Memorandum in opposition to motion to strike counterclaim in judicial foreclosure, arguing misconduct in implementing HAMP, claims for breach of contract, promissory estoppel, negligence, negligent infliction of emotional distress, and UDAP. Bank of America v Izzo CT Superior Court April 2015.
Brief in Opposition to motion to dismiss complaint, raising HAMP TPP claims of breach of contract, UDAP.
Memorandum in Opposition to Motion to Dismiss Complaint: RESPA loss mitigation, RFI, and NOE rules, negligence, UDAP
Tanasi v Citimortgage D. Conn. Oct. 2016 TANASI and Tanasi, Plaintiffs, v. CITIMORTGAGE, INC. and M&T Bank, as Successor by Merger to Hudson City Savings Bank, N.A., Defendant., 2016 WL 11048311 (D.Conn.)
RESPA, UDAP, negligence (RESPA servicing dismissed)
Jeff Gentes
Post-Hearing memorandum, addressing tolling of interest, costs and fees, requesting sanctions against servicer attorney, non-borrower role in FHA loan. NY trial court May 2018 Carrington Mortgage v Morain.
Motion to compel answers to interrogatories, investor guidelines Wigod v. Wells Fargo Bank N.D. Ill. Sept. 28, 2012 and motion to compel further answers to interrogatories Nov 12, 2012 WIGOD, Dan Finlinson and Finlinson, on behalf of themselves and all others similarly situated, Plaintiffs, v. WELLS FARGO BANK, N.A.