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Mortgage Servicing and Loan Modifications: Introduction to Sample Pleadings

The digital version of this treatise includes under “Pleadings and Discovery” over 200 sample pleadings relating to injunction against sale, federally financed housing, RESPA, HOEPA, HAMP loan modifications, MERS, fraud and UDAP claims, land installment sales contracts, TILA rescission, servicing abuses, foreclosure rescue scams, bankruptcy, and other subjects. The pleadings include complaints, discovery requests, motions, briefs, proposed orders, and more.

Consumer Bankruptcy Law and Practice: Introduction

The Official Forms necessary to commence a case are reproduced in Appendix D, supra. These forms are included as sample completed bankruptcy schedules illustrating how to prepare an initial filing. Other Official Forms are included in blank format.

Consumer Bankruptcy Law and Practice: Exhibit A

Exhibit A

Debtor’s Request for Production of Documents Directed to [name] Mortgage Company

The Debtor, [name], by her counsel, and pursuant to Fed. R. Bankr. P. 2004, makes this request for production of documents directed to [name] Mortgage Company. Defendant is requested to produce the documents described below at the Rule 2004 examination to be held as ordered by the Bankruptcy Court.

DEFINITIONS