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IN THE SUPREME COURT OF OHIO

DEUTSCHE BANK NATIONAL TRUST)

COMPANY

Appellee

Kenneth S. Taylor, et al.

JUN ^ 1 Nt0

CLERK pF CQURT

AN'I'S KENN

Case No 10-0939

MOTION TO STAY EXECUTIONOF JUDGMENT. EMERGENCYINJUNCTIVE RELIEF FROMORDER OF UNLAWFUL SALE OFPROPERTY

On Appeal From the

- DISTRICT C.A.NO- 25281

URT OF APPEALS NINTH JUDICIAL

10

CION OF JUDGEMENT. EMERGENCI

Now come Defendants -Appellants Kenneth S. Taylor and

Alycia Driggins Taylor ("the Taylor's") who MOTION TO STAY EXECUTION

OF JUDGEMENT EMERGENCY INJUNCTIVE RELIEF FROM ORDER OF

UNLAWFUL SALE OF PROPERTY. Kevin Williams of Manley Deas

Kochalaski has filed an unlawful Order of Sale of Defendants property with trial

court on 06/ 01/ 2010 in the face of danger. See Exhibit (A) Kevin Williams

signature is false and a forgery this is the absolute highest level of criminal/and /or

civil fraud perpetrated to disengage the Defendants from their home in which they I

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have resided 22 years. Kevin Williams and the lawyers using his name forging his

signature should both be disbarred and immediately removed from this case and

the Prosecutor's Office in Ohio has to be made aware of these crimes. Both

attorneys involved are doing so unlawfully and both their actions step outside the

bounds of human decentness. Kevin Williams and his law firm was fully Apprised

of the Defendants Case before this high court but yet, without any regard and

respect for the court in a dogmatic arrogant fashion in the face of danger

committed this fraud, a crime in the presence of the Supreme Court of Ohio, and

this court should not only remove both lawyers from case but should introduce

them to the State of Ohio Prosecutors Office. We implore this high and powerful

Supreme Court Of Ohio to Stay the Trial Court Order of Sale filed by Plaintiffs

attorney who has never filed notice of appearance with the trial court, is using

another firm and attorney both together at the same time making these illegal filing

with the court both attorneys are operating unlawfully neither one has a legal right

to be involved in this case, both Robin Wilson and Kevin Williams have made

false declarations to this court each and every document filed in this case is

fraudulent See Exhibit ( B ) a forgery of Kevin Williams Signature by someone

from the law firm of Manley Deas Kochalksi in Columbus Ohio in a final decree

order. This crime carries a fine of 5 years in prison (18USC 1623) also Robin

Williams committed both Civil and Criminal Conspiracy See Exhibit (C) this high

court must act immediately this is a emergency The court must not let these

criminal acts by both attorneys lead to a chance that the Defendants home will be

sold at a sheriffs sale before this case is fully adjudicated. That is likely to result in

the regurgitation and disgorge of property later, causing substantial injustice too

move out of home prematurely and move back in later The court should exercise

some of its muscle and power proactively in this case. We now and for last pray

this court enter a order granting Defendants a stay of all proceedings and

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emergency injunctive relief from order of sale filedrby the missing attorney who

remain as missing in action. ^^^3 GG

Alycia Taylor- Driggins, K S. aylor [prose] / for Defendant! Appellant

Kenneth S. Taylor 8610 Hadden Road Twinsburg Ohio 44087 1-330-425-1542

katickit ,vahoo.

Memorandum In u ort

1.} Given the real estate market today and fact that most homes foreclosed upon

stand empty and unattended too the prejudice to Kenneth S. Taylor & Alycia A

Taylor Driggins - appellants being forced out of their home in which they have

resided in for 22 years is substantially greater than the interest of DBNTC, the

Trustees, which will not be moving in to the home Themselves. Given the fact the

have never shown up to protect their allege interest in the appellants home, and

their attorneys have never appeared at any hearing, and there is absolute proof

before this court of fraud, and forgery by the law firm Manley Deas, who filed this

lawsuit and forged attorney Kevin L Williams signature on documents filed with

the trial court. See exhibit (B). Moreover no one has ever seen this attorney he

must not be with this firm any longer and the firm has resorted to lies and forgery

of his name out of complete desperation and disregard for the law. Given these

circumstances the appeals court should reverse the trial court ruling. See exhibit

(E) the fact that a Lis Pendis is filed on title with Summit County Recorder's

Office See exhibit (C). And defendants have a pending Counterclaim, See exhibit

(D). And a fraudulent forged final decree order and Title search has been submitte

into trial courts records as evidence by Plaintiffs, the likelihood of a buyer is slim

to none until the result of this litigation is resolved. The Appeals Court should not

hesitate in reversal of this case, as the attorneys are ghost, and are illegally

involved in this case and have destroyed any fairness to appellants.

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2.1 Whether there exists "a substantial question" and "good cause" for a stay turns

on the applicant's "reasonable probability of succeeding on the merits and whether

the applicant will suffer irreparable injury." Books v. City of Elkhart, 239 F.3d

826, 827 (7th Cir.), cert. denied, 121 S. Ct. 2209 (2001). If either one of these

elements is established, the stay should be granted. See id. At 829 (granting stay

"although the [applicant] presents a weak case for a grant of certiorari"); see also

Deering Milliken, Inc. v. FTC, 647 F.2d 1124, 1128 (D.C. Cir.) (Existence of

"substantial" issues constitutes "good cause" that would make the court "obliged t

grant" stay), cert. denied, 439 U.S. 958 ( 1978). Both elements are present here.

3.1 There is a substantial likelihood of success on the merits of the appeal being

taken regarding this matter filed with the appeals court on March 4,2010 and

further, on the merits that Deutsche Bank National Trust Company did not have

standing to bring the foreclosure action and doing so was a fraud upon this Court

and the judge lacked jurisdiction to sign final decree order. And given the level of

fraud defendants will most likely prevail on all other Errors of Assignment.

WHEREFORE, Kenneth S. Taylor & Alycia A Taylor Driggins - appellants

respectfully requests that this Court enter an Order, on an emergency basis, to stay

Court case as it may deem necessary, just and proper.

25

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gins`=---a-=---------. --------------------------

or {Pro S&I 861/0 Hadden Road Twinsburg Ohio

44087Kenneth S. Taylor {Pro Se} 1-330-425-1542 katickit@ yahoo.com

CERTIFICATE OF SERVICE

The Defendants hereby certifies on June 15, 2010 DEFENDANTS -

APPELLANTS KENNETH S . TAYLOR AND AYLCIA DRIGGINS -

TAYLOR'S MOTION TO STAY EXECUTION OF JUDGEMENT.

EMERGENCY INiUNCTIVE RELIEF FROM ORDER OF UNLAWFUL

SALE OF PROPERTY AND MEMORANDUM IN SUPPORT was filed at

clerks office by mail and sent via ordinary mail at both address below the attorney

for Appellee.

ROBIN WILSON, THOMPSON HINE LLP 3900 KEY CENTER 127 PUBLIC

SQUARE CLEVELAND, OHIO 44114-1291 216-566-5800

KEVIN WILLIAMS, MANLEY DEAS KOCHALSKI LLC P.O. BOX 165028

C UMBUS OI^O 43216 1-614- 222-4921 ATTORNEY FOR LAINTIFFS.n f

lyca T yl r Driggi14s {prose} /s/ Ke: S^,.T,^yA ^

Ke S. Taylor {prose} 8 10 Haen Road

Twinsburg, Ohio 44087

1-330-425-1542

katickit@yahoo.com

25

LIST OF EXHIBITS

(A) Trial Court Docket Report, Actions Filed By Kevin Williams on 6/01/2010 (ORDEROF SALE DEPOSIT) IS ILLEGAL OR FORGERY OR BOTH

(B) Bl KEVIN WILLIAMS ORIGINAL SIGNATURE, DATED JULY 2, 2008B2 FORGERY OF KEVIN WILLIAMS SIGNATURE BY THE LAW FIRM OF

MANLEY DEAS KOCHALASKI LLC OF COLUMBUS OHIO.

(C) EVIDENCE OF SCHEME AND CONSPIRACY OF ATTORNEY ROBINWILSON PARTICIPATION IN BOTH A TELEPHONE CONVERSATION, AND ALETTER WRITTEN FOLLOWING THE UNLAWFUL DIRECTIVE OF JUDGE TODISPOSE OF DEFENDANTS COUNTERCLAIM.

(D) FRAUDULENT TITLE SEARCH DATED SAME DAY AS FORGERY JANUARY15 2010 AND FILED WITH FORGED SIGNATURE IN TRIAL COURT.

(E) NOTICE OF LIS PENDENCY FILED WITH RECORDERS OFFICE OF SUMMITCOUNTY, OHIO WHICH AFFECTS PROPERTY LEGAL DESCRIPTION.

NOTICE OF PENDENCY OF ACTION

(LIS PENDENS)

RECORDING REQUESTED BY -)K°AND WHEN RECORDED MAIL TO: tVepcfecE -\9Uj[Kenneth S. Taylor and Alycia A. Taylor Driggins 8610 HaddenRoad Twinsburg, Ohio 44087]

Above space for Recorder's Use

IN THE COURT OF COMMON PLEAS SUMMIT COUNNTY,OHIO

Kenneth S. Taylor and Alycia A. Taylor- Driggins We asPlaintiffs, in case No # CV-2007-11 -8364 Judge Tom ParkerVs. Notice of Pendency of Action Defendants Deutsche BankNational Trust Company, as Trustee for Certificateholders ofSoundview Home Loan Trust 2006-OPT2 Assets- BackedCertificate, Series 2006-OPT2, 5309.58 O.R.C.

Notice is given that the above -entitled action was filed in theabove court on Nov 30. 2007 by Deutsche Bank National TrustCompany. as Trustee for Certificateholders of Soundview HomeLoan Trust 2006-OPT,2 Assets-Backed Certificate, Series 2006-OPT2, Plaintiff against Kenneth S. Taylor and Alycia A. Taylor -Driggins, Defendants. The action affects a property legaldescription; as situated in the Township of Twinsburg, County of

Pg T of 202/10/2010 12:19PI II^I IIF I III IIIII IIIII^ IIII III I III IIIII II' lll 55681558

John F1 Donofrio, Summit Fiscal Officer mISC 48.00

Summit and the State of Ohio and known as being all Sub lots 281.and 282 except the Westerly 25 feet of these two lots of TwinsburgHeights Allotrnent Number 2, as shown in Plat Book 34, page 3, ofthe Summit County Records, as surveyed by James N. Connor,Registered Surveyor #4570 in June 1980, be the same more or lessbut subject to all legal highways. The mailing address is 8610Hadden Road Twinsburg Township Ohio 44087, which is aspecific real property, or an easement identified in the complaint,lawsuit, and counterclaim as the case is in this action

The property situated in the Township of Twinsburg, County ofSummit and the State of Ohio and Known as being all of Sub lots281 and 282 except Westerly 25 feet of these two lots ofTwinsburg Heights Allotment Number 2, as shown in Plat Book34, Page 3 of the Summit County Records, as surveyed by JamesN. Connor, Registered Surveyor #4570 June 1980, be the samemore or less, but subject to all legal highways, with the mailingaddress of 8610 Hadden Road Twinsb}arg Township Ohi,(y44087

Dated ^ Signature

fil

ACKNOWLEDGMENT

Subscribe and sworn to before me a Notary Public, thisday of 20(0 year_ e^^month

TERi.OPNotary Public

n and for the State of OhioMy Commission Expires

November 13, 2010

2

CO PY

FINAL JUDICIAL REPORTIssued by

CHICAGO TITLE INSURANCE COMPANY

TO: Manley Deas Kochalski LLCP. O. Box 165028

-Columbus, OH 43216-5028

REPORT NO. 7215435-21334FILE NO. 07-13965

Prepared for: Manley Deas Kochalski LLCAttorneys at LawP. O. Box 165028Columbus, OH 43216-5028

In the Case of DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THECERTIFICATEHOLDERS OF SOUNDVIEW HOME LOAN TRUST 2006-OPT2, ASSET-BACKED CERTIFICATES SERIES 2006-OPT2 v. KENNETH S. TAYLOR et al., nowpending in the County Court of Common Pleas, Summit County, Ohio, as Case No. CV 2007 118364, CHICAGO TITLE INSURANCE COMPANY after a search of the records of said SummitCounty, pertaining to the premises involved in said action since September 21, 2007, to the date

January 15, 2010, hereby guarantees that there appear of record, during said period; noinstrumerits of proceedings relating to or affecting said premises except as shown b@low.

(Continued)

07-13965-aab

COPY

Final Judicial Report (Continued) lb 4l TAX INFORMATION: The property stands charged on the Summit County Auditor's

Duplicate in the name of Alycia A. Driggins-Taylor and Kenneth S. Taylor. It carries parcelnumber 62-01346 and has a physical street address of 8610 Hadden Road, Twinsburg, OH44087.

The Treasurer has a first lien for taxes in an amount to be determined.

Taxes or assessments approved, levied or enacted by the State, County, Municipality,Township or similar taxing authority, but not yet certified to the tax duplicate of theCounty in which the land is situated, including any retroactive increases in taxes orassessments resulting, from any retroactive increase in the valuation of the land by theState County, Municipality, Township or other taxing authority.

2. The foreclosure action styled Deutsche Bank National Trust Companv, as Trustee for theCertificateholders of Soundview Home Loan Trust 2006-OPT2 Asset-BackedCertificates, Series 2006-OPT2 v: Kenneth S. Tavlor, et al. of record in the SummitCounty Court of Common Pleas, as Case No. CV 2007 118364, reflects that all partiesnecessary for the adjudication of this dispute have been named. A review of theproceedings in Case No. CV 2007 11 8364, Common Pleas Court, Summit County, Ohiohas been made and the Company finds no record in said proceedings of service completedon the following parties:

NONE

Sdrvice results for the parties are as follows:

• Kenneth S. Tay1ol, served by Private Process Service on December 20, 2007;• Alycia A. Driggins-Taylor, served by Private Process Service on December 20,

2007;• Chevy Chase Bank, served by Certified Mail on December 11, 2007;• Ford Motor Credit Company, served by Certified Mail on December 10, 2007;• The United States of America, served by Certified Mail on December 11, 2007;• The United States of America, served by Certified Mail on December 12, 2007;• Department of Agriculture of the United States of America, served by Certified

Mail on May 9, 2008;

07-13965aeb

COPY

CHICAGO TITLE INSURANCE COMPAN.Yy.'

`4e

11 6Number 7215435-21334

File Number 07-13965

FINAL JUDICIAL REPORT

This is a guarantee of record title only and is made for the use and benefit of all parties tosaid proceedings, and the purchaser at judicial sale thereunder. Liability hereunder and under anyPreliminary Judicial Report issued on the property described in said proceedings shall notexceed, in the aggregate, the sum of $84,000.10.

Dated: January 15, 2010 at 7:59 a.m.

In witness whereof, CHICAGO TITLE INSURANCE COMPANY has caused its corporate

name and seal to be hereunto affixed.

Chicago Title Insurance Company

BY: 'Nicole P. Boritrager, AgentAuthorized Signatory

CHICAGO TITGC INSURANCE COMPA,

0743965-aab

r̂ n̂ '̂

++iOi•il liOl \ ATUNTA CINCINNAI7 COwMBUS NEW YORI:

HIj VE BApSSELS CLEVEfAND nAYio

September 28, 2009

Via Electronic Mai[ (ind¢euarlcercourt*eoconrtsummitoL.net)and Regular U.S. Mail

The Honorable Tom ParkerSumnmit County Common Pleas Court205 South High StreetAkron, Ohio 44308

Attention: Jacqueline

RE: Deutsche Bank National Trust Coinpany, etc v. Kenneth S. Taylor, et aLSummit County Common Pleas CourtCase No. CV 2007-11-8364

Dear Jacqueline:

Enclosed, in response to your telephone request, is a revised Judgment Entry and Decree inForeclosure so as to include Defendants' Counterclaim and PlaintifPs Reply to theCounterclaim.

Very truly yours,

Robin M. Wilson

Enclosure

cc: Kenneth S. Taylor and Alycia A. Driggins-TaylorKent W. PenhallurickChevy Chase BankFord Motor.Credit CompanyThe United States of AmericaDepartment of Agriculture of the United States of America

1i484355.1

Robin.Wilson(a2ThomosonH'uie cmn Phone: 216-566-5572 Fax: 216-566-5800

THOMPSON HINE uP 3900 Key Center wwwThomvsonHine.mm

COPY

Januarv l 5^, 2010

teT^) c-:- l1VY' 4Q . / P

^t'^1114^c I'm

CERTIFICATE OF SERVICE 8 ^The undersigned hereby certifies that a copy of the foregoing Motion for an exteiision of

the date of dismissal was sent to the following by ordinary U.S. Mai1, postage prepaid, on the

date indicated below:

Kenneth S. Taylor,8610 Hadden RoadTwinsburg, OH 44087

Chevy Chase BankATTN: Legal Department .7926 Jones Branch DriveMclean, VA 22101

Kent W. PenhallurickAttorney for The United States of America400 United States Courthouse801 W. Superior AvenueCleveland, OH 44113-1852

Department of Agriculture of the UnitedStates of Americac% The U.S. Attomey for the NorthernDistrict of Ohio801 West Superior AvenueSuite 400Cleveland, OH 44113

July Z 2008

Dated

Alycia A. Driggins-Taylor8610 Hadden RoadTwinsburg, OH 44087

Ford Motor Credit Companyo%o Ct Corporation System, Statutory Agent1300 East Ninth StreetCleveland, OH 44114

The United States of Americao% The United States Attorney General

U.S. Department of Justice950 Pennsylvania Avenue, N.W.Washington, DC 20530-000 t

^lIS tS ^^C 1 >J ^ I ^ ^ 1 3̂ ^

G:\Cases - TM107-13965\M&O for E;dention to DismissA80702-BW.wpd

Docket Report

CIVIL CASE

Court of Common Pleas of Summit County, Ohio

Action For: FORECLOSURE CV-2007-11-836411/30/2007

DEUTSCHE BANK NATIONAL TRUST COMPANY

C/O OPTION ONE MORTGAGE CORP.

6501 IRVINE CENTER DR.

IRVINE, CA 92618

PLAINTIFF

TAYLOR, KENNETH S.

8610 HADDEN RD.

TWINSBURG, OH 44087

DEFENDANT

DRIGGINS-TAYLOR, ALYCIA A.

8610 HADDEN RD.

TWINSBURG, OH 44087

DEFENDANT

CHEVY CHASE BANK

ATTN: LEGAL DEPT.

7926 JONES BRANCH DR.

MCLEAN, VA 22101

DEFENDANT

FORD MOTOR CREDIT COMPANY

C/O CT CORPORATION SYSTEM

1300 E. NINTH ST.

CLEVELAND, OH 44114

DEFENDANT

UNITED STATES OF AMERICA

C/C US ATTORNEY

801 W. SUPERIOR AVE., #400

CLEVELAND, OH 44113

DEFENDANT

UNITED STATES OF AMERICA

C/O U.S. ATTORNEY GENERAL

U.S. DEPT. OF JUSTICE

950 PENNSYLVANIA AVE., N.W.

WASHINGTON, DC 20530

DEFENDANT

ROBIN M WILSON

3900 KEY CENTER

127 PUBLIC SQUARE

CLEVELAND, OH 44114

Attorney for PLAINTIFF

PRO SE

Attorney for DEFENDANT

PRO SE

Attorney for DEFENDANT

Attorney for DEFENDANT

Attorney for DEFENDANT

KENT W. PENHALLURICK

400 U.S. COURTHOUSE

801 W. SUPERIOR AVE.

CLEVELAND, OH 441131852

Attorney for DEFENDANT

KENT W. PENHALLURICK

400 U.S. COURTHOUSE

801 W. SUPERIOR AVE.

CLEVELAND, OH 441131852

Attorney for DEFENDANT

DEPARTMENT OF AGRICULTURE OF THE UNITED STATES

C/O U.S. ATTORNEY NORTHERN

DISTRICT OF OHIO

801 W. SUPERIOR AVE., STE. 400

CLEVELAND, OH 441131852

DEFENDANT Attorney for DEFENDANT

- Docket Entries --

All Docket Entries

1. 11/30/07

2. 11/30/07

3. 11/30/07

4. 11/30/07

5. 11/30/07

6. 12/04/07

7. 12/06/07

8. 12/06/07

9. 12/20/07

10. 12/20/07

11. 01/15/08

COMPLAINT FOR FORECLOSURE.

KEVIN L. WILLIAMS

CASE DESIGNATION FORM.

KEVIN L. WILLIAMS

PRELIMINARY JUDICIAL REPORT.

KEVIN L. WILLIAMS

MOTION TO APPOINT PROCESS SERVER.

KEVIN L. WILLIAMS

INSTRUCTIONS FOR CERTIFIED & PROCESS SERVER.

KEVIN L. WILLIAMS

ORDER APPOINTING PRIVATE PROCESS SERVER. MAS

SUMMONS ISSUED WITH COPY OF COMPLAINT TO KENNETH

S. TAYLOR, ALYCIA A. DRIGGINS-TAYLOR, CHEVY CHASE

BANK, FORD MOTOR CREDIT COMPANY, UNITED STATES OF

AMERICA (OH AND DC), AND DEPARTMENT OF AGRICULTURE

OF THE UNITED STATES BY CERTIFIED MAIL.

SUMMONS ISSUED WITH COPY OF COMPLAINT TO KENNETH

S. TAYLOR AND ALYCIA A. DRIGGINS-TAYLOR BY PROCESS

SERVER.

NOTIFICATION OF FAILURE TO OBTAIN CERTIFIED MAIL

SERVICE ON KENNETH TAYLOR MAILED TO ATTY.

WILLIAMS.

NOTIFICATION OF FAILURE TO OBTAIN CERTIFIED MAIL

SERVICE ON ALYCIA DRIGGINS-TAYLOR MAILED TO ATTY.

WILLIAMS.

DEFENDANTS, KENNETH AND ALYCIA TAYLOR'S MOTION TO

DISMISS IMPROPER VENUE.

PRO SE

12. 01/15/08 DEFENDANTS, KENNETH AND ALYCIA TAYLOR'S MOTION TO

DISMISS PLAINTIFFS' COMPLAINT TO FORECLOSURE FOR

INSUFIENCY OF SERVICE, LACK OF STANDING AND

CERTAIN OTHER MATTERS.

PRO SE

15. 01/18/08 INSTRUCTIONS FOR CERTIFIED MAIL SERVICE.

KEVIN L. WILLIAMS

13. 01/22/08 DEFENDANTS, KENNETH AND ALYCIA TAYLOR'S OPPOSITION

TO MOTION TO DISMISS.

PRO SE

14. 01/22/08 DEFENDANTS, UNITED STATES OF AMERICA'S ANSWER TO

COMPLAINT.

KENT W. PENHALLURICK

16. 01/23/08 SUMMONS ISSUED WITH COPY OF COMPLAINT TO

DEPARTMENT OF AGRICULTURE OF THE UNITED STATES OF

AMERICA BY CERTIFIED MAIL.

NO ATTY. REQUIRED

17. 02/12/08 PRETRIAL 3/12/2008 AT 2:45 P.M. MAS

NO ATTY. REQUIRED

18. 03/11/08 DEFENDANTS, KENNETH TAYLOR AND ALYCIA

TAYLOR-DRIGGINS' ANSWER TO COMPLAINT,

COUNTERCLAIM, CLASS ACTION AND JURY DEMAND.

PRO SE

19. 03/13/08 STATUS CONFERENCE 4/16/2008 AT 2:45 P.M. MAS

NO ATTY. REQUIRED

20. 03/24/08 PLAINTIFF'S REPLY TO ANSWER AND COUNTERCLAIM OF

KENNETH AND ALYCIA TAYLOR.

KEVIN L. WILLIAMS

21. 04/15/08 PLAINTIFF'S RESPONSE IN OPPOSITION TO MOTIONS TO

DISMISS AND REPLY TO OPPOSITION TO MOTION TO

DISMISS.

KEVIN L. WILLIAMS

24. 04/17/08 MEDIATION NOTICE. HEARING DATE 6/2/08 AT 9:30

A.M.

22. 04/18/08 STATUS CONFERENCE 6/2/2008 IMMEDIATELY FOLLOWING

THE MEDIATION CONFERENCE. JUDGE ROBERT GIPPIN

NO ATTY. REQUIRED

23. 04/18/08

25. 05/01/08

26. 05/05/08

CASE REFERRED TO MEDIATION. JUDGE ROBERT GIPPIN

NO ATTY. REQUIRED

INSTRUCTIONS FOR CERTIFIED MAIL SERVICE.

KEVIN L. WILLIAMS

SUMMONS ISSUED WITH COPY OF COMPLAINT TO

DEPARTMENT OF ARGICULTURE OF THE UNITED STATES OF

AMERICA (CLEVELAND, OH.), DEPARTMENT OF

ARGICULTURE OF THE UNITED STATES OF AMERICA

(WASHINGTON, DC.) AND DEPARTMENT OF ARGICULTURE OF

THE UNITED STATES OF AMERICA (WASHINGTON, DC) BY

CERTIFIED MAIL.

NO ATTY. REQUIRED

27. 05/30/08 SHERIFF'S DEED PROPERTY DESC. APPROVAL FORM.

KEVIN L. WILLIAMS

28. 06/04/08 SETTLED AND DISMISSED AT PLAINTIFF'S COSTS UNLESS

ANOTHER ORDER IS FILED WITHIN 30 DAYS. RMG

NO ATTY. REQUIRED

29. 06/04/08 STATUSREPORT OF MEDIATION.

NO ATTY. REQUIRED

30. 06/13/08 NOTIFICATION OF FAILURE TO OBTAIN CERTIFIED MAIL

SERVICE ON DEPARTMENT OF AGRICULTURE MAILED TO

ATTY. WILLIAMS.

31. 06/25/08 DEFENDANT, KENNETH TAYLOR'S MOTION FOR DISMISSAL

VIOLATION OF COURT ORDERS.

PRO SE

32. 06/25/08

33. 07/03/08

34. 07/03/08

35. 07/10/08

36. 07/11/08

37. 07/15/08

38. 07/15/08

39. 07/24/08

40. 08/22/08

41. 08/22/08

42. 08/22/08

43. 09/08/08

44. 09/08/08

45. 09/08/08

46. 09/22/08

47. 10/17/08

DEFENDANT, KENNETH TAYLOR'S MOTION FOR DISMISSAL,

VIOLATION OF COURT ORDERS, SUPPORT MEMORANDUM.

PRO SE

PLAINTIFF'S REPLY TO DEFENDANT'S SECOND MOTION TO

DISMISS.

KEVIN L. WILLIAMS

PLAINTIFF'S MOTION FOR EXTENSION OF DATE OF

DISMISSAL.

KEVIN L. WILLIAMS

COURT EXTENDS DUE DATE TO ADDITIONAL 60 DAYS. RMG

NO ATTY. REQUIRED

ORDER GRANTING PLAINTIFF'S MOTION FOR EXTENSION OF

DATE OF DISMISSAL. RMG

KEVIN L. WILLIAMS

DEFENDANT, KENNETH TAYLOR'S MOTION FOR DISMISSAL,

VIOLATION OF CONFIDENTIAL RULES/MEDIATION.

PRO SE

DEFENDANT, KENNETH TAYLOR AND ALYCIA TAYLOR'S

MOTION FOR DISMISSAL, VIOLATION OF CONFIDENTIALITY

RULES MEDIATION MEMORANDUM IN SUPPORT.

PRO SE

PLAINTIFF'S REPLY TO DEFENDANTS' FOURTHMOTION TO

DISMISS.

KEVIN L. WILLIAMS

PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT.

KEVINL: WILLIAMS.

PLAINTIFF'S FINAL JUDICIAL REPORT.

KEVIN L. WILLIAMS

AFFIDAVIT OF STATUS OF ACCOUNT AND MILITARY

NO ATTY. REQUIRED

DEFENDANTS, KENNETH S. TAYLOR AND ALYCIA

TAYLOR-DRIGGINS' OPPOSITION TO PLAINTIFFS MOTION

FOR SUMMARY JUDGMENT.

PRO SE

KENNETH S. TAYLOR'S CLASS ACTIONALLEGATIONS/COUNTERCLAIM EVIDENCE CLASS ACTION.

PRO SE

KENNETH S. TAYLOR AND ALYCIX

TAYLOR-DRIGGINS'OPPOSITION TO PLAINTIFF'S MOTION

FOR SUMMARY JUDGMENT.

PRO SE

PLAINTIFF'S REPLY BRIEF TO DEFENDANTS' OPPOSITION

TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT.

KEVIN L. WILLIAMS

DEFENDANT, KENNETH TAYLOR'S REPLY TO PLAINTIFF'S

REPLY OF DEFENDANTS OPPOSITION FOR SUMMARY

JUDGMENT.

PRO SE

48. 01/14/09 SETTLEMENT CONFERENCE 3/19/2009 AT 3:00 P.M.

BEFORE MAGISTRATE. JS

NO ATTY. REQUIRED

49. 01/14/09 REFERRAL TO FORECLOSURE SPECIALIST. RMG

NO ATTY. REQUIRED

50. 05/08/09 MEDIATION NOTICE. HEARING DATE 5/21/2009 AT 3:45

P.M.

NO ATTY. REQUIRED

51. 05/22/09 STATUS REPORT OF MEDIATION.

NO ATTY. REQUIRED

52. 05/29/09 STATUS CONFERENCE 07/22/09 AT 8:15 A.M. TP.

NO ATTY. REQUIRED

53. 07/21/09 AFFIDAVIT OF STATUS OF ACCOUNT AND MILITARY

NO ATTY. REQUIRED

54. 07/21/09 PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT.

KEVIN L. WILLIAMS

55. 07/22/09 DEFENDANTS, KENNETH TAYLOR AND ALYCIA

TAYLOR-DRIGGINS' MOTION FOR DISMISSAL FAILURE OF

PLAINTIFFS TO ADD INDEPENSABLE PARTIES AND

UNLAWFUL REMOVAL OF PARTIES NAMES MEMORANDUM IN

SUPPORT.

PRO SE

56. 07/22/09DEFENDANTS, KENNETH TAYLOR AND ALYCIA

TAYLOR-DRIGGINS' MOTION FOR DISMISSAL FAILURE OF

PLAINTIFFS TO ADD INDEPENSABLE PARTIES AND

UNLAWFUL REMOVAL OF PARTIES NAMES.

PRO SE

57. 07/22/09

58. 07/22/09

DEFENDANTS, KENNETH TAYLOR AND ALYCIA

DRIGGINS-TAYLOR'S MOTION FOR PLAINTIFFS TO COMPEL

EVIDENCE, NOTE, TITLE OR MORTGAGE.

PRO SE

DEFENDANTS, KENNETH TAYLOR AND ALYCIA

TAYLOR-DRIGGINS' MOTION FOR SANCTIONS, PLAINTIFFS'

VIOLATIONS OF RULE 22 MEDIATION.

PRO SE

59. 07/24/09 BENCH TRIAL 10/1/2009 AT 9:00 A.M. TP

NO ATTY. REQUIRED

60. 08/05/09 DEFENDANTS, KENNETH S. TAYLOR AND ALYCIA

TAYLOR-DRIGGINS' MOTION IN OPPOSITION TO COURTS

ORDER FOR BENCH TRIAL, REQUEST ORDER BE VACATED OR

REVERSED AND JURY TRIAL DEMAND BE GRANTED.

MEMORANDUM IN SUPPORT.

PRO SE

61. 08/05/09 DEFENDANTS, KENNETH S. TAYLOR AND ALYCIA

TAYLOR-DRIGGINS' MOTION IN OPPOSITION TO COURTS

ORDER FOR BENCH TRIAL, REQUEST ORDER BE VACATED OR

REVERSED AND JURY TRIAL DEMAND BE GRANTED.

PRO SE

62. 08/05/09

63. 08/05/09

DEFENDANTS, KENNETH S. TAYLOR AND ALYCIA

TAYLOR-DRIGGINS' SECOND MOTION IN OPPOSITION TO

PLAINTIFFS SECOND MOTION FOR SUMMARY JUDGMENT.

PRO SE

DEFENDANTS, KENNETH AND ALYCIA TAYLOR'S SECOND

MOTION IN OPPOSITION TO PLAINTIFF'S SECOND MOTION

FOR SUMMARY JUDGMENT. MEMORANDUM IN SUPPORT.

PRO SE

64. 08/20/09 NOTICE OF APPEARANCE OF ROBIN WILSON AS COUNSEL

ON BEHALF OF PLAINTIFF.

ROBIN M WILSON

65. 08/20/09 PLAINTIFF'S RESPONSE TO DEFENDANTS' SECOND MOTION

IN OPPOSITION TO PLAINTIFFS SECOND MOTION FOR

SUMMARY JUDGMENT.

ROBIN M WILSON

66. 08/20/09 PLAINTIFF'S RESPONSE TO DEFENDANTS' MOTION IN

OPPOSITION TO COURTS ORDER FOR BENCH TRIAL.

ROBIN M WILSON

67. 08/20/09

68. 08/20/09

69. 08/20/09

70. 09/01/09

72. 09/01/09

PLAINTIFF'S RESPONSE TO DEFENDANTS MOTION FOR

DISSMISAL (SIC) FAILURE OF PLAINTIFFS TO ADD

INDEPENSABLE (SIC) PARTIES AND UNLAWFUL REMOVAL OF

PARTIES NAMES.

ROBIN M WILSON

PLAINTIFF'S RESPONSE TO DEFENDANTS MOTION FOR

PLAINTIFFS TO COMPELL (SIC) EVIDENCE OF OWNERSHIP,

NOTE, TITLE OR MORTGAGE.

ROBIN M WILSON

PLAINTIFF'S RESPONSE TO MOTION FOR SANCTIONS

PLAINTIFFS (SIC) VIOLATIONS OF RULE 22 MEDIATION.

ROBIN M WILSON

DEFENDANTS, KENNETH AND ALYCIA TAYLOR'S RESPONSE

TO PLAINTIFFS' SECOND RESPONSE TO DEFENDANTS

SECOND OPPOSITION MOTION TO PLAINTIFFS SECOND

MOTION FOR SUMMARY JUDGMENT.

PRO SE

DEFENDANTS, KENNETH S. TAYLOR AND ALYCIA

DRIGGINS-TAYLOR'S MOTION FOR PLAINTIFFS TO COMPELL

EVIDENCE OF OWNERSHIP, NOTE, TITLE, OR MORTGAGE

ANSWER DEFENDANTS FIRST SET OF INTERROGATORIES AND

PRODUCTION OF DOCUMENTS MEMORANDUM IN SUPPORT.

PRO SE

73. 09/01/09 DEFENDANTS, KENNETH S. TAYLOR AND ALYCIA

DRIGGINS-TAYLOR'S MOTION FOR PLAINTIFFS TO COMPELL

EVIDENCE OF OWNERSHIP, NOTE, TITLE, OR MORTGAGE

ANSWER DEFENDANTS FIRST SET OF INTERROGATORIES AND

PRODUCTION DOCUMENTS.

PRO SE

71. 09/02/09 DEFENDANT, KENNETH AND ALYCIA TAYLOR-DRIGGINS'

MOTION IN OPPOSITION TO PLAINTIFF LAWYERS

WITHDRAWAL FROM CASE AND ILLEGAL SUBSTITUTION OF

NEW COUNSEL.

PRO SE

74. 09/03/09

75. 09/08/09

DEFENDANTS, KENNETH AND ALYCIA TAYLOR-DRIGGINS'

MOTION TO DISMISS CASE PLAINTIFFS WHO FILED

FORECLOSURE DO NOT OWN LOAN ARE ONLY TRUSTEES

OVERSEERS FOR A SECURITIZED TOOL OF LOANS.

PRO SE

DEFENDANTS, KENNETH AND ALYCIA TAYLOR'S MOTION FOR

DISMISSAL FOR VIOLATION OF RULES OF COURT 20.03

LIMITATIONS AS TO TIME.

PRO SE

76. 09/10/09 COURT GRANTS PLAINTIFF'S MOTION FOR SUMMARY

JUDGMENT. COURT DENIES THE REMAINDER OF

DEFENDANTS' MOTIONS AS MOOT. THERE IS NO JUST

CAUSE FOR DELAY. TP

NO ATTY. REQUIRED

77. 09/22/09 PLAINTIFF'S NOTICE OF FILING PROPOSED JUDGMENT

ENTRY AND DECREE IN FORECLOSURE.

ROBIN M WILSON

78. 09/22/09 DEFENDANTS, KENNETH S. TAYLOR AND ALECIA

TAYLOR-DRIGGINS' MOTION IN OPPOSITION TO COURTS

ORDER GRANTING PLAINTIFF'S MOTION FOR SUMMARY

JUDGMENT BE REVERSED VACATED OR REMANDED.

PRO SE

79. 09/30/09 DEFENDANTS, KENNETH AND ALYCIA TAYLOR-DRIGGINS'

MOTION OPPOSING NOTICE OF FILING REVISED JUDGMENT

ENTRY AND DECREE IN FORECLOSURE.

PRO SE

80. 10/02/09 COURT VACATES SUMMARY JUDGMENT ENTERED 9/10/2009.

COURT WILL HOLD IN ABEYANCE FURTHER CONSIDERATION

OF THE MOTION FOR 30 DAYS. PLAINTIFF TO PRODUCE

AFFIDAVIT IN SUPPORT OF ITS MOTION FOR SUMMARY

JUDGMENT. IF PLAINTIFF FAILS TO PRODUCE AFFIDAVIT

WITHIN 30 DAYS OF THE DATE OF THIS ORDER, ITS

MOTIQN FOR SUMMARY WILL BE DISMISSED. TP

. . . NO ATTY. REQUIRED

81. 11/03/09

82. 11/09/09

PLAINTIFF'S NOTICE OF FILING REVISED AFFIDAVIT

REGARDING ACCOUNT AND COMPETENCY AND MILITARY

STATUS.

ROBIN M WILSON

PLAINTIFF GRANTED TO FILE REPLY BRIEF NOT LATER

THAN 11/27/2009. PARTIES TO PROVIDE COURTESY

COPIES OF ADDITIONAL RESPONSES. TP

NO ATTY. REQUIRED

83. 11/17/09 DEFENDANTS, KENNETH AND ALYCIA DRIGGINS TAYLOR'S

MOTION SEEKING DISMISSAL OF PLAINTIFFS SECOND

MOTION FOR SUMMARY JUDGMENT FOR FAILURE TO PRODUCE

A CURRENT, ACCURATE, ENDORSED AFFIDAVIT IN SUPPORT

OF SUMMARY JUDGMENT PER JUDGES ORDER ON 10/2/2009.

PRO SE

84. 11/24/09

85. 11/25/09

COURT GRANTS DEFENDANTS TAYLORS LEAVE TO RESPOND

UNTIL 12/11/2009. PLAINTIFF HAS UNTIL 12/28/2009

TO FILE REPLY BRIEF. TP

NO ATTY. REQUIRED

PLAINTIFF'S RESPONSE TO DEFENDANTS MOTION SEEKING

DISMISSAL OF PLAINTIFF'S SECOND MOTION FOR SUMMARY

JUDGMENT FILED 11/17/2009.

ROBIN M WILSON

86. 12/09/09 DEFENDANTS, KENNETH TAYLOR AND ALYCIA

TAYLOR-DRIGGINS' MOTION TO DISMISS CASE.

PRO SE

87. 12/09/09 PLAINTIFFS' INTERROGATORIES AND REQUEST FOR

PRODUCTION OF DOCUMENTS. SECOND MOTION TO COMPEL

DISCOVERY AS RELATED TO NEW AFFIANTS TESTIMONY AND

NEW EVIDENCE SUBMITTED UNDER PENALTY OF PERJURY BY

CYNTHIA STEVENS.

NO ATTY. REQUIRED

88. 12/09/09 DEFENDANT, KENNETH S. TAYLOR'S MOTION SEEKING

DISMISSAL OF PLAINTIFF'S SECOND MOTION FOR SUMMARY

JUDGMENT FOR FAILURE TO PRODUCE A CURRENT,

ACCURATE, ENDORSED AFFIDAVIT IN SUPPORT OF SUMMARY

JUDGMENT PER JUDGES ORDER ON OCTOBER 2, 2009 AND

PER CURRENT NEW ORDER FILED ON NOV. 24, 2009.

PRO SE

89. 12/21/09 PLAINTIFF'S RESPONSE TO DEFENDANTS MOTION TO

DISMISS CASE PLAINTIFFS WHO FILED FOR FORECLOSURE

DO NOT OWN LOAN ARE ONLY TRUSTEES OVERSEERS FOR A

SECURITIZED POOL OF LOANS.

ROBIN M WILSON

90. 12/21/09

91. 12/21/09

DEFENDANTS' MOTION TO STRIKE PLAINTIFFS SECOND

MOTION FOR SUMMARY JUDGMENT FOR FRAUD UPON THE

COURT.

PRO SE

PLAINTIFF'S RESPONSE TO DEFENDANTS MOTION SEEKING

DISMISSAL OF SECOND MOTION FOR SUMMARY JUDGMENT

FILED ON OR ABOUT 12/9/2009.

ROBIN M WILSON

92. 12/28/09 JOINDER OF PARTIES TO DEFENDANTS PENDING

COUNTERCLAIM AND SUPPLEMENTAL PLEADINGS FAILURE TO

JOIN INDISPENSABLE PARTY.

PRO SE

94. 12/31/09 PLAINTIFF'S RESPONSE TO DEFENDANTS MOTION TO

STRIKE PLAINTIFFS SECOND MOTION FOR SUMMARY

JUDGMENT FOR FRAUD UPON THE COURT FILED ON OR

ABOUT DECEMBER 21, 2009.

ROBIN M WILSON

95. 01/04/10 DEFENDANT KENNETH S. TAYLOR AND ALYCIA A. TAYLOR'S

- MOTION FOR STAY PENDING OUTCOME OF THE EVIDENTIARY

HEARING.

PRO SE

96. 01/04/10 DEFENDANTS, KENNETH S. TAYLOR AND ALYCIA A.

TAYLOR'S MOTION FOR EVIDENTIARY HEARING.

PRO SE

97. 01/08/10

93. 01/12/10

98. 01/12/10

COURT GRANTS PLAINTIFF'S MOTION FOR SUMMARY

JUDGMENT. COURT DENIES THE REMAINDER OF

DEFENDANTS' MOTIONS AS MOOT. NO JUST CAUSE FOR

DELAY. TP

NO ATTY. REQUIRED

PLAINTIFF'S RESPONSE TO JOINDER OF PARTIES TO

DEFENDANTS' PENDING COUNTERCLAIM AND SUPPLEMENTAL

PLEADINGS FAILURE TO JOIN INDISPENSABLE PARTY

FILED BY DEFENDANTS.

ROBIN M WILSON

DEFENDANTS, KENNETH S. TAYLOR AND ALYCIA A. TAYLOR

DRIGGINS' MOTION TO RECUSE JUDGE TOM PARKER AND

IMMEDIATE EMERGENCY INJUNCTIVE RELIEF OF JUDGMENT.

PRO SE

99. 01/12/10 DEFENDANTS, KENNETH S. TAYLOR'S MOTION TO VACATED

JUDGES ORDER GRANTING PLAINTIFFS SECOND MOTION FOR

SUMMARY JUDGMENT BE REVERSED, REMANDED.

PRO SE

100. 01/15/10 PLAINTIFF'S FINAL JUDICIAL REPORT.

KEVIN L. WILLIAMS

101. 01/19/10 DEFENDANTS OPPOSITION TO PLAINTIFFS NOTICE OF

FILING OF FINAL JUDICIAL REPORT FRAUD UPON COURT.

PRO SE

102. 01/19/10 DEFENDANT, KENNETH S. TAYLOR'S MOTION JOINDER OF

PARTIES TO DEFENDANTS PENDING COUNTERCLAIM AND

SUPPLEMENTAL PLEADINGS FOR ("AHMSI") AMERICAN HOME

MORTGAGE SERVIN-ING INC.

PRO SE

103. 01/19/10 DEFENDANT, KENNETH S. TAYLOR AND ALYCIA A.

TAYLOR-DRIGGINS' MOTION FOR EVIDENTIARY HEARING

REVISED FOR NEW JUDGE.

PRO SE

104. 01/20/10 DEFENDANT, KENNETH TAYLOR'S SECOND AND REVISED

MOTION TO VACATED JUDGES ORDER GRANTING PLAINTIFFS

SECOND MOTION FOR SUMMARY JUDGMENT BE REVERSED,

REMANDED IN FAVOR OF DEFENDANTS PENDING

COUNTERCLAIM.

PRO SE

106. 01/27/10 PLAINTIFF'S NOTICE OF FILING PROPOSED JUDGMENT

ENTRY AND DECREE IN FORECLOSURE.

ROBINM WILSON

107. 01/27/10 NOTICE OF FILING FINAL JUDICAL REPORT.

ROBIN M WILSON

108. 01/28/10 DEFENDANTS, KENNETH AND ALYCIA TAYLOR'S OPPOSITION

TO PLAINTIFFS NOTICE OF FILING OF FINAL JUDICIAL

REPORT AND JUDGMENT ENTRY AND DECREE IN

FORECLOSURE FRAUD UPON COURT JUDGE LACKS

JURISDICTION FOR FAILURE TO RESPOND. TO RECUSAL

MOTION.

PRO SE

109. 01/28/10 DEFENDANTS, KENNETH AND ALYCIA TAYLOR'S MOTION FOR

TEMPORARY RESTRAINING ORDER FRAUD OF COURTS.

PRO SE

105. 01/29/10 COURT DENIES DEFENDANTS MOTION TO VACATEJUDGE'S

ORDER GRANTING PLAINTIFFS SECOND MOTION FOR

SUMMARY JUDGMENT BE REVERSED, REMANDED, AND DENIES

DEFENDANTS MOTION TO RECUSE JUDGE TOM PARKER AND

IMMEDIATE RELIEF OF JUDGMENT. TP

NO ATTY. REQUIRED

110. 02/01/10 DECREE OF FORECLOSURE. TP

NO ATTY. REQUIRED

111. 02/10/10 DEFENDANTS SECOND MOTION TO RECUSE JUDGE TOM

PARKER EMERGENCY INJUNCTIVE RELIEF OF JUDGEMENT

SUPPORTEDWITH AFFIANT AFFIDAVIT OF

DISQUALIFICATION.

PRO SE

112. 02/10/10 DEFENDANT, KENNETH S. TAYLOR AND ALYCIA

TAYLOR-DRIGGINS' NOTICE OF PENDENCY OF ACTION.

PRO SE

113. 02/22/10 DEFENDANTS, KENNETH AND ALYCIA'TAYLOR'S SHOW CAUSE

ACTION TO DISMISS FINAL JUDGMENT ORDER, HEARING

REQUESTED.

PRO SE

114. 03/04/10 CA-25281 DEFENDANT, KENNETH S. TAYLOR'S NOTICE OF

APPEAL.

PRO SE

115. 03/04/10 DOCKETING STATENtENT.

NO ATTY. REQUIRED

116. 04/13/10 CA-25281 COURT OF APPEALS DISMISSAL.

NO ATTY. REQUIRED

117. 04/23/10 NOTICE ISSUED WITH CERTIFIED COPY OF APPEAL

DISMISSAL TO JUDGE THOMAS PARKER BY REGULAR MAIL.

NO ATTY. REQUIRED

------------------------------ (COST)___---------------_--____-

Posted Action Amount

---------- ------------------------- ----------12/03/2007ORIGINAL COSTS 353.50

------------------------------ (DEPOSITS)---------_-___________----

Received Action Received From Amount

12/03/2007 FORECLOSURE COMPLAIN WILLIAMS, KEVIN L. 525.00

03/11/2008 COUNTER CLAIM TAYLOR, KENNETH 25.00

06/01/2010 ORDER OF SALE DEPOSI WILLIAMS, KEVIN 620.00

--- All Services

Issued Number Status Served $Amount Party

12/06/2007 71603901984536 UNCLAIMED12/06/2007 71603901984536 UNCLAIMED12/06/2007 71603901984536 CLAIMED 12/11/200712/06/2007 71603901984536 CLAIMED 12/10/200712/06/2007 71603901984536 CLAIMED 12/11/200712/06/2007 71603901984536 CLAIMED 12/12/200712/06/2007 7160390198449912/06/2007 179877 RESIDENTIA 12/20/200712/06/2007 179878 RESIDENTIA 12/20/200701/23/2008 7160390198449905/05/2008 71603901984553 CLAIMED 05/09/200805/05/2008 71603901984553 NOT SIGNED 05/12/200805/05/2008 71603901984553 OTHER04/23/2010 278078 CLAIMED 04/23/2010

6.45 TAYLOR, KENNETH S.

6.45 DRIGGINS-TAYLOR, ALYCIA A.

6.28 CHEVY CHASE BANK

6.28 FORD MOTOR CREDIT COMPANY

6.28 UNITED STATES OF AMERICA

6.28 UNITED STATES OF AMERICA

0.00 DEPARTMENT OF AGRICULTURE OF T

0.00 TAYLOR, KENNETH S.

0.00 DRIGGINS-TAYLOR, ALYCIA A.

0.00 DEPARTMENT OF AGRICULTUREOF T

6.45 DEPARTMENT OF AGRICULTURE OF T

6.45 DEPARTMENT OF AGRICULTURE OF T

6.45 DEPARTMENT OF AGRICULTURE OF T

3.54 HONORABLE JUDGE THOMAS PARKER

COPY

DAN1Gl U. ;iURRIGNv'

2010FE8-1 PH 2: 2i

SUMMIT CUUNi`fCLERK OF COUfiTS

IN THE COURT OF COMMON PLEASSUMMIT COUNTY, OHIO

DE17TSCHE BANK NATIONALTRUST COMPANY, as Trustee for theCertificateholders of Soundview HomeLoan Trust 2006-OPT2, Asset-BackedCertificates, Series 2006-OPT2

Plaintiff,

vs.

KENNETH S. TAYLOR, et al.,

Defendants.

CASE N0. CV-2007-I 1-8364

JUDGEPARKER

JUDGMENT ENTRY ANDDECREE IN FORECLOSURE

This cause is before the Court on ahe Complaint filed November 30, 2007 by plaintiff

Deutsche Bank National Trust Company, as Trustee for the Certificateholders of Soundview

Home Loan Trust 2006-OPT2, Asset-Backed Certificates, Series 2006-OPT2 ("Deutsche Bank,

Trustee" or "PlaintifP") pursuant to which Plaintiff seeks a foreclosure decree. The real property

that is the subject of this foreclosurc action (the "Property") is as follows:

Situated in the Township of Twinsburg, County of Summit and State of Ohio andknawn as being all of Sublots 281 and 282 except the Westerly 25 feet of thesetwo lots of the Twinsburg Heights Allotment Number 2, as shown in Plat Book34, page 3 of the Summit County Records, as surveyed by James N. Connor,Registered Surveyor #4570 in June 1980, be the same more or less, but subject toall legal highways.

On January 15, 2008 Defendants Kenneth S. Taylor and Alycia A. Driggins-Taylor

("Defendants") filed a Motion to Dismiss hnproper Venue, and a Motion to Dismiss PlaintifPs

Complaints to Foreclosure for Insufficiency of Service, Lack of Standing, and Certain Other

11483589.7

Matters. 'On January 22, 2008, Defendants filed an "Opposition to Motion to Dismiss" stating

that their motions to dismiss should be treated as a counterclaim and construed as such (the

January 15 and January 22 filings are collectively 'Defendants' Motions to Dismiss"). On March

11, 2008, Defendants answered the Complaint and filed a Counterclaim. Plaintiff filed a Reply

to Defendants' Counterclaim on March 24, 2008, and on April 15, 2008 filed a Response in

Opposition to Defendants' Motions to Dismiss.

On August 22, 2008, Plaintiff filed a Motion for Summary Judgment, which Defendants

opposed. On September 22, 2008, Plaintiff filed a Reply Brief to Defendants' Opposition to

Plaintiffs Motion for Summary Judgment in which Plaintiff fully briefed why Defendants'

Motions to Dismiss, including the counterclaims set forth therein, had no merit. On July 21,

2009 Plain6ff filed a second Motion for Summary Judgment. On July 22, 2009 Defendants filed

a number of Motions including 1) a Motion for Dismissal Failure of Plaintiffs to Add

Indispensable Parties and Unlawful Removal of Parties Names Memorandum in Support; 2) a

Motion for Dismissal Failure of Plaintiffs to Add Indispensable Parties and Unlawful Removal

of Parties Names; 3) a Motion for Plaintiffs to Compel Evidence of Ownership, Note, Title or

Mortgage, and 4) a Motion for Sanctions PlaintifFs Violations of Rule 22 Mediation (collectively

the "July 22 Motions").

On September 10, 2009the Court entered summary judgment in favor of Plaintiff, which

order was vacated on October 2, 2009 due to discrepancies between two affidavits that had been

filed in support of Plaintiffs Motions for Sununary Judgment, and ordered PlaintifYto produce a

current endorsed affidavit. On January 8, 2010, this Court, on Plaintiffs renewed Motion for

Summary Judgment, having reviewed the Complaint, Defendants' Motions to Dismiss, the

Answer and Counterclaim filed by Defendants, Plaintiffs Reply to Defendants' Counterclaim,

11482589.7 2

COPY

PlaintifPs Response in Opposition to Defendants' Motions to Dismiss, Defendants' Opposition to

Summary Judgment, Plaintiffs Reply Brief to Defendants' Opposition to Plaintiffs Motion for

Summary Judgment, the July 22 Motions and Oppositions thereto, as well as all evidence

submitted, including the revised Affidavit submitted by Plaintiff on November 3, 2009

deteimined that no issue of fact remains for resolution and that Plaintiff is entitled to judgment in

its favor as a matter of law on all claims in the suit (the "January 8 Order"). The January 8 Order

also referenced and denied Defendant Mr. Taylor's motions for an evidentiary hearing and for

stay pending the outcome of an evidentiary hearing filed on January 4, 2010.

In its Order, the Court further found that Chevy Chase Bank, Ford Motor Credit

Company, and Department of Agriculture of the United States of America have been served witfi

a Suminons and Complaint but are in default for failure to file an Answer or other responsive

pleading. As a result, with respect to such defendants, the Court granted Plaintiffs Motion for

Default Judgment and entered judgment in favor of Plaintiff for the relief sought by Plaintiff in

its Complaint.

The Court further finds herein that The United States of America has filed a disclaimer of

interest, disclairning all right to, interest in, or tltle to the subject Property. As a result, this

defendant is forever barred from asserting an interest in the Property.

As found in the January 8 Order and re-stated in greater depth herein, the Court finds that

Defendants executed the promissory note referenced in the Complaint (the "Note") and therefore

promised, among other things, to make monthly payments on or before the date such payments

were due. The Court further finds that the sums due under the Note were accelerated in

accordance with the terms of the Note and Mortgage, The Court further finds that Defendants

11482589.7 3

COPY

executed and delivered the mortgage referenced in the Complaint (the "Mortgage"), and that the

Mortgage secures the amounts due under the Note.

As stated in its January 8 Order and reaffirmed herein, the Court finds that the Note and

Mortgage are in default because payments required to be made under the Note and Mortgage

have not been made. The Court finds that the conditions of the Mortgage have broken, the break

is absolute, and Plaintiff is entitled to have the equity of redemptlon and dower of the current

title holders foreclosed. The Court finds that Plaintitf, as the holder of the secured interest

conveyed byvalid and recorded assigmnent, is the real party in interest to prosecute this

foreclosure action: The Court has considered the claims to the contrary made by Defendants, in

their Motions to Dismiss and Counterclaim, and in their briefing before this Court, and in

Defendants' July 22 Motions and finds those claims to be without merit as a matter of law.

The Court further finds that there is due to Plaintiff on the Note principal in the amount

of $84,000.10 plus interest on the principal amount at the rato of 9.7% per annum from March 1,

2007. The Court further finds that there is due on the Note all late charges imposed under the

Note, all advances made for the payment of real estate taxes and assessments and insurance

premiums, and all costs and expenses incurred for the enforcement of the Note and Mortgage,

except to the extent the payment of one or more specific such items is prohibited by Ohio law.

As a result, the Court hereby enters judgment for the amount due on the Note in favor of Plaint[ff

and against Kenneth S. Taylor and Alycia A. Driggins-Taylor.

The Court finds that the Mortgage was recorded with the County Recorder and is a valid

and subsisting firsl mortgage on the Property. The Court forther finds that the parties to the

Mortgage intended that it attach to the entire fee simple interest in the Property. The Mortgage

is, however, junior in priority under Ohio law to the lien held by the County Treasurer to secure

i

11482589.7 4

COPY

the payment of real estate taxes and assessments. All amounts payable under Seetion 323.47 of

the Ohio Revised Code sha11 be paid from the proceeds of the sale before any distribution is

made to other lien holders.

IT IS THEREFORE ORDERED, ADJUDGED, AND DECREED that unless

Kenneth S. Taylor and/or Alycia A. Driggins-Taylor or anyone claiming through them pay or

cause to be paid the costs of this action and the amounts aforesaid found to be due and owing'to

the Plaintiff within three (3) days from the date of this Bntry, the equity of redemption of all

Defendants and anyone claiming through them, in the Property, shaU be forever cut off, barred,

and foreclosed; the Property shall be sold free and clear of any lien, claim, or interest of the

Defendants of whatever nature or lcind, and an Order of Sale be issued to the Sheriff directing

him to appraise, advertise, and sell the Property according to law and the orders of this Court,

and to report his findings to this Court for fiuther order, and that the purchaser at such

foreclosure sale be awarded a writ of possession and that aU other pe.rsons in possession of the

Property be evicted.

Notice of the time and place'of the sale of the Property shall be given to all persons who

have an interest in the Property lecoording to the provisions of Section 2329.26 of the Ohio

Revised Code.

IT IS FURTHER ORDERED that the Sheriff shall send counsel for the party

requesting the Order of Sale a copy of the publication notice promptly upon its first publication.

11482589.7 5

OPY

There is no just reason for delay in entering Judgment as aforesaid.

THIS IS A FINAL ORDER.

I certify this to be a true copyotthe originalpaniel M. Iqrrjgapy,jrlerk of GourEs.

11482589.7 6

:-D€puty