Defendant No.

LNV Corporation, et al Name: _________________________________________________________ 1 Corporate Drive, Suite 360 Street Address: _____________________________________________ Lake Zurich, IL 60047 City, State & Zip Code: _______________________________________ 847-550-7550 Telephone No. ______________________________________________ Dovenmuehle Mortgage Inc., et al Name: _________________________________________________________ 1 Corporate Drive, Suite 360 Street Address: _____________________________________________ Lake Zurich, IL 60047 City, State & Zip Code: _______________________________________ 847-550-7300 Telephone No. ______________________________________________

Defendant No. 4

Defendant No. 5

Select Portfolio Servicing Inc. Name: _________________________________________________________ 3815 South West Temple Street Address: ______________________________________________ Salt Lake City, UT 84115-4412 City, State & Zip Code: ________________________________________ 904-722-7009 Telephone No. ______________________________________________ DLJ Mortgage Capital Inc. Name: _________________________________________________________ 11 Madison Ave, Bsmt 1B Street Address: ______________________________________________ New York, New York 10010 City, State & Zip Code: _______________________________________ 212-325-2000 Telephone No. _______________________________________________ U.S. Bank Name: _________________________________________________________ 800 Nicollet Mall Street Address: ______________________________________________ Minneapolis, MN 55402 City, State & Zip Code: _______________________________________ 612-303-0783 Telephone No. _______________________________________________

Defendant No. 6

Defendant No. 7

Defendant No. 8

Credit Suisse Name: _________________________________________________________ 11 Madison Ave, Bsmt 1B Street Address: _____________________________________________ New York, New York 10010 City, State & Zip Code: _______________________________________ 212-325-2000 Telephone No. ______________________________________________

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Defendant No. 9

Lime Financial Services, LLC Name: _____________________________________________________ 11 Madison Ave. Street Address: ______________________________________________ New York, New York 10010 City, State & Zip Code: _______________________________________ (619) 590-9200 Telephone No. ______________________________________________

Defendant No. 10

MERSCORP Holdings Inc. Name: _________________________________________________________ 1595 Spring Hill Road, Suite 310 Street Address: _____________________________________________ Vienna, Virginia 2218 City, State & Zip Code: _______________________________________ 800-646-6377 Telephone No. ______________________________________________

Defendant No. 11

Dean Morris, L.L.P. Attorneys at Law. Name: _________________________________________________________ 1505 North 9th St. Street Address: _____________________________________________ City, State & Zip Code: _______________________________________ Monroe, LA 71207-2867 318-388-1440 Telephone No. ______________________________________________

II. JURISDICTION AND VENUE

Federal courts are courts of limited jurisdiction. Only two types of cases can be heard in federal court: cases involving a federal question and cases involving diversity of citizenship of the parties. A case involving the United States Constitution or federal laws or treaties is a federal question case. A case in which a citizen of one state sues a citizen of another state and the amount in damages claimed is more than $75,000 is a diversity of citizenship case. Venue is proper in the Middle District of Louisiana pursuant to 28 U.S.C. 1391 (b)(2) and 18 U.S.C. 1965 (a) because defendant reside, are found, have an agent, and / or transact their affairs in this District and a substantial part of the events or omissions giving rise to this claim have occurred in this District.

A. What is the basis for federal court jurisdiction (check all that apply)
X Federal Question X Diversity of Citizenship

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B. If the basis for jurisdiction is Federal Question, what federal Constitutional, statutory, or treaty right is at issue? ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________
domestic or foreign corporation or unincorporated association) 2003 (Obligee In Bad Faith); LA RS 14:123 (Perjury); LA RS 9:5646 (Sale of immovable property by Opportunity Act ); Fifth and Fourteenth Amendments to the United States Constitution; LA CC Art of Interest); 42 U.S.C. 3601 et seq., (Fair Housing Act); 15 U.S.C. 1691 et seq., (Equal Credit U.S.C. 77a, et seq., (Securities Act of 1933); 18 USC Chapter 11, et seq., (Bribery, Graft, and Conflicts seq. (Fraud and False Statements); 18 USC 1348 et seq. (Securities and Commodities Fraud); 15 Act); 15 U.S.C. 1601 et seq., (Consumer Credit Protection and Truth in Lending Acts); 18 USC 47 et Influenced and Corrupt Organizations Act); 12 U.S.C. 27 et seq., (Real Estate Settlement Procedures 18 USC 63 et seq., (Mail Fraud and Other Fraud Offenses); 18 USC 1961 et seq., (Racketeer

______________________________________________________________________________

C.

If the basis for jurisdiction is Diversity of Citizenship, what is the state of citizenship of each party?
Louisiana Plaintiff(s) state of citizenship ___________________________________________ New York, Illinois, Texas, Minnesota, Utah, Virgina Defendant(s) state(s) of citizenship _______________________________________

____________________________________________________________________ The court has jurisdiction over all defendants and Venue is proper in this judicial district pursuant to 15 U.S.C. 1121 and 28 U.S.C. 1331, 1332, 1338, and 1367. Defendants conduct business and can be found in this district, and a substantial part of the events or omissions giving rise to the claims alleged herein occurred in this district. This case primarily involves a federal question, complete diversity of citizenship exists, and the amount in controversy exceeds $75,000.

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III. STATEMENT OF CLAIMS

COUNT I Defendants: D. Andrew Beal, et al; Dean Morris Trustee Services, Inc.; LNV Corporation; Dovenmuehle Mortgage Inc.; MGC Mortgage Inc. Foreclosure Fraud On or about February, 20, 2010 Plaintiff received from Defendant Dean Morris, L.L.P. Attorneys at Law, (hereafter referred to as Dean Morris) a Notice mailed Plaintiffs home dated February, 16, 2010. The contents of this notice stated: Notice Pursuant to the Fair Debt Collection Practices Act: We have been engaged by LNV Corporation to institute and prosecute legal proceedings to enforce the security interest (Mortgage) pertaining to the above referenced account (Foreclosure). To the extent that existing or future laws, regulations, judicial decisions, or interpretations thereof, might be subject such proceedings to the provisions of the Fair Debt Collections Practices Act, you are hereby notified as follows: 1. This is an attempt to collect debt, and any information obtained will be used for that purpose. 2. The amount of the debt you owe is principal of $61,193.82 with interest, late charges, pre-payment penalties, attorneys fees, amount advanced and for taxes, assessments, and maintenance of the property, for the protection, preservation, repair and recovery of the property, for the protection and preservation of the lien of the mortgage, and for the protection and preservation of the mortgagees interest there under, if/as included in the mortgage, and costs.

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3. The name of the creditor is LNV CORPORATION. 4. Unless you, within 30 days of receipt of this notice, dispute the validity of the debt, or any portion thereof, we will assume that the debt is valid. 5. If you notify us in writing within 30 days of receipt of this notice, that the debt or any portion thereof is disputed, we will obtain and provide you with verification of the debt by mail. 6. If LNV CORPORATION is not the original creditor, we will provide you with the name and address of the original creditor, by mail, if you make written request for this information within 30 days after receipt of this notice. Immediately after receipt of this notice Plaintiff phoned Dean Morris and was told all correspondences must be sent to MGC Mortgage Inc., (hereafter referred to as MGC). MGC and LNV Corporation (hereafter referred to as LNV) are both ultimately owned by defendant D. Andrew Beal, (hereafter referred to as Beal). Shortly thereafter, Plaintiff mailed a letter to MGC disputing the debt and requesting information about LNV Corporation because she had never heard of this company before. Additionally she request information about how LNV acquired her mortgage. MGC told Plaintiff that her loan had been transferred to Dean Morris and to contact them. Plaintiff did so and was told by Dean Morris that they did not know why MGC told her that because they had no documents for the loan. Plaintiff then phoned MGC at which time she was led to believe she needed to do a loan modification; HOWEVER she was never in

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default of her own accord but because MGC alleged she was in default due to their own misappropriation of her payments beginning on or around Sept. 1, 2008.

3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

COUNT II Conspiracy to Defraud in Mortgage Foreclosure; Mail and Wire Fraud Beal, LNV, Dovenmuehle Mortgage Inc., (hereafter referred to as Dovenmuehle) and MGC along with SPS, MERSCORP Holdings Inc., (hereafter referred to as MERS), Credit Suisse, DLJ Mortgage Capital Inc. (hereafter referred to as DLJ), U.S. Bank, Lime Financial Services, LLC, (hereafter referred to as Lime), and Dean Morris did knowingly and willfully combine, conspire, confederate and agree with themselves and with others yet unknown or un-named, to commit certain offenses and acts of fraud to execute and attempt to execute a scheme and artifice to defraud, and to obtain money and property by means of material false and fraudulent pretenses, representations, and promises, by utilizing the United States mail and private and commercial interstate carriers, for the purpose of executing such scheme and artifice, in violation of Title 18, United States Code, Section 1341. The defendants acts of fraud include, but are not limited to, the following: a) Beginning in or about 2005, the defendants began forging and falsifying signatures on mortgage-related documents and/or conspired with others to do so as their agents in order to prepare and file with property recorders' offices throughout the United States; and specifically with Louisianas Ascension Parish recorders office where defendants filed various mortgage related documents specific to Plaintiffs property. b) Defendants or their agents and/or cohorts hired temporary workers to sign as Authorized Signers and thereby misrepresent their signatures as those of the Authorized Signers.

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These mortgage-related documents were fraudulently notarized by defendants employees and/or employees of their agents who knew the Authorized Signer did not actually sign the documents. c) These unauthorized signing and notarization practices allowed defendants, and others to generate greater profit and make more money at the expense of their victims, including the Plaintiff. d) After these false documents were signed and notarized, defendants filed them through the mails or by electronic methods with local county property records offices, including the Plaintiffs county. Many of these documents, particularly mortgage assignments and lost note or assignment affidavits, including those pertaining to Plaintiffs property, were later relied upon in non-judicial foreclosure proceedings and court proceedings, including property foreclosures and in federal bankruptcy court. Defendants knew that these property recorders, as well as those who received the documents such as courts, title insurers, and homeowners/borrowers, relied on these documents as genuine. e) Defendants their agents and cohorts and others also took various steps to conceal their actions from detection from consumers/borrowers/homeowners (including the Plaintiff), courts, law enforcement authorities, our government and others.

f) On or about January 28, 2009, MERS, DLJ, Loan Acquisition Corporation (another Beal company, LNV and MGC and/or their agents caused to be delivered to Gonzales, Louisiana, by United States Postal Service or by commercial interstate carrier from MGC, DLJ or LNV or Beal an Assignment of Mortgage filed with the Parish Recorder

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for Ascension Parish Louisiana, with false and fraudulent signatures of Authorized Signers and which bore a false and fraudulent notarization attestation and which contained other false representations. g) Defendants knew that these documents would be relied on and considered as genuine by attorneys, courts and law enforcement officials to the detriment of the Plaintiff. Such false representations were made willfully by defendants with intent to unjustly deprive Plaintiff of her property. h) In fact defendants used these fraudulent documents to initiate foreclosure and sheriff sale on Plaintiffs home scheduled for September 28, 2013, when they knew they in fact did not have legal standing to do so. Plaintiff suffered significant pecuniary loss, personal injury, inconvenience, discomfort, and substantial mental distress as a result of the defendants acts of intentional and willful fraud perpetrated toward her with intent of defrauding her of her money and property.

COUNT III Conspiracy to Defraud in Mortgage Origination, Securitization and Servicing Beal, LNV, Dovenmuehle Mortgage Inc., (hereafter referred to as Dovenmuehle) and MGC along with SPS, MERSCORP Holdings Inc., (hereafter referred to as MERS), Credit Suisse, DLJ Mortgage Capital Inc. (hereafter referred to as DLJ), U.S. Bank, Lime Financial Services, LLC, (hereafter referred to as Lime), and Dean Morris did knowingly and willfully combine, conspire, confederate and agree with themselves and with others yet unknown or un-named, to commit certain offenses and acts of fraud to execute and attempt to execute a scheme and artifice to

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defraud Plaintiff and target her for a loan that they knew would never be legally securitized and that they intended would default causing injury to Plaintiff. Plaintiff was specifically targeted for this fraud because she was a female head-of-household and the sole signer on her mortgage. This criterion was used by defendants to target minorities and other vulnerable consumer groups (including seniors and female head of households) for highly predatory mortgage loans and for financial fraud. Plaintiff relied on the material misrepresentations made by named Defendants to her detriment. Defendants did knowingly and willfully combine, conspire, confederate and agree with themselves and with others to commit certain offenses and acts of fraud to execute and attempt to execute a scheme and artifice to defraud, and to obtain money and property by means of material false and fraudulent pretenses, representations, and promises for the purpose of executing such scheme and artifice which directly caused Plaintiff to suffer significant pecuniary loss, personal injury, inconvenience, discomfort, and substantial mental distress as a result. Shortly after origination, evidence shows that Plaintiffs mortgage was sold to CSMC 2007-CF1 or the Trust. However, there are no admissions or evidence by way of assignments filed with Plaintiffs parish recorders office that this ever happened. The entire sale of the Plaintiffs loan, and its presence within the Trust, were intentionally glossed over and hidden in the loans chain of title history; this was done with intent to defraud. The goal in this scheme was / is to expedite or manufacture a so-called default by the borrowers of the underlying loans in order to trigger the insurance clauses in the Trusts Prospectus.

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No assignment was ever recorded evidencing a sale from Lime Financial Services, LTD to any other Trust entity or the Trust itself. THIS REPRESENTS A NON-CURABLE BREAK IN THE CHAIN OF TITLE. Loans that made up pools in the Trust were essentially converted into stock certificates. Investors in the Trust purchased certificates that did not provide them with an undivided interest in any one particular loan/mortgage. Thus the original terms and conditions of the mortgages and deeds of trust were changed without the borrowers (i.e. Plaintiffs) consent. This constitutes breach of contract, and violates the Truth in Lending Act (TILA) and RESPA. Plaintiffs property after this point was no longer collateral for the loan. Because the Plaintiffs loan has been paid off, a deed of reconveyance should have been issued in the plaintiffs parish extinguishing the Assignment of Mortgage. No other party can now have standing to attempt a foreclosure. Constitutional standing under Article III requires, at a minimum, that a party must have suffered some actual or threatened injury as a result of the Plaintiffs conduct, that the injury be traced to the challenged action, and that it is likely to be redressed by a favorable decision. Valley Forge Christian Coll. V. Am. United for Separation of Church and State, 454 U.S. 464, 472 (1982); United Food & Commercial Workers Union Local 751 v. Brown Group, Inc. 517 U.S. 544, 551, (1996). Standing requires that a party, in this case LNV , MGC or Dovenmuehle will suffer financial loss derived from non-performance (i.e., nonpayment) of the Plaintiffs contract with Lime Financial Services, LTD.

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The Seller of the loans into the Trust, DLJ, purchased Plaintiffs loan / mortgage from Lime Financial Services, Ltd on April 2, 2007. Lime Financial Services was paid for Plaintiffs nonperformance after April 2, 2007. DLJ received payment for Plaintiffs loan from the Depositor when her loan was sold into the Trust. The Depositor sold certificates to investors and used the proceeds to purchase the loans. The Certificate holders/ investors were made whole and were not harmed as a result of any borrowers failure to make monthly payments. DLJ therefor was not harmed by any alleged nonperformance by Plaintiff. (Note: Plaintiff remained current on her loan while it was in the Trust,) None of the sale transactions were documented or recorded in Plaintiffs public land records. Although Plaintiff has evidence that the loan went into Trust CSMC 2007-CF1 upon Plaintiffs request for the PSA from the Securities Exchange Commission, she learned that the said Trust was never filed which is suggestive of further securitization fraud. Furthermore, a key step in the securitization process is the physical delivery and endorsement of the promissory note and mortgage. LNV Corp. provided a copy of the original note in the request for foreclosure and MGC provided a copy upon request and there are no signatures on that copy indicating that the note and mortgage was never physically delivered to the trust. It also indicates that Beal, LNV, MGC and Dovenmuehle should have known of the fraud upon obtaining a copy of a blank note. In addition, they should have known that any transfer / sale from DLJ was not valid being that DLJ had no rights to sale / transfer from a trust with no signatures transferring the note into the trust. Failure to physically deliver the note and mortgage to the trust and failure to record the assignments and sales of the trust entities, and the failure to disclose the Trusts interest in the Plaintiffs note and mortgage and subsequent payoff of such, creates a fatal defect in the chain of

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title and chain of trustee that cannot be re-engineered. Any party attempting to claim ownership of the Plaintiffs note and mortgage after April 2, 2007 has unclean hands Beal, LNV, MGC and Dovenmuehle acquired Plaintiffs loan as stolen good from DLJ. The Jan. 5, 2009 Assignment whereby DLJ attempts to assign, sell, convey, and deliver the note and mortgage to LNV Corporation, in which it had no authority, and should have known of the fraud. The assignment of Mortgage filed with Plaintiffs Clerk of Court, public land records contain false information and forgeries. The robo-signed signatures and other material misrepresentations in an attempt to obfuscate the truth. This legal instrument was fabricated to steal Plaintiffs home through fraud. If these defendants in truth had lagal standing to foreclose they would not have needed to fabricate this fraudulent instrument to give the appearance of such standing. Plaintiff suffered significant pecuniary loss, personal injury, inconvenience, discomfort, and substantial mental distress as a result of the defendants acts of intentional and willful fraud perpetrated toward her with intent of defrauding her of her money and her property.

COUNT IV Conspiracy to Defraud in Mortgage Servicing: Fabricated Default Plaintiff received a letter dated August 15, 2008 from Defendant Select Portfolio Servicing, (hereafter referred to as SPS), stating that the servicing of the loan would be transferred effective Sept. 1, 2008 to MGC Mortgage. A few days later Plaintiff phoned MGC to ask where to and how to make payments since her Sept. 1st payment was coming due and MGC failed to send any welcome letter or payment information.
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MGCs customer service told Plaintiff that the transfer had not taken place yet and her loan was not in their system. MGC told Plaintiff as soon as the transfer was final they would send her a welcome letter and payment information. After many weeks this still had not happened. Plaintiff phoned MGC periodically and was always told the same thing and reassured that all fees and penalties would be waived because their company caused the delay. On or around Nov. 4, 2008 Plaintiff received a letter dated Oct. 27, 2008 stating that SPS would again become the servicer of her loan effective Oct. 30, 2008. Plaintiff immediately phoned SPS and was informed the servicing transfer to MGC Mortgage had failed to finalize; they were again was the servicer, but the loan number had changed. Plaintiff attempted to make her Sept., Oct. and Nov. payments by phone (she had been unable to do so due to MGCs failure to service her loan and held the funds until the time she could make these payments) but SPS told her that since the loan was in default late fees, penalties and a two transfer fees had been added. These added fees were unexpected and exorbitant. SPS refused to accept a partial payment and Plaintiff did not have the extra funds to cover them. Plaintiff has continuously disputed these extra fees to no avail. According to the Servicing Disclosure Statement Plaintiff received and signed at closing this is a violation of the Real Estate Settlement Procedures Act [12 U.S.C. 27 et seq.] (RESPA) This conduct is also a violation of LA CC Art 2003; Obligee in bad faith which states: An obligee may not recover damages when his own bad faith has caused the obligor's failure to perform or when, at the time of the contract, he has concealed from the obligor facts that he knew or should have known would cause a failure. If the obligee's negligence
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contributes to the obligor's failure to perform, the damages are reduced in proportion to that negligence. This is also a violation of Federal Trade Commission Acts (15 U.S.C. 1601 et seq., Thinking she had no choice but to pay the excessive fees, Plaintiff eventually agreed

(Consumer Credit Protection, Fair Debt Collection and Truth in Lending Acts).

to a forbearance plan with SPS. Then on or about Aug 17, 2009 Plaintiff received another letter from SPS dated Aug. 13, 2009 stating that servicing was again transferring to MGC Mortgage effective Sept. 1, 2009. After what happened with the first transfer Plaintiff was very distressed that a repeat of 2008 ordeal might occur. The transfer to MGC actually occurred this time and Plaintiff sent $400.00 every two weeks as per the forbearance plan she had with SPS. HOWEVER MGC returned every check she sent them. Plaintiff set up automatic payments to MGC through her bank so she would have indisputable evidence she attempted to make her payments. Plaintiff consistently disputed the ongoing misappropriation of her payments, MGCs refusal to accept her payments and the excessive fees that MGC continually added to her account to no avail. Some MGC employees told her they would honor her forbearance agreement with SPS, while others said they would not because they had no record of the agreement. All this caused the Plaintiff considerable mental anguish and despair. Automatic checks were sent from Plaintiffs account every two weeks with the first check dated Oct. 16, 2009 until Feb. 12, 2010 when Plaintiff had the checks stopped because of the letter she received from Dean Morriss office dated Feb. 16, 2010 about foreclosure.
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This has been a deliberate scheme to place Plaintiffs loan in default and extort excess fees from her and steal her home. SPS and MGC knowingly misrepresented material fact with intent to deceive Plaintiff. Plaintiff relied on their misinformation to her detriment has suffered injury as a result. MGC and LNV threatened foreclosure with intent to force Plainitff into agreeing to an exceptionally unfair loan modification that would have increased the principal balance on her loan from $61,070.05 to $83,861.12. MGC wanted Plaintiff to sign an agreement to waive all her rights to seek redress. The content of this waiver is quoted below: WAIVER As a material inducement to lender to enter into this agreement, each borrower, on behalf of himself and herself and his and her successors, assigns, heirs, legal representatives and constituents (whether or not a party hereto)(borrower and such successors, assigns, heirs, legal representatives and constituents being referred to herein collectively and individually, as obligors, et al.). hereby fully, finally and completely release and forever discharge original lender, lender and their respective successors, assigns, affiliates, subsidiaries, parents, officers, shareholders, directors, employees, attorneys and agents, past, present and future, and their respective heirs, predecessors, successors and assigns (collectively and individually, lender, et al.) of and from any and all claims, controversies, disputes, liabilities, obligations, demands, damages, expenses (including, without limitation, reasonable attorneys fees), debts, liens, actions and causes of action of any and every nature whatsoever including, without limitation any thereof relating to the loan, and waive and release any defense right of counterclaim, right of set off or deduction to the payment of the indebtedness evidenced by the note and/or mortgage or any other loan document which
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obligors, et al. now have or may claim to have against lender, et al., or any thereof, arising out of, connected with or relating to any and all acts, omissions or events occurring prior to the execution of this agreement. Plaintiff refused to sign MGCs waiver. She instead reached out to other victims of MGC, LNV and D. Andrew Beal; and learned that between June or July 2008 until 2010 MGC used the same pattern of fraud with other homeowners. Plaintiff learned about deed assignments and the legal requirements pertaining to chain of title in land records. She discovered that land records filed in her Parish allegedly assigning her Assignment of Mortgage to LNV had been forged. She learned about securitization and that her loan had been securitized into a Credit Suisse Trust, LNV has no standing to foreclose on Plaintiffs loan. Defendant Beal is the President/Director of LNV. Beal is the primary beneficiary of profits derived from LNVs and MGCs fraudulent business activities. Beal has established hundreds to thousands of companies, including LNV and MGC for purposes of fraud, money laundering and tax evasion. COUNT V Pattern of Criminal Activity Prohibited Under 18 USC Chapter 96 This action is brought pursuant to the provisions of the Racketeer Influenced and Corrupt Organizations Act (RICO) 18 U.S.C. 1961 et seq. This Court has subject matter jurisdiction under 28 U.S.C. 1331 and 18 U.S.C. 1964, 18 USC 1341, 18 USC 1343,

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In January 2009 defendants used mail or by other commercial interstate carrier to file a fraudulent assignment of mortgage in the Parish of Ascension, State of Louisianas public land records located at the Clerk Of Courts Office in Ascension against the property owned by Plaintiff. The RICO statutes provides that a private cause of action to any person who has been injured in their business or property by reason of a qualifying enterprise's affairs through a pattern of acts indictable as mail or wire fraud 18 USC 1964(c). The named defendants above has devised schemes to defraud the plaintiff in such ways that is irreparable, ranging from mailing fraudulent servicing transfers, fraudulent assignments filed with the public land records against Plaintiffs property, false information about Plaintiffs Trustee and Servicer on MERS website, and false information by telephone in communications with the Plaintiff. Plaintiff received correspondence stating that the servicer had transferred to a new servicer when in fact it had not. With three months of constant telephone calls to the servicer that the correspondence indicated was the new servicer and being told that the servicing had not yet transferred, Plaintiff was mislead to believe that as soon as the transfer had finalized she could make the payments without any negative effects. The servicing transferred right back to the original servicer then putting Plaintiff into default. Plaintiff relied on both the correspondences and telephone conversations and was harmed in the process by the default and a large amount of fees. A person commits mail fraud whenever that person, having devised any scheme to defraud, uses the mail or any private or commercial carrier while executing that scheme satisfies the 18 USC 1341. Thus being done when correspondences were sent to Plaintiff with a bogus servicing transfer.

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A person commits wire fraud whenever that person, having devised any scheme to defraud, transmits or causes to be transmitted by means of wire, radio or television communication in interstate or foreign commerce, any writings, signs, signals, pictures or sounds for the purpose of executing the scheme 18 USC 1343. Thus being done through telephone communications to which MGC stated that they would soon be sending a welcome letter and that there would be no ill effects harming the Plaintiff for their delays. MERS is also in violation to the later. When Plaintiff received letters sating LNV Corporation was the lender she turned to MERS website to see if such transfer had occurred. MERS website indicated that while SPS was servicer, U.S. Bank was Trustee and still showing active as long as May 13, 2012 (which Plaintiff did not check again until April 1, 2013). Plaintiff contacted MERS via telephone inquiring on this information and was told that they could not give her any information other than what was showing on their website. MERS purports to show to the homeowner and the public as to the true identity of the Trustee and servicer at all times being that do not think it is necessary to record mortgage assignment transfers in public land records as long as they are named mortgagee. The above named defendants committed fraud upon the courts and the Plaintiff for filing falsified documents, false statements to the Plaintiff and the public on their website, false statements in communications with the Plaintiff and false statements in correspondences.

FURTHERMORE; Plaintiff is filing this complaint pro-se because she has no choice. She is doing so at a horrific disadvantage, but is helpless to do otherwise. Due to the named Defendants criminal actions

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and the impact of their criminal activities on the general economy which in turn impacts the resources available to government agencies appointed with the duty of protecting consumers against fraud, no funding exists to provide effective legal assistance to homeowners victimized by the Defendants crimes or to provide them with recourse to seek effective legal remedy.

VI PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for relief as follows: 1. That the Court determines that it has jurisdiction over this action; 2. That a judgment be entered against defendants in favor of Plaintiff for injunctive relief and declaratory relief, and for equitable monetary relief in the nature of disgorgement, in amounts to be determined at trial; 3. That the Court award damages for tortuous injury and personal injury and other equitable relief to Plaintiff, in amounts to be determined at trial; 4. That the Court award actual damages to Plaintiff, in amounts to be determined at trial; 5. That the Court awards threefold actual damages to Plaintiff, as per the RICO Statutes. 6. That the court appoint a pro-bono counsel(s) to assist Plaintiff in discovery and at trial;
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