Wells Fargo -Motion for Reconsideration of Order Denying Def Motion for Sanction

8/4/2019 Wells Fargo -Motion for Reconsideration of Order Denying Def Motion for Sanction

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not entitled to enforce the note; and (4) to give trial courts greater authority to sanction

plaintiffs who make false allegations.3

3. On December 9, 2010, the Supreme Court clarified its position and stated: Along with the

amendments to form 1.996(a), rule 1.110(b) was amended to require verification of

mortgage foreclosure complaints involving residential real property. One of the primarypurposes of this amendment was to ensure that the allegations in the complaint are

accurate.4

4. Florida Statutes section 92.525 is the statutory framework for verification of documents and

states that (1) When it is authorized or required by law, by rule of an administrative agency, or

by rule or order of court that a document be verified by a person, the verification may be

accomplished in the following manner: (a) Under oath or affirmation taken or administered

before an officer authorized under s. 92.50 to administer oaths; or (b) By the signing of the

written declaration prescribed in subsection (2).5

5. Florida Statutes section 92.525(2) states that as a requirement, a written declaration as defined

under section 92.525(1) of the Florida Statutes, means the following statement: Under

penalties of perjury, I declare that I have read the foregoing [document] and that the facts

stated in it are true, followed by the signature of the personmaking the declaration, except

when a verification on information or belief is permitted by law, in which case the words to

the best of my knowledge and belief may be added. The written declaration shall be

printed or typed at the end of or immediately below the document being verified and

above the signature of the person making the declaration.6

6. Florida Statutes section 92.525(3) states that [a] person who knowingly makes a false

declaration under subsection (2) is guilty of the crime of perjury by false writtendeclaration, a felony of the third degree, punishable as provided in s. 775.082, s. 775.083,

or s. 775.084.7

7. An opinion by the Florida Attorney General dated June 13, 1995 states that a verification may

be made on information or belief, if authorized by law, and will be sufficient to subject

the affiant to penalties of perjury.8

3 In re: Amendments to the Florida Rules of Civil Procedure, No. SC09-1579, (Feb. 11, 2010). (emphasis added)

4 In re: Amendments to the Florida Rules of Civil Procedure-Form (Final Judgment of Foreclosure), Case No.SC09-1579. (emphasis added)

5 Fla. Stat. 92.525(1). (emphasis added)



8 Op.Atty.Gen. 95-40, June 13, 1995. (emphasis added)


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8. Florida Statutes section 92.525(4)(b) states that [t]he term document means any writing

including, without limitation, any form, application, claim, notice, tax return, inventory,

affidavit, pleading, or paper.9

9. Florida Statutes section 92.525(4)(c) states that [t]he requirement that a document be

verified means that the document must be signed or executed by a person and that theperson must state under oath or affirm that the facts or matters stated or recited in the

document are true, or words of that import or effect.10

10. A Judge may dismiss the action with or without prejudice if the court determines a

fraud on the court has occurred. The requisite fraud on the court occurs where it can be

demonstrated, clearly and convincingly, that a party has sentiently set in motion some

unconscionable scheme calculated to interfere with the judicial system's ability to

impartially adjudicate a matter by improperly influencing the trier of fact or unfairly

hampering the presentation of the opposing party's claim or defense.11

11. "There are two elements in mail fraud: (1) having devised or intending to devise a

scheme to defraud (or to perform specified fraudulent acts), and (2) use of the mail for

the purpose of executing, or attempting to execute, the scheme (or specified fraudulent

acts)."12

12. The elements of wire fraud under Section 1343 directly parallel those of the mail fraud

statute, but require the use of an interstate telephone call or electronic communication

made in furtherance of the scheme.13

13. When reviewing a case for fraud, the court should consider the proper mix of factors

and carefully balance a policy favoring adjudication on the merits with competingpolicies to maintain the integrity of the judicial system.14

9 Fla. Stat. 92.525(4)(b). (emphasis added)

10 Fla. Stat. 92.525(4)(c). (emphasis added)

11 Aoude v. Mobil Oil Corp., 892F.2d 1115, 1118 (1st Cir.1989). (emphasis added)

12 Schmuck v. United States, 489 U.S. 705, 721 n. 10 (1989); see also Pereira v. United States, 347 U.S. 1, 8 (1954)("The elements of the offense of mail fraud under . . . 1341 are (1) a scheme to defraud, and (2) the mailing of aletter, etc., for the purpose of executing the scheme."); Laura A. Eilers & Harvey B. Silikovitz, Mail and Wire Fraud,31 Am. Crim. L. Rev. 703, 704 (1994) (cases cited).

13 United States v. Briscoe, 65 F.3d 576, 583 (7th Cir. 1995) (citing United States v. Ames Sintering Co., 927 F.2d232, 234 (6th Cir. 1990) (per curiam)); United States v. Frey, 42 F.3d 795, 797 (3d Cir. 1994) (wire fraud is identicalto mail fraud statute except that it speaks of communications transmitted by wire); United States v. Cassiere, 4 F.3d1006 (1st Cir. 1993) (to prove wire fraud government must show (1) scheme to defraud by means of false pretenses,(2) defendant's knowing and willful participation in scheme with intent to defraud, and (3) use of interstate wirecommunications in furtherance of scheme); United States v. Maxwell, 920 F.2d 1028, 1035 (D.C. Cir. 1990) ("Wirefraud requires proof of (1) a scheme todefraud; and (2) the use of an interstate wire communication to further thescheme.").

14 Id. at 1117-18. (emphasis added)


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14. Because dismissal sounds the death knell of the lawsuit, courts must reserve such

strong medicine for instances where the defaulting party's misconduct is correspondingly

egregious.15

15. The trial court has the inherent authority, within the exercise of sound judicial

discretion, to dismiss an action when a plaintiff has perpetrated a fraud on the court, orwhere a party refuses to comply with court orders.16

DEPOSITION OF WELLS FARGO BANK,N.A.EMPLOYEE AND LEGAL PROCESS SPECIALIST

ALDEN BERNER, CO-WORKER AND TEAM MEMBER OF WELLS FARGO BANK,N.A.

EMPLOYEE AND LEGAL PROCESS SPECIALIST DEBORAH BLANEY, AKA DEBRA BLANEY

16. A deposition of Alden Berner, a Legal Process Specialist for Wells Fargo Bank N.A.,

filed and admitted in three cases involving Wells Fargo Bank, N.A. as plaintiff with Case

Numbers 2010-CA-018991-MB, 2010-CA-023143-MB, and 2010-CA-016671-MB, was

taken December 7, 2010 where Carlton Fields, P.A., through its employee and attorney

Michael K. Winston, Esq., Florida Bar Number 51403 with its business address being

City Place Tower, 525 Okeechobee Boulevard, Suite 1200, West Palm Beach, Florida

33401-6149 appeared as counsel and attorney for plaintiff Wells Fargo Bank N.A.

17. In said deposition dated December 7, 2010, Alden Berner testified that himself, Debra

Blaney, and Craig Zecher reviewed all mortgage foreclosure cases filed in the State of

Florida on behalf of Wells Fargo Bank, N.A.17

Q. What type of training did you get as far as that goes for the -- when you

first became the legal process specialist and dealt with the land

transactions?

A. My training that I received when I originally started with land transactions, I

received training on reviewing plat maps, legal descriptions, titles, and the

various investor requirements for those loans that I reviewed.18

[ ... ]

15 Id. at 1118 (emphasis added)

16 Kornblum v. Schneider, 609 So.2d 138, 139 (Fla. 4th DCA 1992). (emphasis added)

17 Dep. of Alden Berner, Dec. 7, 2010, Wells Fargo Bank, N.A. cases 2010-CA-018991-MB, 2010-CA-023143-MB,and 2010-CA-016671-MB (Palm Beach County) pp. 12 - 17.

18 Dep. of Alden Berner, Dec. 7, 2010, Wells Fargo Bank, N.A. cases 2010-CA-018991-MB, 2010-CA-023143-MB,and 2010-CA-016671-MB (Palm Beach County) pp. 12.


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Q. Who is your supervisor?

A. Mark Kline.

Q. Is he still your supervisor?

A. Yes.

MR. WINSTON: That's K L I N E.

BY MR. FLANAGAN: (resumed)

Q. And is he also located in the same office as you are, on Stage Coach Circle?

A. Yes 19

[ ... ]

Q. Okay. How was it determined that you would review a given mortgage

foreclosure, was it by geographical area, was it by name?

A. It was just we handled Florida -- the entire state of Florida.

Q. "We," being who?

A. Myself and my team, my co-workers.

Q. Okay. So there was yourself and --

A. Two other co-workers.

Q. Who?

A. Deborah Blaney.

Q. Can you spell her last name?

A. B L A N E Y. And Craig, C R A I G, Zecher, Z E C H E R.

Q. And yourself?

19Dep. of Alden Berner, Dec. 7, 2010, Wells Fargo Bank, N.A. cases 2010-CA-018991-MB, 2010-CA-023143-MB,and 2010-CA-016671-MB (Palm Beach County) pp. 13.


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A. And myself, yes.20

[ ... ]

Q. Okay. Did you have any states that you were responsible for -- did the

three of you have any states that you were responsible for other than

Florida?

A. No.

Q. And were the three of you reviewing all of the foreclosure complaints

within the state of Florida?

A. Yes.21

18. In said deposition dated December 7, 2010, Alden Berner testified that it is standard

and systematic procedure for Wells Fargo Bank, N.A. not to look at either a note or

mortgage when verifying a foreclosure Complaint.22

Q. Do you ever get a look at the actual loan document itself, the note or the

mortgage?

MR. [MICHAEL K. WINSTON]: Object to form.

THE WITNESS [ALDEN BERNER]: No.

Q. How about do you get a look at any documents that actually transfer or

assign ownership of any note or mortgage?

A. No, I do not look at them, but I don't need to look at them because I know what

our processes are that refer those loans to our attorneys. And I rely that our

attorneys do their job and put the information in those complaints accurately

20Dep. of Alden Berner, Dec. 7, 2010, Wells Fargo Bank, N.A. cases 2010-CA-018991-MB, 2010-CA-023143-MB,and 2010-CA-016671-MB (Palm Beach County) pp. 15-16.

21Dep. of Alden Berner, Dec. 7, 2010, Wells Fargo Bank, N.A. cases 2010-CA-018991-MB, 2010-CA-023143-MB,and 2010-CA-016671-MB (Palm Beach County) pp. 17.



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and correctly based on the information that was provided to them in our referral

process.23


and systematic procedure for Wells Fargo Bank, N.A. to base their verification solely on

information from a computer screen without any confirmation as to the source of saidinformation.

Q. Do you personally play any role in determining who is or isn't the proper

person or entity for the name to foreclose in?

A. No.

Q. As far as that information is concerned you're relying upon the information you

get from the Investor Matrix?

A. Yes.

Q. And that's computer information that's generated where?

A. I don't know where it is generated, I do know that it is generated by a

department of Wells Fargo who maintains the information that is in that Matrix,

and that Matrix is updated weekly.

Q. Who prepares that Matrix?

A. I don't know who prepares the Matrix.

Q. How does the information get into that Matrix?

A. I am not exactly sure how that information gets in the Matrix.24

[...]

Q. Correct. Okay. Now, how do you know that distinction, the owner versus the

name to foreclose in?

A. I look at our system, per our system it gives us codes, which we need to then

plug those codes into the Investor Matrix; that Investor Matrix is what we relyon to give us that information.




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Q. All right. Then how do you verify that information, if at all?

MR. WINSTON: Object to form.

THE WITNESS: Again, I take the information from the loan, the codes from

the loan, and I plug those codes into our Investor Matrix; and our InvestorMatrix gives me what the correct -- who the owner and the correct name to

foreclose in, and that's what I rely on.

Q. Okay. So, when you're reviewing the information as far as who the proper name

is for the entity to own the loan and to bring the lawsuit in you're relying on the

information that's in that computer system, the Investor Matrix?

A. Yes.

Q. Do you ever get a look at the actual loan document itself, the note or the

mortgage?


THE WITNESS: No.

BY MR. FLANAGAN: (resumed)

Q. How about do you get a look at any documents that actually transfer or assign

ownership of any note or mortgage?

A. No, I do not look at them, but I don't need to look at them because I know whatour processes are that refer those loans to our attorneys. And I rely that our

attorneys do their job and put the information in those complaints accurately

and correctly based on the information that was provided to them in our referral

process.25


and systematic procedure for Wells Fargo Bank, N.A. to never independently verify the

ownership of the subject notes, mortgages, assignment or otherwise by looking at any

actual note, mortgage, assignment or other documentation of ownership in the instant

case.

Q. Now, as I understand it you testified that you didn't personally look at the

information that would have been contained in the note and mortgage, is that

correct?



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A. Yes.

Q. Did you have a reason to look at that information, or is there a reason you didn't

need to look at it?

A. I believe that I did not have a reason to look at that information based on ourreferral process.

Q. What would that referral process be?

A. That referral process would be that the original -- once the loan is in default,

and the thirty day notice of default letters have been sent out, that our

foreclosure department refers these loans to our counsel, and they provide our

counsel with that information, being the note and mortgage - the original note

and mortgage.

Q. And is it the attorneys job to input that information from the note and mortgageinto the complaint?

A. Yes.26


and systematic procedure for Wells Fargo Bank, N.A. to never look at the Complaint as

it is filed in Court nor any of its attachments, per se.

Q. Okay. And I take it you never get a look at a copy of the mortgage that's

attached, or referenced in the complaint, am I correct?

A. No I do not get a look at that again. That's part of our referral process, the

original is sent to our attorneys; and I rely that they accurately input that

information into the complaint, and there is no need that they send it back to us,

when we originally sent it to them.

Q. Now, once you verify the information per your computer programs, the

Investor Matrix and the other information, is that where you either approve or

reject?

A. Yes.

Q. Okay. And if you accept it have I got that right there, the choices you have,

either accept or reject?

26 Dep. of Alden Berner, Dec. 7, 2010, Wells Fargo Bank, N.A. cases 2010-CA-018991-MB, 2010-CA-023143-MB,and 2010-CA-016671-MB (Palm Beach County) pp. 80-81.


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A. Accept, reject, approve or disapprove.27


and systematic procedure for Wells Fargo Bank, N.A. to never verify that all conditions

precedent to the filing of foreclosure actions have been performed or have occurred.

Q. Okay. If you accept and approve the information that you have reviewed on the

computer screen -- if you click "accept" or "approve," then what happens?

A. We get the verification to sign.

Q. The verification that was attached to the complaints in the cases?

A. Yes.

Q. All right. What do you mean you get?

A. Meaning it's now available for us to sign. If we reject it then it's not going to

give us the verification to sign.

Q. When you say it's available for you to sign, does that come up on a computer

screen?

A. It's in the same attorney portal.28

[...]

Q. A couple of these documents make reference to [ ] paragraphs [ ] that state, "all

conditions precedent to the filing of this action have been performed or have

occurred." What does that mean to you?

A. It's legal terminology, but my belief is that that means that all of the things that

had to happen prior to the foreclosure referral have taken place.

Q. Did you do anything as far as investigating to confirm any of that information?

A. No, I didn't need to. Our system is automated to where everything has been

done prior to this coming before me.

Q. Okay. And, so, is this information that again was supplied by counsel that

prepared the form?




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THE WITNESS: Yes.29

DOCUMENTS IN CASE DOCKET/RECORD

23. On or about December 21, 2010, Plaintiff, Wells Fargo Bank, N.A., through its

attorneys, Marshall C. Watson, P.A., and more specifically, attorney Nalini Singh, Esq.,

Florida Bar Number 43700, which lists is business address as 1800 N.W. 49th Street,

Suite 120, Fort Lauderdale, Florida 33309, as an employee and agent of Marshall C.

Watson, P.A., and in representation of Wells Fargo Bank N.A., filed a Complaint against

Defendants Carlos Ramos and Ilsa Ramos of Seminole County, Florida seeking

foreclosure of a certain mortgage recorded in the Official Records Book 04865, Page

0543, of the Public Records of Seminole County, Florida and a related note.

24. Even though the Summons required responses to Marshall C. Watson, P.A., said

Complaint, filed was signed by attorney Nalini Singh, Esq. on behalf of the Law Officesof Marshall C. Watson, P.A. in representation of Wells Fargo Bank N.A.

25. Said Complaint states in paragraph #3 that [m]ortgagee shown on the Mortgage attached

as an exhibit is the original Mortgagee. Plaintiff is now entitled to enforce Mortgage and

Mortgage Note pursuant to Florida Statutes 673.3011.

26. Said Complaint states in paragraph #6 that [a]ll conditions precedent to the filing of this

action has been performed or occurred.

27. Nalini Singh, Esq., as an attorney for the Law Offices of Marshall Watson, P.A., and on

behalf of Wells Fargo Bank, N.A., together with the Summons and Complaint, filed a

separate page titled Fla. R. Civ. P. 1.110(b) Verification signed by a one Debra Blaney

as Legal Process Specialist and stating that [u]nder penalty of perjury, I declare that I

have read the foregoing, and the facts alleged therein are true and correct to the best of

my knowledge and belief.

28. Said document titled Fla. R. Civ. P. 1.110(b) Verification is signed by Debra Blaney as

Legal Process Specialist but does not state who is her employer, whether it is Plaintiff

Wells Fargo Bank, N.A. or its attorneys, the Law Offices of Marshall C. Watson, P.A.

29. The Mortgage attached to the Complaint and referenced in the Complaint, showing tohave been recorded in the Official Records Book 04865, Page 0543 of the Public Records

of Seminole County, Florida patently show, on its first page, that the lender and

mortgagee is Wells Fargo Home Mortgage, Inc. not Wells Fargo Bank, N.A.

29 Dep. of Alden Berner, Dec. 7, 2010, Wells Fargo Bank, N.A. cases 2010-CA-018991-MB, 2010-CA-023143-MB,and 2010-CA-016671-MB (Palm Beach County) pp. 66-67.


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30. The Note attached to the Complaint and referenced in the Complaint patently shows,

on its first page, that the lender is Wells Fargo Home Mortgage, Inc. not Wells Fargo

Bank, N.A.


on its last page, that the lender is Wells Fargo Home Mortgage, Inc., endorsed the noteen blanc; it is patently clear that Wells Fargo Bank, N.A. did not endorse said note

because it was not the Lender nor the Mortgagee in the related aforementioned

Mortgage.

32. Defendants through their undersigned Counsel filed a Motion for Sanctions Against Plaintiff

for Perjury February 21, 2010 stating in paragraph #2 that [t]he documents attached to the

Complaint clearly contradict and show that the allegations made in the Complaint are

false and without merit.

33. Defendants through their undersigned Counsel filed the instant Motion for Sanctions Against

Plaintiff for Perjury February 21, 2010 stating in paragraph #4 that [a]t a minimum, the

person signing such document must have read the Complaint with its attached exhibits,

namely the Mortgage and Note.

34. Defendants through their undersigned Counsel filed the instant Motion for Sanctions Against

Plaintiff for Perjury February 21, 2010 stating in paragraph #5 that [c]learly, Plaintiff has

not been forthcoming or offered such statements without regards to the Candor owed to

the Court thereunder and its actions have caused Defendants to incur legal fees and

expenses that are unnecessary and unjustified but for its actions in bad faith and without

candor.

AGREEMENT BETWEEN THE LAW OFFICES OF MARSHALL C.WATSON,P.A.

AND STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL

35. On or about March 24, 2011, the Law Offices of Marshall C. Watson, P.A. entered into

an agreement with the State of Florida Office of the Attorney General, Department of

Legal Affairs to resolve an investigation into the Law Offices of Marshall C. Watson, P.A.

under the Florida Deceptive and Unfair Trade Practices Act, Part II of the Consumer

Protection Statute, Chapter 501, AG Case #L10-3-1147, styled IN THE MATTER OF :

INVESTIGATION OF LAW OFFICES OF MARSHALL C. WATSON, P.A., AND

MARSHALL C. WATSON, INDIVIDUALLY.

36. Said Agreement entered into by and between the Law Offices of Marshall C. Watson, P.A.,

Marshall C. Watson, individually, and State of Florida Office of the Attorney General dated

March 24, 2011 is entitled: ASSURANCE OF VOLUNTARY COMPLIANCE.30

30 Assurance of Voluntary Compliance agreement between the Law Offices Marshall C. Watson and State of FloridaOffice of the Attorney General dated March 24, 2011.


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37. Page #2 of the Assurance of Voluntary Compliance states in the second paragraph that Law

Offices of Marshall C. Watson, P.A., Marshall C. Watson, individually are working with State

of Florida Office of the Attorney General to establish best practices in foreclosure actions.31

38. Among the several allegations and consumer complaints which triggered the

investigation into the foreclosure practices of Law Offices of Marshall C. Watson, P.A.,detailed in section I, 1.1 of the Assurance of Voluntary Compliance, those relevant to the

instant case are: a. foreclosure actions [ ] filed before the legal standing of the Plaintiff

has been determined, and e. affidavits [ ] filed which were executed by persons without

knowledge of the allegations contained in the affidavits.32

39. As of March 24, 2011, the Law Offices of Marshall C. Watson, P.A., Marshall C.

Watson, individually agreed and assured, in section II of the Assurance of Voluntary

Compliance to implement the following policies and procedures and to ensure such best

practices:

a. As a condition precedent to initiating a foreclosure case in a circuit court in Florida,

each foreclosure case file of the Respondent [(Law Offices of Marshall C. Watson,

P.A.)] will contain the following: (1) the original note, or a lost note affidavit; (2) the

original mortgage or a copy of the recorded mortgage; and (3) documentation

establishing the loan and mortgage are in default; if (1) through (3) do not reflect the

Plaintiff to be named in the foreclosure complaint as the party entitled to foreclose the

note and mortgage, there must also be contained in the law firms file documentation

reflecting that the Plaintiff is a holder of the note or a nonholder in possession of the

note who has the rights of a holder pursuant to Section 673.3011 of the Florida

Statutes.

b. [OMITTED]

c. For cases that have already been filed and active, but in which no final judgment

has been issued by the court on the effective date of this Assurance [(March 24,

2011)], the Respondents [(Law Offices of Marshall C. Watson, P.A.)] will ensure

that prior to seeking entry of a final judgment the foreclosure court file contains

the following: (i) the original note, or a lost note affidavit; (ii) the original mortgage or

a copy of the recorded mortgage; (iii) documentation establishing the loan and

mortgage are in default; and (iv) documentation reflecting that the named Plaintiff

is entitled to enforce the mortgage. A verified complaint will only be required to

be filed for complaints and amended complaints that were filed after June 3, 2010.




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d. For cases currently in litigation on the effective date of this Assurance, without a

final judgment having been issued by the court, the Respondents [(Law Offices of

Marshall C. Watson, P.A.)] shall review said filings for compliance with Section

2.1(c) of this agreement and will file either amended affidavits, replacement

affidavits or notices of withdrawal of any affidavits executed by persons who

Respondents [(Law Offices of Marshall C. Watson, P.A.)] learn did not haveactual knowledge of the allegations contained in the affidavits. Respondents shall

not proceed with the litigation until there is compliance with the terms and

conditions of this provision.33

40. Section II, 2.2 of the Assurance of Voluntary Compliance requires [r]espondents and

their representatives, agents, employees, successors, assigns or any other person who acts

under, by, through, or on behalf of Respondents [(Law Offices of Marshall C. Watson,

P.A.)], directly or indirectly, or through any corporate or other device, shall continue to

comply with the Florida Deceptive and Unfair Trade Practices Act, Chapter 501, Florida

Statutes.34

41. Section II, 2.3 of the Assurance of Voluntary Compliance establishes that [i]t is further

agreed by the parties that Respondents [(Law Offices of Marshall C. Watson, P.A.)] shall

be responsible for making the substantive terms and conditions of this agreement known

to the officers, employees agents, representatives, or any other persons that are

substantially affected by this Assurance and are involved in Respondents [(Law Offices

of Marshall C. Watson, P.A.)] businesses, projects and activities. The obligation imposed

by this paragraph is continuing in nature and shall apply to new officers, employees,

agents, representatives or any other persons who become engaged in Respondents [(Law

Offices of Marshall C. Watson, P.A.)] business activities, including any future business

activities in which MARSHALL C. WATSON engages.35

42. Section II, 2.4 of the Assurance of Voluntary Compliance establishes that [i]t is further

agreed by the parties that Respondents [(Law Offices of Marshall C. Watson, P.A.)] shall

not affect any change in the form of doing business, or the organizational entity of any of

the existing business entities, or create any new business entities, as a method of avoiding

the terms and conditions set forth in this Assurance.36

CARLTON FIELDS,P.A.INVOLVEMENT AND PERPETUATION

33

Assurance of Voluntary Compliance agreement between the Law Offices Marshall C. Watson and State of FloridaOffice of the Attorney General dated March 24, 2011.





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OF MARSHALL C.WATSON,P.A.S CONDEMNED ACTIONS

43. A notice of appearance was filed in the Courts docket July 27, 2011 listing Carlton

Fields, P.A. as co-counsel in the instant case.

44. In an e-mail communication from Jason Perkins, Esq. dated July 28, 2011, with emailaddress [email protected], confirms that Carlton Fields, P.A., and its

employee, attorney Jason Perkins, Esq. with Florida Bar Number 610852, which lists its

business address, of its Orlando office, as CNL Center at City Commons, 450 S. Orange

Avenue, Suite 500, Orlando, Florida 32801-3336, represents Wells Fargo Bank, N.A. in

the instant matter.

45. Marshall C. Watson, P.A. and its employee, attorney Nalini Singh, Esq., Florida Bar Number

43700, which lists its business address as 1800 N.W. 49th Street, Suite 120, Fort Lauderdale,

Florida 33309 is still the original counsel, and now remains co-counsel with Carlton Fields,

P.A., and its employee, attorney Jason Perkins, Esq., Florida Bar Number 610852, which lists

its business address, of its Orlando office, as CNL Center at City Commons, 450 S. Orange

Avenue, Suite 500, Orlando, Florida 32801-3336.

46. An e-mail communication from Renee Kemper, paralegal to Jason Perkins, Esq. of

Carlton Fields, P.A. to Nalini Singh, Esq. of Marshall Watson, P.A. dated August 16,

2011 , in which Mrs. Kemper is forwarding a Notice of Filing of the 2004 merger of Wells

Fargo Bank, N.A. and Wells Fargo Home Mortgage, Inc. in support of Plaintiffs

opposition to sanctions for perjury, confirms Marshall C. Watson, P.A.s continued

control and involvement in the instant matter, notwithstanding the fact that it remains

co-counsel in the instant matter.

47. All filings in the matter by Jason Perkins, Esq. of Carlton Fields, P.A. have also been

copied as a matter of legal process to Nalini Singh, Esq. of Marshall C. Watson, P.A.

48. The Law Offices of Marshall C. Watson, P.A., through its employee attorney Nalini

Singh, Esq., or otherwise, have made no further filings or arguments directly to the

Court in the instant matter.

49. Nonetheless, by virtue of the March 24, 2011 Agreement, titled Assurance of Voluntary

Compliance, by and between the Law Offices of Marshall C. Watson, P.A., the State of

Florida Office of the Attorney General, Department of Legal Affairs, and attorney

Marshall C. Watson, P.A., individually, the actions of Carlton Fields, P.A. remain theresponsibility of the Law Offices of Marshall C. Watson, P.A.

50. Despite the Motion for Sanctions Against Plaintiff for Perjury being filed February 21,

2010 stating in paragraph #2 that [t]he documents attached to the Complaint clearly

contradict and show that the allegations made in the Complaint are false and without

merit, and despite an email from the undersigned attorney to Jason Perkins, Esq. dated
mailto:[email protected]:[email protected]:[email protected]


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August 12, 2010 where Defendants make Plaintiff aware of their concerns and allegations

in the Motion for Sanctions Against Plaintiff for Perjury, Marshall C. Watson, P.A. and

Carlton Fields, P.A. failed to abide by the Assurance of Voluntary Compliance or correct

a known fraud upon the Court.

51. Therefore, their actions callously, egregiously, willfully, and without remorse,perpetuate a fraud upon the Court, through it, upon the citizens of Seminole County and

all those under the jurisdiction of the 18th Judicial Circuit of Florida.

ARGUMENTS PRESENTED BEFORE THE COURT AT THE AUGUST 30,2011

HEARING OF DEFENDANTSMOTION FORSANCTIONS AGAINST PLAINTIFF FORPERJURY

52. The Mortgage attached to the Complaint and referenced in the Complaint, showing to

have been recorded in the Official Records Book 04865, Page 0543 of the Public Records

of Seminole County, Florida patently shows, on its first page, that the lender and

mortgagee is Wells Fargo Home Mortgage, Inc. not Wells Fargo Bank, N.A.


on its first page, that the lender is Wells Fargo Home Mortgage, Inc. not Wells Fargo

Bank, N.A.

54. The Note attached to and referenced in the Complaint patently shows, on its last page,

that the lender is Wells Fargo Home Mortgage, Inc., endorsed the note en blanc; it is

patently clear that Wells Fargo Bank, N.A. did not endorse said note because it was not

the Lender nor the Mortgagee in the related aforementioned Mortgage.

55. Plaintiff argued that Defendants Motion for Sanctions against Plaintiff for Perjury was

unfounded where Plaintiff is the original mortgagee by way of a merger that took place May 8,

2004, where the original mortgagee Wells Fargo Home Mortgage, Inc. merged into Plaintiff

Wells Fargo Bank, N.A.

56. Defendants argued and maintained that the fact that the merger occurred a year after

the mortgage was entered into between the original mortgagee and that Plaintiff was the

surviving entity in the merger proves that Plaintiff is not the original Mortgagee. At the

time the mortgage was executed the original mortgagee was an independent entity from

Plaintiff with a different federal employers identification number (FEIN/Tax Id) and

therefore autonomous and separate from Plaintiff.

57. Defendants argued and maintained that the Complaint makes no mention of a merger,

or an assignment of the note and mortgage, therefore depriving Defendants from raising

potential defenses in that respect.

58. Defendants argued and maintained that Plaintiff Wells Fargo Bank, N.A. through their

Counsels Marshall C. Watson, P.A. and Carlton Fields, P.A. should have corrected its

Complaint to provide information of the merger so as to establish how and when plaintiff


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Wells Fargo Bank N.A. can foreclose when the original mortgagee is Wells Fargo Home

Mortgage, Inc. and that the Complaint makes no mention of the said merger.

59. Moreover, Defendants argued that the information of the merger is irrelevant since it

has nothing to do with the verification statement which makes reference to the

truthfulness and correctness of the allegations made in the Complaint; that it should beclear to the Court that the contradictions are patent and no inferences need be drawn to

see that the Complaint is not truthful or correct.

60. It is clear and irrefutable, that, having had the opportunity and the duty to correct the

Complaint and withdraw the false statement of verification, especially when they were

present when Wells Fargo Bank, N.A. confessed to its perjury, a fraud has been

committed upon the Court and still continues despite all the requirements of the

Supreme Court of Florida and the agreement reached with the State Attorney Generals

office to halt an investigation into the foreclosure practices of these law firms and their

client, Wells Fargo Bank N.A.

61. This Court, during the hearing of the instant Motion for Sanctions Against Plaintiff for

Perjury, agreed with Defendants counsel that the allegations made in the Complaint and

the Verification was a mistake.

62. This Court, in its discretion, denied that sanctions be imposed on Plaintiff stating that

the mistakes of Plaintiff and its counsel did not rise to the sanctions being sought by

Defendants or what the Supreme Court intended.

ARGUMENT AND CONCLUSION OF LAW

Florida Statutes section 92.525 and AMENDMENTS TO RULE 1.110(B).

63. In reaction to this wave of abuses, the Supreme Court of Florida amended Fla. R. Civ. Pro.

1.110(b) to require that, on all actions for foreclosure of a mortgage on residential real

property, the complaint shall be verified. The Plaintiff, through its attorneys made no

efforts whatsoever to verify the allegations in the complaint even though the instant

action is an action for foreclosure of a mortgage on residential real property.

64. The Supreme Court went on to clarify that one of the primary purposes of this amendment

was to ensure that the allegations in the complaint are accurate. However, the Supreme

Court also envisioned that some attorneys and their clients may still ignore the rules andfurther noted that this amendment is also made to give trial courts greater authority to

sanction plaintiffs who make false allegations. Such is the instant case.

65. Since a verification is required, Florida Statutes section 92.525 established the principles of

said verification statement where Under penalties of perjury, I declare that I have read the

foregoing [document] and that the facts stated in it are true, followed by the signature of the

person making the declaration, except when a verification on information or belief is permitted


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by law, in which case the words to the best of my knowledge and belief may be added.

Plaintiff made no effort whatsoever to verify the allegations in the complaint even though

it states under penalty of perjury that those allegations had been verified and they are all

accurate and true.

66. Florida Statutes section 92.525 required that the written declaration shall be printed or typedat the end of or immediately below the document being verified and above the signature of the

person making the declaration. The written declaration of verification was not printed or

typed at the end of or immediately below the document being verified; in fact, it makes

no reference as to what document is being verified.

67. This intentionally false and fraudulent statement of verification has been made despite

Plaintiffs counsels knowledge that under Florida Statutes section 92.525(3) states that [a]

person who knowingly makes a false declaration under subsection (2) is guilty of the crime of

perjury by false written declaration, a felony of the third degree, punishable as provided in s.

775.082, s. 775.083, or s. 775.084. Thus far, despite the investigations by the Attorney

General and the depositions, clearly showing the perjury committed by Plaintiff, no such

individuals appear to have been prosecuted for their crimes upon this Court and the

citizens affected by them.

FRAUD ON THE COURT

68. It is blatantly obvious that a fraud upon the Court has occurred as established in, at least,

three other cases, where the verification system ploy by Plaintiff and their counsel is

systematic and schematically designed to falsely satisfy the requirements of the Supreme

Court amendments to Rule 1.110(b).

a. Alden Berner deposition of December 7, 2010 clearly delineates the

unacceptable protocol used to falsely verify the Complaint and that Debra

Blaney participated in such process; to wit, that himself, Debra Blaney,

Craig Zecher, and no other individuals reviewed all mortgage foreclosure

cases filed in the State of Florida on behalf of Wells Fargo Bank, N.A.;

b. that it is standard and systematic procedure for Wells Fargo Bank, N.A.

not to look at either a note or mortgage when verifying a foreclosure

Complaint; that it is standard and systematic procedure for Wells Fargo

Bank, N.A. to base their verification solely on information from a

computer screen without any confirmation as to the source of said

information;

c. that it is standard and systematic procedure for Wells Fargo Bank, N.A. to

never independently verify the ownership of the subject notes, mortgages,

assignment or otherwise by looking at any actual note, mortgage,

assignment or other documentation of ownership in the instant case;


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d. that it is standard and systematic procedure for Wells Fargo Bank, N.A. to

never look at the Complaint as it is filed in Court nor any of its

attachments, per se;

e. that it is standard and systematic procedure for Wells Fargo Bank, N.A. to

never verify that all conditions precedent to the filing of foreclosure actionshave been performed or have occurred.

VIOLATIONS OF THE MARCH 24,2011 AGREEMENT BY AND BETWEEN THE LAW OFFICES OF

MARSHALL C.WATSON,P.A. AND STATE OF FLORIDA OFFICE OF THE ATTORNEY GENERAL -

ASSURANCE OF VOLUNTARY COMPLIANCE.

69. This case was filed December 21, 2010 and the March 24, 2011 agreement by and between

the Law Offices of Marshall C. Watson, P.A., Marshall C. Watson, individually, and State of

Florida Office of the Attorney General dated March 24, 2011 entitled Assurance of Voluntary

Compliance required that in the instant case, currently in litigation prior to March 24, 2011,

where a final judgment has not been issued by the court, the Law Offices of Marshall C.

Watson, P.A. review its filings for compliance with Section 2.1(c) of the agreement and file

either amended affidavits, replacement affidavits or notices of withdrawal of any affidavits

executed by persons who the Law Offices of Marshall C. Watson, P.A. learn did not have

actual knowledge of the allegations contained in the affidavits.

70. Alden Berner deposition of December 7, 2010 clearly shows that the Law Offices of

Marshall C. Watson, P.A. clearly knew that all of Wells Fargo Bank, N.A. cases filed

prior to March 24, 2011 and the instant case had been subject to false verifications and

fraudulent statements of verifications made under penalty of perjury by the only three

(3) employees and legal process specialists doing said verifications for all foreclosureactions for entire State of Florida; to wit, Alden Berner, Debra Blaney and Craig Zecher.

71. The emails referenced and incorporated herein by reference as exhibits, together with

the filings in opposition to Defendants Motion for Sanctions Against Plaintiff for Perjury

clearly show that the Law Offices of Marshall C. Watson, P.A. and its co-counsel,

Carlton Fields, P.A. proceed with the litigation without complying with the terms and

conditions of provisions of Section II of the Assurance of Voluntary Compliance.

72. In essence, as argued by the undersigned Counsel before the Court in the hearing of

Defendants Motion for Sanctions Against Plaintiff for Perjury last August 30, 2011, Plaintiff

has been on notice of the defects in the Complaint since said motion for sanctions was

filed; Plaintiff has been on notice of the defects in the Complaint through e-mail

communications with the undersigned counsel, which are incorporated as exhibits by

reference; and Plaintiff has made no effort to correct is perjurious and abusive behavior.

73. What is even more unconscionable and unacceptable - even though there was an

investigation into Plaintiffs counsel, Law Offices of Marshal C. Watson, P.A., for unfair and


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fraudulent trade practices and where, as a result of said investigation, the Law Offices of

Marshal C. Watson, P.A. agreed and assured to withdraw its perjurious statements and

Complaints, and where Plaintiffs co-counsel, Carlton Fields, P.A. through its employee,

attorney Michael K. Winston, Esq., conducted and was present in representation of

Plaintiff Wells Fargo Bank, N.A. when Alden Berner, legal process specialist for Plaintiff

Wells Fargo Bank, N.A. testified under oath as to the protocol and scheme to defraudand falsely represent its verification of the Complaint as required by the Supreme Court

of Florida amendment to Rule 1.110(b), Jason Perkins, Esq., employee attorney for

Carlton Fields, P.A. failed and refused to withdraw and correct said false statements and

stated in its email to the undersigned counsel dated August 15, 2011 that he intended to

proceed with litigation and seek other fees and costs.

74. The Law Offices of Marshall C. Watson, P.A. failed to abide by Section II of the Assurance

of Voluntary Compliance where it is clear that the Law Offices of Marshall C. Watson, P.A.

is responsible responsible for making the substantive terms and conditions of this

agreement known to the officers, employees agents, representatives, or any other personsthat are substantially affected by this Assurance and are involved in the Law Offices of

Marshall C. Watson, P.A.s businesses, projects and activities. Said obligations of the

aforementioned paragraph are continuing in nature and applied to co-counsel Carlton

Fields, P.A. as new officers, employees, agents, representatives, who become engaged in

the Law Offices of Marshall C. Watson, P.A.s business activities, including the instant

case.

75. An e-mail communication from Renee Kemper, paralegal to Jason Perkins, Esq. of

Carlton Fields, P.A. to Nalini Singh, Esq. of Marshall Watson, P.A. dated August 16,

2011 , in which Mrs. Kemper is forwarding a Notice of Filing of the 2004 merger of Wells

Fargo Bank, N.A. and Wells Fargo Home Mortgage, Inc. in support of Plaintiffs

opposition to sanctions for perjury, confirms Marshall C. Watson, P.A.s continued

control and involvement in the instant matter, notwithstanding the fact that it remains

co-counsel in the instant matter.

CARLTON FIELDS, P.A.S INVOLVEMENT AND PERPETUATION OF THE KNOWN FRAUDULENT

VERIFICATION OF THE COMPLAINT AND FALSE ALLEGATIONS CONTAINED IN THE COMPLAINT

76.Carlton Fields, P.A., through its employee and attorney Michael K. Winston, Esq., Florida

Bar Number 51403 with its business address being City Place Tower, 525 Okeechobee

Boulevard, Suite 1200, West Palm Beach, Florida 33401-6149 appeared as counsel andattorney for plaintiff Wells Fargo Bank N.A. with regards to the deposition of Alden Berner, a

Legal Process Specialist for Wells Fargo Bank N.A. in three cases involving Wells Fargo

Bank, N.A. as plaintiff with Case Numbers 2010-CA-018991-MB, 2010-CA-023143-MB, and

2010-CA-016671-MB. Therefore, it is clear that Carlton Fields, P.A. was aware of the

fraudulent practices of its client, Plaintiff Wells Fargo Bank, N.A. as far back as

December 7, 2010.


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77. A notice of appearance was filed in the Courts docket July 27, 2011 listing Carlton Fields,

P.A. as co-counsel in the instant case.

78. An e-mail communication from Jason Perkins, Esq. dated July 28, 2011, with email address

[email protected], confirms that Carlton Fields, P.A., and its employee, attorney

Jason Perkins, Esq. with Florida Bar Number 610852, which lists its business address, of itsOrlando office, as CNL Center at City Commons, 450 S. Orange Avenue, Suite 500, Orlando,

Florida 32801-3336, represents Wells Fargo Bank, N.A.

79. All email communications from Jason Perkins, Esq., employee and attorney of Carlton

Fields, P.A. with the undersigned counsel and their statements made before this Court at the

August 30, 2011 hearing of Defendants Motion for Sanctions Against Plaintiff for Perjury

underline the fact that Carlton Fields, P.A. has, like its co-counsel, the Law Offices of

Marshall C. Watson, P.A., no intention of rectifying a known fraud upon this Court;

instead that Carlton Fields, P.A. continues to perpetuate the forbidden actions in the

Law Offices of Marshal C. Watson, P.A.s Assurance of Voluntary Compliance; and

refuses to abide by the requirements of said Assurances made by the Law Offices of

Marshall C. Watson, P.A.

80. It is clear and irrefutable, that, having had the opportunity and the duty to correct the

Complaint and withdraw the false statement of verification, especially when they were

present when Wells Fargo Bank, N.A. confessed to its perjury, a fraud has been

committed upon the Court and still continues despite all the requirements of the

Supreme Court of Florida and the agreement reached with the State Attorney Generals

office to halt an investigation into the foreclosure practices of these law firms and their

client, Wells Fargo Bank N.A.

WHEREFORE, since this Court already agreed that the allegations made in the Complaint

and the Verification were a mistake, and the evidence attached, referred to and filed herein with

this Motion, simultaneously or as a separate document, especially, the damaging sworn

testimony of Wells Fargo Bank, N.A. to Carlton Fields, P.A., which has already been procured

for three (3) other Wells Fargo Bank, N.A. cases and a Wells Fargo Asset Securities Corporation

case in the 15th Judicial Circuit in and for Palm Beach County, Florida, the Defendants Carlos

and Ilsa Ramos, through their undersigned attorney, most respectfully pray this Court reconsiders

their Motion for Sanctions Against Plaintiff for Perjury and reverses its decision denying said

motion for perjury against Plaintiff, and further:

(1) conclude that the required verification ordered by the Supreme Court of

Florida in its amendment of Florida Rules of Civil Procedure 1.110(b), was

not made;

(2) conclude that a false statement filed under penalties of perjury by Plaintiff

Wells Fargo Bank, N.A. through its attorneys the Law Offices of Marshall C.


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Watson, P.A. and Carlton Fields, P.A. was willingly filed to influence the

Court into believing that Plaintiff can foreclose on Defendants;

(3) conclude that, as the Supreme Court of Florida noted in its amendment of

Florida Rules of Civil Procedure 1.110(b), the primary purposes of this

amendment are to provide incentive for the plaintiff to ensure that theallegations in the complaint are accurate and to give trial courts greater

authority to sanction plaintiffs who make false allegations such as that made

under perjury where Plaintiff Wells Fargo Bank, N.A., through its attorneys

the Law Offices of Marshall C. Watson, P.A. and Carlton Fields, P.A. callously

state that such verification actually took place, when, in fact, never happened;

(4) conclude that Plaintiff Wells Fargo Bank, N.A., through its counsel, Law

Offices of Marshall C. Watson, P.A. failed to file the required verification

ordered by the Supreme Court of Florida in its amendment of Florida Rules of

Civil Procedure 1.110(b) pursuant to the format expounded in Florida Statute

section 92.525(2) requiring that the written declaration shall be printed or

typed at the end of or immediately below the document being verified and

above the signature of the person making the declaration;

(5) conclude that those individuals making said perjurious statements,

specifically, Alden Berner, Deborah Blaney - aka Debra Blaney, Craig Zecher ,

be referred to the State Attorney General and investigated pursuant to Florida

Statutes section 92.525(3) which states that [a] person who knowingly makes

a false declaration under subsection (2) is guilty of the crime of perjury by

false written declaration, a felony of the third degree, punishable as provided

in s. 775.082, s. 775.083, or s. 775.084;

(6) conclude that the aforementioned acts by the parties involved, including two

major law firms, constitute a fraud on the Court where Carlos and Ilsa Ramos

have demonstrated, clearly and convincingly that Wells Fargo Bank N.A., the

Law Offices of Marshall C. Watson, P.A. and Carlton Fields, P.A. have

sentiently set in motion this unconscionable scheme calculated to interfere

with the judicial systems ability to impartially adjudicate this mater by

improperly influencing this Court and unfairly hampering the presentation of

Carlos and Ilsa Ramos presentation of their defenses;

(7) conclude that the Law Offices of Marshall C. Watson, P.A. have breached their

Assurance of Voluntary Compliance with the State Attorney Generals office

where it has failed to correct, rectify and withdraw the perjurious statements

and where it has failed to ensure that Carlton Fields, P.A. continues to do so as

co-counsel in cases in which the Law Offices of Marshall C. Watson, P.A. was

originally involved;


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(1) conclude that, pursuant to the legal precedent discussed herein this Motion,

Wells Fargo Bank N.A., the Law Offices of Marshall C. Watson, P.A. and

Carlton Fields, P.A.s actions are so egregious so as to warrant that this case be

DISMISSED WITH PREJUDICE;

(2) that reassured by the legal precedent herein discussed, together with all theundeniable proof and argument provided herein, this Court, having been

appraised of a fraud upon it being committed, DISMISS THIS ACTION

WITH PREJUDICE;

(3) that as expounded in Kornblum v. Schneider, 609 So.2d 138, 139 (Fla. 4th

DCA 1992), this Court has the inherent authority, within the exercise of sound

judicial discretion, to dismiss an action when a plaintiff has perpetrated a fraud

on the court, or where a party refuses to comply with court orders, where, in

the instant case, both situations warranting a DISMISSAL WITH

PREJUDICE have occurred, this Court DISMISSED THIS ACTION WITH

PREJUDICE;

(4) order an investigation into all similar cases filed by Wells Fargo Bank, N.A.

in the State of Florida to ensure the integrity of our judicial system and all

those foreclosures which may have already been adjudicated under such false

and perjurious pretenses;

(5) order an investigation into the Law Offices of Marshall C. Watson, P.A. for its

ongoing fraudulent misrepresentations and lack of candor on this Court;

(6) order an investigation into Carlton Fields, P.A. for its fraudulentmisrepresentations and lack of candor on this Court and for perpetuating a

known fraud vis-a-vis their being appraised of such fraud by way of the

December 7, 2010 deposition of Alden Berner in which Carlton Fields, P.A.

actively participated;

(7) refer and advise the State Attorney General to investigate the Law Offices of

Marshall C. Watson, P.A. and Carlton Fields, P.A. for their breach of the

Assurance of Voluntary Compliance agreement between the Law Offices

Marshall C. Watson and State of Florida Office of the Attorney General dated

March 24, 2011.

(8) refer and advise the Federal Authorities to open a wire/mail fraud

investigation for each and every instance in which any such aforementioned

perjurious statements were mailed, be it as it may, through e-mail, facsimile

(telecopy), or US Mail, in each and every case that may be affected by the

actions of Wells Fargo Bank, N.A., the Law Offices of Marshall C. Watson,

P.A. and Carlton Fields, P.A.


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(1) refer and advise the Florida Supreme Court and the Florida Bar to open

ethical investigations into all attorneys involved in the instant case and all

other such relevant cases where it may be pertinent, together with any and all

other remedies this Court may deem just and proper to maintain the integrity

of the judicial system of the State of Florida.

CERRUD LAW, PLLC

______________________________

EURIBIADES CERRUD II, ESQUIRE

Florida Bar No.: 0523569

324 Wilshire Boulevard

Casselberry, Florida 32707

Telephone No.: (407) 758-6100

Facsimile No.: (407) 386-6570

Attorney for Defendants

Carlos Ramos and Ilsa Ramos

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for

Reconsideration of Order Denying Defendants Motion for Sanctions Against Plaintiff for

Perjury has been furnished by U.S. Mail, postage pre-paid, to Nalini Singh, Esq., Law Offices of

Marshall C. Watson, P.A., 1800 N.W. 49th Street, Suite 120, Fort Lauderdale, FL 33309; Jason

Perkins, Esq., Carlton Fields P.A., 450 S. Orange Avenue, Suite 500, Orlando, Florida

32801-3336 this 13th day of September 2011.

CERRUD LAW, PLLC

______________________________

EURIBIADES CERRUD II, ESQUIRE

Florida Bar No.: 0523569324 Wilshire Boulevard

Casselberry, Florida 32707

Telephone No.: (407) 758-6100

Facsimile No.: (407) 386-6570

Attorney for Defendants

Carlos Ramos and Ilsa Ramos

Documents

Wells Fargo -Motion for Reconsideration of Order Denying Def Motion for Sanction