Country Wide BofA Feb 2011 Complaint

8/7/2019 Country Wide BofA Feb 2011 Complaint

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COMPLAINT

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Philip A. Kramer SB# 113969Kramer & Kaslow23901 Calabasas Rd # 2010Calabasas, CA 91302-3307(818) 224-3900

Attorney for Plaintiffs

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF ORANGE

DANIEL MAXAM, an individual; CARAMCVEY, an individual; DANIELMELENDEZ, an individual; GERALDINEMOECKEL, an individual; EDGAR

MORALES, an individual; DINAHMOREAU, an individual; KEN MORRIS, anindividual; ALAN MOSLEY, an individual;SOSTENES MURGA, an individual; LEE E.NOBLE, an individual; JOSE NUNEZ, anindividual; DONALD OKADA, an individual;JESSE OSBORNE, an individual; LUISPAGES, an individual; MARCELINOPALISOC, an individual; CLAYTONPELLETIER, an individual; MITCHPERERIA, an individual; RICHARD

PILLSBURY, an individual; HAYDENPOGNI, an individual; ROGER PREBLE, anindividual; CARLOS QUINO, an individual;LORETTA RAYA, an individual; RHONDACHISHOLM, an individual; DANIELRICHARD, an individual; ROBERTGILBERT, an individual; AUDRARODRIGUEZ, an individual; CESARRODRIGUEZ, an individual; FRANKROPER, an individual; HOWARDROSENTHAL, an individual; ROGER

ROTTLER, an individual; ANGELASANCHEZ, an individual; SELINA WILDER,an individual; SHARON KING, an individual;JEREMY SHEAFFER, an individual; DEBRASIMPSON, an individual; NATHANSKIVER, an individual; GUILLERMOTABARES, an individual; STEPHENTEICHMAN, an individual; FATIMA

Case No.:

COMPLAINT FOR:

1. FRAUDULENT CONCEALMENT[VIOLATION OF CAL. CIVIL CODE 1572, 1709 AND 1710];

2. INTENTIONALMISREPRESENTATION[VIOLATION OF CAL. CIVIL CODE 1572, 1709 AND 1710];

3. NEGLIGENTMISREPRESENTATION[VIOLATION OF CAL. CIVIL CODE 1572, 1709 AND 1710];

4. INJUNCTIVE RELIEF FORVIOLATION OF CIVIL CODESECTION 2923.5;

5. UNFAIR COMPETITION[VIOLATIONS OF CAL. BUS. &PROF. CODE 17200 ET SEQ.]

[JURY TRIAL DEMANDED]

SummonsIssued

DEPT CX101


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TENDERRO, an individual; TISHARRASHREIBER, an individual; TODD GAGNON,an individual; JORGE TORRES, anindividual; HWANG TRAN, an individual;RONALD TURNER, an individual;

ROSEMARY TURNER, an individual; JOHNURTIAGA, an individual; THOMAS VANDUSEN, an individual; NELDA VARGAS, anindividual; LINDA VULAJ, an individual;RIK WAHLRAB, an individual; PHILIPWARMANEN, an individual; CHRISTIANWELLMAN, an individual; MARKWHITEHEAD, an individual; DARNELLWYRICK, an individual; ALEJANDROALARCON, an individual; JULIEANDERSON, an individual; LYNETTE

ASTORS, an individual; BRUCE BARRETT,an individual; BRANSTON BAUDER, anindividual; BRETT BORBA, an individual;BUNNY BOWERS, an individual; EDDIEBRANDES, an individual; ROY BREWER,an individual; BRAD J. BRITTON, anindividual; HENRY BURGESS, an individual;JOSE CABANAS, an individual; ELVIRACADENAS, an individual; MARIACAMARILLO, an individual; CHRISTINECARPENTER, an individual; ROBERTCASTORE, an individual; JAMES CHAFFIN,an individual; LISA DAGGS-CHARETTE, anindividual; CHRIS CLARK, an individual;CHRISTINE JI, an individual; MICHAELCOLLIGAN, an individual; SEANNACOLLIGAN, an individual; K.C.CRANDALL, an individual; ANTONIOCRUZ, an individual; COSME CRUZ, anindividual; TUAN HAI DANG, an individual;STEPHANIE DIAMOND, an individual;DANG DIEP, an individual; DOLORESSABLAN, an individual; ROBERT DUBOIS,an individual; TERRI EADENS, an individual;EDITHA RESTAURO, an individual; KIRAEDWARDS, an individual; EVELYNSISTRUNK, an individual; ROSIBELFADUL, an individual; ENIO FONTANELLI,an individual; DOUGLAS FORE, anindividual; WILLIAM FOSTER, an


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individual; TRINA FRAZIER, an individual;GENARO MENJIVAR, an individual;GEORGE OLSEN, an individual; PAULETTEOLSEN, an individual; GLEN LEMMON, anindividual; RICARDO GONZALEZ

TAFOLLA, an individual; LEOPOLDOGONZALEZ, an individual; STEPHANIEGOTTERO, an individual; KARLAGOULART, an individual; SALVADORGUTIERREZ, an individual; JACINTOGUZMAN, an individual; OFELIAHERNANDEZ, an individual; TIMOTHYINFANGER, an individual; BENJAMININGRAM, an individual; TAMMYJACKSON, an individual; LYNETTEJAMORA, an individual; MARIA JIMENEZ,

an individual; JOE BARELA, an individual;JOHN ALLEN, an individual; JOHNMORENO, an individual; LAVANCEJOHNSON, an individual; JOSEPHELONGE-FOBIA, an individual; NARINDERKAUR, an individual; KEITH COTANT, anindividual; KEVIN MCVEY, an individual;CHRISTINA KIM, an individual; JANEKOPECKY, an individual; JOSHUAKREITZER, an individual; JONATHANLANDES, an individual; ASHLEY LARSON,an individual; LEVON LATCHINIAN; anindividual; OLIVER LAZARO, an individual;DANIEL LERTIQUE, an individual; KERRIELLOYD, an individual; CYNTHIA LUNA, anindividual; LYN HENLEY, an individual;MADONA OANDASAN, an individual;JANA MALONE, an individual; PIERREMARCOTTE, an individual; MARLENEGONZALEZ, an individual; NAOMIMARTINSEN, an individual; MARVINMENDONCA, an individual; MAZIARABRISHAMIAN, an individual; JULIEBLACKLEY, an individual; DUANEBLEDSOE, an individual; MARK CAIRA, anindividual; DAVID DELGADO, anindividual; CLYDE DODSON, an individual;EVELYN HERRERA, an individual;BACHHONG KHONG, an individual; LOUIELEWIS, an individual; JOEL LIEBKE, an


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individual; LARRY LUNSFORD, anindividual; DARYL MCCANCE, anindividual; EDWARD SANCHEZ, anindividual; CONNIE SCHULENBERG, anindividual; RICHARD VAN DER WORP, an

individual; FRED WHITE, an individual;PETRE MILE, an individual; FRANZ BELL,an individual; TIMOTHY SMITH, anindividual; GILBERT SIGALA, an individual;ELENO DE LA CRUZ, an individual;NAOMI TROWER, an individual;SALVACION AQUINO, an individual;MANUEL ARECHIGA, an individual;AMRIK BAJWA, an individual; ROSARIOBARA, an individual; OLGA BARDALES, anindividual; GIL BECKENSTEIN, an

individual; RHONDA BOGGAN, anindividual; RANDY BROOKS, an individual;HAROLD BYRD, an individual; VITOCALABRESE, an individual; EVERADOCASTRO, an individual; FRANCISCOCEBALLOS, an individual; CYNTHIACHANG, an individual; ANJA CHRISTIE-JOHNSON, an individual; GRACIELACONTRERAS, an individual; ANIBALCORDERO, an individual; OTTO RENE DELEON, an individual; JOSE DELGADO, anindividual; ALICIA DIAZ, an individual;DAVID DILLON, an individual; JOHNDONAHUE, an individual; JULIO DORADO,an individual; TUONG DU, an individual;ELLA FERNANDEZ, an individual; DAWNLENTZ FLOWERS, an individual; CHRISTIEFRANZ, an individual; SUSANGALLAGHER, an individual; RUDYGARCIA, an individual; ADELA GARCIA,an individual; CINDY GEORGE, anindividual; JOERIN GEORGE, an individual;VLADIMIR GURLOR, an individual;RICHARD HALLEY, an individual;CYNTIHIA HALLEY, an individual;CARMELA HERBERT, an individual;CHONTIA HOLMES, an individual;DARRELL HOOVER, an individual;DONALD JENKS, an individual; SHELDONKAMEN, an individual; SHAWN


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KEEBAUGH, an individual; TAMMYKEMMERER, an individual; JANE KIM, anindividual; LOUIS KLEIN, an individual;GERALD KRAMER, an individual; JERRYLEE, an individual; BRIAN LOGAN, an

individual; RONNIE LYLES, an individual;PAUL MAILE, an individual; POLINAMANYIKA, an individual; HASMIKMEKHITARIA, an individual; DONYANNMORGAN, an individual; ROBERT MORSE,an individual; JOSEPH NUGENT, anindividual; DOUGLAS POWERS, anindividual; BETTE LOU PRENTICE, anindividual; DIONICIO QUINONEZ, anindividual; THERESA REAL, an individual;YEVETTE REEVES, an individual; DENISE

REGISTER, an individual; JOEY RIEDEL, anindividual; ENRIQUE ROMERO, anindividual; CONNIE ROOKER, an individual;RODNEY SADLER, an individual; HUGOSALAZAR, an individual; RUBENSANTIAGO, an individual; YADIRASANTILLAN, an individual; NAGINDERSINGH, an individual; JAMES SPELLER, anindividual; ANN TERRILL, an individual;WILLIAM THOMAS, an individual; HAI V.TRAN, an individual; SANDRA VALDEZ, anindividual; TANYA VEGA, an individual;GLENN WARNE, an individual; CHERYLWELCH, an individual; SCOTT WETZEL, anindividual; MICHAEL WIEDERHOLD, anindividual; BERNARDO ZAVALA, anindividual; JAMES PATE, an individual;ANGEL ARIAS, an individual; NEILWHITE, an individual; ACHINI WHITE, anindividual; and others similarly situated namedherein as ROES 1-1000, inclusive,

Plaintiffs,

vs.


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BANK OF AMERICA, N.A., a Delawarecorporation; COUNTRWIDE FINANCIALCORPORATION, a Delaware corporation,dba BAC HOME LOANS SERVICING;COUNTRYWIDE HOME LOANS, INC., a

New York corporation; RECONTRUSTCOMPANY, N.A., a California entity formunknown; CTC REAL ESTATE SERVICES,a California corporation; and DOES 1 through1000, inclusive.

Defendants.

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

INTRODUCTION AND BACKGROUND

OF THE MASTER SCHEME OF DECEPTION AND FRAUD

1. This lawsuit arises from: (1) Defendants deception in inducing Plaintiffs to enterinto mortgages from 2003 through 2008 with the Countrywide Defendants (defined below in

Paragraph 8); (2) Defendants breach of Plaintiffs Constitutionally and statutorily protected

rights of privacy; and (3) Defendants continuing tortious conduct intended to deprive Plaintiffs

of their rights and remedies for the foregoing acts, described below.

2. This action seeks remedies for the foregoing improper activities, including amassive fraud perpetrated upon Plaintiffs and other borrowers by the Countrywide Defendants

that devastated the values of their residences, in most cases resulting in Plaintiffs loss of all or

substantially all of their net worth.

3. Defendant Countrywide Financial Corporation (Countrywide) was among theleading providers of mortgages in California during all times relevant to this Complaint. By

2005, Countrywide was the largest U.S. mortgage lender in the United States, originating over

$490 billion in mortgage loans in 2005, over $450 billion in 2006, and over $408 billion in 2007.


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4. In 2007, Defendant Bank of America (BofA) commenced negotiations toacquire Countrywide. By late 2007, BofA began merging its operations with Countrywide and

adopting some of Countrywides practices. From and after its acquisition of Countrywide in July

2008 and continuing to the present, both as a successor in interest to Countrywide and as a

principal, BofA has engaged in and continued the wrongful conduct complained of herein.

5. The fraud perpetrated by the Countrywide Defendants from 2003 through 2007,including by BofA starting no later than 2007, was willful and pervasive. It begin with simple

greed and then accelerated when Countrywide founder and CEO Angelo Mozilo (Mozilo)

discovered that Countrywide could not sustain its business, unless it used its size and large

market share in California to systematically create false and inflated property appraisals

throughout California. Countrywide then used these false property valuations to induce

Plaintiffs and other borrowers into ever-larger loans on increasingly risky terms. As Mozilo

knew from no later than 2004, these loans were unsustainable for Countrywide and the

borrowers and to a certainty would result in a crash that would destroy the equity invested by

Plaintiffs and other Countrywide borrowers.

6. Hand-in-hand with its fraudulently-obtained mortgages, Mozilo and others atCountrywide hatched a plan to pool the foregoing mortgages and sell the pools for inflated

value. Rapidly, these two intertwined schemes grew into a brazen plan to disregard underwriting

standards and fraudulently inflate property values county-by-county, city-by-city, person-by-

person in order to take business from legitimate mortgage-providers, and moved on to massive

securities fraud hand-in-hand with concealment from, and deception of, Plaintiffs and other

mortgagees on an unprecedented scale.

7. From as early as 2004, Countrywides senior management led by Mozilo knewthe scheme would cause a liquidity crisis that would devastate Plaintiffs home values and networths. But, they did not care, because their plan was based on insider trading pumping for as

long as they could and then dumping before the truth came out and Plaintiffs losses were locked

in.

///


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8. At the very least, at the time of entering into the notes and deeds of trustreferenced herein with respect to each Plaintiff, Countrywide, each Defendant originating a

mortgage, each Defendant in the chain of title of the foregoing mortgages and each Defendant

servicing the foregoing mortgages and the successors to each of the foregoing (collectively, the

Countrywide Defendants) was bound and obligated to fully and accurately disclose to each

borrower, including each Plaintiff herein, that the mortgage being offered to the Plaintiff was, in

fact, part of a massive fraud that Countrywide knew would result in the loss of the equity

invested by Plaintiff in his home and in severe impairment to Plaintiffs credit rating.1

9. It is now all too clear that this was the ultimate high-stakes fraudulent investmentscheme of the last decade. Couched in banking and securities jargon, the deceptive gamble with

consumers primary assets their homes was nothing more than a financial fraud perpetrated

by Defendants and others on a scale never before seen. This scheme led directly to a mortgage

meltdown in California that was substantially worse than any economic problems facing the rest

of the United States. From 2008 to the present, Californians home values decreased by

considerably more than most other areas in the United States as a direct and proximate result of

the Defendants scheme set forth herein. The Countrywide Defendants business premise was to

leave the borrowers, including Plaintiffs, holding the bag once Countrywide and its executives

had cashed in reaping huge salaries and bonuses and selling Countrywides shares based on their

inside information, while investors were still buying the increasingly overpriced mortgage pools

and before the inevitable dnouement. This massive fraudulent scheme was a disaster both

foreseen by Countrywide and waiting to happen. Defendants knew it, and yet Defendants still

induced the Plaintiffs into their scheme without telling them.

10. As a result, Plaintiffs lost their equity in their homes, their credit ratings andhistories were damaged or destroyed, and Plaintiffs incurred material other costs and expenses,described herein. At the same time, Defendants took from Plaintiffs and other borrowers billions

///

1This Complaint uses "mortgage" and "deed of trust" interchangeably. Depending upon the state and other factors,

a loan may be secured by either form of security instrument, the deed of trust being the customary instrument inCalifornia.


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of dollars in interest payments and fees and generated billions of dollars in profits by selling their

loans at inflated values.

11. Like a drug that requires ever-higher doses to yield the same high, the fraudreached its zenith or its nadir when Countrywide systematically destroyed California home

values county-by-county and then State-wide.

12. Then, Defendants began to use their customers most private information for anextra edge. This use of private information violated the inalienable Constitutional rights

accorded to all California citizens. Defendants violations ranged from the disclosure of the

most private and confidential information of more than 2.4 million customers, to the outsourcing

and sale of hundreds of thousands of records to bolster their fraudulent scheme, disenfranchising

Californians of their Article I, 1 inalienable rights of privacy, that went far beyond the sale of

Private Information disclosed in the settlement of the Kentucky class action.

13. When Countrywide pooled the loans it originated and sold them in secondarymortgage market transactions, Countrywide recorded gains on the sales. In 2005, Countrywide

reported $451.6 million in pre-tax earnings from capital market sales; in 2006, it recognized

$553.5 million in pre-tax earnings from that activity. But, after the liquidity crisis hit, in 2007 it

recognized a mere $14.9 million in pre-tax earnings from that activity and reported an overall

pre-tax loss.

14. The foregoing events even to this day benefit the very people who were behindthe Countrywide fraud. For example, Stanford Kerlund, former president of Countrywide, left

Countrywide as the scheme was accelerating in late 2006. He then formed PennyMac, his

current business. PennyMac buys up the mortgages on which Plaintiffs and other Countrywide

borrowers defaulted at pennies on the dollar, repackages the mortgages and sells them for a

profit, thereby adding continued injury and profit to the original scheme. PennyMacs businessis supported and sanctioned by the Defendants herein.

15. The Defendants include some of our leading financial institutions institutions onwhich Plaintiffs thought they could rely, and did rely. But, they were wrong. As is clear from

the mounting number of federal and state enforcement actions against Defendants, it is now


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widely recognized that they engaged in reprehensible conduct with regard to their mortgage

business. Without limitation, the United States Securities and Exchange Commission (SEC)

charged Mozilo and other former senior officers of Countrywide with fraud for the securitization

counterpart of the fraud perpetrated on Plaintiffs; the SEC obtained a $150 million settlement

from BofA for fraud involving its acquisition of Merrill Lynch; the United States Federal Trade

Commission (FTC) obtained $108 million from two Countrywide mortgage servicing

companies to settle FTC charges that they collected excessive fees from cash-strapped borrowers

who were struggling to keep their homes; and New York commenced fraud proceedings against

the recently departed BofA CEO.

16. These acts continue to this day with hardball tactics and deception that continue tothreaten Plaintiffs Constitutional rights and financial security, as well as the economic future of

the State of California.

THE PARTIES

NAMED PLAINTIFFS

17. Plaintiff, DANIEL MAXAM, is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on his California real estate. At all material

times hereto, Countrywide has acted as Servicer or some other control capacity over processing

the loan.

18. Plaintiff ALEJANDRO ALARCON, is an individual residing in the State ofArizona, who borrowed money from Countrywide or its subsidiaries or affiliates between

January 1, 2003, and December 31, 2008, secured by a deed of trust on his Arizona real estate.

At all material times hereto, Countrywide has acted as Servicer or some other control capacityover processing the loan.

19. Plaintiff JULIE ANDERSON is an individual residing in the State of Oregon,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on her Oregon real estate. At all material


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the loan.

20. Plaintiff LYNETTE ASTORS is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on her California real estate. At all material


the loan.

21. Plaintiff BRUCE BARRETT is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

22. Plaintiff BRANSTON BAUDER is an individual residing in the State of Nevada,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on his Nevada real estate. At all material


the loan.

23. Plaintiff BRETT BORBA is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on his California real estate. At all material times

hereto, Countrywide has acted as Servicer or some other control capacity over processing the

loan.

24. Plaintiff BUNNY BOWERS is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,and December 31, 2008, secured by a deed of trust on her California real estate. At all material

times hereto, Countrywide acted as Servicer or some other control capacity over processing the

loan.

///


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25. Plaintiff EDDIE BRANDES is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,


times hereto, Countrywide acted as Servicer or some other control capacity over processing the

loan.

26. Plaintiff ROY BREWER is an individual residing in the State of Florida, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on his Florida real estate. At all material times


loan.

27. Plaintiff BRAD J. BRITTON is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

28. Plaintiff HENRY BURGESS is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

29. Plaintiff JOSE CABANAS is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,


times hereto, Countrywide has acted as Servicer or some other control capacity over processingthe loan.

30. Plaintiff ELVIRA CADENAS is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



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the loan.

31. Plaintiff MARIA CAMARILLO is an individual residing in the State of Arizona,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

32. Plaintiff CHRISTINE CARPENTER is an individual residing in the State ofWashington, who borrowed money from Countrywide or its subsidiaries or affiliates between

January 1, 2003, and December 31, 2008, secured by a deed of trust on her Washington real

estate. At all material times hereto, Countrywide has acted as Servicer or some other control

capacity over processing the loan.

33. Plaintiff ROBERT CASTORE is an individual residing in the State of RhodeIsland, who borrowed money from Countrywide or its subsidiaries or affiliates between January

1, 2003, and December 31, 2008, secured by a deed of trust on his Rhode Island real estate. At

all material times hereto, Countrywide has acted as Servicer or some other control capacity over

processing the loan.

34. Plaintiff JAMES CHAFFIN is an individual residing in the State of Ohio, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on his Ohio real estate. At all material times


loan.

35. Plaintiff LISA DAGGS-CHARETTE is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates betweenJanuary 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate.

At all material times hereto, Countrywide has acted as Servicer or some other control capacity

over processing the loan.

///


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36. Plaintiff CHRIS CLARK is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



loan.

37. Plaintiff CHRISTINE JI is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on her California real estate. At all material times


loan.

38. Plaintiffs SEANNA COLLIGAN and MICHAEL COLLIGAN, are individuals,wife and husband, residing in the State of Colorado, who borrowed money from Countrywide or

its subsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed

of trust on their Colorado real estate. At all material times hereto, Countrywide has acted as

Servicer or some other control capacity over processing the loan.

39. Plaintiff K.C. CRANDALL is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

40. Plaintiff ANTONIO CRUZ is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



41. Plaintiff COSME CRUZ is an individual residing in the State of Illinois, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on his Illinois real estate. At all material times


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loan.

42. Plaintiff TUAN HAI DANG is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

43. Plaintiff STEPHANIE DIAMOND is an individual residing in the State of Utah,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on her Utah real estate. At all material times


loan.

44. Plaintiff DIEP DANG is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



loan.

45. Plaintiff DOLORES SABLAN is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

46. Plaintiff ROBERT DUBOIS is an individual residing in the State of Colorado,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,and December 31, 2008, secured by a deed of trust on his Colorado real estate. At all material


the loan.

///


16/95

- 16 -

COMPLAINT

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47. Plaintiff TERRI EADENS is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



loan.

48. Plaintiff EDITHA RESTAURO is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between

January 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate.



49. Plaintiff KIRA EDWARDS is an individual residing in the State of Idaho, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on her Idaho real estate. At all material times


loan.

50. Plaintiff EVELYN SISTRUNK is an individual residing in the State ofPennsylvania, who borrowed money from Countrywide or its subsidiaries or affiliates between

January 1, 2003, and December 31, 2008, secured by a deed of trust on her Pennsylvania real



51. Plaintiff ROSIBEL FADUL is an individual residing in the State of Florida, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on hER Florida real estate. At all material times

hereto, Countrywide has acted as Servicer or some other control capacity over processing theloan.

52. Plaintiff ENIO FONTANELLI is an individual residing in the State of Florida,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on his Florida real estate. At all material


17/95

- 17 -

COMPLAINT

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

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20

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2425

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28


the loan.

53. Plaintiff DOUGLAS FORE is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

54. Plaintiff WILLIAM FOSTER is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

55. Plaintiff TRINA FRAZIER is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

56. Plaintiff GENARO MENJIVAR is an individual residing in the State of Utah,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on his Utah real estate. At all material times


loan.

57. Plaintiffs GEORGE OLSEN and PAULETTE OLSEN are individuals, husbandand wife, residing in the State of Arizona, who borrowed money from Countrywide or itssubsidiaries or affiliates between January 1, 2003, and December 31, 2008, secured by a deed of

trust on their Arizona real estate. At all material times hereto, Countrywide has acted as Servicer

or some other control capacity over processing the loan.

///


18/95

- 18 -

COMPLAINT

1

2

3

4

5

6

7

8

9

10

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12

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21

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28

58. Plaintiff GLEN LEMMON is an individual residing in the State of Utah, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on his Utah real estate. At all material times


loan.

59. Plaintiff RICARDO GONZALES TAFOLLA is an individual residing in the Stateof California, who borrowed money from Countrywide or its subsidiaries or affiliates between

January 1, 2003, and December 31, 2008, secured by a deed of trust on his California real estate.



60. Plaintiff LEOPOLDO GONZALEZ is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




61. Plaintiff STEPHANIE GOTTERO is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




62. Plaintiff KARLA GOULART is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



63. Plaintiff SALVADOR GUTIERREZ is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between



19/95

- 19 -

COMPLAINT

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3

4

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7

8

9

10

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21

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23

2425

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27

28



64. Plaintiff JACINTO GUZMAN is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

65. Plaintiff OFELIA HERNANDEZ is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




66. Plaintiff TIMOTHY INFANGER is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




67. Plaintiff BENJAMIN INGRAM is an individual residing in the State ofWashington, who borrowed money from Countrywide or its subsidiaries or affiliates between

January 1, 2003, and December 31, 2008, secured by a deed of trust on his Washington real



68. Plaintiff TAMMY JACKSON is an individual residing in the State of Florida,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,and December 31, 2008, secured by a deed of trust on her Florida real estate. At all material


the loan.

///


20/95

- 20 -

COMPLAINT

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

2425

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27

28

69. Plaintiff LYNETTE JAMORA is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

70. Plaintiff MARIA JIMENEZ is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

71. Plaintiff JOE BARELA is an individual residing in the State of New Mexico, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on his New Mexico real estate. At all material


the loan.

72. Plaintiff JOHN ALLEN is an individual residing in the State of Arizona, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on his Arizona real estate. At all material times


loan.

73. Plaintiff JOHN MORENO is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



74. Plaintiff LAVANCE JOHNSON is an individual residing in the State of Virginia,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on his Virginia real estate. At all material


21/95

- 21 -

COMPLAINT

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2

3

4

5

6

7

8

9

10

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20

21

22

23

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27

28


the loan.

75. Plaintiff JOSEPH ELONGE-FOBIA is an individual residing in the State ofArizona, who borrowed money from Countrywide or its subsidiaries or affiliates between

January 1, 2003, and December 31, 2008, secured by a deed of trust on his Arizona real estate.



76. Plaintiff NARINDER KAUR is an individual residing in the State of Washington,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on her Washington real estate. At all material


the loan.

77. Plaintiff KEITH COTANT is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

78. Plaintiff KEVIN MCVEY is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



loan.

79. Plaintiff CHRISTINA KIM is an individual residing in the State of Nevada, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, andDecember 31, 2008, secured by a deed of trust on her Nevada real estate. At all material times


loan.

///


22/95

- 22 -

COMPLAINT

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

2425

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27

28

80. Plaintiff JANE KOPECKY is an individual residing in the State of Illinois, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on her Illinois real estate. At all material times


loan.

81. Plaintiff JOSHUA KREITZER is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

82. Plaintiff JONATHAN LANDES is an individual residing in the State of Oregon,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on his Oregon real estate. At all material


the loan.

83. Plaintiff ASHLEY LARSEN is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

84. Plaintiff LEVON LATCHINIAN is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between



85. Plaintiff OLIVER LAZARO is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



23/95

- 23 -

COMPLAINT

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the loan.

86. Plaintiff DANIEL LERTIQUE is an individual residing in the State of Arizona,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on his Arizona real estate. At all material


the loan.

87. Plaintiff KERRIE LLOYD is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

88. Plaintiff CYNTHIA LUNA is an individual residing in the State of New Mexico,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on her New Mexico real estate. At all

material times hereto, Countrywide has acted as Servicer or some other control capacity over


89. Plaintiff LYN HENLEY is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



loan.

90. Plaintiff MADONA OANDASAN is an individual residing in the State of Hawaii,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,and December 31, 2008, secured by a deed of trust on her Hawaii real estate. At all material


the loan.

///


24/95

- 24 -

COMPLAINT

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7

8

9

10

11

12

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14

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21

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91. Plaintiff JANA MALONE is an individual residing in the State of Arizona, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on her Arizona real estate. At all material times


loan.

92. Plaintiff PIERRE MARCOTTE is an individual residing in the State of Michigan,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on his Michigan real estate. At all material


the loan.

93. Plaintiff MARLENE GONZALEZ is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between

January 1, 2003, and December 31, 2008, secured by deeds of trust on her California real estate.


over processing these loans.

94. Plaintiff NAOMI MARTINSEN is an individual residing in the State of Utah,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on her Utah real estate. At all material times


loan.

95. Plaintiff MARVIN MENDONCA is an individual residing in the State of Nevada,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



96. Plaintiff CARA MCVEY is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



25/95

- 25 -

COMPLAINT

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loan.

97. Plaintiff DANIEL MELENDEZ is an individual residing in the State of Oregon,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on his Oregon real estate. At all material


the loan.

98. Plaintiff GERALDINE MOECKEL is an individual residing in the State ofArizona, who borrowed money from Countrywide or its subsidiaries or affiliates between

January 1, 2003, and December 31, 2008, secured by a deed of trust on her Arizona real estate.



99. Plaintiff EDGAR MORALES is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

100. Plaintiff DINA MOREAU is an individual residing in the State of Arizona, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003 and

December 31, 2008, secured by a deed of trust on her Arizona real estate. At all material times


loan.

101. Plaintiff KEN MORRIS is an individual residing in the State of Kansas, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, andDecember 31, 2008, secured by a deed of trust on his Kansas real estate. At all material times


loan.

///


26/95

- 26 -

COMPLAINT

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9

10

11

12

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102. Plaintiff ALAN MOSLEY is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by deeds of trust on his California real estate. At all material times

hereto, Countrywide has acted as Servicer or some other control capacity over processing these

loans.

103. Plaintiff SOSTENES MURGA is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

104. Plaintiff NOBLE E. LEE is an individual residing in the State of Washington,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by deeds of trust on his Washington real estate. At all material


these loans.

105. Plaintiff JOSE NUNEZ is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



loan.

106. Plaintiff DONALD OKADA is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



107. Plaintiff JESSE OSBORNE is an individual residing in the State of Arizona, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on his Arizona real estate. At all material times


27/95

- 27 -

COMPLAINT

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3

4

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7

8

9

10

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12

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14

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20

21

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27

28


loan.

108. Plaintiff LUIS PAGES is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



loan.

109. Plaintiff MARCELINO PALISOC is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




110. Plaintiff CLAYTON PELLETIER is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




111. Plaintiff MITCH PERERIA is an individual residing in the State of Nevada, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on his Nevada real estate. At all material times


loan.

112. Plaintiff RICHARD PILLSBURY is an individual residing in the State of Oregon,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,and December 31, 2008, secured by a deed of trust on his Oregon real estate. At all material


the loan.

///


28/95

- 28 -

COMPLAINT

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7

8

9

10

11

12

13

14

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16

17

18

19

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21

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28

113. Plaintiff HAYDEN POGNI is an individual residing in the State of Hawaii, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on his Hawaii real estate. At all material times


loan.

114. Plaintiff ROGER PREBLE is an individual residing in the State of Utah, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on his Utah real estate. At all material times


loan.

115. Plaintiff CARLOS QUINO is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

116. Plaintiff LORETTA RAYA is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

117. Plaintiff RHONDA CHISHOLM is an individual residing in the State of Nevada,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on her Nevada real estate. At all material


118. Plaintiff DANIEL RICHARD is an individual residing in the State of Nevada,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



29/95

- 29 -

COMPLAINT

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7

8

9

10

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20

21

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2425

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28


the loan.

119. Plaintiff ROBERT GILBERT is an individual residing in the State of Montana,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on his Montana real estate. At all material


the loan.

120. Plaintiff AUDRA RODRIGUEZ is an individual residing in the State of Virginia,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on her Virginia real estate. At all material


the loan.

121. Plaintiff CESAR RODRIGUEZ is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




122. Plaintiff FRANK ROPER is an individual residing in the State of Massachusetts,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on his Massachusetts real estate. At all

material times hereto, Countrywide has acted as Servicer or some other control capacity over


123. Plaintiff HOWARD ROSENTHAL is an individual residing in the State ofMaryland, who borrowed money from Countrywide or its subsidiaries or affiliates betweenJanuary 1, 2003, and December 31, 2008, secured by a deed of trust on his Maryland real estate.



///


30/95

- 30 -

COMPLAINT

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2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

2425

26

27

28

124. Plaintiff ROGER ROTTLER is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

125. Plaintiff ANGELA SANCHEZ is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

126. Plaintiff SELINA WILDER is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

127. Plaintiff SHARON KING is an individual residing in the State of Washington,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on her Washington real estate. At all material


the loan.

128. Plaintiff JEREMY SHEAFFER is an individual residing in the State of Virginia,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by a deed of trust on his Virginia real estate. At all material


129. Plaintiff DEBRA SIMPSON is an individual residing in the State of Nevada, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on her Nevada real estate. At all material times


31/95

- 31 -

COMPLAINT

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

2425

26

27

28


loan.

130. Plaintiff NATHAN SKIVER is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

131. Plaintiff GUILLERMO TABARES is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




132. Plaintiff STEPHEN TEICHMAN is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




133. Plaintiff FATIMA TENDERRO is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




134. Plaintiff TISHARRA SHREIBER is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates betweenJanuary 1, 2003, and December 31, 2008, secured by a deed of trust on her California real estate.



///


32/95

- 32 -

COMPLAINT

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2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

2425

26

27

28

135. Plaintiff TODD GAGNON is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

136. Plaintiff JORGE TORRES is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



loan.

137. Plaintiff HWANG TRAN is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



loan.

138. Plaintiff RONALD TURNER is an individual residing in the State of Illinois, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on his Illinois real estate. At all material times


loan.

139. Plaintiff ROSEMARY TURNER is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between



140. Plaintiff JOHN URTIAGA is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



33/95

- 33 -

COMPLAINT

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

2425

26

27

28


the loan.

141. Plaintiff THOMAS VAN DUSEN is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




142. Plaintiff NELDA VARGAS is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

143. Plaintiff LINDA VULAJ is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



loan.

144. Plaintiff RIK WAHLRAB is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



loan.

145. Plaintiff PHILIP WARMANEN is an individual residing in the State of Florida,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,and December 31, 2008, secured by a deed of trust on his Florida real estate. At all material


the loan.

///


34/95

- 34 -

COMPLAINT

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

2425

26

27

28

146. Plaintiff CHRISTIAN WELLMAN is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




147. Plaintiff MARK WHITEHEAD is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




148. Plaintiff DARNELL WYRICK is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,

and December 31, 2008, secured by deeds of trust on his California real estate. At all material


these loans.

149. Plaintiff MAZIAR ABRISHAMIAN is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




150. Plaintiff JULIE BLACKLEY is an individual residing in the State of Utah, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



151. Plaintiff DUANE BLEDSOE is an individual residing in the State of Nevada,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



35/95

- 35 -

COMPLAINT

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

2425

26

27

28


the loan.

152. Plaintiff MARK CAIRA is an individual residing in the State of Massachusetts,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

153. Plaintiff DAVID DELGADO is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

154. Plaintiff CLYDE DODSON is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

155. Plaintiff EVELYN HERRERA is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

156. Plaintiff BACHHONG KHONG is an individual residing in the State of Nevada,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,and December 31, 2008, secured by a deed of trust on his California real estate. At all material


the loan.

///


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157. Plaintiff LOUIE LEWIS is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and



loan.

158. Plaintiff JOEL LIEBKE is an individual residing in the State of California, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by deeds of trust on his California real estate. At all material times

hereto, Countrywide has acted as Servicer or some other control capacity over processing these

loans.

159. Plaintiff LARRY LUNSFORD is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

160. Plaintiff DARYL MCCANCE is an individual residing in the State of California,who borrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003,



the loan.

161. Plaintiff EDWARD SANCHEZ is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between



162. Plaintiff CONNIE SCHULENBERG is an individual residing in the State ofWisconsin, who borrowed money from Countrywide or its subsidiaries or affiliates between

January 1, 2003, and December 31, 2008, secured by a deed of trust on her Wisconsin real estate.


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163. Plaintiff RICHARD VAN DER WORP is an individual residing in the State ofCalifornia, who borrowed money from Countrywide or its subsidiaries or affiliates between




164. Plaintiff FRED WHITE is an individual residing in the State of Colorado, whoborrowed money from Countrywide or its subsidiaries or affiliates between January 1, 2003, and

December 31, 2008, secured by a deed of trust on his Colorado real estate. At all materia

Documents

Country Wide BofA Feb 2011 Complaint