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UNITED STATES BANKRUPTCY COURTFOR THE WESTERN DISTRICT OF WISCONSIN

______________________________________________________________________________In Re the Bankruptcy ofSUZANNAH META SCHMID, Case No. 10-12142-tsu

Debtor______________________________________________________________________________

SECOND OBJECTION TO SECURED CLAIM #2-4 FILED BY BAC HOME LOANS SERVICING, LP,

N/K/A BANK OF AMERICA, SUCCESSOR BY MERGER______________________________________________________________________________

NOW COMES the Debtor, Suzannah Meta Schmid, by her attorney Wendy Alison Noraof ACCESS LEGAL SERVICES, respectfully objects to Claim #2-4 in these proceedings andshows the Court:

1. BAC HOME LOANS SERVICING, LP filed Claim #2-4 in these proceedings on July5, 2011.

2. Debtor stipulates that BANK OF AMERICA is the successor by merger with BACHOME LOANS SERVICING, INC. and that its counsel was in possession of the originalmortgage note signed by the Debtor on March 3, 2004 at the discovery conference between hercounsel and counsel for BANK OF AMERICA on or about August 2, 2011.

3. Attached to Claim 2-4 is a copy of the original mortgage note executed by the Debtorin favor of M&I Mortgage Corporation on March 3, 2004.

4. An allonge attached to the mortgage note was purportedly signed by one Lorann TenHaken, for M&I Mortgage Corporation as its Vice-President and purports to make the notepayable to Countrywide Document Custody Services, a Division of Treasury Bank, N.A. WithoutRecourse.

4. At some point in time thereafter, an endorsement was stamped on the allonge wherebythe mortgage note became stamped with a double signature rubber stamp which bears pre-stamped signatures of a Laurie Meder as Vice President which purports to make the mortgagenote payable from Countrywide Document Custody Services, a Division of Treasure Bank, NAto Countrywide Home Loans, Inc. Without Recourse and simultaneously endorses the instrumentin blank to by signature stamp of David A. Spector as Managing Director of Countrywide HomeLoans, Inc. to “anyone who takes this Note by transfer and who is entitled to receive paymentsunder this note . . . called the ‘Note Holder,’ according to the terms of the Debtor’s mortgagenote.

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5. Debtor’s counsel has recently discovered new evidence of the processes of documentcreation at the former Countrywide system of corporations, limited liability partnerships whichsit within each other like self-concealing nesting dolls, and based upon that new evidence, she isforced to make this second objection to the Claim 2-4. Hereafter, the term Countywide will beused to describe the corporate identity concealment scheme, except insofar as the name of thevarious entities are necessary to the factual statements herein.

6. Whereas Debtor’s counsel knew that Treasury Bank, N.A. no longer existed at thetime of the preliminary hearing on the Debtor’s first objection to the claim of BAC Home LoansServicing, LP (which itself came into being as a mere name change from Countrywide HomeLoans Servicing, LP filed with the Texas Secretary of State) the mortgage note, which wasproduced in discovery in these proceedings, facially appeared to be validly endorsed in blank,albeit with a double signature rubber stamp. Both counsel for Debtor and counsel for Bank ofAmerica believed that the use of the signature stamp was legally authorized.

7. On April 15, 2012, Debtor’s counsel was made aware of lack of corporate authorityand failure to secure lawful powers of attorney underlying in the production of documents usingthe double signature rubber stamps at the Countrywide facilities in California where LaurieMeder is employed through the deposition of Michele Sjolander, Vice President in the documentproduction department of the former Countrywide Home Loans Servicing, LP. (A copy of thatdeposition is attached hereto as Exhibit A.)

8. Debtor’s counsel was deceived into conceding that the mortgage note had beenendorsed with lawful authority because, at that time, neither she, nor counsel for Bank ofAmerica, could ever have imagined that the uncontrolled and unauthorized document stampingprocess was being operated in any financial institution anywhere.

9. Two lawful and valid documents are necessary to establish a secured claim forpayments in bankruptcy proceedings: a mortgage note representing the debt obligation and themortgage agreement representing the collateral given to secure the debt obligation.

10. There are two ways to prove a secured mortgage claim: (1) The secured creditor mustown both the mortgage note and be specifically named as the mortgagee in the mortgage or bethe lawful assignee of the mortgage or (2) the owner (lawful holder by transfer with enforcementrights) of the note can seek equitable assignment of the mortgage upon demonstration of thelawful transfer of the note.

11. Because the endorsement of the mortgage note was assumed to have been withlawful authority (who would assume otherwise?) Debtor’s counsel reluctantly agreed to file andserve an adversary proceeding against Associated Bank which filed Claim #1 in theseproceedings as a secured claim for payments of the second mortgage recorded on Debtor’shomestead.

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12. Nevertheless, Debtor’s counsel never waived Debtor’s objection to the validity ofthe assignment of mortgage from Treasury Bank, NA and Debtor’s first objection to Claim #2was dismissed without prejudice.

13. Attached to Claim #2-4 is a certified copy of the mortgage and certified copies pf two subsequent assignments of the mortgage which was executed by the Debtor on March 3,2004.

15. The first assignment of mortgage is dated March 3, 2004 and is signed by Lorann TenHaken, Vice President of M&I Mortgage Corporation, notarized by Mary Ann Sonnentag andpurports to assign the mortgage to Countrywide Document Custody Services, a Division ofTreasury Bank, N.A., identified on the face of the assignment as “a corporation organized andexisting under the laws of the State of New York.”

16. The assignment of mortgage dated March 3, 2004 and signed by Lorann J. TenHaken is notarized by Mary Ann Sonnentag, a Wisconsin notary.

17. Debtor’s mortgage was initially assigned by M&I Mortgage Corporation to an entity(Countrywide Document Custody Services, a Division of Treasury Bank, NA) which is not andnever has been a corporation organized under the laws of the State of New York. (See ExhibitsB and C.)

18. The first assignment of the mortgage was altered to refer to document number of thesimultaneously recorded original mortgage AFTER it was notarized. Note the hand-writtendocument number for the mortgage which was not recorded and did not receive a documentnumber until at least March 8, 2004, which is the date the mortgage was recorded.

19. It appears that the original assignment of mortgage is invalid as having been alteredafter it was notarized.

20. Having been assigned to a nonexistent entity (there was never a corporation calledCountywide Document Custody Services organized under the laws of the State of New York)and altered after it was executed in the presence of Wisconsin Notary Mary Ann Sonnentag, thefirst assignment of mortgage is invalid.

21. Although M&I Mortgage Corporation could theoretically correct the defects in thefirst assignment of mortgage if it still exists, but it does not, having been dissolved on December4, 2006 (See Exhibit D.)

22. Furthermore, a valid mortgage is of record in favor of Associated Bank, dated July29, 2005 and recorded on August 23, 2005 in the Office of the Portage County Register of Deedsas Document #77674 and, under Wisconsin’s race/notice recording law, the mortgage ofAssociated Bank takes priority over any later recording which might have been attempted to

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correct the invalid mortgage assignment.

WHEREFORE, the Debtor respectfully objects to Claim #2-4 of BAC Home LoansServicing, LP’s successor in interest by merger, Bank of America and asks that it be disallowed upon the grounds that

1. Debtor’s mortgage note has not been shown to have been lawfully endorsed by anindividual authorized by lawful resolution of the Boards of Directors of M&I MortgageCorporation;

2. Debtor’s mortgage was initially assigned to an entity (Countrywide DocumentCustody Services, a Division of Treasury Bank, NA) which is not and never has been acorporation organized under the laws of the State of New York;

3. The assignment of Debtor’s mortgage assignment which was altered to refer todocument number of the original mortgage AFTER it was notarized.

4. A double-rubber-stamp was placed upon Debtor’s mortgage note, bearing the pre-printed signatures of individuals who have which has not been shown to have been given signingauthority by the lawful resolution of Board of Directors of either Countrywide DocumentCustody Services as to Laurie Meder, Vice-President, or Countrywide Home Loans, Inc. as toDavid A. Spector, Managing Director;

5. There is no evidence that the individual who stamped the mortgage note wasauthorized to affix the stamp on the note, by power of attorney of Laura Meder and David A.Spector from both corporations for which the stamp purports to have been used and the evidenceis, in fact, otherwise: that signature stamps were being placed on mortgage notes without anyauthorization, quality control or supervision whatseover;

6. The mortgage was assigned to the current claimant from a division of Treasury Bank,N.A., an entity which ceased to exist before the mortgage was purportedly assigned and could nothave authorized the assignment; and/or

7. There never has been a corporation duly organized under the laws of the State of NewYork, by the name of Countrywide Document Custody Services.

8. All or most of the foregoing defects range from technical invalidity to fraud to forgeryand equitable assignment cannot be used to rubber stamp a claim based on invalid, false orfictitious documents.

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Dated at Minneapolis, Minnesota this 27 day of April, 2012.th

/s/ Wendy Alison Nora____________________________________

Wendy Alison NoraACCESS LEGAL SERVICES

210 Second Street NE Minneapolis, Minnesota 55413

VOICE (612) 333-4144FAX (612) 886-2444

accesslegalservices.bky@gmail.comWisconsin Attorney ID #1017043