Pleadings and Discovery

This is an amended answer, defenses and counterclaims to a Florida action to foreclose on a reverse mortgage where there was confusion as to the amount owed on a separate line of credit that was used to pay insurance.  The defenses are based on estoppel, the lender’s failure to comply with HECM servicing requirements, substantial performance, and unclean hands. Counterclaims include violation the state debt collection, ECOA violations for age discrimination and failure to properly send adverse action notices, malicious prosecution, and slander of title.

This is an answer and defenses to a Florida action to foreclose on a reverse mortgage for failure to pay property taxes and insurance where the defenses are based on the lender’s failure to comply with servicing requirements and failure to show it has standing to foreclose. Counterclaims include UDAP and ECOA age discrimination and adverse action notice violations. Lynn Drysdale of Jacksonville Legal Aid drafted the pleadings.

This is an answer and defenses to a Florida action to foreclose on a reverse mortgage for failure to pay property taxes and insurance where the defenses are based on the lender’s failure to comply with servicing requirements and failure to show it has standing to foreclose. Lynn Drysdale of Jacksonville Legal Aid drafted the pleadings.

This is a Florida homeowner’s first request for documents from a reverse mortgage lender in a Florida action to foreclose on the home for non-payment of taxes or insurance. Lynn Drysdale of Jacksonville Legal Aid drafted the pleadings.

This is a homeowner’s first request for documents from a reverse mortgage lender in a Florida action to foreclose on the home for non-payment of taxes or insurance. Lynn Drysdale of Jacksonville Legal Aid drafted the pleadings.

This is an answer and defenses to a Connecticut action to foreclose on a reverse mortgage for failure to pay property taxes and insurance where the lender breached the payment plan that had been agreed upon.  The Connecticut Fair Housing Center drafted the pleadings.

This is a brief in opposition to a lender’s attempt to strike the homeowner’s defenses and dismiss the homeowner’s UDAP and ECOA counterclaims in a Florida action involving the foreclosure of a reverse mortgage for alleged failure to pay property taxes or insurance. Lynn Drysdale of Jacksonville Legal Aid drafted the pleadings.

This is motion to set aside a default judgment on a Florida foreclosure action and sale concerning unpaid property taxes and insurance on a reverse mortgage. The excusable neglect is based on the homeowner’s age and cognitive difficulties. Lynn Drysdale of Jacksonville Legal Aid drafted the pleadings.

This is a 2018 New Jersey state court summary judgment motion seeking to dismiss a judicial foreclosure action concerning a reverse mortgage because HUD had granted an at risk foreclosure extension.  The motion was filed by Legal Services of New Jersey.

This is an action in Pennsylvania state court seeking the court clerk to put a residential foreclosure case into deferred status due to the homeowner’s status as an “At Risk” mortgagor under HECM regulations.