Lenore Albert, a lawyer out of California who has been on top of the MERS fraud for years, sent me an URGENT Email.
She has been working on getting Class Action Suits going against MERS banks.
She started another one against Deutsche Bank. But she needs people that have had the situation listed below.
This is her "Urgent" email to me that I got:
I need to get the word out. We just beat an order to show cause on a complaint and are allowed to file our second amended complaint because it is adequately plead but judge then issued a motion for summary judgment to ensue to see if we have evidence to prove the claims. I need two things:
1. Know if anyone else received a modification from HomEq that was 'faxed' to them and it looked like there was a missing page or a missing term.
2. Who has had their house sold at foreclosure when they were under BK Stay order by the defendants in this case.
3. Any evidence or information appreciated!!! Here is the proposed complaint.
The proposed complaint she sent me is in PDF form. I am not able to put it here. But I am putting some of the first paragraphs.
PLEASE CONTACT LENORE ALBERT and pass this information along to everyone you know that may be similarly situated. She needs people Immediately that have had the situation listed above with HomeEq.
Lenore L. Albert, Esq. SBN 210876
LAW OFFICES OF LENORE ALBERT
7755 Center Avenue, Suite #1100
Huntington Beach, CA 92647
Telephone (714) 372-2264
Facsimile (419) 831-3376
Email: lenorealbert@msn.com
Attorney for Plaintiff, HELEN GALOPE, on behalf of herself and all others similarly situated
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
HELEN GALOPE, an individual, on behalf of herself and all others similarly situated,
Plaintiffs,
vs.
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE UNDER POOLING AND SERVICING AGREEMENT DATED AS OF MAY 1, 2007 SECURITIZED ASSET BACKED RECEIVABLES LLC TRUST 2007-BR4; WESTERN PROGRESSIVE, LLC; and DOES 1 through 10, inclusive,
Defendants.
CASE NO. SACV 12 00323-CJC (RNBx)
Assigned to the Hon: Cormac J. Carney
PROPOSED SECOND AMENDED CLASS ACTION COMPLAINT
PLAINTIFF, HELEN GALOPE, on behalf of herself and those similarly situated bring this national class action against defendants for conducting its business practice in an unlawful, unfair and fraudulent manner as alleged herein.
I. VENUE
PROPOSED SECOND AMENDED CLASS ACTION COMPLAINT
GALOPE v DEUTSCHE BANK NATIONAL TRUST COMPANY, et al CASE NO. SACV 12 00323-CJC (RNBx)
1. The Court has subject matter jurisdiction over this action under 28 USC § 1332 wherein this is a class action over $5,000,000.00 where at least one plaintiff is diverse from one defendant. Alternatively, federal question jurisdiction exists under 28 USC §1331 based on the 11 USC §362 violation.
2. The Court has personal jurisdiction over the defendants in this action by the fact that the Defendants are conducting business in the state of California.
3. Venue is proper in this Court pursuant to 28 USC § 1392 because the action involves real property located in the Central District of California; and pursuant to 28 USC § 1391(b) because a substantial part of the events or omissions on which the claims are based occurred in this District.
II. PARTIES
4. At all times mentioned herein, Plaintiff HELEN GALOPE was the title owner by way of a grant deed to the property duly recorded in the Los Angeles County Recorder’s Office, Book 391, pg 40-42 more commonly known as 19117 DELANO STREET, TARZANA, CALIFORNIA 91335 (hereinafter referred to as “The Premises”) which was her principal residence (APN 2128-022-022).
5. Defendant, DEUTSCHE BANK NATIONAL TRUST COMPANY, as trustee under pooling and servicing agreement dated as of May 1, 2007 securitized asset backed receivables LLC trust 2007-BR4, has its principal place of business in Santa Ana, California and is registered to do business in the State of California and claimed to be the
PROPOSED SECOND AMENDED CLASS ACTION COMPLAINT
GALOPE v DEUTSCHE BANK NATIONAL TRUST COMPANY, et al CASE NO. SACV 12 00323-CJC (RNBx)
title owner of The Premises, by virtue of a trustee’s deed from defendant Western Progressive, LLC at the time this action was originally commenced.
