IN THE FAIRFIELD COUNTY COURT OF COMMON PLEAS

CIVIL DIVISION

N ANN PIWINSKI CASE NO

1470 Mill Park Drive
Marysville Ohio 43040 JUDGE

Plaintiff

V CIVIL COMPLAINT

WELLS FARGO BANK NA

o Csc Lawyers Incorporating Service
c JURY DEMAND ENDORSED HEREON
50 West Broad Street
Columbus Ohio 43215

AND

CHINA BROWN
o Wells Fargo Bank N
c A
3476 Stateview Blvd
Fort Mill South Carolina 29715

Defendants

This civil complaint concerns Defendant Wells Fargo Bank NA

s and China Brown
s

Defendants attempts to deceive this Court and Plaintiff N Ann Piwinski Plaintiff into

entering a default judgment granting foreclosure in favor of Defendants and against Plaintiff in

Fairfield County Case No

2007 CV 00952

Now comes Plaintiff and for her complaint against Defendants states as follows

Parties

1 Plaintiff is a resident of Union County Ohio She formerly resided at 1928 Wind River

Drive Lancaster Ohio 43130 the Property

2 Defendant Wells Fargo is headquartered at 3476 Stateview Blvd Fort Mill South

Carolina 29715

1
3 Defendant China Brown is and was a Vice President of Loan Documentation employed
by Defendant Wells Fargo

Jurisdiction and Venue

4 Defendant
s conduct occurred in Fairfield County Ohio and is in violation of Ohio
s

Consumer Sales Practices Act CSPA C

R 1345 Ohio
s baby RICO statute Baby
RICO C
R 32 and the common law
2923

5 Jurisdiction over this matter lies within this Court pursuant to R

C 04 R
1345 C

34 and the common law

2932

6 This Court has venue to hear this matter pursuant to Civ R 3

B because Defendant
s

conduct which gave rise to Plaintiff

s prayer for relief in Fairfield County Ohio

7 The state court of common pleas has original jurisdiction over this matter as the conduct

which gave rise to Plaintiff

s prayer for relief occurred as a result of Defendant
s filing of

a foreclosure lawsuit in Fairfield County Ohio

Factual Background

8 On or about January 19 2004 Plaintiff executed a mortgage loan with respect to the

residential real estate located at 1928 Wind River Drive Lancaster Ohio 43130 the

Property evidenced by a promissory note and a mortgage in favor of Dominion Homes

Financial Services Ltd

9 On August 6 2007 Defendant filed a complaint for foreclosure in the Fairfield County

Court of Common Pleas seeking judgment against Plaintiff and foreclosure of the

Property the Foreclosure Action The Foreclosure Action bore case no 2007 CV

00952 A copy of the complaint in the Foreclosure Action with the note and mortgage is
attached hereto as Exhibit A

2
10 In the complaint in the Foreclosure Action Wells Fargo claimed it was the holder and
owner of the note Upon information and belief this statement was blatantly false and

was known by Wells Fargo to be false at the time the complaint was drafted in that Wells

Fargo was not the owner of the note

11 Plaintiff did not file an answer to the foreclosure complaint

12 On November 15 2007 Wells Fargo filed a motion for default judgment against Plaintiff

The motion for default judgment is attached hereto as Exhibit B

13 On November 20 2007 Defendants caused to be filed an Affidavit of Status of Account

and Military Affidavit the Affidavit A copy of the Affidavit is attached hereto as

Exhibit C

14 In the Affidavit Defendants stated

1 Affiant is a Vice President of Loan Documentation with Wells Fargo Bank

A
N In this job position affiant has the custody of and has personal
knowledge of the accounts of said company and specifically with the
account of PLAINTIFF defendant herein
2 Affiant states that this said account is in default and that plaintiff has
elected to call the entire balance of said account due and payable in
accordance with the terms of the note and mortgage attached to the
Complaint
3 Affiant states that there is due on said account a principal balance of
18 together with interest thereon
903
194

15 On November 20 2007 based upon Defendants fraudulent complaint and the Affidavit

the Court granted Wells Fargo

s default judgment and issued a Finding and Decree in
Foreclosure

16 It is well documented that for years Wells Fargo has used socalled robosigners in its

mortgage servicing division to expedite foreclosures Robo signers are individuals

whose sole job responsibility is to sign affidavits assignments of mortgage and other

3
 legal documents used in foreclosures en masse so that homeowners can be removed from

their homes by banks as quickly and cheaply as possible As a result of Wells Fargo
s

use of robosigners the Ohio Attorney General has launched an investigation into its

practices See article from Bloomberg News attached hereto as Exhibit D

17 Because they are required to sign so many documents in order to effectuate cost savings

for the banks robo signers do not even read the documents containing critical statements

necessary to grease the wheels of their foreclosure mills The typical robosigner simply

attests under oath that he or she has personal knowledge of the statements made and

swears that those statements are true and accurate without even having read the
document In addition in the rush to generate these documents the robo signer will

generally sign the document outside the presence of a notary public who later notarizes
them

18 The above practices fail to comport with legal requirements thereby rendering the
documents fraudulent and invalid

19 China Brown is and was at all relevant times employed and controlled by Wells Fargo

China Brown is and was a robo signer

20 Based upon the foregoing Plaintiff has reason to believe and does believe that the

Affidavit contained material false and fraudulent statements in that

a China Brown did not have custody of the documents she referred to in the

Affidavit

b The records and accounts referred to were not compiled by Wells Fargo at or near

the time of occurrence of the events referenced

4
 c The records were not kept by Wells Fargo in the course of its regularly conducted

business

d It is not the regular practice of Wells Fargo to keep such records

e China Brown had no personal knowledge of any of the facts she attested to

f Wells Fargo was not the holder of the note and mortgage as it claimed and

g Wells Fargo was not entitled to foreclose on the Property

21 By giving China Brown the title of Vice President of Loan Documentation Wells

Fargo meant to mislead the Court in the above noted foreclosure action and Plaintiff into

believing she was a person with the knowledge and authority to make the statements she

did in the Affidavit and thus not question the validity of it

22 Defendants statements that they were the holder of the note and mortgage were false

and were meant to mislead the Court and the Plaintiff into believing Wells Fargo had the

right to foreclose

23 Based upon the Affidavit and the false allegations in the complaint in the Foreclosure

Action the Court granted Wells Fargo

s motion for default judgment

24 The entire Foreclosure Action noted was contaminated by the fraud of Wells Fargo and

China Brown As a result of that fraud Wells Fargo was permitted under color of law

to take the Property away from Plaintiff

Count I Declaratory Judgment

25 Plaintiff incorporates the foregoing paragraphs herein by reference

26 A justiciable controversy exists with respect to the following issues involved herein

a Whether Wells Fargo was the holder and owner of the note and mortgage and thus

was entitled to foreclose on the Property and

5
 b Whether the Affidavit was executed in accordance with the law and thus whether

it was valid and could be considered by the Court in the Foreclosure Action

27 It is necessary that this Court determine these issues and declare the rights of the Parties

herein

28 Should this Court determine either that Wells Fargo was not the holder and owner of the

note and mortgage or that the Affidavit was not executed in accordance with the law

then this Court should declare the entire Foreclosure Action null and void and should set

aside the default judgment entered against Plaintiff

Count II Violation of The Ohio Consumer Sales Practices Act

29 Plaintiff incorporates the foregoing paragraphs herein by reference

30 Defendant Wells Fargo has engaged in a pattern and practice of unfair deceptive and

unconscionable acts in violation of R

C 02 1345
1345 03 andor 1345
031 by

authorizing and directing the filing of the Affidavit that was false and by proceeding to

pursue a foreclosure action against Plaintiff in spite of the Affidavit that was false

31 Defendant China Brown has engaged in a pattern and practice of unfair deceptive and

unconscionable acts in violation of R

C 02 1345
1345 03 and
or 1345
031 by

executing and causing the filing of the Affidavit that was false

32 Such acts and practices have been previously determined by a court in Ohio to violate the

Consumer Sales Practices Act R

C 01 et seq
1345 Defendants committed said

violation after such decisions were available for public inspection pursuant to R
C

3
A
05
1345

33 As a direct and proximate result of Defendants conduct as described herein Plaintiff has

been damaged in an amount in excess of 25

00
000
6
 Count III Common Law Fraud

34 Plaintiff incorporates the foregoing paragraphs herein by reference

35 China Brown signed the Affidavit a which contained representations b which were
material to the foreclosure proceedings c which were made with knowledge of their

falsity and with utter disregard for whether they were true of false d which were made
with the intent of misleading this Court and opposing parties into relying upon them and

e on which this Court and Plaintiffjustifiably relied

36 Through its agent China Brown and perhaps others Wells Fargo a made representations
with respect to its foreclosure case against Plaintiff b which were material to that
foreclosure proceeding c which were made with knowledge of their falsity or with utter

disregard for whether they were true or false d which were made with the intent of
misleading this Court and others into relying upon them and e on which this Court and

the opposing parties justifiably relied

37 Asa direct and proximate result of Defendants conduct as described herein Plaintiff has

been damaged in an amount in excess of 25

00
000
Count IV Abuse of Process

38 Plaintiff incorporates the foregoing paragraphs herein by reference

39 In filing the Foreclosure Action against Plaintiff Defendants set in motion a legal

proceeding within a purported proper forum and with probable cause

40 Defendants actions as described herein in relation to the Foreclosure Action against

Plaintiff have perverted the proceeding in order to accomplish an ulterior purpose for
which the proceeding was not designed

7
41 As a direct and proximate result of Defendants conduct as described herein Plaintiff has

been damaged in an amount in excess of 25

00
000

Count V Civil Conspiracy

42 Plaintiff incorporates the foregoing paragraphs herein by reference

43 Defendants engaged in a malicious combination involving at least two people or entities

44 Defendants malicious combination caused injury to Plaintiff

45 There exists an unlawful act independent from the conspiracy itself

46 As a direct and proximate result of Defendants conduct as described herein Plaintiff has

been damaged in an amount in excess of 25

00
000

Count VI Violation of Ohio

s Baby RICO Statute

47 Plaintiff incorporates the foregoing paragraphs herein by reference

48 Wells Fargo and China Brown acted in violation of Baby RICO by engaging in and

participating in Plaintiff
s affairs through a pattern of corrupt activity and collection of
unlawful debt

49 As a direct and proximate result of Defendants conduct as described herein Plaintiff has

been damaged in an amount in excess of 25

00
000

Prayer for Relief

WHEREFORE Plaintiff demands judgment against Defendants as follows

a For compensatory damages in excess of 25

00
000

b For punitive damages in an amount to be determined at trial

c A civil penalty of not less than 25

00 for each separate and appropriate violation
000
described herein and pursuant to C
R D
07
1345

d For reasonable and

or statutory attorney
s fees
8
 e For an order finding that Defendants are jointly and severally liable for all monetary
amounts awarded and

f For any other relief this Court deems appropriate

Respectfully submitted

THE SHERROD LAW FIRM LLC

O
eo 0440
339
614
0515 fax
416
614
sherrodlaw
a
iohn
net
00785
ure Drive Ste B1
ublin Ohio 43017

Attorney for Plaintiff

Jury Demand

Plaintiff demands a trial by jury

J She

Instruc ions for Service

To the Clerk please deliver a copy of the summons and complaint via certified mail
each named defendant at abItiv above tion
return receipt requested to
jthe dreyqioted

J Sherrod

9
EXHIBIT A
 FAIRFIELD COUNTY OHIO
EY
iRi i
f Case No
AQ
F
Wells Fargo Bank NA
3476 Stateview Boulevard
Fort Mill SC 29715 Mac 7801 013 i 07 CV 952
Plaintiff COMPLAINT IN FORECLOSURE

vs
With Notice Under the Fair
Debt Collection Practices Act
Nicole Piwinski
1470 Mill Park Drive
Permanent Parcel No
Marysville OH 43040
1053 22927 00
John Doe name unknown spouse
of Nicole Piwinski
i
1470 Mill Park

Marysville OH 43040

Jane Doe name unknown Occupant

1928 Wind River Drive
Lancaster OH 43130
i

Defendants

NOTICE

The Summons attached to this Complaint advises of

you

certain of your rights under state law for to this

responding

Complaint Among these rights is your right to serve your

Answer upon Lerner Sampson Rothfuss within twenty eight 28

days If your name appears in numbered paragraph 1 below you

have additional rights under federal law to request certain

information from Lerner Sampson Rothfuss within thirty 30

I VII NII IIIqII NI N Nll llll IIII IIIII I IIIIIN IN

LSR200731851D157P1300C9
 The federal Fair Debt Collection Practices Act requires

that Lerner Sampson Rothfuss provide you with the following

information The amount of the debt as of July 26 2007 is

09
678
206 This amount is made up of your principal balance

interest late charges and amounts expended by the creditor

such as for taxes and insurance Because many of these items

vary from day to day the amount due on the day you pay will be

greater Hence if you pay the amount shown above an

adjustment will be necessary after we receive your check

The creditor to whom the debt is owed is the plaintiff

listed above Unless within thirty 30 days of your receipt

of this Notice notify Lerner Sampson Rothfuss that you

you

the validity of this debt or portion of it Lerner

dispute any

Rothfuss will assume the debt is valid Lerner

Sampson

Rothfuss is a debt collector This is an attempt to

Sampson

collect and information obtained will be used for

a debt any

that purpose

If you notify Lerner Sampson Rothfuss in writing within

thirty 30 days of the receipt of this Notice that the debt or

thereof is disputed Lerner Sampson Rothfuss will
any portion

of the debt and will mail a copy of that

obtain a verification

verification to you If the creditor named as plaintiff above

2
receipt of this notice Lerner Sampson Rothfuss will provide

you with the name and address of the original creditor

COMPLAINT

COUNT ONE

1 Plaintiff is the holder and owner of a note a copy of

which is attached hereto as Exhibit A By reason of default

under the terms of the note and the mortgage securing same

evidenced said note due and

plaintiff has declared the debt by

there is due thereon from the defendant Nicole Piwinski

with interest at the rate of 5000

5 per
18
903
194 together

court costs advances and other

year from October 1 2006 plus

charges as allowed by law

further that the defendant Nicole

2 Plaintiff says

Piwinski is immune from personal liability on said note by

virtue of Bankruptcy Case No 07 50520 United States Bankruptcy

Court Southern District of Ohio Eastern Division

COUNT TWO

the allegations of Count One and

3 Plaintiff incorporates

it is the holder of a mortgage a copy of

further states that

which is attached hereto as Exhibit B The mortgage was given

of the above described note and said mortgage

to secure payment

3
 2004 in
4 The mortgage was filed for record on January 23

the s
recorder records it was
Volume 1325 Page 3154 of county

to the plaintiff herein The conditions of

subsequently assigned

contained therein have been broken plaintiff has

defeasance

complied with all conditions precedent and plaintiff is entitled

to have said mortgage foreclosed

5 Plaintiff says that the defendant John Doe name

unknown spouse of Nicole Piwinski may claim an interest in the

as the current spouse of the defendant
subject property

Nicole Piwinski Plaintiff states that it cannot

titleholder

currently discover the real name of said defendant

6 Plaintiff says that the defendant Jane Doe name

unknown Occupant may claim an interest in the subject property

Plaintiff states that it cannot
as the current occupant

currently discover the real name of said defendant

for a finding of default There
WHEREFORE plaintiff prays

is due 18
903
194 together with interest at the rate of 5
5000
court costs advances and
per year from October 1 2006 plus

mortgage be
other charges as allowed by law that s
plaintiff

adjudged a valid first lien upon the real estate described herein
and that said mortgage be foreclosed that said real property be

out of the proceeds of

ordered sold and that plaintiff be paid

4
required to set up their liens or interests in said real estate or
be forever barred from asserting same
r

Lorelei o ohan Trial Counsel

Ohio Su
reme Court Reg 0081839
LERNER SAMPSON ROTHFUSS
NA
Attorneys for Wells Fargo Bank
O
P Box 5480
Cincinnati OH 45201 5480
513 241 3100
513 241 4094
Fax
com
attyemail@lsrlaw

5
 Nicole Piwinski
1470 Mill Park Drive
d
Marysville OH 43040

John Doe name unknown spouse of Nicole Piwinski

1470 Mill Park

Marysville OH 43040

Jane Doe name unknown Occupant

1928 Wind River Drive
Lancaster OH 43130

WRITTEN REQUEST FOR PERSONAL SERVICE BY THE SHERIFF OF FAIRFIELD

COUNTY OHIO ON THE FOLLOWING NAMED DEFENDANT
S

Jane Doe name unknown Occupant

1928 Wind River Drive
Lancaster OH 43130p

Certified Article Number

Certified Article Numbe
7160 3901 9849 8281 9106
7160 3901 9849 6281 9120
D

2007
SENDERS SEN
CV 00952
MMMMMEA
2007 CV 00952
O D
P000 0458 74
P000 0458 72

JANE DOE NAME UNKNOWN OCC

NICOLE PIWINSKI OCCUPANT
1470 MILL PARK DR 1928 WIND RIVER DR
MARYSVILLE OH 43040 LANCASTER OH 43130

Certifi Article Numbe

7160 3901 9849 8281 9113
2007 CV 00952 SENDERS RECORD J
L
P000 0458 73

JOHN DOE NAME UNKNOWN SPO

SPOUSE OF NICOLE PIWINSKI
1470 MILL PARK
MARYSVILLE OH 43040

6
 v
U

January 19th 2004 DUBLIN OHIO

tDatc city State

1928 WIND RIVER DRIVE LANCASTER OHIO 43130

rty Address
tProp

1 PARTIES

Borrower means each person signing at the end of this Note aid the person
s successors and assigns Lender
means DOMINION HOMES FINANCIAL SERVICES LTD
and its successors and assigns

2 S PROMISE TO PAY INTEREST

BORROWER
In return for a loan received from Lender Borrower promises to pay the principal stun of Two Hundred Two
Thousand Six Hundred Ninety Seven Dollars
U 00
697
202
plus interest to the order of Lender Interest will be charged on unpaid principal from
the date of disbursement of the loan proceeds by Lender at the rate of Five and one half
500
5
percent per year until the full amount of principal has been paid
3 PROMISE TO PAY SECURED

s promise to pay is secured by a mortgage deed of trust or similar security instrument that is dated the
Borrower
same date as this Note and called the Security Instrument The Security Instrument protects the Lender from losses
which might result if Borrower defaults under this Note

4 MANNER OF PAYMENT
A Time
Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on
March 1st 2004 2034
Any principal and interest retraining on the first day of February
will be due on that date which is called the Maturity Date
B Place
Payment shall be nude at 5000 TUTTLE CROSSING BLVD DUBLIN OR 43016 5555
or at such place as Lender may designate in writing by notice to Borrower
C Amount
Each monthly payment of principal and interest will be in the amount of U
S 150
1
90 This amount will
be part of a larger monthly payment required by the Security Instrument that shall be applied to principal interest and
odreT items in the order described in the Security Instrument
D Allonge to this Note for Payment Adjustments
If an allonge providing for payment adjustments is executed by Borrower together with this Note the covenants of
the allonge shall be incorporated into and shall amend and supplement die covenants of this Note as if the allonge were a
part of this Note Check applicable boxj

Graduated Payment Alionge Otlier specify

Growing Equity Allonge
S S RIGHT TO PREPAY
BORROWER
Borrower has the right to pay the debt evidenced by this Note in whole or in pan without charge or penalty on the
first day of any month Lender shall accept prepayment on other days provided that Borrower pays interest on the
amount prepaid for the remainder of die month to the extent required by lender and permitted by rebvlatiors of the
Secretary If Borrower makes a partial prepayment there will be no changes in the due date or in the amount of the
monthly payment unless tender agrees in writing to those changes

b S FAILURE TO PAY
BORROWER
A Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument as described in Paragraph
C of this Note by the end of Fifteen
4 calendar days after die payment is due Lender may collect
a charge in the amount
late of Four percent 000
4 of the overdue
amount of each payment
B Default
If Borrower defaults by failing to pay in full any monthly payment then Lender may except as limited by
regulations of the Secretary in the case of payment defaults require immediate payment in full of die principal balance
retraining due and all accrued interest Lender may choose not to exercise this option without waiving its rights in die

initials
FHA Multistate Ratc Note 12195
AAFNIG 091424101 Pap I of 2 w m
MortSageBaokinxSystvwsx
 L3evetopment or nts ar ncr ucsigucc
C Payment of Costs and Expenses
If Lender has required immediate payment in full as described above Lender may require Borrower ut pay costs
and expenses including reasonable and customary attorneys fees for enforcing this Note to the extent not prohibited by
applicable law Such fm and costs shall bear interest from the date of disbursement at the same rate as die principal of
this Note

7 WAIVERS
Borrower and any odic person who has obligations under this Note waive the rights of presentment and notice of
dishonor Presentiment menus the right to require Lender to demand payment of amounts due Notice of dishonor
means the right to require Lender to give notice to other persons that amounts due have not been paid
8 GIVING OF NOTICES
Unless applicable law requires a different method any notice that must be given to Borrower under dais Note will be
given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different
address if Borrower has given Lender a notice of Borrower
s different address
Any notice that must be given to Lender under this Note will be given by first class snail to Lender at the address
stated in Paragraph 4
B or at a different address if Borrower is given a notice of that different address
9 OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note each person if fully and personally obligated to keep all of the promises
nude in this Note including the promise to pay the full amount owed Any person who is a guarantor surety or
endorser of this Note is also obligated to do these things Any person who takes over these obligations including the
obligations of a guarantor surety or endorser of this Note is also obligated to keep all of the promises made in this
Note Lender may enforce its rights under this Note against each person individually or against all signatories together
Any one person sighting this Note may be required to pay all of the amounts owed under this Note

the in this Note

BY SIGNING BELOW Borrower accepts
and agrees to terns
anal covenants
Contained
Ul Seal
Burrower
NICOLE PIWINSKI

Seal
Borrower

PAY TO THE ORDER OF

AMERICAN BROKERS CONDUIT mil
Borrower

WITHOUT RECOURSE
DOMINION HONES rINANCIAL Seal
SERVICES LTD Borrower

SY BR C OR
Seel
TS VICE RESIDENT OPERATIONS Borrower

Seal
o TH80 Borrower
O
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m
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tr may at or tiara talks and hold Mwom A Baetmw lama to as appeproe
LA amours am w ereaed
Ra t Bc tua Satltment
OMMM t under the
the medamsm amount in stay be mp d for BcarmWs arrow
Procedaret Act of 1974
12 U c Section 2601 W and ImpluMM
W ate U CPA Pact 35M as
fact de tatddoa or axave pardtad by RBSPA
I may in aaeroded boa tint b 4mv CRBSPA
par wanviupwil ddrtraements or befits tba Bonoms
t paytwo aaa available is We aocoyd
may not a beard ern award fee for tlia Mart w tnataamx P am
if the mourn bald by Imakr Aw 6aaaw tteau estsmd uba aaouma pmmkW w be herd by RPSPA
Lander till atxoattt oo Bdrrntva for the tr am irads n twgttk by RUpA li da amoums of Toads hdd by
Corder a any tin am 5 sufficiest to pay dte Facrmr me vben doe ends may oodfy the Btxruwer oral
ralcim xrowar to Rahn al the iar S as pwmRW by RSSPA
nn ibdatow Punch Rao pk
4td as addidotta MM for art numb t wed by dale Swanty 10072 or If
8orraWrr codas to I ender the full payrma of aB such soma Buatoploc aCCOaat AW Ix a dad with dw
tsm red OMM foe all htspibaeat k a b and a and any eertpV 6001 premiam inaWiaaeyt
ba
tat Leader has not becum obliptad tO PY M the Seer and LenSer dwD pcmgdy see add Roy arenas
Amdc in BCMWer IUND
dy prior to a fandosae calm of iha Property Of its acquiaitlan by L
eoft
hh Reenact AW ba oeduod w11h nay WNW MWNWM AN ON iydailmaabs ix Ina W b and c
trawna
3 Appliftil or PATreaaac All psymrna Ueda p
trapnpha I and 2 tall be applied by Lmdae u
allows
FL to tdra wapp bovow Ii to be paid by I
eada to tie Swm
M or to the mm durtt by
dm S
ewn taller of a mnalhly s ortt
sio imeaanoa Puma w
DL as toy UM4 go aaedaatt
A uis lasaboid paymaala ar Pond rats Said W good add Ober
rd iaeo
11 Raea premlaas as mwirb
UJIL to wicicat dw aft the Nw
Bagh b smotdsg6onof die pdeopd of the NOW and
a to late chatsw due tmdtx the Nam
4 prim Hand sM OWr Board Iynraaee iutrower died tasm RB improreeetts ton 164 hopemy
wIn Cho now is edlslenea or s Asegyautly axeCtad afd
bl mry bpinlede eaasaldet ad omlrgwiaa
gaw its
Rea fill which Lender regabea hwmanro TA s by wwm shall be awatasd in the 4100UM and thr the
oda that Lender tatp
p irx Bdatrfaa shalt ahO insure ai iypdvrartarr om the PtotperrY whaler Raw h
priaana ar s daa pearly aecmd afQm i by ftoda to the sarw re Woo W the 5mmutry All iasutmos
dmE be csniad whhollpagm geed by L umd Mx imamec policka n o play rtmwds shall be held by
ender red slrB iaebidr ldas Rayabk Clapaea in fA w of a
d lam 6x4 atra 0116 m Leda
in tbo a ar of loos Nowr
t awl pive Under idwaodlne no by mull Lombu may make FOLK Of fors
if da nude promptly by eMOM bads idsatstact comPayy armammd it hereby audmod and dWvvd w
maka ptrymem fbr Rrth Iona dy to Lander in icad of w Bon war dad to Under JuilQY Ali of my pan Of
dw Iefrretta pocaeds ally ba aw iad by L
ada at id oplioa aithd a to the reduction of the iodabledwo

1ddpir
O
ONaaW aTilMa rva
wNch tes fefkreod w im pengsrph 2 of clfsa9e the eowamt o au3 payeWOta Arly eftaso imm
rasce procealr
veer a4 moan mgWted to pay so oaulsodiV i4
MD n Ones ft Ntae ead Nie CM bdwam at shad be
paid to the a WMY eOitled MOM
in the cvut of orexiottme of this 9er tm
h Lmsbtum Mt or mbar center of ddo M ax pr perry that
extinstdehss tM iadsbfWriMS aU ri
a Ede sad iafesat of Bvr
ower is sad to i4rursfne puliciea is tunx duel
puss to the Ow dour
S OMAWANeY
rweradrm Msbommaaoe and p
1 mreotbM of the prv
aerty Berrawer
s Lose
dodsm L ssehsdma Borrower o QMM 0061di recd Ustks Propetry at Bomaret
p a rind
mddcax wi im zi w days ater fie asatW4 of drt Samity metfrtOM or wkWg maty drys of ashoer
Baflmsers vdacK pg
salekafr
fx u ar
mlmfsr of We solem add shall collude
ft
to oeadpy hoperdy s

OW ytar char am dare mtaociq

aaY tralell Leader ddamiea do msgaimuem will rasa sddtx hadd dp tar
8otrdv7 of mien UMMM lens dracasiouss exid which are beyoed Boren Oft ooaeMd Borrower fludi
W Ltd of my tfgemeed ammo dot Bfaamar ball mot ooWadt wave u destroy dtrbsge or
sabdodelly Marc fbo Yfdpe
V of Mow IN Ptopedy m dal Mcefe remsontbla wear and M efcepred
Lemdmt Way wpm do PMWV ife P apM is was or ahodmed Or the bam is be dtiadt Leader easy
t1h mumble mom b pod sad psastve CAM vacul of abWA Wd pmpesty Bonuvia shm11 also be in
monk it am darias dw lasm typiicsriom PrOmm Bmn tam gear or Imsxesste lakmotioa as
epmrafeM m Lemon for ladled W PtVA L seat Mid 07 son ice in tO MMho a with fix ken
uvWeuced by ft sate imta6m be not haled to mpseWeWdom coweniall Feel OxUpievy Mrsx
Y sm a prime ftddesae W des WWjty brsrr
teat ie a a ia
seboid 8osfersrsr 4e
11 OVY wMh ow
Owddsiors of the lace If BodMa a70WIn far
encase LANdel OPW to mte
ddk
Wfides
f
0 lopury do kalloid old Is title dM11 sot be
merged
f mWommstka The Pewado of soy Word or cWM Wr mammas d1rWA a comeiloeWW iv
c
W Otas w9h 07 oostasmmstio of OOK mddV of W put of the peoplay or far convo
yano in place of
cohere M hanky twilAed sad Obe paid to Leader to the eatant ee the ail aaoma of the
OLWadts fhd flows etmpdW 1mder did 14am am NkStaaadty Lmamasat ladder dad spry arch pry
To the W
Wtiam of tbo WdeMrdatwt tiler the Nam led dhds SWARY Imnreromt Putt m Ooy 61904MO amommff
mow lathe order pr dtw i pwsgrepb cord drat 10 Porme en of princlpd An epoicackm of the
proceeds to the pria
W shell mot eftemd or pompom The dw dmW of Ne MANY paymena whkB are referred
ih psagspb 2 or dttr V dw amoasr of sockpayer Any wears P11110110 FW on Mona tapuimd a
py aU ougtatidtos Wil teased men Of Nak cord tttie 9WO
emklod thetato
Y lesmmeet mball be paid to the entity legacy 90
YTS4ph of Lsadw 00b W eke Pesperq Bfnmwa ehe11 ley
T fawn a SonvWer amd
b that an mot iaehfded in pstatgsmph 2
ar eo
all P
BoWwmemW at to ddpti dvgW Gas cord dmtpmt WroaW
vdai
Pay that cib6grtIM
adreWly aftact Laadse
to dte
oa dale rBtati7

s icurvet is do Poap m upam

oiad pf w

Laodar mcaipd Viand hac pig

if Boatwrrr falls to torts dyes Pays or 6c paYmamt regtdixd
of
byttoss
aaitr
1 Z or940
aids IQ perfvtat
is legal W00901
of a Y
w
my
d is this 8wwt4Y toom r
Odw esrvan std speomfarm u hseirrV for a
1on of b
afsect Loader
s rime in fie pal eY awh 0 a l ere vibe of ft
sd wOy
sspistiom
rMpe
PrvpU
Io
ts too i
nil i New
HvprtY Wgbd t pmymT or turf Wm d i
mrafee mad ato Nsmf
ntsoaamed in 2

Any modals dW rud b7 tarmac Order W psrsYetrpi dull hseams mn sdditi

W 4M of Borman ad be
accred by is 940RWapfion
lWMMtam Tbam MwdW
sbsA bar imaresmpayable
d d adder ebsil be im
parr do doe of disbtafemarit at Ole
Nda tad end u the
Bonawer shelf V oWdy dirchrrso 01 Tim which Its priority over this Severity Imm cloaca amass
bmvN a mom iswrl
s in ode
l
eias m therMapaytttsn
filet the try mofeekab
the oblignfm
44Mrt seaWad
hN eteae by theof Ike
ed s isa
Ns tie Lnwr
Ind aoorpsl
rr
Prar de w
Loader bl tow
wbicb is Ne Lamdees aydt
opinita opalsdrama
ro paevsol fir eafofcanese of detidefiSaaehy
rm or c seat form the bolder of
Corers
teet4f u
e Lisa a 4 cmfl b lsbOlftting the ft
Leylsr
tf tie
deteerninp dot Wry Pint ofd
a
de 1 1
W 7Lktide
NgWtidrsri
a sV lie wide
fie liednayBoauwer
atTei4 priority
shill addY We lia or take ON
lemameat Ls order my
a Ware of do SAM eat tae s
ar wiNin 10 data of Nr AWW ofnotice
o
g kart Llama nay cadre an d Wrag mol
of Debt
im d by de Secretary
9 Greoulo b r Atedwe k fbe tear of
at
limited by rasmlatWms iy
e Dwbo Leads Wey erogt
s
tr
tart if
ytymmt ddmlo requite tae edim prYMOS bl Ad of on suer wont by lull SCOW
il Bosratea fle6eaW by WK topq is fall aoY Malay prjw mMimd by N o Sec
relovMemt prior to or w dw dw
of do out mn0
17 p qmm or

QHpM 11 3 riM
ri
 d of the Gzma t Camsin Doom
341 y ImOmdow Act of I4r2 12 U
C 170
13 d and with
The pfw q
w44 of the may s 4viro itnmrdua prym m in full of all tam wcixw by chit
sww Iammmmr iE
i AN or pact of the Property or x bmficW imam is a Uw owmop all or put of the
Ptnperty is aoid Of adiI V traat6rrad odor elms by devise or dm m and
1i 1 Property is sot onetrpied by dm pttrtJlmer at pmam as hle or her pdocipw residem or
the pA bur or pow dust w om the Prtrpetty bs bit or he vradit bs mri bens eppitnsd in
it aw il tai die m i emmis of tb Socteta
Y
t Igo WWWW Ir dreslmamnea amt r that woald pa ir Larder a mqK Immedlwa ysymem is
Sp hat Lsmdm does trot regpbe remelt Asymmia Lm dos Wt waive its dpbm wide temparr so
p
aabma evwMk
i Rspiatleoe of MM tleerOWT 14 MMY tutEasMM tyalatiars i
ced by the Smalry will
t L Au rumba in the ewes of pL7MM W to tegpitt taoM mle paymst is mall and
km
lb Wme if mt pdd Thlt 3wm Inmuamat doa not milka ze awdenti m or llnnclmom if rot
ptrnmftsal by mpbdm of fit SwsWy
a ftfaetp p MW hwar
L Bosawsr Setae dote if flit Scarcity ImMumm and dm Note an not
litwmiwd to be eliltic fat is arms tad am Natiomd Homanp Ad wiWo 60 dmm from tie dat
bone Lander my at im op
m4 taRtin imamdwe prtymtear in full of ap pmv arcaled by dis
St Lmowwo A w44 taa
y
V WM Of say indlafind 190 of Its Secretary dated Wb Mwt to
60 d n mo he data land dechmiap to inome d da saarity Imartuaem std lice Mott drab be
dedoed amdagive proof of W3 itty
eppas Notwigtipediap lie fatgMjW this option may sot be
i
exsrcind by Laadet wW tba tmwalitbility of um mane is solely dill to Leader
s fttl um to remit a
prewlem to the Seas
1S RebowmamL known ha a bt a be tti
tsoled if I emdttr hu tegnimd immratiaw pay mszi Ja fall
besac m of smmarm
e shone W pay w w dtta under the Noss or this Sactstity Inrttma nt Tug rig
appites cm atkr breGomm proosabg w It Wwv4 ro mimast die Saw mace Borrower dM
tmdea in a In all aolaaet cep hW t4 hemp Borrowers attaattss tamer 110aft In ft RW they are
oblip om of Bonet sw u lids SWW4 4mfltamme fotseiosmm OEM acrd trtnotmbte and araunmry
arms p rest and w m me popmfy aawlmd with a bmIosow proaedns Upon M Memed by
a tlds Samffay barumme and des abupttiomr dw it secom ales temmis In appear s if Laada cud trot
Rww
I tae jej mme aoreuer header is
in W lf era teq io
ed peo it csysrtwamenr QL
dw
jqQww
bu amspmd amemkmt attar me wmmano mmd of fatar3asms Immoudimpa witlin two YOM isomedi
pnwd
of 0 W
Wom win tsNmly aiEect t
ee priority of ft am Liman by tits
Se miry honest
11 penewrer Na ReMawd rarieanmsa My Lender 1Wt a gYStver IAtbdoe d the lift of ptYrnaet
or mod
at cad m of mw dsrim of Ib suss mmKW by dtia b Iamm pmad by Loader to my
a wcawr In warm of owtow Am cat opum to e cute
titr of the mWw Borrower or omoveet
svocawr in imtetamt Ltmder sball sat be cgdtrd to 4onwame procmdiW apieialt ml xtwmb r i0 iatt m or
mfuae 10 umamd rhea for prymms or adwndw modify NowlinfiDn of as soma mcarsd by tidy Satuuity
Wnmm by stow of My tls W made by the otipiea Bortvo or Bartowcr
s a in inwm Any
faftera cs by IMIW la 990ddM say d0m of MWOY than sot be a waiver of or pmlde the extrcimt of
Lay ripie or remedy
12 p mmm and Awbm B
W peter m d Sererd LWO4 Ca
jpter 7bt cam and
app of tlia Saaurity InMtanlplt dm11 b od end bsaatit the svcctalon sad amtipm of iaodsr and
Borrower subject so dw WMIAom of ptaapsaph Wb Btrrrawest rovamm ad Mm eball be jol t and
WNM Any Barmwar wbo eoaipta k 3emtity lasuMc a but dos trot eswe the Noce a 11 ooaipnibp
ms tatty tti ametla
this Sena h
e Same ad oomty fist portowa Wow in dtt MOM lards die
mm of Ilia Sca
tty b w m b It sot pennaaay obtipamed mo pay e wmm eeemna by this Seca
hwmm ad e toast do I
Wm std MY attar liorrateer my apses b exten modify fotbae or tub
spy ttotoauoodatiopt pith
cord io the seems of tbb Sc m
ty farnmm t or dm Nee wltbow the poeraaW
carmeoL

13 Madam AW nodoe to 1la omm provided for in cis Srsmaity trtsmantmt shall ba plum by ds5van
i or by mmilbtp it by fiat clam wt7 maa wpwwo taw t hw em of anodrer m mod 77te m ice sbaU be
roared b tb Propmty Addaem a ay atbu O
W matmv named
a dmdpsamm by adios to Mdse Any rotica to
Leader tduii be Siven by am dom malt to s addtam
tawkr I
n aW addmm Lem 8esi6rmtes by
atlas m porsowat Awry ttodee pttr Wd for is this Scarcity bsblmsmt
tail be berated w lave beat given so
Bomm or Ltndw whmm Sh m u ptovlded In ibis pmapW
14 Csrpsdmp Laws fib itis Saeaity Iasero
mm hell be povertnd by Peaenl law and dw law
of i1e rtrisdltxiau In whld else Ptapnmry is located la die eves liar my pwd im or cimw of chit SscudO

Idtids
4rAMM ra 4 t t wnw Msau
amniayiuf1el81
mascara
 16 swrw ws spy BOaowor be gk om ouAMled Copt of tM Nox and of this Sectnity
taertutaut
ILK 8mlnla2op 9ettawer INN nit Commit or permit dra pnaawte use dished mton at

mkm of say Nmtrnlaom S mes on or is the Proptsty mtoater

a trot do oar Ww Vcm do in do
de Pmopeety deg ie in viaiatioa of my Eadrttmeteaui I The gmedew two I
m
aieti rot poly tm tie Puna nit or a mo on an Monty Of Amu qmdtim of Hmmrdotte motamm that
are ley nwsdjw to be Rvwo dw tD am W etddmlal wet sad to m ammum of do fropay
emtowet dmH p00q dy Ova Leader writem notice of or hti eaiVAmN cbrim doatnd Uwmft or older
actltns by aeY fOW11111luill C lV91110101T qPW or Private party iavdvis6 de Propmty and my Hatmodotts
3ubutautoe of L
avlramnenesi Law Of Wbkb 8ttrtorta 1121 suwi kWWkdre If Bmromaa larva or x noticed
by arty foxertti me at rgmialmy adtarlty dia my naval or oam rrmdld ins of 221 Humdom
Subttaam adbod tg pre lhgmty k artery BOmwor shell Pmmptly Ub all nOcOmy mmtdiat awmi is
wcotduoc with Bcv
ramrmt Law
lt 16 Hrandom St16dMa
As mod in We paing we draw tubm daftW a astir Or husrdom
mbwmm by Embuoeaed Law and de Wowimg xtffiK Wzl p fiff ketaweae O M f4m2eble Or task
Petrotcem taodeco cook peotkWat sad barb kWU vOUdlm gdvodr ouriak wn kuhV aabwk Or
folmdkhyde and suave molorielL Al met Is this pltraerbph 16 Lt wbcmataati Lew meaee kderd
laws sad hm Of de jodasktioa w m tie Propaty is laeeeed that dare b health W a trrvh
OW mat
1
NONMFOM COYBNAPM Bonmm ass L
Ww Bucher manila red ASM as fdlowc
17 L Am Om
A04POM of Rm y M14 a nd trmta I to Lander all dha ream and
1t vemey of the Pmpaty BOnower sodas Lends or Lender
s PRO to caeca dhe teat sad reveobn sad
ba eby doma ash lust of the Pl
m w M the tent to Leader or l 0adtt s apm However prior w
stamat amoca n Bottom of BOeVwees kmO a aby Varanasi or WINSISeat m alb Slecatity bstrAm al
L
8oeawm stint ad im and n odve ad moat sad ormo es of the Property as aatmee far die bet of Isurkr sal
BMVDWOr Tbit etdpammt Of MU QONdtala AN abaokte 2nipm2mt US dot u AWS
edt for 2ddd
ot
aecmity ably
If Lawba Sim mdse of brptcli to L
9mmm t aU mar mmrived by 8 rmm doll be held by Uorraaa
as once for 0 of Lmoba Only to be appBed l2 dew root rr i r I by the Scrushy Iaemmos N Leak
At be embled so collect and modve 10 Of de reaw of die Pro trod c ach matter of the Property dWl
pay rd1 mo doe sttd V w Ismder or e
cttdet Wm OR r
I eadar wrhna Mud to de mm
L
Sommer bas mot m omm d any prior modrosent of de rose sad hat sot tad wiU nut pedotm awl a t1om
M prtvem Leader ftom nev iaiee im don terser this pa gnO 17
LtoW andl mot br tmgmiwd to etta VOL take ouMd of of mjsWa the Property before or alter glvhlB
OOdoe of Mach to Bormwa However 1
W or a jorkeiaty appdmoed rwAvw may du so at any time Cleo
is a bmcb Any mpphmm of emu dhall Dot Pm W waive MY 0
Wt Of lwdWM say Odff r19M Of mrcdy
of redder The antptmnt of mats OF the Monty shdil teetmiarle whew the debt to
aad by the Security
town mm is p23d la fall
is Fersam trs y wt 9 L
r rrgdras immedIM payout in fat herder gmrW
W pb 9
Lwades a my fereedue thta Sw mff tow row by JaMM pwssmAng tender 011110 be e111160d a Beet
atl napsum barred it pwxm the rats2det ppvW it tbte pwagroo ill fadatih bat let BMW
to emb of dale eddde am
N am f eadees bet to dU iSacwky hobvemet Is hold by ate R ry std the Rwardry rev wlrel
imr psyaaat in till rmdor Porynpi 4 tie 3eeresmry ara
eashm y ww ke tso wmmdodield Paver of 2210
prOVMW to 1 010 madly Morippt Pareciwo Act of 19 Amt 12 U
wader the Art to twoa
C Mt or op by
B
ta frrerfewre bad to roll the
a fwtacletoa tam dmjww
mmgmg
r6
Property w p idd b der Act Ned t 1e ate Pratt M a etturee
It
than tlapmive
kw
Se surmry it Illy
W eperwyt twmseMe eo
r a Loader tatter We WOURPh w

I L dam Upnm paytsut ofall mm OWNW by dos Smgity b

atgimx Lensor ball Achatr dolt
tip btsptamemt vWmg dmp to solvates tammm 0 pey my madmom oats
W Ad
m a M Pcbteee li2oarky Chia 3ocurky ItMUeeatal tAt111 Smn the 1e k balance of advmXS
made by Lanier with Otaprat to tie Prvpeny for ffie psytnea of tax atrttm
OW W t amtt Qrevown tad
m iwarmd for tie ptumdas of die Aapetty
21 Riders to thh Scomity 4atrtaaeaL If amt Or morc M
ot are o cool by Bormww mad tealyded
wSclhm WI tbir 1eoority Imtramenk dw trhvwam of tack Puri rider W be imapcmW tub std shall
mast and OR4003M tie mmmm sad armemeDts err ibis Sscarity Imaudinat a if the cide
s vosm a A nl
this Security lmn mom Kmmk appUWA bos
l
es

Ghmdomiah Rider Gm FAuity Rider o dw lsp

dri
nmm Unit DmMp ncM Rider Gradseted P ty0 t tidy

WWI
wvr
aenmaHS n1lmtr rs
rmwm
 9kcatrd dos 19th day o
f Jentadq 2004

IUW
Nicola PI21139lt
S epreDYKt

Seal
Borrower

add
lortawer

i
rSr
10900

Borrower

seal
r
ltawwww

GnaO as
STATE OF 01111 TtMAUl

Oa thin I
M M 0f P 24
00 beg me a Natty Pubic In rd for sdd
d P
a uq and Star ps4m appu
C

dw ha idm rbt aaamtd

tha f itt WMM and
utwwts W dw AN did ettanune aW mad tha am and did eipt the OX iotmtinaem sod drat
dto mm L A Eras wt and dvA
IN W17wm wMataw I bars Wtea m sat my Arad sad O i

Casa a tfid rim

t dt WApsiirtrarw
r
w
oeraau o7ar01at
 n
0 nr ar u
r
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R8CDRD IH PLAT Calm T 2

I
n1w
EXHIBIT B
200731851
COURT OF COMMON PLEAS
CO
FAIRFIELD COUNTY OHIO

NA Case No 07CV952
Wells Fargo Bank

Berens
Plaintiff Judge Richard E

vs

Nicole Piwinski et al MOTION FOR DEFAULT JUDGMENT

Defendants

Wells Bank NA and

Now comes the plaintiff Fargo

moves the Court for a Default Judgment and Decree in Foreclosure

in its favor for the relief prayed for in its Complaint on the

and John Doe name

that the defendants Nicole Piwinski
grounds

unknown spouse of Nicole Piwinski have been duly served with a

and are in default of motion
copy of the Summons and Complaint

This Motion is made pursuant to Rule 55 of the Ohio

or answer

Rules of Civil Procedure

Respectfull ub itted

Lorelei C Bolohan Trial Counsel

Ohio Supreme Court Reg 0081839
LERNER SAMPSON ROTHFUSS
O Box 5480
P
Cincinnati OH 45201 5480
513 241 3100
attyemail @lsrlaw
com

i
Nicole Piwinski
1470 Mill Park Drive
Marysville OH 43040

John Doe name unknown spouse of Nicole Piwinski

1470 Mill Park
Marysville OH 43040

Lorelei
z
r
C
k
I
ohan

i
EXHIBIT C
 COURT OF COMMON PLEAS
FAIRFIELD COUNTY OHIO LLEY

0
Case No 07CV952
Wells Fargo Bank NA

Plaintiff Judge Richard E Berens

vs
AFFIDAVIT OF STATUS OF ACCOUNT
Nicole Piwinski et al AND MILITARY AFFIDAVIT

Defendants

STATE OF South Carolina

SS

COUNTY OF York

affiant herein and being first

Now comes China Brown

duly sworn states as follows

President of Loan Documentation with

1 Affiant is a Vice

affiant has the

Wells Fargo Bank A
N In this job position

of the accounts of said

custody of and has personal knowledge

with the account of Nicole Piwinski

company and specifically

defendant herein

2 Affiant states that said account is in default and that

plaintiff has elected to call the entire balance of said account

with the terms of the note and
due and payable in accordance

mortgage attached to the Complaint

there is due on said account a
3 Affiant states that

with interest thereon

principal balance of 18
903
194 together

LSR200731851D46P
LSR200731851D46P2100C9
protect the property

4 Affiant states that none of the defendants herein are

service defined by the Servicemembers Civil

in the military as

Relief Act of 2003

China Brown
Vice President of Loan Documentation

Sworn to before me and subscribed in my presence this 15 day

of August 2007

No
4
a ry

Jennifer E Mosca
Notary Public
State of South Carolina
My Commission Expires
December 15 2015
EXHIBIT D
Wells Fargo to Be Focus of Ohio Foreclosure
Probe
By NAichac Riley and Margaret Brennan Oct 28 2010 12
36 PM E
i

A Wells Fargo bank branch stands on Market Street in San Francisco Photographer Noah
BergerBloomberg

i
fak

Oct 28 Bloomberg Ohio Attorney General Richard Cordray talks about the probe by
attorneys general in all 50 states into mortgage foreclosure practices and the disclosure by
Wells Fargo Co that it found flaws in court documents Wells Fargo the biggest U
S
home lender said it will file supplemental foreclosure affidavits to courts in about 55
000
proceedings after finding some statements did not strictly adhere to the required
procedures Cordray speaks with Margaret Brennan on Bloomberg Television
s
InBusiness Source Bloomberg

Wells Fargo Co will be a focus of an investigation into foreclosure practices Ohio

Attorney General Richard Cordray told Bloomberg Television after the lender said it found
flaws in court documents
Wells Fargo said yesterday that it would submit supplemental affidavits to courts in about
0 foreclosure proceedings after finding some statements did not strictly adhere to the
55
required procedures

These people think they can play by a different set of rules Cordray said in an interview
today on Bloomberg Television
s InBusiness with Margaret Brennan It s not just
individuals who signed flawed affidavits It
s a business model designed on fraud

Teri Schrettenbrunner a spokeswoman for San Francisco based Wells Fargo said in an e
mail that none of the paperwork problems have led to foreclosures that shouldn
t have
otherwise occurred and the problems aren
t related to the quality of loan data

We have chosen to submit supplemental affidavits out of an abundance of caution she

said We intend to be responsive to General Cordray
s inquiries and look forward to
addressing his concerns

Attorneys general in all 50 states started a probe into foreclosure practices after court
documents surfaced showing employees signed papers without ensuring their accuracy
Bank of America Corp JPMorgan Chase Co and Ally Financial Inc suspended some
foreclosure sales or evictions pending reviews Wells Fargo said in a statement yesterday
that it doesn
t intend to stop foreclosure sales

New Prong

These disclosures by Wells Fargo will now become the focus for a new prong of our ongoing
investigation Cordray said today in a statement

He called for banks to come up with a global solution to the foreclosure crisis and said
mortgage companies don
t even know what
s going on in their own shop

Cordray said he wasn

t calling for an across theboard foreclosure freeze

They should halt foreclosures in every case with fraudulent evidence Cordray told
Bloomberg
To contact the reporter on this story Michael Riley in Washington at
michaelriley @bloomberg
net