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Memorandum in Support of The Motion To Dissmiss
Memorandum in Support of The Motion To Dissmiss
PLAINTIFF
V.
MIKHAIL LIPSKIY
DEFENDANTS
VALERY GURALNIK
MAYA GURALNIK
_______________________________________________________________________
VALERY GURALNIK
MAYA GURALNIK
COUNTER-PLAINTIFFS
V.
CITIBANK, N.A. AS TRUSTEE FOR
THE CERTIFICATE HOLDERS OF
STRUCTURED ASSET MORTGAGE
INVESTMENTS II, INC., BEAR
STEARNS ALT-A TRUST,
MORTGAGE PASS-THROUGH
CERTIFICATES SERIES 2006-4
COUNTER-DEFENDANT
________________________________________________________________________
MEMORANDUM IN SUPPORT OF MOTION TO DISMISS AND ORDER TO
DISMISS
________________________________________________________________________
Jury Demand on all counts
NOW COMES the above-named Defendants/ Counter - Plaintiffs,
VALERY GURALNIK, MAYA GURALNIK, MIKHAIL LIPSKIY in propria
persona, and hereby respectfully request to file MEMORANDUM
IN SUPPORT OF MOTION TO DISSMISS AND ORDER TO DISMISS
A party seeking to bring a case into court carries the
burden of establishing jurisdiction.
1
OF
8.
Why do
where servicer
Purchase-Payment of money
Delivery to depositor and Custodian as per PSA
Good faith
No knowledge of borrowers defense
It is equally obvious that the trust would have no
Respectfully submitted by
Defendant, In Propria Persona
BY: ______________________
VALERY GURALNIK
BY: __________________________
MAYA GURALNIK
BY: ______________________
MIKHAIL LIPSKIY
Valery Guralnik__________________