MRS V JPMC Doc 94 - Pla. Motion To Compel Discovery, May 27, 2016

Case 1:15-cv-00293-LTS-JCF Document 95 Filed 05/27/16 Page 1 of 3
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
MORTGAGE RESOLUTION SERVICING,

LLC, 1ST FIDELITY LOAN SERVICING, LLC,
and S & A CAPITAL PARTNERS, INC.,
No. 15-cv-00293(LTS)(JCF)
Plaintiffs,
v.
JPMORGAN CHASE BANK, N.A., CHASE
HOME FINANCE, LLC, and JPMORGAN
CHASE & CO.,
Defendants.
DECLARATION OF HELEN DAVIS CHAITMAN IN SUPPORT

OF PLAINTIFFS’ MOTION TO COMPEL AND DEFINE SCOPE OF DISCOVERY
HELEN DAVIS CHAITMAN, an attorney duly licensed to practice law before the courts of
the State of New York and admitted to the bar of this Court, hereby declares under penalties of perjury
as follows:
1. I am a partner in Chaitman, LLP, counsel for the Plaintiffs, S&A Capital Partners, Inc.,
(“S&A”), Mortgage Resolution Servicing, LLC (“MRS”) and 1st Fidelity Loan Servicing, LLC (“1st
Fidelity”). I submit this Declaration in support of Plaintiffs’ Motion, pursuant to Federal Rule of Civil
Procedure 26 and 37 and Local Civil Rule 37.1, (a) to compel Defendants JPMorgan Chase Bank,
N.A., JPMorgan Chase & Company, and Chase Home Finance LLC (collectively, “Chase” or
“Defendants”), to produce documents in response to Plaintiffs’ document demands (“Plaintiffs’
Requests”) and (b) to define the scope of discovery in this case.
2. Attached hereto as Exhibit A is a copy of Defendants’ Objections and Responses to
Plaintiffs’ First Request for the Production of Documents to all Defendants, dated February 24, 2016.
3. Attached hereto as Exhibit B is a copy of the Third Amended Complaint in this matter.
{00020228 1 }
4. Attached hereto as Exhibit C is an email dated December 18, 2009 from Launi
Solomon of Chase.
5. Attached hereto as Exhibit D is a copy of Defendants’ Objections and Responses to
Plaintiffs’ First Set of Interrogatories, sworn to on February 24, 2016.
6. Attached hereto as Exhibit E is a copy of Plaintiffs’ Notice of Deposition pursuant to
Rule 30(b)(6).
7. Attached hereto as Exhibit F is an email dated February 17, 2010 from Launi Solomon
of Chase.
8. Attached hereto as Exhibit G are redacted screenshots showing records from Chase’s
Pre-DOJ Lien Release Project, October 21, 2013.
9. Attached hereto as Exhibit H is an email dated January 3, 2014 from Jason Oquendo
of Chase.
10. Attached hereto as Exhibit I is a letter dated March 1, 2016 from Suzan Arden, an
attorney at Chaitman, to Christian Pistilli, an attorney at Covington & Burling, representing
Defendants.
11. Attached hereto as Exhibit J is a letter dated March 16, 2016, from Mr. Pistilli to Ms.
Arden.
12. Attached hereto as Exhibit K is a letter dated April 20, 2016, from Ms. Arden to Mr.
Pistilli.
13. Attached hereto as Exhibit L is an email chain dated April 22, 2016 between Mr. Pistilli
and Ms. Arden.
14. Attached hereto as Exhibit M is an email chain dated April 29, 2016 and April 28, 2016
between Mr. Pistilli and Ms. Arden.
{00020228 1 }
15. Attached hereto as Exhibit N is an email chain dated May 20, 2016 and May 13, 2016
between Mr. Pistilli and Ms. Arden.
16. Attached hereto as Exhibit O is a copy of Plaintiffs’ Revised Objections and
Responses to Defendants’ First Document Demands.
17. I hereby certify that, as reflected in Exhibits I through N, the parties have met and
conferred in an attempt to resolve discovery issues before bringing this motion.
Dated: May 27, 2016
/s/ Helen Davis Chaitman______

Helen Davis Chaitman
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EXHIBIT A
EXHIBIT B
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S&A CAPITAL PARTNERS, INC.,

MORTGAGE RESOLUTION SERVICING,
LLC; and 1ST FIDELITY LOAN No. 1 :15-cv-00293-LTS-JCF
SERVICING, LLC,
THIRD AMENDED COMPLAINT
Plaintiffs
JURY TRIAL DEMANDED
v.
JPMORGAN CHASE BANK, N.A.,

JP MORGAN CHASE & COMPANY, and
CHASE HOME FINANCE LLC
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:
NATURE OF THIS ACTION
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
between MRS and Chase Home Finance LLC (the "MLPA").
THE PARTIES
Plaintiffs:
2. S&A is a Florida corporation located at 6810 N. State Rd. 7, Coconut Creek,
Florida 33073, whose President is Laurence Schneider. S&A has been acquiring mortgaged
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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
residential mortgage loans from the Defendants.
3. MRS is a Florida limited liability company located at 6810 N. State Road 7,
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
the Defendants and paid full consideration for the loans.
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
and second lien residential mortgage loans from the Defendants.
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
FDIC as Receiver for Washington Mutual Bank, F.S.B.
6. JPMorgan Chase & Company ("JPMC") is a Delaware corporation with its
principal place of business at 270 Park Avenue, New York, New York. In July 2004, JPMC
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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,
JPMC is liable for all of the damages sought herein.
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
Chase and is liable for all of the damages sought herein.
JURISDICTION AND VENUE
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
supplemental jurisdiction of the state law claims under 28 U.S.C. § 1367(a).
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
occurred in this District.
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.
ALLEGATIONS COMMON TO ALL CLAIMS
The Plaintiffs' contracts with the Defendants
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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
file and history.
12. The Plaintiffs’ goal is to work out reasonable and sustainable payment plans with
the borrowers so that they can retain their homes.
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
(the "MMLSA") between S&A as purchaser and Chase as seller.
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
loans S&A purchased from the Defendants is annexed as Exhibit 1 hereto.
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
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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.
.Some of the 1st Fidelity Loans are listed on Exhibit 2 hereto.
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
including all of the original documentation for each 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
sustainable payments which allowed them to retain their homes.
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
of Plaintiffs purchase from HSBC of approximately $250 million of mortgage loans.
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
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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
its Recovery department .
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
collateral properties being offered or the loan balances.
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23. Guerrero informed Schneider that the proposed sale was to be made through a
process of competitive bidding.
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.
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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
Chase could get the loans off its books.
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
$250M deal with HSBC. He communicated this to Guerrero.
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
the portfolio of loans for $200,000.
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
approximately $100 million of “impaired first lien mortgage loans.”
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33. On December 23, 2008, as instructed, Schneider obtained a cashier’s check
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
final data tape after he signed the MLPA.
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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
balance of $156,324,399.24. See Exhibit 3 hereto at 1.
39. After receiving the fully-executed MLPA, Chase emailed to Schneider a data tape
purporting to be Exhibit A to the MPLA with a note: “All yours.”
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.
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42. Pursuant to the MLPA, Chase sold the Mortgage Loans to MRS "AS IS with no
representations or warranties except as expressly provided herein, and with NO RECOURSE
whatsoever to Seller." Exhibit 3 § 4, at 2.
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:
This Agreement includes provisions which the parties hereto

intend will remain in effect after the closing of the transaction
contemplated by this Agreement. Accordingly, this Agreement
shall survive and remain in effect after such closing.
Exhibit 3 § 11.
45. The MLPA contains the following choice of law provision:
This Agreement shall be deemed to have been made in the State of

New York. The Agreement shall be construed in accordance with
the laws of the State of New York and the obligations, rights and
remedies of the parties hereunder shall be determined in
accordance with the laws of the State of New York, excluding
conflict of laws issues. The parties hereby agree that all disputes
arising hereunder shall be submitted to and hereby subject
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themselves to the jurisdiction of the courts of competent

jurisdiction, state and federal, in the State of New York.
Exhibit 3 § 15.
The Defendants' Breaches of their Contractual Obligations under the MLPA
a. Chase failed to provide a proper Exhibit A
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
other customary information necessary for the servicing of mortgage loans.
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
Washington Mutual's system.
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.
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b. Chase knowingly sold loans that were not secured by mortgages
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
remaining after the mortgages had been foreclosed by the Defendants.
51. In many instances, the properties were occupied by people who had purchased the
properties from the Defendants following foreclosure by the Defendants.
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
took no action to remedy their breach.
c. Chase sold MRS loans it did not own
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
on Exhibit A were not owned by Chase.
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
their fraud and increased the liabilities of MRS.
57. When Schneider discovered this, he immediately reported it to Chase.
58. Chase refused to take any action to remedy this breach.
d. Chase failed to comply with applicable law
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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
off-load these loans onto MRS.
60. Chase committed, inter alia, the following violations of law with respect to the
loans sold to MRS:
a. Chase transferred the servicing of the mortgage loans to and from
multiple unlicensed and unregulated debt collection agencies which lacked the
mortgage servicing platforms to account for or service the borrowers’ loan with
any accuracy or integrity.
b. Chase knowingly provided these collection agencies with false and
misleading information about the borrowers.
c. Chase failed to provide proper record keeping for escrow accounts.
d. Chase stripped loan files of most origination documentation, including
federal disclosures and good faith estimates, thus putting MRS in a position where
it was unable to respond to borrower or regulatory inquiries.
e. Chase failed to provide any accurate borrower payment histories for
any of the loans in the MLPA.
f. Chase knowingly executed assignments of mortgage to MRS for
mortgage loans that Defendants knew had been foreclosed and sold to third
parties.
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g. Chase circumvented its own operating procedures and written policies
in connection with servicing federally-related mortgage loans by removing the
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
the security interest,
h. Chase included on Exhibit A loans that it had previously sold to third
parties and loans that it had never owned.
i. Chase knowingly and deliberately changed the loan numbers 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
acceptance of such payments.
e. Chase misrepresented the quantity and value of sold loans
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
A only listed 2,483 loans with an aggregate principal balance of $133,782,353.72.
62. In addition, of the duplicate loans, Exhibit A shows different amounts owed for
the same loan.
63. Because the information on Exhibit A was obfuscated, MRS had to do
painstaking reconciliations to determine the duplications.
f. Chase misrepresented the principal balance of the sold loans
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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
including amounts far in excess of the aggregate principal balance.
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
notes and mortgages for each of the loans listed on Exhibit A.
66. By refusing to provide assignments of the notes and mortgages, Chase prevented
MRS from realizing the value of the purchased loans.
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
treat the sold loans as its own property.
h. Chase converted payments from borrowers whose loans it had sold
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.
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69. In addition, Chase continued to collect payments from insurance carriers on
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.
i. Chase recalled the valuable loans sold under the MLPA
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
induce Schneider to purchase the portfolio.
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
loans by providing additional loans in an amended Exhibit A.
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.
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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
actually worth as a result of the breach of warranty.
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
$8,400 per year.
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
loans for a total of $296,436,000
MRS' efforts to mitigate damages
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
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for recovery operations and he wanted to get "a full understanding of the efforts . . . underway
prior to [Mr. Guerrero's] passing, and move forward as appropriate."
82. On December 9, 2009, Schneider sent Boyle an email confirming a conversation
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.
Defendants' post-sale misconduct
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
mortgagee, including one payment of which MRS is aware for $250,000.
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88. In situations where government enforcement agencies contacted Chase to
investigate Chase's conduct with respect to loans it had purportedly sold to MRS, Chase told the
agencies to contact MRS as the responsible party.
89. In situations where government enforcement agencies contacted Chase to
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
state and federal enforcement agencies against Chase.
91. When Plaintiffs tried to speak with Chase representatives to resolve these matters,
the Chase representatives refused to speak to Plaintiffs.
National Mortgage Settlement
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
well as other financial institutions, engaged in improper practices related to mortgage
origination, mortgage servicing, and foreclosures, including, but not limited to, irresponsible and
inadequate oversight of the banks' quality control standards.
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.
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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
Orders that are still in force.
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
family residential mortgages (the "National Mortgage Complaint").
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
consent agreements, many of which remain in full force and effect.
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.
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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
of quality control and communication with borrowers.
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
comply pursuant to its SPAwith the Treasury.
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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
p.m.., Eastern Standard Time, on February 8, 2012.
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
signed by Patrick Boyle as Vice President of the Bank.
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.
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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
including principal, interest, and expenses.
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:
As part of the recent mortgage servicing settlement reached with

the states and federal government, JPMorgan Chase, N.A. (Chase)
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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 you.
See Exhibit 6 hereto.
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
borrower should continue to make its payments to the Plaintiff.
112. 1st Fidelity did not agree to sell back most of the affected loans because Chase did
not offer a reasonable price.
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
that their loans had been forgiven by Chase.
The Warwick debt forgiveness
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
accordance with that plan.
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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
amount of $167,003.51. See Exhibit 7 hereto.
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.
Kassem refused to do so.
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
value totaling $428,053.61.
The Ahmed Debt Forgiveness
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
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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
communicate with him or with 1st Fidelity.
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
refused to buy back the Ahmeds’ loan from 1st Fidelity.
The Hancock-Roberts Debt Forgiveness
126. On August 27, 2009, 1st Fidelity purchased a loan from Chase that was secured by
a second mortgage on property owned by Teresa M. Hancock-Roberts. Chase executed an
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
with the terms of the payment plan.
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127. On September 13, 2012, Chase sent Hancock-Roberts a Forgiveness Letter
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
Chase refused to do so.
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
the Consumer Financial Protection Bureau which launched an investigation.
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
MLPA but had not yet delivered the assignments.
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."
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Hence, Ms. Cowman urged that Chase release liens in "order to not have a judgment filed on
Chase . . . [and] so Chase would not have any legal responsibility/liability."
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.
135. MRS loans were lien released by Defendants.
136. 1st Fidelity loans were lien released by Defendants.
137. S & A Capital loans were lien released by Defendants.
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
different from one another on numerous notarized documents
140. In its eagerness to avoid liability for urban blight, Chase released liens on
properties that Chase had previously sold to the Plaintiffs.
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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
purchased, as well as to regulatory action.
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
no longer owned the loan. See Exhibit 12 hereto.
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
1st Fidelity to foreclose.
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
to the Plaintiffs has caused the Plaintiffs huge losses.
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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.
The $13 billion RMBS Settlement
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
packaging, marketing, sale and issuance of residential mortgage-backed securities (“RMBS”) by
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
RMBS Settlement required the following payments by JPMC:
$2,000,000,000 Civil penalty under the Financial

Institutions Reform, Recovery, and
Enforcement Act (“FIRREA”)
$1,400,000,000 To settle claims by the National

Credit Union Administration
$515,400,000 To settle claims by the Federal

Deposit Insurance Corporation;
$4,000,000,000 To settle claims by the Federal

Housing Finance Agency;
$298,900,000 To settle claims by the State of

California
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Delaware

Illinois
$34,400,000 To settle claims by the

Commonwealth of Massachusetts

New York
$4,000,000,000 In the form of relief to aid

consumers harmed by the unlawful
conduct of JPMorgan, Bear Stearns
and Washington Mutual.
$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
Chase had previously sold to the Plaintiffs.
FIRST CLAIM FOR RELIEF

Breach of Contract on behalf of MRS
148. Plaintiffs repeat the allegations heretofore stated.
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
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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
consumer protection laws.
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
Consent Judgment and the RMBS.
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.
SECOND CLAIM FOR RELIEF

Breach of Contract on behalf of S & A
155. S&A purchased loans from Chase pursuant to valid and binding contracts
between S&A and Chase.
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
companies on loans it had sold to S&A.
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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.
THIRD CLAIM FOR RELIEF

Breach of Contract on behalf of 1st Fidelity
160. 1st Fidelity purchased loans from Chase pursuant to valid and binding contracts
between 1st Fidelity and Chase.
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
borrowers and/or insurance companies on loans it had sold to S&A.
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
New York law.
FOURTH CLAIM FOR RELIEF

Conversion on behalf of all Plaintiffs
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.
167. Plaintiffs devoted enormous resources to establishing relationships with the
borrowers of the purchased loans and putting them on payment schedules so that they could
make their debt service payments and retain their houses.
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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
securing loans that Chase had sold to the Plaintiffs.
169. These letters constituted willful conversion of the Plaintiffs’ property.
170. Chase is liable to the Plaintiffs for compensatory and punitive damages for its
conversion of Plaintiffs’ purchased assets
FIFTH CLAIM FOR RELIEF

Tortious Interference With Prospective Economic Advantage
on behalf of all Plaintiffs
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.
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SIXTH CLAIM FOR RELIEF

Fraud and Fraudulent Inducement
on behalf of MRS
177. Defendants, by their statements, acts, omissions and conduct, knowingly made
false representations to MRS to induce it to enter into the MLPA.
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
compliance with all applicable law.
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
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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
from Washington Mutual.
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
that should have been provided by Chase in Exhibit A to the MLPA.
183. MRS reasonably relied on Defendants’ misrepresentations and omissions given
Plaintiffs’ long-standing business relationship with Defendants and the apparent sincerity of the
assurances given by Guerrero and others.
184. As a result of Defendants’ fraudulent conduct, MRS has incurred and continues to
incur, damages in an amount to be determined at trial.
SEVENTH CLAIM FOR RELIEF

Negligent Misrepresentation on behalf of MRS
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
proper Exhibit A to the MLPA.
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
loans in compliance with applicable federal, state and local law.
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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
facts through an enormous effort and expense.
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
laws with respect to the origination and servicing of the loans.
191. At a minimum, they negligently concealed this information from MRS.
192. MRS suffered significant losses as a result of Defendants’ negligent
misrepresentations and Defendants are liable to MRS for all of the damages resulting therefrom.
EIGHTH CLAIM FOR RELIEF

Slander of Title on behalf of all Plaintiffs
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
service payments for the Defendants.
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196. Defendants acted in clear violation of their contractual obligations with a specific
malicious intent to enrich themselves at Plaintiffs’ expense.
197. Defendants knew that their conduct would have a devastating impact upon
Plaintiffs’ business and their business reputation.
198. Defendants’ conduct had a devastating impact upon Plaintiffs’ business and
Plaintiffs’ business reputation.
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
Plaintiffs for simply exercising their contractual rights.
200. As a direct and proximate result of Defendants’ conduct, Plaintiffs have incurred,
and continue to incur, damages in an amount to be determined at trial.
NINTH CLAIM FOR RELIEF

Civil RICO: 18 U.S.C. § 1962(c) on behalf of all Plaintiffs
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
reason of a violation of” RICO within the meaning of 18 U.S.C. § 1964(c).
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
the meaning of RICO, 18 U.S.C. §§ 1961(4).
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
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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
the Plaintiffs to make a profit.
206. The enterprise functioned to enable Defendants to fraudulently fulfill the
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
settlement with the DOJ.
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
mail to defraud the governmental entities as well as the Plaintiffs.
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
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to make false communications with borrowers, with collection agencies, with municipalities,
with the States and with the DOJ.
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
Defendants had not done so.
211. Each of the Defendants committed and/or aided and abetted the commission of
two or more acts of racketeering.
212. The predicate acts include Defendants’ use of interstate mail and wires to make
scores of fraudulent misrepresentations, including but not limited to the following:
a. Chase’s head of Loan Recovery, Eddie Guerrero knowingly misrepresented to

Schneider in 2008 that the loans MRS would be acquiring were “closed end first lien
residential mortgage loans” from which Defendants had decided to “walk away”
based on a financial cost-benefit analysis (i.e., the value of the loans was below the
costs associated with foreclosing on the loans), when in fact (a) Defendants were
really seeking to transfer liabilities associated with these loans to an unsuspecting
acquirer, and (b) Defendants actually intended to, and did, transfer deficiency claims,
not first lien mortgages.
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
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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.
g. In September 2012, Defendants mailed debt Forgiveness Letters to thousands of

defaulted borrowers representing to the recipients that Chase was cancelling the
amount owed by the homeowner and that the homeowner “owe[s] nothing more on
the loan and your debt will be canceled.” Defendants mailed these letters to
borrowers whose loans had previously been sold by Defendants to the Plaintiffs.
Thus, Defendants had no standing to forgive the debt.
h. Defendants also mailed thousands of letters to homeowners releasing the liens on

their properties, despite the fact that Defendants had previously sold these loans to the
Plaintiffs. For example, on October 2013 Defendants executed a lien release for loan
number 167446 to Ray Robert Brazelle which was sold to MRS under the MLPA.
Defendants arrange for the lien release to be recorded in December 2013. Similarly,
in November 2013, Defendants executed and recorded a lien release for loan number
20040177974 to Barbaros Ayaz and M. Ayaz, which had been sold to MRS under the
MLPA.
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.
j. Defendants made misrepresentations in various agreements they had executed in

which they represented that Chase is not “in violation of any statute, regulation,
order, decision, judgment or decree of, or any restriction imposed by, the United
States of America, and State, municipality or other political subdivision or agency of
any of the foregoing, or any court or other tribunal having jurisdiction over [Chase] ...
with respect to the conduct of the business of [Chase or the ownership of the
properties of [Chase], which, either individually or in the aggregate with all other
such violations, would materially and adversely affect the business, operations or
condition of [Chase] or the ability of [Chase] to perform, satisfy or observe any
obligation or condition under this Agreement.”
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213. The aforesaid acts of racketeering activity constituted a “pattern of racketeering
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.
214. As a direct result of Defendants’ violation of 18 U.S.C. § 1962(c), Plaintiffs have
incurred and will continue to incur damages in an amount to be determined at trial.
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.
b. Plaintiffs have lost revenue because Defendants sent correspondence to borrowers

whose loans had been sold to the Plaintiffs misrepresenting that Defendants or the collection
agency working for the Defendants owned the loans at issue and/or was the authorized servicer
for the loans at issue and that the borrowers should make payments to Defendants.
c. Plaintiffs have lost revenue as a result of Defendants’ wrongful retention of

payments on loans that Defendants sold to the Plaintiffs.
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
Defendants as a result of Defendants’ approval of short sales on properties on which Plaintiffs
held the mortgages.
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217. Pursuant to RICO, 18 U.S.C. § 1964(c), Plaintiffs are entitled to recover from
Defendants treble damages plus costs and attorneys’ fees.
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
alia, the NMSA Consent Judgment and the RMBS Settlement.
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
whose loans had been sold to the Plaintiffs.
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
of the NMSA Consent Judgment and the RMBS Settlement.
WHEREFORE, Plaintiffs demand judgment:
1. On the first claim, awarding Plaintiffs compensatory damages in the amount of
$300 million for breach of warranty.
2. On the second claim, awarding S&A compensatory damages for breach of
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.
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5. On the fifth claim, awarding plaintiffs compensatory and punitive damages for
tortious interference with prospective economic relations.
6. On the sixth claim, awarding Plaintiffs compensatory and punitive damages for
fraud and fraudulent inducement.
7. On the seventh claim, awarding MRS compensatory damages for negligent
misrepresentation.
8. On the eighth claim, awarding Plaintiffs damages for slander of title.
9. On the ninth claim, awarding Plaintiffs treble damages for Defendants’ violation
of RICO plus an award of all of Plaintiffs’ attorneys’ fees and costs.
10. And such other relief as the Court deems just and proper.
August 24, 2015 BECKER & POLIAKOFF LLP
By _/s/ Helen Davis Chaitman____

hchaitman@bplegal.com
Lance Gotthoffer
lgotthoffer@bplegal.com
45 Broadway
New York, New York 10006
(212) 599-3322
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Exhibits to Third Amended Complaint
1 S&A loans purchased from the Defendants

2 1st Fidelity loans purchased from the Defendants
3 Mortgage Loan Purchase Agreement between MRS and Chase Home Finance
4 Forgiveness Letters that the Defendants sent to borrowers whose loans Defendants
had previously sold to S&A.
5 Forgiveness Letters that the Defendants sent to borrowers whose loans Defendants
had previously sold to 1st Fidelity
6 December 5, 2012 letters sent by Defendants to Schneider offering to buy back over
20 mortgages that had been sold to Plaintiffs and, thereafter, forgiven by Chase.
7 September 13, 2012 letter sent by Defendants to the Warwicks extinguishing the
second mortgage and canceling the debt in the amount of $167,003.51 which
mortgage and debt Defendants had sold to 1st Fidelity 34 months earlier.
8 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.”
9 January 9, 2014 answer filed by the Ahmeds 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 NMSA Consent Judgment.
10 September 13, 2012 debt forgiveness letter sent by Chase to Hancock-Roberts,
cancelling a debt of $28,209.15 as a result of the NMSA Consent Judgment even
though the debt had previously been sold to 1st Fidelity.
11 February 16, 2010 assignment of mortgage by Chase to S&A on property owned by
Patricia B. King, which was recorded on March 15, 2010.
12 November 6, 2013 discharge of King mortgage by Chase, recorded on November 19,
2013 despite the fact that Chase no longer owned the mortgage.
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EXHIBIT 1
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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 2530 Woodstock Pl
Robert L. & Shirley S. 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
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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
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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 Pfafftown
1590 Lewisville Vienna Road 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 Versailles
10356 Greenville Saint Marys 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
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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
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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
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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
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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
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EXHIBIT 2
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1st Fidelity Loan Servicing Acquired From Chase 2009-2010 Document95-2
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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
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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
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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
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EXHIBIT 3
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Chase Home Finance National Recovery Group

Eddie S To Victor B Fox/JPMCHASE@JPMCHASE
Guerrero/JPMCHASE
CC
02/25/2009 08:45 AM
bcc
Subject Re: Q
You can fax to 1-866-522-4547 Attention Larry Schneider.
Thanks,
5C2-38Q-1 i52j 3
Eddie Guerrero. Recovery Supervisor | Real Estate Recovery | S* 602-627-8140 1 1 E-Fax
A21-2557
Victor B Fox/JPMCHASE
r
Post-it1 Fax Note 7671 O

XJ.
Victor B Fox/JPMCHASE
13/., f* S, 3 Fro"V ; i'r-. , J; ' i
02/25/2009 07:40 AM
-t
r™* 7 7, H
Fax*
to? Vic
Here is the electronic version, What fax number do you want me to send the signed copy
[attachment "Mortgage Resolution.NPA.MLPA.data 2-3-09.doc.2ip" deleted by Eddie S

Guerrero/JPMCHASE]
Victor B. Fox
Vice President
Real Estate Recovery ) r
Chase Home Finance /
'' 7
Ac V*l
V
8333 Ridgepoint Drive
Irving, TX 75063
Office - 972-443-2767 3 w
e-FAX-469-5 19-9527
/ S~6 /'- >'7?'

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MORTGAGE LOAN PURCHASE AGREEMENT
between
CHASE HOME FINANCE, LLC

Seller
and
MORTGAGE RESOLUTION SERVICING, LLC

Purchaser
Nonperfonmmg Closed End First Mortgage Loans
Dated as of February^. 2009

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MORTGAGE LOAN PURCHASE AGREEMENT
This Mortgage Loan Purchase Agreement (the "Agreement") is entered iatc as of

February ,34" by and among Chase Home Finance. LLC. a Delaware hmitec Liability
company (the " ") and Mortgage Resolution Serv icing, LLC, a 0 . ri d limited
liability company having an office at 2101 NW Corporate Boulevard, Suite 320: Boca Raton, FL
33431 ("Purchaser").
Seller agrees to sell and Purchaser agrees to purchase, on the terms and conditions
described below, certain 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 bs in default
(individually a "Mortgage Loan" and collectively the "Mortgage Loans"), all as described herein
Seller intends to and shall sell the Mortgage Loans to Purchaser on a servicing released
basis on the Closing Date.
Seller and Purchaser, in consideration of the premises and the mutual agreements, set forth
herein and other good and valuable consideration, agree as follows:
SECTION L Agreement to Purchase Seller agrees to sell, on a servicing-reieased

basis, and Purchaser agrees to purchase, on a servicing-reieased basis, on the terms and
conditions stated herein, Mortgage Loans having an outstanding aggregate principal balance as of
December 22, 2008 (the "Cut-off Date") in the amount of approximately $150,324,399.24
consisting of 3,529 loans.
SECTION 2. Mortgage Loan Schedule Seller and Purchaser hereby agree thai the
Mortgage Loans to be purchased under this Agreement are described in the schedule (the
"Mortgage Loan Schedule") attached hereto as Exhibit A. The Mortgage Loan Schedule 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").
SECTION 3. Purchase Price. Accrued Interest and Allocation of Balances and

Costs. The purchase price for the Mortgage Loans shall be $200,000 (the "Purchase Price").
In addition to the Purchase Price described above, Purchaser shall pay to Seller all payments,
proceeds and recoveries related to the Mortgage Loans received after the Cut-off Dale but prior
to the fifth business day preceding the Closing Date ("Post Cut-off Payments"). The Purchase
Price and the Post Cut- Off Payments shall be paid to Seller in immediately available federal
funds by wire transfer on the Closing Date by 5:00 P.M. EST.
Purchaser shall be entitled to all proceeds arising out of the Mortgage Leans received
after the Cut-off Date which are not included in the Post Cut-Off Payments. Purchaser shall have
no obligation to reimburse Seller for negative escrow balances or negative suspense balances and
shall be entitled to all positive escrow balances and positive suspense balances as of the Cut-OlT
Date. Seller shall not offset the negative escrow- balances against the positive escrows balances.
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Purchaser shall have no obligation to reimburse Seller for any expense, paid or unpaid, blued or
not billed, incurred by Seller prior to the Cut-Off Date. Seller shall be liable for aii expenses,
costs, charges and advances incurred prior to the Cut-Off Date, including any attorneys' fees, real
estate taxes and servicer advances. Purchaser shall be liable for all expenses, costs, charges ana
advances incurred after the Cut-Off Date, including any attorney's fees and servicer advances.
SECTION 4. Due Diligence. Purchaser acknowledges that it has had an opportunity to

conduct a due diligence review of each Mortgage Loan. Purchaser acknowledges and agrees that,
notwithstanding the results of such due diligence and notwithstanding any failure of Purchase to
conduct a due diligence review of any Mortgage Loan, Purchaser will purchase the Mortgage
Loans pursuant to this Agreement AS IS with no representations or warranties except as
expressly provided herein, and with NO RECOURSE whatsoever to Seller
SECTION 5. Closing, The closing of the purchase and sale of the Mortgage Loans
identified on the Mortgage Loan Schedule shall take place on or before Februat^2S 2009, or
such other date as the parties may mutually agree (the "Closing Date").
SECTION 6- Representations. Warranties and Covenants of Seller ami Purchaser-
a. Seller hereby makes the following representations and warranties to Purchaser as

of the Closing Date;
(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;
00 Seller is the sole owner of the Mortgage Loans and has full right to transfer and
sell the Mortgage Loans to Purchaser; and
(hi) 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, predator)' and abusive lending laws applicable '.o the
Mortgage Loans.
b. Purchaser hereby makes the following representations, and warranties and

covenants to Seller;
(i) Purchaser's structure, capitalization, funding and all other matters incidental to its
involvement in the transaction contemplated herein, including, without iimitatjion,
the purchase of the Mortgage Loans, comply with all applicable securities laws
and regulations;
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(«) Purchaser hereby covenants that it will, upon Seller's request, pro1,'ids 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 request, including
information regarding Purchaser's relationships with its investing and funding
sources for the transaction contemplated herein; and
(iii) Purchaser will indemnify and hold Seller and its affiliates harmless from and
against any and all losses, costs, expenses, damages, claims, and fees {including
attorney's fees and court costs) that may be incurred as the result of a breach or
alleged breach by Purchaser of such securities laws.
c. Except as otherwise expressly provided herein, each Mortgage Loan is being soid
bv Seller with NO REPRESENTATIONS OR WARRANTIES of, by or on behalf of Seller and
on an "AS IS, WHERE IS. WITH ALL FAULTS" basis with NO RECOURSE WHATSOEVER
and, without in any way limiting the foregoing, WITH NO REPURCHASE OR BUY BACK
OBLIGATIONS WHATSOEVER.
SECTION 7. Expenses. Except as otherwise provided in Section 6.b.(iii). each party

will bear its own costs, fees and expenses in connection with the transaction contemplated herein
(including the costs, fees and expenses of its attorneys). Seller will bear the cost or the delivery
of the servicing/origination files for the Mortgage Loans to the Purchaser or its designee
(including any costs owed to Seller's custodian related to the release and shipment of the
servicing/origination files to Purchaser or its designee): the costs of preparing and recording any
assignments of mortgage (including intervening assignments necessary to prefect title to
Purchaser) from Seller to Purchaser and endorsing notes to Purchaser, as required the costs of
delivering complete master-file tape information and other electronically stored information to
Purchaser; the costs of notifying the mortgagors, hazard, flood and mortgage insurance
companies, and others, as necessary, and the costs of shipping all Mortgage Loans records and
servicing-relatea files to Purchaser. Purchaser will be responsible for the costs of its cue
diligence
SECTION 8, Nooperforming Mortgage Loans Purchaser acknowledges that ail or

substantially all of the Mortgage Loans are or have been nonperforming on their original and/or
modified terms.
SECTION 9. Confidentiality. Seller and Purchaser each hereby agrees to fully comply
with all applicable laws, rules and regulations governing the confidentiality of any information
acquired from or concerning the mortgagors.
SECTION 1 0- Brokers. Each party to this Agreement hereby represents and warrants to
the other party 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 finder's or originators fee arising out of
or in connection with the transaction contemplated by this Agreement, or (ii) 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.
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SECTION 1 1. Survival of Agreement, This Agreement includes previsions which the

parties hereto intend will remain in effect after the closing of the transac tion contemplated by this
.Agreement. Accordingly, this Agreement shall survive and remain in effect after such closing.
SECTION 12. Notices- All demands, notices and communications under this
Agreement shail be in writing and shall be deemed to have been duly given if mailed by
registered or certified mail, return receipt requested, or by overnight delivery service, addressed
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 NW Corporate Boulevard,
Suite 320, Boca Raton, FL 33431 and in the case of the Seller, to JPMorgan Chase Bank. N.A.,
194 Wood Avenue South, Iselin, NJ 08830, with a copy to /PMorgan Chase Bank. NLA., 194
Wood Avenue South, Iselin, NJ 08830, attention, General Counsel. Any such demand, notice or
communication shall be deemed to have been received on the date delivered to or received at the
premises of the addressee (as evidenced by the date noted on the return receipt cr overnight
delivery receipt).
SECTION 13. Separability Clause. Any part, provision, representation or warranty of

this Agreement which is prohibited or unenforceable or is held to be void or unenforceable in any
jurisdiction shall, as to such jurisdiction, be ineffective to the extent of such prohibition or
unenforceability without invalidating the remaining provisions hereof, and any such prohibition
or unenforceability in any jurisdiction shall not invalidate or render unenforceable such 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 simultaneously in any
number of counterparts. Each counterpart shall be deemed to be an original, and ail such
counterparts shall constitute one and the same instrument.
SECTION 15. Place of Delivery and Governing Law. This Agreement shall be
deemed to have been made in the State of New York. The Agreement shall be construed in
accordance with the laws of the State of New York and the obligations, rights and remedies of
the parties hereunder shall be determined in accordance with the laws of the State of New York,
excluding conflict of laws issues. The parties hereby agree that all disputes arising hereunder
shall be submitted to and hereby subject themselves to the jurisdiction of the courts of competent
jurisdiction, state and federal, in the State of New York.
SECTION 16. Successors and Assigns; Assignment. This Agreement shdi 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 hypothecated by
Purchaser or Seller without the prior written consent of the other party to this Agreement.
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SECTION 17. Amendments. Neither this Agreement nor any provision hereof may be
changed, waived, discharged or terminated orally, but only by a written instrument signed by
both Seller and Purchaser.
SECTION 18. Interpretation. For all purposes of this Agreement, initially capitalized
terms used herein have the meanings asenbed hereto in the Agreement. Except as expressly
otherwise provided herein or unless the context otherwise requires, for purposes of this
Agreement the words "herein," "hereto," "hereof and "hereunder" and other words of similar
effect shall refer to this Agreement as a whole and not to any particular provision.
IN WITNESS WHEREOF, Seller and Purchaser have caused their names to be signed
hereto by their respective authorized officers as of the date first above written,
SELLER:
CHASE HOME FINANCE, LLC
By: VictonPox^r:
Name : ^ 2 r
Title: Vice President
PURCHASER:
MORTGAGE RESOLUTION SERVICING, LLC
By: r^~ ~~ ' ~
Name: / -aC/tAf ,'r-Jt? <—

Title:
to t
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I
EXHIBIT A
MORTGAGE LOAN SCHEDULE
A-f
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CHASE ©
September 1 3, 201 2
WE ARE CANCELLING
THE REMAINING AMOUNT
OWED TO CHASE!
Henri D Wright
1 029 Abbott Ln
University Park, IL 60484-3201
Property Address: 1 029 Abbott Ln

University Park, IL 60466
Dear Henri D Wright:
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.
As part of cancelling the amount owed, we will:
¦ Report the cancellation of the debt to the Internal Revenue Service.

If you have questions about how this affects your taxes, please contact your tax advisor.
¦ 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.
¦ Refund any remaining escrow balances on the account to you.
¦ No longer be responsible for securing the property and/or providing maintenance required
by the city if the property is vacant.
All you need to do:
¦ 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.
If you have any questions, call us at 877-836-3040.
Sincerely,
Your account number:
100001414830009582
Patrick Boyle
Vice President
Please see important disclosures on the next page.
263549 DOJREC_BK 8974

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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.
t=J
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FREQUENTLY ASKED QUESTIONS
Q: Why are you cancelling the amount owed to Chase?
A: Chase and four other mortgage servicers have agreed to a mortgage servicing settlement with the
states and federal government. As part of the settlement, we are waiving the mortgage balance.
For more information, visit nationalmortgagesettlement.com.
Q: What are the benefits of cancelling the amount owed?
A: Nothing more is owed on the account.
Q: What are the effects of cancelling the amount owed?
A: The cancellation of the debt will be reported to the credit bureaus, but we do not know the impact,
if any, this will have on your credit score. Cancelling the amount owed on the account may also
have tax implications. Please consult with your tax advisor to discuss those possible implications.
Q: Will Chase release the lien on the property?
A: Yes. We will release the lien held by Chase and forward the release to your county records office
Q: Do I need to sign and return anything to accept this offer?
A: No action is needed on your part. Keep this letter with your other mortgage documents for
your records.
Q: What if I do not want the mortgage balance cancelled?
A: There are no closing costs or fees for this change. It is part of the mortgage servicing settlement
with the states and federal government. However, if you don't want the debt cancelled, you must
call us at the telephone number listed on the front of the letter by October 1 , 201 2.
1 71 31 -D0J-REC-RR738 FAQ
263549 DOCREC_FAQ 8974

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September 13, 2012 WE ARE CANCELLING

OWED TO CHASE!
Frank G Demske
Barbara L Yockey
265 N Almont Ave
Imlay City, MI 48444-1004
Property Address: 265 N Almont Ave
Imlay City, MI 48444
Dear Frank G Demske and Barbara L Yockey:
• Report the cancellation of the debt to the Internal Revenue Service.

• Report the cancellation of the debt to various credit bureau reporting agencies.
• 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.
• Refund any remaining escrow balances on the account to you.
• No longer be responsible for securing the property and/or providing maintenance required
All you need to do:

• Contact your insurance company and/or taxing authority to make arrangements for paying any
• 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
Sincerely,
100500439800892659
Patrick Boyle
Vice President
263549 DOJREC_BK 7749

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If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney’s
2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131-DOJ-REC-RR738 BK
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your records.

with the states and federal government. However, if you don’t want the debt cancelled, you must
call us at the telephone number listed on the front of the letter by October 1, 2012.
17131-DOJ-REC-RR738 FAQ

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CHASE ©
WE ARE CANCELLING
OWED TO CHASE!
Dianna L Goodwin
5056 Arbor Glen Rd
The Colony, TX 75056-2526
Property Address: 5056 Arbor Glen Road

the Colony, TX 75056
Dear Dianna L Goodwin:
below, totaling $1 7,482.63, as a result of a recent mortgage servicing settlement reached with the

All you need to do:
Sincerely,
100001412610083809
Patrick Boyle
Vice President
263549 DOJREC_BK 9783

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CHASE ©
WE ARE CANCELLING
OWED TO CHASE!
Diane Busza
41 Townhouse Ln
Little Egg Harbor Twp, NJ 08087-1837
Property Address: 41 Town House Ln

Little Egg Harbor, NJ 08087
Dear Diane Busza:

All you need to do:
Sincerely,
10000141 1660007717
Patrick Boyle
Vice President
263549 DOJREC_BK 1936

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YOU OWE CHASE!
Dorothy Vance
Jeffery Vance
40 Leyland Ln
Harpers Ferry, WV 25425-5376
Property Address: 40 Leyland Ln
Harpers Ferry, WV 25425
Dear Dorothy Vance and Jeffery Vance:
We are writing to let you know that we are cancelling the amount you owe Chase on the loan referenced
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.
As part of cancelling the amount you owe, we will:
• Report the cancellation of your debt to the Internal Revenue Service.

• Report the cancellation of your debt to various credit bureau reporting agencies.
• 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.
All you need to do:

Sincerely,
100900426370399018
Patrick Boyle
Vice President
263547 DOJREC_GEN 4232

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We are a debt collector.
2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131-DOJ-REC-RR736
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Q: Why are you cancelling the amount I owe?
states and federal government. As part of the settlement, we are waiving your mortgage balance.
Q: What are the benefits of cancelling the amount I owe?

A: You will never have to pay back this money and you owe nothing more on your account.
Q: What are the effects of cancelling the amount I owe?

A: The cancellation of your debt will be reported to the credit bureaus, but we do not know the impact,
if any, this will have on your credit score. Cancelling the amount you owe on your account may also
Q: Will Chase release the lien on my property?


your records.
Q: What if I do not want my mortgage balance cancelled?

with the states and federal government. However, if you don’t want your debt cancelled, you must

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OWED TO CHASE!
Jerry L Grimm
7031 Wyandotte Dr Apt 58
Cincinnati, OH 45233-4287
Property Address: 7031 Wyandotte Dr
Cincinnati, OH 45233
Dear Jerry L Grimm:
below, totaling $5,642.62, as a result of a recent mortgage servicing settlement reached with the states
and federal government.

All you need to do:

Sincerely,
100900426380031490
Patrick Boyle
Vice President
263549 DOJREC_BK 6807

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YOU OWE CHASE!
Gerard A Solberg
10 Charleston Ct
Chatham, IL 62629-1000
Property Address: 10 Charleston Ct
Chatham, IL 62629
Dear Gerard A Solberg:

All you need to do:

Sincerely,
100001414011078913
Patrick Boyle
Vice President
263547 DOJREC_GEN 12879

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263547 DOCREC_FAQ 12879

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OWED TO CHASE!
Carol Laug
Garry Keeton
127 Campbell Rd
Harrison, OH 45030-1402
Property Address: 127 Campbell Rd
Harrison, OH 45030
Dear Carol Laug and Garry Keeton:

All you need to do:

Sincerely,
100500430521175187
Patrick Boyle
Vice President
263549 DOJREC_BK 6744

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OWED TO CHASE!
Allen Bradley
Gloria Bradley
235 N Concept Dr
Lima, OH 45807-2207
Property Address: 235 North Concept Dr
Lima, OH 45807
Dear Allen Bradley and Gloria Bradley:

All you need to do:

Sincerely,
100500439900055099
Patrick Boyle
Vice President
263549 DOJREC_BK 6942

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OWED TO CHASE!
Randy Frazier
2524 Pendergrass Ln
Ellenwood, GA 30294-6241
Property Address: 2524 Pendergrass Ln
Ellenwood, GA 30294
Dear Randy Frazier:

All you need to do:

Sincerely,
100900426360246451
Patrick Boyle
Vice President
263549 DOJREC_BK 3808

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WE ARE CANCELLING
YOU OWE CHASE!
Jacob A Rossatto
1 334 W Smith St
Orlando, FL 32804-4830
Property Address: 1 334 W Smith St

Orlando, FL 32804
Dear Jacob A Rossatto:
below, totaling $53,1 07.82, as a result of a recent mortgage servicing settlement reached with the
This means you will owe nothing more on the loan and your debt will be cancelled. You don't
¦ Report the cancellation of your debt to the Internal Revenue Service.

¦ Report the cancellation of your debt to various credit bureau reporting agencies.
¦ No longer pay property taxes or insurance on your behalf if this was part of your mortgage.
¦ Refund any remaining escrow balances on the account you are entitled to.
All you need to do:
Sincerely,
0672198561
Patrick Boyle
Vice President

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with the states and federal government. However, if you don't want your debt cancelled, you must
1 71 31 -D0J-REC-RR736 FAQ

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WE ARE CANCELLING
OWED TO CHASE!
George R Lawwill
Theresa A Lawwill
2090 Kylemore Dr
Xenia, OH 45385-3953
Property Address: 2090 Kylemore Dr

Xenia, OH 45385
Dear George R Lawwill and Theresa A Lawwill:

All you need to do:
Sincerely,
10000141001 1576330
Patrick Boyle
Vice President
263549 DOJREC_BK 6876

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Matthew P Di Minno
5805 Herzman Dr
Evergreen, CO 80439-5458
Property Address: 5805 Herzman Dr

Evergreen, CO 80439
Dear Matthew P Di Minno:

All you need to do:
Sincerely,
100001415010307608
Patrick Boyle
Vice President
263547 DOJREC_GEN 13948

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Saleh Ahmed
Beverly A Ahmed
500 S Bouziden Dr
Moore, OK 73160-7360
Property Address: 321 S English St

Oklahoma City, OK 731 60
Dear Saleh Ahmed and Beverly A Ahmed:

All you need to do:
Sincerely,
100001416620120938
Patrick Boyle
Vice President
263547 DOJREC_GEN 13389

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Irene A Williams
1 036 Kamehame Dr
Honolulu, HI 96825-2859
Property Address: 6045 North 40th Street

Paradise Valley, AZ 85253
Dear Irene A Williams:

All you need to do:
Sincerely,
10000244921975881 1
Patrick Boyle
Vice President
263547 DOJREC_GEN 18862

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YOU OWE CHASE!
Yvonne D Harrity
Edward A Harrity
16445 El Centro St
Hesperia, CA 92345-5813
Property Address: 16445 El Centro St
Hesperia, CA 92345
Dear Yvonne D Harrity and Edward A Harrity:

All you need to do:

Sincerely,
100900426370383518
Patrick Boyle
Vice President
263547 DOJREC_GEN 16634

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your records.

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James J Carr
1 0 Royal Palm Way Unit 1 02
Boca Raton, FL 33432-7830
Property Address: 1 0 Royal Palm Way

Boca Raton, FL 33432
Dear James J Carr:

All you need to do:
Sincerely,
100900426430034553
Patrick Boyle
Vice President

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Robert W Warwick
801 Vacation Dr
Odenton, MD 21 113-2262
Property Address: 801 Vacation Dr

Odenton, MD 21113
Dear Robert W Warwick:

All you need to do:
Sincerely,
1 00900426430036548
Patrick Boyle
Vice President

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OWED TO CHASE!
Teresa M Hancock
204 New Haven Ave Unit 8E
Derby, CT 06418-2150
Property Address: 204 New Haven Avenue 8E
Derby, CT 06418
Dear Teresa M Hancock:

All you need to do:

Sincerely,
100900427011269656
Patrick Boyle
Vice President
263549 DOJREC_BK 1389

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WE ARE CANCELLING
OWED TO CHASE!
William J Spence Jr
Laura L Spence
634 Nesting Ln
Middletown, DE 19709-6124
Property Address: 634 Nesting Lane

Middletown, DE 19709
Dear William J Spence Jr and Laura L Spence:

All you need to do:
Sincerely,
100900429258879392
Patrick Boyle
Vice President
263549 DOJREC_BK 3046

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Vito DeRosa
Nicolette DeRosa
2801 SWMontegoTer
Stuart, FL 34997-1203
Property Address: 2801 SW Montego Ter

Stuart, FL 34997
Dear Vito DeRosa and Nicolette DeRosa:

All you need to do:
Sincerely,
100950429200046714
Patrick Boyle
Vice President

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Marvin B Cornish Jr
Cassandra A Cornish
1 4636 London Ln
Bowie, MD 20715-2572
Property Address: 14636 London Ln

Bowie, MD 20715
Dear Marvin B Cornish Jr and Cassandra A Cornish:

All you need to do:
Sincerely,
100950429200061358
Patrick Boyle
Vice President

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EXHIBIT 6
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CHASE C
Chase (AZ1-2557)
1820 E Sky Harbor Circle S, Floor 2
Phoenix, AZ, 85034-4850, United States
December 5, 2012
Mr. Larry Schneider

1st Fidelity Loan Servicing
2101 NW Corporate Blvd, Suite 102
Re: Immediate Attention Required
Dear Mr. Larry Schneider,
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.
3) Choose a combination between option 1.) and 2.)
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, CFA

Vice President / Portfolio Manager
602-627-8661
!
til
under ©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. LC-INVST
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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,
OpITon A OpUon B
ACCOUNT Q CUSTNAME ||PROPADD1 Hpropcity P STp ZPH Buybncg Rolracnfl
1)672196561 ROSSATTO, JACOB ALEJAI 1334 W SMITH ST ORLANDO FL 32804
T0000141001157833oIlAWWILL, GEORGE R 2090 KYLEMORE OR XENIA OH SS385
'100001415010307608 Dl MINNO, MATTHEW P 6805 HERZMAN OR EVERGREEN CO 60439
'100002449219753811 WILLIAMS. IRENE A 6045 NORTH 40TH STREET PARADISE VALLEY AZ
'100900426370383518 HARRITY, YVONNE D 16445 EL CENTRO ST HESPERIA CA 52345 "

'100900426430034553 CARR. JAMES J 10 ROYAL PALM WAY BOCA RATON
'100900426430036548 WARWICK. ROBERT W 601 VACATION PR ODENTON MD 21113

'1 0090042701 1269656 HANCOCK. TERESA M 204 NEW HAVEN AVENUE 8E DERBY "56418
'1 00900429256B79392 SPENCE JR, WILLIAM J 634 NESTING LANE MIDDLETOWN DE *19709
'100950429200046714 DEROSA. VrTO 2801 SW MONTEGO TER STUART " FL 34997
'1009504 29200061 358 CORNISH JR.MARVIN B 14636 LONDON LN BOWIE MD '20715
'100001416620120938 AHMED.SALEH 321 S ENGLISH ST OKLAHOMA CITY OK 73160
-
© LC-INVST
lender ©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A
Case
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CHA5E Cp
Chase (AZ1-2557)
1820 E Sky Harbor Circle S, Floor 2
Phoenix, AZ, 85034-4850, United States
December 5, 2012
Mr, Larry Schneider

S & A Capital Partners
2101 NW Corporate Blvd, Suite 102
Re: Immediate Attention Required
Dear Mr. Larry Schneider,
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.
3) Choose a combination between option 1.) and 2.)
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,
i Omar Kassem, CFA

Vice President / Portfolio Manager
602-627-8661
,
LC-INVST
©2012 JPMorgan Chase & Co JPMorgan Chase Bank, N.A
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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.
Option A Option B
ACCOUNT Hcust_name HPeOPAOOl Hpropcity B STM7IPM BuybncJJj RetracfiQ

100001410011640005 MITCHELL, MARTY LEON 7326 STATE ROUTE 19 UNfT 5215 MOUNT GILEAD OH 43338
100001411660007717 BUSZA.OIANE 41 TOWN HOUSE LN " LITTLE EGG HARBOR NJ '08087 V^*
100001412610083809 GOODWIN.OIANNA L 5056 ARBOR GLEN ROAD THE COLONY TX *75056
100001414011078913 SOLBERG, GERARD A 10 CHARLESTON CT CHATHAM IL §2629
'100001414830009582 WRIGHT, HENRI DEMARCO 1029 ABBOTT LN UNIVERSITY PARK fit §0466
10050Q430521 175187 LAUG, CAROL 127 CAMPBELL RD HARRISON OH 350351
1 00500439900055099 BRADLEY. AU.EN 235 NORTH CONCEPT DR LIMA OH 45807 —
100900426360246451 FRAZ1ER. RANDY 2524 PENDERGRASS LN ELLENWOOD GA 30294*

'100900426370399018 VANCE, DOROTHY 40 LEYLAND LN HARPERS FERRY WV 25425 "$»•<?
'100900426380031490 GRIMM, JERRY L 7031 WYANDOTTE DR CINCINNATI OH '45233
0EMSKE, FRANK G 265 N ALMONT AVE IMLAY CITY Ml 48444
100500439800892659
lender ©2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A LC-INVST
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EXHIBIT 7
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CHASE O

YOU OWE CHASE!
Robert W Warwick
801 Vacation Dr
Odenton.MD 21 113-2262
Property Address: 801 Vacation Dr

Odenton, MD 21113
Dear Robert W Warwick:
below, totaling $167,003,51, as a result of a recent mortgage servicing settlement reached with the
¦ Report the cancellation of your debt to the Internal Revenue Service,

If you have questions about how this affects your taxes, please contact your tax advisor,
We do not know what, if any, effect this will have on your credit score,
for processing. Depending on your county's procedures, this may take several months,
•i
All you need to do:
" Contact your insurance company and/or taxing authority to make arrangements for paying any
• ¦ Provide your address to your homeowners' insurance agent, as well as your taxing authority, so
Sincerely,
100900426430036548
Patrick Boyle
Vice President
263547 D0JRECJ3EN 3987

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EXHIBIT 8
STATE or M,
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^J fiW^OMHISSIO Her of Financial Regulation
| 500 N. Calvert Street, Suite
L3& 402
Baltimore, MD 21202-3651
DEPARTMENT OF LABOR, LICENSIN
G AND REGULATION Mark Kaufman, Commission
er
FAX COVER SHEET

DIVISION OF FINANCIA
L REGULA TION
To: Caroline lacino

From: Marcia Tonkins
Financial Examiner
Of: 1st Fidelity Loan Servicing
Of: Division of Financial Regulat
ion
Phone:
Phone: 410 230-6393
Fax: 561 893 9808

Fax: 410-333-3866 or
Pages (Including Cover She 410-333-0475
etL fv,
Date: December 12, 2012

E-mail: mtonkuis@dllr.state.m
d.us
Subject: Robert and Laurie
Warwick
Complaint# M 13 1150
COMMENTS —Please rev

iew this complaint and respo
December 14, nd in writing by
2012. It is our
understanding that Chase
cancelled this loan. Therefor Home Finance
e, why is 1st Fidelity Loan
on this deb Servicing collecting
t? Please cease all foreclosu
re activities until we have
our investigation. completed
TT*
CONFIDENTIALITY NOTICE '
VTTON IN ERROR, "PLE

ASE NOTIFY US
IMMEDIATELY AND
3«£ —tSSlON TO US BY MAIL. SEND THE ORIGINAL
MESSAGE IS NOT THE INT RETURN POSTAGE IS GUARA
ENDED RECIPIENT, YOU NTEED. IF THE READER/OF
ABE HEREBY NOTIFIED THIS
DISCRIMINATION, DISCLO THAT ANY
SURE, DISTRIBUTION
OR ri-S CONTENT ARE STR AND /OR COPYING OF THI
ICTLY PROHIBITED. S COMMUNICATION
; L
Phone410.230.6I00 • Fax: 410.333.3

866/410.333.0475 -TTY Users, Ca
Toil Free: 1-888-784-0136 ll Via The Maryland Reiay Service
» www.dllr.state.md.us/fin
ance *
E-mail: finreg@dU-R.state.mp 1
Martin O'Malley, Governo .us
r • Anthony G. Brown, Lt. e
# Governor. e Leonard j. Ho
wie 111, Secre tary
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''••marylarid.gov j Facebook.com /DLlR
.Maryland \ Twitter @MD_DLLR
iOm: Jones, Kristin [mailto:kristin.tones@

mlis.state.md.us1
.Sent: Friday, November 30, 2012 5:45
PM
To: Anne 8. Norton
Subject: Warwick - mortgage issue
Anne - Thank you again for your willin

gness to help navigate mortgage issue
s for the Rob & Laurie Warwick.
I've
attacheda few relevant documents. Obviously there
are many more but i tried to include comm
Chase and First Fidelity. Specifically, unica tions from both
i included the (1) notice from Chase indica
ting that their
debt has been cancelled;
(2) followed by an email from someone at
S&A Partners / 1st Fidelity Loan Servicing
LLC informing Laurie that "upper
management" at Chase has decided that
they will not be honoring their letter of
cancellation. She indicates that
someone from Chase would call the
Warwicks and confirm that - something
that never happened; (3) followed by
another email from same individual at 1st Fidelity indicating that if
the do not receive at least 2 payments by
5, 2012 they will initiate foreclosure proce December
edings; (4) followed by a 2009 "notificati
on of loan transfer" from 1st Fidelity
indicating that they had purch ased the Warwick's loan from Chase;
and (5) followed by a 2009 tetter indica
payment arrangement. ting their
I'm afraid based on the notification of

loan transfer that Chase sold their loan
some years ago. Even so, why would
Chase cancel their debt and not Fidel
ity. Further, I question whether Chase is
somehow getting credit for a write-off
they never actually have to honor.
As you can imagine, Rob & Laurie are

at their wits' end (in addition to being
financially strapped mostly due to the
recession's impact on their small lands
caping business) and I know they will
appreciate any assistance you are able
provide. See their conta ct information below. If you or anyon to
e in your office needs to reach me, my
shows below and my cell is (443) 852-0 office contact
308. Thanks so much again. - Kristin
Laurie Warwick
443 336-4733 ceil
410 695-2977 home
Kristin F. Jones, Chief of Staff
Office of the Speaker
State House, Room H-4
Annapolis, Maryland 21401
(410)841-3916
(410) 841-3888 fax
2
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Larry Schneider
From: larry@sacapitalpartners.com
Sent: Monday, January 07, 2013 3:38 PM
To: mtonkins@dllr.state.md.us
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 1 mentioned, I am unable to discuss the particular 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 1st 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.
Per your inquiry:

My direct contact at Chase is Omar Kassem. Omar Kassem reports to Patrick Boylefwhose signature is on all of the DOJ
Debt Forgiveness Letters). Patrick Boyle reports to Mark Davis. I believe Mark Davis reports to Gary Miller. I believe
Gary Miller reports to Steven Hemperly.
• Omar Kassem, CFA

Vice President, Portfolio Manager
1820 E. Sky Harbor Circle S, Floor
Phoenix, AZ 85034
PH: 602.627.8661
Omar, kassem @ ipmoreanchase.com
• Patrick M Boyle
Vice-President, Loss Mitigation and Recovery
1820 E. Sky Harbor Circles
Phoenix, AZ 85034
Mail Code AZ1-2514
PH: 602-627-2489
patrick.m.bovle@ipmchase.com
• Mark Davis
l
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Senior Vice President, Default Operations

mark.w.davis@ipmchase.com
• Gary Miller
Senior Vice-President. Default Servicing and Housing
• Steven Hemperly
Senior Vice- President, Default Operations Management
Please let me know if I can be of any additional assistance in this matter and advise me of the outcome of your
investigation.
Please keep this email confidential and do not forward to Chase.
Sincerely,
Larry Schneider
S & A Capita! Partners
2901 Clintmoore Road, Suite 410
Tel: 561-893-9805 x 204
Fax: 561-893-9808
Cel: 305-710-4201
sacapitalpartners.com
From: Larry Schneider

Sent: Friday, September 14, 2012 4:28 PM
To: Kassem, Omar
Subject: Robert Warwick - 100900426430035543
Importance: High
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
potential problem on our hands. This is the 2nd 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 to know if this can potentially affect
hundreds of my borrowers. Was this DOJ scrubbed before being sent out?
If not, 1 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 wili 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?
Please call me to discuss.
2
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•Sincerely,
Larry Schneider
2101 NW Corporate Blvd., Suite 102
Tel: 561-893-9805x204
Fax: 561-893-9808
This email message has been delivered safely and archived online. This email system is managed by DvnamiCarc E2.
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IN THE DISTRICT COURT OF CLEVELAND COUNTY

STATE OF OKLAHOMA
FIRST FIDELITY LOAN SERVICING,
Plaintiff, JAN 0 9 2014

V
SALEH AHMED,
BEVERLY 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.
ANSWER TO PLAINTIFF'S PETITION
COMES NOW, Defendant SALEH AHMED, and Answers the Plaintiffs Petition
as follows:
1. The Defendant admits facts in paragraph one as to organization, but does
not have sufficient information to determine the authority of Plaintiff.
2. Defendant admits facts stated in paragraph two.
3. Defendant admits facts of paragraph 3 and clarifies that the Payee was
JPMorgan Chase Bank.
4. Defendant admits facts of paragraph 4.
5. Defendant denies facts of paragraph 5. The Plaintiff has shown no proof
of assignment of the note or mortgage to be effective.
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6. Defendant denies facts of paragraph 6 as to Plaintiff because Plaintiff has
not shown that it is the effective holder of the note or mortgage.
7. Defendant admits facts of paragraph 7, and adds the claim that the loan is
now canceled therefore payment is no longer required.
8. Defendant denies facts of paragraph 8 regarding the expenses Plaintiff
incurred on its own being secured by the Mortgage.
9. Defendant denies facts of paragraph 9 as to a foreclosure action brought
with proper authority.
1 0. Defendant denies allegations of paragraph 1 0.
11. Defendant admits facts of paragraph 1 1 .
1 2. Defendant admits facts of paragraph 12.
13. Paragraph 1 3 does not include any allegations against Defendant.
14. Paragraph 14 does not include any allegations against Defendant.
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.
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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
servicing settlement reached with the states and federal government.
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
the note holder.
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.
WHEREFORE, Defendants demand judgment denying Plaintiffs Petition as to
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.
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Terrell Monks OBA #17474

1840 S. Douglas Blvd.
Midwest City, Oklahoma 73130
Attorney for Defendant
Phone: (405) 733-8686
Fax: (405) 212-4403
Terrell@TerrellMonks.Com
CERTIFICATE OF MAILING
I hereby certify that on this 3 day of 2014, a true and correct copy of
the foregoing Answer to Plaintiff's Petition and Cr/ss Claim was mailed to:
James H. Thiesen
Baer, Timberlake, Coulson & Cates, P.C.
P.O. Box 18486
Oklahoma City, OK 73154-0486
Terrell Monks
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RECD JAN10 2014

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IN THE DISTRICT COURT OF CLEVELAND COUT^^^KUHOMAl S.S.

K'J j
FIRST FIDELITY LOAN SERVICING,

JAN 09 2014
Plaintiff,
V
Courtclerk RHONDA HAtL
SALEH AHMED,
BEVERLY 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.
LIMITED ENTRY OF APPEARANCE
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 Plaintiff's Petition,
and drafting initial discovery documents.
DATED this 8th day of January, 2014.
Terrell Monks, OBA # 17474

1840 S. Douglas Blvd.
Midwest City, OK 73130
Telephone: (405) 733-8686
Fax: (405) 212-4403
Ten-ell@terrellmonks.com
Attorney for Saleh Ahmed
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CERTIFICATE OF MAILING
I hereby certify that on this day of , J , 2014, a true and correct copy of the
foregoing Entry of Appearance was mailed and emailed to:
James H. Thiessen
P.O. Box 18486
j im@baer-timberlake.com
TERRELL MONKS, OBA #17474

Attorney for Defendant
1 840 S. Douglas Blvd.
Midwest City, OK 73013
Phone: (405) 733-8686
Fax: (405) 737-6507
Terrell@terrellmonks.com
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li
ISA
-.3
LAW OFFICES OF
<?r
TERRELL MONKS _j \|
J AM
1840 S. Douglas Blvd., Midwest City, OK 73130
James H. Thiessen
P.O. Box 18486
73 1 54SO406 B007
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OWED TO CHASE!
Teresa M Hancock
204 New Haven Ave Unit 8E
Derby, CT 06418-2150
Property Address: 204 New Haven Avenue 8E
Derby, CT 06418
Dear Teresa M Hancock:

All you need to do:

Sincerely,
100900427011269656
Patrick Boyle
Vice President
263549 DOJREC BK 1389

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2012 JPMorgan Chase & Co. JPMorgan Chase Bank, N.A. 17131 DOJ REC RR738 BK
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your records.

17131 DOJ REC RR738 FAQ
263549 DOCREC FAQ 1389

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Book : 6455
RECORDATION REQUESTED BY: Page : 532
S & A Capital Partners, Inc.
WHEN RECORDED MAIL TO:
S & A Capital Partners, Inc.

2101 NW Corporate Blvd., #102
SPACE ABOVE THIS LINE IS FOR RECORD

ER'S USE ONLY
ASSIGNMENT of MORTGAGE
For value received, the receipt and sufficiency of which
are hereby acknowledged, JPMORGAN CHASE BANK,
N.A.,
hereby grants, assigns and transfers to S & A CAPIT
AL PARTNERS, INC., all beneficial interest under
that certain
Mortgage for S69,390.00 dated October 20, 2007,
and executed by PATRICIA B KING, A SINGL
E WOMAN,
Grantors, to CHASE BANK USA, N.A. and recorde
d as Document No. 2007-246690, in Book xx,
Page xx, on
November 1, 2007, of Official Records in the County
Recorder's office of Volusia, State of Florida, as
described in
said Mortgage and more commonly known as 5092
Dundee Ave, De Leon Springs, FL 32130.
LEGAL DESCRIPTION: SEE ATTACHED LEGAL

DESCRIPTION AS EXHIBIT "A"
JPMORGAN CHASE BANK, N.A. sells to Assigne

e all of Assignor's right, title and interest in the
Mortgage Loan, Deed of
Trust/Mortgage and Note in "As Is" condition, with all
faults, without any recourse to Assignor whatsoever and
warranty expresse
without any
d or implied, character or nature. JPMORGAN CHASE
BANK, N.A, further makes no representations or
warranties regarding the Mortgage loan, Note or Deed
of Trust/Mortgage. Assignee confirms that it has taken
such steps as it
deems appropriate with respect to conducting due diligenc
e with respect to the status and quality of the Mortgage Loan,
and Deed of Trust/Mortgage. Note
TOGETHER with the note or notes therein described or

referred to, the money due and to become due thereon
with
interest, and all rights accrued or to accrue under said
Mortgage.
Dated: February 16, 2010

JPMori ly.A.,
M
B;
(
msteuiHent prepared by: Launi Solomon

150 W. University Dr. Floor 1, Tempe, AZ 85281
STATE OF ARIZONA
COUNTY OF MARICOPA
On 1 to 0 , before me, the undersigned Notary Public in and for

said County and State, personally appeared,
fotlTTR , personally known to me (or proved to me on the
basis of satisfactory evidence) to be the person(s)
whose name(s) is subscribed to the within instrume
nt and acknowledged to me that he/she/they execute
d the same in
his/her/their authorized capacity(ies), and that by the
signature(s) on the instrument the person(s), or entity
upon behalf of
which the person acted, executed the instrument.
WITNESS my hancLand official seat

OFFICIAL SEAL
S—
noma WENDI LYNN MILLEh
Notary Public in ana foir said County and State imi NOTARY PUBLIC - Slate ol Arizona I
MARICOPA COUNTY
My Comm. Expires May 31. 2013
WORD/NT/BANK ONE/ASSIGNMENTS/OHIO/PHX5-K
ING
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33^^623 # 2
Page : 533
Diane M. Matousek
Volusia County, Clerk of Court
EXHIBIT "A"
Lots 15 and 16, Block 12, BEARDSLEY'S DEI. EON SPRINGS, according to the Plat
thereof, as recorded
in Map Book I, Page 37, of the Public Records of Volusia County, Florida
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eaiei:i4i5-,ev-oD293-Lf§-2jepokeo£omB4np
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Loan #:
Document Prepared By:

E.Lance/NTC, 2100 Alt. 19 North,
Palm Harbor, FL 34683
(800)346-9152
When Recorded Return To:

JPMorgan Chase Bank, N.A.
C/O NTC 2100 Alt. 19 North
Palm Harbor, FL 34683
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 WHEREOF, said owner and holder has caused its presents to be executed by its VICE
PRESIDENT on \ \ /PL* 72013 (MM/DD/YYYY).
JPMORGAN CHASE BANK, N.A.
(Seal)
By:
Amy Kight
VICE PRE lENT
VicjtiiStrickland Witness is IOjpmocowcmm 1 1 r

Ms
o
EdniqueWilhams Witness '/ ?
'''tlllll'
STATE OF LOUISIANA
PARISH OF OUACHITA
On /_ >/2013 (MM/DD/YYYY), before me appeared Amy Kight, to me personally known, who did
say thai 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).
°uachita par^ chunn

Notary Public - State of LOUISIANA
Commission expires: LIFETIME
T05I31 13714 [C-l]
II
EXHIBIT C
Larry Schneider
Subject: FW: Payments (MRS SALE)
Importance: High
From: Launi L Solomon [mailto:launi.l.solomon@chase.com]

Sent: Friday, December 18, 2009 1:55 PM
To: Angelique Reynoso
Cc: Larry Schneider
Subject: Payments (MRS SALE)
I have pulled a report of the pmts due to you since the Feb sale.
There are issues due to dupe acct # project or something Larry Sandra says you know about? So some
of these accts your groups cant find under certain acct #'s because we changed theM???
Anyway, Im going thru to see what is valid and what is not - I will send updates as I know.
For your benefit, Im going thru the largest pmts first to get them going.
Here is your first one I just ordered
ACCOUNT NUMBER . 19044379

MORRISON,BRANDEN T
$20,000 pmt on 5/26/09, this was a settlment negotiated - so please close after you post this money as
a SIF.
Please let me know if you find this acct, it may be one of the ones you cant locate, but it is yours.
Loss Recovery Support Supervisor

Chase Home Finance
 480-902-6950
 602-914-7348
This transmission may contain information that is privileged, confidential, legally privileged, and/or exempt
from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any
1
disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is
STRICTLY PROHIBITED. Although this transmission and any attachments are believed to be free of any virus
or other defect that might affect any computer system into which it is received and opened, it is the
responsibility of the recipient to ensure that it is virus free and no responsibility is accepted by JPMorgan Chase
& Co., its subsidiaries and affiliates, as applicable, for any loss or damage arising in any way from its use. If
you received this transmission in error, please immediately contact the sender and destroy the material in its
entirety, whether in electronic or hard copy format. Thank you.
2
EXHIBIT D
EXHIBIT E

-------------------------------- x
S & A CAPITAL PARTNERS, INC., et al., :
:
Plaintiffs, : No. 15-cv-00293-LTS-JCF
:
- against - : NOTICE OF DEPOSITION
:
JPMORGAN CHASE BANK, N.A., et al., :
:
Defendants. :
-------------------------------- x
PLEASE TAKE NOTICE that, pursuant to Rule 30(b)(6) of the Federal Rules of Civil
Procedure, Plaintiffs, through their attorneys Chaitman, LLP, will take the deposition on oral
examination commencing at 10:00 a.m. on May 10, 2016, and at any adjourned date or time, at the
offices of Chaitman LLP, 465 Park Avenue, New York, New York 10022, of a witness (or
witnesses), designated by Defendants, who is (or are) most knowledgeable and prepared to testify
concerning the subject matter outlined in the Third Amended Complaint, and location of
documents and information responsive to the discovery demands and responses exchanged
between the parties, including, specifically, the following subject matter:
(a) Where and how particular categories of documents are located, stored and maintained,
including but by no means limited to documents in reference to
a. the plaintiffs
b. communications between Defendants or anyone acting on their behalf, and the
borrowers of loans Defendants sold to the plaintiffs
c. Defendants’ System of Records, including but not limited to the Vendor Lending
System and Mortgage Servicing Program or Platform, both active and inactive
d. All Recovery One (“RCV1”) databases and/or Recovery One “Applications”, both
active and inactive
e. the assessment and/or selection of loans to be included on Exhibit A to the MLPA
between the parties
f. Data tapes listing loans sent to Defendants on or around October 2008 through
February 2009, and the choice of which loans were included on such data tapes
g. Reasons why the data tapes did not include all requisite data such as borrowers’
names and addresses
{00019533 2 } 1
h. attempts to supply borrower information and files regarding the loans available for
sale to Plaintiffs
i. servicing of loans prior to their sale to Plaintiffs
j. the status of the loans sold to Plaintiffs at any time
k. any deviation from law, regulation, guideline or policy in servicing loans
l. Plaintiffs’ request for assignments of the notes and mortgages
m. payments received by Defendants on the loans after their sale
n. statements that Defendants were “recalling” certain loans
o. communications that certain loans were “deficiencies” including internal
documents relating to status of the loans
p. communications with Patrick Boyle regarding conversations regarding Defendants’
potential liability regarding defaulted loans on December 9, 2009
q. “forgiven loans that had previously been sold to others,” including “all
correspondence, both internal and external”
r. release of liens on properties pursuant to the “Pre-DoJ Lien Release Project” as
described in the Third Amended Complaint
s. communications with, and files sent to and received from third party collection
agencies regarding the loans
t. communications and recordkeeping regarding the RMBS settlement and National
Mortgage Settlement and Consent Judgment
(b) Defendants’ document retention policy
(c) How data is collected, stored, maintained and deleted
(d) Document retrieval processes
(e) Litigation hold procedures
(f) What is stored in individual custodians’ files, as specified in Defendants’ Responses

and Objections to Interrogatories
(g) The identity of potential additional custodians
(h) Policies and procedures regarding electronic records management
(i) Policies and procedures regarding employee use of company computers and data,
including but not limited to:
a. Desktop computers
b. Laptop computers
c. Home-based computers used for company business or communication purposes
(j) Computers currently in use and no longer in use, including:
a. Number, types and locations
{00019533 2 } 2
b. Operating systems with versions, dates of use and upgrade history

c. Application software with versions, dates of use and upgrade history
(k) Network architecture including
a. Network topology
b. File-naming conventions
c. Location-saving conventions
d. Disk or tape labeling conventions
(l) Company Email Systems and Instant Messaging Systems
(m) Company Intranets
(n) Onsite and Off-site Servers
(o) Off-site Escrow Services
(p) Archival Systems and Procedures, including disk, tape, or other media
(q) Backup Procedures, Inventories and Schedules, including Tape Reuse Cycles
(r) Disaster Recovery Systems, including power source, capacity and location
(s) Instances of computer or systems failures and subsequent data recovery efforts
(t) Online (third party hosted) repositories
(u) Portable devices,
(v) Document Management Systems
(w) Company Database and Systems Administration
PLEASE TAKE FURTHER NOTICE that the above-noticed deposition will be conducted
before a court reporter, notary public, or other person duly authorized to administer oaths under
the Federal Rules of Civil Procedure and the Local Civil Rules for the Southern District of New
York. The oral examinations will be recorded by stenographic and videographic means, and will
continue from day to day until complete.
{00019533 2 } 3
Dated: April 20, 2016 /s/ Helen Davis Chaitman

New York, New York Helen Davis Chaitman
Chaitman LLP
465 Park Avenue
Phone: (888) 759-1114
Attorneys for Plaintiffs
{00019533 2 } 4
EXHIBIT F
EXHIBIT G
EXHIBIT H
EXHIBIT I
CHAITMAN LLP
465 Park Avenue
New York, NY 10022
(888) 759-1114
TELEPHONE & FAX
Suzan arden
sarden@chaitmanllp.com
March 1, 2016
VIA EMAIL AND UPS
Christian Pistilli, Esq.

Covington & Burling LLP
One City Center
850 Tenth Street, NW
Washington, DC 20001-4956
Re: Mortgage Resolution Servicing, LLC v. JPMorgan Chase Bank, N.A., et al.
Civil Action No. 15-CV-293 (LTS) (JCF)
Dear Chris:
This letter is Plaintiffs’ first step in the meet and confer process regarding our review of
Defendants’ Objections and Responses to Plaintiffs’ First Request for the Production of
Documents to All Defendants (the “Responses”), which we received from you on February 24,
2016.
The Responses are unsatisfactory and do not come close to meeting Defendants’
obligations under the Federal Rules of Civil Procedure or otherwise. The problems with the
Responses are so large on a global scale that it is virtually impossible to tell what categories of
documents your clients are intending to withhold and for what reasons. Accordingly, Plaintiffs
request a 30(b)(6) deposition, prior to document discovery, of a representative of Defendants
who can testify to the contents of the various files and location of the categories of requested
documents. This is vital so that Plaintiffs can understand the full impact of Defendants’ refusal
to produce documents outside of those to be found in the files of 8 people, locatable by 11 search
terms (eight of which terms are mere variations of Plaintiffs’ names.) The following is a non-
exclusive list of global problems which render Chase’s responses impenetrable.
Our first global objection impacts every issue of the case and makes your discovery
responses largely incoherent in terms of what documents will be produced and what will be
withheld. It appears that, no matter how relevant the document sought, if it cannot be found
within the electronic files of the eight persons listed on your Appendix A, and does not contain
one of the eleven terms on Appendix B, Chase will not even search for it, let alone produce it.
This is grossly unreasonable for many reasons, not least because it simply cannot be determined
what documents are in those files and what documents are not. Moreover, the vast majority of
the documents we have requested are unlikely to include a version of Plaintiffs’ names, which
comprise eight out of the eleven terms you have agreed to search.
{00018853 1 }
CHAITMAN LLP Christian Pistilli, Esq.

March 1, 2016
2
Similarly, in General Objection Number 2, you have stated that Chase objects to each
request on the grounds that they might seek “electronic information from sources that are not
reasonably accessible because of undue burden or cost.” What sources? What is the undue
burden or cost and why is that burden or cost “undue” in each particular case? Which requests
does this apply to? We simply cannot tell.
Our second global objection is that Chase has completely ignored the Court’s instructions
to co-ordinate the discovery in this action with discovery in the qui tam case pending in the
District of Columbia, now captioned United States of America et al ex rel. Lawrence Schneider
v. J.P. Morgan Chase Bank, National Association, et al., 114-CV-01047-RMC (the “qui tam
Case”). Both in the Initial Pre-Trial Order and in the Court’s decision denying Defendants’
motion to transfer (Docket 75), the Court ordered the parties to coordinate discovery with the qui
tam Case to avoid duplication, both in terms of the production of documents and in terms of
depositions.
As you know, discovery is not yet under way in the qui tam Case. We anticipate that if a
witness is deposed first in this case, Defendants will argue that this witness cannot be re-
deposed in the qui tam Case. If the parties are generally to coordinate depositions to ensure that
they are not duplicated, it is of course essential to ensure that the parties have access to all the
documents they will need in order to prepare. In fact, Defendants have themselves requested, in
their initial document demands, among other things, that Plaintiffs produce documents that are
applicable to the qui tam Case, such as all documents that Plaintiffs have already provided to the
Government.
Many of your General Objections appear to be directed toward resisting the production of
documents that are also relevant in the qui tam Case although once again we cannot tell what
documents you are intending to withhold or why the objection should apply. For example, in
General Objection Number 4, you state that Chase objects to production that is “not proportional
to the needs of the case, considering the importance of the issues at stake in this action, the
amount in controversy, the parties’ relative access to relevant information, the importance of the
discovery in resolving the issues, and whether the burden or expense of the proposed discovery
outweighs its likely benefit.” Given that Chase clearly has far more access to the relevant
information than do Plaintiffs, your blanket refusal to produce any material pursuant to this
objection completely dismisses the Court’s instructions to co-ordinate discovery.
Our third global objection relates to definitions of Chase. In General Objection Number
10, you object to our Definition Number 5 of “You” “Your” and “Chase” as “overly broad” and
refuse to apply it as written. This definition was taken word for word from your definition of
“You” and “Your” in Instruction 5 in the document requests Chase served on Plaintiffs in
December. What documents are you withholding based on this re-definition and why is it
acceptable in Chase’s requests but not in Plaintiffs’?
{00018853 1 }

March 1, 2016
3
Our fourth objection relates to Chase’s refusal to provide certain responsive documents to
Requests 16, 17, 18, 21 unless Plaintiffs first provide to Chase a list of loan numbers for “loans
allegedly purchased by Chase.” You then provide Chase with an arbitrary and apparently
unreviewable ability to “determine[ ] that a given loan was not purchased by Plaintiffs” before
you will agree to query what Chase unilaterally determines is the “appropriate database(s).”
As Chase is aware, among the allegations Plaintiffs have made is that Chase failed to
meet its obligation to provide Plaintiffs with a proper Exhibit A to the MLPA (e.g. TAC ¶¶ 46-
49; 61-63), sought to recall some loans (e.g. TAC ¶ 71-74), and changed the loan numbers of
particular loans (e.g. TAC ¶ 86-87). It is Chase’s obligation to provide the list of loan numbers
that it believes it sold to Plaintiffs, not the reverse.
As you know, we have agreed upon a relatively short time frame to conduct fact
discovery. In order to be able to move forward, and so that we can reasonably present all ripe
document disputes to the Court promptly, we would like to schedule the 30(b)(6) deposition
shortly, ideally within the next three weeks. Please advise what dates would be most convenient.
Very truly yours,
/s/ Suzan Arden
Suzan Arden
SA/sh
cc: Robert Wick, Esq. (via email and UPS)

Michael Maya, Esq. (via email)
{00018853 1 }
EXHIBIT J
EXHIBIT K
CHAITMAN LLP
465 Park Avenue
New York, NY 10022
(888) 759-1114
TELEPHONE & FAX
SUZAN ARDEN
April 20, 2016
Via Email and Regular Mail
Christian Pistilli, Esq.

One City Center
850 Tenth Street, NW
Washington, DC 20001-4956
Re: Mortgage Resolution Servicing, LLC v. JPMorgan Chase Bank, N.A., et al.
Dear Chris:
This letter responds to yours, dated March 16, 2016, with regard to Defendants’
Objections and Responses to Plaintiffs’ First Request for the Production of Documents to All
Defendants (the “Responses”), which we received from you on February 24, 2016.
As we explained in my letter dated March 1, 2016, the Responses are unsatisfactory and
do not come close to meeting Defendants’ obligations under the Federal Rules of Civil Procedure
or otherwise.
First, with regard to your insistence that Plaintiffs “must first provide Chase with the loan
numbers for the loans they purchased,” it is nonsense for Chase to claim that it does not know
what loans it sold. Chase had the obligation to provide Plaintiffs with a proper Exhibit A to the
MLPA. As such, it was Chase who had the obligation to provide Plaintiffs with a list of the
loans that were encompassed within the MLPA, not Plaintiffs. Further, our clients have on
several occasions outside of this lawsuit provided your clients with a list of loans. As such,
Chase is certainly well aware of the loans that it sold and the discovery that it is required to
make.
Moreover, it is unconscionable for Chase to contend, as it does in the Responses that,

once Plaintiffs provide a complete list of loans that Chase sold it, Chase may still arbitrarily and
apparently unreviewably “determine[ ] that a given loan was not purchased by Plaintiffs” before
you will agree to query what Chase unilaterally determines is the “appropriate database(s).” This
is unacceptable. At a minimum, your clients must provide the requested discovery on all of the
loans that our clients have previously identified.
{00019530 1 }

April 20, 2016
Page 2
Second, as we have already stated, you have provided a very limited list of custodians
and potential search terms. Your agreement to "discuss with us" whether there are other
custodians and search terms that could elicit responsive materials is insufficient. We do not
know the scope of the custodians' files, the locations your clients store responsive documents, or
the methods and expense of conducting searches. Accordingly, we enclose a Rule 30(b)(6)
deposition notice that will allow us to explore these areas. Please advise us who your clients will
produce for this deposition.
Third, it is clear from your letter that we are at an impasse regarding the scope of
discovery. Your refusal to contemplate producing any documents beyond what you consider to
be the scope of the breach of contract claims in this case is unacceptable. There has been no stay
of discovery in either this case or in the qui lam case pending in the District of Columbia, now
captioned United States of America et al ex rel. Lawrence Schneider v. J.P. Morgan Chase Bank,
National Association, el al., 1 14-CV-01047-RMC (the "qui tarn Case").
Moreover, you do not articulate how the documents requested (or, indeed, which
documents, relate only to the qui tarn Case, neither do you provide any articulable basis for doing
so. You do not dispute that if a witness is deposed first in this case, Defendants will argue that
this witness cannot be re-deposed in the qui tarn Case. If the parties arc generally to coordinate
depositions to ensure that they are not duplicated, it is of course essential to ensure that the
parties have access to all the documents they will need in order to prepare. Moreover, at a
minimum, Chase opened the door to production of such documents with Defendants' own
request, in their initial document demands, among other things,
that Plaintiffs produce
documents that are applicable to the qui tarn Case, such as all documents that Plaintiffs have
already provided to the Government.
Finally, we have not received a date from you on which you will commence producing
those documents that you do not contest. Even though there are substantial issues to be resolved,
we have limited time to conduct fact discovery and there is no reason to delay production of the
documents your client has agreed to produce without dispute.
I look forward to hearing from you shortly with regard to these issues, and am available
to conduct the next stage in our meet and confer process by telephone on most days this and next
week.
Very truly yours,
Suzan Arden
SA:leb
cc: Robert Wick, Esq.

Michael Maya, Esq.
{00019530 1 }
EXHIBIT L

From: Suzan Arden
Sent: Friday, April 22, 2016 7:01 PM
To: Pistilli, Christian
Cc: Maya, Michael; Helen Chaitman; Lance Gotthoffer
Subject: RE: Mortgage Resolution Servicing, LLC v. JPMorgan Chase Bank, N.A. Civil Action No. 15‐CV‐293
‐ deposition notices

Chris:

We can be available for a global meet‐and‐confer, but are not prepared to do it piecemeal. The issues
we raised in my letter are not new. We need to discuss all of the outstanding discovery issues, not
simply those that you wish to raise. You have not yet provided a date by which Chase will produce even
those documents that they do not contest.

Please let me know when next week we can sit down and talk about all of the issues raised in my letter
as well as our deposition notices.

Regards,

Suzy Arden

Suzan Arden
Chaitman LLP
465 Park Avenue
Phone: (888) 759‐1114
________________________________________
From: Pistilli, Christian [cpistilli@cov.com]
Sent: Friday, April 22, 2016 5:46 PM
To: Suzan Arden
Cc: Maya, Michael

Suzy,

Please let me know a time on Monday that you are available for a meet and confer regarding plaintiffs’
deposition notices.

Best,

Christian Pistilli

One CityCenter, 850 Tenth Street, NW
Washington, DC 20001‐4956
T +1 202 662 5342 | cpistilli@cov.com
www.cov.com

[cid:image001.png@01D19CBE.E3F5A160]
This message is from a law firm and may contain information that is confidential or legally privileged. If
you are not the intended recipient, please immediately advise the sender by reply e‐mail that this
message has been inadvertently transmitted to you and delete this e‐mail from your system. Thank you
for your cooperation.

From: Lourdes Blanco [mailto:lblanco@chaitmanllp.com]
Sent: Wednesday, April 20, 2016 10:53 AM
To: Pistilli, Christian; Wick, Robert; Maya, Michael; Levitz, Philip
Cc: Helen Chaitman; Lance Gotthoffer; Suzan Arden
Subject: Mortgage Resolution Servicing, LLC v. JPMorgan Chase Bank, N.A. Civil Action No. 15‐CV‐293 ‐
deposition notices

Dear Counsel:
Please see attached as PDF files Suzan Arden’s letter of today’s date along with 30(b)(6) and deposition
notices.

Thank you.

Lourdes Blanco
Chaitman LLP
465 Park Avenue
lblanco@chaitmanllp.com<mailto:lblanco@chaitmanllp.com>
Office: (888) 759‐1114 ext. 3


EXHIBIT M


From: Suzan Arden
Sent: Friday, April 29, 2016 9:06 AM
Cc: Maya, Michael

Chris:

We are also eager to meet and confer with you. However, as I have stated, we have multiple issues on
which we need to confer, as set forth in my letter. We stand ready to meet and confer on all issues and
have repeatedly asked you to provide us with your availability. We are not willing to address only those
issues that you need to address while leaving the issues we need to address in abeyance until you are
willing to respond to them. To date, you have not even bothered to indicate when you will be ready to
do that. It is also outrageous that you have not yet produced a single document, not even any of the
documents that you do not contest should be produced, while we have already produced thousands.

In order to resolve this, we will defer the 30(b)(6) date for a reasonable period of time, from May 10
until May 31, to allow the parties to meet and confer on all issues. Please now provide your availability
to do so.

With regard to your position on the depositions, while we are willing to be flexible on dates, the location
may also be something that we will ask the Court to resolve.

I look forward to hearing from you with your availability for a meet and confer on all of our discovery
issues.

Suzan Arden
Chaitman LLP
465 Park Avenue
Phone: (888) 759‐1114
________________________________________
Sent: Thursday, April 28, 2016 7:36 PM
To: Suzan Arden
Cc: Maya, Michael
Subject: Re: Mortgage Resolution Servicing, LLC v. JPMorgan Chase Bank, N.A. Civil Action No. 15‐CV‐293

Suzy,

This is to inform you that (absent an agreement between the parties) we intend to file, in advance of the
notice date, a motion for a protective order regarding plaintiff's 30(b)(6) notice, which fails to give
reasonable notice, is overbroad, and is not reasonably particularized (among other things).

We remain eager to meet and confer with you on this issue. Please let us know your availability.

On the individual depositions, we will get you dates that work for depositions in Phoenix (where the
witnesses are located).

Chris

Sent from my iPhone

> On Apr 22, 2016, at 4:03 PM, Suzan Arden <sarden@chaitmanllp.com> wrote:
>
> Chris:
>
> We can be available for a global meet‐and‐confer, but are not prepared to do it piecemeal. The issues
we raised in my letter are not new. We need to discuss all of the outstanding discovery issues, not
simply those that you wish to raise. You have not yet provided a date by which Chase will produce even
those documents that they do not contest.
>
> Please let me know when next week we can sit down and talk about all of the issues raised in my letter
as well as our deposition notices.
>
> Regards,
>
> Suzy Arden
>
> Suzan Arden
> Chaitman LLP
> 465 Park Avenue
> New York, New York 10022
> sarden@chaitmanllp.com
> Phone: (888) 759‐1114
> ________________________________________
> From: Pistilli, Christian [cpistilli@cov.com]
> Sent: Friday, April 22, 2016 5:46 PM
> To: Suzan Arden
> Cc: Maya, Michael
> Subject: RE: Mortgage Resolution Servicing, LLC v. JPMorgan Chase Bank, N.A. Civil Action No. 15‐CV‐
293 ‐ deposition notices
>
> Suzy,
>
> Please let me know a time on Monday that you are available for a meet and confer regarding plaintiffs’
deposition notices.
>
> Best,
>
> Christian Pistilli
>
> Covington & Burling LLP
> One CityCenter, 850 Tenth Street, NW
> Washington, DC 20001‐4956
> T +1 202 662 5342 | cpistilli@cov.com
> www.cov.com
>
> [cid:image001.png@01D19CBE.E3F5A160]
> This message is from a law firm and may contain information that is confidential or legally privileged. If
>
>
>
>
>
> From: Lourdes Blanco [mailto:lblanco@chaitmanllp.com]
> Sent: Wednesday, April 20, 2016 10:53 AM
> To: Pistilli, Christian; Wick, Robert; Maya, Michael; Levitz, Philip
> Cc: Helen Chaitman; Lance Gotthoffer; Suzan Arden
> Subject: Mortgage Resolution Servicing, LLC v. JPMorgan Chase Bank, N.A. Civil Action No. 15‐CV‐293 ‐
deposition notices
>
> Dear Counsel:
> Please see attached as PDF files Suzan Arden’s letter of today’s date along with 30(b)(6) and
deposition notices.
>
> Thank you.
>
> Lourdes Blanco
> Chaitman LLP
> 465 Park Avenue
> New York, New York 10022
> lblanco@chaitmanllp.com<mailto:lblanco@chaitmanllp.com>
> Office: (888) 759‐1114 ext. 3
>
> <image001.png>

EXHIBIT N


From: Suzan Arden
Sent: Friday, May 20, 2016 5:43 PM
Cc: Helen Chaitman; Lance Gotthoffer; Brent Tantillo
Subject: RE: MRS v. Chase

Chris:

Further to your email below and to our telephone conversation yesterday afternoon:

1. I understand from our discussions that Chase's intention to produce documents subject to a
protective order does not encompass all documents, merely those to which Chase has raised no
objections. We do not believe that a protective order is necessary or appropriate beyond the scope of
information that would otherwise be protected by law, or potentially to cover personally intimate
material (although this would only include matters that are truly personal, and not related to any form
of business dealings or personal embarrassment that might result from revelations about such business
dealings). We have attached a redlined version of your protective order that encompasses those
provisions we find acceptable.

2. Your offer to provide Plaintiffs with "information from Chase databases regarding loans that plaintiff
purchased from Chase" does not comply with your discovery obligations. You will note that our
requests require the production of a variety of information regarding loans, many of which seek
information regarding loans set forth on the "Corrupted List" as defined in the TAC (Requests 16‐18, 21).
Other requests seek loan information regarding all of the loans about which Chase sent debt forgiveness
letters (Request 28) and the loans regarding which Chase released liens pursuant to the Post DoJ Lien
Release Project (Request 31) . By definition, these do not require a list of loan numbers from the
Plaintiffs.

Accordingly, to the extent Plaintiffs have lists of loans available, as with those attached to the TAC,
these consist of names, properties, etc. and, most importantly, borrowers' social security numbers. Our
claims include allegations that Chase changed certain loan numbers and otherwise did not provide full
and complete lists of loans to the Plaintiffs. Chase has acknowledged that it changed certain account
numbers, particularly with respect to the loans encompassed in the sale to MRS. As such, even to the
extent that Plaintiffs have a list of loan numbers, it would not necessarily pull up all the relevant loans in
Chase's databases, due to Chase's actions. We are therefore providing Chase with the social security
numbers of the borrowers, as Chase provided them to us, across all the loans, broken out by First
Fidelity, S&A Capital, and MRS. Some are partial lists. With respect to the MRS loans, we are providing
you with the same list that Eddie Guerrero provided to the Plaintiffs. Chase's should be able to identify
the loans from these lists. They are attached. Please advise asap whether you are willing to work with
these lists.

3. Your statement is hedged in by caveats such as "relevant, reasonably available loan data for loans
that are at issue in this litigation." Moreover, to the extent that the ownership of a loan is in dispute, as
where the Plaintiffs contend that Chase sold it to them and Chase contends it did not, those loans are
very much the subject of this lawsuit. It is therefore mandatory that information regarding those loans
be produced.

4. The depositions can be conducted in Phoenix. This is not a waiver of any of Plaintiffs' rights with
regard to the location of other depositions.

5. We disagree regarding the email collection and production protocol. We provided a list of
custodians and search terms as part of our document demands. We maintain that there are multiple
other custodians whose records should be searched and that the appropriate searches should include a
much broader area than the very few custodians and terms that you propose. We may be able to make
more progress on this issue when we have resolved the question of the scope of discovery.

6. We look forward to receiving your statement regarding what part of the 30(b)(6) notice you deem
appropriate. We agree that it makes sense to discuss this with you further so we will set the date for
the protective order for June 17 to allow those discussions to play out.

7. We agree that the parties should contact Judge Francis regarding meeting dates. We do not agree
that this should be put off until September, since at this point fact discovery is scheduled to close on or
around that time. July would be more appropriate.

When we spoke yesterday afternoon, we acknowledged that the question of the scope of discovery will
most likely have to be resolved by the Court. We will discuss briefing schedules for a motion and, as
necessary, cross‐motions.

Suzy

Suzan Arden
Chaitman LLP
465 Park Avenue
Phone: (888) 759‐1114
________________________________________
Sent: Friday, May 13, 2016 5:32 PM
To: Suzan Arden
Cc: Maya, Michael
Subject: MRS v. Chase

Suzy,

This is to follow up on our meet‐and‐confer call yesterday regarding discovery and other issues in the
MRS case.

1. We told you that Chase is prepared to produce substantially all of the documents it has committed to
producing within one week of the entry of an appropriate protective order. You agreed to provide us
with a mark‐up to Chase’s proposed protective order, so that we can determine whether the parties can
reach an agreement on its terms.

2. As you know, Chase has offered to provide plaintiff with information from Chase databases regarding
loans that plaintiff purchased from Chase if/when plaintiffs provides Chase with a list of loan numbers.
To date, plaintiffs have not provided a list of loan numbers to Chase for purposes of beginning that
process. In our call, you referenced Exhibits 1 and 2 of the amended complaint. We have reviewed
those exhibits, and they do not include loan numbers. Chase remains ready to begin the process of
collecting data regarding the loans at issue in this case promptly upon receipt from plaintiffs of a list of
loan numbers.

3. You also objected to what you termed Chase’s unilateral ability to withhold loan‐related data in the
event that a loan was not actually sold to plaintiffs by Chase. We suggested that this issue would be
best resolved through the meet‐and‐confer process, if and when an issue arises as to whether plaintiffs
are entitled to data for a particular loan. Chase has every intention of producing relevant, reasonably
available loan data for loans that are at issue in this litigation. However, Chase needs to have some
ability to confirm that a loan has a nexus to this case before it can provide that customer data to
plaintiffs. We do not expect this to be a major issue in practice, and again suggest that any issues would
be best resolved by meeting and conferring regarding any loans for which there is a disagreement.

4. You will let us know whether plaintiffs agree to move forward with the depositions of Ms. Solomon
and Mr. Boyle in Phoenix, where they live and work. If and when we hear from you that the depositions
will go forward in Phoenix, we will work to identify deposition dates. If you do not agree to go forward
in Phoenix, the court will need to resolve the deposition location issue before we can discuss dates.

5. Chase believes that the email collection and production protocol outlined in its responses to plaintiffs’
document requests fully satisfies its obligations under Rule 26. That said, Chase remains willing to meet
and confer regarding additional custodians or search terms that plaintiffs believe are appropriate. You
did not propose any additional search terms or custodians in our call.

6. Unless substantially modified, we told you that Chase intends to seek a protective order regarding
plaintiffs’ 30(b)(6) notice. The notice, among other things, is vague, overbroad, unduly burdensome,
seeks information not relevant to plaintiffs’ claims, and does not specify the topics for examination with
reasonable particularity. You asked us to tell you in writing the topics to which Chase does not object.
We will send you a response on that after conferring with our client.

7. We discussed the deadline in the scheduling order to begin settlement talks with the Magistrate. We
propose a joint letter to the court seeking to re‐set that deadline to sometime in September. Please let
us know if you agree.

We look forward to your response.

Regards,

Christian Pistilli

One CityCenter, 850 Tenth Street, NW
Washington, DC 20001‐4956
T +1 202 662 5342 | cpistilli@cov.com
www.cov.com

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EXHIBIT O


-------------------------------- x
S & A CAPITAL PARTNERS, INC., et al., :
:
Plaintiffs, : No. 15-cv-00293-LTS-JCF
:
- against - :
:
JPMORGAN CHASE BANK, N.A., et al., :
:
Defendants. :
-------------------------------- x
PLAINTIFFS’ REVISED OBJECTIONS AND RESPONSES TO DEFENDANTS’

FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
Pursuant to Federal Rules of Civil Procedure 26 and 34, Plaintiffs S&A Capital Partners,
Inc. (“S&A”), Mortgage Resolution Servicing, LLC (“MRS”) and 1st Fidelity Loan Servicing,
LLC (“1st Fidelity”) hereby submit their Revised Objections and Responses to Defendants
JPMorgan Chase Bank, N.A., JPMorgan Chase & Co., and Chase Home Finance LLC
(collectively, “Defendants” or “Chase”) First Request for Production of Documents (the
“Requests”).
GENERAL OBJECTIONS
Plaintiffs respond to the Requests set forth below subject to the following General
Objections:
1. Plaintiffs anticipate producing documents in response to the Requests on a rolling
basis, commencing on or around March 10, 2016.
2. Plaintiffs object to the Requests, including the Definitions and Instructions, to the
extent that they seek the production of documents or information that exceeds the scope of that set
forth in the Federal Rules of Civil Procedure, Local Civil Rules, and Individual Rules and Practices
of Judge Swain and/or Magistrate Judge Francis.
{00018854 1 }
3. Plaintiffs object to the Requests to the extent that they seek information that may
be protected from disclosure by the attorney-client or other privileges, or the work product
doctrine, or to the extent that they call for the disclosure of confidential or proprietary information,
trade secrets or other sensitive information.
4. The term “non-privileged” as used in each specific Response shall encompass
documents that are protected from disclosure by the attorney-client or other privileges and the
work product doctrine.
5. Plaintiffs object to the Requests to the extent that they seek opinion that is the
proper subject of expert testimony. Such material, if otherwise discoverable, will be provided at
the appropriate time in the appropriate context. In every response submitted hereto, no opinion
that is the proper subject of expert testimony will be produced at this time.
6. Plaintiffs object to the Requests to the extent that they seek information and
material regarding experts that is beyond the scope permitted by the Federal Rules of Civil
Procedure, Local Civil Rules, and Individual Rules and Practices of Judge Swain and/or Magistrate
Judge Francis.
7. Plaintiffs object to the Requests to the extent that they are duplicative.
8. Plaintiffs object to the Requests to the extent that they are ambiguous, vague,
overbroad, unduly burdensome, oppressive, designed to harass, or not proportional to the needs of
the case, the resources of the parties and to the extent that they do not take into account the relative
access of the parties to relevant information.
9. By responding to the Requests, Plaintiffs do not adopt the definitions given within,
or concede that the documents demanded are relevant to the subject matter of the lawsuit or the
claims and defenses, nor do they concede that the requests are proportional to the needs of the
{00018854 1 } 2

case, the resources of the parties or take into account the relative access of the parties to relevant
information.
10. All responses submitted herein are based on the present knowledge, information
and belief of Plaintiffs and are provided subject to such information as may be recalled or produced
in the future. Plaintiffs reserve the right to revise or amend their responses as more information
becomes known.
SPECIFIC OBJECTIONS AND RESPONSES
Subject to and without waiving the General Objections set forth above, and the Specific
Objections set forth within each response, Plaintiffs hereby respond to the Requests as follows:
Request No. 1
All documents that you may rely upon to support your claims or defenses in this action,
irrespective of time period.
Response to Request No. 1
Plaintiffs object to this Request on the grounds that it is overbroad, potentially subject to
the work product doctrine and impossible to ascertain at this stage of the case what documents that
Plaintiffs “may” rely upon. Subject to and without waiving the General Objections, Plaintiffs will
produce non-privileged documents that are responsive to this Request.
Request No. 2
All documents referenced or described in Your Rule 26(a)(1) initial disclosures, as they
may be amended from time to time, irrespective of time period.
Subject to and without waiving the General Objections, Plaintiffs will produce non-
privileged documents that are responsive to this Request.
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Request No. 3
All documents upon which any allegations in the Third Amended Complaint are based,
including any documents referenced or relied upon therein, irrespective of time period.
Request No. 4
A copy of the MMLSA, the MLPA, the individual note sale agreements referenced in
paragraph 15 of the Third Amended Complaint, and any other contract between You and Chase,
together with any exhibits, attachments or amendments thereto, irrespective of time period.
Request No. 5
All documents relating to any alleged conduct or misconduct on the part of Chase that falls
within the scope of the Third Amended Complaint, including but not limited to documents that
may undermine or disprove the allegations of the TAC, irrespective of time period.
Plaintiffs object to this Request on the grounds that it is overbroad and requires a
determination that is subject to the work product doctrine. Subject to and without waiving the
foregoing and the General Objections, to the extent that the Request is interpreted to mean
documents that refer to, describe, were prepared or used as part of, or themselves constitute such
conduct or misconduct, Plaintiffs will produce non-privileged documents that are responsive to
this Request.
{00018854 1 } 4

Request No. 6
All organizational charts covering the period from April 1, 2005 to the present for Plaintiffs
S&A Capital Partners, Inc., Mortgage Resolution Servicing, LLC, 1st Fidelity Loan Servicing,
LLC, and each of their predecessors, successors, divisions, subsidiaries, and affiliates; or (if such
organizational charts do not exist) documents sufficient to identify each of Plaintiffs’ employees,
officers and agents, including but not limited to their job titles and duties, in the period from April
1, 2005 to the present.
Plaintiffs object to this Request on the grounds that it is overbroad and unduly burdensome
both as to time period and scope and seeks information that is not relevant to the issues in this
case. Plaintiffs further object to this Request on the grounds that the information sought, to the
extent it is relevant, is more properly the subject of a narrowly tailored interrogatory. Subject to
and without waiving the foregoing and the General Objections, Plaintiffs state that there are no
documents that are responsive to this Request.
Request No. 7
All documents relating to communications between You and Chase or any current or
former employees of Chase regarding this lawsuit, mortgage servicing, mortgage debt collection,
and/or the actual or potential purchase of residential mortgage loans.
Plaintiffs object to this Request on the grounds that it is overbroad, unduly burdensome
and to the extent that it seeks documents that are not related to the issues in this case. Subject to
and without waiving the foregoing and the General Objections, and to the extent that the Request
is interpreted to encompass communications between Plaintiffs and Chase and/or its current or
former employees, or documents exchanged as part of communications, or describes or discusses
such communications, Plaintiffs will produce non-privileged documents that are responsive to this
Request.
{00018854 1 } 5

Request No. 8
All documents relating to any residential mortgage debt that You purchased from Chase,
including but not limited to purchase or bid agreements, data tapes, offers to purchase or sell loans,
promissory notes, assignments of interest, loan history documents, and any communications
regarding that debt.
Request No. 9
All documents relating to communications regarding the MMLP, the MMLSA, and any
other loan or debt sale agreements between You and Chase, including but not limited to
communications with Chase and/or with the borrowers on the loans that You acquired pursuant to
the MLPA or the MMLSA.
and to the extent that it seeks documents that are not related to the issues in this case. Plaintiffs
further object to this Request to the extent that it seeks documents that may be protected from
discovery by the attorney client privilege or work product doctrine. Subject to and without waiving
the foregoing and the General Objections, and to the extent that the Request is interpreted to
encompass communications between Plaintiffs and Chase and/or its current or former employees,
or documents exchanged as part of communications, or describes or discusses such
communications, Plaintiffs will produce non-privileged documents that are responsive to this
Request.
Request No. 10
All documents relating to the MLPA, the MMLSA, and any other loan or debt sale
agreements between You and Chase, including but not limited to the alleged negotiation and
formation of the contracts, the alleged terms of the contracts, Chase’s alleged breaches of the
contracts, and the harm that You allegedly suffered as a result of the alleged breaches.
{00018854 1 } 6

the foregoing and the General Objections, Plaintiffs will produce non-privileged documents that
are responsive to this Request.
Request No. 11
All documents relating to Your efforts to collect on loans acquired pursuant to the MLPA,
the MMLSA, or any other loan or debt sale agreements between You and Chase, including the
revenues, payments, and collections You received on those loans.
Request No. 12
Documents sufficient to show, from April 1, 2005 to the present, the number of mortgage
loans and the amount of mortgage loan debt that You purchased from Chase, Your recovery and
realization rates on that debt, Your costs of servicing those mortgage loans, and Your revenues
and profits from servicing those mortgage loans.
{00018854 1 } 7

Plaintiffs object to this Request on the grounds that it is overbroad both in scope and in
timeframe, unduly burdensome and to the extent that it seeks documents that are not related to the
issues in this case. Plaintiffs further object to this Request to the extent that it seeks documents
that may be protected from discovery by the attorney client privilege or work product doctrine.
Subject to and without waiving the foregoing and the General Objections, Plaintiffs will produce
non-privileged documents that are responsive to this Request.
Request No. 13
Documents sufficient to show, from April 1, 2005 to the present, the number of mortgage
loans and the amount of mortgage loan debt that You purchased from any source other than Chase,
Your recovery and realization rates on that debt, Your costs of servicing those mortgage loans, and
Your revenues and profits from servicing those mortgage loans.
Plaintiffs object to this Request on the grounds that it is overbroad, unduly burdensome,
designed to harass, and seeks documents that are not related to the issues in this case. Plaintiffs
discovery by the attorney client privilege or work product doctrine. Plaintiffs further object to this
Request on the grounds that it seeks documents that are not proportional to the needs of the case,
or the resources of the parties. Subject to and without waiving the foregoing and the General
Objections, Plaintiffs will produce non-privileged documents that summarize this information,
should any such documents exist.
Request No. 14
All documents relating to any civil, criminal, or administrative complaints filed against
You or to any governmental or regulatory investigations regarding Your mortgage loan servicing
business.
{00018854 1 } 8

Plaintiffs object to this Request to the extent that it seeks documents that are not related to
Defendants’ wrongdoing, or even to the loans purchased from Defendants, or the issues in this
case. Subject to and without waiving the foregoing and General Objections, Defendants will
produce non-privileged documents that are responsive to this Request and that relate to loans that
are the subject of this case.
Request No. 15
All documents relating to communications between You and any government regulators or
authorities regarding Chase, including but not limited to any communications with government
regulators related to the allegations in paragraph 145 of the TAC that Plaintiffs “face[d] the ire of
governmental entities.”
Plaintiffs note that this Request encompasses documents that are relevant to the lawsuit
now captioned United States of America et al ex rel. Lawrence Schneider v. J.P. Morgan Chase
Bank, National Association, et al., 114-CV-01047-RMC, United States District Court for the
District of Columbia and any prior caption (the “Qui Tam Case”). This Court has ordered the
parties to co-ordinate discovery in this and the Qui Tam Case. Subject to the General Objections,
Plaintiffs will produce non-privileged documents that are responsive to this Request, but further
note that their production is applicable to both cases and such documents will not be re-produced
in the Qui Tam case.
Request No. 16
All documents relating to Chase’s Systems of Records for mortgage loans, including but
not limited to the RCV1 System of Records referenced in paragraph 60(g) of the TAC.
Plaintiffs object to this Request on the grounds that it does not take into account the relative
access of the parties to relevant information. Such documents are in the possession, custody and
{00018854 1 } 9

control of Defendants and are the subject of discovery in this case. Subject to and without waiving
Request No. 17
All documents relating to Chase’s alleged violations of federal, state and local laws and
regulations, including alleged violations relating to the proper servicing of mortgage loans,
including but not limited to documents regarding how (if at all) Chase’s alleged conduct harmed
You.
Plaintiffs object to this Request on the grounds that it is duplicative. Plaintiffs note that
this Request encompasses documents that are relevant to the Qui Tam Case. This Court has
ordered the parties to co-ordinate discovery in this and the Qui Tam Case. Subject to the General
Objections, Plaintiffs will produce non-privileged documents that are responsive to this Request,
but further note that their production is applicable to both cases and such documents will not be
re-produced in the Qui Tam Case. Further, Plaintiffs will not duplicate the production of
documents that have already been produced in response to other Requests.
Request No. 18
All documents relating to Chase’s alleged violations of any agreements with federal and
state governments, including the National Mortgage Settlement and the RMBS Settlement
referenced in paragraphs 146-47 of the TAC, including but not limited to documents regarding
how (if at all) Chase’s alleged conduct harmed You.
{00018854 1 } 10

Request No. 19
All documents relating to the allegations in paragraph 151 of the TAC that “(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 MRD; (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 [sic] MRS an uncorrupted data tape 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 consumer protection laws.” .
Request No. 20
All documents relating to Your allegations in paragraphs 157 and 162 of the TAC that
Chase accepted and retained payments it received from borrowers and/or insurance companies on
loans it had sold to You.
Plaintiffs object to this Request to the extent that it is duplicative of Request No. 19 or
other Requests. Subject to and without waiving the foregoing and General Objections, Plaintiffs
{00018854 1 } 11

will produce non-privileged documents that are responsive to this Request but will not duplicate
the production of documents already produced in response to other Requests, including but not
limited to Request No. 19.
Request No. 21
All documents relating to Your allegations in paragraphs 61 through 64 of the TAC that
Chase misrepresented the quantity, value and principal balances of loans sold to You.
limited to Request No. 19. .
Request No. 22
Chase failed to provide You with assignments of notes and mortgages.
limited to Request No. 19..
Request No. 23
Chase converted payments from borrowers whose loans it had sold to You.
{00018854 1 } 12

Plaintiffs object to this Request to the extent that it is duplicative of Requests No. 19 and
20 or other Requests. Subject to and without waiving the foregoing and General Objections,
Plaintiffs will produce non-privileged documents that are responsive to this Request but will not
duplicate the production of documents already produced in response to other Requests, including
but not limited to Request No. 19 and 20.
Request No. 24
Chase recalled valuable loans sold under the MLPA.
limited to Request No. 19..
Request No. 25
All documents relating to Your allegations in paragraphs 78 through 83 of the TAC

regarding MRS’s efforts to mitigate its damages.
Request No. 26
All documents relating to the “post sale misconduct” referenced in paragraphs 84 through
91 of the TAC.
{00018854 1 } 13

Request No. 27
All documents relating to allegations in the TAC regarding alleged fraud,

misrepresentation or concealment by Chase, including but not limited to the allegations included
in paragraphs 61-64, 178, 181 and 212 of the TAC.
Plaintiffs object to this Request to the extent that it is duplicative of Requests No. 19 or 21
or other Requests. Subject to and without waiving the foregoing and General Objections, Plaintiffs
limited to Request No. 19 or 21.
Request No. 28
All documents relating to the “Forgiveness Letters” referenced in paragraphs 103-31 of the
TAC, including but not limited to communications between or among You, borrowers, and Chase
regarding the “Forgiveness Letters,” Chase’s offers to buy back loans impacted by the
“Forgiveness Letters,” and Your responses to Chase’s offers.
Plaintiffs object to this Request to the extent that it does not accurately reflect the content
of the TAC. Subject to and without waiving the foregoing and General Objections, Plaintiffs will
produce non-privileged documents that are responsive to this Request.
Request No. 29
For each borrower to whom You allege or have alleged that Chase improperly sent
“Forgiveness Letters,” including but not limited to Robert W. and Lauren D. Warwick, Saleh and
Beverly Ahmed, Teresa M. Hancock-Roberts, George and Theresa Lawwill, Jacob Rossatto and
Miriam Alvarez, Matthew Di Minno, Yvonne and Edward Harrity, William and Laura Spence,
{00018854 1 } 14

Vito and Nicolette Derosa, and Marvin and Cassandra Cornish, all documents regarding that
borrower, including but not limited to Your communications with the borrower and any files that
You maintain regarding the borrower or the borrower’s mortgage loan debt.
Plaintiffs object to this Request on the grounds that the full extent of the borrowers to whom
Defendants improperly sent “Forgiveness Letters” is within the knowledge of Defendants, not
Plaintiffs, and is the subject of discovery. Plaintiffs’ response to this Request may not be construed
in any way to limit the number of recipients of the “Forgiveness Letters” improperly sent by
Defendants. Subject to and without waiving the foregoing and General Objections, Plaintiffs will
produce non-privileged documents that are responsive to this Request, and to the extent that it is
presently aware of the recipient’s identity.
Request No. 30
All documents relating to the alleged ‘1st Lien Alternative Foreclosure Process” and the
“Pre DOJ Lien Release Project” referenced in paragraphs 132 through 134 of the TAC.
Plaintiffs object to this Request on the grounds that the documents that are requested
primarily include documents belonging to and in the custody of Defendants, not Plaintiffs, and that
are the subject of discovery. Subject to and without waiving the foregoing and General Objections,
Plaintiffs will produce non-privileged documents that are responsive to this Request.
Request No. 31
All documents relating to Chase’s alleged release of liens on properties that Chase had
previously sold to Plaintiffs, including but not limited to all documents reflecting the alleged
resulting “losses” and “damage” to Plaintiffs referenced in paragraphs 144-45 of the TAC, and all
documents regarding communications between or among You, borrowers, and Chase regarding
these lien releases.
{00018854 1 } 15

Plaintiffs object to this Request on the grounds that the full extent of the borrowers whose
liens Defendants improperly released is within the knowledge of Defendants, not Plaintiffs, and is
the subject of discovery. Plaintiffs’ response to this Request may not be construed in any way to
limit the number of borrowers whose liens Defendants improperly released. Subject to and without
waiving the foregoing and General Objections, Plaintiffs will produce non-privileged documents
that are responsive to this Request, and to the extent that it is presently aware of the borrower’s
identity.
Request No. 32
For each property with respect to which You allege that Chase improperly discharged a
lien, all documents regarding the property and the borrower on the loan secured by the property,
including but not limited to Your communications with the borrower and any files that You
maintain regarding the property, the borrower, or the borrower’s mortgage loan debt.
other Requests. Plaintiffs further object to this Request on the grounds that the full extent of the
borrowers whose liens Defendants improperly released is within the knowledge of Defendants, not
Plaintiffs, and is the subject of discovery. Plaintiffs’ response to this Request may not be construed
in any way to limit the number of borrowers whose liens Defendants improperly released. Subject
to and without waiving the foregoing and General Objections, Plaintiffs will produce non-
privileged documents that are responsive to this Request, and to the extent that it is presently aware
of the borrower’s identity but will not duplicate the production of documents already produced in
response to other Requests, including but not limited to Request No. 32.
{00018854 1 } 16

Request No. 33
All documents relating to the allegations in the TAC, including but not limited to paragraph
145, that Chase “destroyed the Plaintiffs’ relationships with the borrowers whose loans Plaintiffs
had purchased” and “caused substantial damage to the Plaintiffs’ business reputation,” including
but not limited to any documents reflecting or quantifying the damages allegedly caused by the
alleged harm to Plaintiffs’ business reputation.
Plaintiffs object to this Request to the extent that it is duplicative. Subject to and without
that are responsive to this Request but will not duplicate the production of documents already
produced in response to other Requests.
Request No. 34
All documents relating to the members of the RICO “enterprise” alleged in the TAC,
including the “debt collectors,” “outside services” and “persons employed by other entities who
assisted [Chase] in releasing liens” referenced in paragraph 204 of the TAC.
Request No. 35
For each third party with whom Chase allegedly interfered with Your prospective
economic advantage, all documents regarding that third party, including but not limited to Your
prospective agreement with the third party, Your communications with the third party, and any
files that You maintain regarding the third party.
Plaintiffs object to this Request on the grounds that it is overly broad and unduly
burdensome and purports to seek documents that are not related to the issues in this case. Subject
to and without waiving the foregoing and General Objections, Plaintiffs will produce non-
privileged documents that are responsive to this Request and are related to the issues in this case.
{00018854 1 } 17

Request No. 36
All documents relating to any statement made by Chase that allegedly constituted a slander
of title regarding Your property, including but not limited to any documents relating to any harm
that You claim to have suffered as a result.
Request No. 37
All documents relating to any damages that You seek in this action, including but not
limited to (1) documents relating to the allegations contained in paragraphs 77-79, 153, 158, 163,
170, 175, 184, 192, 200, and 217 of the Third Amended Complaint, and (ii) [sic] documents
relating to the damages listed in the “Damages Computation” section of your Rule 26(a)(1) initial
disclosures, as they may be amended from time to time.
Plaintiffs object to this Request to the extent that it is duplicative. Subject to and without
that are responsive to this Request but will not duplicate the production of documents already
produced in response to other Requests.
Request No. 38
All financial statements (including but not limited to statements of profit and loss) and tax
returns for S&A Capital Partners, Inc., Mortgage Resolution Servicing, LLC, 1st Fidelity Loan
Servicing, LLC, Laurence Schneider, and each of their predecessors, successors, assigns,
divisions, subsidiaries, affiliates or shareholders.
Plaintiffs object to this Request on the grounds that it is duplicative, overbroad, unduly
burdensome, designed to harass, and seeks documents that are not relevant to the issues in this
case. Further, Plaintiffs object to this Request on the grounds that it seeks confidential documents
regarding an individual who is not a party to this case. Plaintiffs further object to this Request on
{00018854 1 } 18

the grounds that Defendants have no proper basis for demanding tax returns. Plaintiffs are
producing documents related to their damages in response to Request No. 37 and others. Plaintiffs
will produce financial statements of the plaintiff entities only, for the relevant time periods, in
response to this Request. Plaintiffs will not produce the tax returns of any party, and will not
produce any documents on behalf of non-parties such as Mr. Schneider, or unspecified
“predecessors, successors, assigns, divisions, subsidiaries, affiliates or shareholders” in response
to this Request.
Request No. 39
All documents reflecting or relating to Plaintiffs’ financial performance and any alleged
diminution in the revenue, profits or value of the Plaintiff entities.
Plaintiffs object to this Request on the grounds that it is duplicative, overbroad, unduly
burdensome, designed to harass, and seeks documents that are not relevant to the issues in this
case. Plaintiffs further object to this Request on the grounds that it is vague and ambiguous with
regard to the phrase “financial performance.” Plaintiffs construe the term “financial performance”
to constitute a duplication of Request No. 38. Subject to and without waiving the foregoing and
the General Objections, Plaintiffs state that this Request is entirely duplicative of Requests Nos.
37 and 38 and will not produce documents that have already been produced in response to those,
or any other, Request.
Request No. 40
All documents relating to (i) any form of fee or retainer agreement between You and Your
present and former legal counsel in this litigation and (ii) the billing or payment of fees, costs,
expenses or disbursements by Your present and former counsel, including but not limited to, any
timesheet records created by Your present and former counsel.
{00018854 1 } 19

Plaintiffs object to this Request on the grounds that it is overbroad, unduly burdensome,
designed to harass, seeks documents that may be protected from disclosure by the attorney client
privilege or work product doctrine, and premature to the extent that any claim that may trigger an
award of attorney fees as an element of damages is presently the subject of a motion to dismiss.
Subject to and without waiving the foregoing and the General Objections, Plaintiffs state that in
the event that they meet the requirements to trigger an award of attorney fees, they will make the
appropriate disclosure and appropriate submissions at the appropriate time. At the present time,
Plaintiffs will not produce documents that are responsive to this Request.
Request No. 41
All documents that You receive in response to any third-party subpoenas that You issue in
connection with this litigation.
Subject to and without waiving the General Objections, and subject to any confidentiality
provisions that may be negotiated with regard to the production of documents in response to any
third-party subpoenas, Plaintiffs will produce non-privileged documents that are responsive to this
Request within a thirty-day timeframe of receiving such documents, subject to any condition
imposed by the third-party in question, including but not limited to the payment of costs, and to
the extent that the third-party in question has not already produced those documents to Defendants.
Request No. 42
All other documents reflecting or relating to any alleged loss, damage, injury, or breach for
which You may seek recovery from Chase.
{00018854 1 } 20

Plaintiffs object to this Request on the grounds that it is duplicative, and to the extent that
it seeks documents that are not relevant to the issues in this case. Plaintiffs further object to this
Request to the extent that it may seek to limit recovery for any loss, damage, injury, or breach that
is not the subject of this action or that may be the subject of any related or future action, and this
Response may not be considered a waiver of such. Subject to and without waiving the foregoing
and the General Objections, Plaintiffs will produce non-privileged documents that are responsive
to this Request but only with regard to the loss, damage, injury or breach that is claimed in this
action.
Request No. 43
All other documents relating in any way to the allegations in the TAC.
Plaintiffs object to this Request on the grounds that it is duplicative, and with regard to the
phrase “in any way” may be overbroad, unduly burdensome, and may seek documents that are not
relevant to the issues in this case. Plaintiffs further object to this Request on the grounds that it
seeks documents that are not proportional to the needs of the case, the resources of the parties or
take into account the relative access of the parties to relevant information.
{00018854 1 } 21

Dated: New York, New York CHAITMAN LLP

March 1, 2016
By: /s/ Helen Davis Chaitman
hchaitman@chaitmanllp.com
465 Park Avenue
Phone & Fax: 888-759-1114
Attorneys for Plaintiffs S&A Capital

Partners, Inc., Mortgage Resolution
Servicing, LLC and 1st Fidelity Loan
Servicing, LLC
{00018854 1 } 22

CERTIFICATE OF SERVICE
I, Helen Davis Chaitman, an attorney duly admitted to practice law in the State of New
York, affirm the following as true under the penalties of perjury:
That on March 1, 2016, I caused a true and correct copy of Plaintiffs’ Revised Objections
and Responses to Defendants’ First Request for Production of Documents to be served on
Defendants’ attorneys by electronic mail and by UPS as indicated below at the addresses provided
by them for that purpose:
By e-mail:
Robert D. Wick (rwick@cov.com)
Christian J. Pistilli (cpistilli@cov.com)
Michael M. Maya (Mmaya@cov.com)
By UPS:
Robert D. Wick
Christian J. Pistilli
One CityCenter
850 Tenth Street N.W.
Washington, D.C. 20001
I declare under penalty of perjury that the foregoing is true and correct.
Dated: New York, New York /s/ Helen Davis Chaitman_____

March 01, 2016 Helen Davis Chaitman
{00018854 1 } 23


MORTGAGE RESOLUTION SERVICING, ORAL ARGUMENT REQUESTED

LLC, 1ST FIDELITY LOAN SERVICING, LLC,
and S & A CAPITAL PARTNERS, INC.,
No. 15-cv-00293(LTS)(JCF)
Plaintiffs,
v.
JPMORGAN CHASE BANK, N.A., CHASE
HOME FINANCE, LLC, and JPMORGAN
CHASE & CO.,
Defendants.
PLAINTIFFS’ MEMORANDUM OF LAW IN SUPPORT OF MOTION TO COMPEL

AND DEFINE SCOPE OF DISCOVERY
CHAITMAN LLP
Lance Gotthoffer
Suzan Arden
465 Park Avenue
Phone & Fax: 888-759-1114
{00020219 4 }
TABLE OF CONTENTS
Page
TABLE OF AUTHORITIES ........................................................................................................................ iii
PRELIMINARY STATEMENT .................................................................................................................... 1
Background .................................................................................................................................................... 2
ALLEGATIONS ............................................................................................................................................... 6
Representations Regarding The First Lien Pool ....................................................................................... 7
The MLPA ..................................................................................................................................................... 8
False Representations and Warranties in the MLPA ............................................................................... 8
Conduct Subsequent to Execution of the MLPA .................................................................................... 9
Misrepresentation of Loan Ownership to Government Agencies ........................................................ 9
The National Mortgage Settlement and Residential Mortgage Backed Securities

Settlement ....................................................................................................................................................... 9
The Pre-DoJ Lien Release Project ............................................................................................................10
THE MEET AND CONFER PROCESS ..................................................................................................11
CATEGORIES OF DOCUMENTS IN DISPUTE .................................................................................11
ARGUMENT...................................................................................................................................................12
STANDARDS ON DISCOVERY......................................................................................................12
POINT I ..................................................................................................................................................14
DEFENDANTS SHOULD BE COMPELLED TO SEARCH FOR

DOCUMENTS RESPONSIVE TO PLAINTIFFS’ DEMANDS
WITHOUT EXCLUDING DOCUMENTS APPLICABLE TO THE QUI
TAM CASE AND WITHOUT THE PROVISO THAT THE
DOCUMENTS MUST RELATE TO PLAINTIFFS’ BREACH OF
CONTRACT CLAIMS .....................................................................................................................14
A. The Court Has Ordered, and Chase has Conceded, That Discovery
Should Be Coordinated ...................................................................................................15
B. Defendants Have Opened the Door to Discovery that Relates to

the qui tam Case ................................................................................................................19
{00020219 4 } i
C. The Requested Discovery Meets Proportionality Requirements ..............................20
POINT II .................................................................................................................................................22
DEFENDANTS MUST PRODUCE DOCUMENTS RELATING TO THE

LOANS ................................................................................................................................................22
CONCLUSION ...............................................................................................................................................26
APPENDIX 1 ..................................................................................................................................................27
APPENDIX 2 ..................................................................................................................................................34
{00020219 4 } ii
TABLE OF AUTHORITIES
Page(s)
Cases
In re “Agent Orange” Prod. Liability Litig.,

821 F.2d 139 (2d Cir. 1987) ..................................................................................................................... 13
Alli v. Steward-Bowden,
No. 11 CIV. 4952 PKC KNF, 2013 WL 5229995 (S.D.N.Y. Sept. 17, 2013) ................................. 16
Antweil v. Alfin Fragrances, Inc.,

No. 88 CIV. 0525 (JFK), 1988 WL 75275 (S.D.N.Y. July 12, 1988)................................................. 16
Cartel Asset Mgmt. v. Ocwen Fin. Corp.,

No. 01 Civ. 1644, 2010 WL 502721 (D. Colo. Feb. 8, 2010) ............................................................. 13
In re Dewey & LeBoeuf LLP,

522 BR 464 (Bankr. S.D.N.Y. 2014) ...................................................................................................... 16
Fed. Hous. Fin. Agency v. Nomura Holding Am., Inc.,

No. 11CV6201 DLC, 2014 WL 4412388 (S.D.N.Y. Sept. 8, 2014) .................................................. 16
Fletcher v. Atex, Inc.,

156 F.R.D. 45 (S.D.N.Y. 1994) ............................................................................................................... 12
Mikron Indus., Inc. v. Hurd Windows & Doors, Inc.,

No. 07 Civ. 532, 2008 WL 1805727 (W.D. Wash. April 21, 2008).................................................... 22
O’Bar v. Lowe’s Home Ctrs., Inc.,

No. 04 Civ. 19, 2007 WL 1299180 (W.D.N.C. May 2, 2007) ............................................................. 22
Oppenheimer Fund, Inc. v. Sanders,

437 U.S. 340 (1978) ................................................................................................................................... 12
Roxane Labs., Inc. v Abbott Labs.,

2013 WL 5217571 (S.D. Ohio Sept. 16, 2013) ..................................................................................... 16
Schartz v. Unified Sch. Dist. No. 512,

No. 95 Civ. 2491, 1996 WL 741384 (D. Kan. Dec. 18, 1996) ............................................................ 13
Spieker v. Quest Cherokee, LLC,

No. 07 Civ. 1225, 2009 WL 2168892 (D. Kan. July 21, 2009) ........................................................... 22
State Farm Mutual Automobile Ins. Co. v. Fayda,

No. 14 Civ. 9792, 2015 WL 7871037 (S.D.N.Y. Dec. 3, 2015) ................................................... 12, 20
{00020219 4 } iii
In re Uber Techs., Inc., Wage & Hour Employment Practices,

No. MDL 2686, 2016 WL 439976 (U.S. Jud. Pan. Mult. Lit. Feb. 3, 2016) ..................................... 15
United States v. Bank of America,

922 F. Supp. 2d 1 (D.D.C. 2013) .............................................................................................................. 3
United States v. Sanders,

211 F.3d 711 (2d Cir.2000) ...................................................................................................................... 12
Wynne v. McCormick & Schmicks’s Seafood Rests., Inc.,

No. 06 Civ. 3153, No. C06-3153CW(BZ), 2006 WL 3422226 (N.D. Cal. Nov. 28,
2006)............................................................................................................................................................ 23
Statutes
16 U.S.C. § 1962(c) ............................................................................................................................................ 6
Other Authorities
Fed. R. Civ. P. 26 ....................................................................................................................................... passim
Fed. R. Civ. P. 34(a)(1) .................................................................................................................................... 12
Fed. R. Civ. P. 37 .........................................................................................................................................1, 12
Local Civil Rule 37.1.......................................................................................................................................... 1
{00020219 4 } iv
Plaintiffs S&A Capital Partners, Inc. (“S&A”), Mortgage Resolution Servicing, LLC (“MRS”)
and 1st Fidelity Loan Servicing, LLC (“1st Fidelity”), through their attorneys, Chaitman LLP, submit
this memorandum of law in support of their motion, pursuant to Federal Rule of Civil Procedure 26
and 37 and Local Civil Rule 37.1,
(a) to compel Defendants JPMorgan Chase Bank, N.A., JPMorgan Chase & Company, and
Chase Home Finance LLC (collectively, “Chase” or “Defendants”), to produce documents in
response to Plaintiffs’ document demands (“Plaintiffs’ Requests”) and
(b) to define the scope of discovery in this case.
PRELIMINARY STATEMENT
All fact discovery in this case is ordered to be complete by September 2, 2016. (Docket 91).
To date, Plaintiffs have produced over 100,000 pages and are in the process of producing
approximately 100,000 more. Nonetheless, Defendants have not yet produced even a single
document.1 We have exhausted ourselves in meet-and-confers, to no avail. We therefore are forced
to burden the Court with this motion.
Plaintiff has asserted claims for breach of contract, associated torts, and for liability under civil
RICO. There is a pending related qui tam case in the District Court for the District of Columbia and
Judge Swain has indicated that discovery in both cases should be coordinated here.2 All claims relate
to Defendants’ wrongful conduct, including the improper release of liens and forgiveness of loans
they had already sold to Plaintiffs, among others, and for which Defendants claimed credit as part of
an $8 billion package of consumer relief they had agreed to provide in settlement agreements with the
federal government, and regarding its Servicing Participation Agreement (“SPA”) with the Treasury.
1 Defendants’ Objections and Responses to Plaintiffs’ First Request for the Production of Documents to all
Defendants (“Plaintiffs’ Requests” or “PR”) is attached to the accompanying Declaration of Helen Davis
Chaitman (“Chaitman Dec.”), executed on May 27, 2016, as Exhibit A.
2 Docket 32, Point 12, p. 6; Docket 87, p. 3,
{00020219 4 } 1
Defendants have requested in their own demands, and Plaintiffs have been producing,
categories of documents that relate only to the qui tam action. Nonetheless, Defendants have
categorically refused to produce any of the categories of documents that relate to the qui tam case, that
Defendants demanded that Plaintiffs produce and which Plaintiffs have produced.
However, regardless of whether the documents relate to the qui tam case or to the case pending
in this Court, the Defendants refuse to produce a single document. Instead they have devoted their
energies to inventing frivolous excuses for their failure to comply with Plaintiffs’ discovery demands.
One of Defendants’ excuses is that there is a pending motion to dismiss the RICO claim. However:
 Discovery has not been stayed pending resolution of the motion; nor have Defendants
even requested that it should be.
 Most of the discovery Plaintiffs have demanded is necessary for the breach of contract
claims, as well as for the RICO claims. Indeed, Defendants have admitted that there is considerable
factual overlap between the claims they have sought to dismiss and the breach of contract claims,
which means that documents relevant to one type of claim are almost certainly relevant to the others.
Background
The Plaintiffs are in the business of buying mortgage loans (including the note, the mortgage
or deed of trust, the full collateral file and the servicing file and history) that are not performing
according to their original terms, (TAC3 ¶ 12) with the goal of working out payment plans with the
borrowers to enable them to remain in their homes (TAC ¶ 13). Plaintiffs claim that the Defendants,
who are responsible for providing $8 billion of relief to consumers pursuant to certain settlements
with the government, dumped large amounts of liabilities and defective loans on Plaintiffs and also
committed wholescale fraud on Plaintiffs as part of a scheme to appear to comply with those
3 The Third Amended Complaint in this action (“TAC”) is attached to the Chaitman Dec. as Exhibit B.
{00020219 4 } 2
settlements and the SPA. While Defendants seek to mischaracterize their wrongdoing as a mere
breach of contract, Plaintiffs have alleged in the TAC that Defendants also committed wholescale
fraud on Plaintiffs as part of a scheme to appear to comply with those settlements.
In the TAC, Plaintiffs allege that the Defendants first enticed them to purchase a series of
mortgage loans that Defendants claimed were first lien residential mortgages which did not make
financial sense for Defendants to retain—when they were really mostly deficiency claims that had
been improperly serviced. Then, after entering into settlements with the government which required
Defendants to pay out over $8 billion in consumer relief, Defendants sought consumer relief credit
by forgiving loans and releasing liens that had previously been sold to the Plaintiffs. Based on this
fact pattern, Plaintiffs brought claims for breach of contract (Counts One through Three), Conversion
(Count Four), Tortious Interference (Count Five) Fraud and Negligent Misrepresentation (Count Six
and Seven), Slander of Title (Count Eight) and for civil RICO liability (Count Nine).
Plaintiffs’ principal, Laurence Schneider, has a qui tam case pending in the District of Columbia,
now captioned United States of America et al ex rel. Lawrence Schneider v. J.P. Morgan Chase Bank, National
Association, et al., 114-CV-01047-RMC (the “qui tam Case”) in which he contends that Defendants
violated the terms of a consent judgment entered in United States v. Bank of America, 922 F. Supp. 2d 1,
4 (D.D.C. 2013), that required, among other things, that Defendants provide refinancing and other
consumer relief to mortgage customers who satisfy certain eligibility criteria. Defendants moved to
transfer this case to the District of Columbia as a related case (Docket 42). The Court denied that
motion on October 28, 2015 (Docket 75). In the Initial Pre-Trial Order and in the decision denying
the motion to transfer, this Court ordered the parties to coordinate discovery with the qui tam Case,
in which discovery has not yet begun.
The dispute about the applicable scope of discovery here is fundamental. Plaintiffs have
already produced approximately 100,000 pages and are on track to produce many thousands more.
{00020219 4 } 3
Defendants have not produced even one document. In their motion to transfer, Defendants took the
position that the claims in this case and the claims in the qui tam Case concern the same subject matter.
In their motion to dismiss, Defendants took the position that Plaintiffs’ breach of contract claims,
which Defendants did not seek to dismiss, are duplicated by Plaintiffs’ tort claims. Documents do
not suddenly become less relevant to Plaintiffs’ claims in this case simply because they may also be
discoverable in the qui tam Case or because they may also relate to other claims in this case that are
the subject of a motion to dismiss. Further, Defendants do not deny that they will take the position
that, if a witness is deposed in this case, they will claim that this witness cannot be redeposed in the
qui tam Case. In order to prepare properly for depositions, the parties must, of course, have access to
all of the relevant documents before depositions begin.
Second, Defendants’ contend that it is not “remotely feasible” for them to identify the loans
they sold to the Plaintiffs, and their proposed strategy for dealing with that absurd proposition is to
require the Plaintiffs to prepare lists of loan numbers of the loans that they believe they bought.
Plaintiffs attached to the TAC the lists of loans that Defendants had provided to them when S&A
Capital and 1st Fidelity purchased the loans. In addition, Plaintiffs have identified the loans MRS
purchased on several occasions before commencing this lawsuit in an attempt to prevent Defendants
from continuing to take action on loans they no longer owned.
Defendants, however, claim that this is insufficient because it is not a list of loan numbers,
simply the identifying detail provided by Defendants to Plaintiffs. Defendants contended that the
Plaintiffs must first itemize all the numbers before Defendants can produce any documents at all.
However, Defendants turned the loans over to the Plaintiffs without ever providing any loan numbers
and, we understand, Defendants have since changed some of the loan numbers that would have
{00020219 4 } 4
applied in any case.4 In order to provide the most scope for identifying all of the relevant loans,
Plaintiffs have provided Defendants with lists of borrower information, including social security
numbers and property details. Defendants are certainly able to produce the loan information based
on social security numbers. While Defendants may change loan numbers for their own purposes, they
have no power to change the borrowers’ social security numbers.
Moreover, all but one of the requests for which Defendants have raised this issue do not
require identification of the loans Defendants sold to Plaintiffs. As set forth below, the requests
encompass loans whose details were itemized on a list Defendants sent to the Plaintiffs (referred to in
the TAC as the “Corrupted List”), or relate to loans whose borrowers were the recipients of debt
forgiveness letters pursuant to Defendants’ obligations to provide consumer relief, or whose liens
Defendants released starting in October 2013, apparently robo-signed as part of a project to avoid
liability for Defendants’ servicing violations. As such, since the purpose of the requests is for
Defendants to identify loans, not Plaintiffs, Defendants do not require Plaintiffs to provide them
with any identification of the loans they purchased to respond.
There are other discovery issues which Defendants have raised in order to obfuscate the
process. Defendants have been unwilling to agree on the document custodians who possess
responsive information and have refused to expand their search terms beyond 11. While Defendants
represent that they are willing to negotiate the list of custodians and search terms, Plaintiffs do not
know what documents are contained in the files Defendants deem appropriate to search, and what
documents are not, beyond a bare statement in Defendants’ response to Plaintiffs’ interrogatories that
the proposed custodians possess only information concerning “interactions with Plaintiffs and/or the
4For example, Launi Solomon of Chase sent an internal email dated December 18, 2009, copying Plaintiffs’
Principal, regarding “Payments (MRS SALE)” in which she stated that “[t]here are issues due to dupe acct #
project or something Larry Sandra [sic] says you know about? So some of these accts your group cant [sic] find
under certain acct #s because we changed them?” Chaitman Dec. Exh. C.
{00020219 4 } 5
loans and liens purchased by Plaintiffs from Chase.”5 Obviously, the discovery in the qui tam Case
extends to loans that were not sold to Plaintiffs. In order to resolve some of these issues, Plaintiffs
have asked Defendants to provide them with a deposition pursuant to Rule 30(b)(6) to evaluate the
categories of documents stored in various locations as well as the costs and methodology for searching,
reviewing and retrieving documents for production.
But Defendants contend that even the 30(b)(6) notice6 is too broad, and that Plaintiffs are not
entitled to know the location of documents Defendants object to producing. Thus, until the question
of the scope of discovery is resolved, and until Defendants have explained to Plaintiffs what
documents are stored in what databases or locations, Plaintiffs cannot even properly address the
minutiae of Defendants’ more impenetrable objections. Certainly, Plaintiffs cannot negotiate with
Defendants regarding the identity of the appropriate custodians and search terms.7
ALLEGATIONS
Plaintiffs have pled that the Defendants, together with certain officers, debt collection
agencies, the outside services that sent out thousands of debt forgiveness letters, and the persons and
entities that released liens on collateral that had been transferred to the Plaintiffs, formed an enterprise
as set forth in 16 U.S.C. § 1962(c) (TAC ¶ 208). Defendants’ purpose, through control of the
enterprise, was to dump massive liabilities onto the Plaintiffs so that Defendants could avoid liability.
This permitted Defendants to represent to the federal government that they fulfilled the terms of the
NMSA Consent Judgment and the RMBS Settlement by appearing to provide $8.2 billion of consumer
relief when in fact they had not. (TAC ¶¶ 206-07, 210).
5 See Defendants’ Objections and Responses to Plaintiffs’ First Set of Interrogatories to All Defendants,
Chaitman Dec. Exhibit D. Compare with the eight custodians identified on Exhibit A to Defendants’
Objections and Responses to Plaintiffs’ First Request for the Production of Documents to All Defendants,
Chaitman Dec. Exhibit A.
6 A copy of the 30(b)(6) notice is attached to the Chaitman Dec. as Exhibit E.
7 While Defendants have theoretically offered to negotiate regarding adding custodians or search terms, this
offer is hollow because Plaintiffs cannot know in whose possession the relevant documents reside.
{00020219 4 } 6
The scheme included multiple predicate acts, starting when Defendants’ head of loan recovery
knowingly misrepresented to Plaintiffs in 2008 that it was selling “closed end first lien residential
mortgage loans” from which Defendants had decided to “walk away” based on a cost benefit analysis
(TAC ¶ 212a) when they really intended to dump massive liabilities on Plaintiffs (TAC ¶212a) and
when the majority of the loans were in fact deficiency claims, not first lien mortgages. (TAC ¶ 212a,
212b). Defendants’ wrongful conduct continued through Defendants’ mailing out hundreds of letters
to homeowners forgiving loans Defendants had already sold to the Plaintiffs more than three years
earlier and releasing vast numbers of liens on properties pledged to Plaintiffs as collateral through
robo-signed releases executed from September 2012 through October 2013. (TAC ¶¶ 212 g, 212h).
Representations Regarding The First Lien Pool
In 2008, Chase represented to Plaintiffs that Chase wanted to sell a portfolio of first lien
residential mortgages. In order to encourage plaintiffs to purchase the loan package, Chase
represented that it contained some valuable loans that had been erroneously ‘charged off,’ removed
from its primary System of Records and ported to Chase’s Recovery department. (TAC ¶¶ 19-21). In
October 2008 Chase sent Plaintiffs a preliminary data tape of the loan package, which was grossly
incomplete (TAC ¶ 22). This was followed by a second data tape in November 2008 (the “November
2008 Data Tape”), which clearly identified the loans as first lien mortgages, but still lacked information
including certain borrower names and collateral addresses. (TAC ¶ 24). Plaintiffs’ due diligence
revealed that the largest two loans were in excess of $500,000, fully secured and located in areas with
houses valued over $1 million. (TAC ¶25). Chase represented that the loan sale had to close before
the end of the year so that Chase could “get the loans off its books”. (TAC ¶ 29). Despite these
“cherries,” in December 2008, Plaintiffs informed Defendants that they were not interested in making
a competitive bid on the loans. (TAC ¶ 29).
{00020219 4 } 7
Chase then offered to sell the loans to Plaintiffs for $200,000 (TAC ¶ 30). Plaintiffs accepted,
based on their evaluation of the “cherries” and sent a formal offer to purchase approximately $100
million of “impaired first lien mortgage loans” on December 22, 2008 (TAC ¶¶ 31-32).
The MLPA
On February 4, 2009 Defendants provided Plaintiffs with the Mortgage Loan Purchase
Agreement (“MLPA”) for signature. It provided for the sale of 4,271 loans with an outstanding
balance of over $172 million, but Defendants did not provide the list of loans being sold, which was
supposed to form Exhibit A to the MLPA. (TAC ¶ 35). Plaintiffs requested a copy of the final data
tape of the loans so it could be reviewed before signing the MLPA. Defendants represented that it
would provide the final data tape after signature. (TAC ¶ 36).
The fully-executed version of the MLPA, which Defendants sent to Plaintiffs three weeks
later, provided for the sale 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” with an outstanding balance of a little over $156 million. (TAC ¶ 38). Defendants then sent
a data tape containing what purported to be Exhibit A (the “Corrupted List”). (TAC ¶¶ 39, 46).
False Representations and Warranties in the MLPA
Defendants made three key representations and warranties in the MLPA: (1) that the
information on the data tape—i.e. the Corrupted List—“is true and correct in all material respects as
of the date such data tape was compiled”; (2) that Defendants are the sole owner of the loans with
full authority to sell them; and (3) that each loan “complies in all material respects with all applicable
. . . laws” (TAC ¶ 43, TAC Exhibit 3 §6).
All of these warranties were false at the time they were made. First, the Corrupted List did
not include the basic information necessary to service the loans. (TAC ¶46). Second, contrary to the
representation and warranty that Defendants owned the loans, the Corrupted List contained loans
{00020219 4 } 8
Defendants had previously sold to third parties and loans Defendants had never owned.8 (TAC ¶¶
56, 60h). (TAC ¶ 56). Third, the loans did not comply with applicable laws. (TAC ¶¶ 59-60).
Conduct Subsequent to Execution of the MLPA
In addition to the multiple misrepresentations Defendants made prior to execution of the
MLPA, Plaintiffs allege that Defendants subsequently breached it by, among other things, (1) failing
to provide MRS with assignments of the notes and mortgages for the loans (TAC ¶ 65); (2) sending
letters misrepresenting Defendants as owners of the loans and directing borrowers of some loans to
make payments to Defendants instead of MRS or its designees (TAC ¶ 68); (3) collecting payments
from insurance companies pursuant to title insurance claims related to the mortgage loans (TAC ¶¶
69-70); (4) “recalling” certain loans (TAC ¶¶ 71-74); (5) contacting borrowers and misrepresenting
that Defendants had reacquired the loans and that the borrowers had to pay Defendants (TAC ¶ 85);
(6) collecting and retaining payments on certain of the loans (TAC ¶ 86); (7) changing the loan
numbers of certain performing loans (TAC ¶ 87).
Misrepresentation of Loan Ownership to Government Agencies
Plaintiffs further allege that Defendants misrepresented to certain government enforcement
agencies that MRS, not Chase, was responsible for the pre-sale conduct of Defendants regarding loans
that had been sold (TAC ¶ 88), and that MRS, not Chase, was responsible for violations regarding
loans that Defendants had never sold to MRS (TAC ¶ 89).
The National Mortgage Settlement and Residential Mortgage Backed Securities Settlement
Plaintiffs have pled that Defendants were party to the National Mortgage Settlement
Agreement (“NMS”), reflected in a consent judgment (the “NMS Consent Judgment”) (TAC ¶¶ 92-
8For example, on February 17, 2010, Launi Solomon of Chase sent an email to Plaintiffs’ Principal in which
she discussed the need for MRS to close two accounts Chase had sold to MRS because the accounts were
“fraud”: one for Syed Ali and one for Ricardo Salinas. She acknowledged that “it was our fault we sold it. It
was clearly in the notes that its fraud.” Chaitman Dec. Exh. F.
{00020219 4 } 9
97). Among other things, Defendants were required to provide $4.2 billion of consumer relief to
borrowers whose loans they owned. (TAC ¶ 100). Accordingly, from September 13, 2012 through
January 13, 2013, as part of this $4.2 billion consumer relief, Defendants sent over 50,000 letters to
borrowers forgiving various loans. However, among these loans Defendants purportedly forgave
thousands it did not own, including multiple loans it had sold to the Plaintiffs. (TAC ¶¶ 102-08).
Plaintiffs have also pled that Defendant JPMC entered into a $13 billion settlement with the
Department of Justice on November 19, 2013 (“RMBS Settlement”) under the terms of which JPMC
agreed to pay $13 billion in return for complete civil immunity. (TAC ¶ 146). Pursuant to the RMBS
Settlement, these payments included $4 billion of consumer relief, pursuant to which Defendants
wrongfully claimed credit for the full indebtedness owed by borrowers whose loans Defendants had
already sold to Plaintiffs (TAC ¶ 147).
The Pre-DoJ Lien Release Project
Plaintiffs also allege that, starting in October 2013, Defendants released liens9 on thousands
of properties on which they had abandoned their servicing responsibilities in violation of legal
requirements. (TAC ¶ 134). These liens included loans owned by Plaintiffs (TAC ¶¶ 135-37, 140),
which caused them to lose revenue and also exposed them to litigation and regulatory action. (TAC
¶¶ 141-43). The releases appear to have been robo-signed (TAC ¶¶ 138, 144).
9 On October 21, 2013, Chase expedited its Alternative Foreclosure Program, known as the Pre DOJ Lien
release Project. Plaintiffs contend that as part of this process, JPMC specifically targeted loans owned by the
Plaintiffs. The attached screen shot refers to loans owned by S & A Capital, 1st Fidelity Loan Servicing and
Mortgage Resolution Servicing. The record keeping of the loans owned by the Plaintiff entities, whose liens
were released, was notated in Chase’s MSP system of records. Chaitman Dec. Exh. G.
On January 3, 2014, Jason Oquendo, Chase Project Manager, sent an email to Chase Credit Operations in
which he changes the Internal Controls to obtain credits pursuant to the 2nd Lien Extinguishment
Program. The email describes a number of new and changed fields. Chaitman Dec. Exh. H.
{00020219 4 } 10
THE MEET AND CONFER PROCESS
The Plaintiffs have complied with their meet-and-confer obligations and have discussed the
issues set forth herein extensively. Defendants served their Objections and Responses on February
24, 2016. On March 1, 2016, Plaintiffs sent a letter to Defendants raising these issues. Chaitman Dec.
Exh. I. On March 16, 2016, Defendants responded. Chaitman Dec. Exh. J. On April 20, 2016
Plaintiffs sent another letter to Defendants to discuss Defendants’ discovery obligations and served
their 30(b)(6) notice. Chaitman Dec. Exh. K. On April 22, 2016, Defendants sent an email asking to
meet-and-confer on the 30(b)(6) issue alone. Plaintiffs responded that they would meet-and-confer
on all issues rather than in a piecemeal fashion. Chaitman Dec. Exh. L. Defendants did not respond
until April 28, 2016, at which time they expressed their intention to move for a protective order on
the 30(b)(6) notice if no agreement could be reached. Plaintiffs responded on April 29, 2016, asking
again for a global meet-and-confer. Chaitman Dec. Exh. M. The parties conducted that meet-and-
confer on May 12, 2016. Defendants followed up with an email outlining remaining issues on May
13, 2016 and Plaintiffs responded on May 20, 2016 (Chaitman Dec. Exh. N) at which time the parties
agreed that they were unable amicably to resolve the question of the scope of discovery.
CATEGORIES OF DOCUMENTS IN DISPUTE
A list of the specific requests that would elicit documents that Defendants object to producing,
so far as can be determined, fall into three categories: (1) Documents that relate to the qui tam Case or
that Defendants claim are beyond the scope of the breach of contract claims (Plaintiffs’ Request Nos.
7, 26, 27, 29, 31, 33-41); (2) Documents Defendants claim they cannot produce unless Plaintiffs
provide them with a list of loans that Defendants sold (Plaintiffs’ Request Nos. 3, 16-18, 21, 28 and
32); and (3) Documents that Defendants might produce, so long as they can be found in the files of
eight proposed custodians, through the use of eleven proposed search terms.
{00020219 4 } 11
This motion is addressed to the first two categories. The parties will discuss the third category
and attempt to reach an agreement following resolution of the scope of discovery that is available.
ARGUMENT
STANDARDS ON DISCOVERY
“A party may serve on any other party a request within the scope of Rule 26(b)” to produce
“any designated documents or electronically stored information” or “any designated tangible things.”
Fed. R. Civ. P. 34(a)(1). “On notice to other parties .... a party may move for an order compelling
disclosure or discovery.” Fed. R. Civ. P. 37(a)(1). Motions to compel, pursuant to Fed. R. Civ. P. 37,
are left to the sound discretion of the district court. See United States v. Sanders, 211 F.3d 711, 720 (2d
Cir.2000).
Under Rule 26 of the Federal Rules of Civil Procedure, as recently amended, the scope of
discovery includes:
any nonprivileged matter that is relevant to any party's claim or defense and
proportional to the needs of the case, considering the importance of the issues at stake
in the action, the amount in controversy, the parties’ relative access to relevant
information, the parties’ resources, the importance of the discovery in resolving the
issues, and whether the burden or expense of the proposed discovery outweighs its
likely benefit. Information within this scope of discovery need not be admissible in
evidence to be discoverable.
The Court should still construe relevance broadly, “’to encompass any matter that bears on,
or that reasonably could lead to other matters that could bear on’ any party’s claim or defense.” State
Farm Mutual Automobile Ins. Co. v. Fayda, No. 14 Civ. 9792, 2015 WL 7871037, at *2 (S.D.N.Y. Dec. 3,
2015), quoting Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 351 (1978).
While the Court must consider proportionality to discourage the overuse of discovery, as the
advisory committee’s notes to the 2015 amendment reveal, “the rule ‘does not place on the party
seeking discovery the burden of addressing all proportionality considerations.’” Fayda at *2. The
burden remains on the party resisting discovery to show undue burden or expense. Id.; Fletcher v.
{00020219 4 } 12
Atex, Inc., 156 F.R.D. 45, 54 (S.D.N.Y. 1994) (citing In re “Agent Orange” Prod. Liability Litig., 821 F.2d
139, 145 (2d Cir. 1987) (“[I]f a party resists production on the basis of claimed undue burden, it must
establish the factual basis for the assertion through competent evidence.”). “The discovery process
necessarily imposes burdens on a responding party.” Cartel Asset Mgmt. v. Ocwen Fin. Corp., No. 01 Civ.
1644, 2010 WL 502721, at *10 (D. Colo. Feb. 8, 2010); Schartz v. Unified Sch. Dist. No. 512, No. 95 Civ.
2491, 1996 WL 741384, *2 (D. Kan. Dec. 18, 1996) (“[d]iscovery, by its very nature, is inherently
burdensome to some extent” and the operative question “is whether the discovery unduly burdens.”)
(emphasis added). Information still “need not be admissible in evidence to be discoverable.” Fed. R.
Civ. P. 26(b)(1).
There are three broad categories of documents that Defendants are presently unwilling even
to search for, let alone produce. First, Defendants have refused to produce any documents other than
those that are directly related to Plaintiffs’ breach of contract claims. As discussed below, this ignores
the fact that Defendants have themselves asked for Plaintiffs to produce documents that relate to the
qui tam Case.
Second, Defendants have refused to make any attempt to identify the loans they sold to the
Plaintiffs, claiming that it is somehow impossible for them to do so. This response does not even
address the fact that all but one of the requests in question does not require any identification of the
loans Plaintiffs purchased at all. Having taken this position, Defendants require Plaintiffs to produce
identifiers for loan numbers that Plaintiffs contend they were sold, even though Defendants sold the
loans without providing such a list and, indeed, with respect to the MRS loans, apparently changed
some of the loan numbers in any event. Plaintiffs have now provided Defendants with lists of loans
purchased by social security number, loan recipient, property address and amount, but Defendants’
delay tactic is a specious position designed to insulate Defendants from liability, both in this case and
{00020219 4 } 13
in the qui tam Case, for their actions with regard to selling or releasing loans that they had already sold
to the Plaintiffs or others. This Court should not condone it.
Finally, Defendants have refused to review or produce any documents outside of those that
are to be found in the files of a very narrow set of custodians, or that can be located by a very restricted
set of 11search terms, eight of which are variations on Plaintiffs’ names. It is impossible for Plaintiffs
to know what documents are (and perhaps more importantly, are not) contained in those files and we
have requested a Rule 30(b)(6) deposition to guide that inquiry. Defendants have challenged that
notice and have signaled their intent to move for a protective order.
While Defendants have shown some willingness to negotiate on the identities of the
custodians and range of search terms in the future, it would be futile to do so until the question of
what subject matter is proper for discovery has been answered and until Plaintiffs have had a proper
chance to establish the location and custodians of the documents they have requested be produced
through a deposition pursuant to Rule 30(b)(6).
POINT I
DEFENDANTS SHOULD BE COMPELLED TO SEARCH FOR

DOCUMENTS RESPONSIVE TO PLAINTIFFS’ DEMANDS WITHOUT EXCLUDING
DOCUMENTS APPLICABLE TO THE QUI TAM CASE AND
WITHOUT THE PROVISO THAT THE DOCUMENTS MUST RELATE
TO PLAINTIFFS’ BREACH OF CONTRACT CLAIMS
In their response to Plaintiffs’ demands, Defendants have improperly sought to limit the scope
of discovery to exclude documents relevant to the qui tam Case and to include only those documents
that Defendants consider to be responsive to Plaintiffs’ claims of breach of contract. Defendants’
argument seems to be that they should not have to produce documents in New York when they may
not have to produce them in the District of Columbia. This objection is without validity in several
respects. First, this Court has ordered the parties to coordinate discovery in this case with discovery
{00020219 4 } 14
in the qui tam Case. Such coordination does not narrow the scope of discovery. To the contrary, it
properly expands it to encompass discovery from both cases.
In many instances, the documents Plaintiffs have requested in this category are in fact relevant
to both cases. Even if they were only relevant to the qui tam Case, however, Defendants have opened
the door to the production of these documents with their own demand for Plaintiffs to produce
documents that almost exclusively relate to the claims in the qui tam Case.
Second, none of the claims in this case have been dismissed and discovery has not been stayed
in any respect in response to Defendants’ pending motion to dismiss Plaintiffs’ tort and RICO
claims.10 Further, Defendants argued in that motion to dismiss that Plaintiffs’ tort claims are mere
duplications of their breach of contract claims, and that the exact same conduct is alleged with regard
to all claims. Unless they have suddenly changed this position, it is impossible to see how Defendants
could make any principled determination regarding what documents would fall within the restrictions
of relevance to the breach of contract claims and not be relevant to the other claims, or vice versa.
A. The Court Has Ordered, and Chase has Conceded,

That Discovery Should Be Coordinated
This Court ordered in the initial Pretrial Order that the parties should coordinate discovery in
both cases to avoid duplication.11 Further, Judge Swain also provided in her Order issued on
December 22, 2015 that the parties are “encouraged to coordinate informally discovery of common
issues of fact, insofar is feasible, that may arise in the FCA action pending in D.C.” (Docket 87, p. 3).
During the course of motion practice and in the initial discovery in this case, all parties agreed that
there is a substantial degree of overlap between the claims in this case and the claims in the qui tam
10 Indeed, Defendants have not even proposed making such a motion and, if they had done so, Plaintiffs would
have opposed it.
11 Especially where, as here, the defendants are the same and there is a limited number of counsel, coordination
of discovery is appropriate. See, e.g. In re Uber Techs., Inc., Wage & Hour Employment Practices, No. MDL 2686,
2016 WL 439976, at *2 (U.S. Jud. Pan. Mult. Lit. Feb. 3, 2016) (coordinating discovery and even pretrial motions
in cases located throughout the country).
{00020219 4 } 15
Case. Indeed, in that motion, Defendants argued that the claims in this case were largely encompassed
by those in the qui tam Case and specifically contended that:
[l]itigating these common factual questions in two different courts and on two
different discovery schedules would impose substantial burdens on both Chase and
the federal judiciary. . . nor should this Court be forced to waste time and questions of
fact and discovery issues that [Plaintiffs’ principal] has already placed before another
federal court.
Docket 75, p. 11. Defendants cannot change their position now simply because they did not prevail
on the motion to transfer.
It is axiomatic that the purpose of an order to coordinate discovery is to eliminate waste and
to reduce the costs of discovery and litigation. Fed. Hous. Fin. Agency v. Nomura Holding Am., Inc., No.
11CV6201 DLC, 2014 WL 4412388 (S.D.N.Y. Sept. 8, 2014) (discussing prior order coordinating
discovery in RMBS actions in New York and Connecticut, and considering motion to revise schedule
in New York); Antweil v. Alfin Fragrances, Inc., No. 88 CIV. 0525 (JFK), 1988 WL 75275, at *1 (S.D.N.Y.
July 12, 1988); See also Roxane Labs., Inc. v Abbott Labs., 2013 WL 5217571, at *3 (S.D. Ohio Sept. 16,
2013) (ordering coordination of discovery between cases at pretrial conference involving related cases
to avoid overlap of discovery as an alternative to consolidation); In re Dewey & LeBoeuf LLP, 522 BR
464, 479 (Bankr. S.D.N.Y. 2014) (“Coordination of discovery “will reduce the potential for
inconsistent adjudications and allow for more efficient, non-duplicative discovery than would be
possible if the [ ] litigations were allowed to proceed in separate fora.”); See generally Alli v. Steward-
Bowden, No. 11 CIV. 4952 PKC KNF, 2013 WL 5229995, at *2 (S.D.N.Y. Sept. 17, 2013)
(recommending consideration of coordinating discovery on Monell claims in other pending cases
against the City relating to alleged assaults by corrections officers.)
As Judge Francis noted in his Memorandum and Order, dated October 28, 2015, denying
Defendants’ motion to transfer, Plaintiffs’ breach of contract, tort and civil RICO claims all concern
allegations that “the defendants, after selling mortgage loans to the plaintiffs, released liens securing
{00020219 4 } 16
those loans, purported to forgive debt on mortgages they sold, and accepted and retained payments
on loans they no longer owned.” Memorandum and Order at 2-3, referencing TAC ¶¶ 152, 157, 162,
169, 172, 194 and 204, see also p.9 and n. 7, Chaitman Dec. Exhibit N. The Memorandum and Order
also noted that the claims in the qui tam Case are, in essence, allegations that Defendants violated the
terms of certain consent judgments with the government “by, among other things, improperly
claiming credit for forgiving mortgage debt that they no longer owned.” Memorandum and Order at
4, Chaitman Dec. Exhibit N.
As set forth above, in this case, Plaintiffs have pled that Defendants were party to the National
Mortgage Settlement Agreement (“NMS”), reflected in a consent judgment (the “NMS Consent
Judgment”) in settlement of a complaint regarding misconduct related to their origination and
servicing of single family residential mortgages (TAC ¶¶ 92-97). The NMS Consent Judgment
provided both federal and state releases to the financial institutions in exchange for their promise,
among other things, to adhere to certain specified servicing standards and to provide consumer relief
to borrowers. (TAC ¶ 97-99). Among other things, Defendants were required to provide $4.2 billion
of consumer relief to borrowers whose loans they owned. (TAC ¶ 100).
Accordingly, from September 13, 2012 through January 13, 2013, as part of this $4.2 billion
consumer relief, Defendants sent over 50,000 letters to borrowers forgiving various loans. However,
among these loans Defendants purportedly forgave thousands it did not own, including multiple loans
it had sold to the Plaintiffs. (TAC ¶¶ 102-08). Though Plaintiffs attached lists of such loans as they
are aware of to the TAC, nevertheless, Defendants purported to forgive multiple loans it sold to
Plaintiffs that it has refused to identify. (TAC ¶¶ 107-08). Similarly, Plaintiffs have also pled that
Defendant JPMC entered into a $13 billion settlement with the Department of Justice on November
19, 2013 (“RMBS Settlement”) under the terms of which JPMC agreed to pay $13 billion in return for
complete civil immunity. (TAC ¶ 146). Pursuant to the RMBS Settlement, these payments included
{00020219 4 } 17
$4 billion of consumer relief, pursuant to which Defendants wrongfully claimed credit for the full
indebtedness owed by borrowers whose loans Defendants had already sold to Plaintiffs (TAC ¶ 147).
In this case, Plaintiffs contend that this conduct, as well as other conduct described above that
predates the NMS and RMBS, constitutes breach of contract, and forms the basis for Plaintiffs’ tort
claims including fraud and tortious interference. It is the same conduct, the use of loans that
Defendants had already sold (to others as well as to Plaintiffs) as part of proof of Defendants’
compliance with the consent judgments with the government, that provides the focus of the qui tam
Case as well as for a portion of the claims in this case. Compliance with the NMS and RMBS provides
a motive for, and the base of the civil conspiracy that forms a part of Defendants’ wrongful conduct
against Plaintiffs in this case. As such, documents evidencing such activity is relevant and discoverable
in both cases.
Among the documents that Defendants have refused to produce on the basis that they are not
relevant, either on the grounds that they relate to the qui tam Case or somehow do not relate to
Plaintiffs’ breach of contract claims, are those that identify those borrowers for whom Defendants
claimed credit for providing consumer relief, those that relate to policies and procedures or manuals
regarding when releases are to be provided, the criteria and methodology for selection of those
borrowers, as well as communications with them, and documents regarding any investigation
Defendants performed regarding release or discharge of those borrowers’ liens or mortgages.
These documents will demonstrate the full scope of the loans for which consumer relief was
claimed and will allow Plaintiffs to compare it to determine, finally and accurately, which loans that
Defendants sold them have been compromised. The documents are also expected to show how
Defendants decided what loans to identify, whether those criteria included proper provision to ensure
that Defendants knew that they owned the loans and had the right to do forgive them. As such, they
{00020219 4 } 18
are not simply relevant to the qui tam Case, but also directly concern the issues in the breach of contract
case. Defendants should be compelled to produce them.
B. Defendants Have Opened the Door to Discovery that Relates to the qui tam Case
Defendants have made multiple requests to Plaintiffs in their own discovery demands, to
produce documents that relate to the qui tam Case. For example, Defendants have asked that Plaintiffs
produce documents including, but not limited to the following categories:
(1) communications between Plaintiffs and “any government regulators or authorities

regarding Chase”12,
(2) all documents “relating to Chase’s alleged violations of federal, state and local laws
and regulations”13
(3) all documents “relating to Chase’s alleged violations of any agreements with federal
and state governments”14 and
(4) all documents relating to Plaintiffs’ allegations regarding Chase’s
(a) sale of “non-conforming deficiency claims in place of first mortgage

loans;”
(b) withholding “information and documents concerning the loans it

sold”;
(c) sale of loans in which “Chase had violated applicable law in its
dealings with the borrowers”
(d) acceptance and retention of “payments [Chase] received from

borrowers and/or insurance companies on loans it sold” and
(e) pulling back of “valuable loans . . . and adding loans that violated
loan servicing and consumer protection laws.”15
Assuming that Defendants do not intend to seek documents simply for the sake of adding to
Plaintiffs’ costs, they must consider the requests appropriate for production here. Plaintiffs do not
12 Defendants’ Request No. (“DRN”) 15, Chaitman Dec. Exhibit O.

13 DRN 17
14 DRN 18
15 DRN 19
{00020219 4 } 19
disagree, and have agreed to produce responsive, non-privileged documents. In complete contrast,
however, Defendants have flatly refused to produce any documents covering the materials that
Defendants have requested.
This includes directly comparable categories, such as communications between Defendants
and any government agency regarding the loans Defendants sold to Plaintiffs See Plaintiffs’ Request
No. 26. Similarly, Defendants have asked that Plaintiffs produce “all documents relevant to Chase’s
Systems of Records for mortgage loans, including but not limited to the RCV1 System of Records”
(Defendants’ Request No. 16). They have, however, refused to produce any documents “relating to
the reasons, criteria and/or process by which Defendants selected loans to be placed on their Recovery
One (“RCV1”) data basis [sic]”16 This Court should not permit Defendants to claim that such
documents are irrelevant or overly burdensome to produce, when they have conceded the relevance
and propriety of such requests by asking for the documents themselves.
C. The Requested Discovery Meets Proportionality Requirements
The recent revisions to the Federal Rules now require that the court evaluate whether
discovery demands are proportionate, taking into account (1) the importance of the issues at stake in
the action, (2) the amount in controversy, (3) the parties’ relative access to relevant information, (4)
the parties’ resources, (5) the importance of the discovery in resolving the issues, and (6) whether the
burden or expense of the proposed discovery outweighs its likely benefit. Fed. R. Civ. P. 26. As the
advisory committee notes, this restores proportionality factors to their former position in the
subsection “defining the scope of discovery,” as they were prior to the 1993 amendments to the rules
and allows the court to “identif[y] and discourage[e] discovery overuse.” It does not, however, change
the responsibilities of the parties. State Farm Mutual Automobile Ins. Co. v. Fayda, No. 14 Civ. 9792, 2015
WL 7871037, at *2 (S.D.N.Y. Dec. 3, 2015)
16 PRN 7
{00020219 4 } 20
As set forth above, this Court has already generally considered the costs of litigation and
economy of scale in ordering that the discovery in this case be coordinated with the qui tam Case to
avoid duplication. Discovery is not yet under way in the qui tam Case. Documents produced here will
not need to be re-produced in the District of Columbia when discovery starts. The same teams of
attorneys represent Defendants in both cases and therefore the same documents will not need to be
reviewed or reconsidered twice. Moreover, Plaintiffs anticipate that if a witness is deposed first in this
case, Defendants will argue that this witness cannot be re-deposed in the qui tam Case. If the parties
are generally to coordinate depositions to ensure that they are not duplicated, it is of course essential
to ensure that the parties have access to all the documents they will need in order to prepare.
Defendants’ objections to producing documents are in many cases deliberately oblique. They
have raised a general objection (Number 4) that recites the revisions to the rule. It is not at all clear,
however, which documents Defendants intend to withhold on proportionality grounds or how that
impacts each particular request. With regard to the challenged subject matter of the qui tam Case,
Plaintiffs cannot tell whether Defendants are resisting reviewing categories of documents in this case,
or whether they are resisting reviewing those categories at all. If it is simply a question of whether the
documents are reviewable in this case, then that question has already been answered by this Court’s
order that discovery be coordinated.
Defendants clearly have far more access to the relevant information than do Plaintiffs, and
have far more extensive resources. It almost goes without saying that Defendants are in possession
of documents that are otherwise inaccessible to the Plaintiffs. Defendants’ internal communications,
policies, procedures, lists of loans it owned, servicing histories, are all essential to determine Plaintiffs’
claims and cannot be found through other sources.
{00020219 4 } 21
The importance of the issues at stake—whether the Defendants have taken actions that, in
addition to harming Plaintiffs directly, are also in violation of Defendants’ obligations under their
consent agreements with the government—are hard to overstate.
Finally, as yet Defendants have made no showing of any burden associated with the
production, other than statements in correspondence that there are many employees and many files
that the requests conceivably implicate. JPMC is the largest bank in the United States. Surely, the
proportionality concerns of Rule 26 were not intended to relieve JPMC of its discovery obligations.
This Court should order Defendants to conduct discovery in this case that takes into account
the needs of the qui tam Action. Accordingly, Defendants must search for and produce documents
responsive to Plaintiffs’ Request Nos. 7, 26, 27, 29, 31, and 33-41.
POINT II
DEFENDANTS MUST PRODUCE DOCUMENTS RELATING TO THE LOANS
Defendants have refused to produce documents that relate to specific loans sold, offered or
transferred to the Plaintiffs unless the Plaintiffs first provide Defendants with a list of loan numbers
that Plaintiffs contend Defendants sold them. By the terms of their initial objections17, Defendants
granted themselves the right to “determine[ ] that a given loan was not purchased by Plaintiffs” after
which they will query an “appropriate” database and retrieve “reasonably accessible data.” See, e.g
17
During a recent meet-and-confer, Defendants suggested that they will identify any loans about which there
is a dispute and try to resolve that dispute through the meet-and-confer process. However, Defendants claim
that there is “no remotely feasible way for Chase to compile a list of loan numbers for loans that were purchased
by Plaintiffs from Chase.” See Letter from Christian Pistilli, Esq. to Suzan Arden, Esq., dated March 16, 2016
at page 2, Chaitman Dec. Exhibit J. Of course, Defendants provide no factual support for this contention,
nor do they indicate what records they retain regarding loans they have sold, or where they can be located.
There is nothing whatsoever to indicate that this information is inaccessible, or that locating it is either not
“remotely feasible” or even burdensome. The burden of demonstrating that this information—which is
presumably stored somewhere electronically—is not reasonably accessible is on the Defendants. Moreover,
they must come forward with facts to support this contention. See, e.g. O’Bar v. Lowe’s Home Ctrs., Inc., No. 04
Civ. 19, 2007 WL 1299180, *5 n. 6 (W.D.N.C. May 2, 2007). This requires more than a simple cost estimate
or conclusory characterization. Spieker v. Quest Cherokee, LLC, No. 07 Civ. 1225, 2009 WL 2168892, at *4 (D.
Kan. July 21, 2009); Mikron Indus., Inc. v. Hurd Windows & Doors, Inc., No. 07 Civ. 532, 2008 WL 1805727, at *2
(W.D. Wash. April 21, 2008).
{00020219 4 } 22
Request No. 3, Chaitman Dec. Exhibit A. However, Defendants turned the loans over to the
Plaintiffs without ever providing any loan numbers and, we understand, Defendants have since
changed some of the loan numbers that would have applied in any case,18 and as alleged in the TAC,
Chase deliberately “changed the loan numbers of numerous valuable loans sold to MRS after the
MLPA had been fully executed.” (TAC ¶ 60 i). In order to provide the most scope for identifying all
of the relevant loans, Plaintiffs have now provided Defendants with lists of borrower information,
including social security numbers and property details.
It is inconsistent with Rule 26 for Defendants to attempt to dictate to the Plaintiffs the method
that Plaintiffs may use to conduct their discovery. See, e.g., Wynne v. McCormick & Schmicks’s Seafood
Rests., Inc., No. 06 Civ. 3153, No. C06-3153CW(BZ), 2006 WL 3422226, at *1 (N.D. Cal. Nov. 28,
2006) (holding that “the court is aware of no[ authority] for the proposition that defendants can
dictate the means of discovery that the plaintiffs must use” and granting a motion to compel the
production of company-wide human resources data in a case challenging hiring practices in multiple
restaurants rather than requiring the plaintiffs to first determine whether the practices related to only
one of the restaurants rather than the whole chain.)
However, even if Defendants agree to produce information related to those loans with the
assistance of this information, this does not resolve the dispute regarding what documents must be
provided. All but one of the requests for which Defendants have raised this question do not require
identification of the loans Plaintiffs believe they bought. The requests encompass loans whose details
were itemized on a list Defendants sent to the Plaintiffs (referred to in the TAC as the “Corrupted
List”), or relate to loans whose borrowers were the recipients of debt forgiveness letters pursuant to
Defendants’ obligations to provide consumer relief, or whose liens Defendants released starting in
18 Chaitman Dec. Exh. C.
{00020219 4 } 23
October 2013, apparently robo-signed as part of a project to avoid liability for Defendants’ servicing
violations. As such, since the purpose of the requests is for Defendants to identify loans, not Plaintiffs,
it is not appropriate to require Plaintiffs to provide Defendants with any identification of the loans
they purchased to respond.
Specifically, Request 3 asks Defendants to produce documents to identify the loans they “sold,
transferred, put into the name of, designated as belonging to, or offered to sell to” the Plaintiffs. This
request, by its terms, asks the Defendants to identify the loans, not for Plaintiffs to identify them:
Request 3: Documents sufficient to identify the number, type and amount of every
loan, the security therefor, the status of, and the identity of each and every borrower
which Defendants sold, transferred, put into the name of, designated as belonging to,
or offered to sell to Plaintiffs, irrespective of time period.
Requests 16, 17, 18 and 21 all ask Defendants to produce documents related to the loans set forth on
the Corrupted List—a list that was generated by the Defendants, not the Plaintiffs. Plaintiffs can
certainly provide Defendants with a copy of the Corrupted List that the Defendants provided to them
if Defendants do not have a copy on hand and to the extent Plaintiffs have not already done so, but
Defendants cannot ask Plaintiffs to compile an entirely new list for them that contains more of Chase’s
information about the loans than Chase ever provided to them.
Request 16: All documents relating to the servicing of any of the loans set forth on
the Corrupted List prior to their sale to Plaintiffs, including documents to and from
loan servicers.
Request 17: All documents relating to foreclosure of any mortgage loan set forth on
the Corrupted List prior to their sale to Plaintiffs.
Request 18: All documents relating to the actual principal balance and/or the amount
Defendants charged off on any mortgage loan set forth on the Corrupted List prior to
their sale to Plaintiffs.
Request 21: All documents relating to the receipt by Defendants or any person or
entity acting on any Defendant’s behalf of any payments, whether from borrowers,
insurance companies or any other source, regarding any of the loans set forth on the
Corrupted List after February 25, 2009.
{00020219 4 } 24
Request 28 asks the Defendants to identify the loan numbers and recipients of debt
forgiveness letters sent by the Defendants in 2012 and 2013. Plaintiffs’ list of loan numbers is not
relevant to this request, except to the extent that the Plaintiffs expect some of their loans to be included
within it. There may be more recipients than Plaintiffs are even aware of and so, unless Defendants
identify all the loans, Defendants may not reveal which of Plaintiffs’ loans were included among them.
Request 28: Documents sufficient to determine the loan number and identity of
recipients of debt forgiveness letters that were sent by Defendants on or around
September 13, 2012, December 13, 2012, and/or January 13, 2013, including but not
limited documents regarding loans that had previously been sold or transferred to
others, including but not limited to any of the Plaintiffs.
Request 32 asks the Defendants to provide documents related to their release of liens on
various properties pursuant to the “Pre-DOJ Lien Release Project.” Again, Plaintiffs’ list of loan
numbers is not relevant to this request, except to the extent that the Plaintiffs expect some of their
loans to be included within the loans for which Defendants released liens. Again, there may be more
than Plaintiffs are aware of, since new cases are coming to light all the time, and so unless Defendants
identify all the loans, Defendants may not reveal which of Plaintiffs’ loans were included among them.
Request 32: All documents relating to Defendants’ release of liens on properties

serviced by Defendants pursuant to the “Pre-DOJ Lien Release Project” as described
in paragraph 134 of the TAC, including but not limited to those relating to Defendants’
release of liens and/or discharge of mortgages on loans which Defendants had sold to
Plaintiffs.
This issue is inextricably intertwined with the parties’ dispute about the scope of discovery and
therefore may be resolved now. Accordingly, this Court should order that Defendants must produce
documents responsive to Plaintiffs’ Request Nos. 3, 16-18, 21, 28 and 32 without restricting such
response to those documents it can identify either by provision of a loan number or the lists of
information Plaintiffs have provided.
{00020219 4 } 25
CONCLUSION
For all the foregoing reasons, Plaintiffs’ Motion to Compel should be granted in its entirety.
Dated: New York, New York

May 27, 2016
CHAITMAN LLP
By: /s/ Helen Davis Chaitman

hchaitman@chaitmanllp.com
Lance Gotthoffer
lgotthoffer@chaitmanllp.com
Suzan Arden (SA-4715)

465 Park Avenue

Phone & Fax: 888-759-1114
{00020219 4 } 26
APPENDIX 1
Documents Defendants Refuse to Produce That Relate to the qui tam Case or are
Purportedly Beyond the Scope of the Breach of Contract Claims
(Discussed in Point I)
Request No. 5
All documents relating to Chase’s submission of evidence of its provision of consumer

relief as required by the Emergency Economic Stabilization Act of 2008 and relating
to Chase’s satisfaction of the consumer relief requirements of the National Mortgage
Settlement Consent Judgment and its Exhibits as described and defined in paragraph
97 of the TAC. These documents should include identification of the number, type
and amount of every loan, and the identity of every borrower for which Chase claimed
consumer relief credit.
Response
Chase objects to this request on the grounds that it is overly broad and unduly
burdensome, calls for documents that are not reasonably calculated to lead to the
discovery of admissible evidence, and calls for documents that are not relevant to the
claims or defenses of the parties to this action or are disproportionate to the needs of
the case. Chase further objects to this request to the extent it seeks information subject
to any confidentiality agreement, bank examination privilege, or other applicable
privilege. In light of these objections and the General Objections and Responses set
forth above, any materials responsive to this request will not be produced by Chase
except to the extent that such materials are otherwise encompassed within Chase’s
commitments to produce set forth elsewhere herein.
Request No. 7
All documents relating to the reasons, criteria and/or process by which Defendants
selected loans to be placed on their Recovery One (“RCV1”) data basis [sic]
Response
the case. Chase further objects to this request on the grounds that it is vague and
ambiguous in referring to the RCVI “data basis”. In light of these objections and the
General Objections and Responses set forth above, any materials responsive to this
request will not be produced by Chase except to the extent that such materials are
otherwise encompassed within Chase’s commitments to produce set forth elsewhere
herein.
{00020219 4 } 27
Request No. 26
All communications between Defendants and any government agency regarding any
of the MLPA Loans, whether such communication exclusively concerns the MLPA
Loans or otherwise.
Response
Chase objects to this request on the grounds that it is vague, ambiguous, overly broad
and unduly burdensome, calls for documents that are not reasonably calculated to lead
to the discovery of admissible evidence, and calls for documents that are not relevant
to the claims or defenses of the parties to this action or are disproportionate to the
needs of the case. Chase further objects to this request to the extent it seeks
information subject to any confidentiality agreement, bank examination privilege, or
other applicable privilege. In light of these objections and the General Objections and
Responses set forth above, any materials responsive to this request will not be
produced by Chase except to the extent that such materials are otherwise encompassed
within Chase’s commitments to produce set forth elsewhere herein.
Request No. 27
All documents relating to the selection of, and/or criteria for the selection of, and the
methodology actually used for the selection of, recipients of debt forgiveness letters,
including but not limited to those debt forgiveness letters that were sent by Defendants
on or around September 13, 2012, December 13, 2012, and/or January 13, 2013.
Response
the case. In light of these objections and the General Objections and Responses set
Request No. 29
All documents evidencing communications with the borrowers for whose loans Chase
claimed consumer relief pursuant to the Emergency Economic Stabilization Act of
2008, the NMS Consent Judgment, or the RMBS Settlement.
Response
{00020219 4 } 28
Request No. 31
All documents relating to any communications between Defendants and any local or
municipal authority, regardless of timeframe, regarding properties that served as
collateral for loans that Defendants ultimately transferred to Plaintiffs.
Response
Request No. 33
All documents relating to any investigation or research performed by or on behalf of

Defendants prior to releasing such liens, discharging such mortgages, or forgiving
loans that Defendants had sold to Plaintiffs.
Response
the case. Chase further objects to this request on the grounds that it is vague and
ambiguous in failing to specify the liens or mortgages to which it refers. In light of
these objections and the General Objections and Responses set forth above, any
materials responsive to this request will not be produced by Chase except to the extent
that such materials are otherwise encompassed within Chase’s commitments to
produce set forth elsewhere herein.
{00020219 4 } 29
Request No. 34
All documents evidencing communications by Defendants whose persons engaged or

hired to provide services with regard to releasing such liens, discharging such
mortgages, or forgiving loans, including but not limited to those loans that Defendants
had previously sold to Plaintiffs.
Response
the case. Chase further objects to this request on the grounds that it is vague,
ambiguous and unintelligible. In light of these objections and the General Objections
and Responses set forth above, any materials responsive to this request will not be
produced by Chase except to the extent that such materials are otherwise encompassed
within Chase’s commitments to produce set forth elsewhere herein.
Request No. 35
All documents evidencing communications with borrowers for whom You granted
loan modifications and for which You claimed consumer relief credits under Exhibit
D of the NMS Consent Judgment as alleged in paragraph 100 of the TAC.
Response
Request No. 36
Documents sufficient to identify the following information regarding, referring or

relating to modifications of all first or second lien mortgage loans for which You
claimed consumer relief credits under Exhibit D of the Consent Judgment: (i)
Borrower name; (ii) Loan number; (iii) Property address; (iv) Original loan amount; (v)
Origination date; (vi) Charge off amount; and (vii) Charge off date.
{00020219 4 } 30
Response
Request No. 37
All communications, and all documents regarding communications concerning any

exclusion or carve-out from the RMBS Settlement of the claims in the False Claims
Act lawsuit now captioned United States of America et al ex rel. Lawrence Schneider v. J.P.
Morgan Chase Bank, National Association, et al., 114-CV-01047-RMC, United States
District Court for the District of Columbia and any prior caption.
Response
Request No. 38
All documents regarding, referring or relating to Your communications with the

Monitor of the NMS Consent Judgment, or firms and individuals employed by him,
discussing RCV1, which is referred to in paragraph 60 of the TAC.
Response
{00020219 4 } 31
Request No. 39
Documents sufficient to identify the following information regarding, referring or

relating to all loans where the loan was “lien released,” and sent by You to National
Title Clearing for processing the lien releases between January 1, 2013 – December 31,
2014: (i) Borrower name; (ii) Loan number; (iii) Property address; (iv) Original loan
amount; and (v) Origination date.
Response
Request No. 40
All policies, procedures, manuals, instructions, guidelines, or similar documents

showing Your processes to determine when a lien release or Vacation of Lien Release
is to be provided for a loan.
Response
Request No. 41
Documents sufficient to identify the following information regarding which loans

were identified by You for a “Vacation of Modification of Mortgage”, and sent by You
to Nationwide Title Clearing for processing the Vacation of Modification of Mortgage
between January 1, 2014 – December 31, 2014, including: (i) Borrower name; (ii) Loan
number; (iii) Property address; (iv) Original loan amount; and (v) Origination date.
{00020219 4 } 32
Response
{00020219 4 } 33
APPENDIX 2
Documents Defendants Purportedly Require Identification of Loans

to Consider What Documents They Will Produce
(Discussed in Point II)
Request No. 3
Documents sufficient to identify the number, type and amount of every loan, the
security therefor, the status of, and the identity of each and every borrower which
Defendants sold, transferred, put into the name of, designated as belonging to, or
offered to sell to Plaintiffs, irrespective of time period.
Response
the case. Subject to and without waiving these objections and the General Objections
and Responses set forth above, Chase will produce any responsive, non-privileged
documents that it is able to locate in the custodial files of the individuals listed in
Appendix A using the date ranges listed in Appendix A and the search terms listed in
Appendix B hereto.
In addition, Chase will provide available, non-privileged data regarding any loan
purchased by Plaintiffs from Chase under the MLPA pursuant to the following
procedure:
(1) Plaintiffs shall provide Chase with a list of loan numbers for loans
allegedly purchased by Plaintiffs from Chase;
(2) Unless Chase determines that a given loan was not purchased by
Plaintiffs, Chase will query the appropriate database(s) and retrieve any reasonably
accessible data regarding the loans; and
(3) Plaintiffs and Chase shall confer in good faith regarding which
available data fields shall be produced for the loans.
Request No. 16
All documents relating to the servicing of any of the loans set forth on the Corrupted
List prior to their sale to Plaintiffs, including documents to and from loan servicers.
Response
{00020219 4 } 34
Appendix B hereto.
procedure:
(1) Plaintiffs shall provide Chase with a list of loan numbers for loans allegedly
purchased by Plaintiffs from Chase;
(2) Unless Chase determines that a given loan was not purchased by Plaintiffs,
Chase will query the appropriate database(s) and retrieve any reasonably
accessible servicing-related data regarding the loans; and
(3) Plaintiffs and Chase shall confer in good faith regarding which available
data fields (if any) shall be produced for the loans.
Request No. 17
All documents relating to foreclosure of any mortgage loan set forth on the Corrupted
List prior to their sale to Plaintiffs.
Response
Appendix B hereto.
procedure:
{00020219 4 } 35
Request No. 18
All documents relating to the actual principal balance and/or the amount Defendants
charged off on any mortgage loan set forth on the Corrupted List prior to their sale to
Plaintiffs.
Response
Appendix B hereto.
procedure:
Request No. 21
All documents relating to the receipt by Defendants or any person or entity acting on
any Defendant’s behalf of any payments, whether from borrowers, insurance
companies or any other source, regarding any of the loans set forth on the Corrupted
List after February 25, 2009.
Response
Appendix B hereto.
{00020219 4 } 36
procedure:
accessible post-sale payment data regarding the loans; and
Request No. 28
Documents sufficient to determine the loan number and identity of recipients of debt
forgiveness letters that were sent by Defendants on or around September 13, 2012,
December 13, 2012, and/or January 13, 2013, including but not limited documents
regarding loans that had previously been sold or transferred to others, including but
not limited to any of the Plaintiffs.
Response
the case.
Subject to and without waiving these objections and the General Objections and
Responses set forth above, Chase will search for and produce documents sufficient to
show the loan number and identity of recipients of debt forgiveness letters sent by
Chase relating to loans purchased by Plaintiffs pursuant to the following procedure:
Chase will make reasonable efforts to determine whether a debt
forgiveness letter was sent to a borrower regarding that loan; and
(3) Chase shall produce a copy of any such debt forgiveness letter as well as
any subsequent communications with the borrower indicating that the
debt forgiveness letter had been sent in error.
Request No. 32
All documents relating to Defendants’ release of liens on properties serviced by

Defendants pursuant to the “Pre-DOJ Lien Release Project” as described in paragraph
134 of the TAC, including but not limited to those relating to Defendants’ release of
liens and/or discharge of mortgages on loans which Defendants had sold to Plaintiffs.
{00020219 4 } 37
Response
the case.
Subject to and without waiving these objections and the General Objections and
Responses set forth above, Chase will search for and produce documents sufficient to
show the loan number and identity of recipients of debt forgiveness letters sent by
Chase relating to loans purchased by Plaintiffs pursuant to the following procedure:
Chase will make reasonable efforts to determine whether a lien release was
recorded for the property by Chase; and
(3) Chase shall produce a copy of any such lien release as well as any
subsequent instrument vacating the release.
{00020219 4 } 38

MRS V JPMC Doc 94 - Pla. Motion To Compel Discovery, May 27, 2016

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Case 1:15-cv-00293-LTS-JCF Document 95 Filed 05/27/16 Page 1 of 3

UNITED STATES DISTRICT COURT

MORTGAGE RESOLUTION SERVICING,

DECLARATION OF HELEN DAVIS CHAITMAN IN SUPPORT

“Defendants”), to produce documents in response to Plaintiffs’ document demands (“Plaintiffs’

Requests”) and (b) to define the scope of discovery in this case.

2. Attached hereto as Exhibit A is a copy of Defendants’ Objections and Responses to

5. Attached hereto as Exhibit D is a copy of Defendants’ Objections and Responses to

Plaintiffs’ First Set of Interrogatories, sworn to on February 24, 2016.

6. Attached hereto as Exhibit E is a copy of Plaintiffs’ Notice of Deposition pursuant to

Pre-DOJ Lien Release Project, October 21, 2013.

attorney at Chaitman, to Christian Pistilli, an attorney at Covington & Burling, representing

and Ms. Arden.

between Mr. Pistilli and Ms. Arden.

between Mr. Pistilli and Ms. Arden.

16. Attached hereto as Exhibit O is a copy of Plaintiffs’ Revised Objections and

Responses to Defendants’ First Document Demands.

conferred in an attempt to resolve discovery issues before bringing this motion.

Dated: May 27, 2016

/s/ Helen Davis Chaitman______

UNITED STATES DISTRICT COURT

S&A CAPITAL PARTNERS, INC.,

JPMORGAN CHASE BANK, N.A.,

NATURE OF THIS ACTION

between MRS and Chase Home Finance LLC (the "MLPA").

2. S&A is a Florida corporation located at 6810 N. State Rd. 7, Coconut Creek,

residential mortgage loans from the Defendants.

3. MRS is a Florida limited liability company located at 6810 N. State Road 7,

the Defendants and paid full consideration for the loans.

and second lien residential mortgage loans from the Defendants.

FDIC as Receiver for Washington Mutual Bank, F.S.B.

6. JPMorgan Chase & Company ("JPMC") is a Delaware corporation with its

JPMC is liable for all of the damages sought herein.

Chase and is liable for all of the damages sought herein.

JURISDICTION AND VENUE

supplemental jurisdiction of the state law claims under 28 U.S.C. § 1367(a).

occurred in this District.

ALLEGATIONS COMMON TO ALL CLAIMS

The Plaintiffs' contracts with the Defendants

file and history.

the borrowers so that they can retain their homes.

(the "MMLSA") between S&A as purchaser and Chase as seller.

loans S&A purchased from the Defendants is annexed as Exhibit 1 hereto.

.Some of the 1st Fidelity Loans are listed on Exhibit 2 hereto.

including all of the original documentation for each loan.

sustainable payments which allowed them to retain their homes.

of Plaintiffs purchase from HSBC of approximately $250 million of mortgage loans.

its Recovery department .

collateral properties being offered or the loan balances.

process of competitive bidding.

Chase could get the loans off its books.

$250M deal with HSBC. He communicated this to Guerrero.

the portfolio of loans for $200,000.

approximately $100 million of “impaired first lien mortgage loans.”

33. On December 23, 2008, as instructed, Schneider obtained a cashier’s check

final data tape after he signed the MLPA.

balance of $156,324,399.24. See Exhibit 3 hereto at 1.

purporting to be Exhibit A to the MPLA with a note: “All yours.”

representations or warranties except as expressly provided herein, and with NO RECOURSE

whatsoever to Seller." Exhibit 3 § 4, at 2.

This Agreement includes provisions which the parties hereto

45. The MLPA contains the following choice of law provision:

This Agreement shall be deemed to have been made in the State of