dc 89 denise's motion to compel lnv to produce

8/17/2019 DC 89 Denise's Motion to Compel LNV to Produce

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Defendant’ Motion to Consolidate Directly Related Cases of 23

Denise SubramaniamSelf-represented13865 SW Walker RdBeaverton OR 97005503-764-5300

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

PORTLAND DIVISION

LNV CORPORATION Civil Case No. 3:14-cv-01836

Plaintiff,

v. DEFENDANT’S MOTION TO

DENISE SUBRAMANIAM COMPEL PLAINTIFF TO

pro per PRODUCE NEVADA BUSINESS

Defendant LICENSE AND AGREEMENT

MOTION TO COMPEL PLAINTIFF TO PRODUCE NEVADA BUSINESS LICENSE

AND AGREEMENT BETWEEN GMAC-RFC AND PLAINTIFF SPECIFIC TO ITS

CLAIM OF PURCHASE OF DEFENDANT’S DEED OF TRUST

Defendant incorporates herein all her pleadings in this case; her Notice of Directly Related

Cases; her Notice of Constitutional Questions as well as the Notices of Constitutional Questions

filed by the other LNV/Beal victims in the noticed related cases; and in her noticed related cases;

and moves this court pursuant to Federal Rule 12 and Federal Rule 903(11) and Rule 803(6) and

Rule 803(7) (and/or any other Rules to which Defendant as a pro-se litigant may not be aware) to

compel Plaintiff to produce the following records of a regularly conducted activity:

1. Plaintiff LNV Corporation’s (“LNV”) Nevada business license.

2. Plaintiff LNV’s purchase agreement with GMAC’s Residential Funding Corporation

(“GMAC-RFC”) specific to the purchase in which it alleges to have acquired Defendant’s

Case 3:14-cv-01836-MO Document 89 Filed 09/02/15 Page 1 of 93




deed of trust and the deeds of trust/mortgages of the other LNV/MGC/Beal victims in

Defendant’s Notice of Directly Related Cases.

Contrary to LNV’s objection claims specified in the letter LNV’s Counsel Gabrielle Richards

sent to Defendant attached hereto as Exhibit A page 17. These documents are within the scope

of Defendant’s discovery as ordered by Honorable Judge Michael Mosman. At the status

conference hearing where Judge Mosman granted Defendant discovery she specified that she

would need the purchase agreement between LNV and GMAC-RFC.

As LNV’s Counsel Gabrielle Richards pointed out at the status hearing, in Oregon the Note

follows the deed. If the purported conveyance by assignment of deed never occurred or illegally

occurred then LNV cannot be the holder of the Note and LNV has no authority to foreclose on

Defendant’s property by executing the deed of trust to enforce the Note.

Defendant has claimed both that the Note is forged; and that the assignment or conveyance of the

deed never legally occurred. (The Note is forged and Defendant will provide the court with

evidence of this with her objection to LNV’s motion for summary judgment.) However Judge

Mosman specifically said at the status hearing the scope of Defendant’s discovery included

evidence that the conveyance of the deed did not or could not have occurred. In addition to the

securitization audit completed by Bill Paatalo in November 2012, who provided the court with a

sworn declaration specific to his findings which substantiate Defendant’s claim that LNV’s

alleged conveyance of Defendant’s deed never occurred; such conveyance could not have legally

occurred because LNV was not licensed by the State of Nevada to conduct business until after

the March 10, 2008 execution date on the assignment of deed of trust in question.





Nevada corporation statues govern Nevada corporations and Plaintiff LNV by its own admission

is a Nevada corporation. NRS 76.100(1) states:

“A person shall not conduct a business in this State unless and until the person obtains a

state business license issued by the Secretary of State. If the person is: (a) An entityrequired to file an initial or annual list with the Secretary of State pursuant to this title, the person must obtain the state business license at the time of filing the initial or annuallist.”

LNV Corporation is an entity “required to file an initial or annual list with the Secretary of State”

and LNV Corporation was not incorporated until March 17, 2008, so it could not have filed its

first annual list with the Secretary of State prior to this date, and in fact it did not.

LNV could not have obtained a business license prior to its date of incorporation so it could not

have been in compliance with NRS 76.100(1) until after March 17, 2008. Hence the March 10,

2008 corporate assignment of deed of trust alleging to transfer beneficial interest in the

Defendant’s deed of trust to LNV was illegally transacted by LNV in violation of NRS

76.100(1).

If LNV transacted business without a valid Nevada business license in violation of NRS

76.100(1) then this fact is material as to whether this Honorable Court has jurisdiction to grant

Plaintiff LNV the relief it seeks based on an illegally transacted instrument; and it is material as

to whether a legal conveyance of deed occurred.

LNV’S NEVADA BUSINESS LICENSE IS NEEDED TO DETERMINE IF ACONVEYANCE OF THE DEED TO LNV EVER LEGALLY OCCURRED

Plaintiff’s business license is material as to whether or not LNV transacted a conveyance of the

deed of trust to Defendant’s property in violation of NRS 76.100(1). According to JoAnn Larson





from the Nevada Secretary of State (“Nevada SOS”) office a copy of LNV’s business license

would need to be obtained directly from LNV.

LNV’s business license states the date of its issuance and if that date is after March 10, 2008

then the only conclusion that could be inferred from this fact would be that the conveyance of

Defendant’s deed of trust to LNV on March 10, 2008 violated NRS 76.100(1) and was therefore

an illegal business transaction.

The doctrine of unclean hands bars relief to a party who has engaged in inequitable behavior

(including fraud, deceit, unconscionability or bad faith) related to the subject matter of that

party's claim (see Soc'y of Lloyd's v. Shields, 118 F. App'x. 12, 15 (6th Cir. 2004)). The US

Supreme Court in Keystone Driller Co. v. General Excavator Co., 290 U.S. 240, 244–45 (1933)

articulated unclean hands as follows:

“[T]hat whenever a party who, as actor, seeks to set the judicial machinery in motion andobtain some remedy, has violated conscience, or good faith, or other equitable principle,in his prior conduct, then the doors of the court will be shut against him in limine; the

court will refuse to interfere on his behalf, to acknowledge his right, or to award him anyremedy.”

In a later case, the Supreme Court explained the rationale of unclean hands: “That doctrine is

rooted in the historical concept of court of equity as a vehicle for affirmatively enforcing the

requirements of conscience and good faith. This presupposes a refusal on its part to be ‘the

abetter of iniquity.’” Id. at 814 (quoting Bein v. Heath, 47 U.S. (6 How.) 228, 247 (1848)).

The assignment of Defendant’s deed of trust which falsely purports to convey beneficial interest

from GMAC-RFC to LNV is endorsed by GMAC-RFC employee Betty Wright and notarized by

GMAC-RFC employee Diane M. Meistad and it was executed on March 10, 2008. The





assignments of deed of trust/mortgage to LNV in the noticed related cases were also endorsed by

GMAC-RFC employee Betty Wright or GMAC-RFC employee Michael Mead and are all

notarized by GMAC-RFC employee Diane M. Meistad. Copies of these assignments executed

on March 10, 2008 are included with a copy of the assignment specific to Defendant’s deed of

trust in Exhibit B page 20 attached hereto. In addition to those assignments specific to the six

LNV/MGC/Beal victims named in the noticed related cases at least twenty (20) other

assignments to LNV executed on March 10, 2008 are included in this exhibit. The sworn

Affidavit testimony of Terry Howard, another LNV/MGC/Beal victim who witnessed a phone

conversation between Diane M. Meistad and Defendant, supports the fact that Betty Wright,

Michael Mead and Diane M. Meistad were all in fact GMAC and/or GMAC-RFC employees.

Diane M. Meistad also explained that GMAC had a big deal with LNV and how she and the

others signed documents for this transaction for many weeks.

The fact that the parties endorsing these instruments were all GMAC-RFC employees gives

evidences to, and supports what Diane M. Meistad told Defendant and Terry Howard on the

phone; a single transaction occurred between Plaintiff LNV and GMAC-RFC on or before

March 10, 2008 prior to the time in which LNV was licensed to do business in Nevada.

The purchase agreement between GMAC-RFC and LNV and the circumstances in which these

documents were endorsed and by whom they were endorsed and whether the parties so endorsing

these documents had the requisite authority to make such endorsements and/or whether they

themselves made the signatures or whether some other individual made them or they were

computer generated is material to any factual determination as to whether LNV has standing to

foreclose on Defendant’s property; but just as importantly this Honorable Court has an obligation





to the public and to the United States Constitution to protect the equity and property rights of the

other LNV/MGC/Beal victims with deed/mortgage assignments dated March 10, 2008 which

LNV has targeted for foreclosure.

THE PURCHASE AGREEMENT BETWEEN LNV AND GMAC-RFC IS MATERIAL

TO WHETHER THE CONVEYANCE OF THE DEED LEGALLY OCCURRED

The purchase agreement between LNV and GMAC-RFC is material as to a determination of

whether or not a legal conveyance to LNV of beneficial interest in Defendant’s deed of trust

from GMAC-RFC ever occurred. It is therefore within the scope of Defendant’s discovery as

ordered by Honorable Judge Mosman.

LNV’s alleged conveyance of Defendant’s March 10, 2008 assignment and the March 10, 2008

assignments of deed of trust/mortgage to LNV specific to the real property of the other noticed

related victims of LNV/MGC/Beal and endorsed by GMAC-RFC employees Betty Wright or

Michael Mead and Diane M. Meistad are in the opinion of LNV’s Counsel Gabrielle Richards

acts of “frivolous discovery” which she claims she voiced concerns about at the status

conference hearing.

Defendant recalls Your Honorable Judge Mosman asking LNV’s Counsel Gabrielle Richards

three times whether a forged Note would be material to her client’s standing to foreclose. She

evaded the question the first time, she claimed she didn’t believe the Note was forged the second

time, and finally after a reprimand by Your Honor she agreed that it would.

As an indigent disabled pro se litigant (made so by years of paying attorney fees and of suffering

mental anguish defending against numerous fraudulent foreclosure attempts on her property)





Defendant cannot afford to pay the $95 fee required for the transcript of the status conference

hearing at this time. She distinctly recalls Your Honor saying her discovery scope included

evidence that would show that the conveyance of her deed of trust to LNV did not or could not

have occurred.

The purchase agreement between LNV and GMAC-RFC is material as to whether or not

Defendant and the other LNV/MGC/Beal victims including but not limited to the victims named

in the noticed related cases have been victims of racketeering activities and as such are entitled to

treble damages pursuant to 18 U.S. Code § 1961 et seq. (Racketeer Influenced and Corrupt

Organizations Act or “RICO”). Whether or not D. Andrew Beal has promoted and engaged in a

conspiracy to interfere with the civil rights of Defendant and the other LNV/MGC/Beal victims

pursuant to 42 U.S. Code § 1985 et seq. through a pattern of willful fraud upon courts and abuse

of judicial process for personal gain is and should be a concern for this court and the other courts

hearing foreclosure cases involving the property of the other LNV/MGC/Beal victims. Beal’s

personal gain is at the expense of his victims and is achieved via his corrupt enterprise consisting

of numerous shell corporations, like LNV. He deprives his victims of their property, of their

liberty to enjoy or make beneficial financial decisions regarding their investment in their

property, and of their life quality. He does this under color of law. And the pattern of fraud and

judicial abuse he willfully engages in deprives his victims of their due process.

MGC Mortgage Inc. (“MGC”) is a purported mortgage servicer for Plaintiff LNV, Counsel for

LNV has admitted as much in an email communication with the court specific to MGC’s now

former employee Bret Maloney. MGC misappropriates mortgage payments as evidenced by

LNV/MGC/Beal victim Catherine Gebhardt’s six thousand dollar ($6,000) cashier’s check made





payable to MGC but paid to Beal Bank SSB on October 29, 2008. (See Defendant’s Exhibit C

page 61 attached herein) and by the numerous consumer complaints filed with the Texas

Attorney General’s office about MGC misappropriating their payments or by MGC’s refusal to

accept payments. (Copies of these letters are attached as Exhibit B-1 and B-2 to Defendant’s

Notice of Related Cases [doc 59-1].) The pattern of misappropriated payment is the same for all

these LNV/MGC/Beal victims.

Defendant also claims that she never defaulted on her mortgage but was a victim of a trumped up

false default claim made by EMC Mortgage in 2005; and which Litton Loan Servicing (“Litton”)

used to attempt a fraudulent foreclosure on her property in 2006. In 2006 the fact that Litton was

attempting to foreclose on Defendant’s property in behalf of GMAC-RFC was concealed from

Defendant and her attorney. Litton was unable to perfect this 2006 foreclosure action, which

they had proceeded with in spite of Defendant’s attorney proving she had satisfactorily made all

her mortgage payments, and in spite of her attorney’s request for Litton to cancel the sale and

clean up their false credit reporting so Defendant could refinance. Litton’s stated reason was that

their client had “no incentive” because of the amount of equity Defendant had in her property.

LNV is now attempting to perpetrate its own fraud on Defendant in this new foreclosure action.

Beal Financial Corporation, Beal Service Corporation, Beal Bank SSB, Beal Bank USA and

hundreds of shell sham corporations created by D. Andrew Beal to shield him from personal

liability to the victims of his crimes; and designed to deceive the government and prevent

regulators and other government authorities from detecting his corrupt enterprise racketeering

activities. The Beal organization’s parts interact to produce a joint effect that is greater than the





sum of the parts acting alone. The illusion D. Andrew Beal creates of a division between his

many corporate entities is a willful deception.

A TRANSACTION WILLFULLY EXECUTED IN VIOLATION OF STATUE IS NOTENTITLED TO COURT PROTECTION OR SANCTION

Nevada statute bars a Nevada corporation from transacting business prior to its date of

incorporation and bars a Nevada corporation from engaging in any business activity without a

Nevada business license.

Defendant’s Exhibit D page 68 attached hereto is a certified copy of LNV’s Articles of

Incorporation obtained from the Nevada Secretary of State which shows that LNV was not

incorporated until March 17, 2008. LNV’s Articles of Incorporation state on page one (1) that it

is organized under the “General Corporation Law of the State of Nevada.” However NRS

78.020(2) states:

“No trust company, savings and loan association, thrift company or corporationorganized for the purpose of conducting a banking business may be organized under thischapter.”

LNV via its foreclosure complaint against Defendant is attempting to enforce a promissory note

to a mortgage contract via an assignment of deed of trust which was executed on March 10,

2008, seven (7) days prior to LNV’s legal existence as a corporate entity and prior to it acquiring

a Nevada business license.

Plaintiff LNV is in fact “organized for the purpose of conducting a banking business” dealing in

mortgages as evidenced by its own foreclosure complaint in the present case and in its

foreclosure complaints against the other LNV/MGC/Beal victims identified herein and in

Defendant’s Exhibit B.





Nevada Attorney General Opinion 709 (12-17-1948) states:

“Foreign trust company must qualify under banking law to deal in mortgages. Foreigntrust company, in order to buy, sell mortgages on real estate in Nevada, must qualifyunder banking laws rather than general corporation laws.”

Because LNV deals in mortgages it is required by Nevada statute to qualify under banking laws.

By incorporating LNV pursuant to NRS 78.020(2) D. Andrew Beal violated Nevada statues and

is operating LNV illegally.

LNV was illegally incorporated because its Articles of Incorporation fail to disclose its true

business purpose; which was most certainly known to its president and director, D. Andrew Beal.

The fact that D. Andrew Beal is the president and director of LNV is stated in the Nevada SOS

business details for LNV attached hereto as Exhibit E on page 78.

D. Andrew Beal’s deception about the true nature of his LNV Corporation’s business activities

was willful with intent to create a chain of shell corporations which he uses to shield himself

from personal liability for his unlawful activities.

D. Andrew Beal is also president, director and secretary of Beal Bank USA (the Nevada

corporate parent of LNV according to LNV’s Corporate Disclosure); D. Andrew Beal is the

president and director of Beal Nevada Corp.; D. Andrew Beal is the director of Beal Nevada

Service Corporation; D. Andrew Beal is the president and director of Beal Leasing Corporation;

and D. Andrew Beal is the president and director of Beal Savings Investment Corporation. None

of these Beal corporations are publically traded and all are fully controlled by D. Andrew Beal.





LNV Corporation is merely an “alter ego” for D. Andrew Beal. Beal’s other business entities he

incorporated in Nevada (see Exhibit E attached herein) are similarly “alter egos” for D. Andrew

Beal. NRS 78.747(3) states:

“The question of whether a stockholder, director or officer acts as the alter ego of acorporation must be determined by the court as a matter of law.”

LNV Corporation is according to LNV’s corporate disclosure wholly owned by Beal Bank USA,

which is wholly owned by Beal Financial Corporation, none of which are publically traded. In

fact Daniel Andrew “Andy” Beal aka D. Andrew Beal is the primary or sole “shareholder.”

D. Andrew Beal alone influences, governs and controls all these corporate entities and is fully

responsible for their corporate actions. LNV Corporation is inseparable from Beal Bank USA,

which is inseparable from Beal Financial Corporation; which are also all inseparable from Beal

Bank SSB; MGC Mortgage Inc.; LPP Mortgage LTD; CLMG Corporation, CXA Corporation;

and hundreds of other shell sham corporations created for D. Andrew Beal. A shell corporation is

a company which serves as a vehicle for business transactions without itself having any

significant assets or operations. A sham is a thing that is not what it is purported to be. It’s

something bogus or false.

These shell sham corporations owned by D. Andrew Beal, including LNV Corporation and MGC

commingle assets as evidenced by LNV/MGC/Beal victim Catherine Gebhardt’s six thousand

dollar ($6,000) cashier’s check made payable to MGC but paid to Beal Bank SSB on October 29,

2008. (See Defendant’s Exhibit C attached herein.) Not only did this check made payable to

MGC get paid into an account for Beal Bank SSB but MGC claimed this payment made by

Gebhardt was never received and MGC’s false claim as to its not receiving this check and other

checks Gebhardt paid to MGC was used as the basis for LNV to foreclose on Gebhardt’s





property. When LNV failed at foreclosure it brought a “breach of contract” suit against Gebhardt

in federal court. LNV Corporation v. Gebhardt, Case No. 3:12-CV-468-TAV-HBG, U.S. District

Court Eastern District of Tennessee at Knoxville.

Beal Bank SSB, a Texas corporation, is different from Beal Bank USA, a Nevada corporation.

As per LNV’s Corporate Statement Beal Bank USA is the parent corporation for Plaintiff LNV

but a Beal entity incorporated in Texas, Beal Bank SSB, received the funds from Gebhardt’s

cashier’s check made payable to MGC Mortgage; so the comingling of funds and assets is not

just between child and parent corporations.

There is no real separation between the various Beal corporations and each other or their owner,

D. Andrew Beal. This court can and should pursuant to NRS 78.747(3) find that Plaintiff LNV

Corporation is just a sham (i.e. D. Andrew Beal’s alter ego.) Another court has already

adjudicated similar facts specific to other Beal shell corporations and made conclusions that

these shell corporations were created as sham tax shelters. (See Southgate Master Fund, LLC v.

United States, 659 F. 3d 466 - Court of Appeals, 5th Circuit 2011 and Bemont Investments,

L.L.C. v. United States, 679 F.3d 339 (5th Cir. 2012).)

Beal’s shell corporations (including but not limited to LNV, MGC and LPP) are false fronts to

shield D. Andrew Beal from legal liability for his fraudulent and criminal activities. NRS

78.030(1) states:

“A person shall not establish a corporation for any illegal purpose or with the fraudulentintent to conceal any business activity, or lack thereof, from another person or agovernmental agency.”





The numerous consumer complaint letters written to the Texas Attorney General about Beal’s

MGC and attached as an exhibit it Defendant’s Notice of Related Cases shows that MGC is not a

“mortgage servicer” as it purports to be but that D. Andrew Beal incorporated MGC for the

purpose of putting homeowners into false defaults so Beal’s sham LNV or LPP can then

foreclosure using forged documents so that D. Andrew Beal can conceal these activities and his

personal proceeds derived from these activities from the government.

D. Andrew Beal uses his sham shell corporations to deprive citizens of the United States,

including Defendant, of their real property; their liberty to enjoy their real property or to make

beneficial financial decisions about their investment in their real property. D. Andrew Beal

conspires with others to deprive his targets/victims of their civil rights and their property under

color of law.

NRS 78.747(1) provides an exception for individual liability of a stockholder, director or officer

of a corporation when he acts as the alter ego of the corporation. NRS 78.747(2) states: “A

stockholder, director or officer acts as the alter ego of a corporation if:

(a) The corporation is influenced and governed by the stockholder, director or officer;

(b) There is such unity of interest and ownership that the corporation and thestockholder, director or officer are inseparable from each other; and

(c) Adherence to the corporate fiction of a separate entity would sanction fraud or promote a manifest injustice.”

LNV Corporation i.e. D. Andrew Beal appears to be operating a corrupt business enterprise

engaging in several racketeering activities as defined by 18 U.S. Code § 1961 et seq. and appears

to be using his enterprise of shell sham corporations to conspire with others to fraudulently

deprive Defendant and his other targets/victims of their civil right pursuant to 42 U.S. Code §





1985 et seq. and of their property in violation of their rights pursuant to the United States

Constitution.

D. Andrew Beal doesn’t want the targets of his crimes (Defendant and the other noticed related

LNV/MGC/Beal victims) to consolidate their cases and to show judges and other government

authorities their collective evidence of the criminality of his activities because this would

establish a pattern of racketeering activities as defined by 18 U.S. Code § 1961 et seq. that may

result in criminal charges. This is the reason he so vehemently fights discovery. Evidence from

all the LNV/MGC/Beal victims cases when added together constitute a pattern of criminal acts

extending over many years which when reviewed collectively demonstrate, at the very least, the

appearance that D. Andrew Beal is operating a corrupt enterprise and conspiring with others to

perpetrate a racketeering scheme and artifice to defraud and is engaged in monetary transactions

in property derived from specified unlawful activity pursuant to 18 U.S. Code § 1957; engaged

in mail fraud pursuant to 18 U.S. Code § 1341 (what Lorraine Brown was convicted of for

forging mortgage related documents and mailing them to county land recorders offices); engaged

in money laundering in violation of 18 U.S. Code § 1956; engaged in bribery of judges and

counsel for opposing parties pursuant to 18 U.S. Code § 201 (See LNV Corporation v. Gebhardt

on appeal as Case No. 14-5605 in the United States Court of Appeals for the Sixth Circuit;

Breitlings v. LNV ; Case No. 3:15-CV-00703, U.S. District Court for the Northern District of

Texas Dallas Division; and the bankruptcy case of Christopher and Marcia Swift Case No. 12-

35690 In the United States Bankruptcy Court for the Northern District of Illinois, Eastern

Division.) These are all “racketeering activities” as defined by 18 U.S. Code § 1961 et seq. A

criminal investigation is warranted.





Title 18 U.S.C. § 4 – Misprision of a Felony – states:

“Whoever, having knowledge of the actual commission of a felony cognizable by a courtof the United States, conceals and does not as soon as possible make known the same tosome judge or other person in civil or military authority under the United States, shall be

fined under this title or imprisoned not more than three years, or both.”

Defendant hereby informs the Honorable Judge Mosman that she and the other LNV/MGC/Beal

victims have knowledge of the actual commission of a felony cognizable by a court of the United

States specific to Plaintiff LNV and its owner D. Andrew Beal and LNV’s/Beal’s agents.

Defendant moves this court and Judge Mosman, if he hasn’t already done so, to report these

crimes to the FBI and to the United States Attorney General and to any other law enforcement

agency with authority to investigate these criminal activities pursuant to 18 U.S. Code § 4.

Defendant and the other LNV/MGC/Beal victims are not complaining about LNV and MGC

being “bad” companies; we are proving evidence to this court and to other courts that they are

part of a corrupt business enterprise controlled by D. Andrew Beal for his own personal gain and

engaged in “racketeering activities” as defined by 18 U.S. Code § 1961 et seq.

PLEADINGS OF PRO SE LITIGANTS HELD AT A LESS STRINGENT STANDARD

As a pro se litigant Defendant is disadvantaged in the discovery process because she doesn’t

have education in law and is learning as she goes. This is why the United States Supreme Court

has set precedence requiring courts to hold pleadings of the pro se litigant to a less stringent

standard. “Rule 8(f) provides that 'pleadings shall be so construed as to do substantial justice.'

We frequently have stated that pro se pleadings are to be given a liberal construction.” Estelle,

Corrections Director, et al. v. Gample 29 U.S. 97, 97 S. Ct. 285, 50 L. Ed. 2d 251.





Due to being pro se Defendant did not know it is not proper procedure to subpoena an opposing

party. Counsel for LNV has exhibited a hostile attitude towards Defendant and has on several

occasions taken advantage of her disadvantaged position as a pro se litigant and of her medical

condition to thwart her rights to due process. Defendant also knows because of her continuous

interactions with the other LNV/MGC/Beal victims (some who are represented by counsel) that

LNV and other Beal corporate entities ferociously fight discovery, and even when ordered by a

court to produce certain documents they fail to do so. This certainly gives the appearance that

they have something to hide. As a result Defendant hesitated in serving LNV subpoenas but in

the end decided she had no choice not knowing this was not proper procedure.

PRAYER

Defendant prays this Honorable Court orders LNV to produce its Nevada business license and its

agreement with GMAC-RFC through which it allegedly obtained the assignments of deed of

trust/mortgage (including those pertaining to Defendant’s and the other LNV/MGC/Beal victims’

properties) dated / executed on March 10, 2008 and endorsed by GMAC-RFC employees Betty

Wright, Michael Mead and Diane Meistad.

Respectfully Submitted,

_________________________________________Denise Subramaniam

/s/ Denise Subramaniam




CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the foregoing document was

served upon all counsel of record, pro-se parties and the United States Attorney General and the

Attorney General of the State of Oregon via the Court’s CM/ECF system, email, and/or regular

mail, and/or certified mail with return receipt requested.

U.S. Department of JusticeLoretta Lynch,U. S. Attorney General

950 Pennsylvania Avenue, NWWashington, DC 20530-0001202-514-2000

Gabrielle D. Richards | Perkins Coie LLP1120 NW Couch Street10th FloorPortland, Oregon 97209-4128D. +1.503.727.2255F. [email protected]

Respectfully Submitted,

_________________________________________Denise Subramaniam

Case 3:14-cv-01836-MO Document 89 Filed 09/02/15 of 93

s Denise Subramaniam

mailto:[email protected]





Defendant’ Motion to Consolidate Directly Related Cases Page 17 of 22

Exhibit A





Exhibit B




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PAID RECORDED - OAKlAtlO COUNTY

RUTH JOHHSOII.

CLERK/REGISTER

OF t<EEDS

Dated: 3/10/2008 CORPORATION ASSIGNMENT ofMORTGAGE

After Recording Return

to:

MGC Mortgage Inc

Document Control, Allison Martin

7195 Dallas Parkway

Plano, Texas 75024

RFC

Loan Nuinber:-ion7180

Seller Loan Number: 2006050 I 00428 l C.

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MIN: 100175200003079665 MERS Phone: 1-888-679-6377

FOR VALUE

RECEIVED,

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the undersigned hereby grants, assigns and transfers to

LNV Corporation

7195

Dallas

Parkway

Plano, Texas 75024

all beneficial interest under that certain Mortgage dated 9/25/2006 .

executed by MICHAEL SADLER .......

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MORTGAGE

AMOUNT: $145,000.00 o ..k-( ......_{ C . o . - ~ 1 / R.c.c.onl r

PROPERTY

ADDRESS: 17499 WEST THIRTEEN MILE ROAD SOUTHFIELD, Ml 48076

TOGETHER with the note or notes therein described or referred to, the money due and to become due thereon

with interest, and all rights accrued

or to

accrue under said Mortgage.

pIN # 9..'1-l).

-41 00}....

(MERS)Mortgage Electronic Registration Systems, Inc.'

/ )::3>

B Y ~

STATE

OF

COUNTY OF

Minnesota)

Hennepin)

NAME: Michael Mead '

TITLE: Assistant Vice President

On 3/10/2008 before me, the undersigned, a Notary Public in and for said State personally appeared Michael

Mead, Assistant Vice President of'(MERS) Mortgage Electronic Registration Systems, Inc.' personally known

to me

to

be the person whose name is subscribed

to

the within instrument and acknowledged to me that slhe

executed the same in his/her authorized capacity, and that by his/her signature on the instrument the entity upon

behalfof which the person acted, executed the instrument. WITNESS my hand and official seal.

Prepared 3/10/2008 by Diane Meistad, Residential

Funding Company, LLC, One Meridian Crossings,

Suite 100, Minneapolis, MN 55423, (952) 979-4000.

DIANE M. MEISTAO

NOTARY PUBLIC-MINNESOTA

IIJ CommllliCiflEqirlo JM.

31.2010

oJ .-LG

@





Exhibit C





Exhibit D





Exhibit E




y Details - Secretary of State, Nevada

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Business Entity Information

Status: Active File Date: 3/17/2008

Type: Domestic Corporation Entity Number: E0169702008-8

Qualifying State: NV List of Officers Due: 3/31/2016

Managed By: Expiration Date:

NV Business ID: NV20081614653 Business License Exp: 3/31/2016

Registered Agent Information

Name:THE CORPORATION TRUSTCOMPANY OF NEVADA

Address 1: 311 S DIVISION ST

Address 2: City: CARSON CITY

State: NV Zip Code: 89703

Phone: Fax:

Mailing Address 1: Mailing Address 2:

Mailing City: Mailing State: NV

Mailing Zip Code:

Agent Type: Commercial Registered Agent - Corporation

Jurisdiction: NEVADA Status: Active

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Financial Information

No Par Share Count: 0 Capital Amount: $ 100.00

Par Share Count: 10,000.00 Par Share Value: $ 0.01

Officers Include Inactive Officers

President - D ANDREW BEAL

Address 1: 7195 DALLAS PARKWAY Address 2:

City: PLANO State: TX

Zip Code: 75024 Country:

Status: Active Email:

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Director - D ANDREW BEAL





Secretary - TIM H TAYLOR





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Type: Domestic Corporation Entity Number: C19892-2004









Phone: Fax:



Mailing Zip Code:





No Par Share Count: 0 Capital Amount: $ 3,000,000.00

Par Share Count: 3,000,000.00 Par Share Value: $ 1.00


President - D. ANDREW BEAL

Address 1: 6000 LEGACY DR Address 2:


Zip Code: 75024 Country: USA





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Director - D. ANDREW BEAL





Secretary - D. ANDREW BEAL





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No Par Share Count: 0 Capital Amount: $ 1,000.00

Par Share Count: 1,000.00 Par Share Value: $ 1.00



Address 1: 6000 LEGACY DRIVE Address 2:







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Treasurer - JAMES W LEWIS JR










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Type: Foreign Corporation Entity Number: E0180652005-3

Qualifying State: TX List of Officers Due: 4/30/2016








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President - JACOB CHERNER





Treasurer - CRAIG SINGER










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Exhibit F


dc 89 denise's motion to compel lnv to produce

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