional and venue oriented facts set forth above, the racketeering and money laundering scheme outlined in detail throughout this complaint had as its only epicenter: These Plaintiffs are further entitled to punitive damages in order to punish these Defendants for their malicious, oppressive and willful conduct as herein described.
The Defendants have made use of wholly or partially owned foreign companies in an effort to continue to hide and to misrepresent the ownership of the promissory notes executed by the borrowers, including the Plaintiffs, who borrowed funds from them. These have included enterprises of each Defendant as set forth herein, that dealt in the converted assets of tens of thousands of American homeowners — 3 To be clear, Plaintiffs make no allegation whatsoever that any Defendant herein — individually or in conspiracy with any other Defendant — has converted any real property.
This massive fraudulent scheme was a disaster both foreseen by the Defendants as well as waiting to happen. TOP Related Posts.
Vigar All Defendants have Case 1: Indeed, prior to the theft of their first dollar and their first dossier of private information of the Plaintiffs and other Americans, Defendants — and each of them in conspiracy with all other Defendants -applied to the United States Patent and Trademark Office seeking the approval of thousands of patents detailing complex schemes involving the movement of money, information and assets to secret entities whether located offshore or otherwise. All of the above Paragraphs of this Complaint are hereby incorporated by reference as though fully set forth herein. Apart from all Defendants set forth herein, Exhibit A hereto lists subsequent transferee Defendants affiliated with all Defendants herein and which may be added as Doe defendants in the future should sufficient information exist to do so. Defendants failed to disclose this material information to the Defendants, or omitted critical elements from the disclosures that were made. Each Defendant herein is no.
CASE NO.12-CV-04269-JBW-RML PDF
Mezill Thus, the original lender was paid when it sold the promissory note executed by the borrower, and the MBS pool was also paid in full by virtue of the CDS payments received. As is clear from the mounting number of federal and state enforcement actions against Defendants, it is now widely recognized that they have committed numerous illegal acts in the process of operating their mortgage businesses. This system led to the Defendants making multiple sales of the same promissory notes to multiple MBS pools. The Defendants willfully committed the wrongdoing against each Plaintiff as described herein and knowingly chose to deceive him in the above-described manner. This is the largest scheme in United States history where domestic banking institutions — on an international basis, involving all Defendants herein and their coconspirators operating n. Navy aircraft carrier George Washington docked after its arrival at a Manila bay October 24, The Defendants did not utilize appropriate underwriting processes. These multiple sales of the same promissory notes to multiple buyers do not create ownership of such negotiable instrument under Article 3 of the Uniform Commercial Code.