1 2 3 4 5 6 7 8 9 10 11Summons Issued

Philip A. Kramer SB# 113969 Kramer & Kaslow 23901 Calabasas Rd # 2010 Calabasas, CA 91302-3307 (818) 224-3900 Attorney for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE

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DANIEL MAXAM, an individual; CARA MCVEY, an individual; DANIEL MELENDEZ, an individual; GERALDINE MOECKEL, an individual; EDGAR MORALES, an individual; DINAH MOREAU, an individual; KEN MORRIS, an individual; ALAN MOSLEY, an individual; SOSTENES MURGA, an individual; LEE E. NOBLE, an individual; JOSE NUNEZ, an individual; DONALD OKADA, an individual; JESSE OSBORNE, an individual; LUIS PAGES, an individual; MARCELINO PALISOC, an individual; CLAYTON PELLETIER, an individual; MITCH PERERIA, an individual; RICHARD PILLSBURY, an individual; HAYDEN POGNI, an individual; ROGER PREBLE, an individual; CARLOS QUINO, an individual; LORETTA RAYA, an individual; RHONDA CHISHOLM, an individual; DANIEL RICHARD, an individual; ROBERT GILBERT, an individual; AUDRA RODRIGUEZ, an individual; CESAR RODRIGUEZ, an individual; FRANK ROPER, an individual; HOWARD ROSENTHAL, an individual; ROGER ROTTLER, an individual; ANGELA SANCHEZ, an individual; SELINA WILDER, an individual; SHARON KING, an individual; JEREMY SHEAFFER, an individual; DEBRA SIMPSON, an individual; NATHAN SKIVER, an individual; GUILLERMO TABARES, an individual; STEPHEN TEICHMAN, an individual; FATIMA

Case No.: COMPLAINT FOR: 1. FRAUDULENT CONCEALMENT [VIOLATION OF CAL. CIVIL CODE 1572, 1709 AND 1710]; 2. INTENTIONAL MISREPRESENTATION [VIOLATION OF CAL. CIVIL CODE 1572, 1709 AND 1710]; 3. NEGLIGENT MISREPRESENTATION [VIOLATION OF CAL. CIVIL CODE 1572, 1709 AND 1710]; 4. INJUNCTIVE RELIEF FOR VIOLATION OF CIVIL CODE SECTION 2923.5; 5. UNFAIR COMPETITION [VIOLATIONS OF CAL. BUS. & PROF. CODE 17200 ET SEQ.] [JURY TRIAL DEMANDED]

DEPT CX101

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TENDERRO, an individual; TISHARRA SHREIBER, an individual; TODD GAGNON, an individual; JORGE TORRES, an individual; HWANG TRAN, an individual; RONALD TURNER, an individual; ROSEMARY TURNER, an individual; JOHN URTIAGA, an individual; THOMAS VAN DUSEN, an individual; NELDA VARGAS, an individual; LINDA VULAJ, an individual; RIK WAHLRAB, an individual; PHILIP WARMANEN, an individual; CHRISTIAN WELLMAN, an individual; MARK WHITEHEAD, an individual; DARNELL WYRICK, an individual; ALEJANDRO ALARCON, an individual; JULIE ANDERSON, an individual; LYNETTE ASTORS, an individual; BRUCE BARRETT, an individual; BRANSTON BAUDER, an individual; BRETT BORBA, an individual; BUNNY BOWERS, an individual; EDDIE BRANDES, an individual; ROY BREWER, an individual; BRAD J. BRITTON, an individual; HENRY BURGESS, an individual; JOSE CABANAS, an individual; ELVIRA CADENAS, an individual; MARIA CAMARILLO, an individual; CHRISTINE CARPENTER, an individual; ROBERT CASTORE, an individual; JAMES CHAFFIN, an individual; LISA DAGGS-CHARETTE, an individual; CHRIS CLARK, an individual; CHRISTINE JI, an individual; MICHAEL COLLIGAN, an individual; SEANNA COLLIGAN, an individual; K.C. CRANDALL, an individual; ANTONIO CRUZ, an individual; COSME CRUZ, an individual; TUAN HAI DANG, an individual; STEPHANIE DIAMOND, an individual; DANG DIEP, an individual; DOLORES SABLAN, an individual; ROBERT DUBOIS, an individual; TERRI EADENS, an individual; EDITHA RESTAURO, an individual; KIRA EDWARDS, an individual; EVELYN SISTRUNK, an individual; ROSIBEL FADUL, an individual; ENIO FONTANELLI, an individual; DOUGLAS FORE, an individual; WILLIAM FOSTER, an -2COMPLAINT

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individual; TRINA FRAZIER, an individual; GENARO MENJIVAR, an individual; GEORGE OLSEN, an individual; PAULETTE OLSEN, an individual; GLEN LEMMON, an individual; RICARDO GONZALEZ TAFOLLA, an individual; LEOPOLDO GONZALEZ, an individual; STEPHANIE GOTTERO, an individual; KARLA GOULART, an individual; SALVADOR GUTIERREZ, an individual; JACINTO GUZMAN, an individual; OFELIA HERNANDEZ, an individual; TIMOTHY INFANGER, an individual; BENJAMIN INGRAM, an individual; TAMMY JACKSON, an individual; LYNETTE JAMORA, an individual; MARIA JIMENEZ, an individual; JOE BARELA, an individual; JOHN ALLEN, an individual; JOHN MORENO, an individual; LAVANCE JOHNSON, an individual; JOSEPH ELONGE-FOBIA, an individual; NARINDER KAUR, an individual; KEITH COTANT, an individual; KEVIN MCVEY, an individual; CHRISTINA KIM, an individual; JANE KOPECKY, an individual; JOSHUA KREITZER, an individual; JONATHAN LANDES, an individual; ASHLEY LARSON, an individual; LEVON LATCHINIAN; an individual; OLIVER LAZARO, an individual; DANIEL LERTIQUE, an individual; KERRIE LLOYD, an individual; CYNTHIA LUNA, an individual; LYN HENLEY, an individual; MADONA OANDASAN, an individual; JANA MALONE, an individual; PIERRE MARCOTTE, an individual; MARLENE GONZALEZ, an individual; NAOMI MARTINSEN, an individual; MARVIN MENDONCA, an individual; MAZIAR ABRISHAMIAN, an individual; JULIE BLACKLEY, an individual; DUANE BLEDSOE, an individual; MARK CAIRA, an individual; DAVID DELGADO, an individual; CLYDE DODSON, an individual; EVELYN HERRERA, an individual; BACHHONG KHONG, an individual; LOUIE LEWIS, an individual; JOEL LIEBKE, an -3COMPLAINT

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individual; LARRY LUNSFORD, an individual; DARYL MCCANCE, an individual; EDWARD SANCHEZ, an individual; CONNIE SCHULENBERG, an individual; RICHARD VAN DER WORP, an individual; FRED WHITE, an individual; PETRE MILE, an individual; FRANZ BELL, an individual; TIMOTHY SMITH, an individual; GILBERT SIGALA, an individual; ELENO DE LA CRUZ, an individual; NAOMI TROWER, an individual; SALVACION AQUINO, an individual; MANUEL ARECHIGA, an individual; AMRIK BAJWA, an individual; ROSARIO BARA, an individual; OLGA BARDALES, an individual; GIL BECKENSTEIN, an individual; RHONDA BOGGAN, an individual; RANDY BROOKS, an individual; HAROLD BYRD, an individual; VITO CALABRESE, an individual; EVERADO CASTRO, an individual; FRANCISCO CEBALLOS, an individual; CYNTHIA CHANG, an individual; ANJA CHRISTIEJOHNSON, an individual; GRACIELA CONTRERAS, an individual; ANIBAL CORDERO, an individual; OTTO RENE DE LEON, an individual; JOSE DELGADO, an individual; ALICIA DIAZ, an individual; DAVID DILLON, an individual; JOHN DONAHUE, an individual; JULIO DORADO, an individual; TUONG DU, an individual; ELLA FERNANDEZ, an individual; DAWN LENTZ FLOWERS, an individual; CHRISTIE FRANZ, an individual; SUSAN GALLAGHER, an individual; RUDY GARCIA, an individual; ADELA GARCIA, an individual; CINDY GEORGE, an individual; JOERIN GEORGE, an individual; VLADIMIR GURLOR, an individual; RICHARD HALLEY, an individual; CYNTIHIA HALLEY, an individual; CARMELA HERBERT, an individual; CHONTIA HOLMES, an individual; DARRELL HOOVER, an individual; DONALD JENKS, an individual; SHELDON KAMEN, an individual; SHAWN -4COMPLAINT

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KEEBAUGH, an individual; TAMMY KEMMERER, an individual; JANE KIM, an individual; LOUIS KLEIN, an individual; GERALD KRAMER, an individual; JERRY LEE, an individual; BRIAN LOGAN, an individual; RONNIE LYLES, an individual; PAUL MAILE, an individual; POLINA MANYIKA, an individual; HASMIK MEKHITARIA, an individual; DONYANN MORGAN, an individual; ROBERT MORSE, an individual; JOSEPH NUGENT, an individual; DOUGLAS POWERS, an individual; BETTE LOU PRENTICE, an individual; DIONICIO QUINONEZ, an individual; THERESA REAL, an individual; YEVETTE REEVES, an individual; DENISE REGISTER, an individual; JOEY RIEDEL, an individual; ENRIQUE ROMERO, an individual; CONNIE ROOKER, an individual; RODNEY SADLER, an individual; HUGO SALAZAR, an individual; RUBEN SANTIAGO, an individual; YADIRA SANTILLAN, an individual; NAGINDER SINGH, an individual; JAMES SPELLER, an individual; ANN TERRILL, an individual; WILLIAM THOMAS, an individual; HAI V. TRAN, an individual; SANDRA VALDEZ, an individual; TANYA VEGA, an individual; GLENN WARNE, an individual; CHERYL WELCH, an individual; SCOTT WETZEL, an individual; MICHAEL WIEDERHOLD, an individual; BERNARDO ZAVALA, an individual; JAMES PATE, an individual; ANGEL ARIAS, an individual; NEIL WHITE, an individual; ACHINI WHITE, an individual; and others similarly situated named herein as ROES 1-1000, inclusive, Plaintiffs,

vs.

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BANK OF AMERICA, N.A., a Delaware corporation; COUNTRWIDE FINANCIAL CORPORATION, a Delaware corporation, dba BAC HOME LOANS SERVICING; COUNTRYWIDE HOME LOANS, INC., a New York corporation; RECONTRUST COMPANY, N.A., a California entity form unknown; CTC REAL ESTATE SERVICES, a California corporation; and DOES 1 through 1000, inclusive. Defendants.

Plaintiffs, and each of them, hereby demand a jury trial and allege as follows.

INTRODUCTION AND BACKGROUND OF THE MASTER SCHEME OF DECEPTION AND FRAUD 1. This lawsuit arises from: (1) Defendants deception in inducing Plaintiffs to enter

into mortgages from 2003 through 2008 with the Countrywide Defendants (defined below in Paragraph 8); (2) Defendants breach of Plaintiffs Constitutionally and statutorily protected rights of privacy; and (3) Defendants continuing tortious conduct intended to deprive Plaintiffs of their rights and remedies for the foregoing acts, described below. 2. This action seeks remedies for the foregoing improper activities, including a

massive fraud perpetrated upon Plaintiffs and other borrowers by the Countrywide Defendants that devastated the values of their residences, in most cases resulting in Plaintiffs loss of all or substantially all of their net worth. 3. Defendant Countrywide Financial Corporation (Countrywide) was among the

leading providers of mortgages in California during all times relevant to this Complaint. By 2005, Countrywide was the largest U.S. mortgage lender in the United States, originating over $490 billion in mortgage loans in 2005, over $450 billion in 2006, and over $408 billion in 2007.

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4.

In 2007, Defendant Bank of America (BofA) commenced negotiations to

acquire Countrywide. By late 2007, BofA began merging its operations with Countrywide and adopting some of Countrywides practices. From and after its acquisition of Countrywide in July 2008 and continuing to the present, both as a successor in interest to Countrywide and as a principal, BofA has engaged in and continued the wrongful conduct complained of herein. 5. The fraud perpetrated by the Countrywide Defendants from 2003 through 2007,

including by BofA starting no later than 2007, was willful and pervasive. It begin with simple greed and then accelerated when Countrywide founder and CEO Angelo Mozilo (Mozilo) discovered that Countrywide could not sustain its business, unless it used its size and large market share in California to systematically create false and inflated property appraisals throughout California. Countrywide then used these false property valuations to induce Plaintiffs and other borrowers into ever-larger loans on increasingly risky terms. As Mozilo knew from no later than 2004, these loans were unsustainable for Countrywide and the borrowers and to a certainty would result in a crash that would destroy the equity invested by Plaintiffs and other Countrywide borrowers. 6. Hand-in-hand with its fraudulently-obtained mortgages, Mozilo and others at

Countrywide hatched a plan to pool the foregoing mortgages and sell the pools for inflated value. Rapidly, these two intertwined schemes grew into a brazen plan to disregard underwriting standards and fraudulently inflate property values county-by-county, city-by-city, person-byperson in order to take business from legitimate mortgage-providers, and moved on to massive securities fraud hand-in-hand with concealment from, and deception of, Plaintiffs and other mortgagees on an unprecedented scale. 7. From as early as 2004, Countrywides senior management led by Mozilo knew

the scheme would cause a liquidity crisis that would devastate Plaintiffs home values and net worths. But, they did not care, because their plan was based on insider trading pumping for as long as they could and then dumping before the truth came out and Plaintiffs losses were locked in. /// -7COMPLAINT

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8.

At the very least, at the time of entering into the notes and deeds of trust

referenced herein with respect to each Plaintiff, Countrywide, each Defendant originating a mortgage, each Defendant in the chain of title of the foregoing mortgages and each Defendant servicing the foregoing mortgages and the successors to each of the foregoing (collectively, the Countrywide Defendants) was bound and obligated to fully and accurately disclose to each borrower, including each Plaintiff herein, that the mortgage being offered to the Plaintiff was, in fact, part of a massive fraud that Countrywide knew would result in the loss of the equity invested by Plaintiff in his home and in severe impairment to Plaintiffs credit rating.1 9. It is now all too clear that this was the ultimate high-stakes fraudulent investment

scheme of the last decade. Couched in banking and securities jargon, the deceptive gamble with consumers primary assets their homes was nothing more than a financial fraud perpetrated by Defendants and others on a scale never before seen. This scheme led directly to a mortgage meltdown in California that was substantially worse than any economic problems facing the rest of the United States. From 2008 to the present, Californians home values decreased by considerably more than most other areas in the United States as a direct and proximate result of the Defendants scheme set forth herein. The Countrywide Defendants business premise was to leave the borrowers, including Plaintiffs, holding the bag once Countrywide and its executives had cashed in reaping huge salaries and bonuses and selling Countrywides shares based on their inside information, while investors were still buying the increasingly overpriced mortgage pools and before the inevitable dnouement. This massive fraudulent scheme was a disaster both foreseen by Countrywide and waiting to happen. Defendants knew it, and yet Defendants still induced the Plaintiffs into their scheme without telling them. 10. As a result, Plaintiffs lost their equity in their homes, their credit ratings and

histories were damaged or destroyed, and Plaintiffs incurred material other costs and expenses, described herein. At the same time, Defendants took from Plaintiffs and other borrowers billions ///This Complaint uses "mortgage" and "deed of trust" interchangeably. Depending upon the state and other factors, a loan may be secured by either form of security instrument, the deed of trust being the customary instrument in California.

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of dollars in interest payments and fees and generated billions of dollars in profits by selling their loans at inflated values. 11. Like a drug that requires ever-higher doses to yield the same high, the fraud

reached its zenith or its nadir when Countrywide systematically destroyed California home values county-by-county and then State-wide. 12. Then, Defendants began to use their customers most private information for an

extra edge. This use of private information violated the inalienable Constitutional rights accorded to all California citizens. Defendants violations ranged from the disclosure of the most private and confidential information of more than 2.4 million customers, to the outsourcing and sale of hundreds of thousands of records to bolster their fraudulent scheme, disenfranchising Californians of their Article I, 1 inalienable rights of privacy, that went far beyond the sale of Private Information disclosed in the settlement of the Kentucky class action. 13. When Countrywide pooled the loans it originated and sold them in secondary

mortgage market transactions, Countrywide recorded gains on the sales. In 2005, Countrywide reported $451.6 million in pre-tax earnings from capital market sales; in 2006, it recognized $553.5 million in pre-tax earnings from that activity. But, after the liquidity crisis hit, in 2007 it recognized a mere $14.9 million in pre-tax earnings from that activity and reported an overall pre-tax loss. 14. The foregoing events even to this day benefit the very people who were behind

the Countrywide fraud. For example, Stanford Kerlund, former president of Countrywide, left Countrywide as the scheme was accelerating in late 2006. He then formed PennyMac, his

current business. PennyMac buys up the mortgages on which Plaintiffs and other Countrywide borrowers defaulted at pennies on the dollar, repackages the mortgages and sells them for a profit, thereby adding continued injury and profit to the original scheme. PennyMacs business is supported and sanctioned by the Defendants herein. 15. The Defendants include some of our leading financial institutions institutions on

which Plaintiffs thought they could rely, and did rely. But, they were wrong. As is clear from the mounting number of federal and state enforcement actions against Defendants, it is now -9COMPLAINT

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widely recognized that they engaged in reprehensible conduct with regard to their mortgage business. Without limitation, the United States Securities and Exchange Commission (SEC) charged Mozilo and other former senior officers of Countrywide with fraud for the securitization counterpart of the fraud perpetrated on Plaintiffs; the SEC obtained a $150 million settlement from BofA for fraud involving its acquisition of Merrill Lynch; the United States Federal Trade Commission (FTC) obtained $108 million from two Countrywide mortgage servicing companies to settle FTC charges that they collected excessive fees from cash-strapped borrowers who were struggling to keep their homes; and New York commenced fraud proceedings against the recently departed BofA CEO. 16. These acts continue to this day with hardball tactics and deception that continue to

threaten Plaintiffs Constitutional rights and financial security, as well as the economic future of the State of California.

THE PARTIES NAMED PLAINTIFFS 17. Plaintiff, DANIEL MAXAM, is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 18. Plaintiff ALEJANDRO ALARCON, is an individual residing in the State of

Arizona, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Arizona real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 19. Plaintiff JULIE ANDERSON is an individual residing in the State of Oregon,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Oregon real estate. At all material - 10 COMPLAINT

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times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 20. Plaintiff LYNETTE ASTORS is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 21. Plaintiff BRUCE BARRETT is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 22. Plaintiff BRANSTON BAUDER is an individual residing in the State of Nevada,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Nevada real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 23. Plaintiff BRETT BORBA is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 24. Plaintiff BUNNY BOWERS is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide acted as Servicer or some other control capacity over processing the loan. /// - 11 COMPLAINT

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25.

Plaintiff EDDIE BRANDES is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide acted as Servicer or some other control capacity over processing the loan. 26. Plaintiff ROY BREWER is an individual residing in the State of Florida, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Florida real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 27. Plaintiff BRAD J. BRITTON is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 28. Plaintiff HENRY BURGESS is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 29. Plaintiff JOSE CABANAS is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 30. Plaintiff ELVIRA CADENAS is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material - 12 COMPLAINT

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times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 31. Plaintiff MARIA CAMARILLO is an individual residing in the State of Arizona,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 32. Plaintiff CHRISTINE CARPENTER is an individual residing in the State of

Washington, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Washington real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 33. Plaintiff ROBERT CASTORE is an individual residing in the State of Rhode

Island, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Rhode Island real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 34. Plaintiff JAMES CHAFFIN is an individual residing in the State of Ohio, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Ohio real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 35. Plaintiff LISA DAGGS-CHARETTE is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 13 COMPLAINT

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36.

Plaintiff CHRIS CLARK is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 37. Plaintiff CHRISTINE JI is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 38. Plaintiffs SEANNA COLLIGAN and MICHAEL COLLIGAN, are individuals,

wife and husband, residing in the State of Colorado, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on their Colorado real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 39. Plaintiff K.C. CRANDALL is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 40. Plaintiff ANTONIO CRUZ is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 41. Plaintiff COSME CRUZ is an individual residing in the State of Illinois, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Illinois real estate. At all material times - 14 COMPLAINT

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hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 42. Plaintiff TUAN HAI DANG is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 43. Plaintiff STEPHANIE DIAMOND is an individual residing in the State of Utah,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Utah real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 44. Plaintiff DIEP DANG is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 45. Plaintiff DOLORES SABLAN is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 46. Plaintiff ROBERT DUBOIS is an individual residing in the State of Colorado,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Colorado real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 15 COMPLAINT

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47.

Plaintiff TERRI EADENS is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 48. Plaintiff EDITHA RESTAURO is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 49. Plaintiff KIRA EDWARDS is an individual residing in the State of Idaho, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Idaho real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 50. Plaintiff EVELYN SISTRUNK is an individual residing in the State of

Pennsylvania, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Pennsylvania real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 51. Plaintiff ROSIBEL FADUL is an individual residing in the State of Florida, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on hER Florida real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 52. Plaintiff ENIO FONTANELLI is an individual residing in the State of Florida,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Florida real estate. At all material - 16 COMPLAINT

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times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 53. Plaintiff DOUGLAS FORE is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 54. Plaintiff WILLIAM FOSTER is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 55. Plaintiff TRINA FRAZIER is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 56. Plaintiff GENARO MENJIVAR is an individual residing in the State of Utah,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Utah real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 57. Plaintiffs GEORGE OLSEN and PAULETTE OLSEN are individuals, husband

and wife, residing in the State of Arizona, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on their Arizona real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 17 COMPLAINT

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58.

Plaintiff GLEN LEMMON is an individual residing in the State of Utah, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Utah real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 59. Plaintiff RICARDO GONZALES TAFOLLA is an individual residing in the State

of California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 60. Plaintiff LEOPOLDO GONZALEZ is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 61. Plaintiff STEPHANIE GOTTERO is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 62. Plaintiff KARLA GOULART is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 63. Plaintiff SALVADOR GUTIERREZ is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. - 18 COMPLAINT

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At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 64. Plaintiff JACINTO GUZMAN is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 65. Plaintiff OFELIA HERNANDEZ is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 66. Plaintiff TIMOTHY INFANGER is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 67. Plaintiff BENJAMIN INGRAM is an individual residing in the State of

Washington, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Washington real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 68. Plaintiff TAMMY JACKSON is an individual residing in the State of Florida,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Florida real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 19 COMPLAINT

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69.

Plaintiff LYNETTE JAMORA is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 70. Plaintiff MARIA JIMENEZ is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 71. Plaintiff JOE BARELA is an individual residing in the State of New Mexico, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his New Mexico real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 72. Plaintiff JOHN ALLEN is an individual residing in the State of Arizona, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Arizona real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 73. Plaintiff JOHN MORENO is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 74. Plaintiff LAVANCE JOHNSON is an individual residing in the State of Virginia,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Virginia real estate. At all material - 20 COMPLAINT

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times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 75. Plaintiff JOSEPH ELONGE-FOBIA is an individual residing in the State of

Arizona, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Arizona real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 76. Plaintiff NARINDER KAUR is an individual residing in the State of Washington,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Washington real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 77. Plaintiff KEITH COTANT is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 78. Plaintiff KEVIN MCVEY is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 79. Plaintiff CHRISTINA KIM is an individual residing in the State of Nevada, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Nevada real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 21 COMPLAINT

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80.

Plaintiff JANE KOPECKY is an individual residing in the State of Illinois, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Illinois real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 81. Plaintiff JOSHUA KREITZER is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 82. Plaintiff JONATHAN LANDES is an individual residing in the State of Oregon,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Oregon real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 83. Plaintiff ASHLEY LARSEN is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 84. Plaintiff LEVON LATCHINIAN is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 85. Plaintiff OLIVER LAZARO is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material - 22 COMPLAINT

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times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 86. Plaintiff DANIEL LERTIQUE is an individual residing in the State of Arizona,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Arizona real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 87. Plaintiff KERRIE LLOYD is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 88. Plaintiff CYNTHIA LUNA is an individual residing in the State of New Mexico,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her New Mexico real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 89. Plaintiff LYN HENLEY is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 90. Plaintiff MADONA OANDASAN is an individual residing in the State of Hawaii,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Hawaii real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 23 COMPLAINT

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91.

Plaintiff JANA MALONE is an individual residing in the State of Arizona, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Arizona real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 92. Plaintiff PIERRE MARCOTTE is an individual residing in the State of Michigan,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Michigan real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 93. Plaintiff MARLENE GONZALEZ is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by deeds of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing these loans. 94. Plaintiff NAOMI MARTINSEN is an individual residing in the State of Utah,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Utah real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 95. Plaintiff MARVIN MENDONCA is an individual residing in the State of Nevada,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Nevada real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 96. Plaintiff CARA MCVEY is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times - 24 COMPLAINT

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hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 97. Plaintiff DANIEL MELENDEZ is an individual residing in the State of Oregon,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Oregon real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 98. Plaintiff GERALDINE MOECKEL is an individual residing in the State of

Arizona, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Arizona real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 99. Plaintiff EDGAR MORALES is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 100. Plaintiff DINA MOREAU is an individual residing in the State of Arizona, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003 and December 31, 2008, secured by a deed of trust on her Arizona real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 101. Plaintiff KEN MORRIS is an individual residing in the State of Kansas, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Kansas real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 25 COMPLAINT

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102.

Plaintiff ALAN MOSLEY is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by deeds of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing these loans. 103. Plaintiff SOSTENES MURGA is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 104. Plaintiff NOBLE E. LEE is an individual residing in the State of Washington,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by deeds of trust on his Washington real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing these loans. 105. Plaintiff JOSE NUNEZ is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 106. Plaintiff DONALD OKADA is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 107. Plaintiff JESSE OSBORNE is an individual residing in the State of Arizona, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Arizona real estate. At all material times - 26 COMPLAINT

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hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 108. Plaintiff LUIS PAGES is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 109. Plaintiff MARCELINO PALISOC is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 110. Plaintiff CLAYTON PELLETIER is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 111. Plaintiff MITCH PERERIA is an individual residing in the State of Nevada, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Nevada real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 112. Plaintiff RICHARD PILLSBURY is an individual residing in the State of Oregon,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Oregon real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 27 COMPLAINT

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113.

Plaintiff HAYDEN POGNI is an individual residing in the State of Hawaii, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Hawaii real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 114. Plaintiff ROGER PREBLE is an individual residing in the State of Utah, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Utah real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 115. Plaintiff CARLOS QUINO is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 116. Plaintiff LORETTA RAYA is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 117. Plaintiff RHONDA CHISHOLM is an individual residing in the State of Nevada,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Nevada real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 118. Plaintiff DANIEL RICHARD is an individual residing in the State of Nevada,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Nevada real estate. At all material - 28 COMPLAINT

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times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 119. Plaintiff ROBERT GILBERT is an individual residing in the State of Montana,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Montana real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 120. Plaintiff AUDRA RODRIGUEZ is an individual residing in the State of Virginia,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Virginia real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 121. Plaintiff CESAR RODRIGUEZ is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 122. Plaintiff FRANK ROPER is an individual residing in the State of Massachusetts,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Massachusetts real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 123. Plaintiff HOWARD ROSENTHAL is an individual residing in the State of

Maryland, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Maryland real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 29 COMPLAINT

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124.

Plaintiff ROGER ROTTLER is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 125. Plaintiff ANGELA SANCHEZ is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 126. Plaintiff SELINA WILDER is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 127. Plaintiff SHARON KING is an individual residing in the State of Washington,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Washington real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 128. Plaintiff JEREMY SHEAFFER is an individual residing in the State of Virginia,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Virginia real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 129. Plaintiff DEBRA SIMPSON is an individual residing in the State of Nevada, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Nevada real estate. At all material times - 30 COMPLAINT

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hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 130. Plaintiff NATHAN SKIVER is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 131. Plaintiff GUILLERMO TABARES is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 132. Plaintiff STEPHEN TEICHMAN is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 133. Plaintiff FATIMA TENDERRO is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 134. Plaintiff TISHARRA SHREIBER is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 31 COMPLAINT

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135.

Plaintiff TODD GAGNON is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 136. Plaintiff JORGE TORRES is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 137. Plaintiff HWANG TRAN is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 138. Plaintiff RONALD TURNER is an individual residing in the State of Illinois, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Illinois real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 139. Plaintiff ROSEMARY TURNER is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 140. Plaintiff JOHN URTIAGA is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material - 32 COMPLAINT

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times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 141. Plaintiff THOMAS VAN DUSEN is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 142. Plaintiff NELDA VARGAS is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 143. Plaintiff LINDA VULAJ is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 144. Plaintiff RIK WAHLRAB is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 145. Plaintiff PHILIP WARMANEN is an individual residing in the State of Florida,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Florida real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 33 COMPLAINT

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146.

Plaintiff CHRISTIAN WELLMAN is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 147. Plaintiff MARK WHITEHEAD is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 148. Plaintiff DARNELL WYRICK is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by deeds of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing these loans. 149. Plaintiff MAZIAR ABRISHAMIAN is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 150. Plaintiff JULIE BLACKLEY is an individual residing in the State of Utah, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 151. Plaintiff DUANE BLEDSOE is an individual residing in the State of Nevada,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material - 34 COMPLAINT

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times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 152. Plaintiff MARK CAIRA is an individual residing in the State of Massachusetts,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 153. Plaintiff DAVID DELGADO is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 154. Plaintiff CLYDE DODSON is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 155. Plaintiff EVELYN HERRERA is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 156. Plaintiff BACHHONG KHONG is an individual residing in the State of Nevada,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 35 COMPLAINT

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157.

Plaintiff LOUIE LEWIS is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 158. Plaintiff JOEL LIEBKE is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by deeds of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing these loans. 159. Plaintiff LARRY LUNSFORD is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 160. Plaintiff DARYL MCCANCE is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 161. Plaintiff EDWARD SANCHEZ is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 162. Plaintiff CONNIE SCHULENBERG is an individual residing in the State of

Wisconsin, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her Wisconsin real estate. - 36 COMPLAINT

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At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 163. Plaintiff RICHARD VAN DER WORP is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 164. Plaintiff FRED WHITE is an individual residing in the State of Colorado, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Colorado real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 165. Plaintiff PETRE MILE is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 166. Plaintiff FRANZ BELL is an individual residing in the State of Utah, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Utah real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 167. Plaintiff TIMOTHY SMITH is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 37 COMPLAINT

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168.

Plaintiff GILBERT SIGALA is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 169. Plaintiff ELENO DE LA CRUZ is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 170. Plaintiff SALVACION AQUINO is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 171. Plaintiff MANUEL ARECHIGA is an individual residing in the State of Texas,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Texas real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 172. Plaintiff AMRIK BAJWA is an individual residing in the State of New Jersey,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his New Jersey real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 173. Plaintiff ROSARIO BARA is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material - 38 COMPLAINT

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times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 174. Plaintiff OLGA BARDALES is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 175. Plaintiff GIL BECKENSTEIN is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 176. Plaintiff RHONDA BOGGAN is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 177. Plaintiff RANDY BROOKS is an individual residing in the State of Alabama,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Alabama real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 178. Plaintiff HAROLD BYRD is an individual residing in the State of Iowa, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Iowa real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 39 COMPLAINT

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179.

Plaintiff VITO CALABRESE is an individual residing in the State of Illinois,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Illinois real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 180. Plaintiff EVERARDO CASTRO is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 181. Plaintiff FRANCISCO CEBALLOS is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 182. Plaintiff CYNTHIA CHANG is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 183. Plaintiff ANJA CHRISTIE-JOHNSON is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 184. Plaintiff GRACIELA CONTRERAS is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. - 40 COMPLAINT

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At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 185. Plaintiff ANIBAL CORDERO is an individual residing in the State of New York,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her New York real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 186. Plaintiff OTTO RENE DE LEON is an individual residing in the State of

California, who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 187. Plaintiff JOSE DELGADO is an individual residing in the State of California,

who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 188. Plaintiff ALICIA DIAZ is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 189. Plaintiff DAVID DILLON is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. /// - 41 COMPLAINT

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190.

Plaintiff JOHN DONAHUE is an individual residing in the State of Florida, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Florida real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 191. Plaintiff JULIO DORADO is an individual residing in the State of Florida, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his Florida real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 192. Plaintiff TUONG DU is an individual residing in the State of California, who

borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate. At all material times hereto, Countrywide has acted as Servicer or some other control capacity over processing the loan. 193. Plaintiff ELLA FERNANDEZ is an individual