THE SUMMARY JUDGMENT OBTAINED IN THE PLAINTIFF’S FAVOR ON OR AROUND 06/27/2009, IS DEFECTIVE AS IT DOES NOT MEET THE REQUIREMENTS OF ADMINISTRATIVE

1. The Summary Judgment of Foreclosure obtained by the Plaintiff on or around 06/27/2007, does not meet the requirement. It does not have the address of the Plaintiff as required.

2. The address on the FINAL JUDGMENT OF FORECLOSURE is: 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120

3. This is not the address of the named Plaintiff. This address is being used by more

than 20 Plaintiffs, Banks, loan servicing companies. Here is an example of the

companies using this address:

THE BANK OF NEW YORK1270 NORTHLAND DR STE 200SAINT PAUL  MN   55120

WELLS FARGO BANK NA TRUSTEE1270 NORTHLAND DR SUITE 200MENDOTA HEIGHTS, MN 55120INSPECTOR: Eddie Prieto  274-5545

DEUTSCHE BANK NATIONAL TRUST1270 NORTHLAND DR STE 200MENDOTA HEIGHTS, MN 55120INSPECTOR: RANDEL SMITH 274-5545

Current Beneficiary: MERS as nominee for Aegis Mortgage Corp Care of Servicer Aegis Mortgage Corp/Fidelity C/O Fidelity National Foreclosure Solutions 1270 Northland Drive. Suite 200 Mendota Heights, MN 55120 

BANK ONE NATIONAL ASSN TRUSTEE1270 NORTHLAND DR STE 200MENDOTA HEIGHTS MN 55120

LONG BEACH MTG LOAN TRUST1270 NORTHLAND DR STE 20MENDOTA HEIGHTS  MN 551201156

HomEq Servicing Corp.1270 Northland Dr., #200Mendota MN 55120-    

IndyMac Bank-FSB;The Leader Mortgage Co.1270 Northland Drive, Suite 200Mendota HeightsMN55120-    

Saxon Mortgage; Homecomings Financial1270 Northland Dr., #200Mendota HeightsMN 55120-    

FEDERAL NATIONAL MORTGAGE ASSOC 1270 NORTHLAND DR STE 200 MENDOTA HEIGHTS MN 55120

JPMORGAN CHASE BANK1270 NORTHLAND DR STE 200 MENDOTA HEIGHTS MN 55120

BANK ONE AS TRUSTEE       1270 NORTHLAND DR STE 200     MENDOTA HEIGHTS MN 55120-

JP MORGAN CHASE BANK (TRUSTEE)1270 NORTHLAND DR SUITE 200SAINT PAUL, MN 55120

WELLS FARGO BANK NA 1270 NORTHLAND DR STE 200 MENDOTA HEIGHTS MN, 55120

SELECT PORTFOLIO SERVICING, INC1270 NORTHLAND DR STE 200 MENDOTA HEIGHTS MN 55120  

Select Portfolio Servicing Inc.1270 Northland Drive, Ste. 200Mendota Heights, MN 55120

4. The named Plaintiff commenced this foreclosure action without having and

holding the Original Note and Original Mortgage, without having a Note Indorsed

/ Endorsed in blank or to the named Plaintiff and without having a valid

assignment of mortgage recorded in Public Records of Miami-Dade County,

Florida;

5. The Assignment filed by plaintiff AFTER this foreclosure action was commenced

is bogus, fraudulent, and due to the fact that the Assignment of Mortgage was not

signed and notarized by employees of the Original Lender. They are all

employees of the Assignee”, Plaintiff’s Attorneys and/or Subcontractors

6. Defendant would like to address the court to please place extra attention to who

was the alleged authorized representative from MERS.

On September 25, 2009, R.K. Arnold, the President and CEO of MERSCORP, Inc. — the parent corporation of Mortgage Electronic Registration Systems, Inc. was deposed in Alabama. Arnold is also an Officer of MERS. Arnold admitted MERS does not have a beneficial interest in any mortgage; does not loan money; does not suffer a default if monies are not paid; etc. etc. On November 11, 2009, William C. Hultman was deposed in Alabama and made the same admissions. And, of course, the internal agreement used by MERS expressly disavows any beneficial interest.

7. In addition, there are, however, three defects in the Plaintiff’s Complaint which

prove

fatal to its cause. The facts surrounding each defect are explained in detail below.