UNITED STATES DISTRICT COURT

OF THE DISTRICT OF COLUMBIA

WELLS FARGO BANK N.A. (WFB)

as Trustee for Option OneMortgage Loan Trust 2005-2,
Asset-Backed Certificates, Series 2005-2
Plaintiff USDC of DC Case No.
V. (formerly Circuit Court of the City of Alexandria,
Movent: CASE NO. GV 2200- 2052 )
JANICE WOLK GRENADIER (JWG) JURY TRIAL DEMAND
15 W. Spring ST.
Alexandria, VA 22301
202-368-7178
jwgrenadier@gmail.com
Defendant - Pro Se

COUNTERCLAIM CROSS COMPLAINT /

CRIMINAL COMPLAINT

MOVENT:
JANICE WOLK GRENADIER (JWG)
Defendant

V.

WELLS FARGO BANK N. A. (WFB)

as Trustee for Option OneMortgage Loan Trust 2005-2,
Asset-Backed Certificates, Series 2005-2
420 Montgomery Street
San Francisco, CA 94104
888-878-5865

CEO CHARLES W. SCHARF

WELLS FARGO N.A.
420 Montgomery Street,
San Francisco, CA 94104

OCWEN LOAN SERVICING LLC aka PHH MORTGAGE (NMLS# 2726)

aka OCWEN MORTGAGE SERVICING, INC. (OCWEN/PHH)
Ocwen Financial Corporation, NMLS#: 1849337 Ocwen USVI Services, LLC,
1661 Worthington Road #100
West Palm Beach, Fl 22409
(877) 226-2936

LEON COOPERMAN
Insider Trader of OCWEN/PHH Stock
7118 Melrose Castle Ln
Boca Raton, Florida, 33496

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S. MOHSIN REZA
TROUTMAN SANDERS LLP
(Greenberg Traurig LLP),
533 Great Falls St.
Falls Church, VA, 22046 / Falls Church City
mohsin.reza@troutman.com
202-274-1927

STEVE LEWIS
Leadership Partner Chair
TROUTMAN PEPPER HAMILTON SANDERS LLP
Registered Agent Office: Megan C. Rahman
1001 Haxall Pt Fl 15,
Richmond, VA, 23219 - 3944
steve.lewis@troutman.com
404-885-3448

ALLISON MELTON
929 Duke of Suffolk Dr.
Virginia Beach, VA 23454 / Virginia Beach City
allison.melton@troutman.com
757-687-7542

JOHN CURTIS LYNCH

TROUTMAN PEPPER HAMILTON SANDERS LLP
222 Central Park Ave, Ste 2000
Virginia Beach, VA 23462 / Virginia Beach City
757-687-7765
john.lynch@troutman.com

ANDREW BRIAN PITTMAN

TROUTMAN PEPPER HAMILTON SANDERS LLP
100 E. Ocean View Ave, Apt 1109,
Norfolk, VA 23503 / Norfolk City
andrew.pittman@troutman.com

MARY C. ZINSNER
TROUTMAN PEPPER HAMILTON SANDERS LLP
1100 Collingwood Rd,
Alexandria, VA 22308 / Fairfax County
mary.zinsner@troutmansanders.com

MYRA A. BENJAMIN
TROUTMAN PEPPER SANDERS LLP / CFPB / NIXON PEABODY LLP
2351 Eisenhower Ave, Aprt 2401
Alexandria, VA 22314 / City of Alexandria
Nixon Peabody LLP
799 9th St NW Suite 500,
Washington, DC 20001 / District of Columbia
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202-585-8738
Myra.Benjamin@troutman.com

BRIAN CAMPBELL
TRUSTEE SERVICES OF VIRGINIA LLC
aka BROCK & SCOTT PLLC
5431 Oleander Drive
Wilmington, NC 28403
Ph : 910-392-4988 x1206
Brian.Campbell@brockandscott.com

HOWARD BIERMAN
BWW LAW Group aka BIERMAN, (BWW) GEESING, WARD & Wood, LLC.
Aka EQUITY TRUSTEES, LLC
2101 Wilson Boulevard 402
Arlington, VA 22201
Phone: (703) 243-5903
howie.bierman@bww-law.com

AG JASON MIYARES
Attorney General's Office
202 North Ninth Street
Richmond, Virginia 23219
Phone: (804) 786-2071

Jane and or John Doe

DEFENDANTS aka (CC Defendants)

USDC of the DISTRICT OF COLUMBIA MOVED COMPLAINT AS DEFENDANT

WITH COUNTERCLAIM / CRIMINAL COMPLAINT By JWG
FOR CASE MOVED FROM THE CITY OF ALEXANDRIA CASE NO. GV 2200- 2052
CIVIL RIGHTS VIOLATIONS OF JANICE WOLK GRENADIER BY
THE CITY OF ALEXANDRIA & VIRGINIA COURTS

CASE IS BEING MOVED AFTER Janice Wolk Grenadier HAS HAD HER VIRGINIA and UNITED
STATES CONSTITUTIONAL RIGHTS DENIED BY THE VIRGINIA COURTS TO THE RIGHT TO
DISCOVERY AND WITNESS’s BY JUDGE SONYA L. SACKS

THIS VIOLATES JWG CIVIL RIGHTS UNDER Section 1983 which provides an individual the right
to sue state government employees and others acting "under color of state law" for civil rights
violations.

42 U.S. Code § 1983 - Civil action for deprivation of rights

Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or
Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or
other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities
secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or

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 other proper proceeding for redress, except that in any action brought against a judicial officer for an act or
omission taken in such officer’s judicial capacity, injunctive relief shall not be granted unless a declaratory
decree was violated or declaratory relief was unavailable. For the purposes of this section, any Act of
Congress applicable exclusively to the District of Columbia shall be considered to be a statute of the
District of Columbia.

18 U.S. Code § 242 - Deprivation of rights under color of law

Whoever, under color of any law, statute, ordinance, regulation, or custom, willfully subjects any person in
any State, Territory, Commonwealth, Possession, or District to the deprivation of any rights, privileges, or
immunities secured or protected by the Constitution or laws of the United States, or to different
punishments, pains, or penalties, on account of such person being an alien, or by reason of his color, or
race, than are prescribed for the punishment of citizens, shall be fined under this title or imprisoned not
more than one year, or both; and if bodily injury results from the acts committed in violation of this section
or if such acts include the use, attempted use, or threatened use of a dangerous weapon, explosives, or fire,
shall be fined under this title or imprisoned not more than ten years, or both; and if death results from the
acts committed in violation of this section or if such acts include kidnapping or an attempt to kidnap,
aggravated sexual abuse, or an attempt to commit aggravated sexual abuse, or an attempt to kill, shall be
fined under this title, or imprisoned for any term of years or for life, or both, or may be sentenced to death.

18 U.S. Code § 241 - Conspiracy against rights

If two or more persons conspire to injure, oppress, threaten, or intimidate any person in any State,
Territory, Commonwealth, Possession, or District in the free exercise or enjoyment of any right or privilege
secured to him by the Constitution or laws of the United States, or because of his having so exercised the
same; or

If two or more persons go in disguise on the highway, or on the premises of another, with intent to
prevent or hinder his free exercise or enjoyment of any right or privilege so secured—

They shall be fined under this title or imprisoned not more than ten years, or both; and if death results
from the acts committed in violation of this section or if such acts include kidnapping or an attempt to
kidnap, aggravated sexual abuse or an attempt to commit aggravated sexual abuse, or an attempt to kill,
they shall be fined under this title or imprisoned for any term of years or for life, or both, or may be
sentenced to death.

When Judge Sacks denied discovery she showed favoritism/BIAS and violated her
Professional code of ethics and violated her Judicial Canons of fairness. Judge Sacks
argued for the opposing side and protected them taking away “under the color of law” JWG
rights to a fair trial. Discovery enables the parties to know before the trial begins what
evidence may be presented. It's designed to prevent "trial by ambush," where one side doesn t
learn of the other side's evidence or witnesses until the trial, when there's no time to obtain
answering evidence. In this case even the Bill of Particulars did not break down the charges.
The opposing side lawyers know they own the system.

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That the State of Virginia took over 1 Billion dollars to allow the Banks, the Servicers and the
Lawyers to IGNORE THE LAW and the CONSTITUTIONAL RIGHTS OF HOMEOWNERS. This could
be and should be considered BRIBERY1 by the State of Virginia employees and or elected
officials who directly and or indirectly from the “pay-off”

That all Americans are equal as The Declaration of Independence included these three major
ideas: People have certain Inalienable Rights including Life, Liberty and Pursuit of Happiness.
All Men are created equal. Individuals have a civic duty to defend these rights for themselves
and others.

The United States Constitution then states under the due process right, established by the
Fourteenth Amendment, guarantees that the government cannot take a person's basic rights to
“life, liberty, or property, without due process of law.” The due process right is designed to
protect citizens from actions taken by state government, counties, towns, and cities.

The Fifth Amendment breaks down into five rights or protections: the right to a jury trial when
you're charged with a crime, protection against double jeopardy, protection against
self-incrimination, the right to a fair trial, and protection against the taking of property by the
government without compensation.

Janice Wolk Grenadier has been DENIED “under the color of law” thes basic Constitutional Rights.

THIS VERIFIED COMPLAINT / CROSS COMPLAINT

CRIMINAL COMPLAINT
IS BEING WRITTEN AS AN AFFIDAVIT OF TRUTH
BY JANICE WOLK GRENADIER
for Applicable Relief and Jury Trial on all Counts

THE COMPLAINT WILL SHOW THE ILLEGAL AND CRIMINAL COLLUSION OF

THE HEADS of BANKS OF 2008 WHO HAVE NOW MOVED TO THE HEADS SERVICERS
TO CONTINUE THE SCHEME OF THEFT OF HOMES FROM THE AMERICAN PEOPLE WITH NO
STANDING AND NO ABILITY TO SHOW STANDING EXCEPT WITH MADE UP DOCUMENTS
(INSIDERS OF OCWEN/PHH HAVE CONFIRMED THIS),
FORGED DOCUMENTS,
USE OF FAKE LAWYER NUMBERS ON ASSIGNMENTS,

1
The penalties for bribery of a public official includes a fine of up to three times the value of the bribe, and
imprisonment for up to 15 years in a federal penitentiary. A conviction can also disqualify the individual from
holding any office of honor, trust or profit under the United States.
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 Made UP ASSIGNMENTS, FALSE and MISLEADING ADVERTISING, the SALE OF SERVICING OF
FORECLOSED LOANS FOR FINANCIAL GAIN, THAT ONCE A LOAN IS FORECLOSED ON THE
LOAN IS NOT TAKEN OFF THE BOOKS - IT IS SOLD TO ANOTHER SERVICER, ET AL

THAT THE BANKS CO-MINGLED LOANS ON FINANCIAL STATEMENTS by all appearance & now
this accounting is being done by the SERVICERS/Lawyers as seen between OCWEN/PHH & NEWREZ
LLC

THE UNITED STATES SENATE

STATED TO JAMIE DIAMON ON FEBRUARY 2022 “ROBO SIGNING IS ILLEGAL” Exhibit A

THE UNITED STATES GOVERNMENT, THE STATE of VIRGINIA and ELECTED OFFICIALS are
aware of the issues of the Banks, Servicers and Lawyers ignoring the law and the Judges allowing it.

THE VIRGINIA AND FEDERAL CODES VIOLATED BY BANKS/SERVICERS AND LAWYERS:

FOR A HIGHLY SOPHISTICATED ORGANIZED CRIMINAL ENTERPRISE WITH THE KNOWLEDGE

INTENT TO ILLEGALLY FORECLOSE ON 15 W. Spring St., Alexandria, VA 22301
By using a FRAUDULENT “ AFFIDAVIT OF LOST ASSIGNMENT”
Forged Signatures and the Bar No. belongs to Tallahassee Judge Alexander
There was no standing for Brock & Scott to Foreclose and OCWEN told them not to (taped conv)

Signed by Leticia N. Aries as Vice President of Homeward and states (actual ROBO Signer for
OCWEN)

Leticia N. Arias signature on file with the Florida Notary;

Leticia N. Arias signature on the lost assignment of 15 W. Spring St.:

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The Signature above on Spring alleged Lost Assignment is not Leticia N. Arias - It appears to be Naomi
Smith and or Scott Anderson - both have been found guilty in other cases and Foreclosures illegal

The problem is these signatures don’t match the signature on Arias’ notary application she has on file
with the state of Florida nor does it match the signature on her bond certificate. THIS is a FORGERY ON
A DOCUMENT THAT LAWYER ALLISON MELTON KNOWS OF AND OR SHOULD HAVE KNOWN AS
A LAWYER yet she colluded in BWW Law Group with the forgery of HOWARD BERMAN on documents
as well as with the OCWEN et al documents.

The Florida Secretary of State suspended Leticia Arias’ notary privileges due to complaints of fraud. In
the mortgage assignment filed with the Macomb County Register of Deeds (recorded on 7/12/2012) not
only does the signature of Leticia Arias not match what the state of Florida has on file, it appears the
notary on the files, Naomi Smith, also an employee of OCWEN, was pulling some double duty that day.
If you look closely at both signatures of Leticia Arias on these documents, they are remarkably identical
to Naomi Smith.

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 SCOTT ANDERSON, OCWEN LOAN SERVICING, WHEN DOES "MERE" ROBO SIGNING
BECOME FRAUD AND FORGERY?

Or did Scott Anderson sign for Leticia N. Aries?

VA Code § 18.2-172. Forging, uttering, etc., and other

writings.

If any person forge any writing, other than such as is mentioned in §§ 18.2-168
and 18.2-170, to the prejudice of another's right, or utter, or attempt to employ
as true, such forged writing, knowing it to be forged, he shall be guilty of a Class
5 felony. Any person who shall obtain, by any false pretense or token, the
signature of another person, to any such writing, with intent to defraud any other
person, shall be deemed guilty of the forgery thereof, and shall be subject to like
punishment.

The federal crime of 18 U.S.C. § 471 forgery can be defined as the

making, altering, using, or possession of a false document or material
with the specific intent of committing fraud.

Further: Loan Servicer Ceases Foreclosures Found to be Wrongful2

August 6, 2019 — 7 Comments

2
https://www.mortgagefraudblog.com/loan-servicer-ceases-foreclosures-found-to-be-wrongful/
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 Ocwen Financial Corporation is a national provider of loan servicing for lenders. It is
headquartered in Florida and has offices in several states. In its Consent Agreement with Maine’s
Bureau of Consumer Credit Protection and Attorney General, Ocwen admitted that after July
2014 it pursued foreclosures against Maine homeowners based on paperwork which the State
found to be legally defective.

Specifically, Ocwen used “powers of attorney” granted by corporate originators of the mortgages,
but those corporate originators of the mortgages had been legally dissolved – had ceased to exist
– no later than March 2012. The State alleges that the powers of attorney terminated when the
granting corporations dissolved.

Under the Consent Agreement, the State found that Ocwen’s use of the powers of attorneys from
legally nonexistent entities violated a statute prohibiting “false, deceptive or misleading
representation or means in the collection of any debt.”

Ocwen’s illegal filings continued into January of 2019, even after Ocwen’s lawyers had assured
State regulators in November 2018 that the practice would stop. The company termed the
additional filings as “inadvertent.”

Ocwen Financial Corporation will refund or credit 24 Maine residents more than $50,000 in
attorney’s fees they were assessed when their homes were foreclosed upon, and the company
will pay $24,000 in civil penalties and $10,000 in investigative costs to the State of Maine, as part
of a Consent Agreement signed last week.

“Maine’s Supreme Court has made clear that lenders must establish that they have the legal right
to pursue foreclosures,” said Will Lund, Superintendent of the Maine Bureau of Consumer Credit
Protection. “Those requirements were not followed in these cases.”

Attorney General Aaron M. Frey, whose office assisted state mortgage regulators in negotiating
and resolving the matter, stated, “The Consent Agreement puts Ocwen – and other national
mortgage lenders and servicers – on notice that they must follow the legal standards here in
Maine if they pursue actions on defaulted mortgages.”

The Consent Agreement may have ramifications beyond Ocwen, noted Superintendent Lund,
since other lenders may be filing foreclosures based on similar powers of attorney issued by the
same nonexistent corporate loan originators used by Ocwen.

SoFla Woman’s 2-Year Battle Gets Mortgage Wiped Out:

Wonder whose signature was/is still on her documents? His name is Scott Anderson!

NBC 6-

A South Florida woman succeeded with the unheard of when she was able to get her mortgage
wiped out by a lender. In an effort to save her mother’s home, Idania Castro waged a two-year

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 battle with the bank. “The mortgage got wiped out, so I have no mortgage payment, everything
was completely satisfied,” Castro said.

The woman, who took it upon herself to go through every document related to the mortgage,
finally
discovered robo-signing. She said the signatures on her foreclosure documents appeared to have
been
signed by different people

In FEBRUARY OF 2022 The United States Senate Exhibit A stated to Jamie Diamond that Robo
signing is illegal yet the banks after paying the different STATES OVER 1 BILLION dollars and
contributions along with lawyers like TROUTMAN to look the other way have changed the laws /
statutes to support the corruption of the Servicers and Banks. Troutman Lawyer Allisson Melton
has colluded in this:
Representative Matters3
● Court denied a request for a temporary restraining order halting a foreclosure sale based on
a successful argument that the non-mortgagor plaintiffs were not borrowers with legal
standing to sue under RESPA.
● Court dismissed a borrower’s claims arising from a loan servicer’s alleged failure to conduct
a face-to-face meeting required by HUD regulations.
● Court dissolved an injunction obtained by a homeowners’ association barring the mortgage
lender from foreclosing based on an argument that the injunction unconstitutionally impaired
the mortgage lender’s contract rights.
● Court rejected a “show-me-the-note” argument brought by mortgagors challenging a lender’s
right to foreclose – one of the first appellate courts in the U.S. to do so.
● Court held that sending notice of a nonjudicial foreclosure sale to a mortgagor does not
make the foreclosing trustee a debt collector under the FDCPA, distinguishing Fourth Circuit
precedent to the contrary.
● Assisted a national mortgage loan servicer in crafting demand letter templates consistent
with state and federal requirements.
● Counseled several mortgage loan servicers on compliance with the FHA face-to-face
meeting requirement in 24 C.F.R. 203.604.

Publications
● Co-author, “Fourth Circuit Clarifies What Constitutes a QWR Under RESPA,”
Troutman Pepper, February 24, 2022.
● Co-author, “2019 Consumer Financial Services Year in Review & A Look Ahead,”
Troutman Sanders, February 24, 2020.

3
https://www.troutman.com/professionals/allison-a-melton.html
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 Theft by deceptive taking taking: the attorney and trustee acts, under color of law, are intentionally designed to
harass and intimidate plaintiff to wrongfully deprive her of her lawful rights of ownership, by Brock & Scott PLLC
on or around March 30, 2018,

That the Attorney’s Duty to the Court Against Concealment, Nondisclosure and Suppression of Information
as Coextensive with the Duty Not to Allow Fraud To Be Committed upon the Court 4

For ABUSE AND FRAUDULENT PROCESS by Officers of the Court acting to wrongly take real estate by theft
of JWG located at 15 Spring Street, Alexandria, Virginia (22301) under color of law and fraudulent trustee process,
to intimidate and cause a wrongful auction on August 17, 2017 and now October 5, 2017 (stating information
requested in 2012 will be given to Plaintiff on or around October 2, 2017) , to wrongfully take petitioner’s real
estate without right established by AUTHENTIC DOCUMENTS as REQUIRED BY LAW. FOR THE taking on
March 30, 2018 with an illegal and fraudulent FORECLOSURE.

THEFT BY DECEPTIVE taking: the attorney and trustee acts, under color of law, are intentionally designed to
harass and intimidate plaintiff to wrongfully deprive her of her lawful rights of ownership,

THAT the Defendants, individually and jointly are acting in bad faith, for their own financial interests (and not
that of any client) to perpetuate a financial law-scam for their own advantage against the Plaintiff under color of
law, including breach of fiduciary duty to this plaintiff/homeowner indicating a LACK OF DUTY OF CARE, FAIR
DEALING AND GOOD FAITH that is A PATTERN AND PRACTICE OF DEFENDANTs

Co-Defendant conspiracy to enrich themselves: SERVICER OCWEN AND FORECLOSURE LAWYERS

BWW Law GROUP, MCCABE WEISBERG & CONWAY, BROCK & SCOTT and TROUTMAN PEPPER
HAMILTON SANDERS (AND OTHERS) APPEAR to have designed a fraudulent ‘foreclosure’ scam that takes
personal financial ADVANTAGE of homeowners by FRAUD under color of law, without a bonafide client (in this
case, Wells Fargo Mortgage Co.) THE Defendant’s acts seek to BENEFIT themselves, as officers of the court, by
manipulating the “trustee” system, to illegally move homeowner property into foreclosure auction, where the
officers of the court are the sole-beneficiaries. This FRAUDULENT SCHEME, uses illegal intimidation and
improper auction process (of Virginia real estate) TO generate excessive profits for their own law-corporate/trustee
POCKETS

In this case, pursuant to Wells Fargo CEO office statements to Plaintiff / JWG and CRPB on or around August 11,
2017, there is no Plaintiff / Wells Fargo loan underlying the OCWEN and co-defendant's actions.

Servicer-Company, OCWEN/PHH fraudulently stated, “ we have a copy of a note we get to collect on.” For
reasons demonstrated herein, that statement is untrue, and all defendants have refused to produce any such
instrument. Under color of law, the Defendants fraudulently acted to ‘collect’ a non-existent Wells Fargo “loan” by
hiring Foreclosure Lawyers/Defendants/BWW/MCW and Brock & Scott,” who ignored the Fourth Circuit stay on
said property which put JWG in Bankruptcy to stop foreclosure, then the request/ demand of OCWEN not to
Foreclose to Brock & Scott (conversation is taped and can be heard
https://www.youtube.com/watch?v=00gWnLp11vI) – by improperly implementing foreclosure and auction
proceedings for their joint-profit, by acts and omissions that are illegal and unethical under the laws of Virginia.

OCWEN WITH OCWEN LAWYERS MALICIOUSLY INTERFERED WITH the rights and real property
interests of the Plaintiff, and have cause extensive damage and irreparable harm as a result, for which the plaintiff
seeks compensatory and punitive damages for the Defendant’s joint illegal acts of pretext, by lawyers and trustees,

4
The extent to which it is regarded as council's duty to advise the court as to matters relevant to the proper
decision of the case of which opposing counsel is ignorant or which he has overlooked turns on the degree to which
the old idea that litigation is a game between the lawyers has been supplanted by the more modern view that the
lawyer is a Minister of Justice. H. Drinker, legal ethics 76 (1953)
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under color of law. OCWEN used its own employees to impersonate that they had Power of Attorney for Wells
Fargo Bank.

Janice Wolk Grenadier (JWG) reserves the right to amend this Complaint and to add additional Parties per FRCP
Rule 15. That Amended Verified Complaint corresponds with attached Exhibits filed and should be used as with the
Verified Complaint. Plaintiff Janice Wolk Grenadier complains against the captioned Defendants as follows:

Real estate fraud generally involves making false statements to obtain property or credit. Under
Virginia Code § 18.2-186, a person is guilty of this crime by:

1. Making any materially false statement,

2. Knowing it to be false and intending that it be relied upon,
3. For the purpose of procuring personal property, cash, or credit.

That the appearance from the documents the “FORGERY OF THE LOST ASSIGNMENT” and Lawyer
Howard Berman with the Knowledge or should be knowledge of Alison Melton is chilling and has harmed
many homeowners in Virginia et al. The professionalism appears to be lacking in this case.

That anyone in the State of Virginia can report violations of the Professional Code of Ethics and or the
Judicial Canons. The following Professional Code of Ethics come into question:

Rule 1.3 Diligence

​ (a) A lawyer shall act with reasonable diligence and promptness in representing a client.
​ (b) A lawyer shall not intentionally fail to carry out a contract of employment entered into with a client for
professional services, but may withdraw as permitted under Rule 1.16.
​ (c) A lawyer shall not intentionally prejudice or damage a client during the course of the professional
relationship, except as required or permitted under Rule 1.6 and Rule 3.3.

Rule 1.4 Communication

​ (a) A lawyer shall keep a client reasonably informed about the status of a matter and promptly comply with
reasonable requests for information.
​ (b) A lawyer shall explain a matter to the extent reasonably necessary to permit the client to make informed
decisions regarding the representation.
​ (c) A lawyer shall inform the client of facts pertinent to the matter and of communications from another party
that may significantly affect settlement or resolution of the

Rule 1.6 Confidentiality of Information

​ (c) A lawyer shall promptly reveal:

​ (1) the intention of a client, as stated by the client, to commit a crime reasonably certain to result in
death or substantial bodily harm to another or substantial injury to the financial interests or property
of another and the information necessary to prevent the crime, but before revealing such information,
the attorney shall, where feasible, advise the client of the possible legal consequences of the action, urge
the client not to commit the crime, and advise the client that the attorney must reveal the client's

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 criminal intention unless thereupon abandoned. However, if the crime involves perjury by the client,
the attorney shall take appropriate remedial measures as required by Rule 3.3; or

​ (2) information concerning the misconduct of another attorney to the appropriate professional
authority under Rule 8.3. When the information necessary to report the misconduct is protected under
this Rule, the attorney, after consultation, must obtain client consent. Consultation should include full
disclosure of all reasonably foreseeable consequences of both disclosure and non-disclosure to the
client.
​

Rule 3.3 Candor Toward The Tribunal

​ (a) A lawyer shall not knowingly:

​ (1) make a false statement of fact or law to a tribunal;

​ (2) fail to disclose a fact to a tribunal when disclosure is necessary to avoid assisting a criminal or
fraudulent act by the client;
​ (3) fail to disclose to the tribunal controlling legal authority in the subject jurisdiction known to the
lawyer to be adverse to the position of the client and not disclosed by opposing counsel; or
​ (4) offer evidence that the lawyer knows to be false. If a lawyer has offered material evidence and
comes to know of its falsity, the lawyer shall take reasonable remedial measures.

​ (b) A lawyer may refuse to offer evidence that the lawyer reasonably believes is false.
​ (c) In an ex parte proceeding, a lawyer shall inform the tribunal of all material facts known to the lawyer which
will enable the tribunal to make an informed decision, whether or not the facts are adverse.
​ (d) A lawyer who receives information clearly establishing that a person other than a client has perpetrated a
fraud upon the tribunal in a proceeding in which the lawyer is representing a client shall promptly reveal the
fraud to the tribunal.
​ (e) The duties stated in paragraphs (a) and (d) continue until the conclusion of the proceeding, and apply even
if compliance requires disclosure of information protected by Rule 1.6.

Rule 4.1 Truthfulness In Statements To Others

In the course of representing a client a lawyer shall not knowingly:

​ (a) make a false statement of fact or law; or

​ (b) fail to disclose a fact when disclosure is necessary to avoid assisting a criminal or fraudulent act by a client.

Rule 7.1 Communications Concerning A Lawyer's Services

A lawyer shall not make a false or misleading communication about the lawyer or the lawyer’s services. A
communication is false or misleading if it contains a material misrepresentation of fact or law, or omits a fact necessary
to make the statement considered as a whole not materially misleading.

Rule 8.1 Bar Admission And Disciplinary Matters

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An applicant for admission to the bar, or a lawyer already admitted to the bar, in connection with a bar admission
application, any certification required to be filed as a condition of maintaining or renewing a license to practice law, or
in connection with a disciplinary matter, shall not:

​ (a) knowingly make a false statement of material fact;

​ (b) fail to disclose a fact necessary to correct a misapprehension known by the person to have arisen in the
matter;
​ (c) fail to respond to a lawful demand for information from an admissions or disciplinary authority, except that
this Rule does not require disclosure of information otherwise protected by Rule 1.6; or
​ (d) obstruct a lawful investigation by an admissions or disciplinary authority.

Rule 8.3 Reporting Misconduct

​ (a) A lawyer having reliable information that another lawyer has committed a violation of the Rules of
Professional Conduct that raises a substantial question as to that lawyer's honesty, trustworthiness or fitness to
practice law shall inform the appropriate professional authority.
​ (b) A lawyer having reliable information that a judge has committed a violation of applicable rules of judicial
conduct that raises a substantial question as to the judge's fitness for office shall inform the appropriate
authority.

​ (c) If a lawyer serving as a third party neutral receives reliable information during the dispute resolution
process that another lawyer has engaged in misconduct which the lawyer would otherwise be required to report
but for its confidential nature, the lawyer shall attempt to obtain the parties' written agreement to waive
confidentiality and permit disclosure of such information to the appropriate professional authority.

​ (d) This Rule does not require disclosure of information otherwise protected by Rule 1.6 or information gained
by a lawyer or judge who is a member of an approved lawyer's assistance program, or who is a trained
intervenor or volunteer for such a program or committee, or who is otherwise cooperating in a particular
assistance effort, when such information is obtained for the purposes of fulfilling the recognized objectives of
the program.
​ (e) A lawyer shall inform the Virginia State Bar if:

​ (1) the lawyer has been disciplined by a state or federal disciplinary authority, agency or court in any
state, U.S. territory, or the District of Columbia, for a violation of rules of professional conduct in that
jurisdiction;

​ (2) the lawyer has been convicted of a felony in a state, U.S. territory, District of Columbia, or federal
court ;
​ (3) the lawyer has been convicted of either a crime involving theft, fraud, extortion, bribery or perjury,
or an attempt, solicitation or conspiracy to commit any of the foregoing offenses, in a state, U.S.
territory, District of Columbia, or federal court.

The reporting required by paragraph (e) of this Rule shall be made in writing to the Clerk of the
Disciplinary System of the Virginia State Bar not later than 60 days following entry of any final order
or judgment of conviction or discipline.

Rule 8.4 Misconduct

It is professional misconduct for a lawyer to:

● 14
 ​ (a) violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another to do so,
or do so through the acts of another;
​ (b) commit a criminal or deliberately wrongful act that reflects adversely on the lawyer's honesty,
trustworthiness or fitness to practice law;
​ (c) engage in conduct involving dishonesty, fraud, deceit or misrepresentation which reflects adversely on the
lawyer’s fitness to practice law;
​ (d) state or imply an ability to influence improperly or upon irrelevant grounds any tribunal, legislative body,
or public official; or
​ (e) knowingly assist a judge or judicial officer in conduct that is a violation of applicable rules of judicial
conduct or other law.

Rule 8.5 Disciplinary Authority; Choice Of Law

​ (a) Disciplinary Authority. A lawyer admitted to practice in this jurisdiction is subject to the disciplinary
authority of Virginia, regardless of where the lawyer's conduct occurs. A lawyer not admitted in Virginia is also
subject to the disciplinary authority of Virginia if the lawyer provides, holds himself out as providing, or offers
to provide legal services in Virginia. By doing so, such lawyer consents to the appointment of the Clerk of the
Supreme Court of Virginia as his or her agent for purposes of notices of any disciplinary action by the Virginia
State Bar. A lawyer may be subject for the same conduct to the disciplinary authority of Virginia and any other
jurisdiction where the lawyer is admitted.

​ (b) Choice of Law. In any exercise of the disciplinary authority of Virginia, the rules of professional conduct to
be applied shall be as follows:

​ (1) for conduct in connection with a proceeding in a court, agency, or other tribunal before which a
lawyer appears, the rules to be applied shall be the rules of the jurisdiction in which the court, agency,
or other tribunal sits, unless the rules of the court, agency, or other tribunal provide otherwise;

​ (2) for any other conduct, the rules of the jurisdiction in which the lawyer’s conduct occurred; and

​ (3) notwithstanding subparagraphs (b)(1) and (b)(2), for conduct in the course of providing, holding
out as providing, or offering to provide legal services in Virginia, the Virginia Rules of Professional
Conduct shall apply.

https://www.vsb.org/pro-guidelines/index.php/main/print_view

The Professional Code of Ethics and the Judicial Canons is important to the court system to hold
Judges who are lawyers, and lawyers accountable for misconduct. Especially when Judges and
Lawyers have a self reporting requirement.

12 U.S. Code § 265 Insured banks as depositaries of public money; duties; security; discrimination between banks
prohibited; repeal of inconsistent laws

12 U.S. Code § 2605 Servicing of mortgage loans and administration of escrow accounts

15 U.S. Code § 77q. Fraudulent interstate transactions

15 U.S. Code Subchapter V - DEBT COLLECTION PRACTICES, § 1692d - Harassment or abuse, § 1692e
-False or misleading representations, § 1692f - Unfair practices, § 1692g - Validation of debt, § 1692j -Furnishing

● 15
certain deceptive formFair Debt. Collection Act (FDCPA), § 806 Harassment, § 807 False and misleading, § 808
Unfair practices,
§ 809 Validation of debts, § 812 Furnishing deceptive forms, et al

42 U.S. Code § 1983 - Civil action for deprivation of rights

18 U.S. Code § 242 - Deprivation of rights under color of law
18 U.S. Code § 241 - Conspiracy against rights
18 USC § 371 Conspiracy
18 USC § 1341 Frauds and Swindles
18 USC § 1343 Fraud by Wire,
18 USC §1344 Bank Fraud
18 USC §1346 Honest Services
18 USC § 1348 Securities and commodities fraud
18 USC §1349 Attempt and Conspiracy Sarbanes – Oxley Act
18 U.S. Code § 666 - Theft or bribery concerning programs receiving Federal funds
18 U.S.C. § 471 forgery

26 U.S.C. § Section 61 A (1)

26 U.S.C. § Section 108 (i)
26 U.S.C. § Section 451
26 U.S.C. § Section 1033
U.S.C Section 1.751, CFR 1.752
SEC Rule 1122 AB
Regs. Sec. 1.707-3(b)(2) Disguised sales of property to partnership

Virginia Fraud Against Taxpayers Act. CODE OF VIRGINIA FALSE CLAIMS; CIVIL PENALTY
Virginia Code Ann. § 8.01-216.3 (A)(1)-(A-4), 8.01-216.3 (A)(7)

31 U.S.C. § 3729 Federal False Claims Act Violation of the Consent Order in 2014 with the DOJ and 48
states including Virginia.

When OCWEN issued the 1099-A it did not use a company it would have and did use a name that could be a
“Payer Agent” ? ALL FDCPA “debt collections” of JWG were denied.

This is the ENRON game with a twist:

1. Take Bad Assets written down to 10% of the original appraised value
2. Recap them by pulling them into CMBS
3. Originate loans to anyone by taking the title up front - under the IRS Rules for installment sale
4. Now the pool of crap is properly capitalized
5. Now amortize the bad Bank OREO by 10% annually to keep within range of a qualified investment
6. Assign the amortized amount annually to Consumers as pass-through investors
7. and then issue a 1099 A to close out these like-kind exchanges in the year of disposition
8. Where the title held by a BANK TRUSTEE A is released to the payees agent OCWEN
9. For the LLC to recast Itself by paying your withholding taxes on the Phantom earnings

● 16
 The IRS calls these tax promoters and liquidation schemes “genius” intended to beat the best intent of Congress
who is the authoritative guidance under Title 26. These are passed through Investments. JWG did not agree to a
pass through Investment.

That JWG claims against OCWEN et al for ABUSE AND FRAUDULENT PROCESS by Officers of the Court
acting to wrongly take real estate of the Petitioner located at 15 Spring Street, Alexandria, Virginia (22301) under
color of law and fraudulent trustee process, to intimidate and cause a wrongful auction on August 17, 2017 and now
October 5, 2017 (stating information requested in 2012 will be given to JWG on or around October 2, 2017) , to
wrongfully take JWG’s real estate without right established by AUTHENTIC DOCUMENTS as REQUIRED BY
LAW.

Theft by deceptive taking taking: the attorney and trustee acts, under color of law, are intentionally designed to
harass and intimidate plaintiff to wrongfully deprive her of her lawful rights of ownership, by Wells Fargo Bank &
Brock & Scott PLLC on or around March 30, 2018,

JURISDICTION AND VENUE

This court has original jurisdiction of federal questions pursuant to 28 U.S.C. § 1331 – 1332. The court has
supplemental jurisdiction of state claims pursuant to 28 U.S.C. § 1367.

Venue is proper in this court pursuant to 28 U.S.C. § 1391(b)(2). That both Wells Fargo Bank N.A. Brook & Scott,
Troutman Pepper Harmilton Sanders are Corporations licensed to do Business in Virginia and other states.
Troutman Pepper Hamilton Sanders transacts business in Maryland, Virginia, District of Columbia, Florida,
Pennsylvania, New York, Florida and surrounding states making this a multi-jurisdictional matter in which this
court has jurisdiction and authority. Defendants have intentionally interfered with Plaintiffs rights under the
Interstate Commerce Act which rights are protected under Title 15 U.S.C. This court has jurisdiction under FRCP
Rule 1, 2, & 3 and 28 U.S.C. § 45. That the Property is located in the City of Alexandria, Virginia. That
Government Plaintiff’s are located in the District of Columbia.

Wells Fargo Bank is asking for $120.000.00 over the $75,000. With JWG being denied Discovery and Witness
by the Judge.
PARTIES
WELLS FARGO NATIONAL ASSOCIATION, as Trustee for Option One Mortgage Loan Trust 2005-2, Asset-
Backed Certificates, Series 2005-2 Has stated clearly and has filed in the court they have no information regarding
any loan. They further researched it in Mers which shows no documentation under JWG SS#, address or name.

CEO Charles W. Scharf WELLS FARGO N.A., has the responsibility of Wells Fargo to ensure integrity and to
protect the name of Wells Fargo N. A. et al That “FAKE”

OCWEN LOAN SERVICING LLC aka PHH aka OCWEN MORTGAGE SERVICING, INC. aka Ocwen
Financial Corporation, NMLS#: 1849337 Ocwen USVI Services, LLC, NMLS#: 2726 PHH Mortgage

● 17
CorporationForeclosed on or around March 30, 2018 stated Wells Fargo Bank is the owner of such loan in court -
in phone calls. Stated to Broke and Scott not to Foreclose. Has never provided accounting that was readable. That
moved such loan to NewRez LLC in Plaintiffs Name, SS# and address NewRez around September of 2019 after
foreclosing on March 30, 2018.

●
OCWEN LOAN SERVICING, LLC, aka PHH a Delaware limited liability company, on December 31,
2012 purchased Homeward Residential Service (f/k/a name changed from American Home Mortgage
Servicing Inc February 17, 2012). American Home Mortgage Servicing Inc was purchased by Option One
Mortgage servicing May 17, 2008) Option One lost their right do to business in December of 2008. Has
lawsuits against it all across America, including a suit by the CFPB in Florida for the same criminal activity
against JWG. Foreclosed on or around March 30, 2018 stated Wells Fargo Bank is the owner of such loan
in court - in phone calls. Stated to Broke and Scott not to Foreclose. Has never provided accounts that
were readable. That moved such loan to NewRez LLC in Plaintiffs Name, SS# and address. OCWEN
LOAN SERVICING LLC aka PHH aka OCWEN MORTGAGE SERVICING, INC. Foreclosed on or
around March 30, 2018 stated Wells Fargo Bank is the owner of such loan in court - in phone calls. Stated
to Broke and Scott not to Foreclose. Has never provided accounts that were readable. That moved such
loan to NewRez LLC in Plaintiffs Name, SS# and address.
OCWEN’s Known Issues;

Zimmerman Reed Lawyers https://www.zimmreed.com/case/ocwen-mortgage-errors-illegal-foreclosures/

States:

OCWEN MORTGAGE FORECLOSURES & PAYMENT PROBLEM RealServicing is a proprietary loan servicing
platform Ocwen used to process and apply payments and communicate information to borrowers – and it’s alleged
they loaded inaccurate information into the system resulting in the platform generating scores of errors. Using this
inaccurate information, Ocwen did not accurately account for homeowners payments or the amounts due under the
home loans they serviced, failed to correctly process and provide for required foreclosure mitigation protection to
homeowners, failed to timely and properly respond to homeowners’ requests for information in regards to their
loans, and in many instances wrongfully and improperly instituted foreclosure proceedings against them.

The following include common complaints from homeowners:

● Disputes concerning the amounts due and owing on the loan after a transfer to Ocwen
● Account disputes and inaccuracies provided by Ocwen through its customer website
● Payment application issues
● Escrow accounting issues
● Loan modification process issues, including, issues related to Ocwen’s failure to properly document loan
modification terms
● Wrongful foreclosure (e.g., authority to foreclose, amounts alleged to be due and owing)
● Failure by Ocwen to adequately respond to customer inquiries
● Backdating of homeowner correspondence

MAHANY LAW https://www.mahanyertl.com/2019/ocwen-fraud-investigations/

States:

MahanyLaw is investigating Ocwen and hopes to file one or more national class action complaints against the
company within coming weeks.

● 18
Specifically, we are investigating the following allegations of wrongdoing:

1. Use of a proprietary software known to trigger unsupported fees and speed foreclosures (REAL
Servicing);
2. Knowing use of infirm loan data,
3. Illegal foreclosures,
4. Failure to credit borrowers’ payments,
5. Mismanagement of escrow accounts,
6. Manufactured force-placed insurance,
7. Delayed termination of private mortgage insurance,
8. Charges for additional products without consent,
9. Mishandling accounts for deceased borrowers, and
10. Failure to correct errors identified by the borrower.

We agree. In our opinion, Ocwen has taken fraud and abuse to a new level.

We hoped that Ocwen had finally met its demise in 2015. That year investors sold off their stock in the company
causing the company’s value to plummet. Over one hundred trusts holding $82 billion of mortgages gave Ocwen
the boot. Their reasons?

● Using trust funds to pay off Ocwen’s obligations owed under a regulatory settlement. Instead of
paying what they owe, the trusts say that Ocwen pushed the payments onto them;Gross conflicts of
interests. Ocwen used corporate affiliates such as Altisource and Home Loan Servicing Corporation
to further enrich itself and hurt borrowers and the trusts;
● Failing to comply with foreclosure and consumer protection laws;
● Engaging in illegal and improper loan modification and advance recovery practices;
● Improper records practices;
● Failing to properly communicate with borrowers; and
● Failing to properly pay the trusts.

In other words, it isn’t just homeowners who claimed they were the victims of Ocwen fraud. It is the investors who
own the loans too.

How They Connect:

NAME NOW HISTORY

Charles W. Scharf 2019 CEO & President Wells 2017 - 2019 The Bank of New York Mellon Corp
Fargo Bank Chairman & CEO
2012 - 2016 Visa Inc
2004 - 2011 JPMorgan Chase & Co CEO
2000 - 2004 Bank One Corp CFO
One Equity Partners LLC
1999 - 2000 Citigroup Inc CFO Global Corporate &
Investment Bank Division
1995 - 1999 Salomon Smith Barney, Inc CFO
Primerica, Inc
Commercial Credit Corp

● 19
 Brian Thomas CEO /President Bank of America
Moynihan US Trust, Bank of America Private
Wealth Management Chairman &
CEO
Bank of America Private Bank
President
2008 Merrill Lynch & Co. CEO
2008 - 2009 QuaiSec
-2014 US Trust Co., N.A. Director & President
1993 - 2004 FleetBoston Financial Corp Deputy General
Counsel, Executive VP
Countrywide Bank President Global Corporate
FIA Card Services President
Edwards & Angell LLP Professional
Bank of America London Branch President & CEO
LaSalle Bank Midwest NA President
Bank of America NA Troonto Branch Director &
President Global Wealth

Glenn A. Messina CEO OCWEN/PHH 2011 PHH Corp. President / CEO / Consultant & COO
Megallen Advisors LLC Principal 2002 - 2011 General Electric Company CEO / CFO

1996 - 1998 GE Capital Mortgage Services, Inc CFO

MICHAEL New Residential Investment Corp 2013 Fortress Investment Group LLC Managing
NIERENBERG Director
2013 Bank of America Corp Global Head of Mortgages
& Securitized Products
2008 - Merrill Lynch MD & Head-Global Mortgages &
Securitized Products
2006 - 2008 Bear Stearns & Co Inc. Director

Baron Silverstein 2020 President of NewRez LLC 2008 Merrill Lynch Managing Director, Global
Mortgages & Securitized Products Group
2008 JPMorgan Chase & Co Co-Head, US RMBS
Mortgage Finance Department
2008 Bear Stearns & Co., Inc

Bruce John Williams
2020 CEO NewRez LLC
1996 - Current Credit-Based Asset
Servicing & Securitization LLC
CEO
C- Bass Investment Management LLC Co-Chief
Executive Officer
Shellpoint Partners LLC Co- CEO & Director
2016 Shellpoint Advisors LLC Co-CEO
1995 - 1996 Citicorp Securities Managing Director

Kevin Harrigan Member, Executive Management of 2013 NewRez LLC President, CEO
NewRez LLC

Leon Cooperman 10% past owner of OCWEN. SEC is covering - up Insider Trader of OCWEN
Stock (born April 25, 1943) is an American billionaire investor and hedge fund manager. He is the chairman
and CEO of Omega Advisors, a New York-based investment advisory firm managing over $3.3 billion in
5
assets under management, the majority consisting of his personal wealth.
In September 2016 the U.S. Securities and Exchange Commission charged Cooperman and
Omega Advisors with insider trading, more specifically for "trading stocks, bonds and call options
5 https://en.wikipedia.org/wiki/Leon_Cooperman

● 20
 of Atlas Pipeline Partners in July 2010 on information he obtained from an executive at the
company."Cooperman's firm agreed to a $4.9 million settlement with the SEC in May 2017 but
admitted no wrong-doing As part of the settlement, Cooperman and Omega agreed to be subject to a
compliance monitor with access to their electronic communications and trading records and to submit
monthly certifications that they had not engaged in insider trading until 2022

Early career and Goldman Sachs:

Directly after graduating from Columbia, Cooperman joined Goldman Sachs. He spent his first 22
years at Goldman in the Investment Research Department as partner-in-charge, co-chairman of
the Investment Policy Committee and chairman of the Stock Selection Committee. In 1989, he
became chairman and chief executive officer of Goldman Sachs Asset Management and was
chief investment officer of the equity product line including managing the GS Capital Growth
Fund, an open-end mutual fund, for one and one-half years.
While at Goldman Sachs, for nine consecutive years, Cooperman was voted the number one
portfolio strategist in the Institutional Investor "All-America Research Team" survey.]
At the end of 1991 after twenty-five years of service, Cooperman retired from his positions as a
general partner of Goldman, Sachs & Co. and as chairman and chief executive officer of
Goldman Sachs Asset Management

TROUTMAN PEPPER HAMILTON SANDERS AKA TROUTMAN SANDERS aka Mays & Valentine
Represents OCWEN and in past created a FRAUD ON THE COURT in representing Wells Fargo and claiming
Wells Fargo Bank owned a loan in the name of Janice Wolk Grenadier which Wells Fargo has denied to JWG and
the CFPB. That this law firm “Swindled” $30,000 in a Cover Up of monies stolen through a trust account and the
worked in collusion to cover up with Divorce Lawyer Ilona Grenadier Heckman and Ben DiMuro her lawyer.
Involved in the theft of Trust Accounts with Divorce Lawyer Ilona Grenadier Heckman colluding to insure no
justice for Janice Wolk Grenadier

S. Mohsin Reza TROUTMAN PEPPER HAMILTON SANDERS Lawyer now with (Greenberg Traurig
LLP),who with his apparent Agent Micheal Martinez after a foreclosure with a home that is not in her name,
colludes for a short sale. Lied in Court in the City of Alexandria. Has unclean hands has violated the Professional
Code of Ethics 3.3 Candor of with the court, 8.0 – 8.5 Responsibility to report the criminal activity of Judges and
other lawyers. Mr. Reza has colluded and conspired with others to harm Plaintiff. He is guilty of USC § 4
Misprision of a Felony with his e-mail where he conspires with other lawyers. Lawyer who with his apparent Agent
Micheal Martinez after a foreclosure with a home that is not in her name colludes for a short sale.

STEVE LEWIS (Atlanta). Leadership Partner Chair, TROUTMAN PEPPER HAMILTON SANDERS LLP Was
the Managing Partner of Troutman Sanders, now serves as Chair and Chief Executive Officer of the combined firm.

ALLISON MELTON - TROUTMAN PEPPER HAMILTON SANDERS LLP & BWW LAW Group aka
Equity Trustees Involved in Cover-Up of lies of Wells Fargo Bank and OCWEN. Was involved in trying to
foreclose when OCWEN/PHH told her not to. Involved in Cover-UP

JOHN CURTIS LYNCH TROUTMAN PEPPER HAMILTON SANDERS LLP colluded to cover-up and
appears to have been involved in lies to the Supreme Court of Virginia and the City of Alexandria Circuit Court

● 21
ANDREW BRIAN PITTMAN TROUTMAN PEPPER HAMILTON SANDERS LLP colluded to cover-up and
appears to have been involved in lies to the Supreme Court of Virginia and the City of Alexandria Circuit Court

MARY C. ZINSNER TROUTMAN PEPPER HAMILTON SANDERS LLP colluded to cover-up and appears
to have been involved in the lies to the USDC of VA (Alexandria).

MYRA A. BENJAMIN TROUTMAN PEPPER SANDERS LLP / CFPB / NIXON PEABODY LLP appears
to have left the firm colluded to cover-up and appears to have been involved in the lies to the City of Alexandria
Court. Knows of the scheme and worked for the CFPB, to protect the public

Brian Campbell Lawyer Brock & Scott, PLLC Had knowledge Wells Fargo N.A. had no knowledge of such loan
as stated by documents filed in the court.

Howard Norman Bierman Partner BWW Law Group aka Equity Trustees, LLC Had knowledge Wells
Fargo N.A. had no knowledge of such loan as stated by documents filed in the court. Sent a letter that Spring Street
was part of the National Foreclosure Settlement through Bank of America. Appears to have with knowledge
allowed documents filed against Spring St. to be foreclosed forged with his name. Forgery on documents as a
pattern and practice

The shoddy unlawful and unethical behavior from these banks, attorneys, agents, employees, and representatives,
all who willfully refused to produce the note because the alleged documents they rely upon for their actions are
forged, robo-signed, or reverse engineered.

INTRODUCTION

JANICE WOLK GRENADIER being denied discovery a right to ensure a fair trial requested
the Judge to recuse herself and she refused. Violates Virginia and US Constitutional rights to Due
Process, Includes in this all Fillings already made in this case filed in this court.

Without discovery, JWG learned of further criminal activity of lawyers with Troutman Pepper Hamilton
Sanders (Troutman) and Allison Melton with moving forward with a document to foreclose on that is
forged.

Further, JWG believes that Trouman Melton knew it and was involved in the creation of the “Affidavit of
Lost Assignment'' that was used in the document and that is why OCWEN has refused any real
discovery to the CFPB and to JWG. That Troutman has controlled for financial gain any and all
meaningful discovery.

Further, all Judges have had conflicts financially and or a Bias to protect their friends, and in Virginia
where all Judges are also lawyers and should be held accountable by the VSB and the JIRC instead they
all call there

a. The head of the Bar stated to the legislature that only 19% of Bar Complaints are
considered but, rarely go anywhere of the approx 31,655 lawyers as reported in Virginia6
Of the 71 lawyers publicly disciplined, 34 lawyers received public reprimands or

6
https://www.vsb.org/docs/84th_Annual_Report.pdf
● 22
 admonitions; 18 lawyers were suspended; and 19 lawyers’ licenses were revoked. We
have a broken system in the State of Virginia.

THE FRAUD OF THE LOST ASSIGNMENT:

1. Troutman and Wells Fargo did not have the standing to initiate or maintain that was filed in
this case, due to a FRAUDULENT FORECLOSURE which was known to Allison Melton whom
interfered in my ability to get a Hamp Refinance with BWW Law Group and has the knowledge of the
forgery is or should have on the “Affidavit of Lost ASSIGNMENT” Further she is aware that no lawyer
reviewed the Affidavit of Lost Assignment as the BAR No. Belongs to Judge Donald R. Alexander
Exhibit B which could be considered Identity theft as this can be shown to be a pattern and practice of
“FAKE and or STOLEN” Lawyer Bar Numbers all across the USA by OCWEN Melton is aware of this.
Or should be

On April 22, 2013 , OCWEN aka American Home Mortgage Servicing aka Homeward , the servicer at the
time, MERS, Fannie Mae or Freddie Mac have no knowledge of such loan, caused the "CORRECTIVE
ASSIGNMENT OF THE DEED OF TRUST" to be filed into The City of Alexandria official public records
(known to lawyers and Clerk of Court Ed Semonian and now J. Greg Parks) as document number
130014851.

The corrective assignment includes the statement that,

Leticia N. Arias is a Contract Manager per for OCWEN, not a Vice President for Homeward which is
owned by OCWEN/PHH

No effort was made and is never made by the Contract Managers as an insider stated they have goals
as to how many documents hourly need to be signed - in taped conversations

Wells Fargo Bank and lawyers have NO STANDING To have foreclosed on false and fraudulent
documents that the Servicer had already had to pay Billions for this behavior to BRIBE judges and states
to look the other way.

2. The assignment documents that were recorded into City of Alexandria public records and known
possess suspicious signatures that are purported to be that of Leticia N. Arias and that do not match the
purported originators established signature on forms that have been, or caused to be, filed by Leticia N.
Arias with Florida Secretary of State. See attached Exhibits - NOTARY PUBLIC COMMISSION
APPLICATION and STATE OF FLORIDA BOND OF NOTARY PUBLIC. A comparison of signatures from

● 23
documents that were filed with the Secretary of State for Florida, by or on behalf of Leticia N. Arias
reveals that the signatures were provided by two different individuals. Considering that the signatures
found on Notary Application and Bond Certificate were provided on November 15, 2007, and the earliest
of the assignments was filed on April 22, 2013, it should be presumed that the previous signatures are
from Leticia N. Arias. See the signature purporting to be "Leticia N. Arias" in the signatures areas on
documents that are filed with the Florida Secretary of State attached. Both assignment documents'
Notary areas state "The State of Florida, County of Palm Beach". The business name and address that is
provided on the "Notary Public Commission Application" is "1661 Worthington Road, Suite 100 40
Ocwen Financial Corporation West Palm Beach, FL 33408"

The Defendants as Trustee, Alisson Melton, BWW Law Group, Troutman, OCWEN/PHH and others,
through fraud that they knew of and or should have known have benefited from a forged signature that
has been applied to a document purporting to transfer an interest that encumbrances property that is
known as 15 W. Spring St., Alexandria, VA 22301 home of Janice Wolk Grenadier

THE STATE OF VIRGINIA ATTORNEY GENERAL LOOKED THE OTHER WAY

THE VIRGINIA LEGISLATURE TO CHANGE STATUES FOR FINANCIAL GAIN OF THE LAWYERS,
SERVICERS, and BANKERS
OVER $ 1 BILLION WAS GIVEN TO THE STATE OF VIRGINIA

3. It has become clear that Wells Fargo et al did not have standing to Foreclose that is if the law
matters?. When a party does not have standing then the court does not acquire subject matter
jurisdiction and therefore any order thereafter is void and must be vacated.

4. That Wells Fargo et al has standing to assert a claim is an essential part of the court's subject matter
jurisdiction. E.g., Int'l. Ass'n of Firefighters Local 1789 v. Spokane Airports, 146 Wn.2d 207, 212, 245,
P.3d 186 (2002). The assignment is in violation of RCW 40.16.030 and constitutes a forgery under COV
§ 18.2-172 Forging, uttering, etc., other writings & § 18.2-168 & Forging public records, §
18.2-178. Obtaining money or signature, etc., by false pretense. etc. & § 18.2-170. Forging coin
or bank notes it could be considered under § 18.2-95. Grand larceny defined; and § 8.01-428,
Setting aside default judgments; clerical mistakes; independent actions to relieve party from
judgment or proceedings; grounds and time limitations applies hereto. OCWEN LOAN SERVICING,
with an address of 1661 Worthington Road, Ste. 100 West Palm Beach, Florida 33408 prepared and
presented the document for recordation. "Where a judgment has been entered by a court which has not
first secured jurisdiction, such judgment is void and of no effect." Wiles v. Dept. of Labor & Indus. Of
State, 34Wn.2d 714, 723, 209, P.2d.462 (1946)

The lawyers

● 24
Real estate fraud generally involves making false statements to obtain property or credit. Under
Virginia Code § 18.2-186, a person is guilty of this crime by:

1. Making any materially false statement,

2. Knowing it to be false and intending that it be relied upon,
3. For the purpose of procuring personal property, cash, or credit.

That the appearance from the documents the “FORGERY OF THE LOST ASSIGNMENT” and Lawyer
Howard Berman with the Knowledge or should be knowledge of Alison Melton is chilling and has harmed
many homeowners in Virginia et al. The professionalism appears to be lacking in this case.

That anyone in the State of Virginia can report violations of the Professional Code of Ethics and or the
Judicial Canons. The following Professional Code of Ethics come into question:

Rule 1.3 Diligence7

Rule 1.4 Communication
Rule 1.6 Confidentiality of Information
Rule 3.3 Candor Toward The Tribunal
Rule 4.1 Truthfulness In Statements To Others
Rule 7.1 Communications Concerning A Lawyer's Services
Rule 8.1 Bar Admission And Disciplinary Matters
Rule 8.3 Reporting Misconduct
Rule 8.4 Misconduct
Rule 8.5 Disciplinary Authority; Choice Of Law
​

https://www.vsb.org/pro-guidelines/index.php/main/print_view

The Professional Code of Ethics and the Judicial Canons is important to the court system to hold
Judges who are lawyers, and lawyers accountable for misconduct. Especially when Judges and
Lawyers have a self reporting requirement.

That the American Citizens have had their rights violated by a government that is supposed to protect them from
schemes that are obviously FRAUD by BANKS, SERVICERS & LAWYERS. That the courts / judges have a
financial interest if they have a Vanguard or other money market account.

OCWEN/PHH Mortgage:

● Ocwen failed to provide any accounting or proof of JWG prior payments had been properly
credited, and refused to accept JWG payments or otherwise communicate with JWG.

7
See page 12 - 15 of complaint for description of rules
● 25
 ● OCWEN caused damages including the imposition of late charges for JWG purported nonpayment,
charges for "forced insurance on the property," and interest and costs related to untimely property
tax payments and property inspections.
● OCWEN employees have stated the following of OCWEN’s acts and actions in collusion with
lawyers to harass and further mentally abuse homeowners: Do not answer phones, Turn off Fax
machines etc. That the lawyers did not respond to the OCWEN employees questions and requests.
● OCWEN past employees state clearly: after the purchase of PHH that OCWEN was going to be
going into Bankruptcy and or Closing its doors.
● The appearance is that OCWEN is moving its assets into NewRez, a subsidiary of New Residential
Investments Corp. you then have , Mr. Cooper / COOP on the Stock Market, and Brookfield BAM
on the stock market. After PHH took over it moved 15 W. Spring St. as an alleged loan to
NewRez. This loan should not exist, as Wells Fargo Bank N.A. according to the Foreclosure and
their lawyer Troutman Sanders, Syed Mohsin Reza was the owner of the loan alleged on the
property
● WELLS FARGO BANK in a notarized statement states no ownership and or any record of any loan
or interest in Spring St.

The appearance of the facts that insiders have shared with JWG and with the acts and actions of OCWEN / PHH
is moving its assets to NewRez that was once owned by PHH. That further shows that investors, shareholders of
owner The Residential Investment Corp may not know loans that do not exist and or should not exist are being
moved and or counted as assets on OCWEN / PHH as well as New Rez and the question becomes:

How many non existing assets accounted for - for which companies etc. is a Question all Plaintiffs should be
concerned with as they are supposed to protect the public from these Schemes.

The documents filed against the home at Spring St. also show it being on the balance sheet of Wells Fargo / Bank
of America aka LaSalle Bank.

Stay granted and violated. That on August 8, 2017 a “STAY” in Appeal No. 16- 2459 in the Fourth Circuit Court
of Appeals which Defendant OCWEN Loan Servicing LLC along with BWW LAW GROUP, a/k/a BIERMAN,
GEESING, WARD & Wood, LLC. HOWARD N. BIERMAN , EQUITY TRUSTEES, LLC. MARK R.
GALBRAITH , WELLS FARGO, BANK OF AMERICA, f/k/a - as successor-in-interest to LaSALLE BANK, are
Defendants. With a Claim Wells Fargo is the Note Holder while Wells Fargo informs CFPB they have nothing
to do with a loan at 15 W. Spring St., Alexandria VA 22301 and or with Janice Wolk Grenadier. That Wells
Fargo Bank went as far as to file a such a statement in the Circuit Court of the City of Alexandria, and then
to OVERNIGHT prior to court to JWG a STATEMENT THAT WELLS FARGO BANK HAD NO SUCH
DOCUMENTS

A WELLS FARGO BANK employee went so far as to investigate including with Mers and other sites and
stated very clearly to JWG “NO SUCH LOAN EXISTS, DO NOT GIVE UP YOUR FIGHT”.

That OCWEN foreclosed on Janice Wolk Grenadier's home of 29 years with Forged, Fake Fraudulent Documents.
The foreclosure took place On or around March 30, 2018 (JWG is still in the home) then sent a Fraudulent IRS
1099-A, (February 2019). The lawyers for OCWEN - TROUTMAN SANDERS have used an agent Micheal
Martinez to harass and try to get JWG to do a short sale after the Foreclosure with all appearances for personal gain
for lawyers at Troutman Sanders aka Mays & Valentine (Lawyer Syed Mohsin Reza. The alleged loan has now

● 26
been transferred to NewRez LLC by OCWEN /PHH as of on or around August 26, 2019, remember this loan
was foreclosed on by Wells Fargo Bank N.A. on or around March 31, 2018. That lawyer Syed Mohsin Reza on
February 27, 2020 sent JWG a malicious, threatening letter, after having stated in court on or around August of
2019 that “ WELLS FARGO BANK N.A.” owned the alleged loan. On December 7, 2018 Wells Fargo Bank
N.A. filed in the City of Alexandria Court that it was unable to locate any Information on such loan and or home.
On August 7, 2019 in a notarized letter Wells Fargo N.A. No documents, records, or other materials exist for
Janice Wolk Grenadier and or the property at 15 W. Spring Street, Alexandria, VA 22301. That Janice Wolk
Grenadier owns stock in OCWEN / PHH merge on or around October 4, 2018, NewRez LLC (OCWEN is
moving its Assists which includes and not limited to loans that do not EXIST or should not such as Spring St.) aka
New Residential Investments Corp, Wells Fargo Bank and Mr. Cooper. JWG filed 42 Complaints between 2017 -
2019 Ignored by the CFPB.

Defendant lack of standing. That on or around 2013, Defendant OCWEN (only has Servicing Rights not the Right
to assign) became aware of its lack of standing to pursue any type of foreclosure action on Plaintiff’s home, located
at 15 W. Spring Street, Alexandria VA 2230, but they nevertheless, for their own financial profit and gain, pursued
illegal collection remedies that have wrongfully harmed this Plaintiff. Evette Morales who signed as attorney in
Fact for Wells Fargo Bank is an employee of OCWEN. The person who notarized the document that gave Surety
Trustee aka McCabe Weisberg and Conway the right to Foreclose has the same title as Evette Morales and seems to
be office mates. Further Wells Fargo Bank denies ever giving Evette Morales any type of POWER OF
ATTORNEY to decide who has foreclosure POWER. Evette is a Contract Management Coordinator at OCWEN
Financial Corporation. This job advertises for a salary of $30,000 - $36,000 approx. That OCWEN/PHH
employee stated clearly that OCWEN employee’s jobs were gagged on how many documents were done in an
hour. That the working conditions were like a sweatshop. Employees let go were replaced with employees in
India. The employees were told by Lawyers to leave customers on hold, turn off FAX machine’s so they
could not receive documents, and not to answer the phones. The foreclosure lawyers depended on the
employees to create “FAKE and FRAUDULENT” documents for them to put their names on as they
reviewed them.

That in or around 2014, OCWEN to avoid any criminal charges – no different then in the past with Wells Fargo
Bank and Bank of America did a consent ORDER to cease and desist the criminal activity. The Securities and
Exchange Commission (“Commission”) deems it appropriate that cease-and-desist proceedings be, and hereby are,
instituted pursuant to Section 21C of the Securities Exchange Act of 1934 (“Exchange Act”) against Ocwen
Financial Corp. (“Ocwen” or “Respondent”).8

That OCWEN has violated the Consent ORDER that was also signed by the Attorney General of Virginia.

That the CFPB has filed a new Complaint against OCWEN on or around April 20, 2017: in the USDC of the
Southern District of Florida West Palm Beach Division Case No. 9:17 –cv- 80495 - CFPB v. OCWEN
FINANCIAL CORPORATION a Florida Corporation , OCWEN MORTGAGE SERVING, INC, a US Virgin
Islands corporation AND OCWEN LOAN SERVICING LLC a Delaware Corporation Page 2 Paragraph 2 States:
The bureau brings this action against the Defendants under: (1)Sections 1031 and 1036 of the CFPA , 12 USC §§
5531, 5536; (2) Sections 807 (2)(a), 807(10), and 808 of the Fair Debt Collection Practices Act, 15 USC §§
1692e(2)(a), 1692e(10), and 1692f (the “FDCPA”); (3) Section 6 and 19 of the Real Estate Settlement Procedures
Act (RESPA), 12 USC §§ 2605, 2617, and the regulations, promulgated thereunder at Regulation X, 12 C.F.R. part
8
Https://www.sec.gov/litigation/admin/2016/34-76938.pdf
● 27
1024 (“Regulation X”); (4) Section 105(a) of the Truth and Lending Act (“TILA”), 15 USC § 1604(a), and the
regulations promulgated thereunder act Regulation Z, 12 C.F.R. part 1026 (“Regulation Z”): and (5) Section 3(b) of
Homeowners Protection Act of 1998, 12 USC § 4902(b)(the “HPA”). PLAINTIFF INCORPORATES THIS
COMPLAINT into THIS COMPLAINT that shows the UNCLEAN HANDS OF OCWEN AND DEFENDANTS
TO COVER UP criminal activity.

This Government and this Court is aware of the UNCLEAN hands and have supported the Banks and
Servicers criminal activity ignoring the American Citizen.

The scheme and artifice between the CC Defendants who intentionally and willfully scheme to defraud Plaintiff,
was for the purpose of using color of law and misuse of the Trustee function, to obtain money, attorney fees, and
plaintiffs property for their own benefit by materially false and fraudulent pretense, representations and promises,
by intentionally defrauding both the Plaintiff and Wells Fargo Bank by collecting on a non-existent loan, which they
knew was not collectible, was written off by the bank, and which they interfered with refinancing to cause harm to
Plaintiff and opportunity for themselves.

Manners and means. During the relevant period, Defendants schemed to foreclose on 15 W. Spring St, Alexandria
VA 22301 with knowledge aforethought and despite questions raised in court that there is no valid loan
documentation in existence as required for foreclosure under law. Through deceptive practices foreclosed on
March 30, 2018.

The knowing acts and omissions of BWW, MWC, Brock & Scott, Troutman, AG Herring et al show a pattern and
practice of law firms, government enabling and covering up for each other for their own self-profit. The defendants
represent Foreclosure Mills across America – when law firms and trustees operate fraudulently to cause and create
unnecessary foreclosures – as in this case, solely for their own financial gain.

The knowledgeable acts and actions described herein violate Rules of court, federal law, and the United States
Constitution, by denying JWG fundamental right to Due Process and ownership of property. Under a pattern of
‘legal mortgage fraud’ in administration/collection.

Here, so-called lawyer “Trustees” are attorneys who operate as joint lawyers in the same shared office space, who
double dip by churning illegitimate collection, sale, attorney, and trustee fees in violation of Rules of Ethics and
self-dealing, by churning closed and settled collection accounts into their own profit.

Here, the involved lawyers failed to disclose they operate both as collection lawyers, trustee, and foreclosure
lawyers, without disclosure and in violation of fiduciary and ethical duties.

● 28
The “ Servicer”, the lawyer and the trustee all worked in collusion to provide false and misleading information to
defraud the Plaintiff.

Wire Fraud. The scheme was transmitted by interstate wire communications in writings, emails, telephone calls,
facsimiles all in violation of Section 1343 of Title 18 of the United States Code.

This action’s for appropriate for relief pursuant to the common law, statute and/or Constitution of the United
States of America, for impermissible restraints upon JWG constitutionally protected property, in Violation of the
Fair Debt Collection Practices Act (FDCPA) (15 U.S.C 1692, ET SEQ.), also for Breach of Contract, Honest
Service under 18 U.S.C. § 1346 for the Breach of Fiduciary duty to defraud a homebuyer / owner and deprive her of
the right to honest services without fraud.

Pursuant to the Federal Civil False Claims Act, 31 U.S.C. § 3729 et seq.(to preserve the right of the Government to
become a party to the suit as a Relator in the protection of many others) That the CC Defendants pursued and
continue to pursue foreclosure actions using false and fabricated documents, particularly mortgage assignments to
conceal that they are missing critical documents, namely, the mortgage assignments. Without lawfully executed
mortgage assignments, the value of the mortgages and notes held by the trusts is impaired because effective
assignments are necessary for the trust to foreclose on its assets in the event of mortgage defaults. When the trustee
banks discovered that the mortgage assignments were missing, the trustee banks, together with an associated
servicing company, default Management Company and/or mortgage loan documentation company (OCWEN),
devised and operated a scheme and artifice to replace the missing assignments with fraudulent, fabricated
assignments. The purpose of this scheme was to meet the evidentiary requirements imposed by courts in the
foreclosure cases and to conceal from trust shareholders the true, impaired value of the assets of each of the alleged
trusts, crippled by the missing assignments and related documents, creating illegal foreclosure.

That all this was disclosed in 2010 and the bad behavior of the banks is now the bad behavior of the Servicers. The
Servicers have a front door and by all appearance one set of books for the SEC et al and one for the back door of
fraudulent fake mortgages. That past employee stated they were instructed to create “FAKE” assignments that
consisted of “FAKE” bar numbers as the one Spring St.

Wells Fargo and Bank of America f/k/a LaSalle Bank presently claim they have no loan (including the loan
number claimed by OCWEN), or any other loan under the name Janice Wolk-Grenadier aka Janice Wolk Grenadier
or under her Social Security number. Wells Fargo stated such to the CFPB. Wells Fargo bank has filed in the City
of Alexandria and Notarize letter stating it has no loan.

● 29
Through the attached documentation, JWG shows the shoddy unlawful and unethical practices of this server, the
attorneys and their representatives, including the nonproduction of any original note documents. Counterclaim CC
Defendants and their representatives either generated or rely on loan documents that are forged, robo-signed, or
reversed-engineered., and in a manner that is arbitrary and capricious in dealing with the JWG.

The Fraud carried out by the CC Defendants in this case includes, inter alia:
● Mortgage assignments with forged signatures of the individuals signing on behalf of the grantors, and
forged signatures of the witnesses and the notaries by all appearance;
● Mortgage assignments with signatures of individuals signing as corporate officers for banks and mortgage
companies that never employed them by all appearance;
● Mortgage assignments prepared on behalf of grantors who had never themselves acquired ownership of the
mortgage and notes by a valid transfer, including assignments where the grantor was identified as “Bogus
Assignee for Intervening Assignments” and
● Mortgage assignments notarized by notaries who never witnessed the signatures that they notarized.
● 1099 to the IRS that the IRS has deemed a Fraud
● SEC as a stockholder the playing of double accounting to enhance each financial statements by all
appearance
● False Advertising the home with the wrong address for Wells Fargo Bank and claiming Wells Fargo
Bank was the owner of the home on HudForeclosed. Stated contact Wells Fargo Bank at 800 S Broad
St. Meriden, CT 6450 Tel 860-368-3400 or 860-368-3400 all Fraudulent Nos. The principle of a
California Lawyer not practicing stated the information came from the Bank. The Bank denies any
knowledge of such a listing especially since they don’t own such homes. On around May / June of
2020
● Troutman Pepper Hamilton's Sanders lawyer S. Mohsin Reza requested I do a “SHORT SALE” after the
home was foreclosed with his partner Micheal Marteniz. Mr. Reza even gave him my daughter's phone
number to harass her.
● Troutman Pepper Hamiltons Sanders lawyer S. Mohsin Reza interfered with the answers that Wells Fargo
Bank supplied to the CFPB
● Troutman Pepper Hamiltons Sanders lawyer S. Mohsin Reza did the accounting I requested and never got
from OCWEN it is not readable and does not make note of monies sent to the company
● Troutman Pepper Hamilton Sanders lawyer S. Mohsin Reza lied in the City of Alexandria Circuit Court
when he stated Wells Fargo Bank owned this loan. Or Wells Fargo Bank is lying.

There is nowhere for a homeowner to go for “REAL HELP”. The appearance and the facts show the Government
and the courts have disenfranchised homeowners of all rights

● 30
 STATEMENT of FACTS

That the Wells Fargo N. A. / OCWEN / Troutman Lawyers, Brock & Scott Lawyers et al colluded/conspired
and now have created A defective title
A title that is impaired with a lien or other defect. Defective titles are considered unmarketable, so the
asset in question cannot be transferred or sold legally.
Any encumbrances on a defective title must be cleared before the owner can sell the asset.
That the United States Constitution states clearly in the 5th and 14th Amendment that no one shall be "deprived of
life, liberty or property without due process of law." That JWG has attached Exhibits to show the scheme that
appears to have started in 2006 and documents filed against the home in 2009 put the property at 15 W. Spring St.,
Alexandria VA 22301 on the balance sheet of Wells Fargo Bank and Bank of America aka LaSalle Bank.

A year after the foreclosure OCWEN sent a 1099 A with OCWEN as the owner along with past Insurance
Statements that state OCWEN the Server as Owner. The Server can be the owner but, you have to disclose such
ownership. ALL Lawyers have stated it was Wells Fargo Bank along with OCWEN that Wells Fargo Bank is the
owner.

Wells Fargo Bank from 2012 has stated it has no ownership in Spring St. nor any loans and or interest in any loans
with Janice Wolk Grenadier, 15 W. Spring St. and or under Social Security No. Wells Fargo Bank filed this in the
City of Alexandria Court and then put it in a Notarized Letter.

The Foreclosure was on March 30, 2018 and it is on the open market which I was never notified of, and no where in
the listing does it state the Title is tainted and will stay tainted for life as the Foreclosure was created on Falsified
documents with the support and help of the CC Defendants Lawyers.

That after a Foreclosure your loan should go away - JWG will show that OCWEN/PHH kept such loan on there
books by all appearance and transferred it to NEWRez who also had it on its balance sheet.

That the documents attached will show an unbelievable Scheme / Enterprise of the Banks, Servicers and Lawyers
for personal financial/professional gain. The Listing states Bank owned property - yet the Bank has declared this a
lie.

Mers, Fannie Mae, Freddie Mac have no information on any alleged loan on 15 W. Spring St., Alexandria, VA
22301.

The scheme appears to be headed by Troutman Pepper Hamilton Sanders aka Mays & Valentine who has a conflict
as they with others swindled $30,000. From Plaintiff September of 1990 - to Cover-Up Trust monies stolen from
the Sonia Grenadier Trust. This court Case No. 1:93-cr-00302-CMH - You can Read More:
https://judicialpedia.com/listing/criminal-trust-theft-by-lawyer-jim-arthur-of-troutman-pepper-hamilton-sanders-aka
-mays-valentine-cover-up-of-trust-theft-by-divorce-lawyer-ilona-ely-freedman-grenadier-heckman-of-sonia-grenadi
er/

● 31
For ABUSE AND FRAUDULENT PROCESS by Officers of the Court acting wrongly to take real estate of the
Petitioner located at 15 Spring Street, Alexandria, Virginia 22301, under color of law and fraudulent trustee
process, to intimidate and cause a wrongful auction.

The wrongfully taking of petitioner’s real estate without right established by AUTHentic DOCUMENTS as
REQUIRED BY LAW THEFT BY DECEPTIVE taking: the attorney and trustee acts, under color of law, are
intentionally designed to harass and intimidate JWG has wrongfully deprive her of the United States
Constitutional Rights of Due Process under the 5th and 14th Amendment "deprived of life, liberty or property
without due process of law." by a court and judge with jurisdiction.

1. That Real Estate Property 15 W. Spring St., Alexandria, VA was illegally Foreclosed on March 30 of 2018
and the title is tainted by the collusion and cover-up of defendants / mostly lawyers who have knowledge of
the facts and ignored them for personal and professional self-dealing.
https://www.youtube.com/watch?v=82tllotwvW0 Link to taped foreclosure with Wells Fargo Bank buying
the property back?

2. The Documents prior to the foreclosure will show that from 2009 - 2013 fraudulent/falsified documents
filed against the home put it on the Balance Sheet of Bank of America aka Lasalle Bank and Wells Fargo
Bank by Lorraine Brown of Dox who went to jail.

3. That a letter from BWW Law Group shows it was still on the Bank of America et al and included in a
Federal Settlement - this turned out to be false

4. That a Corrected Lost Assignment filed was done by a Robo-Signer who I have interviewed and stated and
gave several hours of disclosure of the corruption. The State of Virginia requires a review of such
documents by a lawyer - the BAR NO. The document belongs to a Judge in Florida. No such number exists
in Virginia. According to OCWEN/PHH employees, this is a pattern and practice not to use lawyers and
add “FAKE” Bar Numbers.

5. Conversations with Wells Fargo Bank and OCWEN on home which shows it was known by all the scheme
to foreclose on falsified documents and that Wells Fargo Bank had no knowledge

August 10, 2017, Emily with Wells Fargo 8 10 2017 video

27m50s webcamera io Wells Fargo
https://youtu.be/ol0n-EDveLk

August 10, 2017, Emily with Wells Fargo OCWEN 8 9 2017

video 26m26s webcamera io https://youtu.be/ZU_JP9w5sDQ

● 32
August 11, 2017 OCWEN 8 11 2017 video 10m15s webcamera io
https://youtu.be/EUenT0aKsHk

August 11, 2017 OCWEN 2 Video Fri 8011 2017 video 39m22s
webcamera io https://youtu.be/SKZtWosXiUk

August 11, 2017 OCWEN No 3 video 34m10s webcamera io

https://youtu.be/iwMIBXHWtj8

Friday, August 11, 2017, OCWEN No 4 Legal Brenda video

12m34s webcamera io https://youtu.be/qXIy54bvCIo

6. Brook & Scott who foreclosed were told by OCWEN not to. It appears that Troutman Pepper Hamilton
Sanders demanded the foreclosure for personal financial gain.

7. Troutman Pepper Hamitlong Sanders aka Mays & Valentine has a conflict as they with others swindled
$30,000. From Plaintiff September of 1990 - to Cover-Up Trust monies stolen from Sonia Grenadier. This
court Case No. 1:93-cr-00302-CMH - You can Read More:
1https://judicialpedia.com/listing/criminal-trust-theft-by-lawyer-jim-arthur-of-troutman-pepper-ham
ilton-sanders-aka-mays-valentine-cover-up-of-trust-theft-by-divorce-lawyer-ilona-ely-freedman-gren
adier-heckman-of-sonia-grenadier/

8. March 29, 2018 - Brock and Scott / OCWEN conversation admits OCWEN had told Brock & Scott to not
Foreclose conv starts at about 6 min and 40 sec
https://www.youtube.com/watch?v=00gWnLp11vI&t=1127s

9. The illegal Foreclosure took place on March 30, 2018, with the bank Wells Fargo Bank purchasing the
home - JWG is still in the property https://www.youtube.com/watch?v=82tllotwvW0

10. On April 6, 2018, Brock and Scott filed a Deed that Wells Fargo Bank was the Owner of the Loan. The
lawyers have stated in several documents and in court that Wells Fargo Bank is the lender.

11. On or around April 4 2019 Troutman Pepper Hamilton Sanders Lawyer S. Mohsin Reza exposes that he
and his “Friend” want me to short sell my home to them. That his friend states they can get Wells Fargo to
do whatever they want - There are taped conversations

12. On March 31, 2019, JWG received 1098 stating the owner was OCWEN - the IRS finds this to be a fraud
and the complaint is being moved to the Tax Court in Washington DC

13. On August 26,2019 JWG received a letter from OCWEN / PHH is transfer to new servicer after the
foreclosure NewRez

14. On October 1, 2019 Copy of Computer - print out for NewRez loan

15. On or around February 10, 2020 Exhibits 22 - 24 Servicer for Loan No. 7143312465 JWG received a
letters from New Rez they now had a loan on property 15 W. Spring St. The home was foreclosed on
March of 2018 and in 2020 JWG is getting letter from a new Servicer?

16. That the documents from signing into accounts will show now after the foreclosure JWG still had a loan
with Two Servicers.

● 33
 17. Bank of America has always taken a stand they had no ownership and or an interest in a loan on 15 W.
Spring St., but never took the corrective steps to ensure JWG was not harmed by lawyers et al.

18. On April 4, 2020 Troutman Pepper Hamilton Sanders Reza Moushin asked JWG to agree to sell the
property - knowing the Title of the property was tainted. He would then go on to harass me and my
daughters by giving out our phone numbers by all appearances to his friend Micheal Martinez who several
taped conversations will show the intent and the insider relationship.

19. On or around Nov 18, 2018 Wells Fargo Bank answered discovery and stated they had no loan on 15
W. Spring St. and filed it directly in the City of Alexandria court. They also had no knowledge that
Troutman Pepper Hamilton Sanders was representing them.

20. Wells Fargo Bank answered discovery on August 6, 2019 and August 7, 2019 with a Notarized Letter that
they had no loan or ownership of 15 W. Spring St., Alexandria, VA 22301. Again Wells Fargo Bank had no
knowledge of lawyers Troutman Pepper Hamilton Sanders

21. That in or around 2021 the home without notification to Plaintiff was put on the market for Sale by
Altisource, Houbzu, REALHOME SERVICES AND SOLUTIONS, INC. aka Altisource, and MLS
BRIGHT the problem is nowhere on the listing did they disclose the tainted title. Misleading the public of
a home that was illegally foreclosed on.

22. That the majority of those involved are Lawyers, Realtors and have an obligation under the professional
code of ethics and the law to report such corruption and collusion.

23. They have a responsibility to the public to protect it from such a fraud and the very least to disclose it in
any listing to the public that they will pay over $1 million for a property that the bank has tainted the title
with the filing of there document in the court that they have no interest in such property.

BACKGROUND AFTER FORECLOSURE On MARCH 30, 2018

Of 15 W. Spring St., Alexandria, VA 22301

Complainant is entitled to the relief for the following reasons:

1. That JWG can show that Wells Fargo Bank N. A. had no standing to foreclose and OCWEN using
Identity Theft, Money Laundering, Insurance Fraud and many other criminal acts foreclosed on 15 W.
Spring St., Alexandria, VA 22301
2. That you can hear OCWEN telling Brock & Scott NOTto Foreclose on Spring St. @ Brock and Scott /
OCWEN conversation March 2019 Admits OCWEN had told them to not Foreclose conv starts at about
6 min and 40 sec https://www.youtube.com/watch?v=00gWnLp11vI&t=1127s

3. That you can then see the Foreclosure taped: The Foreclosure by Wells Fargo NOT OCWEN a total
SCAM March 2018. https://www.youtube.com/watch?v=82tllotwvW0
4. The Deed attached shows the property in the name of Wells Fargo N.A. et al with an odd caveat for
OCWEN.

● 34
 5. Troutman Sanders then approached JWG on or around April 4, 2019 Troutman Sanders Lawyer S. Moshin
Reza asked JWG to do a short sale on a home that had been foreclosed. Micheal Martinez appears to be an
agent of Troutman Sanders whose investors in the Foreclosure properties are located in Florida and New
Jersey. Further Mr. Martinez stated “Wells Fargo will be easy to deal with and will do almost anything we
want” paraphrase.
6. That in or around November of 2018 both Bank of America and Wells Fargo Bank responded to subpoenas
that neither had any documentation to being a party to a loan on 15 W. Spring Street, Alexandria, VA 22301
7. On or around August 8, 2019 Wells Fargo Bank did a notarized document that they had no documentation.
8. That OCWEN the loan servicer did a fraudulent 1099 to the IRS that is under investigation.
9. That PHH on or around August 26, 2019 sent a Letter stating Loan Servicing Moved to NewRezLLC.
NewRez LLC was created by PHH in or around 2008 and sold prior to PHH moving to OCWEN in 2018
to New Ressidential Investment Corp traded as NRZ. Investors can be seen
10. According to insiders of OCWEN: OCWEN is going out of business or into Bankruptcy and is moving any
and all assets. The top 10 investors by CNN on or around Jan 30, 2020 of Wells Fargo Bank, Bank of
America, OCWEN and New Residential Investment Corp.
11. On January 5, 2020 in Wells Fargo’s research they looked towards Mers to show the loan history - they did
not believe me at first this alleged loan is nowhere to be found in Mers (even though they have filed
documents against the home putting it in a Mtg Back Sec that it did not meet the criteria), FNMA, Freddie
Mac, my personal credit report since around 2012 show no none ownership of any loan.
12. The CFPB / JWG have requested documentation that shows OCWEN / Wells Fargo Bank / Bank of
America to give some type of document and all have been denied. The documents provided have had no
substance.

RE: DEMAND to remove the “ILLEGAL, FRAUDULENT FILING” TO MISLEAD on the ownership of a
alleged loan on 15 W. Spring St., Alexandria, VA 22301

The law is clear and included in this letter that three (3) assignments were filed illegally against 15 W. Spring
Street, Alexandria, VA 22301 due to not being prepared properly by a lawyer, but by a lay person acting as a
lawyer and using another's Florida State Bar No. This includes the VA Code that rules the Clerk's Office, as well as
stated in the Virginia State Bars code of Professional Conduct for Practicing Law without a license.

HISTORY OF FRAUDULENT DOCUMENTS AGAINST SPRING ST

Prior to the Foreclosure

1. Filed on or around February 4, 2009 against 15 W. Spring Street, Alexandria, VA 22301 Document No.
190003603 000551 000075 “Notice of Assignment of Deed of Trust” Virginia fraud on the court
with the basics of Virginia fraud claim requires proof of:

(1) a false representation, that the loan went to a Mtg Back Security that was closed prior to the loan being
created
● 35
 (2) of a present, material fact, the Assignment was done by a non-lawyer Rob Meharg
(3) made intentionally and knowingly, That Docx person Lorraine Brown went to jail for the “Black
Market” Back Door loans
(4) with intent to mislead, the letter by Bank of America through BWW Law Group shows the intend in or
around December of 2012
(5) reasonable reliance by the party misled, and the Facts that Lorraine Brown went to jail the fact the Mtg
Back Security was closed on or around July 1, 2003 and the alleged loan is dated February of 4, 2005
(6) resulting damage. Illegal Foreclosure on March 30, 2019

2. Filed on or around June 18, 2009 against 15 W. Spring Street, Alexandria, VA 22301 Document NO.
090012907 000253 000076 “Notice of Assignment of Deed of Trust” Virginia fraud on the court
with the basics of Virginia fraud claim requires proof of:

(1) a false representation, that the loan went to a Mtg Back Security that was closed prior to the loan being
created
(2) of a present, material fact, the Assignment was done by a non-lawyer Rob Meharg
(3) made intentionally and knowingly, That Docx person Lorraine Brown went to jail for the “Black
Market” Back Door Mortgage Back Securities for the “Back Room” for financial gains of Banks and
Servicers
(4) with intent to mislead, the letter by Bank of America through BWW Law Group shows the intend in or
around December of 2012
(5) reasonable reliance by the party misled, and the Facts that Lorraine Brown went to jail the fact the Mtg
Back Security was closed on or around July 1, 2003 and the alleged loan is dated February of 4, 2005
(6) resulting damage. Illegal Foreclosure on March 30, 2019

3. Filed on or around April 22, 2013 against 15 W. Spring Street, Alexandria, VA 22301 Document No.
130014851 000586, 000587 000071 “Affidavit of Lost Assignment” Virginia fraud on the court with
the basics of Virginia fraud claim requires proof of:

Sister Nora Nash states: OCWEN and Altisource, through a systematically designed process, induce
foreclosures and then sell these foreclosed homes on HUBZU.com so they can earn listing commissions,
Buyer's Premium, Escrow Fees, Web Technology Fee, Property Preservation Fees, Title Insurance Fees,
Closing Coordination Fees and more!

(1) a false representation, After BWW Law Group failed at foreclosure and questions asked, and evidence
of the fraud presented to Servicer and Lawyers they created by a non-lawyer a “Affidavit of Lost
Assignment” using a Judge Donald Alexander in Florida Bar number
(2) of a present, material fact, That Wells Fargo Bank in phone calls and written to CRPB and this court no
ownership or any involvement in any loan with 15 W. Spring St. Alexandria, VA 22301
(3) made intentionally and knowingly, the Facts are clear JWG had disclosed to Howard Bierman of BWW
Law Group the Fraud
(4) with intent to mislead, The filing with the Commissioner, and the foreclosure itself showed OCWEN et
al believe they are above the law as long as there is financial gain for lawyers
(5) reasonable reliance by the party misled, and The foreclosure on March 30, 2018

April 4, 2019 at Prince Georges MD - Courthouse Mohsin Reza of Troutman Sanders asks JWG
“Are you interested in a short sale” JWG stated clearly “NO” and then asked by Mr. Reza “if I had gotten
● 36
 a recent call about selling the home” you will notice this TEXT sent March 23, 2019. Michael as he states
has contacted me in the past and even had been given my daughters phone number in the past. The
Question Becomes: “BLACK MARKET” by lawyers and WHO ELSE harassing and forcing short
sales on illegal foreclosures

March 29, 2018 Phone call between OCWEN, Janice Wolk

Grenadier and Brock & Scott aka Trustee Services Of Virginia,
LLC., where OCWEN informs Brock & Scott and Brock & Scott
acknowledge that on or around March 22, 2018 they had received
notice from OCWEN not to foreclose. They then received from the
Investor that no matter what they were to foreclose - ignoring
whatever OCWEN said.
https://www.youtube.com/watch?v=00gWnLp11vI&t=562s

On March 30, 2018 OCWEN Loan Servicing held an illegal

foreclosure on 15 W. Spring St., Alexandria VA 22301. The
property owner then and legally still today is Janice Wolk
Grenadier. Video March 30, 2018 The foreclosure
https://www.youtube.com/watch?v=82tllotwvW0

On or around April 6, 2018 a Trustee Deed was filed on the

property that Wells Fargo Bank National Association, as Trustee
for Option One Mortgage Loan Trust 2005-2, Asset Backed
Certificates, Series 2005-2 Trustee for Option One (Mtg Back Security does not exist) see attached

On or around December 8, 2018 Wells Fargo Bank N. A. would file in the courthouse of the City of Alexandria
in response to a Subpoena by JWG that they had no interest in this foreclosure or this home - see attached

On or around February 3, 2019 Janice received from OCWEN a Fraudulent 1099-A Acquisition or
Abandonment of Secured Property Information Returns that stated they “OCWEN” not Servicing, not LLC only
OCWEN is / was the lender on the loan (OCWEN on its own does not exist as an entity). The IRS has deemed
this 1099 from evidence presented to be “FRAUDULENT” and has told Janice Wolk Grenadier to ignore such 1099
while Criminal Investigation is starting. See attached - It should be noted Janice Wolk Grenadier is still at home.

OCWEN Entities found: Ocwen Loan Servicing, which is licensed to service mortgages in the state, used
unlicensed affiliate offshore companies to “perform activities considered residential mortgage loan servicing.”
Ocwen Financial Solutions Private Limited, operating out of a location in India, and Ocwen Business Solutions,
operating out of a location in the Philippines, to conduct “servicing” activities on residential mortgage loans. VA
SCC states OCWEN is Licensed as:

F1991993 OCWEN BUSINESS SOLUTIONS, INC. Foreign Corporation Active

F1995820 OCWEN FINANCIAL INSURANCE SERVICES, INC. Foreign Corporation Active

F1564386 OCWEN FINANCIAL SOLUTIONS PRIVATE LIMITED Foreign Corporation Active

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 T0206161 OCWEN LOAN SERVICING, LLC Foreign Limited Liability Company Active

OCWEN filed a 1099-A Acquisition or Abandonment of Secured Property with the IRS where Ocwen was not a
secured creditor.

Ocwen Financial Corporation is a provider of residential and commercial mortgage loan servicing, special
servicing, and asset management services, which has been described as "essentially debt collectors, collecting
monthly principal and interest from homeowners". Ocwen is headquartered in West Palm Beach, Florida, with
additional offices in Addison, Texas, Orlando, Florida, Houston, Texas, Rancho Cordova, California, St. Croix, U.S.
Virgin Islands, and Washington, D.C. It also has support operations in the Philippines and India.

Ocwen under 26 U.S.C. § 7434 willfully filed fraudulent 1099 information returns with the IRS 26 U.S.C. §
7434. Civil damages for fraudulent filing of information returns9. That OCWEN never lent any money to Janice
Wolk Grenadier thus suffered no financial loss and was not a secured creditor under any state property laws. That
the Trustee Deed and OCWEN acting as the Servicer at all times stated clearly that Wells Fargo Bank was the
lender and or Wells Fargo Bank National Association, as Trustee for Option One Mortgage Loan Trust 2005-2,
Asset Backed Certificates, Series 2005-2 Trustee for Option One (Mtg Back Security does not exist).

Banks: All Banks state in writing to Janice Wolk Grenadier and the CFPB they have no knowledge, no
information and no involvement in or on a loan against Janice Wolk Grenadier and or 15 W. Spring St., Alexandria
VA 22301

● Bank of America aka LaSalle Bank

● Wells Fargo

That on or around April 3, 2019 Wells Fargo Bank N. A. made it clear they are cooperating and most likely
working with OCWEN and supporting the “Black Market” Mortgage Back Securities and the “FRAUD”

(6) resulting damage. The foreclosure on March 30, 2019 was and is Common law theories of negligence,
gross negligence, payment by mistake, unjust enrichment, money had and received, breach of fiduciary
duty, breach of contract, misrepresentation, deceit, fraud, and aiding and abetting, Retaliation and
Retribution, RICO & Racketeering, the cruelty of the acts and actions are and where willful acts were
malicious, violent, oppressive, fraudulent, wanton or grossly reckless, any of the foregoing all acts
and actions have been knowledgeable by lawyers, banks and Servicers et al ;

The VSB: https://www.vsb.org/pro-guidelines/index.php/unauthorized-practice-rules/rule-6/

Violating Unauthorized Practice of Law Rule 6 Real Estate Practice 6-1010 (B) (C),UPR 6-102 (A), UPR 6-103
(A) (B) UPR 6-106 UPC 6-1 UPC 6-2 UPC 6-4 UPC 6-8

9
26 USC § 7434. Civil damages for fraudulent filing of information returns(a) In general If any person willfully files a fraudulent information return
with respect to payments purported to be made to any other person, such other person may bring a civil action for damages against the person so filing such
return.(b) Damages In any action brought under subsection (a), upon a finding of liability on the part of the defendant, the defendant shall be liable to the
plaintiff in an amount equal to the greater of $5,000 or the sum of—(1) any actual damages sustained by the plaintiff as a proximate result of the filing of the
fraudulent information return (including any costs attributable to resolving deficiencies asserted as a result of such filing),(2) the costs of the action, and(3) in
the court’s discretion, reasonable attorneys’ fees.(c) Period for bringing action Notwithstanding any other provision of law, an action to enforce the liability
created under this section may be brought without regard to the amount in controversy and may be brought only within the later of—(1) 6 years after the date
of the filing of the fraudulent information return, or(2) 1 year after the date such fraudulent information return would have been discovered by exercise of
reasonable care.(d) Copy of complaint filed with IRS Any person bringing an action under subsection (a) shall provide a copy of the complaint to the Internal
Revenue Service upon the filing of such complaint with the court.(e) Finding of court to include correct amount of payment The decision of the court
awarding damages in an action brought under subsection (a) shall include a finding of the correct amount which should have been reported in the information
return.(f) Information return For purposes of this section, the term “information return” means any statement described in section 6724(d)(1)(A).(Added Pub.
L. 104-168, title VI, § 601(a), July 30, 1996, 110 Stat. 1462; amended Pub. L. 105-206, title VI, § 6023(29), July 22, 1998, 112 Stat. 826.) A prior section 7434
was renumbered 7437 of this title. 1998—Subsec. (b)(3). Pub. L. 105-206 substituted “attorneys’ fees” for “attorneys fees”. Pub. L. 104-168, title VI, § 601(c),
July 30, 1996, 110 Stat. 1462, provided that: “The amendments made by this section [enacting this section and renumbering former section 7434 as 7435 of
this title] shall apply to fraudulent information returns filed after the date of the enactment of this Act [July 30, 1996].”
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JWG asked for a response prior to May 1, 2019 due to a court hearing on May 6, 2019 in regard to the
Commissioners Case CASE NO. CW 1800 1465 where I have filed a Motion for the Judge to remove the
Assignments and I would appreciate your support of such actions. I WAS IGNORED.

13. In May June of 2020 the home was listed for Sale, the home with the wrong address for Wells Fargo Bank
and claiming Wells Fargo Bank was the owner of the home on HudForeclosed. Stated contact Wells Fargo
Bank at 800 S Broad St. Meriden, CT 6450 Tel 860-368-3400 or 860-368-3400 all Fraudulent Nos. The
principle of a California Lawyer not practicing stated the information came from the Bank. the Bank
denies any knowledge of such a listing especially since they don’t own such a home. On around May /
June of 2020
14. To harass and try to embarrass JWG the beginning of May 2020 this MeMe was put on the internet - This is
the pattern and practice to just keep throwing things at one person to see if you can break them and shut
them up? Or maybe your goal and this “GANG” is hoping I will commit suicide. I will not. Or maybe
you think I will become afraid of you - You can go to my blog VALaw2010.blogspot.com or to the new
website I have founded JudicialPedia.com to see I am not running. I am Standing Up and Speaking Out
against the corruption

BACKGROUND PRIOR TO FORECLOSURE

Plaintiff incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

On February 4, 2005 JWG took out an alleged loan from Mortgage and Equity Funding Corporation. The alleged
loan in question went immediately to Option One Mortgage Corporation for servicing.

Option One was purchased by American Home Mortgage Servicing Inc. on or around May 17, 2008
American Home Mortgage Servicing Inc. was purchased by Homeward Residential on or around February 17,
2012.

Homeward Residential transferred to OCWEN and JWG alleged loan was transferred Tuesday February 19, 2013
(the day prior Monday February 18, 2013 was a Federal Holiday for Presidents day with the Banking industry
closed.)

On or around December 18, 2012 BWW-Law Group sent JWG a letter stating that Bank of America owned her
loan. BWW-Law was sending the letter under an obligation under Section IV.D.6 of the National Mortgage
Settlement, which Wells Fargo was not a party to.

Robo-Signers. On or around December 28 of 2012 Bank of America representatives denied ever owning such a
loan. Bank of America purchased LaSalle Bank October 1, 2007. February 24, 2009 and February June 18, 2009
Bank of America f/k/a LaSalle Bank filing - Notice of Assignment of Deed of Trust using nationally known
Robo-signers Linda Green (VP) [Ex 5], Tywannia Thomas ( Asst. VP ), and Korell Harp (VP). Exhibit 2 is both
Assignments

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Linda Green. It was proven in the USA and Lynn E. Szymoniak vs. American Home Mtg et al that Linda Green
was not employed by American Home Serving, Inc. and did not have any authority to sign.

Tywannia Thomas. She did not sign all of the documents that her name is affixed on the DOCX – prepared
assignments. The use of several different corporate titles exists.

Korell Harp. Also did not sign all the documents to which his name is affixed.

Affixing or submitting false signatures on a mortgage document is a violation of federal and state law, and those
signatures are without authority to complete the transaction. According to a mortgage fraud notice prepared jointly
by the Federal Bureau of Investigation and the Mortgage Bankers Association, submitting false mortgage
assignments and forging signatures violates potentially eight federal criminal statutes. Specifically: (1) 18 U.S.C.
§1001 – Statements or entries generally; (2) 18 U.S.C. § 1010 - HUD and Federal Housing Administration
transactions; (3) 18 U.S.C. § 1014 – Loan and credit applications generally; (4) 18 U.S.C. § 1028 – Fraud and
related activity in connection with identification documents; (5) 18 U.S.C. § 1341 – Frauds and swindles by mail;
(6) 18 U.S.C. § 1342 – Fictitious name or address; (7) 18 U.S.C. § 1343 – Fraud by wire; and (8) 18 U.S.C. § 1344
10 – Bank Fraud. See FBI Mortgage Fraud Notice (available at
http://www.mbaa.org/FBIMortgageFraudWarning.htm); see, also, Truth in Lending Act, title 1 of the Consumer
Credit Protection Act, as amended 15 U.S.C. § 1601 et seq. ; Mortgage Fraud.

False or fraudulent notary acknowledgements are also a violation.

The signatures contained on the assignments filed in Foreclosure are fraudulent, in violation of Federal and Virginia
law, and therefore they do not serve to assign the note and mortgage properly, they lack the essential authority for
Defendants to act on note and mortgage and Defendants cannot foreclose.

The practice of fraudulent mortgage assignments is widespread across the United States. Defendants have the
knowledge of the serious problems of their fraudulent actions to cover up / conceal this problem. That nothing has
changed since 2010.

Defendants Use of Fake Documents, False Officer Titles and Forged Signatures violates Federal Lending Law,
State Mortgage Fraud law and Notary Fraud law.

Title. On or around December 28 / 31, 2012 JWG called BWWLaw Group and asked who owned the loan on 15 W.
Spring Street? According to a letter on December 18, 2012, the owner was Bank of America –but Bank of America
denied such ownership. BWWLaw group referred JWG back to the Homeward Residential that BWW Law Group
had no knowledge who owned the loan.

JWG was in the process of applying for the Government Independent Foreclosure Review and learned about the
possibility of this break in the chain of title.

The HAMP Program. In 2008 and thereafter, Homeward on a Deed Mortification through the programs offered
by Congress. The Servicers reaped excessive false rewards for losing/processing refinance documents because of a
flaw in a financial incentive for servicers document handling, motivating Servicers to delay, loose paperwork etc.
Servicers of loans such as JWG, received money per application /and document/ but not per person, creating a
reward for negligent and fraudulent corporate/organizational bad behaviors that deprived or deterred homeowner
refinancing, such as occurred here.
● 40
Improper interference with JWG HAMP Application. On or around January 28, 2013, Homeward Mortgage sent
JWG a Notice of Servicing Transfer (RESPA) and Welcome to OCWEN Loan Servicing, LLC

Homeward Mortgage servicing was the servicer of JWG loan till February 18, 2013. February 19, 2013 OCWEN
became the servicer. The Homeward Mortgage supervisor had advised JWG on three different occasions that all
documents were in place for the HAMP Modification. Homeward then kept coming back with issues that JWG had
been told by Homeward that they were cleared up. The Homeward supervisor had left JWG a message that the
foreclosure of her home had been stayed.

February 19, 2013 JWG phoned OCWEN to confirm that there had not been any issue that the foreclosure had
been stayed as the BWW Law Group still showed it active on BWW Law website. OCWEN informed JWG she
would need to re-submit documents for the HAMP Program – but to “ignore the foreclosure date because a
“foreclosure sale cannot be conducted” until after the evaluation of the HAMP program is complete and a borrower
found ineligible. As long as JWG was being considered for the HAMP the foreclosure could not go forward” JWG
went over this statement three times with the agent at OCWEN. OCWEN could not have been more helpful and
was reassuring about the foreclosure not going ahead. The phone conversation was close to an hour going over
everything.

February 20, 2013 JWG phoned OCWEN again and went through the fact the foreclosure was still on the website
schedule of BWWLaw Group, and would OCWEN please contact BWWLaw? OCWEN again reassured Plaintiff
they could not foreclose as the process had begun with OCWEN and it was illegal to foreclose.

February 20, 2013 JWG sent emails to BWW Law Group after being unable to reach BWWLaw group on the
phone about the pending foreclosure. BWWLaw Group informed JWG that the alleged owner of the loan (Equity
Trustees) had made the decision and planned to move forward to foreclose on JWG property. In December 2012
(two months earlier) BWWLaw Group had no idea who owned JWG’s loan or who had the original note.

JWG continued to try to contact BWWLaw Group through phone calls and emails. through the end of business
February 20, 2013.

JWG made phone calls to OCWEN and supervisors at OCWEN, who were at a loss as to how to help JWG.
OCWEN claimed to have never seen a situation like this. OCWEN kept informing Plaintiff that BWW Law group
could not foreclose prior to or on April 17, 2013 and only thereafter if Plaintiffs’ documents had not been received
by OCWEN. Phone calls are taped. OCWEN has never turned over documents of phone calls et al

With no other recourse, and based on BWWLaw Group bad faith, JWG was forced to file involuntary Bankruptcy
February 21, 2013 to protect her interest in the property. Video available

On February 21, 2013 JWG could not get through to a voice-mail or anyone at BWWLaw group, which at times
blocked JWG calls and emails. JWG took a copy of the receipt for the bankruptcy to the address of the alleged
“owner” of the loan (according to BWWLaw Group – was “Equity Trustees” with an address of 2020 14th Street
N., Suite 250 Arlington Va 22201. Plaintiff delivered the bankruptcy receipt in person, because on the website for
BWWLaw, showed only addresses in Richmond, VA and Bethesda, Md.

February 21, 2013. JWG was shocked to discover that BWW Law group and Equity Trustees LLC ``shared” the
same office! The actions of BWW Law (by refusing to turn over a copy of JWG original note and other
● 41
information) but/while concealing that they ‘sharing’ offices with the foreclosure trustee, indicates egregious
self-interest and malicious intent to defraud JWG. Here, they actively (by omission and affirmative acts)
intentionally interfered and violated JWG rights to participate and reap the rewards of the Government backed
HAMP program, by actively setting her up for foreclosure in violation of law.. These Actions of Equity Trustees
LLC, BWWLaw Group and other defendants were and are willful acts that are self-interest, malicious, violent,
oppressive, fraudulent, wanton, and grossly reckless in light of the fiduciary nature of the law/firm/trustee duties.

On February 22, 2013 JWG e-mailed Allison Melton, an associate at BWW Law requesting a copy of the Spring
Street original note, and Allison (an associate with BWW Law Group) denied her request

On March 1, 2013 JWG returned to the offices of BWW- Law Group and Equity Trustees, LLC to hand deliver a
“qualified written request” under the Federal Servicer Act, which is a part of the Real Estate Settlement Procedures
Act, 12 U.S.C. 2605 (e). Requesting by law the information JWG had been denied by Plaintiff .

The letter at page 4, reminds Equity Trustees of the mandatory duty to acknowledge receipt of this qualified written
request within 20 business days, pursuant to 12 U.S.C. Section 2605 (e) (1)(A) and Reg. X Section 2500.21 (e)(1).
Equity Trustees LLC “shares” offices with BWWLaw Group, and is owned by lawyers, who are expected to be
cognizant of the federal and state laws regarding their “specialty.” Here self-interest and greed seem to 13 have
motivated the law firm/lawyers to violate federal law/rights and fiduciary duties owed to the Plaintiff because they
controlled the documents and intentionally kept them from JWG.

JWG is an Entrepreneur and as a result of Melton's improper interference she lost funding because BWW Law
advertised her home for foreclosure February 7, 2013. JWG worked diligently with Homeward and OCWENt o
prevent foreclosure and by filing for Bankruptcy.

BWW-Law group f/k/a Bierman, Geesing, Ward & Wood, LLC acted in its own best interest by putting its own best
interests and that of the other lawyers, before the best interest of the JWG.

Robo-Signers. Jacob Geesing is a partner of BWW Law Group and since October 13, 2010 is publicly known as
“The Robo Trustee.”

Attorney Howard N. Bierman, also of BWW Law Group, is also publicly known as a Robo Signer included in 4
different signatures on JWG’s forged documents by the BWW Law Group.

Documents filed against 15 W. Spring St. by BWWLaw Group Deed of Appointment of substitute Trustee June 2,
2006 Deed of appointment of Substitute Trustee prepared by BWW- Law Group on or around March 23, 2012 –
but, not signed by BWW-Law Group – Signed by April King VP reading – Wells Fargo Bank, N.A. as Trustee for
Option One Mortgage Loans Trust 2005-2 Asset Backed Certificates, Series 2005-2 ( Option One Mortgage shuts
down and is sold on or around May 17, 2008 to AHMSI) [Ex 18 ] By: American Home Mortgage Servicing Inc.
(AHMSI)

The absence of any valid promissory note( necessary for enforcement on a secured interest), and the recent Wells
Fargo CEO/office representation that there is no bank interest, and that Wells Fargo is not involved in the lawyer
collection/foreclosure/auction process – demonstrate improper Plaintiff actions on a loan which is no longer
enforceable or supported in law.

● 42
BWW-Law Group and Equity Trustees LLC acted in bad faith and apparent self interest when both ignored all
correspondence from JWG.

On or Around May 17, 2012 JWG learned Mark R. Galbraith was representing Wells Fargo.

JWG reached out to Mr. Galbraith by phone and email. Mr. Galbraith also refused to answer any questions in regard
to whether Wells Fargo had the original Note for 15 West Spring Street, Alexandria, Va. 22301.

Other Documents filed in Court-- February 4, 2005 – Deed of Trust – Mortgage Equity Funding Corp July 9, 2007 -
Corporation Assignment of Deed of Trust – Prepared by Option One Mortgage Corp December 18, 2007 – Loan
Mortification Agreement – Option One Mortgage

Lawyer overcompensation based on unacceptable and inappropriate practices. It has been well documented in U.S.
Congressional oversight that lawyer practices, such as the lawyer/trustees in this case ( who ignored the Servicing
Companies conversations with this homeowner) – are unethical practices lawyers engage in who are afraid of losing
foreclosure income and assets payable to their law firm - practices involving foreclosure, banks, eviction or closing,
including Robo-signing.

The U.S. House Committee on Oversight and Government Relations, in response to inquiry from Congressman
Elijah Cummings, wrote from theFederal Housing Finance Agency on May 13, 201, a letter which establishes ( as
improper practices) the acquisition of real estate using illegitimate foreclosure practices - a lawyer practice of
self-interest, such as occurred in this case. Page 3 describes as “Attorney Misconduct”, self-dealing and
inappropriate practices, which itemizes the practices in this case as “unacceptable” and shows Forms 104DC
submitted to Freddie Mac by the Servicers that S & B (Shapiro & Burson LLP) were paid to the lawyers - 2009 - $
3,369,146.14 By – FREDDIE MAC’S SERVICERS 2010 - $ 6,342,051.30 By - FdREDDIE MAC’S SERVICERS
In the First quarter of 2011 - $ 1,746,816.13 By – FREDDIE MAC’S SERVICERS The amounts are not broken out
into separate categories for the type of matter handled, but include payments for services provided for foreclosures,
bankruptcies, eviction, and closings in Maryland and Virginia.

The Question then becomes, what is the difference between BWW-Law Group f/k/a BIERMAN, GEESING,
WARD & Wood, LLC and Shapiro & Burson LLP and now McCabe Weisberg and Conway? When you search the
Internet for Maryland and Virginia you see no difference in the criminal activities of both law firms. The answer
will come after a FOIA request for the 104DC will be submitted to Freddie Mac.

On or around Judge James Clark of the City of Alexandria for “Friendship” and other illegal reasons give Divorce
lawyer Ilona Ely Freedman Grenadier the right to foreclose on 15 W. Spring St, Alexandria VA 22301 – This Fraud
included the help of DiMuroGinsberg, Troutman Sanders aka Mays & Valentine (1990 stole $30,000 from plaintiff
to help cover up thefts of lawyer Ilona Grenadier Heckman and James Arthur with false and fraudulent, misleading
information)

Once again forcing Janice Wolk Grenadier into Bankruptcy.

What this does is show the FORECLOSURE MILLS / LAWYERS collusion to make it a pattern and practice to
ensure the MURDER of and or the homeless of Janice Wolk Grenadier who continues to STAND UP and SPEAK
OUT of the corruption with even illegally jailing her and holding her in solitary confinement for 14 days. October
22, 2014 – November 12, 2014 – 22 days Janice illegally jailed and tortured in the City of Alexandria, Solitary
Confinement till 5pm on Election day Tuesday, November 4, 2014. Illegally Jailed to:
● 43
 1. Silence her and stop exposure of e-mails between herself and Mark Warner’s office on the corruption in
the Judiciary. Janice went to Mark Warner for help instead he had her jailed, at the same time it was
exposed his “Pay to Play '' with a Federal Judgeship for a favor. Being ignored by the Senate Ethics
Committee.

2. To Bully / scare her into either committing Suicide or to turning the other check of the corruption and not
holding Virginia and the Federal Judiciary, the Government and Elected Officials accountable, as well as
the criminal acts and actions of the Old Boys Network in Virginia That the law is very clear: That Judge
Clarks actions have turned back time. Giving me less rights than a slave. Taking someone under Title 42
US Code 1994 and Title 18 US Code 1581(a): Whoever holds or returns any person to a condition of
PEONAGE, shall be fined under this title for imprisonment not more than 20 years or both.

3. That on October 22, 2014 I was placed in jail for failure to pay legal fees in 30 days which is a violation
of my Thirteenth Amendment "Neither Slavery not involuntary servitude, except as punishment for a crime
where of the party shall have duly convicted, shall exist within the United States, or any subject to their
Jurisdiction". Furthermore the right by placing me 16 "under" a state Peonage / Involuntary Servitude
violating the Fourth Amendment right by malicious prosecution, false imprisonment and unconstitutional
arrest. This violation of my Eighth Amendment Right as to Excessive Bail which in this case constitutes
"Restitution Bail" which further shows the knowledgeable malicious intent to silence me till the election
was over on November 4th. 2014. Bias, Retaliation and Retribution to further line the Lawyers pockets by
Judge Clark. Further: The system is one where the Lawyers and Judges have set it up to protect each other
and line each other's pockets with Cash.

That the lack of duty of care, fair dealing and Good Faith when dealing with homeowners as the Big Banks
negotiated their way out of Jail and paid the United States Government $251 Billion Dollars should not be ignored.
The questions are does the $251 Billion compel improper for influence or favor of the Judiciary? Further that vested
by the Constitution and the Oath of Office taken by the Judiciary, the Government and the Elected Officials are
bound by the unique Oath of Office that they take to “preserve, protect and defend the Constitution of the United
States of America” and ensure Due Process in our courts.

That despite disclaimers and legal arguments, banks can’t walk away from their duty of due care and good faith.
That the documents filed against 15 W. Spring Street, have been forged in conflict with the law to enhance
the balance sheet of Bank of America aka LaSalle Bank, Wells Fargo, Option One and Equity Trustees that
this alone should be a concern of all Judges. That it shows an illegal conversion of loans to enhance the balance
sheet, while harming the title of the home at the same time. A loss that occurred because of their failure to perform
those duties is a loss to the bank – not the customer / homeowner who knew nothing about the “problem” Hence the
arguments of servicers (and the undisclosed principals for whom they act), banks and trustees of REMIC Trusts and
even trustees on deeds of trust and self proclaimed mortgagees and beneficiaries on deeds of trust should be
rejected if the homeowner has alleged, based upon ultimate facts upon which relief could be granted, that the entity
failed to act in good faith and due care.

That the Exhibits filed with this case showed the lack of care taken in legal documents filed against the home.

OCWEN in the original suit have ignored the rules of the Fourth Circuit Court, and have never filed a response or
properly put notice into the Court as to the appearance of the lawyers without badgering from the court.

● 44
The court has an obligation to a pro se “poor person” of care, fair dealing and Good Faith.

That the Banks and Lawyers also had a duty of care, fair dealing and Good Faith.

Troutman Pepper Hamilton Sanders aka Troutman Sanders aka Mays & Valentine swindled with the help of
Divorce Lawyer Ilona Grenadier Heckman $30,000. For monies Divorce Lawyer Ilona admitted in 2008 of stealing
out of her law firm from using a forged Trust Addendum to the Sonia Grenadier Trust (mother of the late Judge
Albert Grenadier her 2nd husband and her third husband Judge Grenadier’s 1 st cousin c. 9 months after his death
by all appearance colluded with her). The Note for the money “borrowed” is still with the Grenadier Starace Duffett
& Levi Law firm due after 30 years in 2020. The only copy demanded as my lawyer sits in Ilona’s safe according to
Ilona who stated at the time “Let me keep this for safe keeping” who JWG was naive and trusted her.

Wells Fargo and OCWEN lawyers colluded with Divorce Lawyer Ilona Grenadier Heckman in the City of
Alexandria Case No. CL1500 – 3661 to ensure and help Lawyer Ilona deny JWG, all JWG rights and monies owed
to Janice from being divorced without a Property Settlement. The settlement would have resolved this case. That
TroutmanSanders aka Mays & Valentine has a real fright of being held accountable for collusion of the thefts from
JWG.

The following e-mail states clearly how Troutman Sanders relationships with Judges are how they ignore the law.

Further Mohsin Reza profile on the Troutman Sanders states he is an expert at: Mohsin Reza’s practice focusing on
representing corporate clients in complex litigation in state and federal courts. Mohsin represents financial
institutions in various commercial, consumer, and lender liability disputes, including lawsuits involving claims
brought under the Fair Credit Reporting Act, the Fair Debt Collection Practices Act, the Equal Credit Opportunity
Act, the Truth-in-Lending Act, the Telephone Consumer Protection Act, the Real Estate Settlement Procedures Act,
the Uniform Commercial Code, and state consumer protection statutes. Mohsin also represents small and large
businesses in defending against and asserting claims of negligence, breach of contract, fraud, civil conspiracy, and
business torts. Furthermore, he has experience representing clients in estate litigation and probate matters.

● 45
That Wells Fargo, Option One, Equity Trustees, Bank of America all in one way or another have claimed ownership
of a loan. BWW Law Group, Howard Bierman and several bad actors from McCabe Weisberg & Conway, Michael
Weiser ESQ, DiMuroGinsberg, Parker Simon & Kokolis LLC, McQuireWoods, TroutmanSanders LLP, Grenadier
Starace duffett & Levi PC, Hunoval Law, OCWEN have all acted as Debt collectors under the “FDCPA” Fair Debt
Collection Practices Act. And the “CFPB” Consumer Financial Protection Act of 2010 which has independent
litigating authority to commence civil actions to address violations of the “Federal Consumer Financial Laws”, with
DOJ, FTC and others having additional oversight.

Violating: all the 15 U.S. Code Subchapter V - DEBT COLLECTION PRACTICES Current through Pub. L.
114-38. (See Public Laws for the current Congress.) 15 SC § 1692 - § 1692d - Harassment or abuse § 1692e - False
or misleading representations § 1692f - Unfair practices § 1692g - Validation of debts § 1692j - Furnishing certain
deceptive forms

Further Violating with Knowledgeable intent: FDCPA Laws & Guidelines of the Fair Debt Collection Act and debt
collection services in your area. Table of Contents 801 Short title 804 Acquisition of location information 805
Communication in connection with debt collection 806 Harassment or abuse 807 False or misleading
representations 808 Unfair practices 809 Validation of debts 812 Furnishing certain deceptive forms 801 15 USC
1601 note 801. This short sale title may be cited as the "Fair Debt Collection Practices Act." 802. Congressional
findings and declaration of purpose (a) There is abundant evidence of the use of abusive, deceptive, and unfair debt
collection practices by many debt collectors. Abusive debt collection practices contribute to the number of personal
bankruptcies, to marital instability, to the loss of jobs, and to invasions of individual privacy. (b) Existing laws and
procedures for redressing these injuries are inadequate to protect consumers. As Lawyers the Defendants and others
know their wrong doing. (c) Means other than misrepresentation or other abusive debt collection practices are
available for the effective collection of debts. (d) Abusive debt collection practices are carried on to a substantial
extent in interstate commerce and through means and instrumentalities of such commerce. Even where abusive debt
collection practices are purely intrastate in character, they nevertheless directly affect interstate commerce. (e) It is
the purpose of this title to eliminate abusive debt collection practices by debt collectors, to insure that those debt
collectors who refrain from using abusive debt collection practices are not competitively disadvantaged, and to
promote consistent State action to protect consumers against debt collection abuses.

That OCWEN uses the name and Scheme as WELLS FARGO BANK as their employee has shopped lawyers and
now hired McCabe Weisberg and Conway/ Brock & Scott to ignore suits and Foreclose. On or around May 17,
2017 a letter was received by them that stated clearly that Wells Fargo had no instruments that should have been
standing, which is what Plaintiff has been claiming.

Which would be followed with a letter to Foreclose on July 20, 2017

On or around July 9, 2017 a Motion to Stay Foreclosure by Wells Fargo, OCWEN by McCabe Weisberg & Conway
was filed by Janice with this court as an Emergency Stay due to the shopping of a law firm that would Foreclose
while still in court. The following Documents filed with it should be incorporated herein. (That a Reconsideration
and EnBanc has been filed)

That MCW letter dated July 18, 2017 from McCabe Weisberg & Conway LLC which was received on the 21st of
July 2017.

● 46
The Letter seemed misleading and with all the above had been done to deny Janice and Janice’s Constitutional
Rights Janice created a Trust and on July 25, 2017 did a Quick Claim Deed of 15 W. Spring Street, Alexandria VA
22301 into the Trust. Janice mailed a copy to OCWEN.

On or around Friday July 28, 2017 Janice would receive Occupant; Homeowner and Janice Wolk Grenadier
letters stop your foreclosure.

On or around Tuesday August 1, 2017 Janice would receive a letter from McCabe Weisberg & Conway LLC that
they were foreclosing on 15 W. Spring St., Alexandria VA 22301 on August 17, 2017. That with such a
misleading letter on or around May 21, 2017 the research of the misleading and appearance of criminal acts and
actions of many sent Janice to learn that the SEC which forwarded Janice to CRPB, the DOJ, the FTC, 15 USC
1692 and the FDCPA protected Janice from PREDATORY ACTS and ACTIONS of Wells Fargo, Option One,
Equity Trustees, Bank of America all in one way or another have claimed ownership of a loan. BWW Law Group,
Howard Bierman and several bad actors from McCabe Weisberg & Conway, Michael Weiser ESQ,
DiMuroGinsberg, Parker Simon & Kokolis LLC, McQuireWoods, TroutmanSanders LLP, Grenadier Starace duffett
& Levi PC, Hunoval Law and OCWEN.

Virginia has no regulations for Deceptive and Abusive practices by debt collectors so Janice is protected by the
Federal Fair Debt Collection Practices Act (FDCPA).

The Statute of Limitations to collect on a debt is 3 – 5 years from the last payment accepted.

According to OCWEN the last payment not returned was 3,152 days from June 16, 2017, with the last payment in
2008 that the Statute of Limitations on Collection had run out.

That Plaintiff only did the Trust / Quick Claim Deed due to the Predatory acts and actions of Defendants,
Defendants lawyers and others.

JWG moved the property prior to any notification of the new foreclosure date (which according to the FDCPA and
others the date is illegally done) and or a Judgment that a Re-Consideration with an EN BANC, and Oral
Arguments is filed.

That on August 9, 2017 Janice would receive a phone call from OCWEN that the Foreclosure had been canceled as
of August 4, 2017 – Phone conversations is taped and can be heard

That on August 11, 2017 after sending email and several unreturned phone calls from McCabe (Remember this
scheme and artifice of OCWEN to say one thing and do another Janice was and still is a VICTIM Of with BWW
Law Group. The McCabe et al would not return calls to confirm Foreclosure was removed from their schedule.

On August 11, 2017 from OCWEN she learned that the foreclosure was never removed, that OCWEN and McCabe
had schemed no differently illegally and in collusion to try and deceive JWG that the Foreclosure had been
removed from the schedule. That this illegal practice by OCWEN and Lawyers acting as Foreclosure Mills to
further line their pockets is a pattern and practice all across America.

On August 11, 2017 Janice would call the CEO of Wells Fargo’s office to ensure he was aware of the CRIMINAL
ACTIVITY of his Servicer and Lawyers. Janice would learn in a taped conversation that Wells Fargo has no loan

● 47
under the Loan No. given by OCWEN, under her name as Janice Wolk Grenadier or Janice Wolk-Grenadier or
under her Social Security No.

That JWG on several occasions offered to settle and why should opposing sides settle or consider a settlement
when they know with or without the Truth the duty of care, fair dealing and Good Faith the Judges will ignore all
criminal acts and actions by the Banks and Lawyers as shown in the above e-mail.

That JWG is still willing to try and settle this matter. At this point the home is in a Trust and protected by the law /
Statute of Limitations of Collections on a loan.

On August 17, 2017 at or around 10:00 am JWG would receive notice from MWC that the FRAUD allegations
have been taken seriously and the foreclosure put on hold.

Then as stated above and described on March 18, 2018 the home was illegally foreclosed on ignoring the law and
rights of the homeowner.
CAUSES OF ACTION

Count 1
18 USC § 371 Conspiracy, Federal False Claims Act, 31 U.S.C. § 3729 (a)(1)(A); 31 U. S. C. § 3729 (a)1(B); 31
U.S.C. § (a)(1)(C) 18 USC §1349 Attempt and Conspiracy forms Fair Debt. Collection Act (FDCPA) § 806
Harassment, § 807 False and misleading, § 808 Unfair practices, § 809 Validation of debts, § 812 Furnishing
deceptive forms, et al

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint.

CC Defendants and others known and unknown did knowingly and unlawfully combine, conspire, confederate, and
agree to commit the following offenses against Janice Wolk Grenadier a. to, directly and indirectly, corruptly give,
offer, and promise a thing of value, that is, among other things, cash or cash equivalents, with intent to influence
illegal acts, to commit and aid in committing, and to collude in, and allow fraud, and make opportunity for the
commission of any fraud, on the United States,

PURPOSES OF THE CONSPIRACY to ensure the COVER UP of Divorce Lawyer Ilona Grenadier Hackman’s
crimes as attached in Exhibit Criminal Complaint filed with the Department of Justice et al.

Manner and Means of the Conspiracy: Includes Elected Officials, the Government and the Judiciary to protect
one of their own.

OVERT ACTS: That divorce lawyer Ilona Grenadier Heckman has been on a Criminal Spree stealing out of her
law firm that Janice can document starting on or around November of 1983 with the forgery of Sonia Grenadier
Heckman. That the defendants are two of many USED to try and silence, mislead and act criminally to protect the
accountable $30 MILLION if not more that Ilona stole through her law firm from Sonia Grenadier the mother of
the late Judge Albert Grenadier and then Janice Wolk Grenadier which by the Banks, the Servicers lawyers
involvement has created the scheme and artifice to prevent Janice any type of financial where for all.

This is a claim for treble damages and forfeitures under the False Claims Act, 31 U.S.C. § 3729 et seq. 2

● 48
The CC Defendants created, sold or participated in Mortgage backed securities. The Mortgage backed Securities
were composed of mortgages bundled to create the securities in which the mortgages lacked the requisites to create
a secured, real estate debt obligation, namely:

The legally binding assignments from the originating bank to the securities trust and, and finally, to the foreclosure
agent

Recording of Title in the Cities Clerk's office

Original Note and Mortgage, signed by both borrower and lender. The prospectus for each mortgage-backed
securities trust, and other public statements, falsely represented that the trust held good title to the mortgages and
notes bundled in the securities.

By Virtue of the wrongful conduct alleged here including, but not limited to, the false signatures used in
manufactured mortgage assignments, or stating the person had POWER OF ATTORNEY which does not exist each
of the mortgage-backed securities sold to the Treasury, or other entity funded by the U.S. government, violated state
and federal laws and furthered an effort to transfer impaired securities to the Treasury, or other government funded
entity. CC Defendants and their agents and employees falsely represented that they held good title to 15 W. Spring
Street. CC Defendants received millions of dollars in U.S. government funds to provide services involving
fraudulent mortgage assignments. Accordingly, the Defendants and their agents and employees knowingly
presented or caused to be presented a false or fraudulent claim for payment or approval from the government entity
purchasing the mortgage-backed securities.

CC Defendants and their agents and employees falsely represented that they had a good title to 15 W. Spring Street.
When in Fact they had in their knowledgeable fraudulent actions created a cloud on the Title making the home
unsellable.

CC Defendants acted in concert to create fraudulent legal documentation to conceal that the trust was missing title
to the asset, thus impairing the value of the security sold to the treasury, or other government funded entity. Each of
the mortgage-backed securities sold to the Treasury, or other government funded entity, was in violation of state and
federal law.

THE GOVERNMENT (AG Eric Holder, Ben Bernanke & ) SELLS OUT THE AMERICAN PEOPLE

The Financial Crisis Inquiry Report: Final report of the National Commission on the Causes of the Financial
Economic Crisis in the United State of America
https://www.govinfo.gov/content/pkg/GPO-FCIC/pdf/GPO-FCIC.pdf - This link will take you to the Official
Government Edition.

Some of the Banks that received the SECRET Bail out through AIG

Bank of America $ 1,535,002,662,031

Citi $ 1,535,002,662,031
Goldman Sachs $ 874,552,426,455
JP Morgan Chase $ 460,982,382,326
Morgan Stanley $ 2,287,966,932,941

● 49
Wells Fargo $ 198,712,559,776

Then 5,000. of the Executives received at least $1 MILLION in bonus each

CASES YOU CAN’T Or Shouldn’t ignore IGNORE

Other then the Two CFPB Cases Above:

BEAR STEARNS MORTGAGE PASS-THROUGH CERTIFICATES LITIGATION / : 850

Securities/Commodities Date September 18, 2008 City/County New York Type of Case 850
Securities/Commodities Class Action Complaint for Violation of the Securities Act of 1933
https://judicialpedia.com/listing/bear-stearns-mortgage-pass-through-certificates-litigation-850-securities-commodities
/

Case Number 1:09-cv-06172-LTS Lead case: 1:08-cv-08093-LTS Member case: (View Member Case) Related
Case: 1:08-cv-08093-LTS Cause: 15:78m(a) Securities Exchange Act
Judges Judge Laura Taylor Swain Read More:
https://judicialpedia.com/listing/bear-stearns-mortgage-pass-through-certificates-litigation-850-securities-commodities
/

BEAR STEARNS MORTGAGE PASS-THROUGH CERTIFICATES LITIGATION / : 850

Securities/Commodities Date September 18, 2008 City/County New York Type of Case 850
Securities/Commodities Class Action Complaint for Violation of the Securities Act of 1933 Case Number
1:09-cv-06172-LTS Lead case: 1:08-cv-08093-LTS Member case: (View Member Case) Related Case:
1:08-cv-08093-LTS Cause: 15:78m(a) Securities Exchange Act Judges Judge Laura Taylor Swain
https://judicialpedia.com/listing/bear-stearns-mortgage-pass-through-certificates-litigation-850-securities-commodities
/

Carvelli v OCWEN Financial Who Regulates Whom? Who's Regulating the BANKS & SERVICER'S?
FORECLOSURE COMPLAINTS UP STATES THE CFPB Date April 21, 2017 City/County West Palm Beach
Type of Case Cause: 15:0077 Securities Fraud Nature of Suit: 850 Securities/Commodities
https://judicialpedia.com/listing/carvelli-v-ocwen-financial-who-regulates-whom-whos-regulating-the-banks-servicers
-foreclosure-complaints-up-states-the-cfpb/

Federal Housing Finance Agency v. JPMorgan Chase & Co. et al Nature of Suit: 850 Securities/Commodities
Were you told to not make payments by your Servicer? Date September 2, 2011 City/County New York City
Type of Case Cause: 15:77 Securities Fraud / 850 Securities/Commodities Jurisdiction: U.S. Government Plaintiff
https://judicialpedia.com/listing/federal-housing-finance-agency-v-jpmorgan-chase-co-et-al-nature-of-suit-850-securiti
es-commodities-were-you-told-to-not-make-payments-by-your-servicer/

In Re: BEAR STEARNS MORTGAGE PASS-THROUGH CERTIFICATES LITIGATION / 850

Securities/Commodities Jurisdiction: Federal Question / Date September 18, 2008 City/County New York Type of
Case 850 Securities / Commodities Case Number 1:08-cv-08093-LTS - Related Case: 1:09-cv-06172-LTS Related
Case No. 1:09-cv-06172-LTS Case in other court: Supreme Court-County of New York, 602426- 08
Judges Judge Laura Taylor Swain
https://judicialpedia.com/listing/in-re-bear-stearns-mortgage-pass-through-certificates-litigation-850-securities-comm
odities-jurisdiction-federal-question/

● 50
 John Hancock Life Insurance Company (U.S.A.) et al v. JP Morgan Chase & Co / 850 Securities/Commodities
Date April 23, 2012 City/County New York City Type of Case 850 Securities/Commodities
Case Number 1;12-cv-03184- RJS Case in other court: Supreme Court- New York County, 650195-12 Cause:
28:1441nr Notice of Removal Judges Judge Richard J. Sullivan
https://judicialpedia.com/listing/john-hancock-life-insurance-company-u-s-a-et-al-v-jp-morgan-chase-co-850-securitie
s-commodities/

LYNN E SZYMONIAK "HERO" Whistleblower ILLEGAL FORECLOSURE STILL HAPPENING WITH

"FAKE" MORTGAGE BACK SECURITIES Date June 4, 2010 City/County Rock Hill Type of Case
FORECLOSURE Case Number 0:10-cv-01465-JFA Related Cases 0:15-mc-000062-JFA 0:13-cv-00464-JFA
Judges Judge Joseph F. Anderson, Jr
https://judicialpedia.com/listing/lynn-e-szymoniak-hero-whistleblower-illegal-foreclosure-still-happening-with-fake-
mortgage-back-securities/

Stichting Pensioenfonds ABP v. JPMorgan Chase & Co. et al / 850 Securities/Commodities

Date February 24, 2013 City/County New York City Type of Case : 850 Securities/Commodities case is
hereby designated for inclusion in the Pilot Project Regarding Case Management Techniques for Complex Civil
Cases in the Southern District of New York (the Pilot Project), Case Number 1:12-cv-01398-LAK Case in
other court: State Court- Supreme, 653383-11 Cause: 28:1441nr Notice of Removal Judges Judge Lewis A.
Kaplan
https://judicialpedia.com/listing/stichting-pensioenfonds-abp-v-jpmorgan-chase-co-et-al-850-securities-commodities/

Powell et al v. Ocwen Financial Corporation et al 29 U.S. Code § 1109.Liability for breach of fiduciary duty
Date March 5, 2018 City/County New York Type of Case Cause: 29:1109 Breach of Fiduciary Duties,
Nature of Suit: 791 Labor: E.R.I.S.A, Jurisdiction: Federal Question
Case Number 1:18-cv-01951-VSB-SDA Judges Assigned to: Judge Vernon S. Broderick Referred to:
Magistrate Judge Stewart D. Aaron
https://judicialpedia.com/listing/powell-et-al-v-ocwen-financial-corporation-et-al-29-u-s-code-%c2%a7%e2%80%af1
109-liability-for-breach-of-fiduciary-duty/

COUNT 2
Breach of Contract – Implied Covenant of Good Faith and Fair Dealing –
Breach of Contractual Duty of Good Faith and Fair Dealing Honest Services 18 U.S.C. § 1346

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

By virtue of the facts stated above, defendants have violated their contractual duty of good faith and fair dealing.
Honest Service under 18 U.S.C. § 1346 the CC Defendants schemed to foreclose on JWG home with forged
documents, with knowledgeable intent of Fraud.

The above CC defendants and CC defendant’s representatives breached their contractual duty of good faith and fair
dealing when they refused to provide the requested original Note.

The above CC defendants Breach of Contract includes not limited to their involvement with breaking the chain of
title and creating a situation where JWG could not sell the home . The documents speak for themselves that the
defendants were aware of these breaches.

● 51
JWG through implied covenant of good faith and Fair Dealing continued to work with the different Servicing
groups even after they continued to lose paperwork, and make false claims, and advertise her home for a
Foreclosure Sale.

The CC defendant’s “flagrantly violated” their Fiduciary responsibility to JWG to deal in Good Faith while JWG
continued to deal in Good Faith.

That a Breach of Contract was created when the documents by Wells Fargo, Bank of America were forged, by
known robo signers.

That now Wells Fargo Bank and Bank of America claim no alleged ownership while a Servicer needs an employer
to foreclose – needs a contract to show it has any type of STANDING. OCWEN has used it’s own employees to
fraudulently sign rights over to Surety Trustees who must know as it states right on it – OCWEN employees. AS
Debt Collectors that they state clearly they are, they need to ensure that the debt they are collecting is a legitimate
debt and owned by OCWEN. MCW was informed that it was not a legitimate debt owned by OCWEN.

Count 3
Violation of the Fair Debt Collection Practices Act (FDCPA)
(15 U.S.C 1692, ET SEQ.) § 1692e - False or misleading representations § 1692f - Unfair practices § 1692g -
Validation of debt § 1692j - Furnishing certain deceptive forms forms Fair Debt. Collection Act (FDCPA) §
806 Harassment, § 807 False and misleading, § 808 Unfair practices, § 809 Validation of debts, § 812
Furnishing deceptive forms, et al

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

That there is no debt as the statute of limitations for collection has run out, the banks Wells Fargo and Bank of
America have stated they have no loan that they can account for.

CC Defendants used unfair/unconscionable means to try and foreclose illegally and unethically on 15 West Spring
Street while Plaintiff was under the production of the HAMP program as described in paragraph

That the statute of limitations to collect on any type of debt has passed

That the documents filed against t the home by OCWEN, BWW Law Group, Brock and Scott, MCW are fraudulent
as Wells Fargo in a taped conversation out of the CEO’s Executive office states very clearly they have no loan
under the Loan No. of OCWEN, under the name Janice Wolk Grenadier or Janice Wolk – Grenadier or under
Janice’s social security No.

Further Stating that Evette Morales who signed as Attorney in Fact for Wells Fargo Bank does not have a Power of
Attorney to do such act for 15 W. Spring St. Alexandria VA 22301.

Further to ignore the STAY as issued by the 4th Circuit is in direct conflict of the lawyers Professional Code of
Ethics Cinder with the court 3.3 Further a self reporting group Lawyers and Judges have an obligation to report
criminal activity by Servicers and Banks. The appearance is OCWEN, BWW Law Group, Brock and Scott and
MCW is further lining their pockets as well as being a party to the Cover Up of Divorce Lawyer Ilona Grenadier
Heckman’s Criminal Spree.

● 52
Further even the Attorney General's Office has stated to OCWEN this Foreclosure should not take place as an
investigation is underway.
Count 4
Wrongful Foreclosure Threat and Foreclosure – Failure to Comply with HAMP rules

JWG incorporates herein by reference all of the allegations contained in the above a. Paragraphs of this Complaint

HAMP PROHIBITS A PARTICIPATING server from taking several actions including the following:

Proceeding with a foreclosure sale. Any foreclosure sale must be suspended and no new foreclosure action may be
initiated during the trial period, and until the borrower has been considered and found ineligible for other available
foreclosure prevention options.

Requiring a borrower to make an initial contribution payment pending the processing of the trial period plan before
the plan starts.

Soliciting borrowers to opt out of consideration for HAMP during the temporary review period.

Reporting borrowers as delinquent to credit reporting bureaus without explanation. For borrowers who are current
when they enter a trial period, the servicer should report the borrower current but on modified payment if the
borrower makes timely payments during the trial period. For borrowers who are delinquent when they enter the trial
period, the servicer should report in such a manner that accurately reflects the borrower’s current workout status.

Assessing prepayment penalties for full or partial prepayment as part of the modification.

The HAMP rules were expressed to JWG several times by AHMSI, Homeward and OCWEN - that you
could not be foreclosed on while you were being considered for the program.

It is documented that lawyers are nervous of losing the financial gain of Foreclosures stopping due to their illegal
and unethical practices. That if the homeowner gets into the HAMP program and an adjustment is made to the loan
– the lawyer loses an extra $50,000 or more. he gets from a foreclosure.

BWW Law group and now McCabe Weisberg and Conway, Brock and Scott Pllc had no other motivation to
foreclose on Plaintiff except for personal financial gain, greed and the exposure of their illegal and unethical
practices and for COVER UP of others criminal activity as stated in the CFPB Complaint of

The attached emails will back up these intentions being malicious, violent, oppressive, fraudulent, wanton,
or grossly reckless.

JWG after CC Defendants lawyers Troutman Sanders aka Mays & Valentine attached themselves to the Cover Up
of Divorce Lawyer Ilona Grenadier Heckman’s Criminal Spree to help deny Janice any and all Justice in the courts
in collecting her monies owed her from the THEFT of Ilona she is unable to if there was a loan qualify.

That the defendants have impeded with their lawyers the ability for Janice to earn a living

● 53
The BWW Law Group, the MCW, PARKER, SIMON & KOKOLIS LLC, the Brock and Scott Lawyers
attached Exhibits back up their intentions being malicious, violent, oppressive, fraudulent, wanton, or
grossly reckless.
Count 5
Consumer Protection Act

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

Bank of America and Wells Fargo used representatives to use unfair or deceptive acts or practices in forgery and
robo signing / FORGERIES of documents were deliberate with knowledgeable acts and actions to COVER UP
criminal behavior.

The deceptive acts of BWW Law Group, MCW, Brock and Scott, PARKER, SIMON & KOKOLIS LLC, and
Troutman Sanders aka Mays & Valentine lawyers for OCWEN have caused JWG the loss of Funding for her
company, and monies due her from her divorce and the opportunity to meet the guidelines needed for the Hamp
Loan.

That the CC defendants OCWEN is directly involved in helping to cover up the Criminal spree of divorce lawyer
Ilona Grenadier Heckman and now with the help of MCW LLC, BWW Law Group and Brock and Scott PLLC

Count 6
Breach of Fiduciary Duty - Unjust Enrichment/Constructive Trust

JWG incorporates herein by reference all of the allegations contained in the above a. Paragraphs of this Complaint

BWW Law, MCW, PARKER, SIMON & KOKOLIS LLC, and Brock & Scott breached its Fiduciary Duty when it
put its financial gain above the law and the rights of JWG.

BWW Law, MCW, PARKER, SIMON & KOKOLIS LLC, and Brock & Scott breached its Fiduciary Duty when it
ignored the HAMP rules for financial gain and greed.

Bank of America and its representatives breached its Fiduciary Duty with the Robo Signing / forgery of documents
breaking the chain of title on 15 West Spring Street.

Well Fargo and its representative breached its Fiduciary Duty with the Robo Signing / forgery of documents
breaking the chain of title on 15 West Spring Street.

MCW LLP, PARKER SIMON & KOKOLIS LLC, BWW Law Group, Howard Bierman, and Mark Galbraith,
Brock & Scott breached their Fiduciary Duty with the refusal of production of the original Note or any proof of the
right to Foreclose on 15 West Spring Street.

OCWEN and the above as well as BWW Law, MCW, PARKER SIMON & KOKOLIS LLC, and Brock & Scott
have and had a responsibility of good faith and fair dealings that they have ignored.

Further the double dipping and filing of fraudulent documents against 15 W. Spring St with their Trustee company

That documentation from JWG since on or around 2010 has been requested and ignored.
● 54
Stating that Wells Fargo is the Note Holder while Wells Fargo informs CFPB they have nothing to do with a loan at
15 W. Spring St., Alexandria VA 22301 and or with Janice Wolk Grenadier. See Exhibits

Cc Defendant lack of standing. That on or around 2013, CC Defendant OCWEN became aware of its lack of
standing to pursue any type of foreclosure action on JWG’s home, located at 15 W. Spring Street, Alexandria VA
2230, but they nevertheless, for their own financial profit and gain, pursued illegal collection remedies that have
wrongfully harmed this JWG.

That Evette Morales who signed as attorney in Fact for Wells Fargo Bank is an employee of OCWEN. The person
who notarized the document that gave Surety Trustee aka McCabe Weisberg and Conway the right to Foreclose has
the same title as Evette Morales and seems to be office mates. Further Wells Fargo Bank denies every giving Evette
Morales any type of POWER OF ATTORNEY to decide who has foreclosure POWER. Evette is a Contract
Management Coordinator at OCWEN Financial Corporation. This job advertises for a salary of $30,000 - $36,000
approx.

That in or around December 2013 - 2014 OCWEN to avoid any criminal charges – no different then in the past with
Wells Fargo Bank and Bank of America did a consent ORDER to cease and desist the criminal activity.

That OCWEN has violated the CONSENT ORDER that was also signed by the Attorney General of Virginia. That
the OAG’s of the State of Virginia’s office has requested this illegal Foreclosure be put on HOLD For further
investigation.

That the CFPB filed this Complaint against OCWEN on or around April 20, 2017: in the USDC of the Southern
District of Florida West Palm Beach Division Case No. 9:17 –cv- 80495 - CFPB v. OCWEN FINANCIAL
CORPORATION a Florida Corporation , OCWEN MORTGAGE SERVING, INC, a US Virgin Islands corporation
AND OCWEN LOAN SERVICING LLC a Delaware Corporation - Defendants Page 2 Paragraph 2 States: The
bureau brings this action against the Defendants under: (1)Sections 1031 and 1036 of the CFPA , 12 USC §§ 5531,
5536; (2) Sections 807 (2)(a), 807(10), and 808 of the Fair Debt Collection Practices Act, 15 USC §§ 1692e(2)(a),
1692e(10), and 1692f (the “FDCPA”); (3) Section 6 and 19 of the Real Estate Settlement Procedures Act (RESPA),
12 USC §§ 2605, 2617, and the regulations, promulgated 29 thereunder at Regulation X, 12 C.F.R. part 1024
(“Regulation X”); (4) Section 105(a) of the Truth and Lending Act (“TILA”), 15 USC § 1604(a), and the
regulations promulgated thereunder act Regulation Z, 12 C.F.R. part 1026 (“Regulation Z”): and (5) Section 3(b) of
Homeowners Protection Act of 1998, 12 USC § 4902(b)(the “HPA”).

That this complaint shows that CFPB knew the acts and actions of OCWEN and that they had UNCLEAN HANDS
and yet allowed the foreclosure shows the COVER UP criminal activity.

The Government and this Court is aware of the UNCLEAN hands and have supported the Banks and Servicers
criminal activity ignoring the American Citizen.

The scheme and artifice between the CC Defendants who intentionally and willfully scheme to defraud JWG,, was
for the purpose of using color of law and misuse of the Trustee function, to obtain money, attorney fees, and
plaintiffs property for their own benefit by materially false and fraudulent pretense, representations and promises,
by intentionally defrauding both JwG and Wells Fargo Bank by collecting on a nonexistent loan, which they knew
was not collectible, was written off by the bank, and which they interfered with refinancing to cause harm to JWG
and opportunity for themselves..
● 55
 Count 7
Injunctive / Declaratory Relief

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

That JWG now needs to pray this court grants temporary or permanent injunctive relief as JWG resides in
the property and as Defendants are seeking, through illegal and unlawful means and without satisfying the
necessary legal standing requirements to institute a foreclosure, take possession, custody, and control of the
Property.
Count 8
Common Law Fraud12 U.S.C 1972

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint.

On several occasions JWG sent money to the Servicing agency of Wells Fargo and Bank of America to only have
funds returned and agreement squashed.

It is very well documented that the Mortgage Servicer’s were instructed to not take any payments and to "work
with you" only after borrowers fall behind in payments. Once borrowers fall behind on purpose and at the lender's
request, foreclosure proceedings begin in earnest. The Foreclosure lawyers and their friends are the beneficiary in
the game, as is seen above with the amount of money Shapiro and Burson have reported making from being one of
Freddie Mac Servicers.

The CC defendants or their representatives on several occasions made false statements of material facts. ie
OCWEN – “Ignore the Foreclosure it is illegal for them to as you are in the HAMP program process”

The CC defendants and or their representatives making these statements knew or should have known it to be untrue;

JWG to whom the statement was made had a right to rely on the statement; but, fortunately knew how deceitful the
defendants had been in the past.

JWG relied on the statement for as long as time permitted.

JWG believes the statement was made for the purpose of inducing the other party to be able to Foreclose on JWG’s
home and gain financially.

JWG relied on the Banks and their representatives at Homeward and OCWEN to not foreclose and to give JWG's
legal right to the opportunity to get Funding for her company and the opportunity to keep her home.

These statements made – created a situation that Plaintiff was not able to get the funding needed for her company,
giving her the income to qualify for a loan.
Count 9
Negligence – the negligent infliction of emotional distress;
the intentional infliction of emotional distress

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

● 56
The CC defendant’s had a legal duty to use reasonable care to protect the Chain of Title to the property at 15 West
Spring Street. By not doing this simple act the defendant’s malicious actions caused great emotional distress to
Plaintiff.

That Evette Morales who claims to have a Power of Attorney from Wells Fargo Bank and signs as Attorney in Fact,
OCWEN and its attorneys have shown no employee contract with Wells Fargo on alleged loan as Wells Fargo and
Bank of America have claimed no ownership in alleged loan and further Wells Fargo Bank claims never to have
given such Power of Attorney.

The actions of the actors to cause this emotional distress were malicious, violent, oppressive, fraudulent, wanton, or
grossly reckless.

The CC defendants failed in their duty and unreasonably caused emotional distress to JWG with intentional
infliction of emotional distress. The negligence is sufficient to support this cause of action.

The CC defendants were negligent in all actions against JWG and 15 West Spring Street not following the law and
the Rules of the HAMP program.

The defendants had a Fiduciary Duty to JWG, the public and 15 West Spring Street.

Count 10
Constructive Fraud,,18 USC § 1341
Frauds and Swindles 18 USC § 1343 Fraud by Wire, 18 USC §1344
Bank Fraud 18 USC §1346 Honest Services 18 USC § 1348 Securities and Commodities fraud

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

The defendants were deceptive of material misrepresentations of past and existing facts and remained silent when a
duty to speak existed.

That in 2014 OCWEN in a consent ORDER was commanded to cease and desist all criminal activity and in return
would not be pressed with criminal charges. OCWEN did not follow the Consent Order and continues illegal
foreclosures.

That on or around April 20, 2017 the CFPB filed a new suit in the USDC of Southern District of Florida West Palm
Beach Division Case No. 937-cv- 80495 which claims it has not stopped their criminal activities.

The CFPB has on its site:

COMPLAINTS:

Option One Showing 27,176 matches out of 1,744,719 total complaints

American Home Mortgage Servicing Showing 18,754 matches out of 1,744,719 total complaints
PHH Mortgage Showing 3,261 matches out of 1,744,719 total complaints
OCWEN Mortgage Showing 3 0,219 matches out of 1,744,719 total complaints
Wells Fargo Bank Showing 80,785 matches out of 1,744,719 total complaints
Bank of America Showing 119,746 matches out of 1,744,719 total complaints
● 57
The CFPB further States:
Mortgage Servicer’s Widespread Errors, Shortcuts, and Runarounds Cost Borrowers Money, Homes

APR 20, 2017

WASHINGTON, D.C. — The Consumer Financial Protection Bureau (CFPB) today sued one of the country’s
largest nonbank mortgage loan servicers, Ocwen Financial Corporation, and its subsidiaries for failing borrowers at
every stage of the mortgage servicing process. The Bureau alleges that Ocwen’s years of widespread errors,
shortcuts, and runarounds cost some borrowers money and others their homes. Ocwen allegedly botched basic
functions like sending accurate monthly statements, properly crediting payments, and handling taxes and insurance.
Allegedly, Ocwen also illegally foreclosed on struggling borrowers, ignored customer complaints, and sold off the
servicing rights to loans without fully disclosing the mistakes it made in borrowers’ records. The Florida Attorney
General took a similar action against Ocwen today in a separate lawsuit. Many state financial regulators are also
independently issuing cease-and-desist and license revocation orders against Ocwen for escrow management and
licensing issues today.

"Ocwen has repeatedly made mistakes and taken shortcuts at every stage of the mortgage servicing process, costing
some consumers money and others their homes," said CFPB Director Richard Cordray. "Borrowers have no say
over who services their mortgage, so the Bureau will remain vigilant to ensure they get fair treatment."

Ocwen, headquartered in West Palm Beach, Fla., is one of the nation’s largest nonbank mortgage servicers. As of
Dec. 31, 2016, Ocwen serviced almost 1.4 million loans with an aggregate unpaid principal balance of $209 billion.
It services loans for borrowers in all 50 states and the District of Columbia. A mortgage servicer collects payments
from the mortgage borrower and forwards those payments to the owner of the loan. It handles customer service,
collections, loan modifications, and foreclosures. Ocwen specializes in servicing subprime or delinquent loans.

The CFPB uncovered substantial evidence that Ocwen has engaged in significant and systemic misconduct at
nearly every stage of the mortgage servicing process. The CFPB is charged with enforcing the Dodd-Frank Wall
Street Reform and Consumer Protection Act, which protects consumers from unfair, deceptive, or abusive acts or
practices, and other federal consumer financial laws. In addition, the Bureau adopted common-sense rules for the
mortgage servicing market that first took effect in January 2014. The CFPB’s mortgage servicing rules require that
servicers promptly credit payments and correct errors on request. The rules also include strong protections for
struggling homeowners, including those facing foreclosure. In its lawsuit, the CFPB alleges that Ocwen:

● Serviced loans using error-riddled information: Ocwen uses a proprietary system called REALServicing to
process and apply borrower payments, communicate payment information to borrowers, and maintain loan
balance information. Ocwen allegedly loaded inaccurate and incomplete information into its
REALServicing system. And even when data was accurate, REALServicing generated errors because of
system failures and deficient programming. To manage this risk, Ocwen tried manual workarounds, but
they often failed to correct inaccuracies and produced still more errors. Ocwen then used this faulty
information to service borrowers’ loans. In 2014, Ocwen’s head of servicing described its system as
“ridiculous” and a “train wreck.”

● 58
● Illegally foreclosed on homeowners: Ocwen has long touted its ability to service and modify loans for
troubled borrowers. But allegedly, Ocwen has failed to deliver required foreclosure protections. As a result,
the Bureau alleges that Ocwen has wrongfully initiated foreclosure proceedings on at least 1,000 people,
and has wrongfully held foreclosure sales. Among other illegal practices, Ocwen has initiated the
foreclosure process before completing a review of borrowers’ loss mitigation applications. In other
instances, Ocwen has asked borrowers to submit additional information within 30 days, but foreclosed on
the borrowers before the deadline. Ocwen has also foreclosed on borrowers who were fulfilling their
obligations under a loss mitigation agreement.

● Failed to credit borrowers’ payments: Ocwen has allegedly failed to appropriately credit payments made by
numerous borrowers. Ocwen has also failed to send borrowers accurate periodic statements detailing the
amount due, how payments were applied, total payments received, and other information. Ocwen has also
failed to correct billing and payment errors.

● Botched escrow accounts: Ocwen manages escrow accounts for over 75 percent of the loans it services.
Ocwen has allegedly botched basic tasks in managing these borrower accounts. Because of system
breakdowns and an over-reliance on manually entering information, Ocwen has allegedly failed to conduct
escrow analyses and sent some borrowers’ escrow statements late or not at all. Ocwen also allegedly failed
to properly account for and apply payments by borrowers to address escrow shortages, such as changes in
the account when property taxes go up. One result of this failure has been that some borrowers have paid
inaccurate amounts.

● Mishandled hazard insurance: If a servicer administers an escrow account for a borrower, a servicer must
make timely insurance and/or tax payments on behalf of the borrower. Ocwen, however, has allegedly
failed to make timely insurance payments to pay for borrowers’ home insurance premiums. Ocwen’s
failures led to the lapse of homeowners’ insurance coverage for more than 10,000 borrowers. Some
borrowers were pushed into force-placed insurance.

● Bungled borrowers’ private mortgage insurance: Ocwen allegedly failed to cancel borrowers’ private
mortgage insurance, or PMI, in a timely way, causing consumers to overpay. Generally, borrowers must
purchase PMI when they obtain a mortgage with a down payment of less than 20 percent, or when they
refinance their mortgage with less than 20 percent equity in their property. Servicers must end a borrower’s
requirement to pay PMI when the principal balance of the mortgage reaches 78 percent of the property’s
original value. Since 2014, Ocwen has failed to end borrowers’ PMI on time after learning information in
its REALServicing system was unreliable or missing altogether. Ocwen ultimately overcharged borrowers
about $1.2 million for PMI premiums, and refunded this money only after the fact.

● Deceptively signed up and charged borrowers for add-on products: When servicing borrowers’ mortgage
loans, Ocwen allegedly enrolled some consumers in add-on products through deceptive solicitations and
without their consent. Ocwen then billed and collected payments from these consumers.

● Failed to assist heirs seeking foreclosure alternatives: Ocwen allegedly mishandled accounts for
successors-in-interest, or heirs, to a deceased borrower. These consumers included widows, children, and
other relatives. As a result, Ocwen failed to properly recognize individuals as heirs, and thereby denied
assistance to help avoid foreclosure. In some instances, Ocwen foreclosed on individuals who may have
been eligible to save these homes through a loan modification or other loss mitigation option.

● Failed to adequately investigate and respond to borrower complaints: If an error is made in the servicing of
a mortgage loan, a servicer must generally either correct the error identified by the borrower, called a notice

● 59
 of error, or investigate the alleged error. Since 2014, Ocwen has allegedly routinely failed to properly
acknowledge and investigate complaints, or make necessary corrections. Ocwen changed its policy in April
2015 to address the difficulty its call center had in recognizing and escalating complaints, but these changes
fell short. Under its new policy, borrowers still have to complain at least five times in nine days before
Ocwen automatically escalates their complaint to be resolved. Since April 2015, Ocwen has received more
than 580,000 notices of error and complaints from more than 300,000 different borrowers.

● Failed to provide complete and accurate loan information to new servicers: Ocwen has allegedly failed to
include complete and accurate borrower information when it sold its rights to service thousands of loans to
new mortgage servicers. This has hampered the new servicers’ efforts to comply with laws and investor
guidelines.

The Bureau also alleges that Ocwen has failed to remediate borrowers for the harm it has caused, including the
problems it has created for struggling borrowers who were in default on their loans or who had filed for bankruptcy.
For these groups of borrowers, Ocwen’s servicing errors have been particularly costly.

Through its complaint, filed in federal district court for the Southern District of Florida, the CFPB seeks a court
order requiring Ocwen to follow mortgage servicing law, provide relief for consumers, and pay penalties. The
complaint is not a finding or ruling that the defendants have actually violated the law.
The lawsuit is available at:
https://files.consumerfinance.gov/f/documents/20170420_cfpb_Ocwen-Complaint.pdf

The CFPB has ignored the criminal activity of OCWEN / PHH Mortgage. That not only should a civil suit but a
criminal investigation from what the insiders have stated should be immediately filed

The defendant’s actions were Arbitrary and Capricious absent a rational connection between the facts found and the
choice’s made, made choices that were not in accordance with the law.

Count 11
Civil Conspiracy, Theft by deceptive taking Illegal Conversion of Real Estate

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

The Collusion of the CC Defendants to prevent JWG from the chance at the HAMP refinance, of the loan for her
company, was done with malicious, violent, oppressive, fraudulent, wanton, or grossly reckless intentions.

CC Defendants Civil Conspiracy to Commit Tortious Interference with Contractual Relations abuse of process,
intentional infliction of emotional distress,

Civil conspiracy to commit injurious falsehood by advertising 15 West Spring St in the newspaper for a Foreclosure
Sale that violated the Law and Rules of HAMP. That Wells Fargo Bank has an alleged loan that Wells Fargo Bank
denies.

That the foreclosure now leaves a cloud on the title for life.. One that was illegally, fraudulently offered for Sale by
BWW Law Group, MCW, PARKER, SIMON & KOKOLIS LLC, AND AKA Surety Trustees, and OCWEN.
That the title is riddled with defects from Judges, lawyers and Banks.
● 60
That the apparent Conversion would be for Personal Financial Gain of lawyers, Servicers that had no Bank
Authority to sell such property, and to COVER UP criminal activity as established in The 2013 – 2014 Consent
Order by OCWEN where it is called to Cease and Desist from criminal fraudulent violations by the CFPB.

That all knowledgeable ACTS and ACTIONS by the Defendants and others were for deceptive, malicious acts for
illegal taking of Real Estate.

CC Defendants were in collusion of civil conspiracy to intentionally inflict emotional distress.

Count 12
18 U.S. Code § 666 – Theft or bribery concerning programs receiving Federal funds

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

The clients of OCWEN Bank of America aka LaSalle Bank, Wells Fargo all received by appearance monies in bail
outs, while paying in the Billions to the DOJ for executives to not go to jail.

That indirectly or directly through clients have received Federal Funds by all appearances.

That payday’s to Lawyers are ensured prior to anyone else being paid in the scheme and 33 artifice of fraud on
homeowners as Lawyers and as Trustees
Count 13
Sarbanes – Oxley Act

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

That OCWEN and their lawyers had a responsibility to act in a timely manner that information that Plaintiff has
requested since 2012 Plaintiff has still to this date not received.

The “Corporate and Auditing Accountability, Responsibility, and Transparency Act: that set new United States
Federal Law that expanded requirements for all U.S. Public company boards, management and public accounting
firms. There are also a number of provisions of the act that also apply to privately held companies.

That JWG believes under this act the accounting of OCWEN, Wells Fargo, Bank of America and others in this
Complaint failed.

That in or around Trust Assignment Fraud Letter to SEC , Posted on July 14, 2010 Which you can see nothing
has changed since her suit was won. That the allegations in this suit and the facts are no different than what was
happening in 2010 –

1. OCWEN was Ordered to Cease and Desist in the 2014 Consent Order between OCWEN and the CFPB and
48 other States
2. CFPB in a new Suit against OCWEN alleges the same criminal behavior of FRAUD - WHEN DO THE
JUDGES STAND UP AND SPEAK OUT FOR THE AMERICAN CITIZEN? STOPPING THE ILLEGAL
ACTS AND ACTIONS OF THE SERVICERS, THE BANKS AND THE LAWYERS

● 61
 3. The Banks were given Bail outs, the Servicers the opportunity to follow the law all have instead continued
the criminal activity, Frauds through today.

This is not the complete letter but you can see that Plaintiff had the same Robo-Signers on documents
against Spring St. and Trust is listed as a “VOID” trust under Whistleblower Lynn E. Szymoniak Esq

April 15, 2010 LYNN E. SZYMONIAK, ESQ. in a letter to Mary L. Schapiro, Chairman
Robert S. Khuzami, Director, Division of Enforcement / Securities & Exchange Commission
100 F Street, NE Washington, D.C. 20549 enforcement@sec.gov

Re: Mortgage-Backed Trusts Missing Critical Documents

Dear Chairman Schapiro and Director Khuzami:

This is a report of suspected fraud involving mortgage-back securities. Certain mortgage

backed trusts have been using forged and fraudulent mortgage assignments in foreclosure actions in
Florida, and throughout the United States. These assignments are most often produced by
employees of Lender Processing Services, Inc., (“LPS”), a mortgage default management company
located in Jacksonville, FL. LPS produced several million Mortgage Assignments, using its own
employees to sign as if they were officers of the original lenders The fraud includes:

● Mortgage assignments with forged signatures of the individuals signing on behalf of

the grantors, and forged signatures of the witnesses and the notaries;
● Mortgage assignments with signatures of individuals signing as corporate officers for
corporations that never employed them in any such capacity;
● Mortgage assignments prepared and signed by individuals as corporate officers of
mortgage companies that had been dissolved by bankruptcy years prior to the
Assignment;
● Mortgage assignments prepared with purported effective dates unrelated to the date
of any actual or attempted transfer (and in the case of trusts, years after the closing
date of the trusts);
● Mortgage assignments prepared on behalf of grantors who had never themselves
acquired ownership of the mortgages and notes by a valid transfer, including
numerous such assignments where the grantor was identified as “Bogus Assignee for
Intervening Assignments;” and
● Mortgage assignments notarized by notaries who never witnessed the signatures that
they notarized. Trust officers used these fraudulent mortgage assignments to conceal
the fact that the trusts are missing critical documents, namely, the mortgage
assignments that were supposed to have been delivered to the trusts at the inception
of the trust.

These trusts suffered the following economic harm:

The Trusts paid substantial fees to the Trustees for Document Custodial Services including fees for
obtaining and retaining a Mortgage Assignment for each of the properties in the trust. The
Assignment was supposed to have been “in recordable form” – that is, legally sufficient to allow
the Trustee to foreclose in the event of default. These services were never provided. In each trust
● 62
identified herein, many if not all of the Mortgage Assignments were never obtained, or were
obtained and lost.

Because the Assignments were not obtained and/or retained, the Trusts incurred significant
additional expenses:

i) each Trust paid, and will continue to pay, hundreds of thousands of dollars in fees to mortgage
servicers, document preparation companies and law firms to prepare and record “Replacement
Assignments” including Assignments that were prepared with false information regarding dates
and signers;

ii) each Trust paid, and will continue to pay, hundreds of thousands of dollars in fees to the default
management company and to law firms retained by the mortgage servicing companies and/or
default management company (usually, Lender Processing Services) to litigate the issue of the
standing of the trust to file the foreclosure action because the Assignment to the Trust that
established standing was missing or never obtained. 35 In many cases, because the Assignments
were not obtained and/or retained, the Trust could not successfully foreclose when loans in the
Trust defaulted.

In many cases, where the Trust has successfully foreclosed, it had no legal right to do so and the
Trust has been or will be exposed to claims for wrongful foreclosure by former homeowners and
claims of fraud by subsequent purchasers. In many cases, where mortgage servicing companies or
law firms representing the Trust attempted to collect amounts due from defaulting homeowners of
properties in the trust, the debt collection activities violated the Federal Fair Debt Collection
Practices Act because the Trust had no right to pursue collection or foreclosure where it lacked a
valid Assignment.

In many cases, particularly where the loan originator is a mortgage company that is no longer in
existence, it may not be possible to ever obtain a valid Assignment to the Trust. Long after the
Trustees and Servicers became aware that critical documents, the Assignments, were missing, the
Trustees and Servicers failed to disclose that information to the Certificate Holders and to the SEC.

Attached hereto are examples of fraudulent Assignments. Many (over 100,000) of these are
signed by Linda Green. From an examination of the signatures, it is apparent that many
different employees signed the name Linda Green. Job Titles attributed to Green include the
following:

• Vice President, Loan Documentation, Wells Fargo Bank, N.A., successor by merger to Wells
Fargo Home Mortgage, Inc.;
• Vice President, Mortgage Electronic Registration Systems, Inc., as nominee for American Home
Mortgage Acceptance, Inc.;
• Vice President, American Home Mortgage Servicing as successor-in interest to Option One
Mortgage Corporation; • Vice President, Mortgage Electronic Registration Systems, Inc., as
nominee for American Brokers Conduit;
• Vice President & Asst. Secretary, American Home Mortgage Servicing, Inc., as servicer for
Ameriquest Mortgage Corporation; • Vice President, Option One Mortgage Corporation;
• Vice President, Mortgage Electronic Registration Systems, Inc., as nominee for HLB Mortgage;
● 63
 • Vice President, American Home Mortgage Servicing, Inc.;
• Vice President, Mortgage Electronic Registration Systems, Inc., as nominee for Family Lending
Services, Inc.;
• Vice President, American Home Mortgage Servicing, Inc. as successor-in-interest to Option One
Mortgage Corporation;
• Vice President, Argent Mortgage Company, LLC by Citi Residential Lending Inc.,
attorney-in-fact; • Vice President, Sand Canyon Corporation f/k/a Option One Mortgage
Corporation;
• Vice President, Amtrust Funding (sic) Services, Inc., by American Home Mortgage Servicing,
Inc. as Attorney-in fact; and
• Vice President, Seattle Mortgage Company.

Other LPS employees similarly used job many different job titles and claimed to be officers of
many different mortgage companies on Mortgage Assignments. Korell Harp and Tywanna
Thomas used a variety of conflicting job titles on Assignments of Mortgages in 2008 and 2009,
holding themselves out to be officers of numerous different banks and mortgage-related entities,
often using numerous conflicting titles in the same week.

Titles attributed to Korell Harp include Vice President of American Home Mortgage
Servicing, Inc. as successor-in-interest to Option One Mortgage Corporation; Vice President of
American Brokers Conduit; Vice President of Argent Mortgage Company, LLC; and Vice President
of Mortgage Electronic Registration Systems, Inc. Titles attributed to Tywanna Thomas include
Assistant Vice President of Option One Mortgage Corporation, Assistant Vice President of
American Home Mortgage Servicing, Assistant Vice President of Mortgage Electronic Registration
Systems, Assistant vice President of Argent Mortgage Company, LLC, Assistant Vice President of
Deutsche Bank National Trust Company, Assistant Vice President of Sand Canyon Corporation and
Assistant Vice President of American Home Mortgage Acceptance.

That the above letter further points out and shows that this criminal activity has been going
on for a long time. That Banks, the Servicers and the Lawyers have been given chance after
chance to clean up their act, but, find it cheaper to pay off the Government, Government agencies
who by all appearance take the money and pocket it for personal use.

Count 14
Title 26, U.S. Code. The Internal Revenue Code (IRC)
is the body of law that codifies all federal tax laws, including income, estate, gift, excise, alcohol, tobacco, and
employment taxes. U.S. tax laws began to be codified in 1874, but there was no central, comprehensive source
for them at that time

Material false claims under SEC enforced 1122 AB

26 U.S.C. § Section 61 A (1), 26 U.S.C. § Section 108 (i), 26 U.S.C. § Section 451, 26 U.S.C. § Section 1033,
U.S.C Section 1.751, CFR 1.752, SEC Rule 1122 AB
Regs. Sec. 1.707-3(b)(2) Disguised sales of property to partnership

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint.

CAUSES:
● 64
[1] Disguised Sale Rule under the IRC title 26 used in manipulative method and means for ill gotten gains

[2] Violations of the Federal rules on partnerships and pass through taxable income in a constructive liquidation

● where denying the pass through investor a proration distribution credited as a earn out over a set
term
● The mortgagor is a pass through for the amounts booked at settlement and not disbursement
● Resulting in the attribution of ordinary and causal to compelled abandonment under tax payer form
1099 A

[3] Deceptive Practices that succeed by failing to properly disclose the correct character of the subject matter
transaction.

● Whereas parties are foreclosing on the good faith understanding of default by mortgagor in default
● Wherefore the good faith understanding is lost under the doctrine of extinguishment
● Where by the instruments are cancelled for ORDINARY INCOME and title transferred under the
the instruments TRANSFER RIGHTS IN THE PROPERTY
● TRANSFER IS AFFIRMED at the origination the TRUSTEE sale whereby GRANTEE paid to
TRUSTEE CONSIDERATION
● The Consideration is for a credit back from date of the reversion [fictitious foreclosure ] backdating
ot the date of the orginal loans settlement

[4] For material violations by way of willful avoidance of a pass through right and entitlement to disclosures
mandated by assignment Pro Tanto

● Including life estate contracted by irrevocable transfers of the title for which the mortgagor is
TRANSFEROR under a QUALIFIED INVESTMENT
● Whereas the Qualified Property is by Transferors holding the reversion upon all properties having
been argued and amortized to a basis in asset of zero
● A sale for assets held in a constructive liquidation at zero is taxable to the attribution as 1099 A
recipient treated as ordinary at time of disposition .

[5] Material false claims under SEC enforced 1122 AB

● Government actor withheld as indispensable parties under the vendors understanding holding in
1122 AB
● Material false claims made under the FDCPA Federal debt collections practices act used for
assessing consumers in conventional foreclosures
● Using the state in the role of tax gather for the IRS to satisfy state budget liabilities

[6] Public sector entering the private side and violating the the taking provisions and "no capitation" guarantees
afforded on the fifth and fourteenth amendments

● DUE PROCESS denied where the trier of fact is a beneficial interest under a NOMINEE
● Whereas MERS conceals the government obligations owed to its depositors as Qualified
Investments
● Wherefore the title secured Qualified deposits levered against the benefits payable to its state
Municipal Employees Retirement System.

[7] Violations of GAAP and Non Recognition Rules for final sale accounting rule barring a subsequent recovery on
a default using the accrual method of accounting.

● 65
 ● Whereas the consumer is a Mortgagor for a debt converted into a reversionary interest as equity
and
● Lender , lender's successors and successor of lender are the seller for title transferred into trust to a
third party as trustee under the installment method.
● In violation of IRC Title 26 by tax matter partnerships to satisfy third party antecedent debt
assigned to mortgagors prorated shares of third party commercial obligations owed as "receivables
to offshore financial institutions.

When OCWEN Fraudulently did the 1099, then sold the loan to NEWREZ LLC it violated § 1.707-3
Disguised sales of property to partnership; general rules.

Count 15
26 CFR § 1.707-3 - Disguised sales of property to partnership; general rules.
A disguised sale Regs. Sec. 1.707-3(b)(2)
JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint.

The partnership has incurred or is obligated to incur debt to acquire the money or other consideration necessary to
permit it to make the transfer, taking into account the likelihood that the partnership will be able to incur the debt
(considering such factors as whether any person has agreed to guarantee or otherwise assume personal
responsibility for the debt);

The partnership holds money or other liquid assets, beyond the reasonable needs of the business, which are
expected to be available to make the transfer (taking into account the income that will be earned from those assets);

Partnership distributions, partnership allocations, or control of partnership operations is designed to effect an

exchange of the burdens and benefits of property ownership;

The transfer of money or other consideration by the partnership to the partner is disproportionately large in
relationship to the partner's general and continuing interest in partnership profits;or

The partner has no obligation to return or repay the money or other consideration to the partnership or has such an
obligation but it is likely to become due at such a distant point in the future that the present value of that obligation
is small in relation to the amount of money or other consideration transferred by the partnership to the partner.

Caution: Note that the disguised sale regulations apply to deemed sales from the partner to the partnership, from the
partnership to a partner, and among the partners.

KNOW A MORTGAGE FROM A DISGUISED SALE

The partnership has incurred or is obligated to incur debt to acquire the money or other consideration necessary to
permit it to make the transfer, taking into account the likelihood that the partnership will be able to incur the debt
(considering such factors as whether any person has agreed to guarantee or otherwise assume personal
responsibility for the debt);

The partnership holds money or other liquid assets, beyond the reasonable needs of the business, which are
expected to be available to make the transfer (taking into account the income that will be earned from those assets);

● 66
Partnership distributions, partnership allocations, or control of partnership operations is designed to effect an
exchange of the burdens and benefits of property ownership;

The transfer of money or other consideration by the partnership to the partner is disproportionately large in
relationship to the partner's general and continuing interest in partnership profits;or
The partner has no obligation to return or repay the money or other consideration to the partnership or has such an
obligation but it is likely to become due at such a distant point in the future that the present value of that obligation
is small in relation to the amount of money or other consideration transferred by the partnership to the partner.

Caution: Note that the disguised sale regulations apply to deemed sales from the partner to the partnership, from the
partnership to a partner, and among the partners.

The following facts and circumstances may prove the existence of a disguised sale (Regs. Sec. 1.707-3(b)(2)):

● The timing and amount of a subsequent transfer are determinable with reasonable certainty at the time of
the earlier transfer;
● The transferor has a legally enforceable right to the subsequent transfer;
● The partner's right to receive the transfer of money or other consideration is secured in any manner (taking
into account the period during which it is secured);
● Any person has made or is legally obligated to make contributions to the partnership to permit the
partnership to make the transfer of money or other consideration;
● Any person has loaned or has agreed to loan the partnership the money or other consideration necessary to
permit it to make the transfers, taking into account whether any such lending obligation is subject to
contingencies related to the results of partnership operations;

Count 16
18 U.S. Code § 1033 Insurance Fraud
False Advertising - FTC Act, Lanham Act and Dodd-Frank Wall Street Reform, Consumer Protection Act
US Constitution Fifth & 14th Amendment deprived of life, liberty or property without due process of law
Theft by Deceptive taking - 18 USC §4, aka the Misprision Of Felony Statute,

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

The CC defendants have violated JWG United States Constitutional rights to Due process and are trying to deprive
her of her home of 32 years with falsified documents and a Scheme that is for personal financial gain. That this is
Theft by deceptive taking by all.

That not disclosing the issues with the title to the public violates the Consumer Protection Act and the Professional
Code of Conduct.

Count 17
Civil Rights

42 U.S. Code § 1983 - Civil action for deprivation of rights. 18 U.S. Code § 242 - Deprivation of rights under
color of law, 18 U.S. Code § 241 - Conspiracy against rights United States Constitution 5th and 14th
Amendment

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JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

That when the courts denied discovery and subpoenas for witness JWG rights to the minimum the right to fair trial
includes the following fair trial rights in civil and criminal proceedings: the right to be heard by a competent,
independent and impartial tribunal. the right to a public hearing. the right to be heard within a reasonable time.
Violating the right to Due Process

Count 18
Forgery

JWG incorporates herein by reference all of the allegations contained in the above Paragraphs of this Complaint

Federal Code 18 U.S.C. § 471 forgery that all documents including and not limited to lawyer Howard Birman
appear to be forged. Forgery is generally described as creating a fake document, modifying an existing one, or the
signing of a document without proper authorization. Some common objects that are the target of a forgery include
contracts, checks, deeds for property, identification cards, and even money. That the property was taken with
forged documents, with the knowledge of the lawyers

A Pro Se Litigant

The law is very clear a pro se litigant is to be given equal treatment if not special treatment, especially in a case
where the intervening Person is a lawyer and has the financial ability to bring in as many powerful unscrupulous
lawyers to defend her criminal actions.

"Pro se plaintiffs are often unfamiliar with the formalities of pleading requirements. Recognizing this, the Supreme
Court has instructed the district courts to construe pro se complaints liberally and to apply a more flexible standard
in determining the sufficiency of a pro se complaint than they would in reviewing a pleading submitted by counsel.
See e.g., Hughes v. Rowe, 449 U.S. 5, 9-10, 101 S.Ct. 173, 175-76, 66 L.Ed.2d 163 (1980) (per curiam); Haines v.
Kerner, 404 U.S. 519, 520-21, 92 S.Ct. 594, 595-96, 30 L.Ed.2d 652 (1972) (per curiam); see also Elliott v.
Bronson, 872 F.2d 20, 21 (2d Cir.1989) (per curiam). In order to justify the dismissal of a pro se complaint, it must
be " 'beyond doubt that the plaintiff can prove no set of facts in support of his claim which would entitle him to
relief.' " Haines v. Kerner, 404 U.S. at 521, 92 S.Ct. at 594 (quoting Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct.
99, 102, 2 L.Ed.2d 80 (1957)).
“Fairness of course requires an absence of actual bias in the trial of cases. But our system of law has always
endeavored to prevent even the probability of unfairness. “In re Murchinson, 349 U.S. 133, 136 (1955)”
No officer of the law may set that law at defiance with impunity. All the officers of the government from the highest
to the lowest, are creatures of the law, and are bound to obey it.” Butz v. Economou, 98 S.Ct. 2894 (1978); United
States v. Lee, 106 U.S. at 220, 1 S.Ct. at 261 (1882)” “Further it is the obligation of every Judge to honor, abide by,
and uphold not only the Constitution and laws of the State, but they are bound by the laws and Constitution of the
United States as well.” State courts, like federal courts, have a constitutional obligation to safeguard personal
liberties and to uphold federal law.” Stone v Powell, 428 US 465, 483 n 35, 96 S. Ct 3037, 49 L Ed. 2d 1067
(1976)”
PRAYER FOR RELIEF

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WHEREFORE, JWG requests that this Court:

1. Award JWG compensatory, punitive, explore damages against defendants jointly of $39 million dollars to
send a strong message of deterrence for this type of attorney / trustee / banks / servicers behavior.
2. Have the home at 15 W. Spring St,, Alexandria VA signed back over to JWG
3. That this court turn complaint over the appropriate authorities for investigation
4. Award JWG reasonable attorney fees and costs if an attorney is appointed by the court or will take case on
contingency.
5. Grant to JWG such other and further relief as The Honorable Court may find just and proper under the
circumstances, including but not limited to appropriate injunctive relief

JURY TRIAL DEMAND pursuant to the Seventh Amendment to the United States Constitution

Date November 9, 2022

Respectfully submitted

Janice Wolk Grenadier

15 W. Spring St.
Alexandria, VA 22301
202-368-7178
jwgrenadier@gmail.com

CERTIFICATION: I declare under penalty and perjury; that NO attorney has prepared or assisted in the
preparation of this document. Janice Wolk Grenadier - Name of Pro Se Party

Janice Wolk Grenadier

November 9, 2022

Attached:

Certificate of Service for Service

Exhibit A Senate Letter
Exhibit B Spring Documents from 2006 - 2013
Exhibit C Spring Documents from 2009 - 2020

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