Deutsche Bank National Trust Company attempts foreclosure using a forged promissory note.

In the pending mortgage foreclosure case of DEUTSCHE BANK NATIONAL TRUST COMPANY v. DOMINIC CODIO, et al. (Kings County Supreme Court, Index No.  6839/2010), the law firm of Knuckles, Komosinski & Elliott LLP representing foreclosure plaintiff Deutsche Bank National Trust Company, brought to our office a document that their attorney Fincey John, Esq. claimed was an original promissory note that our client Dominic Codio, the homeowner, had signed when he received a mortgage loan.  Mr. Codio, who was present for the inspection of the document, immediately recognized that his signature and initials at the bottom of each page had been forged and the document was a fake.

Mr. Codio has graciously allowed us to write about his case as a public service to other New York homeowners who are losing their homes to banks and mortgage trusts that submit false, forged and fraudulent documents to courts to prove ownership of mortgage loans that they do not own.   To put it bluntly the banks and mortgage trusts are stealing the homes of people who owe them no money — and getting away with it.

Under New York law a bank or trust must prove ownership of the mortgage loan upon which it is trying to foreclose, which means that the bank must produce the original, properly endorsed promissory note that the homeowner signed.  Without the original promissory note showing an unbroken chain of endorsements transferring ownership of a mortgage loan from the original lender to the bank or mortgage trust currently claiming to own the loan, the homeowner should prevail in a foreclosure (or quiet title) case.

One of the first things our law firm does in a foreclosure or quiet title case is to demand to see the original promissory note.  The law firm representing the bank or mortgage trust usually resists showing it to us at first, but they know they will need to produce the original, properly endorsed promissory note if they want to win at trial.  They also know that if they do not allow the homeowner’s law firm to inspect the original promissory note, the court will probably not allow them to introduce the promissory note as evidence at trial and they will lose the case.  After a frank discussion of the consequences of not allowing us to inspect the original promissory note, the attorneys for the bank or mortgage trust have always agreed to let us inspect the document and make photocopies and/or color scans of the document for our files.

Whenever possible, we have our client present when we inspect the document because the client is the only person in the conference room who saw the original promissory note when it was signed and initialed at the bottom of each page.  Clients can easily tell if their own signatures and initials have been forged and they can spot differences between the original document they signed and the document being presented.

After Mr. Codio informed us that his signature and initials had been forged, we contacted handwriting analyst Roger Rubin, a preeminent expert in his field who has been qualified as an expert witness in well over a hundred New York lawsuits and arbitrations.  He has helped the US Department of Justice solve crimes using handwriting analysis, taught handwriting analysis, and amassed other impressive credentials as detailed in Roger Rubin’s attached Curriculum Vitae.

Mr. Rubin compared the signatures and initials on the document presented as the original promissory note with a variety of other samples of Mr. Codio’s signature that were obtained from official documents, from a copy of the original promissory note filed by the original lender, and from other handwriting samples that Mr. Codio provided.

As detailed in Roger Rubin’s attached report, Mr. Rubin concluded that none of the signatures or initials on the document that Deutsche Bank National Trust Company’s attorney presented to us as the original promissory note had been written by our client Dominic Codio.

We now have undisputed expert proof that all of the signatures and initials on the document presented by plaintiff’s attorney Fincey John, Esq. as the original promissory note are not those of Mr. Codio, which means that Deutsche Bank National Trust Company is trying to foreclose upon Mr. Codio’s home using a forged, fake promissory note.

Last month (4/13) during routine discovery, we were shocked to learn that plaintiff’s attorneys Knuckles, Komosinski & Elliott LLP had not hired a handwriting expert and did not intend to retain an expert, even though they were notified four months earlier (12/12) of Mr. Rubin’s expert findings that the signatures and initials on the document Fincey John, Esq. presented as the original promissory note were not those of Mr. Codio.

Although Dominic Codio has pledged his full cooperation with any handwriting expert that Knuckles, Komosinski & Elliott LLP wishes to use, so far they have not accepted his generous offer and have neglected to hire a handwriting expert to investigate the undisputed expert evidence that they are attempting to foreclose upon Mr. Codio’s home using a forged instrument.  We hope they will eventually agree to investigate whether their law firm is facilitating a fraud on Mr.Codio, our firm, and the Court.

Thanks to Dominic Codio for allowing us to share his story.  We hope that the time, effort and expense that he has been forced to invest in defending against this undisputedly fraudulent foreclosure attempt will not go to waste if other homeowners benefit from learning about Mr. Codio’s ordeal.

Expect to see updates as this important case develops.

LENOIR LAW FIRM, PLLC
2753 Broadway, Suite 251
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

Important information:  This is legal advertising.  It contains no legal advice and makes no representation as to the outcome of any legal matter. The information on this blog and website may not apply to your individual situation and should not be relied upon for any purpose.

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Posted in 1. Foreclosure Defense, 2. Quiet Title Lawsuits, Attorney Blog, Foreclosure Fraud | Leave a comment

LeNoir Law Firm Quoted in National News on Million Dollar Fashion Week Slapping Lawsuit

The other day a reporter named Natalie Wolchover from LifesLittleMysteries.com called and asked me whether a person could be sued for $1 million dollars for slapping someone.  We ended up having an interesting conversation.  She wrote a blog post that ended up in national news.  Click here to read the article on Yahoo News.  Or click here for a PDF.

LENOIR LAW FIRM
2753 Broadway, Suite 251
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

Important information:  This is legal advertising.  It contains no legal advice and makes no representation as to the outcome of any legal matter. The information on this blog and website may not apply to your individual situation and should not be relied upon for any purpose.

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The Mathematics of Quiet Title

Due to continuing rampant fraud in the mortgage industry, the LeNoir Law Firm believes that the overwhelming majority of New York quiet title actions can be won if handled properly.

The average size of a mortgage loan that the LeNoir Law Firm challenges in a quiet title lawsuit is about $400,000. We usually charge a flat legal fee of $7,000 to handle a homeowner’s quiet title case from beginning to end. The out-of-pocket expenses (not legal fees) of a quiet title case can vary significantly but average around $2,500. This means that the homeowner will spend an average of $9,500 for the entire quiet title case.

If the homeowner wins the quiet title case, the homeowner sheds the $400,000 mortgage debt and gains $390,500 in non-taxable debt relief ($400,000 – $9,500). This comes out to a 4,111% tax-free return on the homeowner’s $9,500 investment. If the homeowner loses the quiet title case, the maximum loss will be the $9,500 invested — which is only 2.4% of the $400,000 mortgage loan balance being challenged.

With odds like these, a quiet title lawsuit may be the best bet going.

LENOIR LAW FIRM
2753 Broadway, Suite 251
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

Important information:  This is legal advertising.  It contains no legal advice and makes no representation as to the outcome of any legal matter. The information on this blog and website may not apply to your individual situation and should not be relied upon for any purpose.

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The Best Time to File a Quiet Title Lawsuit

Clients often ask us whether they should file a quiet title lawsuit, either now or in the future.  As we have written previously, a quiet title lawsuit is a legal action against the bank claiming to own your mortgage loan, and banks that may have claimed to have owned the loan previously, to prove that they are the actual owners of the loan.

If no bank can prove that it owns your mortgage loan, then the mortgage lien on your title must be removed. You are then free to keep or sell the property as you please, and you owe no money on your former mortgage loan. In fact, as part of the quiet title case, you may be able to get a judgment against the bank for return of the mortgage payments you have made in the past.

Additionally, your attorney can force the three national credit reporting agencies (Equifax, Experian and Transunion) to remove all negative records of the mortgage loan from your credit reports.  This can substantially increase your credit score and help you qualify for a new mortgage.

The best time to file a quiet title lawsuit is when the homeowner is current on mortgage payments. If the homeowner is having trouble making mortgage payments on time, bringing the quiet title action might provoke a foreclosure.

The next best time to bring a quiet title action is when a homeowner has missed numerous mortgage payments, and the bank has taken no action to foreclose, or has started a foreclosure case but dropped it. These are strong indicators that the bank does not believe it could win the foreclosure, often due to lack of standing (which generally means ownership of the mortgage loan). If the bank could not win the foreclosure, it is very unlikely that it could win the quiet title case.

Whether the homeowner wins the quiet title case will usually depend on whether the bank can produce a properly endorsed original promissory note. The only way to find out whether the bank has the required documentation is to start a quiet title lawsuit. The bank will never show you the promissory note voluntarily. Your attorney must demand to see the original promissory note through discovery in the quiet title case.

Given all of the problems that banks have had in mortgage foreclosures, it is unlikely that the bank will be able to produce the original promissory note with all proper endorsements.     In our opinion most New York homeowners with mortgages stand a good chance of winning a quiet title case.  The potential upside to the homeowner of shedding the mortgage loan and getting a money judgment against the bank is many times greater than the legal fees and expenses of the quiet title action.

For further information on quiet title actions, please contact the LeNoir Law Firm.

LENOIR LAW FIRM
2753 Broadway, Suite 251
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

Important information:  This is legal advertising.  It contains no legal advice and makes no representation as to the outcome of any legal matter. The information on this blog and website may not apply to your individual situation and should not be relied upon for any purpose.

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Ever wonder why banks choose not to take advantage of federal mortgage loan modification programs?

Insider dealing at the expense of homeowners and taxpayers continues, and the financial incentives for most types of mortgage-related fraud will be unaffected by the recent $26 billion dollar federal/state foreclosure fraud settlement.

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A Homeowner May Have a Better Chance of Winning a Quiet Title Lawsuit than a Foreclosure

A quiet title action is a lawsuit by a homeowner against the bank claiming to own the homeowner’s mortgage loan to force the bank to prove that it owns the promissory note for the loan.  If the bank cannot prove that it owns the promissory note, the homeowner should win the quiet title case. 

Winning the quiet title case means that the mortgage is extinguished (deleted) and the homeowner owns the property free and clear of the mortgage.  The homeowner owes no money to the bank and may keep or sell the home as desired. 

QUIET TITLE:  BANK MUST PROVE OWNERSHIP OF THE MORTGAGE LOAN

In order to stop a homeowner from winning a quiet title case, the bank must prove that it owns the homeowner’s mortgage loan.

To prove ownership of a mortgage loan, the bank (or its attorneys) must possess the original promissory note for the mortgage loan, and it must have been properly endorsed (signed over) by a person with authority to assign the loan.  The note can be endorsed to the bank or endorsed “in blank,” such as “Pay to the Order of _________________________.    Signed,  Rabid Robosigner.”

Even when a bank produces a supposedly “endorsed” promissory note in a quiet title case, there may be numerous grounds to challenge its validity (and the bank’s claim to own the mortgage loan).  The reasons why an “endorsed” promissory note may be legally defective are beyond the scope of this article, but stay tuned.

FORECLOSURE:  BANK MUST PROVE RIGHT TO ENFORCE THE MORTGAGE LOAN

Ironically, to win a foreclosure case and take away a family’s home, the bank does not have to own the mortgage loan.  It only has to prove that it has the right to enforce the loan.

Although the foreclosing bank still must possess the original promissory note, the note does not have to be endorsed.  The law only requires the bank to present proof that the previous owner of the loan had the intent to transfer the loan to the foreclosing bank.

It has become harder for banks to prove intent to transfer since the Silverberg case, which invalidated the majority of mortgage loan transfer documents on the basis that they were illegally executed by “robo-signers” claiming to represent MERS (which did not own the loans and had no authority to transfer them).

Still, it is easier for a bank to prove its right to enforce a mortgage loan (in a foreclosure case) than to prove it owns the loan (as required in a quiet title lawsuit).  Since the bank must prove more to win the quiet title case, a homeowner may have a better chance of winning a quiet title lawsuit than a foreclosure case involving the same mortgage loan.

For further information on the benefits of quiet title lawsuits, please contact our office.

LENOIR LAW FIRM
2753 Broadway, Suite 251
New York, New York 10025
Office: 212-531-0284
Email:
info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

Important information:  This is legal advertising.  It contains no legal advice and makes no representation as to the outcome of any legal matter. The information on this blog and website may not apply to your individual situation and should not be relied upon for any purpose.

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A Rare Opportunity to Win a Quiet Title Case in New York

A quiet title case is a lawsuit by a homeowner against any bank that may claim to own the homeowner’s mortgage loan to force the bank to prove that it owns the loan.  If no bank can produce the original mortgage and endorsed properly endorsed promissory note, the homeowner should win the quiet title case.

Winning the quiet title case means that the mortgage lien is extinguished (deleted) and the homeowner owns the property free and clear of the mortgage.  The homeowner may keep or sell the home without paying the former mortgage debt.

Winning a quiet title case in New York became easier in 2011 when the law changed to help homeowners.  The change of law occurred in the case of Bank of New York v. Silverberg (2d Dept. 2011), in which a New York Appellate Court ruled that all trades of mortgages on the Mortgage Electronic Registration Systems, Inc. (MERS) system were invalid because MERS never holds any of  the underlying promissory notes.

MERS (mis)handles the majority of mortgages in New York and the United States.  If your mortgage loan paperwork mentions Mortgage Electronic Registration Systems, Inc. (MERS), then MERS probably mishandles your mortgage and the Silverberg case may invalidate your mortgage debt in a New York quiet title action.

Keep in mind that the change of law created by the Silverberg case may not be permanent, so it is important to start your quiet title action as soon as possible.

For further information on quiet title actions by homeowners, contact the LeNoir Law Firm to speak with an attorney.

LENOIR LAW FIRM
2753 Broadway, Suite 251
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

Important information:  This is legal advertising.  It contains no legal advice and makes no representation as to the outcome of any legal matter. The information on this blog and website may not apply to your individual situation and should not be relied upon for any purpose.

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The Motion to Dismiss a New York Foreclosure Case: Part 3 of 3

Free Document:  Motion to Dismiss a New York Foreclosure Case for Lack of Personal Jurisdiction

In Part 3 of this series we discuss the Motion to Dismiss a New York Foreclosure Case because the court lacks “personal jurisdiction” because the Summons and Complaint and/or other required documents were not properly delivered to the homeowner.  When the Court lacks personal jurisdiction in a foreclosure case, the Court may not take any action against you including foreclosing your mortgage.  

Of course, the homeowner’s attorneys must tell the judge that the Court lacks jurisdiction over the homeowner.  If the judge does not realize that the Court lacks personal jurisdiction, a foreclosure judgment will probably be entered and the property sold. 

The purpose of the Motion to Dismiss for Lack of Personal Jurisdiction is to notify the Court that the Summons and Complaint and/or other required documents were not delivered to the homeowner in a lawful manner.  If all necessary documents were not delivered properly according to strict legal requirements, the Court does not have personal jurisdiction over the homeowner and the foreclosure case must be dismissed.

In New York, a Motion to Dismiss for Lack of Personal Jurisdiction can be made either (1) instead of answering the foreclosure complaint or (2) after answering the foreclosure complaint.  The LeNoir Law Firm prefers to make the motion to dismiss instead of answering the foreclosure complaint.  The motion to dismiss can cause the foreclosure case to be dismissed without the homeowner ever having to admit or deny the bank’s claims.  It can also save substantially on legal fees.

If the homeowner loses the Motion to Dismiss for Lack of Personal Jurisdiction, it just means that the homeowner’s attorney has to answer the foreclosure complaint.  Meanwhile, the homeowner usually enjoys several more months in the home while the Motion to Dismiss is being argued and decided by the judge.

In the attached Motion to Dismiss, the LeNoir Law Firm made a variety of arguments as to why the Court lacked personal jurisdiction over the homeowner and therefore had no right to conduct foreclosure proceedings.  The homeowner’s name and identifying information have been removed to protect our client’s privacy. 

For further information on motions to dismiss foreclosure cases for lack of personal jurisdiction, please contact our office.

LENOIR LAW FIRM
2753 Broadway, Suite 251
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

Important information:  This is legal advertising.  It contains no legal advice and makes no representation as to the outcome of any legal matter. The information on this blog and website may not apply to your individual situation and should not be relied upon for any purpose.

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Most New York Home Mortgages May be “Unforeclosable” under a 2011 Appellate Court Ruling

A recent New York Appellate Court ruling may mean that the majority of home mortgages in New York State are “unforeclosable,” and that homeowners may keep their homes without making mortgage payments.

In the majority of New York foreclosure cases, the infamous electronic mortgage registry known as Mortgage Electronic Registration Systems, Inc. (MERS) executes an “assignment” document that supposedly transfers ownership of the mortgage to the foreclosing bank shortly before the bank starts the foreclosure. 

However, in the foreclosure case of Bank of New York v. Silverberg (2d Dept. 2011), a New York appellate court dismissed the case on the basis that the alleged “assignment” of the mortgage by MERS was invalid.  The court ruled that MERS had no right to assign The Silverbergs’ mortgage because MERS did not hold (own) the promissory note for the underlying mortgage loan.  

The appellate court’s ruling was based upon the fundamental rules of property law that: (1) a mortgage cannot be assigned unless the underlying promissory note is also assigned; and (2) only the holder of the promissory note may assign it to another party. 

MERS does not own or possess the promissory notes for any of the mortgage loans that it purportedly ”assigns” to banks in preparation for foreclosures.

The benefits of the Silverberg case to homeowners facing foreclosure can hardly be overstated.  Under the Silverberg decision, practically all foreclosure cases involving faulty ”assignments” of mortgages by MERS are required to be dismissed for lack of standing.

The Silverberg case is THE law governing foreclosures of homes located in the following New York counties:  Kings (Brooklyn), Queens, Nassau, Suffolk, Richmond (Staten Island), Westchester, Rockland, Orange, Putnam and Dutchess. 

Although the Silverberg case is only required to be followed by courts in these counties, its sound reasoning may persuade judges elsewhere to grant motions to dismiss for lack of standing when an invalid MERS “assignment” is involved.  To quote the court in Silverberg  (see Page 9 of the attached decision):  

MERS purportedly holds approximately 60 million mortgage loans . . . and is involved in the origination of approximately 60% of all mortgage loans in the United States . . . This Court is mindful of the impact that this decision may have on the mortgage industry in New York, and perhaps the nation.  Nonetheless, the law must not yield to expediency and the convenience of lending institutions. Proper procedures must be followed to ensure the reliability of the chain of ownership, to secure the dependable transfer of property, and to assure the enforcement of the rules that govern real property.

Contact the LeNoir Law Firm to find out whether your home mortgage may be “unforeclosable.”

LENOIR LAW FIRM
2753 Broadway, Suite 251
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

Important information:  This is legal advertising.  It contains no legal advice and makes no representation as to the outcome of any legal matter. The information on this blog and website may not apply to your individual situation and should not be relied upon for any purpose.

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Posted in 1. Foreclosure Defense, 3. Debt Collection Defense, Attorney Blog, Debt Collection Fraud, Foreclosure Fraud, MERS | Leave a comment

New York City Council, US Supreme Court May Determine the Legality of MERS

A resolution was introduced in New York City Council this week, “calling on the New York State Legislature and the Governor to enact legislation that would prohibit lenders from concealing mortgage assignments through the use of the Mortgage Electronic Registration Systems, Inc., known as MERS.”   The controversial MERS electronic mortgage trading system has emerged as the epicenter of the national foreclosure fraud epidemic.  

We think the NYC Council resolution will pass and lead the way to strong anti-MERS legislation in New York State.   Few New York politicians will risk political suicide by voting to keep residential mortgage transfer records secret from their angry constituents. 

In other news the United States Supreme Court was asked for the first time to consider a number of issues relating to foreclosure fraud and the dubious legality of the MERS system.  

In the case of Jose Gomes v. Countrywide Home Loans, Inc. a California appellate court ruled that MERS had the right to foreclose on San Diego homeowner Jose Gomes without allowing Gomes to question if Countrywide (on whose behalf MERS was allegedly acting) actually held the note on his house.  

Mr. Gomes’ attorney filed an urgent request to the United States Supreme Court (a Petition for Writ of Certiorari) to hear Mr. Gomes’ final appeal before he loses his home.  Unfortunately for Mr. Gomes, his final appeal to the nation’s highest court may never be heard.  The Supreme Court gets to pick and choose which cases it will decide.  

If the Supreme Court decides not to hear the Gomes v. Countrywide case, Mr. Gomes will lose his home to a foreclosing bank that has not proved it owns Mr. Gomes’ mortgage and promissory note.  To make matters worse, Mr. Gomes may be sued again for the same debt if the real owner of his mortgage shows up later and demands the money owed. 

Frankly, we have more faith in New York City, and even Albany, than in the Roberts Supreme Court to protect the rights of homeowners against illegal foreclosures.

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

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Brooklyn’s Own Supreme Court Justice Arthur Schack Breaks New Ground (Again)

In a recent ruling dismissing a foreclosure case, Justice Arthur Schack of Supreme Court, Kings County (Brooklyn) relied on a scathing investigative report on foreclosure fraud and robo-signers produced by two top investigators in the Florida Attorney General’s Office.  Both investigators have been forced to resign, apparently because they knew too much. 

Justice Schack is known for his continuing investigation of foreclosure fraud and “robo-signers.”  He routinely dismisses improperly brought foreclosure cases “with prejudice,” meaning the cases cannot be re-started.   

Click here to read the full story in the Palm Beach Post.

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

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Why the Federal Government Refuses to Prosecute Top Bank Executives

“As Wall St. Polices Itself, Prosecutors Use Softer Approach”
New York Times, 7/7/11

The title of this New York Times article is misleading because Wall Street has never policed itself and never will.  The article itself (which had a different title yesterday) does an excellent job of explaining how the federal government arrived at its policy of not prosecuting a single top executive of the major banks that made billions of dollars through the criminal practices that caused the nation’s financial, housing and mortgage fraud crises. 

Under its new policy the Justice Department routinely signs ”nonprosecution” and “deferred prosecution” agreements with major banks and corporations in the course of settling corporate “white collar” criminal cases. The executives who orchestrated the crimes agree that their corporation will pay money to the government in exchange for immunity from prosecution of the executives.  If the government wants to reach a monetary settlement, it must strike a deal with the criminal executives. 

A more rational approach would be for the government to prosecute the executives who participated in the corporate crimes as a deterrent to other wayward executives.  That was the federal government’s policy before it was changed to protect politically connected bank and corporate executives from prosecution. 

It is said that prison is the only consequence that the extremely wealthy fear.  The federal government’s current policy leaves millionaire and billionaire corporate executives feeling “prison proof” and free to commit more crimes to become wealthier. 

Let’s hope that New York State’s Attorney General Eric Schneiderman, who has undertaken a massive investigation of the crimes committed by the major banks and their executives, will teach these arrogant white collar criminals otherwise. 

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: 212-531-0284
Email: i
nfo@DebtInversion.com
Web:
www.DebtInversion.com
Blog:
www.DebtInversion.com/blog

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Revolution Comes from the Bottom Up – Never from the Top Down

“Big Banks Easing Terms on Loans Deemed as Risks”
New York Times, 7/3/11

JP Morgan Chase and Bank of America would not have given these homeowners the time of day if individual homeowners across the country hadn’t taken them on, by insisting these banks prove ownership of the mortgages and promissory notes on their homes.

Often the banks cannot prove ownership.  They are granting these “generous” loan modifications to avoid having more delinquent mortgages and losing more foreclosure cases for lack of standing to foreclose. 

Don’t settle for a loan modification just because a bank gives it to you without asking first.  A generous bank is an oxymoron.  You may already own your home free and clear of any mortgage.  You may owe the bank nothing. 

In fact, another bank may own your mortgage and promissory note.  That bank may sue you later even if you make all “modified” payments to the first bank.

Don’t become another victim of mortgage fraud by JP Morgan Chase, Bank of America or another major bank.  If a bank gives you a deal that sounds too good to be true, contact the LeNoir Law Firm to learn your legal options.

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

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The Motion to Dismiss a New York Foreclosure Case: Part 2 of 3

Free Document:  Motion to Dismiss a New York Foreclosure Case for Lack of Standing to Foreclose

In Part 2 of this series we discuss the Motion to Dismiss a New York Foreclosure Case for Lack of Standing to Foreclose.  Lack of standing in a foreclosure case means that the bank trying to foreclose your mortgage and take your home cannot prove that it owned your mortgage and promissory note on the date that the foreclosure case was started.  If the bank did not own your mortgage and promissory note, it had no right to start the foreclosure lawsuit and the case should be dismissed.

When a homeowner’s attorney makes a Motion to Dismiss for Lack of Standing, the bank must prove that it owned the mortgage and promissory note on the date the foreclosure case was started.  You as a homeowner do not have to prove anything.  You only have to question whether the bank owned the mortgage and note on the date the case was started.  If the bank cannot prove it owned the mortgage and note, the foreclosure case must be dismissed. 

When a homeowner wins a Motion to Dismiss for Lack of Standing, the case is often dismissed “with prejudice.”  This means the bank cannot sue the homeowner again for the same claim.  In some cases the homeowner can get the house free and clear of any mortgage because one or more banks that owned or serviced the mortgage mishandled the “paperwork” (which is usually done electronically).

Although the foreclosing bank is required to prove that it owned the mortgage and note on the date the foreclosure case was started, the case is more likely to be dismissed if the homeowner’s attorney can persuade the judge that something improper happened in the transfers of the mortgage and note from bank to bank. 

In the attached Motion to Dismiss, the LeNoir Law Firm made a variety of arguments to convince the judge that the transfers of the mortgage and note were not done in a legal and proper manner.  The homeowner’s name and identifying information have been removed to protect our client’s privacy. 

Keep in mind that this Blog entry and the attached Motion to Dismiss are not legal advice, and that any information and legal arguments presented may not apply to your specific case.  To obtain accurate legal advice regarding a foreclosure case, please contact the LeNoir Law Firm to speak with an attorney.

LENOIR LAW FIRM
461 Central Park West

New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

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“Reckless Endangerment: How Outsized Ambition, Greed, and Corruption Led to Economic Armageddon,” a video interview by Democracy Now!

“I think that there is a genuine sense out there that there are two sets of rules, one for big and powerful institutions that are deemed to be too politically interconnected or powerful to fail, and the rest of us, Main Street,” says our guest Gretchen Morgenson, the Pulitzer Prize-winning business reporter who has written extensively on how the U.S. government has failed to prosecute any of the top figures who played a role in the economic crash.

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

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The Motion to Dismiss a New York Foreclosure Case: Part 1 of 3

A foreclosure lawsuit in New York State begins with the filing in Supreme Court and delivery to the homeowner of a Summons and Complaint.  When a homeowner receives a Summons and Complaint, he or she has three choices:

1.  Do nothing.

2.  Answer the Complaint.

3.  Make a Motion to Dismiss.

Each of these options is discussed below:

1.  Do nothing: 

When you receive a Summons and Complaint for foreclosure of your mortgage, you are required by law to respond.  The two ways to respond are discussed below.  If you do not respond, the bank can get a judgment of foreclosure and possibly a “deficiency judgment.”  A judgment of foreclosure means that the bank has the right to kick you out of your home and sell it or do whatever it wants with it. 

If the bank sells your home for less than the amount they claim is owed on the mortgage, it can enter a deficiency judgment in court that requires you to pay the difference between the amount they say you owe on the mortgage and the lesser amount that the bank receives when it sells your home.  A deficiency judgment can be for tens or hundreds of thousands of dollars. 

A deficiency judgment can result in your wages being garnished, your bank account being seized, and other property being taken away.  A deficiency judgment can cripple you financially.  It can be incredibly expensive to resolve, either through legal action or by paying the amount of the judgment.  

Rather than ignoring the Summons and Complaint, it is better to hire an attorney, or at least represent yourself, to fight the foreclosure case.

2.  Answer the Complaint: 

Although better than doing nothing, answering the complaint requires a great deal more work, and legal fees, than making a motion to dismiss.  Every aspect of the case must be scrutinized and investigated for (1) possible defenses to the foreclosure, (2) counterclaims against the bank, and (3) possible claims against other responsible parties such as Mortgage Electronic Registration Systems (MERS) and process service companies.

Furthermore, when you answer the complaint rather than make a Motion to Dismiss the foreclosure case, it pleases the bank’s attorneys that you have taken the next step in the foreclosure process.  They hope that you will continue to participate complacently in the judicial process until they can obtain a judgment of foreclosure of your mortgage, and a “deficiency” monetary judgment against you personally. 

On the other hand, if you answer the Complaint, you at least get your day in court.   In some cases, if you win the foreclosure lawsuit, you can keep your home free and clear of any mortgage.  It is also possible to be awarded monetary damages against the bank suing you and other responsible parties.  This is the goal of the LeNoir Law Firm’s legal strategy of Debt Inversion.  

However, you can still answer the Complaint later if you lose the Motion to Dismiss.  But while the Motion to Dismiss is being decided (which can take many months), you can stay in your home.

3.  Make a Motion to Dismiss:

A motion to dismiss in a foreclosure case is a request to the court that the entire case be thrown out of court because something was not done or was not done correctly.  If there is a good reason to make a motion to dismiss, the LeNoir Law Firm will usually make a motion to dismiss rather than answering the foreclosure complaint.  However, every law firm practices law differently, and this is not legal advice.

The reasons that your attorney may use to make a motion to dismiss are limited only by the law and your attorney’s imagination.  We cannot begin to discuss all of the reasons why a foreclosure case might be dismissed, but in the next two articles in this series, we will discuss the following common reasons for dismissal of a foreclosure action in New York State:

          A.  The plaintiff lacks standing to bring the foreclosure case.  This means that the bank trying to foreclose cannot prove that it owns your mortgage and promissory note.  If the bank does not own your mortgage and promissory note, it has no right to foreclose.

          B.  The court lacks jurisdiction over the defendant.  This means that the home owner has not been served properly with the summons and complaint and other documents required to start a foreclosure case in New York State

Each of the above reasons for dismissing a New York State foreclosure case will be discussed in Parts 2 and 3 of this series.

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

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Thank you, Mr. Schneiderman

NYS Attorney General Eric T. Schneiderman has served subpoenas upon New York State’s largest foreclosure law firm.

Thank you, Mr. Schneiderman. Please serve subpoenas upon the rest of the large and medium-sized foreclosure firms known to have filed  “inaccurate” documents.  Private attorneys do not have your criminal investigative powers and cannot discover, or at least prove, all of the frauds perpetrated against our clients.

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A lawsuit against a mortgage loan servicer is a personal injury action.

Interesting article in The Huffington PostFacing Foreclosure Without Missing A Payment:  One Couple’s Housing Nightmare 

When you finally enter the mortgage loan servicer’s consciousness as a potential threat, they can be incredibly efficient at correcting your account and restoring your credit. It sounds like the couple had a good lawyer.

Now they can sue the loan servicer for their pain and suffering, lost income, damage to credit, etc.  The couple had no contract with the servicer, so a lawsuit against the servicer would essentially be a personal injury action, for which they can recover much larger damages than breach of contract.

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Sue Predatory Telemarketers under the Federal Telephone Consumer Protection Act

The Federal Telephone Consumer Protection Act (TCPA) is a powerful law for suing telemarketers who make harassing telephone calls or send unsolicited marketing faxes.  You can recover $1,500 for each and every violation of the the TCPA plus court costs.

Violations of the federal Telephone Consumer Protection Act for which you can collect monetary damages include:

1. Cell phones and pagers: A telemarketer may not use an auto dialer or an artificial or prerecorded voice message to call cell phones or pagers. All telemarketers use auto dialers and most use artificial or prerecorded voice messages.

2. Residential land lines: A telemarketer may not leave an artificial or prerecorded voice message for calls to your residential land line without your express consent.

3. Voicemail Messages: Anyone using an auto dialer or an artificial or prerecorded voice message to call any number must state the identity of the caller at the beginning of the message and give the address or phone number of the caller during the call.

4. Marketing faxes: Each marketing fax received from a company with which you have no business relationship is a violation of the TCPA. 

Damages recoverable through the Telephone Consumer Protection Act

1. Up to $1,500 per violation or your actual damages, if greater

2. The costs of the lawsuit. (Costs can be substantial because serial predatory telemarketers tend to fight every lawsuit aggressively to deter others from suing them.)

For example, if a company calls your cell phone, or leaves prerecorded messages on your home phone without your consent, or sends you unsolicited marketing faxes, and does so ten times per week, you can recover up to $15,000 per week, or $60,000 per month plus the costs of the lawsuit .

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What is Foreclosure Fraud and How Does It Affect Home Owners and Buyers?

Mortgage foreclosure fraud causes two terrible things to happen: (1) a home owner may be foreclosed upon by a bank that doesn’t own the mortgage and promissory note; not only is the person’s home stolen, but the real owner of the promissory note can sue the former home owner later for the full amount owed on the mortgage; (2) banks selling foreclosed homes may not actually own them because the foreclosure was fraudulent; this means that 20 years down the road when the person wants to sell the home, they may find out that they never owned it, or worse yet, the real owner could show up after the sale and sue to get their property back.

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How and Why Debt Inversion Works

Debt Inversion is a proprietary legal practice of the LeNoir Law Firm designed to turn debtors into creditors by defeating debt collection actions and aggressively suing debt collectors, creditors and the three national credit reporting agencies for violations of your legal rights under federal and state debt collection laws, credit reporting laws and criminal laws. Successful debt inversion allows you to recover monetary damages greater than your debt, so that you make a profit.

The LeNoir Law Firm employs a comprehensive, three-part approach to successful debt inversion:

PART 1: ADVISE

We conduct a complete examination of each new client’s legal and financial circumstances to determine which legal services and strategies will be most beneficial. In certain cases we advise the client that the best strategy is to ignore the debt collectors and do nothing at all — at least for the time being.

If you ignore a debt collector, and the debt collector doesn’t sue you (most don’t), the debt disappears from your credit report, as if it never existed, exactly seven years from the date of your last payment.

Of course, ignoring collectors’ letters and phone calls does not prevent you from suing them for monetary damages for violations of your legal rights. See “Attack” below.

Just as importantly, we warn our clients against debt “solutions” that usually do more harm than good. These include Bankruptcy, Home Refinancing, Debt Settlement, “Credit Repair” and Credit Counseling.

In addition to wasting your scarce money, these strategies can have extremely undesirable consequences such as causing you to lose your home; extending the time period the debt owner has to sue you (the statute of limitations); or lengthening the amount of time that the debt will remain on your credit report.

For example, if you file for bankruptcy, the bankruptcy can remain on your credit report for over 15 years from the date you file. See Bankruptcy. This means that a bankruptcy filed in 2011 can remain on your credit report until 2026 or later.

PART 2: DEFEND

After analyzing the client’s financial and legal circumstances, we take care of matters that require immediate attention, such as eliminating default judgments, termination of wage garnishments, and removal of liens on real estate, financial accounts and other property.

Once the case is on track, we defend our client by forcing the attorneys for the creditor or debt collector that owns the debt (“the collection attorneys”) to produce all documents and witnesses necessary to prove the amount they claim is owed.

Producing all of the necessary paperwork and witnesses is usually impossible or not worth the effort for the collection attorneys, especially since most defaulted debts have been sold from one debt buyer to the next.

The current owner of your account has no power over the employees of the previous owner; nor does it have access to the previous owner’s business records. This means that the collection attorneys must subpoena the records and employees of all of the previous owners of the debt — something they almost never do.

Even if the collection attorneys disregard their usual business practices and serve all of the necessary subpoenas, inevitably one or more of the previous debt owners will have lost or destroyed its records of the client’s account; or employees who kept records of the client’s account for previous debt owners will no longer be employed by them; or one or more of the previous owners of the debt will ignore the subpoena.

This means we win the case because the debt collection attorney is unable to produce the documents and witnesses necessary to prove its client’s case.

In those extremely rare cases in which a collection attorney is able to produce all necessary documents and witnesses and prove in court that you owe the amount claimed, assembling everything they need takes quite a long time.

This allows you to avoid a judgment against you and/or stay in your home much longer than if you did not put up a fight.

In fact, the debt collection business relies on people not fighting back. If everyone put debt collectors to their proof as we do, they would all be forced out of business.

PART 3: ATTACK

Lawsuits for Illegal Debt Collection: All debt collectors break federal and state debt collection laws, credit reporting laws and criminal laws that have been enacted to protect unsophisticated debtors from overly aggressive debt collectors. When debt collectors violate your legal rights, federal law allows you to recover up to $1,000 or your actual damages, plus legal fees and court costs.  You may be able to recover additional amounts under state laws.

Lawsuits for Illegal Credit Reporting: We sue the three national credit reporting agencies; creditors and debt collectors who provide false information to credit bureaus; and companies that misuse information provided by credit bureaus, for violations of federal credit reporting laws. You can recover up to $1,000 or your actual damages for each violation, plus punitive damages, attorney’s fees and court costs.

If you win the lawsuit (or obtain a favorable settlement) and collect monetary damages greater than your debt, if any, you make a profit. This joyful experience is known as Debt Inversion.

Debt Collection Crimes: Many violations of debt collection laws are also violations of federal and New York State criminal laws. In cases of serious misconduct, we refer the creditor or debt collector to federal or state authorities for criminal prosecution, in addition to suing them.

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Great idea. Too bad they didn’t think of it ten years ago.

“Federal officials studying how to protect housing market”,  Washington Post, 1/18/11

“Currently, banks can pool mortgage loans together into an investment and sell that to investors around the globe, passing on all the risk associated with the loans. But a report released by the Treasury Department, as required by the Dodd-Frank law overhauling financial regulation, endorsed the law’s prescription that banks be forced to hold on to a portion of the investment, making it difficult for a bank to ignore the risks associated with lending.” 

Once again the federal government is fighting yesterday’s war.  The housing and mortgage-backed securities markets have already collapsed and banks will only lend to people with stellar credit.  The proposed regulation will not protect against any current risk, but it may come in handy during the next real estate bubble.

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Collection Law Firm Mel S. Harris & Associates Sued for Racketeering in Federal Class Action for Using Robo-Signers and “Sewer Service”

“To get judgments against the borrowers, the judge said, a single Mel Harris employee named Todd Fabacher signed 40,000 affidavits attesting to the accuracy of debt claims.

Assuming 260 business days a year, Fabacher had to have personally (and purportedly knowledgeably) issued an average of twenty affidavits of merit per hour, i.e., one every three minutes, over a continuous eight-hour day.”

Read the Full Article in Forbes

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Complete 185-Page Deposition of Internationally Infamous Robo-Signer Beth Cottrell

Beth Cottrell is one of the thousands of “Vice Presidents” of Mortgage Electronic Registration Systems (MERS).  All large mortgage banks including  Bank of America, JP Morgan/Chase, Citibank, GMAC, etc.  are “members” of MERS.  Any MERS member bank is allowed to appoint any employee it wishes, regardless of inexperience or incompetence, to sign documents prepared by the bank, not as a bank employee but as a “Vice President” of  MERS.   As a Vice President of MERS working for Chase, Ms. Cottrell distinguished herself as one of the world’s most prolific robo-signers.  She was deposed on May 17, 2010 in the case of Chase Home Finance, LLC v. Judith Koren, et al., Circuit Court of the Fifteenth Judicial Circuit, Palm Beach County, Florida, Case No. 50-2008-CA-01687. 

During her deposition Ms. Cottrell admitted to executing 18 thousand documents per month without any personal knowledge of the contents of what she was signing.    In the first page of her deposition testimony, she identified herself as an “Operation Supervisor” for Chase Home Finance.  She did not mention her position as Vice President of MERS, a title under which she had blindly executed hundreds of thousands of documents later used by Chase as evidence in foreclosure cases.

The deposition of Ms. Cottrell is long, so it has been divided into two PDFs, both of which can be downloaded below.  It contains a fascinating story — a must for everyone’s holiday reading list.

Beth Cottrell Deposition – Part 1

Beth Cottrell Deposition – Part 2

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com

Important information:  This document and any attachments contain no legal advice and make no representation as to the outcome of any legal matter.  The information in this legal advertisement may not apply to your individual situation and should not be relied upon for any purpose.

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Bank Executives Flock to Washington to Force Lawmakers to “Legalize” MERS

Designed by the major banks to track the rapid trading of mortgages between themselves, Mortgage Electronic Registration Systems (MERS) has emerged as the epicenter of the current nationwide mortgage foreclosure crisis.   Since MERS was ”discovered” by the media in recent months — which has prompted investigations by all 50 states’ attorneys general — foreclosures nationwide for mortgages traded on the MERS system have ground to a halt.   The problems in foreclosing on these mortgages are expected only to get worse as more details emerge about the rampant fraud perpetrated on homeowners and buyers of foreclosed properties through a criminal conspiracy involving MERS and the major banks.  

The privately-owned MERS system has managed to stay under the radar for years by keeping its internal operations secret from the public.  Homeowners are denied access to MERS records of the trading of their own mortgages.  MERS only allows the bank currently servicing a mortgage loan to access the MERS records for that loan.   Not even other members of MERS are allowed to see the MERS records for mortgage loans that they are not servicing. 

With all of the recent attention on MERS and its role in the massive foreclosure fraud crisis, the banks that own MERS know that they will not be able to keep its internal operations secret much longer.   It’s only a matter of time until the full extent of the illegal activities conducted by MERS through its member banks will become public knowledge.  

Judges that have turned a blind eye to patently fraudulent foreclosure documents for years, are being forced to examine the affidavits, assignments and other documents presented by attorneys for large banks, and to dismiss foreclosure actions that have been tainted by MERS fraud.  Additionally, attorneys in New York and many other states are now being forced to swear under the penalties of perjury that they have reviewed all documents and information pertaining to a foreclosure action and investigated any irregularities, and that the documents and information being presented to the court are complete and accurate to the best of their knowledge. 

This combination of circumstances has created a perfect storm in which banks and foreclosure attorneys have become fearful of bringing foreclosure actions on the vast majority of mortgages that are registered with MERS.  Not only do the banks and foreclosure attorneys risk prosecution for fraud (and disbarment for the attorneys), but every foreclosure that is thrown out of court for fraud sets additional negative legal precedent, and reporting of these cases increases public awareness of MERS fraud.  Increased awareness of MERS fraud has caused many homeowners facing foreclosure to hire foreclosure defense attorneys to challenge the rights of the banks to foreclose — which is creating more negative legal precedent for foreclosing banks.  

Furthermore, increased awareness of MERS fraud by people considering buying foreclosed properties has made them reluctant to buy for fear of not receiving clear title to the properties, since the banks selling the properties may not be the rightful owners.  In fact, major title insurance companies are refusing to insure titles on foreclosure properties whose mortgages were traded through MERS.   Without title insurance, even people who want to buy a foreclosed “MERS property” are not able to get a mortgage.  As a result, banks are holding an increasing inventory of foreclosed properties that they are unable to sell.

Faced with the disastrous consequences of further criminal investigation, civil litigation, and additional publicity regarding the MERS system, the major banks have decided that the simplest way to resolve their problems is to “change the law” and “legalize MERS” as the official national registry of the trading of mortgages between banks.  As a quasi-governmental agency with federal approval, MERS would become largely immune to the current attacks on its practices.  

For banks and other large corporations, “changing the law” has become a rather simple endeavor since the Roberts Supreme Court ruled that corporations may contribute as much as they desire to any candidate’s political campaign.  In the past two weeks the major banks have sent droves of lobbyists and bank executives, armed with hundreds of millions of dollars in potential campaign contributions and other rewards, to meet with legislators and their staff members. 

The meetings have two main purposes.   First, the lobbyists and bank executives are briefing legislators with strategies to rationalize supporting the extremely unpopular MERS system without committing political suicide.   Second and more importantly, the major banks are reminding legislators that banks have unlimited spending power to have them thrown out of office by donating as much as necessary to the campaigns of their opponents.   On the other hand, if the legislators cooperate with the banks, the money will be spent to keep the compliant legislators in office until the banks need them to cover up their next massive fraud.

Presented with an offer they can’t refuse, legislators will vote for the interests of the banks.  Once the issue of the legality of MERS is behind them, banks will be free to resume foreclosures based upon fraudulent MERS records without reprisal.  The foreclosure fraud crisis might be mostly over for the banks, but foreclosure fraud would continue to have the same disastrous effects on owners of homes in foreclosure and buyers of foreclosed properties.   

The new legislation would violate longstanding principals of property law governing the physical assignment, transfer and recording of mortgages and other property interests.  Additionally, the new law would create numerous conflicts with the property laws of all 50 states that would take years, hundreds of lawsuits, and heaps of blackmail and bribery to resolve.

One thing is certain:  Without lively public discussion of what banks are doing, they will succeed effortlessly in robbing the public once again, and the politicians they control will suffer minimal repercussions from voters.  

Please write or email your Senator and Representative, as well as President Obama, and tell them that if they vote to “legalize” MERS, you will vote for their opponents in the next election.   Anyone with other ideas of how to stop the impending legislative whitewash of the MERS conspiracy is encouraged to leave a comment.

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The Nation’s Most Notorious Robo-Signers: Brooklyn Supreme Court Justice Arthur Schack kicks out foreclosure cases and names names.

What do you get when you cross a Mafia don with a bond salesman? A dealer in collateralized debt obligations (C.D.O.’s) — someone who makes you an offer you don’t understand.

-Paul Krugman, Just Say “AAA”, New York Times

Read the article in STOPForeclosureFraud.com.   We have nothing to do with this site but liked the article.

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New York Debt Collection Defense and Counterclaims

In New York, a debt collection action is neither simple nor cut-and-dried.  If the collection action is properly contested, it is frequently possible to win the case and owe no money.  It is sometimes possible to force the collector to pay money to you.

To illustrate how difficult it can be for an debt collector or alleged creditor to collect a debt in New York, we will describe our overall approach to defending clients against debt collections.  Our strategy for defeating debt collection actions, part of our overall legal strategy of Debt Inversion, involves a combination of:  (1) forcing the debt collector or alleged creditor to prove its entire claim against our client, (2) using specific defenses against debt collection lawsuits, and (3) bringing counterclaims (lawsuits) against the debt collector or creditor, and third-party claims (lawsuits) against companies that were not originally involved in the debt collection lawsuit. 

The following information is for illustrative purposes only and not intended to substitute for the advice of a licensed attorney. To have any chance at successfully defending against a debt collection, you generally must hire a licensed attorney.    

Forcing the debt collector or alleged creditor to prove its entire claim and defeat all defenses: 

In any debt collection action, we force the debt collector or alleged creditor to prove its entire claim against our client and defeat any defense we assert (see below).  If the debt collector or alleged creditor fails to prove its entire claim, it cannot legally obtain a monetary judgment against our client.  This means we win the case and you owe nothing.

For more information on how we force debt collectors and creditors to prove their claims against our clients, please see the Debt Inversion section of our website. 

Defenses against debt collection lawsuits: 

In this section we list some defenses that we use to defend our clients against debt collectors.  We have not attempted to translate the legal terminology into plain English or to explain the legal concepts behind each defense, because it would double or triple the length of this section.  The point we wish to make is that many excellent defenses are available, but they are complicated and should only be used by a licensed New York State attorney who understands them completely. 

  • The Court lacks personal jurisdiction over the homeowner due to improper service of the summons and complaint.  
  • The plaintiff lacks legal standing to bring the action.
  • The plaintiff does not own the alleged debt.
  • The plaintiff did not pay fair and adequate consideration for the alleged debt and plaintiff would be unjustly enriched if plaintiff were to receive the relief requested.
  • The amount plaintiff claims to be due on the alleged debt is incorrect.
  • The complaint fails to state a claim upon which relief can be granted.
  • Plaintiff’s claims are barred, in whole or in part, by the applicable statutes of limitations.
  • Plaintiff’s claims are barred, in whole or in part, by the applicable principles of waiver, ratification, latches and/or estoppel.
  • Plaintiff’s claims are barred, in whole or in part, by the doctrine of unclean hands.
  • Plaintiff lacks standing because it has no business relationship with the alleged debtor.
  • The alleged debtor’s defense is based upon documentary evidence.
  • Plaintiff is not the real party in interest. 
  • The plaintiff is not legally authorized to bring the action. 
  • The plaintiff does not own the alleged debt.
  • The alleged debt was not duly assigned, transferred or sold to plaintiff.
  • Plaintiff lacks standing to commence the action because the alleged credit agreement was not with the same entity that commenced the lawsuit.
  • Plaintiff and/or its predecessor(s) in interest failed to respond to the defendant’s request for validation of the alleged debt. 
  • Defendant never borrowed any money from plaintiff and does not owe any money to plaintiff.  
  • Defendant never entered into any contract or agreement with plaintiff to borrow or repay money. 
  • Defendant never agreed to pay attorneys’ fees to plaintiff under any circumstances, and therefore plaintiff is not entitled to attorneys’ fees in this action.  

Counterclaims (lawsuits) against the debt collector or creditor suing you, and claims against people and companies not yet involved in the lawsuit such as process servers (third-party claims): 

There are numerous counterclaims and third-party claims available to a defendant in a debt collection action.  Rather then repeat all of them here, we ask that you refer to the following sections of the Debt Inversion website for ideas on lawsuits that your attorney might bring against the party suing you (counterclaims) or another party not yet involved in the case such as a process server (third-party claims).

Lawsuits for illegal debt collection
Lawsuits for debt collection crimes 
Lawsuits for illegal credit reporting
Debt Inversion

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Counterclaims against a Foreclosing Bank in New York

Since the mortgage foreclosure crisis has captured national headlines, it has become increasingly possible to win a foreclosure case and keep your home.  New York courts are now being forced to look carefully for fraudulent documents submitted by foreclosure attorneys.  A court’s determination that foreclosure attorneys have submitted fraudulent documents will help prove  the counterclaims that the foreclosure defense attorney asserts.

The end result may be that you keep your house and the bank ends up owing you money for your counterclaims. Eliminating debts and keeping your property while recovering damages from banks and debt collectors is the goal of our strategy of Debt Inversion.

In our opinion no one should attempt to fight a foreclosure action without an attorney experienced in defending against mortgage foreclosures.  A foreclosure defense attorney can make the difference between losing your home, and keeping your home and recovering monetary damages from the foreclosing bank.

Here are a few of the counterclaims that the LeNoir Law Firm uses against banks in foreclosure actions. Keep in mind that all cases are different and the counterclaims below may not apply to your situation.  Additional counterclaims may apply to your case that are not listed below.  Nothing below is intended as legal advice.

FIRST COUNTERCLAIM FOR FRAUD AND MISREPRESENTATION

1. That plaintiff brought this action without legal authority or standing for the purpose of inducing defendant to pay money she does not owe to plaintiff and/or the alleged trust.
2. That as a result of the foregoing, defendant has been damaged in the amount of One Hundred Thousand Dollars ($100,000.00) together with punitive damages, attorneys’ fees and costs.

SECOND COUNTERCLAIM FOR FRAUD AND MISREPRESENTATION

1. That plaintiff brought this action without legal authority or standing for the purpose of inducing defendant to assign, convey and/or transfer title to her home to plaintiff and/or the alleged trust.
2. That as a result of the foregoing, defendant has been damaged in the amount of One Hundred Thousand Dollars ($100,000.00) together with punitive damages, attorneys’ fees and costs.

THIRD COUNTERCLAIM FOR FRAUD AND MISREPRESENTATION

1. That plaintiff intended to induce defendant to respond to this improperly commenced action based upon defendant’s misrepresentations in the affidavit of service it filed as set forth above.
2. That as a result of the foregoing, defendant has been damaged in the amount of One Hundred Thousand Dollars ($100,000.00) together with punitive damages, attorneys’ fees and costs.

FOURTH COUNTERCLAIM FOR FRAUD AND MISREPRESENTATION

1. That plaintiff intended to induce defendant to respond to this improperly commenced action based upon defendant’s misrepresentations in the summons that defendant was required to respond, when in fact defendant had no duty to respond because plaintiff had failed to take the necessary actions for the court to acquire jurisdiction over defendant.
2. Defendant has been forced to answer the purported complaint to prevent entry of a default judgment and does not submit to the jurisdiction of this Court, and defendant has suffered noneconomic damages including but not limited to severe emotional distress and large economic damages including attorney’s fees and costs.
3. That as a result of the foregoing, defendant has been damaged in the amount of One Hundred Thousand Dollars ($100,000.00) together with punitive damages, attorneys’ fees and costs.

FIFTH COUNTERCLAIM FOR FRAUD AND MISREPRESENTATION

1. That plaintiff, the trust, and/or other parties that were/are under the control of or acting on behalf of the plaintiff and/or the trust fabricated documents and/or made false statements in documents including but not limited to the dates of execution of said documents for purposes of inducing defendant to pay money or surrender her home to plaintiff, the trust, or another party under the control of or acting on behalf of the plaintiff.
2. That as a result of the foregoing, defendant has been damaged in the amount of One Hundred Thousand Dollars ($100,000.00) together with punitive damages, attorneys’ fees and costs.

FIRST COUNTERCLAIM FOR VIOLATIONS OF THE FEDERAL FAIR CREDIT REPORTING ACT

1. That upon information and belief, plaintiff and/or its attorneys, agents, servants and/or employees, and/or plaintiff’s alleged predecessor(s) interest and/or their attorneys, agents, servants and/or employees, repeatedly reported false, negative information on defendant’s credit report in violation of the federal Fair Credit Reporting Act causing defendant to suffer damages.
2. That as a result of the foregoing, defendant respectfully requests that this Court award the greater of one hundred thousand dollars ($100,000.00) or $1,000 for each violation of the Fair Credit Reporting Act, and/or defendant’s actual damages including damages related to emotional distress and monetary losses, together with punitive damages, attorneys’ fees and costs.

SECOND COUNTERCLAIM FOR VIOLATIONS OF THE FEDERAL FAIR DEBT COLLECTION PRACTICES ACT

1. That as previously set forth defendant has committed numerous frauds in the course of attempting to collect this alleged debt, some or all of which constitute crimes under federal, state or local law. Crimes committed in the course of attempting to collect a debt are violations of the Federal Fair Debt Collection Practices Act.
2. That as a result of the foregoing, defendant seeks damages in the amount of One Hundred Thousand Dollars ($100,000.00) and/or statutory and other damages as are provided for in the Federal Fair Debt Collection Practices Act, including but not limited to attorneys’ fees and costs.

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: 212-531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com
Blog: www.DebtInversion.com/blog

Important information: This document contains no legal advice and makes no representation as to the outcome of any legal matter. The information in this legal advertisement may not apply to your individual situation and should not be relied upon for any purpose.

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Under a New Court Rule, Foreclosure Attorneys Can Be Disbarred and Prosecuted for Filing False Documents

The Chief Judge of New York’s courts has implemented a new Rule that requires every attorney representing a bank in a foreclosure action to file a signed affirmation (click here for a sample affirmation) swearing that he or she took “reasonable” steps to verify the accuracy of the documents filed in the case.

In a statement, New York Chief Judge Jonathan Lippman said he was convinced the courts were seeing “systemic structural failings” in the foreclosure process, and he said judges and lawyers have a responsibility not to close their eyes to paperwork errors — even if they seem minor.

In the newly required affirmation, foreclosure attorneys must now swear under the penalties of perjury that they have communicated with a representative of the foreclosing bank and that they have personally reviewed all documents and records related to the case and made “other diligent inquiry” as necessary to confirm the accuracy of the documents.  The attorney must swear that “to the best of my knowledge, information and belief, the Summons and Complaint and all other documents filed in support of this action for foreclosure are complete and accurate in all relevant respects.”

The new rule is effective immediately and applies to both new cases and foreclosure actions currently pending in New York courts.  It is the first rule of its kind in the nation.

“You are talking about tremendous consequences. You are talking about taking people’s homes,” Judge Lippman said. “Those papers have to be accurate. They have to be credible.”

“This new filing requirement will play a vital role in ensuring that the documents judges rely on will be thoroughly examined, accurate, and error-free before any judge is asked to take the drastic step of foreclosure. We want to make sure that everyone is focusing like a laser on these particular types of proceedings,” he said. “It puts them on notice. That’s what this is all about. We all have to make doubly sure that we are doing what we should be doing in the first place.”

If the affirmation submitted by a foreclosure attorney is discovered to be false, the attorney may be referred to the Attorney Disciplinary Committee, and depending on the severity of the offense and the attorney’s prior history of disciplinary violations, may result in the attorney being disbarred

Disbarment, however, may be the least of the dishonest attorney’s problems.  By signing a false affirmation, the attorney has committed the felony of perjury.  If the attorney is guilty of perjury in a foreclosure case, he or she is also guilty of the felony of fraud (lying for the purpose of monetary gain) and the felony of attempted grand larceny for trying to take someone’s home under false pretenses without the legal right to do so.  If the foreclosure is completed and the bank seizes the home, the felony of attempted grand larceny would give way to the more serious felony of grand larceny because the home was actually stolen.  And let us not forget the constant companion of grand larceny, felony possession of stolen property

Moreover, if anyone else is involved in the falsification of the attorney’s affirmation – such as the bank’s representative that supplies information to the attorney — the attorney, bank representative and other persons can be charged with the felony of conspiracy.  

Proving that other persons were involved in the falsification of the attorney’s affirmation is not as difficult as it may seem.  Once the dishonest attorney has been arrested and charged with three or four felonies (perjury, fraud, and either grand larceny or attempted grand larceny and possession of stolen property) and is facing a long prison sentence, the attorney will probably do absolutely anything to save his or her own hide.  In exchange for immunity from prosecution for conspiracy and/or a reduced sentence for the other three or four felonies, the crooked attorney will jump at the chance testify against anybody that was even remotely involved, or appeared to be involved, in the crimes. 

All of the above crimes committed when a foreclosure attorney signs a false affirmation are violations of both New York State and Federal criminal laws.  Serious and repeated violations should be prosecuted in Federal Court where longer prison sentences are available. 

It remains to be seen whether judges, attorney disciplinary committees, district attorneys and U.S. Attorneys will take advantage of Judge Lippman’s tough new rule, to rid the system of criminal foreclosure attorneys and their accomplices.  The major banks have legions of attorneys and lobbyists using their power and influence to stop enforcement of laws against corrupt foreclosure attorneys.  If they are successful it will be up to the public to force officials to enforce the laws through organized political action.  We hope that will not be necessary. 

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: (212) 531-0284
Email: info@DebtInversion.com
Web:
www.DebtInversion.com

IMPORTANT INFORMATION:   This blog post and any attachments are legal advertising. They contain no legal advice and make no representation as to the outcome of any legal matter. The information, documents, links and other materials on this blog and website may be inaccurate or not apply to your individual situation and should not be relied upon for any purpose.

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Defending Foreclosure Defense: You Know You’re Fighting Evil When The Wall Street Journal Demonizes You

Paperwork Trail:  The Lawyers Who Fight Foreclosures – WSJ.com – “Niche Lawyers Spawned Housing Fracas”

The Wall Street Journal article blames the foreclosure fraud crisis on “the growth of a legal sub-specialty called foreclosure defense that has sown confusion and turmoil in the housing market.” 

Sorry, our bad.  Sincere apologies to the robo-signers, mortgage bundlers, MERS records bunglers, foreclosure mills, crooked foreclosure attorneys, politicians, investment bankers and mortgage bankers, thieves, liars, fraudsters and corrupt judges who had nothing to do with the foreclosure fraud crisis (and didn’t see a thing).

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: (212) 531-0284
Email: info@DebtInversion.com
Web:
www.DebtInversion.com

IMPORTANT INFORMATION:   This blog post and any attachments are legal advertising. They contain no legal advice and make no representation as to the outcome of any legal matter. The information, documents, links and other materials on this blog and website may be inaccurate or not apply to your individual situation and should not be relied upon for any purpose.

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Criminal Charges Should be Filed over Foreclosure-Gate

To find out why, how, and against whom criminal charges should be filed, read the excellent blog entry by Barry Ritholtz in his blog The Big Picture.

Sincerely,

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: (212) 531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com

IMPORTANT INFORMATION:   This blog post and any attachments are legal advertising. They contain no legal advice and make no representation as to the outcome of any legal matter. The information, documents, links and other materials on this blog and website may not be accurate or apply to your individual situation and should not be relied upon for any purpose.

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Why MERS Matters to Home Owners and Buyers

Mortgage Electronic Registration Systems (MERS) has emerged as the epicenter of the current mortgage foreclosure crisis, despite the financial and real estate industries’ clamor to keep it out of the conversation. MERS maintains the only records in existence of most sales of mortgages from one bank to another. All MERS records are stored electronically and no paper records are kept.

Nearly all major mortgage banks are “members” of MERS, either directly or through subsidiaries. THE PUBLIC IS NOT PERMITTED ACCESS TO MERS RECORDS. Without access to MERS records, it is impossible for home owners (or prospective home buyers) to review the electronic transactions and determine which bank currently owns the mortgage on the home.

The mainstream media recently reported that MERS records and documents are fraught with errors. Incorrect MERS records can cause at least three terrible things to happen: (1) a home owner may be foreclosed upon by a bank that doesn’t own the mortgage and promissory note; not only is the person’s home stolen by a bank that had no right to foreclose, but the real owner of the promissory note can sue the former home owner later for the full amount owed on the loan; (2) home owners who sell their homes voluntarily may pay off their mortgage to a bank that doesn’t own the loan; again the real owner of the mortgage loan can sue the seller later; and (3) banks selling foreclosed homes may not actually own them because the foreclosure was illegal; this means that 20 years down the road when the foreclosure sale buyer wants to sell the home, they may find out that they never owned it, or worse yet, the real owner could show up after the sale and sue to get the property back.

For information on how the LeNoir Law Firm can protect you against catastrophic real estate transactions caused by incorrect MERS mortgage transfer records, please contact our office.

Sincerely,

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: (212) 531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com

Important information: This is an advertisement for legal services. It contains no legal advice and makes no representation as to the outcome of any legal matter. The information in this advertisement may not apply to your individual situation and should not be relied upon for any purpose.

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JPMorgan Chase & Company abandons the fraudulent Mortgage Electronic Registration Systems (MERS)

According to an article in today’s (10/14/10) New York Times:  “On the same day that all 50 state attorneys general announced that they would investigate foreclosure practices, JPMorgan Chase & Company became the first big lender to acknowledge that it had stopped using Mortgage Electronic Registration Systems, or MERS, for foreclosures.” 

MERS has emerged as the epicenter of the forclosure fraud crisis, despite the financial and real estate industries’ clamor to keep it out of the conversation.   Most major mortgage banks and real estate interests are owners and members of MERS, either directly or through subsidiaries.  The public is not permitted access to MERS records, despite the fact that MERS has the only records in existence of most transfers of ownership of mortgages and promissory notes from one investor to another. 

Without access to MERS records, it is impossible for home owners to verify which bank owns their mortgage and promissory note.   This can lead to disastrous results when a bank that does not own the mortgage and note fraudulently forecloses on a home, and later the real owner of the mortgage and note shows up and tries to foreclose on the same home.

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: (212) 531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com

*IMPORTANT INFORMATION:   This blog post and any attachments are legal advertising. They contain no legal advice and make no representation as to the outcome of any legal matter. The information, documents, links and other materials on this blog and website may not be accurate or apply to your individual situation and should not be relied upon for any purpose.

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Free Document* – Answer with Counterclaims in a Credit Card Collection Case

The attached PDF is a copy of an Answer with counterclaims* that we served today in response to a credit card collection lawsuit against our client by the law firm Mel S. Harris and Associates, LLC.  Click here to view and download the PDF file. 

Mel S. Harris and Associates, LLC. is a national debt collection law firm whose name is synonymous with “SEWER SERVICE”.  Sewer service means the defendant is never actually served with the Summons and Complaint and a false Affidavit of Service is filed in court to obtain a default judgment against the defendant.  Victims of sewer service usually don’t find out about the lawsuit against them until their bank accounts are frozen or their employers inform them that their wages are being garnished. 

*IMPORTANT INFORMATION:   This document and attachment are legal advertising. They contain no legal advice and make no representation as to the outcome of any legal matter. The information, documents, links and other materials on this blog and website may not apply to your individual situation and should not be relied upon for any purpose.

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: (212) 531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com

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Sad but Funny: Jon Stewart Rants on National Foreclosure Fraud Crisis

“Even if the foreclosure was legit, you do know you can’t lock someone out of their house while they’re in it.”

The Daily Show With Jon Stewart Mon – Thurs 11p / 10c
Foreclosure Crisis
www.thedailyshow.com
Daily Show Full Episodes Political Humor Rally to Restore Sanity

 

*IMPORTANT INFORMATION:   This blog post and any attachments are legal advertising. They contain no legal advice and make no representation as to the outcome of any legal matter. The information, documents, links and other materials on this blog and website may not apply to your individual situation and should not be relied upon for any purpose.

LENOIR LAW FIRM
461 Central Park West
New York, New York 10025
Office: (212) 531-0284
Email: info@DebtInversion.com
Web: www.DebtInversion.com

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Fraud Factories: U.S. Rep. Alan Grayson of Florida – the nation’s foreclosure fraud capital – exposes and explains foreclosure fraud nationwide.

“The average foreclosure hearing in a Florida court is only 90 seconds.”

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Legislation to help banks steal homes killed over foreclosure fraud fury.

Obama Kills Foreclosure Bill As Fury Mounts – Reuters 10/7/10

If the corporations running the federal government have their way, equivalent legislation will pass after public attention is diverted to the next corporate/government-induced crisis.  “The cost of democracy is eternal vigilance.” -  Thomas Jefferson

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How foreclosure fraud affects home owners and buyers

Mortgage foreclosure fraud causes two terrible things to happen: (1) a home owner may be foreclosed upon by a bank that doesn’t own the mortgage and promissory note; not only is the person’s home stolen, but the real owner of the promissory note can sue the former home owner later for the full amount owed on the mortgage; (2) banks selling foreclosed homes may not actually own them because the foreclosure was fraudulent; this means that 20 years down the road when the person wants to sell the home, they may find out that they never owned it, or worse yet, the real owner could show up after the sale and sue to get their property back.

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The nation’s largest banks admit submitting “faulty” documentation in foreclosure cases. Home owners behind on mortgage payments get a reprieve. Buyers of foreclosed homes get defrauded.

Company Stops Insuring Titles in Chase Foreclosures – New York Times, 10/2/10

Excerpt:  When foreclosures are done with faulty documentation, that could leave the new owners of the house vulnerable to claims [that someone else actually owns the property they think they’re buying].  Title insurance protects the buyer against defects, errors and omissions in the chain of title . . . . lenders will not issue a new mortgage without title insurance.

On the Foreclosure Front – New York Times, 10/2/10

Excerpt:  The improprieties raise the prospect that some families may have lost their homes in a less-than-legal process, and that some buyers of foreclosed homes may not have clear title to their properties. . . . The robo-signing scandal is yet another reminder that it is folly to rely on banks that got us into this mess to get us out.

Bank of America to Freeze Foreclosure Cases – New York Times, 10/1/10

Excerpt:  Bank of America, in an emailed statement, said it would “amend all affidavits in foreclosure cases that have not yet gone to judgment.”   That could mean tens of thousands of foreclosure cases would be in limbo for months or, if the consumers in default hire lawyers, years. 

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The Rise and Fall of the ROBO-SIGNER in Mortgage Foreclosure Fraud

It’s a great time to be behind on your mortgage payments.  Consult with an attorney early, before the foreclosure process begins.

Foreclosures Slow as Document Flaws Emerge – New York Times, 9/30/10
Excerpt:  In depositions taken by lawyers for homeowners, executives at GMAC and Chase said they or their teams signed 10,000 or more affidavits and related documents a month. That did not give them time to review the cases.

JPMorgan Suspending Foreclosures – New York Times, 9/29/10
Excerpt:  Chase and GMAC, in their zeal to process hundreds of thousands of foreclosures as quickly as possible and get those properties on the market, employed people who could sign documents so quickly they popularized a new term for them: “robo-signer.”

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Recover monetary damages from debt collectors and debt collection attorneys who commit crimes while attempting to collect a debt in New York State.

Violation of any federal, New York State or local criminal law while attempting to collect a debt is also a violation of the federal Fair Debt Collection Practices Act, for which you may recover up to $1,000 or your actual damages, plus your attorney’s fees and court costs.

FEDERAL CRIMINAL OFFENSES 

Fraud:
The federal mail fraud statute prohibits deceitful statements, half-truths, and concealment of material facts. It could apply to a debt collector who uses the mails to fraudulently collect a debt.

The federal laws against wire fraud and internet fraud are similar to the law against mail fraud except that the offenses are committed by telephone or internet.

Harassing Telephone Calls:
Under the Federal Communications Act of 1934, a person may be fined up to $50,000 or imprisoned for up to six months, or both, if he or she calls another and:

• Causes a telephone to ring repeatedly, with the intent to harass;

• Makes repeated phone calls solely to harass;

• Permits a telephone under his or her control to be used for any of the above purposes.

NEW YORK STATE CRIMINAL OFFENSES

It is a violation of New York State Criminal Law to:

• Commit fraud for the purpose of collecting a debt or foreclosing on a mortgage;

• Commit larceny (theft) by garnishing money or seizing assets to which the debt collector or collection attorney has no right to take;

• Attempt to seize assets to which the collector or attorney has no rights (attempted larceny);

• Practice law in New York without a license.  Out-of-state debt collection attorneys who garnish the wages of New Yorkers commit the following crimes:  (1) unauthorized practice of    law; (2) larceny of attempted larceny; and (3) if the larceny is completed (the money or assets stolen), possession of stolen property.  Such out-of-state attorneys face prosecution in New York State and loss of their law licenses in their home state.  They are usually extremely eager to settle the lawsuit.

• Possess stolen property.  Every successful larceny (not attempted larceny) results in possession of stolen property once the property is stolen.

• Engage in extortion or coercion (also known as “black-mail”), which means wrongfully using fear to obtain your consent to take your property.  Attempting to induce fear by making any of the following threats is a criminal offense:

  • to commit unlawful injury to you or another person;
  • to have another person injure you or another person;
  • to make a criminal accusation against you, even if it is true;
  • to expose or impute to you, or any of your relatives, a deformity, disgrace or crime;
  • to expose a person’s criminal record;
  • to expose a secret affecting you or any of your relatives;

• Make telephone calls with intent to annoy or harass a person;

• Use obscene language while attempting to collect a debt;

• Present as authentic a document, such as a letter, which appears to be an official government document but is not;

• Listen to or record telephone conversations without proper authorization;

A debt collector or collection attorney who violates any of the above criminal laws can be sued for monetary damages in addition to being forced to pay your attorney’s fees and court costs.  In cases of serious misconduct, our clients may decide to refer the debt collector or collection attorney to federal or state authorities for criminal prosecution, in addition to suing them. 

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Mortgage Foreclosure Defense in New York State

Of the millions of people in the United States facing foreclosure of their homes each year, few hire an attorney to defend them, assuming that there is nothing an attorney can do to stop a foreclosure.  This is often a huge mistake.  In New York, a mortgage foreclosure is neither simple nor cut-and-dry.  If the foreclosure is properly contested, it is possible to delay or defeat the foreclosure completely or obtain a very advantageous settlement.

To illustrate how difficult it can be for an alleged mortgage holder to foreclose on a home in New York, we will describe our overall approach to defending clients against mortgage foreclosures.  Our strategy for defeating foreclosure actions, part of our overall approach to Debt Inversion, involves a combination of:  (1) forcing the mortgage holder to prove its entire claim against the homeowner, (2) asserting specific defenses to mortgage foreclosure lawsuits, and (3) bringing counterclaims (lawsuits) against the alleged mortgage holder, and third-party claims (lawsuits) against companies that were not originally involved in the mortgage foreclosure lawsuit.

The following information is for illustrative purposes only and not intended to substitute for the advice of a licensed attorney. To have any chance at successfully defending against a mortgage foreclosure, you generally must hire a licensed attorney. 

Forcing the Mortgage Holder to Prove Its Claim

In a mortgage foreclosure action, we force the party claiming to own the mortgage to prove its entire claim against our client and defeat any defense we raise (see below).  If the alleged mortgage holder fails to prove its entire claim, it cannot legally obtain a judgment of foreclosure or a monetary judgment against the homeowner.  This means we win the lawsuit.

For more information on how we force debt collectors and creditors to prove their claims against our clients, please see the Debt Inversion section of our website. 

Defenses Against Mortgage Foreclosure Lawsuits

In this section we list some defenses that we use to defend our clients in mortgage foreclosure lawsuits.  We have not attempted to translate the legal terminology into plain English or to explain the legal concepts behind each defense, because it would double or triple the length of this section.  The point we wish to make is that many excellent defenses are available, but they are complicated and should only be used by a licensed New York State attorney who understands them completely. 

General defenses that may apply to any debt collection lawsuit including a mortgage foreclosure: 

  • The Court lacks personal jurisdiction over the homeowner due to improper service of the summons and complaint.   Proper application of this defense in a mortgage foreclosure case can delay the foreclosure for up to six months, giving the homeowner a much longer time to improve her financial circumstances enough to negotiate a good settlement of the foreclosure lawsuit or to find other housing.
  • The plaintiff lacks legal standing to bring the action.
  • The plaintiff does not own the alleged promissory note.
  • The plaintiff did not pay fair and adequate consideration for the alleged mortgage and note and plaintiff would be unjustly enriched if plaintiff were to receive the relief requested.
  • The amount plaintiff claims to be due on the alleged mortgage and note is incorrect.
  • Documents and/or witnesses necessary to prove plaintiff’s claim are unavailable or nonexistent.
  • The complaint fails to state a claim upon which relief can be granted.
  • Plaintiff’s claims are barred, in whole or in part, by the applicable statutes of limitations.
  • Plaintiff’s claims are barred, in whole or in part, by the applicable principles of waiver, ratification, latches and/or estoppel.
  • Plaintiff’s claims are barred, in whole or in part, by the doctrine of unclean hands.
  • Plaintiff lacks standing because it has no business relationship with the homeowner.
  • The alleged lender(s) and mortgage holder(s) violated the Federal Truth In Lending Act.
  • The homeowner’s defense is based upon documentary evidence.
  • Plaintiff is not the real party in interest.
  • The plaintiff is not legally authorized to bring the action.
  • Defendant never borrowed any money from plaintiff and does not owe any money to plaintiff.
  • Defendant never entered into any contract or agreement with plaintiff to borrow or repay money.
  • Defendant never agreed to pay attorneys’ fees to plaintiff under any circumstances, and therefore plaintiff is not entitled to attorneys’ fees in this action. 

Specific defenses to mortgage foreclosure lawsuits: 

  • The homeowner was not duly notified of the alleged default as required under the alleged note and/or alleged mortgage.
  • The plaintiff has not fully complied with all of its duties and obligations under the alleged note and/or alleged mortgage.
  • The plaintiff has not fully complied with all preconditions to bringing the instant action.
  • The plaintiff does not own the alleged mortgage.
  • The alleged mortgage was not duly assigned, transferred or sold to plaintiff.
  • The note was not duly assigned, sold or transferred each and every time the mortgage was assigned, sold or conveyed.
  • Plaintiff has no recourse to collect any amounts from the homeowner not realized from any future foreclosure sale.
  • Plaintiff and/or its predecessors in interest of the alleged mortgage and note failed to respond to the homeowner’s request for validation of the alleged debt despite repeated requests.
  • The Statute of Frauds applies to invalidate any and all transfers of the mortgage or note that were not memorialized in writing at the times of the transfers.
  • In the event a monetary judgment is entered, the homeowner asserts her right to retain the amount of her homestead exemption as provided by law.
  • The alleged owner of the mortgage and/or note did not exist on the date of its alleged transfer of the mortgage and/or note to the plaintiff.
  • The documents memorializing the transfer or the mortgage and note to plaintiff were not executed until after the date of commencement of the action.  Accordingly, plaintiff lacked standing to bring the action on the date it was commenced.
  • Plaintiff’s claims were extinguished as a result of the bankruptcy of the original lender or a subsequent owner of the mortgage and note.
  • That defendant’s defense is based upon documentary evidence.
  • The Statute of Frauds applies to invalidate any and all transfers of the mortgage and/or note that were not duly memorialized in writing and executed at the time of the transfers.
  • In the event a monetary judgment is entered against the defendant, defendant hereby asserts, claims and reserves her rights to receive and retain her Homestead Exemption as exempt from judgment enforcement.
  • Plaintiff is not the real party in interest.

Defenses to foreclosures of mortgages converted into “mortgage backed securities”:

The defenses listed below may apply in the case of a mortgage for which the stream of mortgage payments have been sliced and diced into “mortgage backed securities” bought by investors.  The mortgage backed securities are held in a legal trust that collects payments from homeowners and distributes the income to investors in the mortgage backed securities. 

At least that’s how it was supposed to work. 

The conversion of ordinary mortgages into mortgage backed securities was the primary cause of the real estate market crash that led to massive bank failures and the current recession.

However, fortunately for homeowners facing foreclosure, the slicing and dicing of ordinary mortgages into mortgage backed securities makes it difficult for any one party to foreclose on the entire mortgage.

The plaintiff in a case involving mortgage backed securities is the trustee for the legal trust that administers the mortgage backed securities created from the original mortgage.

  • The plaintiff lacks authority to bring the action from the trust created to administer and collect and disburse payments on the mortgage backed securities. 
  • The trust is not duly permitted or authorized to own the entire alleged mortgage.
  • The alleged trust has no rights pursuant to the alleged mortgage.
  • The alleged trust has no rights pursuant to the alleged note.
  • The alleged trust is not duly permitted or authorized to receive all payments allegedly due on the alleged note.
  • Pursuant to the terms of its formation and existence, the trust is not permitted to own the entire mortgage and note.
  • The alleged trust does not contain the alleged mortgage allegedly executed by the homeowner.
  • The alleged trust does not own the alleged note.
  • The alleged trust does not own the alleged mortgage.
  • The alleged mortgage was not duly assigned, conveyed or sold to the alleged trust.
  • The alleged trust from which plaintiff allegedly derives its alleged right and/or standing to bring the action does not have or possess the legal right and/or standing to bring the action.
  • Neither plaintiff nor the alleged trust is in possession and/or control of the documents and/or witnesses necessary to prove its alleged claim against the homeowner.
  • Neither plaintiff nor the alleged trust owns the entire alleged mortgage.
  • Neither plaintiff nor the alleged trust owns or possesses the right(s) to receive all payments or amounts allegedly due or owed pursuant the alleged note.
  • Neither plaintiff nor the alleged trust owns or possesses the right(s) to receive any payments or amounts allegedly due or owed pursuant the alleged note.
  • Any alleged rights of plaintiff, the alleged trust, and/or any alleged predecessor(s) in interest with regard to the alleged mortgage were extinguished as a result of the bankruptcy of the original lender or subsequent mortgage holder prior to the time of the alleged conveyance of the mortgage and note to plaintiff and/or the alleged trust.
  • The lender or mortgage holder did not exist on the date of its alleged transfer of the mortgage and note to the trust.
  • The documents produced by plaintiff regarding the alleged transfer of the mortgage and note to the trust were executed after the commencement of the action.

Counterclaims against the mortgage holder, and claims against parties not yet involved in the lawsuit (third-party claims): 

The counterclaims and third-party claims available in a mortgage foreclosure action are generally the same as in other debt collection actions.  Rather then repeat all of them here, we ask that you refer to the following sections of the Debt Inversion website for ideas on lawsuits that your attorney might bring against the alleged mortgage holder (counterclaims) or another party not yet involved in the case such as a process server (third-party claims). 

Lawsuits for illegal debt collection
Lawsuits for debt collection crimes 
Lawsuits for illegal credit reporting
Debt Inversion

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Debt Collection Defense in New York State

In New York, a debt collection action is neither simple nor cut-and-dried.  If the collection action is properly contested, it is frequently possible to win the case and owe no money.  It is sometimes possible to force the collector to pay money to you.

To illustrate how difficult it can be for an debt collector or alleged creditor to collect a debt in New York, we will describe our overall approach to defending clients against debt collections.  Our strategy for defeating debt collection actions, part of our overall concept of Debt Inversion, involves a combination of:  (1) forcing the debt collector or alleged creditor to prove its entire claim against our client, (2) using specific defenses against debt collection lawsuits, and (3) bringing counterclaims (lawsuits) against the debt collector or creditor, and third-party claims (lawsuits) against companies that were not originally involved in the debt collection lawsuit. 

The following information is for illustrative purposes only and not intended to substitute for the advice of a licensed attorney. To have any chance at successfully defending against a debt collection, you generally must hire a licensed attorney.    

Forcing the debt collector or alleged creditor to prove its entire claim and defeat all defenses: 

In any debt collection action, we force the debt collector or alleged creditor to prove its entire claim against our client and defeat any defense we assert (see below).  If the debt collector or alleged creditor fails to prove its entire claim, it cannot legally obtain a monetary judgment against our client.  This means we win the case and you owe nothing.

For more information on how we force debt collectors and creditors to prove their claims against our clients, please see the Debt Inversion section of our website. 

Defenses against debt collection lawsuits: 

In this section we list some defenses that we use to defend our clients against debt collectors.  We have not attempted to translate the legal terminology into plain English or to explain the legal concepts behind each defense, because it would double or triple the length of this section.  The point we wish to make is that many excellent defenses are available, but they are complicated and should only be used by a licensed New York State attorney who understands them completely. 

  • The Court lacks personal jurisdiction over the homeowner due to improper service of the summons and complaint.  
  • The plaintiff lacks legal standing to bring the action.
  • The plaintiff does not own the alleged debt.
  • The plaintiff did not pay fair and adequate consideration for the alleged debt and plaintiff would be unjustly enriched if plaintiff were to receive the relief requested.
  • The amount plaintiff claims to be due on the alleged debt is incorrect.
  • The complaint fails to state a claim upon which relief can be granted.
  • Plaintiff’s claims are barred, in whole or in part, by the applicable statutes of limitations.
  • Plaintiff’s claims are barred, in whole or in part, by the applicable principles of waiver, ratification, latches and/or estoppel.
  • Plaintiff’s claims are barred, in whole or in part, by the doctrine of unclean hands.
  • Plaintiff lacks standing because it has no business relationship with the alleged debtor.
  • The alleged debtor’s defense is based upon documentary evidence.
  • Plaintiff is not the real party in interest. 
  • The plaintiff is not legally authorized to bring the action. 
  • The plaintiff does not own the alleged debt.
  • The alleged debt was not duly assigned, transferred or sold to plaintiff.
  • Plaintiff lacks standing to commence the action because the alleged credit agreement was not with the same entity that commenced the lawsuit.
  • Plaintiff and/or its predecessor(s) in interest failed to respond to the defendant’s request for validation of the alleged debt. 
  • Defendant never borrowed any money from plaintiff and does not owe any money to plaintiff.  
  • Defendant never entered into any contract or agreement with plaintiff to borrow or repay money. 
  • Defendant never agreed to pay attorneys’ fees to plaintiff under any circumstances, and therefore plaintiff is not entitled to attorneys’ fees in this action.  

Counterclaims (lawsuits) against the debt collector or creditor suing you, and claims against people and companies not yet involved in the lawsuit such as process servers (third-party claims): 

There are numerous counterclaims and third-party claims available to a defendant in a debt collection action.  Rather then repeat all of them here, we ask that you refer to the following sections of the Debt Inversion website for ideas on lawsuits that your attorney might bring against the party suing you (counterclaims) or another party not yet involved in the case such as a process server (third-party claims).

Lawsuits for illegal debt collection
Lawsuits for debt collection crimes 
Lawsuits for illegal credit reporting
Debt Inversion

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Client testimonial from Matthew M. (last name withheld to protect client’s privacy)

I ran a small business in New York for 5 years. After 9/11, things started going downhill and pretty soon I found myself making personal loans to my own company that I couldn’t pay off — just to stay afloat. I was too small to succeed, and no government handouts to keep ME going. Eventually, my personal debt became unsustainable and I had to close my business. I had no idea what to do — at that point in my life, I was saddled with an enormous debt that I couldn’t possibly pay off with all my other non-negotiable debt like student loans. But thanks to LeNoir Law Firm, I am happy to report that I’m doing very well after my bankruptcy, 7 years later. I must say – working with John and his team way back in 2003 was the smartest decision I ever made. I’m doing VERY VERY well now. Student loan paid off, house paid off, car paid off. ZERO DEBT. Savings in the bank, retirement funds going. John and his firm provided me with the financial relief I desperately needed to push the reset button on my life and get back on track.

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Client testimonial from John K. (last name withheld to protect client’s privacy)

When I found myself faced with a surprise wage garnishment, I began looking for attorneys. I had many to choose from and began calling around, to attorney after attorney. Their responses all seemed to be lukewarm, my $2000 wage garnishment seemingly couldn’t mean less to them, but right before Thanksgiving and Christmas, it meant a lot to me. How did I get garnished? How was this money already coming out of my check? Where did it come from? How did my employer authorize this? How could they garnish me without papers? How could I get my money back? I began to ask about a dozen questions to several lawyers who advertised “free consultations” and “no fee unless we win” and other ad friendly claims… I called them, and when they found out the amount and what happened, they were no longer interested. Many had high fees up front, with little hope in stopping or recovering anything.

I called John LeNoir, and he was eager to help, understanding, and laid out all of my options on the table. He called me back after researching my case, and told me in detail what to expect. He sent a strongly worded letter to their attorneys, and the judgement was reversed within the month, and the money was refunded from the garnishment soon after. Additionally, he was sensitive to the fact that I had little money due to the garnishment, and split the fee up into payments so it wasn’t due all at once. He was sociable, laid back and easy to deal with, not stiff and unreasonable like the other attorneys I dealt with. He fought for me against a company that tried to take advantage of me, and has succeeded in doing so to others. He understood the impact the collector and their law firm had on me, and pursued them for practicing law in another state with no legal right to. He stood up for a regular working guy, when the rest of the attorneys in my area didn’t do as they advertised. Not only did he defend me from an unjust judgement, he turned it into an inversion. I have recommended him to over a dozen friends and co-workers, and will to anyone I know in any situation. He has helped friends and co workers with all types of legal matters, is very well educated and has credentials beyond many, and I know I can trust that he will go the extra mile with anyone I know that finds themselves in any type of situation.

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The Federal Fair Credit Reporting Act (FCRA) by the LeNoir Law Firm

You can take legal action against the three national credit reporting agencies; creditors, debt collectors and other companies that report incorrect, negative information to credit reporting agencies; and companies that misuse your credit information, for violations of the federal Fair Credit Reporting Act (FCRA).

The FCRA regulates the collection, dissemination, and use of consumer credit information. Whenever a creditor, debt collector or credit bureau violates your rights under the FCRA, you can recover up to $1,000 PER VIOLATION or your Actual Damages (see below), plus PUNITIVE DAMAGES, attorney’s fees and court costs.

LAWSUITS AGAINST CREDIT REPORTING AGENCIES

Under the FCRA you may sue a credit reporting agency for violation of any of the following rules:

• A credit reporting agency must investigate, change or remove any incorrect data from your credit report.

• Credit reporting agencies may not retain negative information for more than seven years from the last payment made. The exceptions to this rule are that bankruptcies may be reported for 10 years after the bankruptcy discharge and tax liens can be reported for seven years from the time they are paid.

• Credit reports can be issued only to those with a legitimate business reason. These include creditors, employers, landlords, insurers and government agencies, or anyone else for whom you request a report.

• You must give your consent for a credit report to be issued to a potential employer or landlord.

• Credit reporting agencies are required to help you understand your credit report.

LAWSUITS AGAINST CREDITORS, DEBT COLLECTORS AND OTHERS WHO REPORT FALSE OR INCOMPLETE CREDIT INFORMATION TO CREDIT REPORTING AGENCIES

A credit information furnisher is a company that provides information to credit reporting agencies. Information furnishers include creditors, debt collectors (collection agencies), credit card companies, auto finance companies, mortgage lenders, state and city courts, and employers. Under the FCRA you may sue a credit information furnisher for violation of any of the following rules:

• An information furnisher must provide complete and accurate information to the credit reporting agencies.

• If you dispute an entry on your credit report, the information furnisher must correct any error, or explain why the credit report is correct within 30 days of receipt of notice of a dispute.

• The information furnisher must correct inaccurate or incomplete information in your report.

• The information furnisher must notify all credit reporting agencies where they sent incorrect information of any error.

• An information furnisher must inform consumers about negative information which has been or is about to be placed on a consumer’s credit report within 30 days.

LAWSUITS AGAINST USERS OF CREDIT INFORMATION OBTAINED FROM CREDIT REPORTING AGENCIES

Under the FCRA you may sue a user of credit information for credit, insurance, or employment purposes (including background checks) for violation of any of the following rules:

• Users of credit information must notify the consumer when an adverse action is taken on the basis of such reports.

• Users of credit information must identify the company that provided the report, so that consumers may verify or dispute the information in the report.

DAMAGES RECOVERABLE UNDER THE FCRA

If someone violates your rights under the Fair Credit Reporting Act, you can recover the following damages:

1. UP TO $1,000 PER VIOLATION or your “ACTUAL DAMAGES” (see below)

2. PUNITIVE DAMAGES

3. Attorneys’ fees.

4. The costs of the lawsuit.

EXAMPLES OF “ACTUAL DAMAGES” RECOVERABLE UNDER THE FCRA

The following is a list of “actual damages” that you may be able to recover when a creditor, debt collector, credit reporting agency, credit information furnisher or credit information user violates your rights under the Fair Credit Reporting Act. This is not a complete list of all possible damages recoverable under the FCRA. You may have suffered different or additional damages that are not on the list.

1. Monetary damages.

Inaccurate negative information on your credit report may cost you money due to loss of employment, loss of credit needed to conduct your business, higher insurance premiums or denial of coverage, fees paid to attorneys, debt settlement companies and others for assistance with credit issues prior to bringing suit, and other costs and expenses of being denied credit and attempting to correct incorrect negative credit information.

2. Damages for emotional distress may include stress-related injuries and conditions such as the following:

Heart attack, angina, chest constrictions; miscarriage; ulcers, diabetic flare-up; shock; loss of appetite; crying; nightmares; insomnia, night sweats; emotional paralysis; inability to think or function at work; headaches; shortness of breath; anxiety, nervousness; fear and worry; hypertension (elevation of blood pressure); stress to children; irritability; hysteria; embarrassment, humiliation; indignation, and pain and suffering.

If you suffer from one or more of the above conditions as a result of a creditor, debt collector, credit bureau, credit information furnisher or credit information user violating your legal rights, you may be entitled to a substantial monetary recovery, equivalent to the amount you could recover in a personal injury case involving similar injuries.

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PITFALLS OF “CREDIT REPAIR” – A consumer alert from the LeNoir Law Firm

Everyday, “credit repair” companies target consumers who have poor credit histories with promises to clean up their credit report so they can get a car loan, a home mortgage, insurance, or even a job once they pay them a fee for the service.

The truth is, these companies can’t deliver an improved credit report for you using the various illegal tactics they promote. 

So after you pay them hundreds or thousands of dollars in fees, you’re left with the same credit report and someone else has your money.

If you follow illegal advice and commit fraud, you may find yourself in legal hot water, too. It’s a federal crime to lie on a loan or credit application, to misrepresent your Social Security number, and to obtain an Employer Identification Number from the Internal Revenue Service under false pretenses.

You can be prosecuted for mail or wire fraud if you use the mail, telephone, or Internet to apply for credit and provide false information.

To learn about how the LeNoir Law Firm uses lawsuits (instead of “credit repair” and other scams that do more harm than good) to resolve credit reporting problems, please visit the following page on our main site:  http://www.debtinversion.com/r/Lawsuits-Illegal-Credit-Reporting.php.

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Client testimonial from Rusty W. (last name withheld to protect client’s privacy)

I first heard of, and became a facebook fan of, the LeNoir Law Firm by my facebook friendship with John LeNoir.

I have thus read all about Debt Inversion and I am convinced that it is a better solution to my credit card debt then bankruptcy.

I am now almost maxed out on 8 credit cards for about $25,500.

I am retired from The NYC Health and Hospitals Corporation and together with my Social Security I have an income of about $26,000. annually. I have a rent controlled apartment which just recently qualified for SCRIE fixing my rent at $668 per month. The only asset I have is a small TDA now valued at $7,000.

I previously went bankrupt in September 2002 on about $50,000 credit card debt exclusively. I was represented by MELS (Municipal Employees Legal Services) of my union DC 37 and it only cost me the filing fees and some legwork; it’s too bad they didn’t do Debt Inversion. It was my first bankruptcy and I was hoping that it would be my only bankruptcy, but then my wife died suddenly from stomach cancer June 21, 2004. I’m afraid that the grief that felt like a knife was stuck in my heart made me go a little crazy and I spent to a point of indebtedness from which I have been unable to recover from financially.

I asked for a consultation with John and he granted it. My first impression upon meeting John was that of a young family man taking his turn at caring for his young son John in his NYC apartment on Central Park West, across from the North Woods which John also knows well from walks and picnics with his son, wife and dog. It was the most unusual first consultation I have ever had but then John is not just another lawyer. He is also a musician and this creative side of him is what also impressed me. Before I met John I was impressed with all the love I picked up on from the pictures of him and his family on his Facebook Wall. In person I could feel the love even from the family dog. His son misbehaved a little and I was also impressed in the loving way he handled it. I am a grandfather with four loving grandchildren and so will John be someday with a fruitful lifetime of accomplishment to look back on.

I was already impressed with John’s intelligence through our Facebook exchanges. He impressed me during our consultation with his legal knowledge and expertise. I must say I feel like he’s some kind of Clarence Darrow. His legal knowledge, his creativity and his love filled family life has given me complete confidence in him. Without reservation I would recommend him to anybody who is over their head in debt. I have followed his advice without question and will continue to do so, fully expecting that he will be representing me legally, down the line, if and when Collection Agencies come into the picture.

As promised the legal consultation was free but meeting this wonderful man, his young son and the dog were priceless.

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Client testimonial from Christopher I. (last name withheld to protect client’s privacy)

John Helped Me Put My Life Back Together . . .

I moved to Atlanta from New York and moved back again a short time later due to a failed relationship. I had spent almost all of my savings moving South to begin with and returned home with almost nothing. I had a difficult time finding a job in my field and ended up living off of my credit cards. The job was decent, but I was barely making ends meet. After I paid rent and credit card bills, there was barely enough money for food and commuting. I missed a few credit card payments and immediately, my interest rates were doubled. Though I tried to work with the credit card companies, they would not budge. At that point there was no way I could pay all of my bills on my salary.

I went to John for help. He talked with me about my situation. He looked at the numbers and showed me that even if I got the highest possible raises, it would take me over 10 years to pay down my debt, all the while living in poverty. He talked to me about all of my options and helped me chose the best one for me – a person who found himself in a bad situation because of things that he had no control over.

Now a happily married father, I am glad that I was able to put my life back on track so that I could move forward.

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