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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF SUFFOLK
----------------------------------------------------------------------- X Index #
HSBC BANK USA, NATIONAL ASSOCIATION AS
TRUSTEE FOR WELLS FARGO ASSET
SECURITIES CORP, MORTGAGE ASSET-BACKED
PASS THROUGH CERTIFICATES, SERIES 2007-PAI

Plaintiff,
VERIFIED ANSWER
-against-

_______________________________________, ET AL;

Defendants.
----------------------------------------------------------------------- X

Defendant, xxxxxxxxxxxx, and xxxxxxxxxxx and for their Answer to the Complaint
herein, sets forth and alleges the following :

1. As to the allegation(s) contained within the paragraph numbered: 1 of the

Complaint, Defendants, _________________ and _________________ lack sufficient

information and knowledge to form a belief, and must therefore leave the strict burden

of proof upon the Plaintiff. Though Plaintiff is a banking corporation duly licensed duly

licensed, organized and exists pursuant to the laws of the United States of America,

Plaintiff must show proof they are admitted and duly authorized to conduct business in

the State of New York. It is Defendants belief that Plaintiff lacks any standing to

pursue this action and as such this action should be dismissed.


2. Denies each and every allegation in paragraph numbered, 5 and 6 of the

Complaint and leaves the strict burden of proof upon the Plaintiff as Defendant calls for a

strict accounting of the alleged principal balance claimed owed.



3. Defendants admit the allegation in paragraphs numbered 2 and 3 of the

Complaint only insofar as to admit the Defendants did execute the said note and

mortgage on the stated date, but as to the purported assignment of that mortgage,

Defendants believe the assignment was of a fraudulent nature and if the within

foreclosure action is based upon a fraudulent transaction, the foreclosure action must fail

as a matter of law and be dismissed in whole.

It should also be noted that Plaintiff merely states a recording date of said mortgage, but

fails to state the date said mortgage was acknowledged. Defendant leaves the strict

burden of proof upon the Plaintiff to show and prove the date of acknowledgement of

said mortgage.

4. Denies any knowledge or information sufficient to form a belief

as to each and every allegation contained in paragraph numbered 4 , 14 , 17, and

must therefore leave the strict burden of proof upon the Plaintiff.

5. The answering Defendant respectfully refers the allegations

contained in paragraphs numbered 7 , 8 , 9 , 10,of the Complaint to the Trial

Court for determination to the extent that these paragraphs set forth allegations of legal

conclusions and are incapable of an answer.

6. Defendant demies the allegations numbered 11 and 12 of the Complaint


7. Defendant denies all allegations not expressly admitted.



Further answering, Defendant pleads the following affirmative defenses




AS AND FOR FIRST AFFIRMATIVE DEFENSE

As for the allegations set forth in paragraph 5 of the Complaint, Plaintiff alleges
Defendant ____________ has failed to comply with the terms of the mortgage by failing
to make said mortgage payment on July 1
st
, 2009. Meanwhile, in a foreclosure action of
the same caption, to enforce the same mortgage debt, under index # 09 49728 and filed
with the Suffolk County Clerk on December 18, 2009, Defendant respectfully refers to
paragraph 5 of that Complaint where Plaintiff at that time states Defendant ________
failed to comply with the terms of the same mortgage by failing to make said mortgage
payment on May 1
st
, 2009.
Furthermore, in paragraph 6 of the instant Complaint, Plaintiff calls the
principal amount due on the mortgage $306,561.67 at 7% interest from June 1
st
, 2009.
Meanwhile, under that previous foreclosure action filed December 18, 2009 under index
# 09 49728, Plaintiff at that time calls the principal amount due on the mortgage
$307,171.18 at 7% interest from April 1
st
, 2009.
A major discrepancy and miscalculation. Defendants seek a dismissal of action as it is
apparent that Plaintiffs prior action was unsuccessful, ending in the discontinuance of
their action for their inability to maintain the action. Plaintiff now tries once more to
prosecute but apparently cannot get the material facts correct. Essential, material facts
that are the basis to the within foreclosure action. The foreclosure action must fail, and
dismissed in its entirety because the most basic facts are contradicted by the Plaintiffs
previously filed foreclosure action.
(Please see Exhibit A, 2009 Foreclosure Complaint paragraph 5 and 6)

AS AND FOR SECOND AFFIRMATIVE DEFENSE
LACK OF STANDING

On November 28
th
, 2006 Defendant engaged Franklin First Financial (hereinafter
FFF) and Mortgage Electronic Registration Systems Inc., (hereinafter MERS) and
entered into a loan agreement. The terms of the loan were memorialized in a promissory
note ("the Note"), which was secured by a Mortgage lien on the Property. Said Mortgage
was recorded on January 24
th
, 2007 in Suffolk County, New York, Liber: M00021460
and Page: 458 Defendant executed the Note naming FFF as lender and then separately
executed the Mortgage naming MERS, as lender Mortgagee.
On February 10
th
, 2014 HSBC Bank USA, National Association as Trustee F(O)R
Wells Fargo Asset Securities Corporation, Mortgage Asset-Backed Pass-Through
Certificated, Series 2007-PA1 3476 Stateview Boulevard, Ft. Mill, SC 29715 commenced
foreclosure proceedings against the Defendant, recording with the Suffolk County Clerk,
a Notice of Lis Pendens announcing that the Plaintiff intends to seize the Defendants
property.
In both of the Plaintiffs Complaints to foreclose on the Defendants property, the
2009 action and the instant 2014 action, the Plaintiff claims that they are the holder of the
note, thus, they are entitled to enforce the note. However, the Plaintiff does not state that
the note was indorsed and negotiated to the Plaintiff in either complaint. The Plaintiff
attached said endorsed note in both complaints, as an exhibit. However, on the 2009
Foreclosure Action Complaint the note has a stamp stating an Allonge attached for the
purpose of endorsing the note yet, said Allonge is missing. Most likely never attached,
most likely this note was never endorsed period.

(please see exhibit B, note attached in 2009 action and exhibit C, note attached in
instant 2014 action)
In the Plaintiffs second complaint, the stamp stating Allonge attached for the
purpose of endorsing the note was repeatedly crossed out, and all of the sudden, multiple
stamps popped up. Stamps, not originally recorded with the mortgage or note, nor in the
original 2009 complaint now stating: Without recourse pay to the order of Wells Fargo
Bank, N.A. Franklin First Financial, By Wells Fargo Bank, N.A. Attorney-In-Fact By:
Joan M. Mills, Vice President, as well as another crossed out stamp stating Without
recourse pay to the order of ** Wells Fargo Bank, N.A. By: Joan M. Mills, Vice
President, and finally a crossed out type written clause stating **HSBC BANK USA
NATIONAL ASSOCIATION AS TRUSTEE FOR WELLS FARGO ASSET BACKED
SECURITIES CORPORATION MORTGAGE ASSET-BACKED PASS-THROUGH
CERTIFICATED SERIES 2007-PA1 with initials (illegible) no doubtably approving
said cross-out. There now appears 2 attached pieces of paper (again not originally
recorded with the note and mortgage nor the original complaint) the first, with just one
stamp stating Without recourse pay to the order of Wells Fargo Bank, N.A. Samuel C.
Shelley, Senior Vice President. The Second is a Certification Attachment Which states
the original specs of the loan, and someone named Jason B. Desiderio? stating that they
have compared these newly fabricated documents with the original and is certifying that
the aforementioned paperwork is a true and complete copy. Defendant wonders how they
could have, essentially, two different certified reliable copies of their mortgage and
note. This is fraud at its most obvious. Defendant takes serious offense to the Plaintiffs
blatant attempts to insult their intelligence and fraudulent smoke and mirror actions,
which consequently are meant to insult and spit on the intelligence of the public, the law
and the court system.
Had the Plaintiff not attempted to cover up heir blatant mistakes, said
endorsement would have proved that in fact, the note was indorsed and negotiated to the
lender, not the Plaintiff and the security relating to said note was negotiated and claimed
to have been endorsed by someone else in its entirety, when again, there was never any
endorsement. Defendant finds it odd and highly unethical that MERS could be both
holder of the mortgage as well as nominee of the true owner. MERS claiming its status
of mortgagee of record is a vague term that does not give one legal standing as
mortgagee. Hence, at best, MERS is only a nominee. MERSs actions backed by claims
that as nominee it can assign notes or mortgages is completely without standing a
nominee has limited rights and those most certainly do not include the right to transfer
ownership unless there is specific written instruction to do so. Further, said evidence
provided by the Plaintiff would only prove indebtedness and obligation to the Lender
NOT the Plaintiff, however since said evidence attached to the original complaint, lacks
endorsements, and an allonge allotted for endorsements in its entirety, it proves
indebtedness to no one.
Plaintiff is not the true holder in due course, lacks the legal standing to commence
an action and as a matter of Law this Complaint should be dismissed.




AS AND FOR THIRD AFFIRMATIVE DEFENSE
LACK OF STANDING / NOT HOLDER IN DUE COURSE
The Plaintiff claims it is also the current holder and beneficiary of the Mortgage
which secures the note, yet not mentioning that the originals are in Plaintiffs possession
or control, and still claiming they are entitled to enforce the aforementioned mortgage
and note pursuant to law. Plaintiff feels they are entitled to enforce their standing, so
where are the original documents, if not in their possession and control?
Further, the Plaintiff avoids claiming it is the true and lawful holder of the said
note and is mortgagee of record or has been delegated the authority to institute a
mortgage foreclosure action by owner and holder of the subject mortgage and note. As
stated above, if the Plaintiff has received its official status based upon a trail of lies and
illegalities, does the Plaintiff actually have standing to commence these proceedings?
Thus, upon information and belief, Defendant alleges that the Plaintiffs claim is
untrue. There is no evidence that the Defendants Mortgage Note was ever officially
transferred to the now purported holder-in-due-course as the original documents (that
being the note and its security) were assigned by a party which lacked standing to assign
them. One may think (using common sense) even if the assignee did have standing to
assign the security, the note would not assign, simply because, a nominee lacks standing
to do such. Thus the Plaintiff lacks standing to enforce said note, as it is not in legal
ownership of said mortgage. Even if it is in physical possession of the original
paperwork (which Defendant believes to be a complete impossibility), they did not
legally obtain possession of said paperwork, therefore they cannot enforce. Further, in
order to help better educate the Plaintiff on who is who and what is what, the UCC
Article 3 defines its imperative terms and principles as such:
(a) Negotiable instrument (defines Instrument as a negotiable
instrument.), means an unconditional promise or order to pay a fixed amount of
money, with or without interest or other charges described in the promise or
order, if it:
(1) is payable to bearer or to order at the time it is issued or first
comes into possession of a holder;
(2) is payable on demand or at a definite time; and
(3) does not state any other undertaking or instruction by the
person promising or ordering payment to do any act in addition to the
payment of money, but the promise or order may contain (i) an
undertaking or power to give, maintain, or protect collateral to secure
payment, (ii) an authorization or power to the holder to confess judgment
or realize on or dispose of collateral, or (iii) a waiver of the benefit of any
law intended for the advantage or protection of an obligor.
(b) An instrument is transferred when it is delivered by a person other than
its issuer for the purpose of giving to the person receiving delivery the right to
enforce the instrument.
(c) Whether or not the transfer is a negotiation, vests in the transferee any
right of the transferor to enforce the instrument, including any right as a holder in
due course, but the transferee cannot acquire rights of a holder in due course by a
transfer, directly or indirectly, from a holder in due course if the transferee
engaged in fraud or illegality affecting the instrument.
(d) Unless otherwise agreed, if an instrument is transferred for value and
the transferee does not become a holder because of lack of endorsement by the
transferor, the transferee has a specifically enforceable right to the unqualified
endorsement of the transferor, but negotiation of the instrument does not occur
until the endorsement is made.
Further, since the Plaintiff has made such insane attempts at trying to cover up
their improper treatment of these instruments, Defendant reiterates, again for Plaintiffs
knowledge, the following WITH EMPHASIS:
For The Plaintiff to prove that it has the right to enforce Defendants note, said
note must be indorsed either to The Plaintiff directly, or in blank.
(a)
"Endorsement" means a signature, other than that of a signer as maker,
drawer, or acceptor, that alone or accompanied by other words is made on
an instrument for the purpose of (i) negotiating the instrument, (ii)
restricting payment of the instrument, or (iii) incurring endorsers liability
on the instrument, but regardless of the intent of the signer, a signature and
its accompanying words is an endorsement unless the accompanying
words, terms of the instrument, place of the signature, or other
circumstances unambiguously indicate that the signature was made for a
purpose other than endorsement.

Defendant lacks legal standing to enforce this debt and the Complaint should be
dismissed in its entirety.

The Plaintiff attached to its original and most recent complaints a copy of the note
as an exhibit. Defendant asks that you please see the attached note from each one of the
Plaintiffs complaints where on the signature page of note, there appears a stamp in
which Allonge attached for the purpose of endorsing the note which consequently was
never attached to the note, never recorded and therefore, the note is lacking an
endorsement, period. The mortgage, coincidentally, was never endorsed either.
In the Plaintiffs second complaint, the aforementioned stamp stating Allonge
attached for the purpose of endorsing the note was crossed out, and all of the sudden,
numerous undated endorsements stating,: Without recourse pay to the order of Wells
Fargo Bank, N.A. Franklin First Financial, By Wells Fargo Bank, N.A. Attorney-In-Fact
By: Joan M. Mills, Vice President, as well as another crossed out stamp stating Without
recourse pay to the order of ** Wells Fargo Bank, N.A. By: Joan M. Mills, Vice
President, and finally a crossed out type written clause stating **HSBC BANK USA
NATIONAL ASSOCIATION AS TRUSTEE FOR WELLS FARGO ASSET BACKED
SECURITIES CORPORATION MORTGAGE ASSET-BACKED PASS-THROUGH
CERTIFICATED SERIES 2007-PA1. As well as two new attachments, the first, with
just one stamp stating Without recourse pay to the order of Wells Fargo Bank, N.A.
Samuel C. Shelley, Senior Vice President. The Second is a Certification Attachment
Which states the original specs of the loan, and a certification that the aforementioned
paperwork is a true and complete copy.
Defendant asks, who are these people endorsing and signing certifications? You
are a Vice President of who? To what? Said unauthenticated endorsements in blank
serves to memorialize the sale/transfer of Defendants loan which had previously taken
place.
Defendant alleges that The Plaintiff does not have the requisite evidence needed
to claim it is the holder of Defendants Note as The Plaintiff falsely created the
endorsement needed to prove it had the ability to enforce Defendants note.
There is an ever-increasing quantity of lawsuits filed on behalf of home owners,
governmental agencies and MBS investors, which have accused MERS, HSBC, Wells
Fargo and Deutsche and its affiliates of fraudulently creating documents in order to
justify legal entitlement to institute foreclosure proceedings.
Defendant has conducted numerous internet searches regarding the endorsement
of notes allegedly indorsed by Joan M. Mills producing numerous results containing and
exact replica of the signature and stamp of one Joan M. Mills along with the words fake,
fraudulent and robo-signing.
Upon information and belief, made blatantly obvious by the attached Exhibits,
Defendant alleges that The Plaintiff intentionally falsified the Note by utilizing a
computerized photo shopped stamp, or some other device to create said blank
endorsement allegedly signed by, Vice President Joan M. Mills.
For the Note to be considered bearer paper, Joan M. Mills must have personally
indorsed the note and her signature must have been authenticated by a notary, which is,
oddly enough- missing.
Thus the Defendant alleges that Joan M. Mills did not personally indorse Note,
nor was her signature authenticated by a legal notary, thus rendering said document as
fraudulent.
Moreover, since these endorsements only appeared on the note when the second
complaint was filed, Defendant knows and affirms that these documents have been
mishandled and completely falsified to make the Plaintiffs case.
The chain of custody of this Note and Mortgage is of a fraudulent nature and as
such, Plaintiffs Complaint should be dismissed.

AS AND FOR FORTH AFFIRMATIVE DEFENSE (SECURITAZATION)

The Plaintiff references in its complaint how the note and its security came to be
in their possession. Within that description, the note was transferred, sold, assigned, and
who knows what else, in order for it to land in the Plaintiffs lap. Defendant is interested
to know, how a simple note executed between the original parties, became this trust with
mortgage-backed pass through certificates. Upon research, Defendant came across the
answer- Securitization.
First, securitization involves the rapid transfer (as per the Plaintiff, Transfer or
SALE) of loans through a chain of parties. Second, the entity that ultimately holds the
loan works through a number of agents, each with different roles and responsibilities. The
failure of any or all of these parties to uphold their legal obligations creates chaos in
maintaining the record title to real property essential to homeownership.
This practice is in violation of numerous laws. Property law requires recording
these sales publically. Notes must be affixed (permanently) to the security instrument a
mortgage without the note has been ruled a nullity by the Supreme Court. MERSs
recommended business practice (with the servicer retaining the note) would make the
mortgages a nullity. Therefore, a complete chain of title is required to foreclose on
property every sale of a mortgage must be endorsed over to the purchaser, and properly
recorded. Without this, it is illegal to foreclose on property no matter how many
payments the Defendant has missed.
However, if the notes can be found and if MERS, FFF, HSBC or Wells Fargo can
provide records, it is possible that the mortgages can be made valid, for purposes of
collecting upon the indebtedness, but, again- foreclosure would not be possible without a
valid continuous perfected mortgage showing a chain of title from origination through to
the current party trying to enforce the mortgage note. Any break in the chain of
endorsements along with any break in the chain of title renders the Power of Sale clause
in the security instrument to be a nullity and therefore no party can foreclose on the real
property.
So long as there is no fraud affecting the mortgage note, then rights to enforce the
indebtedness can be further negotiated. If there is no break in the chain, when fraud is
shown affecting the security instrument (such as robo-signers), this does not affect the
rights to enforce the mortgage note but such fraud will affect the validity of the security
instrument perhaps making foreclosure impossible. Fraud affecting the mortgage note
would affect the right to foreclose.
If the note cannot be found and a Lost Note Affidavit can not reestablish the
indebtedness, then foreclosure is not possible and collecting of the indebtedness is also
not possible.
However since the mortgage-backed securities are governed by PSAs (pooling
and service agreements), the practices above make the securities unsecured debt and there
is no solution. The securities are no good. (This would be a Representation & Warrant
violation as the MBSs stated that a secured indebtedness was to be purchased, but since
the Trustees of the securitization would not have the notes, the securities cannot be
secured.).
In furtherance of Plaintiffs creation and maintenance of mortgage backed
securities the bundling and packaging of mortgage loans into investment vehicles
Defendant maintains, Plaintiff has filed,
(a) Falsified, forged, and/or fraudulently executed mortgage-related
documents through a practice called robo-signing; and
(b) Mortgages and deeds of trust assigned to a private registry called
MERS, that Defendants created for the express purposes of hastening
their securitization deals and avoiding the costs of maintaining accurate
and publicly recorded real estate documents regarding transfer and
assignment of mortgages.
Plaintiff systematically created the falsified, forged and/or fraudulently executed
mortgage documents filed with the Suffolk County Clerks Office by what infamously has
become known as robo-signing, which is the practice of signing mortgage assignments,
satisfactions and other mortgage-related documents in assembly-line fashion, often with a
name other than the affiants own, and swearing to personal knowledge of facts of which
the affiant has no knowledge.
Plaintiffs scheme, that failed to disclose and track ownership in mortgages
accurately, was manifested in a private electronic registry many of the Defendants
created called the Mortgage Electronic Registration System (MERS). Through MERS,
Plaintiff disrupted citizens fundamental right to determine through public searches who
holds interests in property.
AS AND FOR DEFENDANTS FIRST COUNTERCLAIM
CONFLICT OF INTEREST

In a foreclosure action of the same caption, to enforce the same mortgage debt,
under index # 09 49728 and filed with the Suffolk County Clerk on December 18,
2009, twelve days subsequent, on December 7
th
, 2009 the assignor, Elpiniki M.
Bechakas, a known employee of one Steven J. Baum, Esq. plaintiff's counsel, Steven J.
Baum, P.C., commenced the instant action on behalf of assignee HSBC BANK USA
NATIONAL ASSOCIATION AS TRUSTEE FOR WELLS FARGO ASSET BACKED
SECURITIES CORPORATION MORTGAGE ASSET-BACKED PASS-THROUGH
CERTIFICATED SERIES 2007-PA1, with the filing of a notice of pendency, and the
summons and complaint in the Suffolk County Clerk's Office. The Defendant is
concerned that the apparent simultaneous representation of Steven J. Baum, P.C. for both
MERS and HSBC BANK USA NATIONAL ASSOCIATION AS TRUSTEE FOR
WELLS FARGO ASSET BACKED SECURITIES CORPORATION MORTGAGE
ASSET-BACKED PASS-THROUGH CERTIFICATED SERIES 2007-PA1could be
deemed a conflict of interest in violation of 22 NYCRR 1200.24, the Disciplinary Rule
of the Code of Professional Responsibility, entitled "Conflict of Interest; Simultaneous
Representation."
All residential mortgage foreclosure actions require an affirmation from the
attorney representing the Plaintiff, as stated in the affirmation attached to this order, that
he/she has inspected all documents. The Plaintiff is also required to provide an affidavit
of regularity/merit from the Plaintiff representative that he/she has reviewed the file in
this case and that he/she documents that all paperwork is correct. The Plaintiffs
representative shall also provide in said affidavit of regularity her/his position, length of
service, training, educational background and a listing of the documents and financial
records reviewed substantiating the review of the amounts owed. The affidavit should
also include that she/he has personally reviewed both the mortgage and the note and any
assignments for accuracy.
The Plaintiff bears the burden of proof in a summary judgment proceeding
and judgment will only be awarded when all doubt is removed as to the existence of any
triable issue of fact. Under the present circumstances, where there have been numerous
instances of alleged conflicts of interest regarding these documents and a failure to attest
to the accuracy of documents in mortgage foreclosure proceedings, the Plaintiff must
prove its entitlement to foreclose on mortgage as a matter of law by establishing the
regularity and accuracy of the financial documentary evidence submitted and the court
should be scrutinizing all documents for accuracy.
In this instance, the assignor, Elpiniki M. Bechakas attesting to all of the
facts within the Plaintiffs assignment, is the employee of a well-known alleged felon,
and dis-barred attorney, one, Steven J. Baum, Esq.
Plaintiffs systematic schemes have confused, misled, and deceived Defendant,
numerous borrowers, homeowners, and other citizens who relied on the validity of the
Plaintiffs actions.




AS AND FOR DEFENDANTS SECOND COUNTERCLAIM FRAUD

It is well known and publicized that Plaintiff, WELLS FARGO, has many
pending federal lawsuits for preparing, executing, notarizing and presenting false and
misleading documents, the most current brought before New Yorks Southern District
Court in a bankruptcy proceeding, claims assert that Plaintiff WELLS FARGO has
instituted internal procedures to fabricate foreclosure papers on demand exposing the
existence of a Wells Fargo Foreclosure Attorney Procedures Manual created November
9
th
, 2011 and updated February 24
th
, 2013 whereas the Manual details procedure for
processing [mortgage] notes without endorsements and obtaining endorsements and
allonges
Regarding the within instant action, an endorsed, altered and fabricated copy of
the underlying note had appeared in the action, attached thereto as exhibit, even though
the properly endorsed note was not included in the prior foreclosure filing under index
# 09 49728. In that previous filing, the accompanying note was endorsed in blank.
Now, miraculously, the same note appears now properly endorsed.
(Please see Exhibits B and C).
To legally transfer a securitized loan, the endorsements and allonges have to be created in
a very specific way and within a specific time frame.
This loan in foreclosure now, which was originated years ago and then sold, it is way too
late to correct incomplete documents.
It is the Defendants position, that Plaintiff fraudulently ordered the note to be endorsed
now just in order to prosecute the foreclosure, that the act is fraudulent in nature, and as
such, the instant action should be dismissed with prejudice.


WHEREFORE , the defendant demands judgment against the Plaintiff for the
following relief :

Due to the legal, and procedural defects in this foreclosure action;

A. Dismissing the Plaintiffs Complaint in all respects, with prejudice, and

B. Granting to the Defendant such further relief as to this Court may seem

Just and proper, together with the legal costs and disbursements of this action.


Dated March __ 2014



__________________________ _______________________
xxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxx
Defendant, Pro Se Defendant, Pro Se



To :
Laura M. Strauss, Esq.
Attorneys for Plaintiff
Gross Polowy Orlans, LLC
25 Northpoint Parkway, Suite 25
Amherst, NY 14228


















INDIVIDUAL VERIFICATION



STATE OF ______________)
:ss
COUNTY OF ____________)


xxxxxxxxxxxxxxxx, being duly sworn, deposes and states that deponent is

a defendant in the fore mentioned action individually ;

that deponent has read The foregoing VERIFIED ANSWER and knows the

contents thereof ;

and that the same is true to the deponents own knowledge, except as to

the matters therein stated to be alleged on information and belief, and that

as to those matters, deponent believes them to be true.



___________________________ ,
xxxxxxxxxxxxxxxxxxxxxx
Defendant, Pro Se



Sworn to, before me

This _____ day of March 2014


_________________________________
NOTARY PUBLIC







INDIVIDUAL VERIFICATION



STATE OF ______________)
:ss
COUNTY OF ____________)


xxxxxxxxxxxxxxxx, being duly sworn, deposes and states that deponent is

a defendant in the fore mentioned action individually ;

that deponent has read The foregoing VERIFIED ANSWER and knows the

contents thereof ;

and that the same is true to the deponents own knowledge, except as to

the matters therein stated to be alleged on information and belief, and that

as to those matters, deponent believes them to be true.



___________________________ ,
xxxxxxxxxxxxxxxxxxxxx
Defendant, Pro Se



Sworn to, before me

This _____ day of March 2014


_________________________________
NOTARY PUBLIC

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