FACTS O.F.R. OFFICE OF FINANCIAL REGULATIONS 'G.R.P. …€¦ · "motion to dismiss'attached hereto...
Transcript of FACTS O.F.R. OFFICE OF FINANCIAL REGULATIONS 'G.R.P. …€¦ · "motion to dismiss'attached hereto...
MOTION 3). TO'DISMISS'LIS PENDIS, 7/08
MOTION 4). TO 'DISMISS' FORECLOSURE 7/14/09,
MOTION 5). TO "DISMISS"FORECLOSURE 7/14/09,
MOTION 6). TO "DISMISS "CERTIFICATE OF SALE 7/14/09,
MOTION 7). TO "DISMISS'" CERTIFICATE OF TITLE 10/8/09 AND
MOTION 8). TO "DISMISS' D.L.J. MORTGAGE CAPITAL INC.'SALE"
7/27111.... AND IN SUPPORT THEREOF STATES, AS FOLLOWS;
FACTS
O.F.R. OFFICE OF FINANCIAL REGULATIONS 'G.R.P. LOANSL.L.C.ENTITY (EXHIBIT 'A')NOW (EXHIBIT " E")FL. RULE OF CIVILPROCEDURE 1.120 (A). AND G.R.P. LOANS L.L.C. NEVER EXISTED INFLA. STATUE 865.09 "FACELESS" PLAINTIFF....
1). ON JULY__ 2008 G.R.P. LOANS L.L.C. &/ ATTY. AMYMC GROTTY FILED A LISPENDIS ON DEF.'S HOME 8219 DANBURY LANE HUDSON, FL. 34667.
(EXHIBIT "A")
2).ON JULY 1STH. 2008, (G.R.P. LOANS L.L.C.&/ PLAINTIFF'S ATTY. AMY MC GROTTYFILED A PLEADING ENTITLED'COMPLIANT FOR 'FORECLOSURE'
(THE "COMPLIANT" EXHIBIT "B")
A COPY OF WHICH IS ATTACHED "LOST,"STOLEN" & OR "DESTROYED" NOTE W/;NO" ASSIGNMENT OF MORTGAGE OR "NOTE"(W/ "NO"LEGAL OWNERSHIP 7/15/08)
HERETO; AS
( EXHIBIT "B"').
3).PARAGRAPH.__.0FCOMPLIANTATTY. AMYMC GROTTY STATES;"PLAINTIFF ISNOW THE OWNER AND HOLDER OF THE "NOTE" AND MORTGAGE BY VIRTUE OF
ASSIGNMENT."
EXHIBIT "C"
4).THE'VERIFICATION'STATEMENT STATES THAT JOANNE DINARDi lN CONTROL OFSERVICING "LOAN" & PAYMENTS. TAXES , & INSURANCES PAYMENTS FOR;
"PLAINTIFF" G.R.P. LOANS L.L.C.UNDER THE PAINS & PENALTIES OF PERJURY,HASREAD THE FOREGOING, AND THE FACTS ALLEGED THEREIN ARE TRUE AND
CORRECT TO THE BEST OF HER KNOWLEDGE AND BELIEF.
EXHIBIT "D"
5). THE COPY OF THE "NOTE" ATTACHED TO THE COMPLIANT AS AN EXHIBliIDENTIFIES THE LENDER AS G.R.P. LOANS L.L.C. A (DELAWARE'
ENTITY/CORP) 3PGS.FROM G.R.P.FINANCIAL SERVICESCORP, A (N.Y.ENTITY).
6).THE COPY OF THE MORTGAGE ATTACHED TO THE COMPLIANT AS AN EXHIBITIDENTIFIES THE "LENDER" AS"G.R.P.LOANS L.L.C." AND THE
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS(MERS)
7).UNDER A SEARCH FOR "G.R.P.LOANS L.L.C."IN THE FLORIDA DEPARTMENTSTATE DIVISION OF CORPORATIONS, & "OFFICE OF FINANCIAL REGULATIONS
TALLAHASSEE,FLA. THE RESULTS(ATTACHED HERETO;AS EXHIBIT "E"
("NO" G.R.P. LOANS L.L.C.WAS"ORIGINALLY EXHIBT 'A')
ARGUMENTS AND AUTHORITIES
8).WHILE THE PLAINTIFF ALLEGES IN THE COMPLIANT THAT IT IS ENTITLED TOENFORCE THE "NOTE" AND"MORTGAGE," THE EXHIBITS ATTACHED TO THE
COMPLIANT SUGGEST THE CONTRARY. WITH NO COPY OF "NOTE" & "NO'ASSIGNMENT OF MORTGAGE ON COMPLIANT ON 7/15/08 ATTACHED TO THECOMPLIANT
CONTAINS NOTHING CONFERRING ANY AUTHORITY ON PLAINTIFF TO ENFORCETHE "NOTE". THERE IS ALSO "NO" ASSIGNMENT OF MORTGAGE ON 7/15/08
CONFERRING ON PLAINTIFF'S THE "AUTHORITY"G.R.P. LOANS L.L.C.("DELAWARE" ENTITY TO'FORECLOSE' THE MORTGAGE (ATTACHED TOCOMPLIANT)...
THE PROPER PARTY WITH STANDING TO FORECLOSE A NOTE AND MORTGAGEIS THE "HOLDER" OF THE NOTE & MORTGAGE OR THE HOLDER'S
REPRESENTATIVE. SEE TAYLOR VS. DEUTSCHE BANK NATIONALTRUST CO. 44 SO. 3D 618,622 FLA. 5TH DCA 2010 BAC FUNDING
CONSORTIUM INC. ISADA/ATIMA VS, JEAN JACQUES, 28 SO.3D 936 , 938(FLA.2D DCA 20101.
WHEN EXHIBITS ARE ATTACHED TO A COMPUANT, THE CONTENTS OF THEEXHIBITS CONTROL OVER THE ALLEGATIONS OF THE COMPUNT.
SEE HUNT RIDGE A T TALL PINES,1NC.VS. HALL.7ee SO. 2ND 399,401(FLA. 2D. DCA 2010) IN ADDITION, THE EXHIBITS WHICH ARE ATTACHED TO THE
PLAINTIFF'SCOMPUANT ESTABLISH THAT A PARTY OTHER THAN THE NAMEDPLAINTIFF MAY BE THE REAL PARTY IN INTEREST IN THIS CASE.
WHEN CONFUCT BETWEEN GENERAL ALLEGATIONS MADE W/IN THEPLEADINGS AND THE EXHIBITS WHICH ARE ATTACHED TO THE COMPLIANT, THEEXHIBITS
CONTROL. SEE GEICO GEN. INS. CO VS. GRACI, 849 SO. 2D.1196(FLA.APP.4 DIST. 2003.SEE ALSO GINSBERG VS. LENNAR FLORIDA
HOLDINGS,
645 SO. 2D. 490 (FLA. APP. 3D. 1994) AS STATED ABOVE, EXHIBITSATTACHEDTO THE COMPLIANTARE CONTROLUNG ,WHERE ALLEGATIONS OF THECOMPLIANT
ARE CONTRADICTED BY THE EXHIBITS, THE PLAIN MEANING OF EXHIBITS WILLCONTROL.
9).RULE 1.130 (A), FLA. R. CIV.P.(2010) MANDATES THAT A COPY OF THE NOTE &MORTGAGE BE ATTACHED TO THE COMPLIANT.ELGEN VS. FDIC 492 SO. 2D.826
(FLA. 2ND DCA 1986) IN THIS CASE,COPIES OF THE NOTE AND MORTGAGE REATTACHED TO THE COMPLIANT. HOWEVER, BOTH THE COPIES OF THE MORTGAGEAND
NOTE ATTACHED TO THE COMPUANT. HOWEVER, BOTH THE PARTIES OF THEMORTGAGE AND NOTE IDENTIFY THE "LENDER" AS'FREEMONT -INVESTORS'.THEREIS
NOTHING ATTACHED EXHIBITS SPECIFICALLY CONFERRING ANYAUTHORITY ON"PLAINTIFF" G.R.P. LOANS L.L.C. TO BRING THIS ACTION.
THESE OMISSIONS ARE A CLEAR VIOLATION OF THE MANDATEREQUIRING ; "ALL.....DOCUMENTS UPON WHICH ACTIONS MAY BEBROUGHT...OR A
COPY THEREOF...SHALL BE...ATTACHED TO THE PLEADING"
10).ON 8/10/11 CLAIM TO "VACATE" FINAL SUMMARY JUDGEMENT FLA. R CIV PRO.
1.110(B)CLAIMS FOR "RELIEF" WAS AMENDED TO ADD
THE FOLLOWING LANGUAGE AT THE END OF 1.110 (B).
WHEN FILING AN ACTION FOR "FORECLOSURE" OF A MORTGAGE ONRESIDENTIAL REAL PROPERTY THE COMPLIANT SHALL BE "VERIFIED".
WHEN "VERIFICATION"OFA DOCUMENT IS REQUIRED, THE DOCUMENT FILEDSHALL INCLUDE AN'OATH' AFFIRMATION,OR THE FOLLOWING STATEMENT;
"UNDER THE PAINS & PENALTIES OF PERJURY", IDECLARE THAT I HAVE READ THE FOREGOING, AND THE FACTSALLEGED
THEREIN ARE CORRECT TO THE BEST OF MY KNOWLEDGE ANDBELIEF....
11).IN THE FLA. SUPREME COURT'S MEMORANDUM ENTITLED IN RE;AMENDMENTS TO THE FLA. RULES OF CIVIL PROCEDURE, 44SO.3D555 (FLA.
2010) (ISSUED FEB. 11, 2010 MODIFIED JUNE 3RD, 2010), THE COURT STATESIN PERTINENT PART AS FOLLOWS;
RULE 1.110(B) IS AMENDED TO REQUIRE VERIFICATION OF MORTGAGEFORECLOSURE COMPLIANTS INVOLVING RESIDENTIAL PROPERTY.
THE PRIMARYPURPOSES OF THIS AMENDMENT ARE ;
1) TO PROVIDE INCENTIVE FOR THE PLAINTIFF TO APPROPRIETELYINVESTIGATE &"VERIFY" IT'S "OWNERSHIP"OF THE "NOTE'OR RIGHTS TO ENFORCETHE
"NOTE" & ENSURE THAT THE ALLEGATIONS IN THE COMPLIANT AREACCURATE;
• 2). TO CONSERVE JUDICAL RESOURSES THAT ARE CURRENTLY BEINGWASTED AND INAPPROPRIATELY PLEADED "LOST NOTE' COUNTS &INCONSISTANT
ALLEGATIONS;
3).TO PREVENT THE WASTING OF JUDICAL RESOURCES AND HARM TODEFENDANT'S RESULTING FROM SUITS BOUGHT BY THE PLAINTIFF'S NOT ENTITLEDTO
ENFORCE THE "NOTE"; AND
4).TO GIVE TRIAL COURTS GREATER AUTHORITY TO SANCTION PLAINTIFF'SWHO MAKE "FALSE" ALLEGATIONS...
12). SINCE THE ENACTMENT OF THE AMENDMENT, MANY COMPLIANTS HAVE BEENFILED WHERE THE VERIFICATION WAS EITHER A WHOLLY SEPERATE FILED
PLEADING, OR IT WAS A STAND-ALONE SECTION ON THE LAST PAGE OF THECOMPLIANT.
CIVIL COURTS IN MANYJUDICAL CIRCUITS HEARD "MOTIONS" TO"DISMISS'BECAUSE THE PLACEMENT OF THE VERIFICATION IN ONE OF THESE TWOPLACES
DID NOT INSURE THAT THE PURPOSE OF THE AMENDMENT WAS MET.
MANY COURTS SIGNED'ORDERS'DISMISSING THESE COMPLIANTS AND INFACT, CONCLUDED THAT THE "VERIFICATION"SHOULD BE PROPERLY BE
PLACED BETWEEN THE LAST PARAGRAPH OF THE COMPLIANTAND THEATTORNEY'S SIGNATURE BLOCK.
THE PLAIN LANGUAGE OF RULE 1.110(B) MORE THAN SUPPORTS THATTHE VERIFICATION MUST BE WITHIN THE COMPLIANTITSELF WHERE THE RULE
STATES," [WJHEN "VERIFICATION" OF A DOCUMENT IS REQUIRED, THEDOCUMENT FILED SHALL INCLUDE AN OATH, AFFIRMATION, OR THE FOLLOWING
STATEMENT."
(EMPHSIS ADDED)COPIES OF SOME OF THESE ORDERS ARE ATTACHED HERETO, INGLOBO, AS EXHIBIT " ".
13). THE LANGUAGE IN JUDGE COX'S FINAL ORDER OF "DISMISSAL" 2 WHICH IS CONTAINEDIN EXHIBIT " "lS USEFUL AS A GUIDE AND ILLUSTRATION. AFTER DISCUSSING THESUPREME
COURT'S PPURPOSE FOR THE CHANGETO RULE 1.110 (B) JUDGE COX STATES;
THE "VERIFICATION" MUST BE INCLUDED IN THE COMPLIANT ITSELF FOR THECOURT TO BE CERTAIN TNT THE AFFIANT HAS READ THE ACTUAL ALLEGATIONS AND MAKEIT CLEAR
WHAT IS BEING VERIFIED. THERE IS NO PROVISION IN THE RULE FOR THE FILING OF ASEPERATE VERIFICATION IN A SEPERATE DOCUMENT. COMMON SENSE DICTATES THATWITHOUT
VERIFICATION IN THE COMPLINT ITSELF, IT WOULD NEVER BE CLEAR WHAT THE AFFIANTREVIEWED AND WHAT ALLEGATIONS THEY VERIFIED....
14). IN ADDITION,THESE SAME ORDERS HAVE FURTHER REFINED THE VERIFICATIONREQUIREMENT BY DEMANDING THAT THE PLAINTIFF, AND NOT THE REPRESENTATIVE FROMA
NON-PARTY OR "AGENT'OF THE PLAINTIFF,VERIFY THE FACTS ALLEGED IN THES COMPLIANT. AS JUDGE HOLCOMB STATES IN HIS "ORDER'GRANTING DEFENDANT'S
"MOTION TO DISMISS' ATTACHED HERETO EXHIBIT "E"
HENRY TRAWICK MAKES IT CLEAR THAT "VERIFICATION"MEANS THAT THEVERIFYING "PARTY"( EMPHASIS IN "ORIGINAL") ATTESTS THAT THE FACTS ALLEGED IN THE
COMPLIANT ARE TRUE. TRADWICK'S FLA. PRACTICE AND PROCEDURE SEC.6:14(VERIFICATION) BEVERETTE VS. GRAHAM , 131 SO. 2ND 826 , 8279 (FLA. 1931 )
BURNS VS. BURNS 174 SO. 2ND. 432, 434 (FLA. 2ND DCA 196. RULE 1.110 (B)DOES NOT SPECIFICALLY PROVIDE FOR OR ALLOW VERIFICATION TO[BEJMADE BY A
"NON-PARTY"SUCH AS A LOAN SERVICER OR AGENT OF THE PLAINTIFF.
15).THE "VERIFICATION' OF THIS COMPLIANT VIOLATES THE RULEAND SUBSEQUENT ORDERS IN SEVERAL WAYS
THE VERIFICATION APPEARS BE;OW THE ATTY.'S SIGNATURE, NOTINCOMPLIANCE WITH THE ABOVE-
1). THESE ARE TYPICALLYJUST ORDERS OF THE COURT ND ARE NOTPUBLISHED. ALTHOUGH NOT FOR PURPOSES OF PRECEDENCE ORDERS IN SEVERAL
PER SE'DEFENDANT HAS ATTACHED A NUMBER OF ORDERSADDRESSING THE PROPER METHOD FOR VERIFYING A COMPLIANT PURSUANT TOAMENDED
RULE 1.110(B).
2). BANK OF AMERICA N.A. VS.NEBRASKA INVESTMENTS, PENDING IN THECIRCUIT COURT OF THE 19TH. JUDICAL CIRCUIT IN & FOR INDIAN RIVER COUNTY, FL.
CASE NO. 10-CAA-3882 (JAN. 24, 2010).
3).PNC BANK NATIONAL ASSOCIATION VS.KATHLEEN PECKHAM ET.AL,PENDING IN THE CIRCUli COURT OF THE 18TH JUDICAL CIRCUIT IN & FOR BREVARD
COUNTY,FLORIDA, CASE NO.05-CA-33741(JAN.14, 2011).MENTIONEDORDERS. THE PAGE WHERE VERIFICATION APPEARS CONTAINS NO INFORMATION
CONNECTINGVERIFICATION TO THE ACTION. THEREFORE IT IS UNCLEAR IFMS. JOANNE DINARDI HAD REVIEWED THE REST OF THE COMPLIANT OR HAD ANY
KNOWLEDGE OF THE PRESENT ACTION OR FACTS TO WHICH SHE WASVERIFYING. ASSUMING MS. JOANNE DINARDI KNEW SHE WAS VERIFYING AMORTGAGE
FORECLOSURE COMPLIANT, AND SHE HAD READ THE COMPLIANT AND WASABLE TO VERIFY THEREIN, SHE HOLDS POSITION OF IN CHARGE OF BOOKS AND IN
CONTROL OF PAYMENTS, TAXES & INSURANCE, FOR G.R.P.LOANS L.L.C.
ATTORNEY, IN FACT FOR THE PLAINTIFF, NOT WITH THE PLAINTIFFITSELF.THE COMPLIANT FAILS TO OFFER ANY EVIDENCE SPECIFICALLYAUTHORIZING.
IT'S ATTORNEYIN FACT, OR SOMEONE IN THE POSITION OF THE "CONTRACTMANAGEMENT COORDINATOR" FOR PLAINTIFF'S ATTORNEY-IN-FACT,
TO VERIFY ANY DOCUMENT.
THEREFORE,THE COMPLIANT ISINVALID DUE TO INSUFFICENT VERIFICTION......
16).FLA. STA TUE 865,09 (9)(A) G.R.P. LOANS L.L.C.[NEVER] EXISTED IN FLORIDA
THE "FICTITOUS' NAME ACT"STATES:
IF A BUSINESS FAILS TO COMPLYWITH THIS SECTION, THE BUSINESS, IT'S MEMBERS, & THOSE
INTERESTED IN DQING SUCH BUSINESS MAY NOTMAINTAIN ANYACTION, SUIT, OR PROCEEDING IN ANY
COURT OF THIS STATE UNTIL THIS SECTION ISCOMPLIED WITH.
• AN ACTION, SUIT, OR PROCEEDING MAY NOTBE MAINTAINED IN ANY
COURT OF THIS STATE OF'FLORIDA" BY ANY
""SUCCESSOR",OR "ASSIGNEE" OF SUCH BUSINESS ONANY
RIGHT, CLAIM, DEMAND ARISING OUT OF THIS THISTRANSACTIONS OF BUSINESS BY SUCH BUSINESS IN THIS STATE OF;
"FLORIDA."UNTIL THIS SECTION IS COMPLIED WITH.
17).AS STATED ABOVE,A SEARCH UNDER "G.R.P. LOANS L.L.C."
THRU "O.F.R."EXHIBIT OFFICE OF FINANCIAL REGULATIONS &WEBSITE FOR THE
FLORIDA DEPARTMENT OF STATE DIV. OFCORPORATION RETURNS A RESULT SHOWINGUNDER RULE 494
"PLAINTIFF' G.R.P. LOANS L.L.C. WAS AN"ENTITY" I'CORP. WAS NEVER A "FLA." ENTITY....
G.R.P. LOANS L.L.C.IS A'DELAWARE' ENTITY, &HAS"NO" STANDING IN THIS COMPLIANT: 51-08-CA-5736 WS/J2...
HOWEVER, PARAGRAPH "__"OF THE COMPLIANTSIMPLY STATES "PLAINTIFF" IS NOW THE OWNER AND HOLDER OFTHE
"NOTE" &'MORTGAGE' BY VIRTUE OF THEASSIGNMENT.
WITH THIS LITTLE AMOUNT OF INFORMATION ABOUTTHE PLAINTIFF SHOWN IN THE COMPLIANT, PLAINTIFF HAS FAILED TO ALLEGESUFFICIENT
FACTS FOR THIS COURT AND THE DEFENDANT TO KNOW IN WHAT
"JURIDICTION" G.R.P. LOANS L.L.C. IS "DELAWARE"DOMICILED.
THEREFORE,lT ISUNCLEAR WHETHERPLAINTIFF "G.R.P. LOANS L.L.C." HAS "SUFFICIENT"
STANDING TO MAINTAIN THIS ACTION BEING A"DELAWARE" ENTITY & (NOT FLA.) STAT. 865.09 "FACELESS'PLAINTIFF.
RELEASEOF LIS PENDIS
1). PURUANT TO SECTION48.23, FLA.STATUE (2010) AND RULE1.420(F) FLA. RULE OF CIVIL PROCEDURE
PLAINTIFF'S "NOTICE OF LIS PENDIS" MUST BERELEASED, OR "DISOLVE" UPON "DISMISSAL" OF THE
COMPLIANT; RULE 1.420 (F).AS FOLLOWS;
EFFECT ON LIS PENDIS HAS BEEN FILED IN CONNECTION WITH A CLAIM
FOR AFFIRMATIVE RELIEF THAT IS'DIMISSED'.UNDER THIS RULE, THENOTICE OF LIS PENDISCONNECTED WITH THE "DIMISSED" CLAIM IS
AUTOMATICALLY"DISSOLVED"@ THE SAME TIME.
THE NOTICE, STIPULATION, OR ORDER SHALL BE RECORDED.
WHEREFORE, DEFENDANT, MARGETTA LANGLOIS "PRO.SERESPECTFULLY REQUESTS THAT THIS HONORABLE COURT
ENTER ORDERS; ON (ALL) DEFENDANT'S (" 8") MOTIONS..
RESPECTFULLY SUBMITTED,MARGETTA LANGLOIS PRO.SE'P.O.BOX 3091 HOLIDAY, FLA.34692
(727) 326-3629...
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CERTIFICATE NO. Il-E-146
August 5. 2011
... CERTIFICATE
1. the undersigned. Custodian of the Records. State of Florida, Omce of Financial Reguhelen, do
hereby certify.
The Office of Financial Regulation issues all licenses to conduct business in the State ofFlorida
under the provisions of Chapter 494. Florida Statutes. A diligent search of the6
reveals that it ha record of licensure, tader the WS of®ermnó StaWJWt LLc or one Loans LLC.
A diligent search of the records of the OMce reveals that it has record of licensure, under the
provision ofChapter 494. Florida Statutes, for the following entities:
Select Portfolio Servicing Inc.; License • MLO701204Active License 9/29 2005 - Present
DLJ Mortgage Capital lac; License a MLO701349 AUG $ $1 3 2011 A ve License 6/6:2007 - Present
/Af3 y ) e
commeufn GRP Financial Services Corp; License a MLO701 I SActive License 6/10/2004 -2/8'2010
Liceese Terminated on 2/8 2010&*M 3%/0/4f
IN TESTIMONY WHEREOF,1 hereto subscribe my name and affix the seal of my off ce to
certificat No. I l-F-146. at Tallahassee, the day and year first above written.
Brian Hermeling
OMce of Emancial Regulation
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OUTLINE ON CASE/APPEAL W/ "DOCKET"ON (2) L.T. CASES & TO BE FILED ON EACH APPEAL;
51-08-CA- 5736 WS/ J2 "MORTGAGE-FRAUDCLOSURE"
BRANCHED OFF INTO
51-11-CA-2859 WS/ H "INSURANCE-FRAUD"
I, DEF. MARGETTA LANGLOIS PRO.SE' WAS
(NEVER) "SERVED" & WAS (NEVER) IN FORECLOSURE IN;
1). L.T.CASE; 51-08-CA-5736 WS/J2JUDGE (S) ; STANLEY MILLS 7/15/08 - 12/31/10
WALTER SHAFER JR. 1/24/11 - PRESENT
MOTION TO "REVERSE" 8. "DISMISS" (WHOLE)
"MORTGAGE-FRAUD-CLOSURE" FOR;
("INSURANCE-FRAUD".BRANCHED OFF THIS CASE)& NOW
"GRANT" "FULL"FINAL SUMMARY JUDGEMENT
(ATTACHED)
IN FAVOR OF DEF. MARGETTA LANGLOIS PRO.SE'
G.R.P. LOANS L.L.C.(EXHIBIT "A")
"NO" PLAINTIFF, G,R,P.(NEVER)EXISTED IN FLA.
2). THEREFORE, ".N_O" CASE (LEGAL)
'NO"FLA.JURISDICTION....,
3). "N_O" G.R.P. LOANS L.L.C, (LEGAL IN FLA.)
4). ATTY. AMY MC GROTTY HAD "N_Q" CLIENT a
(ILLEGALLY) FORECLOSED ON;;
5). MARGETTA LANGLOIS PRO.SE'S HOME,
FOR "lNSURANCE-FRAUD" TO "EXTORTION"
6).FOR MARGETTA LANGLOIS'S HER_
4/12/05 "TOTAL-LOSS" OF HER HOME ON HER
"INSURANCE-CLAIM" ONLY LANGLOIS
"BENEFICIARY" ON 4/12/05 POLICY
BY;
7). ("3")JUDGES;MILLS, SHAFER, & BRAY
CREATED A
"GROSS" MISCARRIAGE OF JUSTICE FOR;
DEF. MARGETTA LANGLOIS W/
"N_Q" PRODUCTION OF DOCUMENTS EXISTS
W/ "NON-EXISTING" G.R.P.LOANS L.L.C.
8).THESE (2) JUDGES;RE; "MORTGAGE-FRAUD-CLOSURE"
HAVE BEEN "BIAS," "PREJUDICE,"& "DISCRIMINATING,"
AND FILED (6+ ) FRAUD/ ILLEGAL ORDERS
AGAINST DEF.MARGETTA LANGLOIS PRO.SE'
TO "STOP"FILING "EXCULPATORY" EVID.
ON PUBLIC RECORD TO VIEW BY PUBLIC."NO" OTHER
(LEGAL) OTHER PARTIES IN EITHER CASES. ONLYLEGAL/ ONLY LIVE STANDING PERSON IN THIS SUIT FROM
"PREVAILING" JUSTICE.(ATTACHED DOCKET).
9). (3 ) JUDGE'S HAVE "OBSTRUCTED-JUSTICE"
( FOR (ONLY) LEGAL PARTY IN (2) CASES;
DEF. MARGETTA LANGLOIS PRO.SE')
(W/ "CRIMINAL") "INTENT TO DEFRAUD," DEF.
MARGETTA LANGLOIS PRO.SE' BY;
(3) JUDGES,(7+) ATTY.'S.W/ "NO" (LEGAL) CLIENTS
10)). FIRST OF ALL, THERE IS "NO" "FORECLOSURE" CASE
BY ATTY. AMY MC GROTTY;
(ILLEGALY) 7/15/08 (FILED),
& (ILLEGALLY) 7/14/07 (PREVAILED)
11). THERE IS ("NO") PLAINTIFF "NO" G.R.P. LOANS L.L.C.
"NO" FLORIDA ENTITY (LEGAL)
(EXHIBIT "A")
PRIOR MORTGAGE CO/ ENTITY "FREEMONT" WAS
(NEVER) A FLORIDA "ENTITY"
THEREFORE COULD (NEVER) LEAVE G.R.P. AS A
(LEGAL) "SUCCESSOR"
A DEL/ & N.Y. ENTITY (NONE) LEGALIN FLA.
TO DO BUSINESS/ &W/ "NO" (LEGAL) CAPACITY TO SUE IN ANY
FLA. COURT ...
MOTION TO DISMISS 'NON EXISTING" PLAINTIFF'S
G.R.P. LOANS L.L.C.
"MORTGAGE-FRAUD-CLOSURE
JUDGE'S ARE VERY FAMILIAR
NOW W/ THESE FLA.LAWS;
12).BASED ON FLA. CIVIL PROCEDURE RULE 1.120 (A)&
FLA. STATUE LAW 865.09 "FACE-LESS"PLAINTIFF/DEF.
13). G.R.P. LOANS L.L.C. HAD "NO"(LEGAL) CAPACITY TO SUE
14). G.R.P. LOANS L.L.C. WAS (NEVER) LEGALLY
LICENSED/ REGISTERED W/ O.F.R.TALLAHASSEE, FLA.
15). THEREFORE, G.R.P. LOANS L.L.C.COULD (N_QTJ LEGALLY
PURSUIT &/ OR PREVAIL IN ANY FLA. COURT &
(ALL) JUDGES HAVE VERY GOOD "KNOWLEDGE".
16). THEREFORE, D.L.J. MORTGAGE CAPITAL INC.lS;
"NO"(LEGAL) DEF.'S, CROSS, X-PARTE', COUNTER
"NO" PLAINTIFF'S, "NO" FLA. CLIENTS FOR FLA. ATTY.'S.
17). WHEREAS, G.R.P. LOANS L.L.C.(NEVER-EXISTED IN FLA.
LEAVES "NO" OTHER (LEGAL) "SUCESSORS"/ "ASSIGNEES"
THEREFORE, ("NO") D.L.J. MORTGAGE CAPITAL INC.(LEGAL)
IN FLORIDA (EXHIBIT "B").
18).NEITHER L.T. CASES (LEGAL)
19). (3) JUDGES MILLS, SHAFER & BRAY BROKE THE FLA. LAWS;
W/ "NO' PLAINTIFF G.R.P. LOANS L.L.C.IN MORTGAGE-FRAUDCLOSURE
W / "NO" DEF.'S. IN "INSURAANCE-FRAUD"
"CONSPIRED", "COLUTED," "COLABERATED",
BY "COURT-CORRUPTION" & "COVER-UP" ,
"AIDED," & "BETTED," "FRAUD," "FORGERIES," & "PERJURY'
OF ("7+") ATTY.'S W/ "NO" CLIENT'S
(TRANSCRIPTS" ATTACHED).
20). PROOF OF ("CRIMINAL," / "lLLEGAL" )
JUDICAL MISCONDUCT BY ("3") JUDGES ;
MILLS., SHAFER, & BRAY'S "TRAVESTY" &
MAKING A "MOCKERY" OF THE COURT....
TO COMMIT (CRIMINAL) FELONY
"COURT-CORRUPTION"
• W/ "N_O" G.R.P. LOANS L.L.C.,(EXHIBIT "A')
• W/ "NO" D.L.J. MORTGAGE CAPITAL INC.(EXHIBIT "B").
PROVEN BY ALL ("6") ILLEGAL/ FRAUD COURT ORDERS
TO "OBSTRUCT" JUSTICE
FOR DEF/ APPELLANT, MARGETTA LANGLOIS PRO.SE'
(3) JUDGES ; MILLS, SHAFER JR, & BRAY JR.To CONDONE (ILLEGAL) NON-EXISTING PARTIES TO BE
ILLEGALLY, "GRANDFATHERED" IN TO "CLOSE"
G.R.P.'S MORTGAGE-FRAUDCLOSURE.
51-08-CA-5736 WS/J2&
51-11-CA-2859 WS/H BRAY TO;
"SWINDLE" ME A 64 YR. OLD OUT OF MY 4/12/05
INS. CLAIM I ONLY "ENTITLED" TO 4/1/05
W. INTENT TO DEFRAUD ME.
21). ALSO BY "EXTORTION" BY JUDGE LOWELL BRAY JR. FOR;
ATTY. ADAM LEICHTLING W/
"NO" NOTICE OF APPEARANCE ON RECORD
51-11-CA-2859 WS/ H W/ "NO" CLIENT
"NO" D.L.J. MORTGAGE CAPITAL INC.
"NO"• ONLY (LEGAL) DEF. IS MARGETTA LANGLOIS PRO.SE'S
• ENTITLEMENT TO;
4/12/05 SINKHOLE INS. CLAIM ON TOTAL-LOSS 4/12/05 OF HER
HOME.
22). THESE (3) JUDGES & (7+) ATTY.'S "EMBEZZELED" MY HOME(ILLEGLLY)
23). THESE (3) JUDGES & (7+) ATTY.'S "EXTORTED' MY 4/12/05 INS. CLAIM
W/ "NO" ("9") NON-FLA. ENTITIES,
CREATED ME 'LOSS' OF EVERYTHING IN LIFE, ALL MY PARTIAL MONIES,ON
A PRIOR HOUSE SALE I AM STILL OWED MORE MONIES NEVER PAID INFULL
& NOw (3) JUDGES OBSTRUCTING JUSTICE
I AM (ILLEGALLY) FRAUD ORDERS (3) JUDGES HAVE STOPPED ME
FROM
FILING'EVIDENCE" & FOR TRIAL BY JURY ONCOUNTERCLAIMS
ON (2) CASES
ILLEGALLY BY SAME (3) JUDGES TOPURSUIT .
I LOST EVERYTHING ; (5) YRS. BACK S.S. WIDOW' BENEFITS,
MONIES FROM IMPLANT CLAIM OVER $60,000.DEP. + TOTAL INTHIS
(ILLEGAL) MORTGAGE-FRAUD CLOSURE W/
"NO' OTHER PARTIES (LEGAL).
"ENORMOUS" HARDSHIP. "
UNNECESSARY "HOMELESSNESS" "
(7+) ATTY.'S W/ "NO" CLIENTS
& (3) JUDGES HAVE "N_O" DEFENSE.'
APPEAALS COURT JUDGE'S ARE VERY WELL
AWARE OF THIS "COURT-CORRUPTION," TO FIND ANY
(ILLEGAL EXCUSE TO "DISMISS" MY APPEALS BUT I
HAVE (ALL) THE "EXCULPAATORY-EVID,' FOR;
THIS CASE MUST BE "OVERTURNED"
&ALLOTHERSCASES/APPEALS
MUST "GRANTED" IN FAVOR OF APPELLANT,
MARGETTA LANGLOIS PRO.SE'
FOR HER "FULL" SUMMARY IN ("2") ILLEGAL
L.T, CASES;
DUE TO "NO" OTHER PARTIES (LEGAL).
1. MARGETTA LANGLOIS SIGN UNDER THE PAINS & PENALTIES
OF PERJURY ALL IS THE "TRUTH", WI "EVIDENCE" TO BACK IT UP.
WHAT DO THEY HAVE "NOTHING" til
MARGETTA LANGLOIS PRO.SE' P.O.BOX 3091 HOLIDAY, FLA. 34692
(727) 326-3629
CERTIFICATE OF SERVICE
I, MARGETTA LANGLOIS DO HEREBY CERTIFY ON
THIS DAY OF 2012 SENT BY
F . BAR; (7+) ATTY.'S W/ "NO'CLIENTS'NO'CASES
Y FAX (941) 906 -6851 SENT TO ;ATTY. REBECCA LEVY
& ATTY. CHRISTOPHER KAISER.(W/'INTENT TO 'DEFRAUD'THEIR OWN 4/12/05 INSURED)
"REFUSED' TO PAY 4/12/05 MARGETTA LANGLOIS PRO.SEIN "FULL" ......
(305) 569-0000 SENT TO ;
ATTY. ADAM LEICHTLING W/ "NO" CLIENTA NILDA A. ARROYOVA W/ "NO" CLIENT _.
TGAGE FRAUD/ CLOSURE -FOR INS.-FRAUD"
FAX (813) 443-5089 SENT TO : è in
ATTY. AMY MC GROTTY W/"NO" CLIENT aATTY. MICHELLE GARCIA GILBERT " " n
ATTY. LAURA WALKER W/"NO" CLIENTORTGAGE-FRAUD/CLOSUREFOR INS. FRAUD
FAX (813) 433-5353 SENT TO :
'ERWIN'@ SUNRAYE REALTORS(ILLEGALLY)'SOLD'MYHOME 7/27/11W/"OPEN"
CASE, APPEALS,& IN 'LITIGA TION" W/ "NO" LEGALRIGHTS TO "SELL" I WAS NEVER IN "FORECLOSURE".TO OTHERS IN CIVIL SUITS,
O.F.R. BANKING & FINANCING *INS-FRAUD"
Brief on jurisdiction
Brief on jurisdiction
. . 'Once d t
llS, 505 F2d 1026. "There is no discretion to ignore that lack ofjurisdiction." Joyce v. US, 474 F2d215. "The burden shifts to the court to prove jurisdiction." Rosemond v. Lambert, 469 F2d 416."Court must prove on the record, all jurisdiction facts related to the jurisdiction asserted." Lantana v.Hopper, 102 F2d 188; Chicago v. New York, 37 F Supp 150. "A universal principle as old as the lawis that a proceedings of a court without jurisdiction are a nullity and its judgment therein withouteffect either on person or property." Norwood v. Renfield, 34 C 329; Ex parte Giambonini, 49 P. 732."Jurisdiction is fundamental and a judgment rendered by a court that does not have jurisdiction to hearis void ab initio." In Re Application of Wyatt, 300 P. 132; Re Cavitt, 118 P2d 846. "Thus, where ajudicial tribunal has no jurisdiction of the subject matter on which it assumes to act, its proceedingsare absolutely void in the fullest sense of the term." Dillon v. Dillon, 187 P 27. "A court has nojurisdiction to determine its own jurisdiction, for a basic issue in any case before a tribunal is itspower to act, and a court must have the authority to decide that question in the first instance." RescueArmy v. Municipal Court ofLos Angeles, 171 P2d 8; 331 US 549, 91 L. ed. 1666, 67 S.Ct. 1409. "Adeparture by a court from those recognized and established requirements of law, however closeapparent adherence to mere form in method of procedure, which has the effect of depriving one of aconstitutional right, is an excess ofjurisdiction." Wuest v. Wuest, 127 P2d 934, 937. "Where a courtfailed to observe safeguards, it amounts to denial of due process of law, court is deprived ofjuris,"Merritt v. Hunter, C.A. Kansas 170 F2d 739. "the fact that the petitioner was released on a promise toappear before a magistrate for an arraignment, that fact is circumstance to be considered indetermining whether in first instance there was a probable cause for the arrest." Monroe v. Papa, DC,Ill. 1963, 221 F Supp 685. -
And, you may find this interesting as well: , _...
"An action by Department of Motor Vehicles, whether directly or through a court si radministratively as the hearing officer, must be clearly defined in the statute before i bj Tmatter jurisdiction, without such jurisdiction of the licensee, all acts of the agency, b }t£empiãyeeagents, hearing officers, are null and void." Doolan v. Carr, 125 US 618; City v Pearso3j 181 Oal,640. "Agency, or party sitting for the agency, (which would be the magistrate of a munipipal coirt)has no authority to enforce as to any licensee unless he is acting for compensation. SuclGn act is 7highly penal in nature, and should not be construed to include anything which is not embraced withinits terms. (Where) there is no charge within a complaint that the accused was employed forcompensation to do the act complained of, or that the act constituted part of a contract." Schomig v.Kaiser, 189 Cal 596. "When acting to enforce a statute and its subsequent amendments to the presentdate, the judge of the municipal court is acting as an administrative officer and not in a judicialcapacity; courts in administering or enforcing statutes do not act judicially, but merely ministerially".Thompson v. Smith, 154 SE 583. "A judge ceases to sit as a judicial officer because the governingprinciple of administrative law provides that courts are prohibited from substituting their evidence,testimony, record, arguments, and rationale for that of the agency. Additionally, courts are prohibitedfrom substituting their judgment for that of the agency. Courts in administrative issues are prohibitedfrom even listening to or hearing arguments, presentation, or rational." ASIS v. US, 568 F2d 284."Ministerial officers are incompetent to receive grants of judicial power from the legislature, their actsin attempting to exercise such powers are necessarily nullities." Burns v. Sup. Ct., SF, 140 Cal. 1."The elementary doctrine that the constitutionality of a legislative act is open to attack only by
-:.-.:~. =rmrwiuris brief.htm 9/4/201
Page2of2
persons whose rights are affected thereby Ivalidity of which may not be called into , app ies to statute relating to administrative agencies, theactual or impending, to a legally protecteduentt nst di ctibsence of a showing of substantial harmstatute." BoardofTrade v. Olson, 262 US 1; 29 ALR 2d 05esu ting from the enforcement of the
Text Version
IN THE CIRCUIT COURT FOR THE 6TH. JUDICAL CIRCUITIN & FOR PASCO COUNTY PASCO, FLORIBN(34656)
MONDAY APRIL 16TH, 2012
51-08-CA-5736 WS/ J2
JUDGES' STANLEY MILLS 7/15/08-12/31/10 &WALTER SHAFER JR.1/24/11-PRESENT
G.R.P. LOANS L L.C.
MARGETTA LANGLOIS 'PRO.SE'
DEFENDANT'S MARGETTA LANGLOIS PRO.SE'S
MOTIONTO "DISMISS" PLAINTIFF'S COMPLIANT,7/15/08 MOTION TO"DISMISS" FINAL SUMMARY JUDGEMENT 3/13/09MOTION TO "DISOLVE" LIS PENDIS 7/08 MOTION TO "DISMISS"FORECLOSURE 7/14/09MOTION TO "DISMISS" CERTIFICATE OF SALE 7/14/09 MOTION TO "DISMISS"CERTIFICATE OF TITLE 10/8/09 ANDMOTION TO "DISMISS" D.L.J. MORTGAGE CAPITAL INC.'SALE'7/27/11
NOW COMES DEF. MARGETTA LANGLOIS 'PRO.SE;'PURSUANT
TO SECTION 48.23 FLA. S TA T.(2010) AND RULES 1.110 (B)AND 1.130(A) OF THE FLA. PROCEDURE, AND FL. STATUE865.09 (9)(A)
UNDER FLA CIVIL RULES OF CIVIL PROCEDURE 1.120(A).G.R.P. LOANS L.L.C.lS A'DELAWARE' ENTITY
UNDER FLA. STATUE RULE 865.09 G.R.P.LOAANS L.L.C.
m consutuuon : y new statutes : Unline Sunshine Page 1 of I
setect Year: 2011 • Tl
The 2011 Florida Statutes
Title XLVI Chapter 865 View Entire Chaoter
CRIMES VIOLATIONS OF CERTAIN COMMERCIAL RESTRICTIONS
865.09 Fictitious name registration.-(1) SHORT TITLE.-This section may be cited as the "Fictitious Name Act."
(2) DEFINITIONS.-As used in this section:
(a) "Fictitious name" means any name under which a person transacts business in this state, otherthan the person's legal name.
(b) "Business" means any enterprise or venture in which a person sells, buys, exchanges, barters,deals, or represents the dealing in any thing or article of value, or renders services for compensation.
ic) "otvision" means the Division of Corporations of the Department of State.(3) REGISTRATION.-A person may not engage in business under a fictitious name unless the person
first registers the name with the division by filing a sworn statement listing:
- (a) The name to be registered.
. ...y (b) The mailing address of the business.(c) The name and address of each owner and, if a corporation, its federal employer's identification
number and Florida incorporation or registration number.(d) Certification by the applicant that the intention to register such fictitious name has been
advertised at least once in a newspaper as defined in chapter 50 in the county where the principal placeof business of the applicant will be located.
(e) Any other information the division may deem necessa'ry to adequately inform other governmental
agencies and the public as to the persons so conducting business.
Such statement shall be accompanied by the applicable processing fees and any other taxes or penalties
owed to the state.(4) CHANGE OF OWNERSHIP.-if the ownership of a business registered under this section changes,
the owner of record with the division shalt file a cancettation and reregistration that meets therequirements set forth in subsection (3) within 30 days after the occurrence of such change.
(5) TERA -A fictitious name registered under this section shall be valid for a period of 5 years andexpires on December 31 of the 5th year.
(6) RENEWAL-
(a) Renewal of a fictitious name registration shall occur on or after January 1 and on or before
December 31 of the expiration year, lJpon timely filing of a renewal statement, the effectiveness of the
name registration is continued for 5 years as provided in subsection (5).
(b) in the last year of the registration, the division shall notify the owner or registrant of the
expiration of the fictitious name. If the owner or registrant of the fictitious name has provided thedepartment with an electronic mail address, such notice shall be by electronic transmission.
http://www.leg,state.fl.us/statutes/index.cfm?mode=View%20statuteohu-'^" ~^^
GEOVERA SPECIALTY INSURANCECOMPANY f/k/a USF&G SPECIALTYINSURANCE COMPANY,
Plaintiff,vs.
MARGETTA LANGLOIS, GRP LOAN, LLC,and DU MORTGAGE CAPITAL, INC.,
Defendants./
IN THE CIRCUIT COURT OF THE6" JUDICIAL CIRCUIT IN AND FORPASCO COUNTY, FLORIDA
CASE NO.: 51-2011-CA-0028 WS
SECTION: H
FINAL JUDGMENT ANDORDF,R TO CI.F.R.K TO DISBURSE FUNDS FROM COURT REGISTRY
THIS CAUSE, having come on to be heard on August 30, 2012, on Defendant DU
Mortgage Capital, Inc.'s Motion for Summary Judgment on its Claim/Cross-Claim to
Interpleader Funds, and the Court, having heard argument of counsel and of pro se Defendant
Margetta Langlois, and otherwise being advised in the premises, it is hereupon
ORDERED AND ADJUDGED that:
1) Defendant DU Mortgage Capital, Inc.'s Motion for Summary Judgment on itsClaim/Cross-Claim to Interpleader Funds is GRANTED. pc
2) Defendant GRP Loan, LLC, 12061 Bluemont Way, A 190, which wasdefaulted in this action on August 30, 2011, shall take action.
3) Defendant Margetta Langlois, P.O. Box 3091, Holiday, Florida 34692, shall takenothing by this action.
4) DLJ Mortgage Capital, Inc., 3815 S. West Temple, Salt Lake C 115, isdue $181,281.16 from Margetta Langlois as the amount of the of themortgage loan executed by Margetta Langlois that was not recouped timough theforeclosure sale in Pasco County Circuit Court Case No. 51-2008-CA-005736-WS,plus interest at the rate of 4.75% since July 14, 2009, which sum shall bear interest atthe rate of 4.75% a year, for which let execution issue.
CASE NO.: 51-2011-CA-002g59-W8
5) The Clerk of the Court is hereby ordered to immediately distmrse the full amount heldin the Court Registry in this action to DU Mortgage Capital, Inc., in partialsatisfaction of DU Mortgage Capital, Inc.'s deficiency judgment against ManganaLanglois, The Clerk shall mail the disbursement check to DU Mortgage Caplant,Inc.'s counsel, Adam B, IAichtling, Esq. at Lapin & Leichtling, LLP,255 Alhambra Circle, Suite 1250, Coral Gables, Florida, 33134.
6) DU Mortgage Capital, Inc. is entitled to mcover its reasonable attorneys' fees andcosts in this action against Margetta Langlois, and the Court reserven jurisdiction todetermine the amounts of reasonable attorneys' fees and costs so awardable.
DONE AND ORDERED in Chambers at Pasco County, Florida this day of
, 2012. ÓRIGINAL SIGNED
SEP 0 6 202CIRCUIT COURT JUDOR towm nmy
ora*Mee
Copies furnished to:
Adam B, Leichtling, Esq.Lapin & Leichtling, LLP255 Alhambra CircleSuite 1250Coral Gables, Florida 33134Attorneysfor Defendant DLJ Mortgage Capital, Inc,
Margetta LangloisP.O. Box 3091Holiday, Florida 34692Pro se Defendant
ORP Loan, LLC12061 Bluement WayReston, VA 20190
Page 2 of 2
--- quevu vu4
STATE OF UTAþi
LacuenemGo raor
OEFARTHENT OFFinAnciAt
insnTeriousC. Edward Leary
CommmewMirksel L Josts
on c - n
FAX COVER SHEET
liver
Fax Number 7 -1 A'])
From:
Total number of pages including this cover sheet:
ADDITIONAL MESSAGE
If you do not receive all the pages, please call (80 l)S38-8830
Meilleg Addetss - P.O. Bes 146906 • Seit Lake Citytiteh 84t l4-6800 - DMce Address - 324 South Stase. Suite 208 • Seit Lake City, thah 84111-2393 •Telephone (801)$38-8830 • Fax(801)338-8894 • wwwdlareAgov
STATE OF UTAH
DuAanum orFmanenAL
lusTmmonsa r.d..rd i.e.ry
Mich=ss L. Jewown..,•wa. Paul Anred
o,p,,,ca..,w....
Øctober 2, 2012
To Whom It May Concern:
The Utah Departrnent of Financial Insti_ttutions_docs_not have record of D.L.L MortgageConsumer Credit Notification or a First R_endagiaLMorgage
if you have any questions or concerns, please feel free to contact me at (801)538-8854.
Sincerely,
Merisa LanfoAdministrative Secretary
Maiang Address • P.O. Bos 146009•ssN Lake City, Utah 84114-6000 • oScc Address • 324 South state. Suise 201 • Salt 12ke City, Utah $4111-2393Telephone (801)338-8830 • Fax(801)538-8594 • wm41seekgav