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LIT’s Watchin’ the Wolf, Debt Collecting Lawyers for that German Bank before Judge Pittman

Deutsche Bank National Trust Company seeks a declaratory judgment and foreclosure so it may enforce its security interest in the Property.

Deutsche Bank National Trust Company v. Chandler-Newton

(4:22-cv-00120)

District Court, N.D. Texas

FEB 15, 2022 | REPUBLISHED BY LIT: FEB 18, 2022

ORDER: Before the Court is Plaintiff’s Motion to Reinstate the Case on Active Docket (“Motion”).

ECF No. 19 .

This case was abated and administratively closed upon Plaintiffs request on April 6, 2022. Plaintiff and Defendant entered into negotiations while this case was abated but were unable to agree on a settlement.

After reviewing the Motion and the applicable law, the Court concludes that the Motion should be, and is hereby, GRANTED.

Accordingly, the Clerk of Court is instructed to REOPEN this case. Upon further review of the docket, the Court concludes that Plaintiff’s pending Motion for Default Judgment (ECF No. 11 ) should be DENIED without prejudice as moot.

(Ordered by Judge Mark Pittman on 7/22/2022) (sre) (Entered: 07/22/2022)

PLAINTIFF’S MOTION TO ABATE ACTION

Plaintiff Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-OPT1, Asset-Backed Certificates, Series 2006-OPT1 (“Deutsche” and “Plaintiff”) files this its Motion to Abate Action, and respectfully shows as follows:

I.

1. Plaintiff filed its Original Complaint on February 15, 2022 (the “Complaint”) against Defendant Annette F. Chandler-Newton (the “Defendant”) seeking a declaratory judgment allowing non-judicial foreclosure of the real property commonly known as 8524 Crestview Drive, North Richland Hills, Texas 76182. (ECF Docket No. 1).

2. On March 29, 2022, Plaintiff filed its Motion for Default Judgment against Defendant because she did not file a responsive pleading within 21 days after service of the Complaint. See FED. R. CIV. P. 12(a)(1)(A)(i) (ECF Document No. 11).

3. However, the undersigned has been recently informed that there is ongoing active loss mitigation on the subject mortgage loan.

As a result, Plaintiff is prohibited from moving forward with default judgment in this action, under current CFPB regulations.

See 12 CFR §1024.41(g).

4. Plaintiff therefore respectfully requests that this suit and all upcoming deadlines, settings and rulings be abated for a period of, at least, ninety (90) days to allow sufficient time to allow time for the loss mitigation procedures to be concluded.

In the event that the loss mitigation procedures do not conclude successfully, then Plaintiff shall immediately reinstate the case in order for the Court to rule on the pending Motion for Default Judgment which would dispose the entire case.

WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that this Court abate this action and all upcoming settings, deadlines and rulings for at least, ninety (90) days and for such other relief to which it may be justly entitled.

Respectfully submitted,
By: /s/ Vivian N. Lopez

MARK D. CRONENWETT
Texas Bar No. 00787303
mcronenwett@mwzmlaw.com

VIVIAN N. LOPEZ
PR State Bar PR20818
vlopez@mwzmlaw.com

MACKIE WOLF ZIENTZ & MANN, P.C.
14160 N. Dallas Parkway, Suite 900
Dallas, Texas 75254
214-635-2685 (Phone)
214-635-2686 (Fax)

ATTORNEYS FOR PLAINTIFF

CERTIFICATE OF CONFERENCE

I hereby certify that I have been unable to conference with the Defendant in this matter, as she has failed to appear in this case.

/s/ Vivian N. Lopez
VIVIAN N. LOPEZ CERTIFICATE OF SERVICE

The undersigned certifies that on April 6, 2022, a true and correct copy of the foregoing document was delivered to the following in the manner indicated:

Via U.S. Mail:
Annette F. Chandler-Newton
8524 Crestview Drive
North Richland Hills,
Texas 76182

/s/ Vivian N. Lopez
VIVIAN N. LOPEZ

April 6, 2022:

ORDER GRANTING PLAINTIFF’S MOTION TO ABATE ACTION…

CAME ON TO BE CONSIDERED this day the Motion to Abate Action (the “Motion”) filed by Plaintiff Deutsche Bank National Trust Company, as Trustee for Soundview Horne Loan Trust 2006-OPT I, Asset-Backed Certificates, Series 2006-OPTI.

After reviewing the Motion, the Court believes the Motion has merit and should be granted.

It is therefore, ORDERED that the Motion to Abate Action is GRANTED; and it is further, ORDERED that this action is abated for a period of 90 days.

The clerk of court is instructed to Administratively close this case.

Plaintiff shall file a status report no later than July 5, 2022.

(Ordered by Judge Mark Pittman on 4/6/2022) (wxc) (Entered: 04/06/2022)

PLAINTIFF’S ORIGINAL COMPLAINT

Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-OPT1, Asset-Backed Certificates, Series 2006-OPT1 (“Plaintiff” or “Deutsche”), complains of Annette F. Chandler-Newton, and Gonzalez Financial Holdings, Inc. aka GFH, Incorporated, Defendants, files this Original Complaint, and states as follows:

I. PARTIES

1. Plaintiff Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-OPT1, Asset-Backed Certificates, Series 2006-OPT is the trustee of a trustee of a trust with its principal place of business in California.

2. Defendant Annette F. Chandler-Newton is an individual and may be served with process at her residence, 8524 Crestview Drive, North Richland Hills, Texas 76182 or at such other place as she may be found. Summons is requested.

3. Defendant Gonzalez Financial Holdings, Inc. aka GFH, Incorporated is a domestic for-profit corporation doing business in the State of Texas and may be served through its registered agent, David D. Gonzalez, 909 NE Loop 410, Suite 902, San Antonio, Texas 78209. Summons is requested.

II. PROPERTY

4. This proceeding concerns the following real property and improvements commonly known as 8524 Crestview Drive, North Richland Hills, Texas 76182 more particularly described as:

LOT 15R, IN BLOCK 15, STONYBROOKE ADDITION, AN ADDITION TO THE CITY OF NORTH RICHLAND HILLS, TARRANT COUNTY, TEXAS, ACCORDING TO THE PLAT RECORDED IN VOLUME 388-95, PAGE 58, OF THE PLAT RECORDS OF TARRANT COUNTY, TEXAS (the “Property”).

III. DIVERSITY JURISDICTION AND VENUE

5. This Court has jurisdiction over the controversy because there is complete diversity between Plaintiff and Defendants, and the amount in controversy exceeds $75,000.00. See 28 U.S.C. § 1332.

6. Deutsche is a national bank association and the trustee of a trust. A trustee who possesses “customary powers to hold, manage, and dispose of assets” is the real party in interest to a suit. Navarro Sav. Assoc. v. Lee, 446 U.S. 458, 464 (1980); see BAC Home Loans Servicing, LP v. Tex. Realty Holdings, LLC, 901 F. Supp. 2d 884, 907–09 (S.D. Tex. 2012). “[W]hen a trustee files a lawsuit in her name, her jurisdictional citizenship is the State to which she belongs.” Bynane v. Bank of N.Y. Mellon, 866 F.3d 351, 357 (5th Cir. 2017) (quoting Justice v. Wells Fargo Bank National Association, 674 F. App’x 330, 332 (5th Cir. 2016) (quoting Americold Realty Tr. v. ConAgra Foods, Inc., 136 S. Ct. 1012, 1016 (2016))). A national banking association is considered a citizen of the state in which it is located, as determined by the state of its main office in the articles of association. Wachovia Bank, NA v. Schmidt, 546 U.S. 303, 318 (2006) (citing 28 U.S.C. § 1348). Because Deutsche’s main office is in California, Plaintiff is a citizen of California for diversity purposes. See FFGGP, Inc. v. Deutsche Bank Nat’l Tr. Co., Civil Action No. 3:16-CV-0742-M-BK, 2017 U.S. Dist. LEXIS 162336, at *6 (N.D. Tex. Sep. 6, 2017).

7. Defendant Annette F. Chandler-Newton is an individual and citizen of the state of Texas.

8. Defendant Gonzalez Financial Holdings, Inc. aka GFH, Incorporated is a corporation with its principal business in San Antonio, Texas. A corporation is a citizen of the state where it has been incorporated, and any state where the corporation has its principal place of business. See 28 U.S.C. § 1332(c)(1). Therefore, Defendant Gonzalez Financial Holdings, Inc. aka GFH, Incorporated is a citizen of Texas for diversity purposes.

9. In this suit, Plaintiff seeks a declaratory judgment and foreclosure so it may enforce its security interest in the Property. Because the lien interest is valued at more than $75,000.00, the minimum amount-in-controversy requirement has been met. When the object of the litigation is a mortgage lien that entitles its owner to the full use and enjoyment of the property, the lien may be measured by the appraised value of the property, the purchase price, or the outstanding principal and interest. Cf. Farkas v. GMAC Mortg., LLC, 737 F.3d 338, 341 (5th Cir. 2013).

10. When a party seeks declaratory relief, the amount in controversy is measured by the value of the object of the litigation, and the value of that right is measured by the losses that will follow. Webb v. Investacorp, Inc., 89 F.3d 252, 256 (5th Cir. 1996). Stated differently, the amount in controversy is “the value of the right to be protected or the extent of the injury to be prevented.” Hartford Ins. Grp. v. Lou-Con, Inc., 293 F.3d 908, 910 (5th Cir. 2002) (quoting Leininger v. Leininger, 705 F.2d 727, 729 (5th Cir. 1983)); see also Farkas, 737 F.3d at 341.

11. Here, the value of the right to be protected is enforcement of a mortgage lien through foreclosure. If Plaintiff were to foreclose on the Property, it would be entitled to either the full use and possession of it, or the proceeds of a foreclosure sale. As of February 10, 2022, the total amount due was $158,013.38. Further, the Tarrant County Appraisal District has valued the Property at $222,989.00. Therefore, the amount in controversy is more than $75,000.00.

12. Venue is proper in the Northern District of Texas, Fort Worth Division, because this suit concerns title to real property located in Tarrant County, Texas. See 28 U.S.C. §§ 124, 1391(b)(2).

IV. FACTS

13. The foregoing paragraphs are incorporated by reference for all purposes.

14. On or about October 29, 1996, Oran T. Stein executed a Warranty Deed with Vendor’s Lien (“Warranty Deed”) in favor of Vernon Newton and Defendant Annette F. Chandler-Newton granting them title in the Property. The Warranty Deed was recorded in the Official Public Records of Tarrant County, Texas under Document Number D196217475.

15. On or about January 4, 2006, Defendant Annette F. Chandler-Newton (“Borrower”) executed certain Texas Home Equity Adjustable Rate Note in the principal amount of $97,600.00 (“Note”), originally payable to Lenders Residential Mortgage Corp. (“Lenders Residential”) and bearing interest at the initial rate of 8.450% per annum. A true and correct copy of the Note is attached hereto as Exhibit A.

16. Concurrently with the Note, the Borrower and her husband at that time, Vernon Newton, executed that certain Texas Home Equity Security Instrument (the “Security Instrument” and together with the Note, the “Loan Agreement”), as grantors, granting a security interest in certain real property and improvements located in Tarrant County, Texas. On March 2, 2006, the Security Instrument was recorded in the Official Public Records in Tarrant County, Texas under Document Number D206060086. A true and correct copy of the Security Instrument is attached hereto as Exhibit B.

17. The Note was initially specially indorsed by Lenders Residential in favor of Option One Mortgage Corporation (“Option One”). The Note was then indorsed in blank by Option One, and there have been no other endorsements or allonges.

18. Plaintiff is the current owner and holder of the Note. See Exhibit A.

19. On February 6, 2010, Vernon Newton executed a Quitclaim Deed, conveying his interest in the Property to Borrower. The Quitclaim Deed was filed in the Real Property Records of Tarrant County on March 5, 2010, as Instrument Number D210049431.

20. Prior to the execution of the Loan Agreement, a Consent to Transfer of Tax Lien (“Consent to Transfer”) was executed by Borrower and Vernon Newton on August 19, 2005. The Consent to Transfer provided consent for payment of all delinquent ad valorem taxes on the Property by GFH, Incorporated (“GFH”). Concurrently, a Deed of Trust – Tax Lien was executed pursuant to the Consent to Transfer agreement, granting GFH a security interest in the Property. The Consent to Transfer, along with the Deed of Trust – Tax Lien, was filed in the Real Property Records of Tarrant County on August 23, 2005, as Instrument Number D205248021. Upon information and belief, the Deed of Trust – Tax Lien was satisfied from the proceeds of the Loan Agreement in 2006. However, no release of the Deed of Trust – Tax Lien was ever filed. No action has been taken since 2005, by GFH, to enforce its tax lien on the Property.

21. Under the terms of the Loan Agreement, Borrower was required to pay when due the principal and interest on the debt evidenced by the Note, as well as any applicable charges and fees under the Note.

22. The Loan Agreement further provides that should Borrower fail to make payments on the Note as they became due and payable or fail to comply with any or all of the covenants and conditions of the Security Instrument, that the lender may enforce the Security Instrument by selling the Property according to law and in accordance with the provisions set out in the Loan Agreement.

23. Borrower failed to make the payments under the terms of the Loan Agreement and a Notice of Default and request to cure was mailed to Borrower in accordance with the Loan Agreement and with section 51.002 (d) of the Texas Property Code on June 27, 2018. A true and correct copy of the Notice of Default dated June 27, 2018, is attached hereto as Exhibit C.

24. The Borrower failed to cure the default, and the maturity date of the debt was accelerated on September 25, 2018, when a Notice of Acceleration of Loan Maturity was mailed to the Borrower. A true and correct copy of the Notice of Acceleration of Loan Maturity is attached hereto as Exhibit D.

25. After the acceleration of the debt, the Borrower applied and was working on a loss mitigation option to resolve the default under the Loan Agreement. On August 28, 2019, a Notice of Rescission of Acceleration of Loan Maturity was mailed to the Borrower advising her that the prior acceleration of the debt was rescinded without prejudice. A true and correct copy of the Notice of Recission of Acceleration of Loan Maturity is attached hereto as Exhibit E.

26. The Borrower was finally approved for a loan modification and executed a Loan Modification Agreement with Plaintiff on December 15, 2020, thereby modifying the terms of the Loan Agreement to cure the default. A true and correct copy of the executed Loan Modification Agreement is attached hereto as Exhibit F.

27. Subsequently, Borrower failed to make the payments under the terms of the Loan Agreement, as modified. The Loan Agreement is currently due for the October 1, 2021, payment, and all subsequent monthly payments. Notice of default and request to cure was mailed to Borrower in accordance with the Loan Agreement and with section 51.002 (d) of the Texas Property Code on November 18, 2021, A true and correct copy of the Notice of Default dated November 18, 2021, is attached hereto as Exhibit G.

28. The default was not cured, and the maturity of the debt is hereby accelerated by the filing of the instant action.

29. Plaintiff brings this suit for declaratory judgment and foreclosure so it may enforce its security interest in the Property. Plaintiff also brings this suit to obtain a declaratory judgment that GFH’s tax lien is extinguished by law and no longer presents a cloud on title to the Property. In the alternative, Plaintiff seeks a declaration that the tax lien of GFH has been satisfied and no longer encumbers the Property in question.

V. CAUSE OF ACTION: DECLARATORY JUDGMENT (STANDING TO FORECLOSE)

18. The foregoing paragraphs are incorporated by reference for all purposes.

19. Plaintiff has standing to enforce the Security Instrument as holder and owner of the Note. Hardaway v. Select Portfolio Servicing, Inc., No. 4:18-CV-1062, 2020 U.S. Dist. LEXIS 63172 at *8 (S.D. Tex. Apr. 10, 2020) (citing Everbank v. Seedergy Ventures, Inc., 499 S.W.3d 534, 541 (Tex. App.—Houston [14th Dist.] 2016, no pet.)) Plaintiff requests a declaration from this Court that, as the owner and holder of the Note it has standing and is authorized under the Security Instrument to enforce the power of sale contained in the Security Instrument through a non-judicial foreclosure of the Property.

20. Plaintiff has been forced to hire the undersigned attorneys to seek a declaratory judgment as a result of the Borrower’s failure to comply with the Loan Agreement. Plaintiff is therefore entitled to its reasonable attorney’s fees in this action, both through trial and in the event of a subsequent appeal, as provided by the Security Instrument signed by the Borrower. Plaintiff requests that the award of attorney’s fees be made not as a money judgment against the Defendants, but as further obligation under the subject Note and Security Instrument.

VI. CAUSE OF ACTION: FORECLOSURE

21. The foregoing paragraphs are incorporated by reference for all purposes.

22. As the current owner and holder of the Note who has the right to enforce the Note and the Security Instrument, Plaintiff asserts a cause of action for foreclosure against Borrower. The Loan Agreement is a contract, and Plaintiff fully performed its obligations under it. Borrower, however, did not comply with the Loan Agreement by failing to substantially perform material obligations required under its terms (principally, the payment of amounts due under the contract, among others). Therefore, Plaintiff seeks a judgment allowing it to foreclose on the Property in accordance with the Security Instrument and Texas Property Code § 51.002.

23. Plaintiff has been forced to hire the undersigned attorneys to seek a declaratory judgment as a result of the Borrower’s failure to comply with the Loan Agreement. Plaintiff is therefore entitled to its reasonable attorney’s fees in this action, both through trial and in the event of a subsequent appeal, as provided by the Security Instrument signed by the Borrower. Plaintiff requests that the award of attorney’s fees be made not as a money judgment against the Defendants, but as further obligation under the subject Note and Security Instrument.

24. All conditions precedent for foreclosure have been performed or have occurred, and any other action required under applicable law and the loan agreement, contract, or lien sought to be foreclosed has been performed.

VIII. CAUSE OF ACTION: DECLARATORY JUDGMENT (EXTINGUISED LIEN)

25. The foregoing paragraphs are incorporated by reference for all purposes.

26. Plaintiff requests a declaration from the Court that the lien held by GFH on the Property is released and is extinguished by the commencement of this litigation. GFH’s tax lien was satisfied through the proceeds of the 2006 Security Instrument, and there was a subsequent failure to release the lien.

IX. CAUSE OF ACTION: SUIT TO QUIET TITLE

27. The foregoing paragraphs are incorporated by reference for all purposes.

28. In addition to the declaratory judgment causes of action, Plaintiff brings a claim to quiet title in its favor. That is, Plaintiff seeks a judgment that there are currently no valid liens on the Property other than Plaintiff’s superior first lien. Any uncertainty as to the validity of the secured interests previously held by GFH creates a cloud on title. Therefore, Plaintiff requests that title shall be quieted as to any stranger to title.

29. Plaintiff seeks that a declaration that any competing interests in the Property would be extinguished when Plaintiff foreclose on the Property.

X. PRAYER

WHEREFORE, PREMISES CONSIDERED, Plaintiff requests that Defendants be summoned to appear and answer, and that upon final hearing, the Court enter judgment granting declaring that

(1) Plaintiff is the owner and holder of the Note,

(2) Borrower is in default on her obligations on the Loan Agreement,

(3) Plaintiff as the owner and holder of the Note has standing and is authorized to enforce the power of sale through non-judicial foreclosure of the Property pursuant to the terms of the Loan Agreement and Texas Property Code § 51.002, or alternatively, by judicial foreclosure,

and

(4) that the lien held by GFH on the Property is released and extinguished.

Plaintiff further a declaratory judgment quieting title against the Property and requests attorneys’ fees and costs of suit, not as a money a judgment against Defendants, but as further obligation under the subject Note and Security Instrument, and all other relief, in law and in equity, to which Plaintiff is entitled.

Respectfully submitted,

By: /s/ Mark Cronenwett
MARK D. CRONENWETT
Texas Bar No. 00787303
mcronenwett@mwzmlaw.com

VIVIAN N. LOPEZ
State Bar No. PR20818
vlopez@mwzmlaw.com

MACKIE WOLF ZIENTZ & MANN, P.C.
14160 North Dallas Parkway, Suite 900
Dallas, Texas 75254
Telephone: 214-635-2650
Facsimile: 214-635-2686

ATTORNEYS FOR PLAINTIFF

Deutsche Bank National Trust Company and The Wolves of Texas v. Dianna Freeman

The Loan Agreement is in default as of July 1, 2021 after Mack Freeman’s Death in 2019. A Notice of Default was sent on March 8, 2021.

US Bank and the Wolves of Texas Quickly Dismiss both Defendants Without Prejudice

The harassment will continue, once the foreclosure mill refiles, in this perpertual scheme they use to keep foreclosures running for decades.

Perjured Affidavit by PHH Ocwen’s Juliana Thurab. It Could Not Be Based on Personal Knowledge

Juliana Thurab is a Contract Management Coordinator at Ocwen Financial based in West Palm Beach, Florida. She submitted a perjured affidavit.

U.S. District Court
Northern District of Texas (Fort Worth)
CIVIL DOCKET FOR CASE #: 4:22-cv-00120-P

Create an Alert for This Case on RECAP

Deutsche Bank National Trust Company v. Chandler-Newton et al
Assigned to: Judge Mark Pittman
Cause: 28:1332 Diversity-Breach of Contract
Date Filed: 02/15/2022
Jury Demand: None
Nature of Suit: 290 Real Property: All Other Real Property
Jurisdiction: Diversity
Plaintiff
Deutsche Bank National Trust Company
As Trustee for Soundview Home Loan Trust 2006-OPT1, Asset-Backed Certificates, Series 2006-OPT1
represented by Mark D Cronenwett
Mackie Wolf Zientz & Mann PC
14160 N Dallas Parkway, Suite 900
Dallas, TX 75254
214-635-2650
Fax: 214-635-2686
Email: mcronenwett@mwzmlaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Bar Status: Admitted/In Good StandingVivian Nahir Lopez
Mackie Wolf Zientz Mann PC
14160 N Dallas Parkway
Suite 900
Dallas, TX 75254
214-635-2662
Fax: 214-635-2686
Email: vlopez@mwzmlaw.com
ATTORNEY TO BE NOTICED
Bar Status: Admitted/In Good Standing
V.
Defendant
Annette F. Chandler-Newton
Defendant
Gonzalez Financial Holdings, Inc.,
also known as
GFH, Incorporated

 

Date Filed # Docket Text
02/15/2022 1 COMPLAINT against Annette F. Chandler-Newton, Gonzalez Financial Holdings, Inc., filed by Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-OPT1, Asset-Backed Certificates, Series 2006-OPT1. (Filing fee $402; Receipt number 0539-12602971) Plaintiff will submit summons(es) for issuance. In each Notice of Electronic Filing, the judge assignment is indicated, and a link to the Judges Copy Requirements and Judge Specific Requirements is provided. The court reminds the filer that any required copy of this and future documents must be delivered to the judge, in the manner prescribed, within three business days of filing. Unless exempted, attorneys who are not admitted to practice in the Northern District of Texas must seek admission promptly. Forms, instructions, and exemption information may be found at www.txnd.uscourts.gov, or by clicking here: Attorney Information – Bar Membership. If admission requirements are not satisfied within 21 days, the clerk will notify the presiding judge. (Attachments: # 1 Exhibit(s), # 2 Cover Sheet) (Cronenwett, Mark) (Entered: 02/15/2022)
02/15/2022 2 Request for Clerk to issue Summons as to all Defendants, filed by Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-OPT1, Asset-Backed Certificates, Series 2006-OPT1. (Cronenwett, Mark) (Entered: 02/15/2022)
02/15/2022 3 CERTIFICATE OF INTERESTED PERSONS/DISCLOSURE STATEMENT by Deutsche Bank National Trust Company, as Trustee for Soundview Home Loan Trust 2006-OPT1, Asset-Backed Certificates, Series 2006-OPT1. (Lopez, Vivian) (Entered: 02/15/2022)
02/15/2022 4 New Case Notes: A filing fee has been paid. File to: Judge Pittman. Pursuant to Misc. Order 6, Plaintiff is provided the Notice of Right to Consent to Proceed Before A U.S. Magistrate Judge. Clerk to provide copy to plaintiff if not received electronically. Attorneys are further reminded that, if necessary, they must comply with Local Rule 83.10(a) within 14 days or risk the possible dismissal of this case without prejudice or without further notice. (sre) (Entered: 02/16/2022)
02/16/2022 5 Summons Issued as to Annette F. Chandler-Newton, Gonzalez Financial Holdings, Inc.. (sre) (Entered: 02/16/2022)
LIT’s Watchin’ the Wolf, Debt Collecting Lawyers for that German Bank before Judge Pittman
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