Lone Star Home Buyers, LLC v. Mortgage Electronic Registration System Inc.
(4:25-cv-00211)
District Court, S.D. Texas
LIT COMMENTARY & UPDATES
Correction (Mar 23, 2025)
Upon revisiting, LIT missed the comma in the business entity registration, LONE STAR HOME BUYERS, LLC which comes back as “active” in Texas. However, the standing argument remains, as the general warranty deed is a fraudulent conveyance, and the deed of trust for the reverse mortgage states that a borrower must reside at the homestead (see #4).
Top of the morn’
Lone Star Home Buyers, LLC v. Mortgage Electronic Registration System Inc. et al
Assigned to: Judge Kenneth M Hoyt
CASE #: 4:25-cv-00211
We’re working on this case as part of our “Foreclosure Scam Squad Series” on LIT.
A simple check of the entity Lone Star Home Buyers LLC show this case mirrors Judge Sim Lake’s:
DHI Holdings L.P. v. Duetsche [sic] Bank National Trust Company (4:24-cv-01270)
MEMORANDUM OPINION AND ORDER – Because Plaintiff has forfeited its right to transact business in Texas, Tex. Bus. Orgs. Code § 153.309(a)(1) bars Plaintiff from bringing this action. (Signed by Judge Sim Lake) (Entered: 07/30/2024).
Despite Lone Star’s (Mathew A. Niemi) representation by Ms. Hagger, opposed by PHH’s counsel at Mackie Wolf, none of these seasoned legal foreclosure and real estate veterans – or the court – have raised this jurisdictional issue.
Rather, it would appear, everyone has blanked the simple online check to confirm the validity of the entity, and allowed this case to proceed to discovery without an initial conference which could have raised this issue.
Please advise if we have missed anything as 84-year-old Ms. Ingrid Forrest remains in an apartment whilst her home of over a decade (at a minimum) is marketed for sale by a forfeited entity, purportedly owned by what we believe is a “ten-dollar deed thief“, and supported by officers of the court for their own financial greed.
Disclaimer: Any and all responses are subject to publishing on LIT.
Y’all have a great day.
Mark Burke
Justice Seeker
Laws In Texas
#restoretx
Meet Marcella A. Hagger (website profile)
Marcella A. Hagger is a proud Houston native, born and raised in the heart of the city. She graduated from the High School for Law Enforcement and Criminal Justice, where her passion for advocacy and public service first took root. She went on to earn her bachelor’s degree in Political Science from the University of Houston, solidifying her foundation in law, government, and policy.
Before attending law school, Marcella worked in the Loss Mitigation Department at Nationstar Mortgage. It was there that she gained firsthand experience with foreclosure prevention and homeowner assistance — knowledge that would later become the cornerstone of her legal career.
Marcella graduated from Thurgood Marshall School of Law in 2017 and passed the Texas Bar that same year. Today, she is the Managing Attorney of Land Labor & Capital PLLC, where she focuses her practice on foreclosure defense and real estate litigation. She is passionate about protecting property rights and guiding clients through complex legal challenges with care and expertise.
Marcella is committed to mentorship and service within the legal community. She has been a Moot Court coach for the past three years, helping law students sharpen their advocacy skills and prepare for careers in litigation. Additionally, she serves as the current Treasurer of the African American Law Section of the Texas State Bar, contributing her leadership to advancing diversity and professional development in the legal field.
At the heart of her practice is a genuine dedication to her clients and community. Marcella’s journey from Houston classrooms to the courtroom is a testament to hard work, resilience, and a lifelong commitment to making a difference.
LIT’s Human Rights War Escalates Under Trump #LITAMO2025 pic.twitter.com/9r3OtVbyvR
— lawsinusa (@lawsinusa) March 11, 2025
Lone Star Home Buyers, LLC v. Mortgage Electronic Registration System Inc.
(4:25-cv-00211)
District Court, S.D. Texas
ORIGINAL ANSWER, COUNTERCLAIM, AND THIRD-PARTY CLAIM OF PHH MORTGAGE CORPORATION
84-year-old Ingrid C Forrest served at apartments by the wolves of foreclosure, who knew exactly where to find her.
III. COUNTERCLAIM AND THIRD-PARTY CLAIM
A. Parties
1. Plaintiff/Counter-Defendant Lone Star Home Buyers, LLC has previously appeared herein through counsel and may be served through counsel of record.
2. Third-Party Defendant Ingrid C. Forrest is an individual who resides in Texas and may be served with process at her residence, 1617 Fountain View Dr. Apt. 87, Houston, Texas 77057. Citation is requested.
3. Defendant/Counter-Plaintiff PHH Mortgage Corporation has previously appeared herein through the undersigned counsel.
B. Property
4. This proceeding concerns the real property and improvements commonly known as 15686 Barkers Landing Road, Houston, Texas 77079, and more particularly described as:
LOT TWENTY-SEVEN (27) IN BARKER COURT, A TOWNHOUSE DEVELOPMENT IN HARRIS COUNTY, TEXAS, ACCORDING TO THE MAP OR PLAT THEREOF RECORDED IN VOLUME 257, PAGE 79 MAP RECORDS, HARRIS COUNTY, TEXAS. (the “Property”).
C. Jurisdiction and Venue
5. This Court has subject matter jurisdiction over this cause because this suit concerns real property located within Harris County, Texas and the amount in controversy exceeds the minimum jurisdiction of this Court.
6. Venue is proper in Harris County, Texas, pursuant to Section 15.011 of the Texas Civil Practice & Remedies Code in that this action involves title to real property located Harris County, Texas.
D. Facts
7. The foregoing paragraphs are incorporated by reference for all purposes.
8. On or about March 22, 2012, Ingrid C. Forrest (“Borrower”) executed an Adjustable-Rate Note Home Equity Conversion1 (“Note”) in the original principal balance of $322,500.00 that was originally payable to One Reverse Mortgage, LLC (“ORM”).
9. The Note was secured with a lien on the Property by an Adjustable Rate Home Equity Conversion Deed of Trus2t (“Security Instrument”, together with the Note, the “Loan”) in favor of OMR, which was recorded on April 12, 2012 in the official public records of Harris County, Texas as Instrument No. 20120157636.
10. MERS as nominee for ORM assigned the Note and Security Instrument to Traditional Mortgage Acceptance Corp. (“TMAC”) as evidenced by the Assignment of Deed of Trust3 recorded on August 8, 2022 in the official records of Harris County, Texas as Instrument No. RP-2022-404650.
11. Subsequently, TMAC assigned the Note and Security Instrument to Onity Loan Acquisition Trust 2024-HB2 (“Onity”) as evidenced by the Assignment of Deed of Trust4 recorded on October 31, 2024, in the official records of Harris County, Texas as Instrument No. RP-2024-404423.
12. PHH is the current servicer on behalf of Onity.
13. On June 1, 2023, Borrower conveyed the Property to Lone Star Home Buyers, LLC via General Warranty Deed5recorded in the official records of Harris County, Texas as Instrument No. RP-2023-201629.
14. The Loan provides that Lender may require immediate payment-in-full of all sums secured by this Security Instrument if all of the Borrower’s title in the Property is sold or
1 Exhibit A – Note
2 Exhibit B – Deed of Trust
3 Exhibit C- First Assignment
4 Exhibit D – Second Assignment
5 Exhibit E – General Warranty Deed
otherwise transferred and no other Borrower retains title to the Property.
See Exhibit B at ¶ 9(a)(ii).
15. Borrower defaulted under the terms of the Loan when she conveyed all of her interest in the Property to Lone Star Home Buyers LLC.
Accordingly, on October 24, 2024, PHH sent a Home Equity Conversion Mortgage Due and Payable Notice6 (“Notice of Default”) to Borrower via certified mail in accordance with the Loan Agreement and the Texas Property Code.
16. The default was not cured, and the maturity of the Note was accelerated.
On November 26, 2024, PHH, through its counsel, sent a Notice of Acceleration of Loan Maturity7 (“Notice of Acceleration”) to Borrower and Lone Star Home Buyers LLC in accordance with the Loan Agreement and the Texas Property Code.
17. On December 5, 2024, Lone Star Home Buyers LLC and Borrower were both provided a Notice of Foreclosure Sale8 for a foreclosure sale to occur on January 7, 2025.
The January 7, 2025 foreclosure sale did not occur because Lone Star Home Buyers LLC obtained a Temporary Restraining Order in the morning of January 7, 2025 from the State Court before the sale occurred.
E. Cause of Action: Suit for Foreclosure
18. The foregoing paragraphs are incorporated by reference for all purposes.
19. PHH asserts a cause of action for foreclosure against Borrower.
The Loan is a contract, and PHH fully performed its obligations under it.
Borrower however, did not comply with the Loan by failing to substantially perform material obligations required under its terms (principally, transferring her entire interest in the Property).
6 Exhibit F – Notice of Default
7 Exhibit G – Notice of Acceleration
8 Exhibit H – Notice of Foreclosure Sale
20. PHH seeks a judgment for judicial foreclosure allowing it to enforce its lien against the Property in accordance with the Security Instrument and Texas Property Code section 51.002.
21. Alternatively, PHH seeks a judgment for foreclosure together with an order of sale issued to the Harris County sheriff or constable, directing the sheriff or constable to seize and sell the Property in satisfaction of the Loan Agreement debt, pursuant to Texas Rule of Civil Procedure 309.
22. PHH has been forced to hire the undersigned attorneys to seek an order allowing foreclosure as a result of Borrower’s failure to comply with the Loan. PHH is therefore entitled to and seeks judgment against Borrower for its reasonable attorney fees in this action, both through trial and in the event of a subsequent appeal, as further obligation on the debt under the Loan only and not as a personal judgment against Plaintiff.
23. All conditions precedent to Defendant’s right to enforce the Loan and to obtain the relief requested herein have been performed or have occurred.
F. Cause of Action – Declaratory Judgment
24. The foregoing paragraphs are incorporated by reference for all purposes.
25. The federal Declaratory Judgment Act states, “[i]n a case of actual controversy within its jurisdiction, . . . any court of the United States, upon the filing of an appropriate pleading, may declare the rights and other legal relations of any interested party seeking such declaration, whether or not further relief is or could be sought.” 28 U.S.C. § 2201.
Federal courts have broad discretion to grant or refuse declaratory judgment.
Torch, Inc. v. LeBlanc, 947 F.2d 193, 194 (5th Cir. 1991).
“Since its inception, the Declaratory Judgment Act has been understood to confer on federal courts unique and substantial discretion in deciding whether to declare the rights of litigants.”
Wilton v. Seven Falls Co., 515 U.S. 277, 286, 115 S. Ct. 2137, 132 L. Ed. 2d 214 (1995).
26. PHH seeks a declaratory judgment that Borrower was provided with all required notices of default, acceleration and foreclosure sale required by law and that PHH have and recover a judgment for it to proceed with a non-judicial foreclosure sale of the Property due to the payment default on the Note.
PHH further seeks a declaration that such foreclosure sale will divest Lone Star Home Buyers LLC of any purported ownership interest it may have in the Property as the General Warranty Deed she allegedly received from Borrower is subject to the lienholder’s Deed of Trust.
WHEREFORE, PREMISES CONSIDERED, PHH prays the Court enter judgment that: Lone Star Home Buyers LLC take nothing on their claims and that PHH have and recover a declaratory judgment that it may proceed with a non-judicial foreclosure sale of the Property and that Lone Star Home Buyer LLC’s interest in the Property is subject to and inferior to PHH’s interest. PHH further requests such other and further relief to which it may be entitled.
By: /s/ Nicholas M. Frame
NICHOLAS M. FRAME
COMES NOW, Defendant/Counter-Plaintiff PHH Mortgage Corporation (“PHH” or “Defendant”), and file this its Original Answer, Counterclaim against Lone Star Home Buyers, LLC, and Third-Party Claim against Ingrid C. Forrest and show as follows:
I. ANSWER
1. Paragraph 1 of the Petition contains a statement regarding a state court discovery control plan, which is not applicable to this action that is now pending in this Court.
2. Defendant admits the statements and allegations in Paragraph 2 of the Petition.
3. Defendant does not have sufficient information to admit or deny the statements in Paragraph 3 of the Petition.
4. Defendant does not have sufficient information to admit or deny the statements in Paragraph 4 of the Petition.
5. Defendant admits the statements and allegations in Paragraph 5 of the Petition.
6. With respect to the statements and allegations in Paragraph 6 of the Petition, Defendant states this Court has subject matter jurisdiction over this action.
7. Paragraph 7 contains a statement of relief to which no response is required. To the extent a response is required, Defendant denies Plaintiff is entitled to the relief requested therein.
8. Paragraph 8 of the Petition contains a citation to statute to which no response is required. To the extent a response is required, Defendant denies the statements and allegations in Paragraph 8 and demands strict proof thereof.
9. Paragraph 9 contains a statement of relief to which no response is required. To the extent a response is required, Defendant denies Plaintiff is entitled to the relief requested therein.
10. Paragraph 10 contains a statement of relief to which no response is required. To the extent a response is required, Defendant denies Plaintiff is entitled to the relief requested therein.
11. With respect to the statements and allegations in Paragraph 11 of the Petition, Defendant states this Court has jurisdiction over the parties.
12. With respect to the statements and allegations in Paragraph 12 of the Petition, Defendant states this Court has jurisdiction over the parties.
13. With respect to the statements and allegations in 13 of the Petition, Defendants states this Court is the proper venue for this action because it concerns real property and improvements located in Harris County, Texas.
14. With respect to the statements and allegations in 14 of the Petition, Defendants states this Court is the proper venue for this action because it concerns real property and improvements located in Harris County, Texas.
15. Defendant denies the statements and allegations in Paragraph 15 and demands strict proof thereof.
16. Defendant admits the statements and allegations in Paragraph 16 of the Petition.
17. Defendant admits the statements and allegations in Paragraph 17 of the Petition.
18. Defendant admits the statements and allegations in Paragraph 18 of the Petition.
19. Defendant does not have sufficient information to admit or deny the statements and allegations in Paragraph 19 of the Petition. To the extent a response is required, Defendant denies the statements in this paragraph and demands strict proof thereof.
20. Defendant denies the statements and allegations in Paragraph 20 and demands strict proof thereof.
21. Defendant does not have sufficient information to admit or deny the statements and allegations in Paragraph 21 of the Petition. To the extent a response is required, Defendant denies the statements in this paragraph and demands strict proof thereof.
22. Defendant does not have sufficient information to admit or deny the statements and allegations in Paragraph 22 of the Petition. To the extent a response is required, Defendant denies the statements in this paragraph and demands strict proof thereof.
23. Defendant admits the Property was previously listed for a scheduled foreclosure sale on January 7, 2025.
24. Defendant does not have sufficient information to admit or deny the statements and allegations in Paragraph 24 of the Petition. To the extent a response is required, Defendant denies the statements in this paragraph and demands strict proof thereof.
25. Defendant incorporates its previous responses above.
26. Paragraph 26 of the Petition contains legal conclusions to which no response is required. To the extent a response is required, Defendant denies the statements and allegations in this paragraph and demands strict proof thereof.
27. Defendant denies the statements and allegations in Paragraph 27 and demands strict proof thereof.
28. Defendant incorporates its previous responses above.
29. Paragraph 29 of the Petition contains legal conclusions to which no response is required. To the extent a response is required, Defendant denies the statements and allegations in this paragraph and demands strict proof thereof.
30. Paragraph 30 of the Petition contains citation to statute and legal conclusions to which no response is required. To the extent a response is required, Defendant denies the statements and allegations in this paragraph and demands strict proof thereof.
31. Paragraph 31 of the Petition contains citation to statute and legal conclusions to which no response is required. To the extent a response is required, Defendant denies the statements and allegations in this paragraph and demands strict proof thereof.
32. Paragraph 32 of the Petition contains citation to statute to which no response is required. To the extent a response is required, Defendant denies the statements and allegations in this paragraph and demands strict proof thereof.
33. Defendant denies the statements and allegations in Paragraph 33 and demands strict proof thereof.
34. Paragraph 34 contains a statement of relief to which no response is required. To the extent a response is required, Defendant denies Plaintiff is entitled to the relief requested therein.
35. Defendant incorporates its previous responses above.
36. Paragraph 36 of the Petition contains citation to statute to which no response is required. To the extent a response is required, Defendant denies the statements and allegations in this paragraph and demands strict proof thereof.
37. Defendant denies the statements and allegations in Paragraph 37 and demands strict proof thereof.
38. Paragraph 38 contains a statement of relief to which no response is required. To the extent a response is required, Defendant denies Plaintiff is entitled to the relief requested therein.
39. Paragraph 39 of the Petition contains legal conclusions to which no response is required. To the extent a response is required, Defendant denies the statements and allegations in this paragraph and demands strict proof thereof.
40. Paragraph 40 contains a statement of relief to which no response is required. To the extent a response is required, Defendant denies Plaintiff is entitled to the relief requested therein.
41. Paragraph 41 contains a statement of relief to which no response is required. To the extent a response is required, Defendant denies Plaintiff is entitled to the relief requested therein.
42. Paragraph 42 contains plaintiff’s jury demand to which no response is required.
43. Paragraph 43 contains a prayer for relief to which no response is required. To the extent a response is required, Defendant denies Plaintiff is entitled to the relief requested therein.
II. AFFIRMATIVE DEFENSES
Defendant raises the following defenses:
1. Some or all of Plaintiff’s claims and causes of action are barred, in whole or in part, because Plaintiff has failed to state a claim upon which relief may be granted.
2. Some or all of Plaintiff’s claims and causes of action are barred, in whole or in part, because one or more of the material obligations of the note and security instrument have not been satisfied.
3. Some or all of Plaintiff’s claims and causes of action are barred, in whole or in part, by the equitable doctrine of waiver.
4. Some or all of Plaintiff’s claims and causes of action are barred, in whole or in part, by the Parol Evidence Rule.
5. Some or all of Plaintiff’s claims and causes of action are barred, in whole or in part, by the applicable statute of limitations.
6. Some or all of Plaintiff’s claims and causes of action are barred, in whole or in part, by the waiver provisions contained in the security instrument at issue in this lawsuit.
7. Some or all of Plaintiff’s claims and causes of action are barred, in whole or in part, by the failure of a condition precedent.
8. Some or all of Plaintiff’s claims and causes of action are barred, in whole or in part, by his prior material breach of the loan agreement.
9. While Defendant denies that Plaintiff suffered any injury, any injury sustained by Plaintiff is the result of the acts or omissions of third parties, over which Defendant exercised no control.
10. While Defendant denies that Plaintiff suffered any damages, Plaintiff’s damages, if any, were proximately caused by the acts, omissions, or breaches of other persons and entities, including Plaintiff, and said acts, omissions, or breaches were intervening and superseding causes of Plaintiff’s damages, if any.
11. Some or all of Plaintiff’s claims and causes of action are barred, in whole or in part, by the “one satisfaction” and “con-tort” doctrines.
12. Some or all of Plaintiff’s claims and causes of action are barred, in whole or in part, by the “economic loss” doctrine.
13. Defendant claims all offsets and credits available to it.
14. Some or all of Plaintiff’s claims and causes of action are barred by the doctrines of judicial estoppel, res judicata, and collateral estoppel.
15. Some or all of Plaintiff’s claims and causes of action are barred by the doctrine of equitable estoppel.
16. Plaintiff’s damages, if any, were proximately caused by the acts, omissions, or breaches of other persons and entities, including Plaintiff, and these acts, omissions, or breaches were intervening and superseding causes of Plaintiff’s damages, if any. Defendant claims the right to a determination of proportionate responsibility as provided in Chapter 33 of the Texas Civil Practice and Remedies Code.
WHY IS THE MILLIONAIRE JUDICIAL PIMP – SANCTIONED LAWYER CLAY VILT – FACING FORECLOSURE WITH PASQUALE?
The largest theft of distressed homes from Texans in modern history, aided by the federal judiciary in Houston providing the stage n’ mock proceedings. https://t.co/h9hxjJXrRq pic.twitter.com/EBMqDMqctW
— lawsinusa (@lawsinusa) March 20, 2025
Lone Star Home Buyers, LLC v. Mortgage Electronic Registration System Inc.
(4:25-cv-00211)
District Court, S.D. Texas
JAN 17, 2025 | REPUBLISHED BY LIT: MAR 22, 2025
MAR 22, 2025
Above is the date LIT Last updated this article.
LIT
There’s no standing for the defunct LLC, and the third party complaint cannot stand as this court lacked jurisdiction to consider the case.
“MEMORANDUM OPINION AND ORDER – Because Plaintiff has forfeited its right to transact business in Texas, Tex. Bus. Orgs. Code § 153.309(a)(1) bars Plaintiff from bringing this action.”
DEFENDANTS’ MOTION TO DISMISS PLAINTIFF’S COMPLAINT WITHOUT PREJUDICE
Pursuant to the Memorandum Opinion and Order entered by this Court on July 30, 2024 (ECF No. 21), and the provisions of Texas Business Organizations Code § 153.309, the Defendants hereby move the Court to dismiss the above-captioned case without prejudice.
On July 30, 2024, this Court entered an order staying the proceedings for 90 days, directing the Plaintiff, DHI Holdings, LP, to cure its defect by reinstating its right to transact business in Texas.
(ECF No. 21)
A true and correct copy of this order is attached hereto as Exhibit A.
The Court explicitly conditioned the continuation of this case on Plaintiff’s compliance with this requirement within the stipulated timeframe of 90 days.
As of the date of this motion, which is beyond 90 days from the entry of the order, Plaintiff has failed to demonstrate that it has cured the defect of capacity to sue, as required by the Court’s order and under Texas Business Organizations Code § 153.309.
A true and correct copy of the Texas Secretary of State entity report is attached hereto as Exhibit B.
Therefore, under the terms of the Court’s order, this action is subject to dismissal. Defendants respectfully request that this Court dismiss the present action without prejudice due to Plaintiff’s failure to cure the defect in capacity as ordered by this Court.
ORDER FOLLOWING TELEPHONE SCHEDULING CONFERENCE held on March 13, 2025 at 8:45 a.m.
Appearances: Waived.
Telephonic appearances are waived unless otherwise notified by the Court.
Initial Disclosures due by 3/25/2025.
Pltf Expert Witness List due by 6/2/2025.
Pltf Expert Report due by 6/2/2025.
Deft Expert Witness List due by 7/1/2025.
Deft Expert Report due by 7/1/2025.
Discovery due by 7/30/2025.
Dispositive Motion Filing due by 10/20/2025.
Docket Call set for 1/5/2026 at 11:30 AM in Courtroom 11A before Judge Kenneth M Hoyt.
Discovery may be extended by agreement of the parties without Court intervention.
The dispositive motion deadline and docket call dates, however, may not be extended without leave of Court.
Attorney’s fee applications are handled on the papers of the parties after notice.
Expedited responses are required on all pretrial motions save dispositive motions.
ETT: TBA. Jury trial.
(Signed by Judge Kenneth M Hoyt)
Parties notified. (cjh4) (Entered: 03/12/2025)
ORDER granting 13 Unopposed MOTION to Dismiss
One Reverse Mortgage, One Reverse Mortgage, LLC terminated.
(Signed by Judge Kenneth M Hoyt) Parties notified. (glc4) (Entered: 03/04/2025)
ORDER denying without prejudice 3 Motion for Temporary Restraining Order.
(Signed by Judge Kenneth M Hoyt) Parties notified. (jm4) (Entered: 02/18/2025)
ANSWER to 1 State Court Petition/Notice of Removal,
THIRD PARTY COMPLAINT against Ingrid C. Forrest,
COUNTERCLAIM against Lone Star Home Buyers, LLC
by PHH Mortgage Corporation, and their successors and assigns, filed.
(Attachments: # 1 Exhibit) (Frame, Nicholas) (Entered: 01/24/2025)
| DHP |
U.S. District Court
SOUTHERN DISTRICT OF TEXAS (Houston)
CIVIL DOCKET FOR CASE #: 4:25-cv-00211
| Lone Star Home Buyers, LLC v. Mortgage Electronic Registration System Inc. et al Assigned to: Judge Kenneth M Hoyt
Cause: 28:1332 Diversity-Breach of Contract |
Date Filed: 01/17/2025 Jury Demand: Plaintiff Nature of Suit: 220 Real Property: Foreclosure Jurisdiction: Diversity |
| Plaintiff | ||
| Lone Star Home Buyers, LLC | represented by | Marcella Arteal Hagger Land, Labor, Capital 5718 Westheimer Road Suite 1000 Houston, TX 77057 281-236-6456 Email: mahagger.legal@gmail.com LEAD ATTORNEY |
| V. | ||
| Defendant | ||
| Mortgage Electronic Registration System Inc. | ||
| Defendant | ||
| One Reverse Mortgage, LLC TERMINATED: 03/04/2025 |
||
| Defendant | ||
| PHH Mortgage Corporation, and their successors and assigns | represented by | Crystal G Gibson Mackie Wolf Zientz & Mann P.C. Litigation 14160 Dallas Parkway Suite 900 Dallas, TX 75254 214-635-2670 Fax: 214-635-2686 Email: cgibson@mwzmlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICEDNicholas Michael Frame Mackie Wolf Zientz Mann, P.C. 5177 Richmond Avenue Suite 1230 Houston, TX 77056 713-730-3219 Email: nframe@mwzmlaw.com ATTORNEY TO BE NOTICED |
| Third Party Defendant | ||
| Ingrid C. Forrest | ||
| Third Party Defendant | ||
| Ingrid C. Forrest | ||
| ThirdParty Plaintiff | ||
| PHH Mortgage Corporation, and their successors and assigns | represented by | Crystal G Gibson (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICEDNicholas Michael Frame (See above for address) ATTORNEY TO BE NOTICED |
| Counter Claimant | ||
| PHH Mortgage Corporation, and their successors and assigns | represented by | Crystal G Gibson (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICEDNicholas Michael Frame (See above for address) ATTORNEY TO BE NOTICED |
| V. | ||
| Counter Defendant | ||
| Lone Star Home Buyers, LLC | represented by | Marcella Arteal Hagger (See above for address) LEAD ATTORNEY |
| Date Filed | # | Docket Text |
|---|---|---|
| 01/17/2025 | 1 | NOTICE OF REMOVAL from 133th Judicial District, Harris County, case number 2025-00937 (Filing fee $ 405 receipt number ATXSDC-32781009) filed by PHH Mortgage Corporation, and their successors and assigns. (Attachments: # 1 Exhibit, # 2 Civil Cover Sheet) (Frame, Nicholas) (Entered: 01/17/2025) |
| 01/17/2025 | 2 | CERTIFICATE OF INTERESTED PARTIES by PHH Mortgage Corporation, and their successors and assigns, filed. (Frame, Nicholas) (Entered: 01/17/2025) |
| 01/20/2025 | 3 | First MOTION for Temporary Restraining Order by Lone Star Home Buyers, LLC, filed. Motion Docket Date 2/10/2025. (Hagger, Marcella) (Entered: 01/20/2025) |
| 01/21/2025 | 4 | CLERKS NOTICE Regarding Consent to Jurisdiction of Magistrate Judge. Parties notified, filed. (bkt4) (Entered: 01/21/2025) |
| 01/23/2025 | 5 | ORDER for Initial Pretrial and Scheduling Conference by Telephone and Order to Disclose Interested Persons. Counsel who filed or removed the action is responsible for placing the conference call and insuring that all parties are on the line. The call shall be placed to (713)250-5613. Telephone Conference set for 3/13/2025 at 08:45 AM before Judge Kenneth M Hoyt.(Signed by Judge Kenneth M Hoyt) Parties notified. (cjh4) (Entered: 01/23/2025) |
| 01/24/2025 | 6 | ANSWER to 1 State Court Petition/Notice of Removal, THIRD PARTY COMPLAINT against Ingrid C. Forrest, COUNTERCLAIM against Lone Star Home Buyers, LLC by PHH Mortgage Corporation, and their successors and assigns, filed. (Attachments: # 1 Exhibit) (Frame, Nicholas) (Entered: 01/24/2025) |
| 01/24/2025 | 7 | Request for Issuance of Summons as to Ingrid C. Forrest, filed. (Frame, Nicholas) (Entered: 01/24/2025) |
| 01/29/2025 | 8 | Summons Issued as to Ingrid C. Forrest. Issued summons delivered to plaintiff by NEF, filed. (mew4) (Entered: 01/29/2025) |
| 02/06/2025 | 9 | RETURN of Service of SUMMONS Executed as to Ingrid C. Forrest served on 2/1/2025, answer due 2/24/2025, filed. (Frame, Nicholas) (Entered: 02/06/2025) |
| 02/10/2025 | 10 | RESPONSE to 3 First MOTION for Temporary Restraining Order filed by PHH Mortgage Corporation, and their successors and assigns. (Frame, Nicholas) (Entered: 02/10/2025) |
| 02/13/2025 | 11 | NOTICE of Service of its Initial Disclosures, by PHH Mortgage Corporation, and their successors and assigns, filed. (Frame, Nicholas) (Entered: 02/13/2025) |
| 02/18/2025 | 12 | ORDER denying without prejudice 3 Motion for Temporary Restraining Order.(Signed by Judge Kenneth M Hoyt) Parties notified. (jm4) (Entered: 02/18/2025) |
| 02/26/2025 | 13 | Unopposed MOTION to Dismiss One Reverse Mortgage by Lone Star Home Buyers, LLC, filed. Motion Docket Date 3/19/2025. (Attachments: # 1 Appendix Memorandum, # 2 Proposed Order Proposed Order) (Hagger, Marcella) (Entered: 02/26/2025) |
| 03/03/2025 | 14 | JOINT DISCOVERY/CASE MANAGEMENT PLAN by PHH Mortgage Corporation, and their successors and assigns, filed. (Frame, Nicholas) (Entered: 03/03/2025) |
| 03/04/2025 | 15 | ORDER granting 13 Unopposed MOTION to Dismiss One Reverse Mortgage, One Reverse Mortgage, LLC terminated. (Signed by Judge Kenneth M Hoyt) Parties notified. (glc4) (Entered: 03/04/2025) |
| 03/12/2025 | 16 | ORDER FOLLOWING TELEPHONE SCHEDULING CONFERENCE held on March 13, 2025 at 8:45 a.m. Appearances: Waived. Telephonic appearances are waived unless otherwise notified by the Court. Initial Disclosures due by 3/25/2025. Pltf Expert Witness List due by 6/2/2025. Pltf Expert Report due by 6/2/2025. Deft Expert Witness List due by 7/1/2025. Deft Expert Report due by 7/1/2025. Discovery due by 7/30/2025. Dispositive Motion Filing due by 10/20/2025. Docket Call set for 1/5/2026 at 11:30 AM in Courtroom 11A before Judge Kenneth M Hoyt. Discovery may be extended by agreement of the parties without Court intervention. The dispositive motion deadline and docket call dates, however, may not be extended without leave of Court. Attorney’s fee applications are handled on the papers of the parties after notice. Expedited responses are required on all pretrial motions save dispositive motions. ETT: TBA. Jury trial. (Signed by Judge Kenneth M Hoyt) Parties notified. (cjh4) (Entered: 03/12/2025) |
| PACER Service Center | |||
|---|---|---|---|
| Transaction Receipt | |||
| 03/22/2025 20:49:14 |
WE’RE WELL AWARE OF THE “REMOTE HEARINGS” ATTRIBUTING TO GULF OF GALVESTON AND TEXAS BECOMING THE GULF OF CALIFORNIA.
ARE JAIL CALLS NEXT?
Gulf of California: On Feb. 28, 2025 Monica Riley Jailed for 5 Years in the Former State of Texas – Laws In Texas https://t.co/SzFvQt5cc1— lawsinusa (@lawsinusa) March 22, 2025
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LONE STAR HOME BUYERS LLC vs. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC
JAN 7, 2025 | REPUBLISHED BY LIT: MAR 22, 2025
MAR 22, 2025
Above is the date LIT Last updated this article.
Original stop foreclosure filing by Hagger for tax-forfeited entity. TRO Granted.
What’s Next for the Fords and Their Latest Legal Bandit Marcella Hagger?
Ford I Ends in Agreed Federal Court Dismissal With Prejudice n’ Ford II Ends on Summary Judgment in State Court with No Foreclosure Judgment.
Bandit Lawyer Hagger Abandons Client as Judge Hanen Issues Particularly Unpersuasive Opinion
While the Court finds no binding precedent on point, it finds multiple decisions from within the Fifth Circuit to be particularly persuasive.
Warning: Lone Star Lawyer Marcella Hagger is a Creditor Rights Attorney and Foreclosure Defense Lawyer
The Controversial Path of Bounty Hunter and Lawyer Marcella Hagger: She Navigates Both Sides of Foreclosure with Changing Allegiances.
