GMAC Mortgage LLC ruin my credit, prevented me from getting a job causing me to go into foreclosure

8/14/2019 GMAC Mortgage LLC ruin my credit, prevented me from getting a job causing me to go into foreclosure

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

DIVISION OF SAN JOSE

SYLVIA JONES,

Plaintiff,

vs.

MORTGAGEIT et. al.,; GMAC MORTGAGELLC et. al., AND DEBRA ROSENSTIEN et.al.,

Defendant,

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Case No.:

CIVIL ACTION

DEMAND FOR JURY TRIAL

COMPLAINT

Sylvia Jones (hereinafter Plaintiff) is the legal title holder and owner of the property located at

1057 Delna Manor Ln, San Jose, California. In April 2006 Plaintiff obtained a first and second

loan to purchase her property. The loans were obtained from MortgageIT Inc. ( hereinafter

MIT) The loans financing was a 100% that consisted of a 80% first in the amount of

$371,200 and a 20% second loan in the amount of $92,800. The total amount of credit extendedto Plaintiff from MIT was in the amount of $464,000. MIT transferred the servicing rights for

the first loan to GMAC Mortgage LLC (hereinafter GMACM) on July 14, 2006. The servicing

right for the second loan was transferred on July 3, 2006 to Select Portfolio Service (hereinafter

SPS). Upon information and belief, Plaintiff alleges that all the Defendants are responsible

for the wrongfulacts alleged herein and are responsible for the injuries and damages caused to

Plaintiff.

JURISDICTION

Pursuant to 28 U.S.C. 1331 and 28 U.S.C. 1332 , this court has subject matter jurisdiction in

the form of a federal question and/or diversity jurisdiction. Plaintiffs damages exceed the

$75,000.00 jurisdictional minimal required by this Court.

COMPLAINT FOR DAMAGES - 1-


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VENUE

Venue is appropriate in this court because all of the Defendants reside outside this district, and

a substantial amount of the acts and omissions giving rise to this lawsuit occurred in this district.

Defendants MIT, GMACM, and DEBRA ROSENSTIEN (hereinafter ROSENSTEIN)conducted and engaged in substantial, systematic, and continuous business activities herein

California.

INTRADISTRICT ASSIGNMENT

This lawsuit should be assigned to the San Jose Division of this Court because a substantial part

of the events or omissions which give rise to this lawsuit occurred in Santa Clara County.

PARTIES

Defendant, MORTGAGEIT INC. is a foreign corporation organized and existing under the laws

of the State of New York with its principal place of business being in State of New York,

and regularly conducted, continues to conduct business, and at all times relevant hereto,

regularly conducted business, in California.

Defendant, GMAC MORTGAGE LLC is a foreign corporation organized and existing underthe laws of the State of Delaware with its principal place of business being in the State of

Delaware. GMACM conducted, continues to conduct, and at all times relevant hereto,

regularly conducted business in California.

Defendant, DEBRA ROSENSTEIN, is an authorized agent and employee for GMACM at their

office located at 100 Witmer Road, Horsham, PA 19044 a foreign corporation which

conducts business, and at all times relevant hereto, regularly conducted business, in

California.

Sylvia Jones is a homeowner who resides in San Jose, California and whos property is located

at 1057 Delna Manor Ln, San Jose, CA 95128



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FACTUAL BACKGROUND

Plaintiff purchased her very first home in April of 2006. Plaintiff obtained 100%financing from MIT. MIT transferred the servicing rights to both Plaintiffs loans shortly after

the loan closed escrow. The first loans servicing rights were transferred to GMACM beginning

on July 14, 2006. Servicing rights to the second loan was transferred to SPS on July 3, 2006.

Plaintiff made all of her mortgage payments to the new servicers via cashier checks pursuant to

the terms of the mortgage contract before the 15 day grace as stated on page three (3), item 7(A).

(see attached exhibit A)

Plaintiff intended to refinance her home after six (6) months of ownership so that she

could lower her interest rate and access the equity in her home . The Plaintiff began the refinance

process in October of 2006. Interstate Financial was Plaintiffs employer and brokered the

original loan to MIT.

Interstate Financial pulled Plaintiffs credit report through Land America INFO1

(hereinafter INFO1) on October 17, 2006. The credit report showed Plaintiffs first loan,

which was being serviced by GMACM, had not been reported to any of the credit reporting

agencies (hereinafter CRAs). However, SPS had reported the second loan which it was

servicing.

The credit report also showed that Plaintiff whose original credit score as of April 2006

was 683 had decreased to 622 a drop of61 points. Plaintiff had not incurred any additional

debt obligation from April through October which could have justified the 61 point drop in

Plaintiffs credit score.

Plaintiff contacted INFO1 and spoke to Sandra and asked her to take a look at Plaintiffs

credit report to try and determine the cause for the drastic drop in Plaintiffs credit score. Sandra

stated to Plaintiff the reason that her credit score had dropped was because the first mortgage

loan had not been reported to the CRAs. Sandra advised Plaintiff to contact the loan servicing

company and ask them to report her payment history. Sandra assured Plaintiff that once they

report her mortgage her credit score would increase well over 720.

Plaintiff contacted GMACM on October 17, 2006 and spoke to a customer service

representative named Zabby. Zabby insured Plaintiff that he would put a rush on her request to



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report her mortgage and he was sending an email to the department in charge of reporting to the

CRAs. Zabby also stated to Plaintiff she would receive a return call from the Credit Reporting

Department by 4:00 p.m. that afternoon. Plaintiff did not received a return phone call from

GMACM that afternoon., so Plaintiff placed another phone call to GMACM and spoke to

another customer service representative shortly after 4:00 p.m..

This employee stated Zabby had provided the Plaintiff with incorrect information. She

stated that even if a mortgagor requested expedited reporting, GMACM would take up to at least

4 to 6 weeks to report to the CRAs and that it was their companys policy. Plaintiff asked to

speak to a supervisor. Plaintiff spoke to a gentleman named Robert (employee number 85062)

who identified himself as a customer service supervisor. Robert stated that as per the Real Estate

Settlement Procedure Act (hereinafter RESPA) GMACM did not have to report a mortgage

payment history with the CRAs until it had serviced the loan for a period of60 days.

He further explained that GMACM had only began servicing Plaintiffs loan on July 14,

2006 and therefore it was not going to and not required to report her loan until November 2006.

Plaintiff stated that if RESPA required a loan servicer to report the mortgage, after 60 days of

servicing a loan then Plaintiffs mortgage should have been reported in October 2006 if

servicing started on July 14, 2006. Roberts response was that RESPA and GMACMs policy

requires that they report to the CRAs in November of 2006 and they would not report her

mortgage until then and he abruptly ended the conversation.

Plaintiff contacted the Department of Corporation and filed a complaint. Plaintiff also

sent three (3) qualified written request (hereinafter QWR) to GMACM asking specifically for

the Defendant to report her mortgage payment history, so she could refinance her property.

GMACM never responded to Plaintiffs three (3) QWR. Plaintiff received a letter from

GMACMs authorized agent, Debra Rosenstein (hereinafter Rosenstein). Her letter stated that

it was GMACMs policy to report Plaintiffs mortgage in November to insure there would no

errors and inaccurate information furnished to the CRAs. Shortly after receiving the letter from

Rosenstein Plaintiff began getting harassing phone calls from GMACM stating that her

mortgage payments were late. Plaintiff repeatedly explained to GMACMs telephone

representative that she was current on her mortgage payments and requested that the employee

review her payment history and stop the harassing calls. The live calls stop, but then Plaintiff

began receiving systematic automated calls claiming she was late. Plaintiff again called



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GMACM asked them to remove her from the automated call system. The annoying calls finally

stopped.

Plaintiff assumed she would be able to refinance her property in November 2006 and

opened an escrow account with title officer, Denise Perrucci, who worked for Financial Title.

Mrs. Perrucci ordered the payoff demand and faxed Plaintiff a copy. The payoff demand

indicated that Plaintiff owed a late fee. Plaintiff and Mrs. Perrucci contacted GMACM via a

conference call to dispute the validity of the alleged late fee. Mrs. Perrucci asked which month

was the late fee owed because according to Plaintiffs documents she is current. GMACM stated

it had reviewed the account and didnt see any late fees and stated that until her new loan closes

she owed and would be charged a upfront late fee. Mrs. Perrucci stated to GMACM that they

could not charge a upfront late fee because the payoff demand instructions state that if the loan

closes after the 15th day of the month Plaintiff would be charged a daily per diem interest late fee

up to the time the loan closes. Mrs. Perrucci requested GMACM send her amended title

instructions with the unwarranted upfront late fee removed. GMACM refused to remove the late

fee. Plaintiff had INFO1 verify her mortgage with GMACM and she also ordered a copy of her

payment history from GMACM. Both of the requested documents indicated that the Plaintiff

had been current with all of her payments as of date during the time which GMACM had

serviced her loan. Plaintiff learned after sending letters to the CRAs in November 2006 that

GMACM had still not reported her mortgage in November 2006. Plaintiff then sent GMACM a

complaint letter attaching the responses she had received from the CRAs. GMACM responded

by letter dated December 3,2006 that stated it had reported her mortgage in December. Plaintiff

had her credit report pulled in December 2006 and learned that GMACM had reported to the

CRAs. She also learned that GMACM reported false, inaccurate, and misleading information to

the CRAs. After GMACMs December reporting to the CRAs Plaintiffs credit score dropped to

602. As a direct result of GMACMs failure to timely report the Plaintiffs excellent payment

history in October of 2006 Plaintiffs credit was seriously impaired. Whereas; from the time

GMACM did not report to the time they finally did report the inaccurate mortgage payment

history her credit score dropped a total of 81 points.

MIT contributed to the demise of the Plaintiffs credit reputation and the delay in her

refinancing by transferring her loan to a new servicer Americas servicing company directly

after GMACMs inaccurate reporting in December 2006. MITs action compounded with



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GMACMs negligence caused Plaintiff to have to wait another 60 days before the new servicer

would report her mortgage history.

Plaintiff is a subscriber to a credit service company that monitors any activity on her

credit. Plaintiff received a alert on August 8, 2008 GMACM had accessed her credit, without her

written authorization and furnished additional inaccurate, false and misleading information to the

CRAs about her mortgage payment history. GMACM no longer serviced Plaintiffs loan as of

December 2006 whereby accessing her credit without written authorization is a violation of the

consumer protection laws.

COUNT ONE

FALSE LIGHT

(Against all Defendants)

Plaintiff re-alleges and reincorporates each and every allegation contained in the GeneralAllegations and all previous paragraphs of all previous sections and Causes of Action in this

Complaint, inclusive, as though fully set forth herein.

1. The Defendants furnished inaccurate information to the three major credit reporting

agency as follows: Trans Union, Experian and Equifax ( hereinafter CRA).

Defendants knowingly submitted false and inaccurate information which did not

reflect the Plaintiffs true and factual mortgage credit history. Defendants knew or

should have known that their willful misrepresentation to the CRAs would have an

adverse effect on Plaintiffs credit rating, destroy her ability to obtain credit, and also

would affect her ability to find gainful employment.

2. Defendants knew or should have known the detrimental effects such false information

being made available to the public would cause Plaintiff. Defendants presented Plaintiff

in a false light when they dissemination highly prejudicial, false, and inaccurate

information in a public forum. Defendants actions were negligent, and their refusal to

retract the lies they submitted to the CRAs show a callous indifference to the harm it

caused Plaintiff to experience. Plaintiff already possesses clear and convincing

evidence the Defendants knew the publication would create a false impression

regarding Plaintiffs mortgage history and cause her irreparable harm.



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8. GMACMs failure to report Plaintiffs mortgage caused her credit score to drop which

in turn prevented her from refinancing in 2006. Plaintiffs reliance on Defendants

representation was a substantial factor in causing her harm.

COUNT THREE

INTENTIONAL TORT OF CONCEALMENT AND DECEIT

(Against Defendants GMAC Mortgage and Debra Rosenstein)

Plaintiff re-alleges and reincorporates each and every allegation contained in the General

Allegations and all previous paragraphs of all previous sections and Causes of Action in this


9. July 14, 2006 MIT and GMACM enter into a servicing contract which established a

fiduciary relationship between them. This contract, which upon information and belief,

was a pooling and servicing agreement, legally required GMAC to act at all times for

the sole benefit and interests of MIT.

10.Defendants were obligated by law to inform the Plaintiff that they had submitted

negative credit information about her to CRAs. Although the Defendants did not report

Plaintiffs excellent mortgage payment history to the CRAs in October 2006, nor did

they report it the following month. It was not until December 2006 that the Defendants

finally reported Jones payment history. The December report contained serious lies

about the Plaintiff. Defendants December report stated: Plaintiff was having

difficulties making her mortgage payments; and Plaintiff had such severe financial

problems that she requested and agreed to enter into a forbearance agreement with the

Defendants.

11. Plaintiff states she had timely made all of her mortgage payments.

12. Plaintiff also states she never requested, authorized, nor contracted with Defendant for

a forbearance agreement.

13. By law the Defendants were required to notify Plaintiff if and when it submitted

negative credit information to CRAs. Defendants never notified Jones of their reporting

activities.



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14. Not only did Defendants failed to abide by the law; they also knowingly conceal their

wrongful acts by failing to inform Plaintiff of their ongoing practice of submitting, not

only negative information, but, also submitting information which was blatantly false

and deceptive. Plaintiff reasonably relied on Defendants statement that they report her

excellent payment history to the CRAs in December 2006.

15. As a direct and proximate cause of the Defendants submitting blatantly false, deceptive,

and inaccurate information and it intentional concealment of material facts, Plaintiff has

been ruined financially and her business and professional reputation have been

negatively affected..

COUNT FOUR

FALSE PROMISE





16.

Rosenstein made a promise to Plaintiff that GMAC would report Plaintiffs mortgagehistory to the CRAs in a letter dated November 16,2006.

17.Rosenstein knew this promise was of critical importance to Plaintiff. Plaintiff informed

Rosenstein that she needed to refinance her home before the end of 2006 and that it was

imperative her credit history be reported to the CRAs immediately. Plaintiff explained

that this report would insure Plaintiffs credit score increase high enough to refinance

her interest only mortgage into a lower interest rate and access her equity.

18. Defendants were made aware of the importance of keeping their promise to reportPlaintiffs credit history. Defendants assured the Plaintiff that they would keep their

promise. Neither GMACM nor, its agent, Rosenstein, made good on their promise to

the Plaintiff.

19.Plaintiff believed and relied on the Defendants to keep their promise. Defendants

failure to report Plaintiffs mortgage payment history, cause her true credit history to



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be unavailable to interested parties. Defendants failure to keep their promise caused

Plaintiff to suffer pecuniary damages when she could not access the equity in her home

which was approximately $86,000.00. Defendants interference with Plaintiffs ability to

refinance her property resulted in Plaintiff having to forgo opportunities to obtain a loan

which had a lower interest rate and help her honor roll son finance his college

education.Defendants actions were a direct and approximate cause of harm to Plaintiff.

COUNT FIVE

NEGLIGENT MISREPRESENTATION


Plaintiff re-alleges and reincorporates each and every allegation contained in the

General Allegations and all previous paragraphs of all previous sections and Causes of

Action in this Complaint, inclusive, as though fully set forth herein.

20. Defendant, Rosenstein, sent Plaintiff a letter in November of 2006 which she stated

that Plaintiffs mortgage history would be reported to the CRAs. Contrary to

Rosenstein written statement Plaintiffs mortgage payment history was not reported to

the CRAs in November 2006.

21. Plaintiff alleges Rosenstein knew that GMACM would not send Plaintiffs mortgage

payment history to the CRAs as this would violate its fiduciary responsibility to MIT

by assisting the Plaintiff in refinancing and becoming someone elses customer.

22. Plaintiff who was unaware, that GMACM, as the servicer of her mortgage, was

obligated to protect the interests of its principle MIT.

23. Plaintiff alleges that Defendants negligently misrepresented what actions it would take

regarding the reporting of Plaintiffs mortgage payment history. To her detriment

Plaintiff relied on Defendants negligent misrepresentation and was harmed by

Defendants actions.

24. Defendants negligent misrepresentation was a substantial factor in causing harm to her

credit score to drop and prevent her from refinancing in 2006.



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COUNT SIX

VIOLATION OF THE FAIR CREDIT REPORTING ACT (15 USC1681i)

(Against all Defendants)Plaintiff re-alleges and reincorporates each and every allegation contained in the General



25. Plaintiff is a consumer within the meaning of 15 USC 1692a(3). Aconsumer report is a written, oral, or other communication of any information to a

consumer reporting agency bearing on a consumer's credit worthiness, credit standing,

credit capacity, character, general reputation, personal characteristics, or mode of

living which is used or expected to be used or collected in whole or in part for the

purpose of serving as a factor in establishing the consumer's eligibility for the

extension of credit and employment purposes.

26. What constitutes a consumer report covers more than just credit information,

as indicated by the phrase "any information." Reports regarding driving records,

criminal history, educational background, professional certifications, and similar

matters also are considered consumer reports.

27. A consumer reporting agency includes in its public reports more than credit

history reporting as well as other credit worthy information. Private investigators and

persons and agencies that perform employee background checks qualify as well.

Requirement For Furnishers To Update Records:

28. Defendant is a corporation who regularly furnishes information to the CRAs. Under

the Fair Credit Reporting Act (hereinafter FCRA), 15 USC 1681s-2. Furnishers

must change records, delete records, or permanently block reported information that is

found to be inaccurate or incomplete. Defendants violated 15 USC 1681 by refusing to



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correct the reporting errors it submitted to the CRAs even after the Plaintiff brought the

errors to Defendants attention.

29. Defendants failed to report Plaintiffs mortgage history in October 2006 to the CRAs

even though they are required to do so after having serviced her loan for 60 days.

Plaintiff sent GMACM a Qualified Written Request letter dated November 20, 2006

informing the Defendant that it had failed to report her mortgage payment history to the

CRAs. Plaintiff did not receive a response from GMACM until after she lodged a

complaint with the Department of Corporations.

30. In response to the complaint, Defendants sent Plaintiff a notice which stated GMACM

would report to the CRAs Plaintiffs mortgage payment history in November 2006.

31. Plaintiff sent the CRAs letters to check if the reporting promised was done as well as

requesting the CRAs to report her mortgage as a new account. Plaintiff received

responses from the CRAs stating that the Defendants are subscribers and furnishers of

information and that the Defendants had not reported Plaintiffs mortgage history in

November 2006.

32. Plaintiff sent Defendants a certified letter of complaint dated November 30, 2006 and

attached copies of the correspondences she received from the CRAs stating that

Defendants never submitted Plaintiffs mortgage payment history in November 2006.

33. In December 2006 Defendants willfully and maliciously with the intent to further

harmed Plaintiffs credit by manufacturing false information and reporting inaccurate

data to the CRAs. Defendants submitted the mortgage history payment report knowing

it was nothing more the a composite of lies and other erroneous data.

34. For example, GMACM reported Plaintiff was struggling to make her mortgage

payments and had requested and was granted a forbearance agreement. This

information was categorically false.

35. Instead of retracting and removing the inaccurate furnished in the December 2006

report, GMACM elected to violate the law by failing to comply with the requirements

imposed under FCRA, including but not limited to, failing to follow reasonable

procedures to assure maximum possible accuracy of the information reported to the

CRAs regarding Plaintiffs mortgage history.



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36. Defendants furnished information in December of 2006 to Trans Union which stated

that Plaintiffs loan amount had increased and that the increase consisted of her current

mortgage payment of $2,049.33 with an additional per diem interest late fee of $67.40,

both amounts were added to the back end of Plaintiffs original five years interest only

loan. The original amount was $371,200. By GMACM increasing her loan amount to

$373,317 it directly interfered and changed the terms of the original contract Plaintiff

had with MIT for a loan amount of $371,200 fixed for five (5) years.

37. Defendants also falsely reported in December 2006 to Experian and Equifax that

the account was in dispute and closed causing her mortgage history not to be rated and

included as part of her credit score. Defendants action caused the Plaintiffs credit

score to deteriorate even further and resulted in the Plaintiff being unable to obtain

credit.

38. Defendants transferred the servicing rights to Plaintiffs loan to Americas Servicing

Company in December 2006. Unbeknownst to the Plaintiff, after transferring the

servicing right GMACM continued to report negative credit information about the

Plaintiffs to the CRAs.

39. Defendants continued to harm Plaintiff by accessing her credit without her knowledge

and consent. Consumer law prohibits GMACM or any for that matter from accessing

Plaintiffs credit report without her prior written consent. Even after GMACM was no

longer the servicing company for her loan it continued to illegally invaded Plaintiffs

privacy by accessing her credit. The Defendant continued to harm Plaintiffs credit

reputation by continuously reporting negative and false information after it no longer

serviced her loan.

40. Defendants are furnishers of credit information to the CRAs and are required by law

to notify Plaintiff when negative information they have submitted to the CRAs has

been placed on Plaintiffs credit report. In violation of consumer credit laws GMACM

reported false and inaccurate information concerning Plaintiff in December 2006 and

August 2008 and failed to notify Plaintiff that they had taken such action. Defendants

action deprived Plaintiff of the opportunity to dispute the veracity of the information

submitted, object to its inclusion on her credit report, to take whatever actions



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necessary to protect her credit history and preserve her reputation as an honest person

who paid her debts.1

41. The Fair Isaac credit scoring model is used in the credit reporting industry to generate

a consumer credit scores based on information obtain about a consumer. Scores are

determined by different factors which are calculated as percentages. Defendants

negatively impacted Plaintiffs credit score in the following areas: 35% for payment

history, 30% for Capacity, and 15% for length of credit historywhich when totaled and

accounts for 80% of Plaintiffs credit score.

42. As a result of Defendants violations of the FCRA, Plaintiff has been denied credit and

employment opportunities. Her personal and business reputations have been severely

tarnished. Having been terrorized by the Defendants relentless campaign to deprive her

of home and decimate her financial well being Plaintiff has experienced and continues

to experience extreme anguish, panic attacks, emotional stress, depression, anxiety,

fear, embarrassment, frustration, and humiliation. Plaintiff has also been hospitalized

for acute chest pains . Defendants were a direct and proximate cause of harm to the

Plaintiff.

COUNT SEVEN

VIOLATION OF THE TRUTH AND LENDING ACT

(TILA)




Daily Interest When Payments Are Made After Due Date.

11Study Of Information Sharing: Federal statues require federal financial services and the FTC to study the

following: the purposes for which affiliate sharing information is used; the types of information shared withaffiliates; choices provided to consumers regarding control of sharing and the degree to which consumers useoptions; if information is used foremployment or hiring, orfor general publication of such information; and theinformation sharing practices that financial institutions and other creditors and users of consumer reports

employ for purposes of credit underwriting or evaluation



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43. Most mortgage loans have grace periods, during which a borrower may make the

monthly payment after the due date without incurring a late charge. The late charges are

assessed as a percentage of the monthly mortgage payment.

44. While it may be proper for a lender to charge daily interest late fee when the loan

so provides on the payoff demand, however, it is deceptive for a lender to charge a late

fee as well as daily interest late fee before the 15 day grace period expires.

45. The Defendants violated TILA by deceptively charging a upfront late fee on the

November 2006 payoff demand prior to the 15 day grace period. The Defendants were

prohibited by TILA from charging an unauthorized upfront late fee prior to the expiration

of the 15 day grace period or attempting to collect the unauthorized fee. Defendants are

only allowed to charge a daily interest late fee if the new loan closes after the 15 th day of

the month and each day thereafter.

46. Plaintiff signed her original loan documents in April 2006. The loan agreement

stipulated that Plaintiff mortgage payment is due the first day of each month. The

agreement also states that if the Plaintiff fails to pay her mortgage installment by the 15 th

day of the month she becomes obligated to pay a 6% late fee after the 15th day of the

grace period. Defendants erroneously accessed plaintiffs account a late fee of $122.95

on November 6, 2006.

47.

Denise Perricci, who is a title officer with Financial Title, made numerous phonecalls on the Plaintiffs behalf requesting Defendants to send her amended title instructions

to remove the unauthorizedlate fee of $122.95. Defendants refused to send her amended

title instructions which would have allowed for the deletion of the unauthorized late

charge Plaintiff did not owe.

48. As a result of Defendants violating TILA by refusing to correct its accounting error.

Plaintiff became concerned as to the Defendants honesty and ability to correctly

account for and administer her mortgage. Plaintiff was caused to suffer worry, fear,

distress, frustration, and mental anguish and hospitalization for chest pains all to her

damages in the amount to be determined by the jury. Defendants were a direct and

proximate cause of harm to Plaintiff .

COUNT EIGHT

VIOLATION OF RESPA



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49. On July 14, 2006 GMAC Mortgage LLC was the servicer of Plaintiffs mortgage and

was required to adhere to and comply with 12 U.S.C.2605 (RESPA). GMAC

Mortgage LLC failed to comply with the RESPA requirements.

50. Plaintiff sent GMAC mortgage LLC three certified qualified written request

(hereinafter QWR) dated November 20, 26, 30 of 2006 regarding its failure to report

Plaintiffs mortgage to the CRAs after it had been the servicer for 60 days. Plaintiffs

QWRs asked the Defendant to report her mortgage and remove the wrongfully

charged late fee from the payoff statement.51. GMAC mortgage violated 12 U.S.C.2605 by not acknowledging receipt of Plaintiffs

written requests within 20 days as required by RESPA. GMAC also violated section 6

of RESPA when it failed to investigate issues raised in Plaintiff s QWRs and provide

her with a written report within the 60 days as required by RESPA.

52. GMAC mortgage LLC was prohibited under RESPA from reporting any negative

or inaccurate information during the 60 day investigation period. Specifically GMAC

Mortgage LLC violated 12 U.S.C.2605(e)(I)(A);(1)(c);(c)(2);(e)(2);(e)(3); As a result

of the above violations, Plaintiff has been damaged and is entitled to damages and costs

pursuant to 12U.S.C.2605(f). Defendants actions were the direct and proximate cause

of harm to the Plaintiff.

COUNT NINE

NEGLIGENT NONDISCLOSURE BY FIDUCIARY

(Against All Defendants )Plaintiff re-alleges and reincorporates each and every allegation contained in the General



53. A fiduciary relationship existed between the Plaintiff and the Defendants that required

the highest good faith and the undivided service and loyalty. Defendants possessed



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information material to Plaintiffs interest. Defendant knew or should have known that

the false information furnished to the CRAs was of material interest to Plaintiff ability

to refinance in 2006.

54. Defendants failed to disclose this material information to Plaintiff and concealed the

fact they intended to report false and negative information to the CRAs about Plaintiffs

mortgage history. This nondisclosure caused Plaintiff to suffer injury, damage, loss and

harm. Defendants concealment of material facts was a direct and proximate cause of

harm to the Plaintiff.

COUNT TEN

NEGLIGENT INFLICTION OF EMOTION DISTRESS

(Against all Defendants)




55. Defendants were all negligent in the handling and servicing of her loan. Defendants

erroneously claimed Plaintiff failed to timely pay her mortgage. Defendants own

accounting records clearly shows that Plaintiff was not delinquent on her mortgage

obligation.

56. Instead of correcting its error and simply apologizing to the Plaintiff the Defendants

chose to compound their negligence by: 1) refusing to remove the late charge fee; 2)

and ignoring Plaintiffs request that her credit history be reported to the CRAs until she

officially filed a complaint with the Department of Corporation.

57. In furnishing inaccurate information to the CRAs a sharply cascading tier effect

resulted which caused Plaintiff to be denied employment; defend against a wrongful

and fraudulent foreclosure action, the needlessly filing for Chapter 7 and Chapter 13

bankruptcy protection to avoid the unwarranted and illegal forfeiture of her home.

58. The Defendants conduct was outrageous. Plaintiff has been and continues to be

terrorized by the Defendants complicity and duplicity in committing fraud, failure to

disclose material facts and deceptive actions. As a direct and proximate cause of

Defendants unwarranted acts. Plaintiff has suffered mental anguish, severe emotional



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distress, fright, horror, nervousness, grief, panic attacks, depression, anxiety, worry,

shock, humiliation and shame.

59.Plaintiff had to be hospitalized on numerous occasions for chest pains and other heart

attack like symptoms. The Defendants actions caused such turmoil in Plaintiffs life

that her treating physician prescribed medication to help her emotionally and physically

contend with the horrific stress that Defendants actions were causing her. Plaintiff

suffered emotional distress that a reasonable person would be unable to cope with in

the same circumstances. Defendants negligence was a substantial factor in causing

Plaintiff serious emotional distress.

COUNT ELEVEN

DEFENDANTS ARE ESTOPPED FROM ASSERTING STATUE OF LIMITATIONSDEFESNSE




60. In response to a settle demand in April of 2008. GMACMs attorney advised Plaintiff

she was not allowed to file her suit in the federal district court. Plaintiff relied on

Defendants advice and therefore did not timely exercise her right to file a lawsuit to

protect her federal causes of actions.

61. Plaintiff did not discover until after the statute of limitation had expired that the

Defendants attorney had intentionally deceived her by advising her incorrectly about

her legal right to proceed in federal district court.

62. Plaintiff contends that the statute of limitation should be tolled because the Defendants

lawyer acted in bad faith when he misinformed Plaintiff, who is a lay person. Plaintiff

ask that the Court take under consideration that once plaintiff became aware of her

rights she expeditiously proceeded to file this instant action. Defendants behavior

which was unethical and unconscionable was direct and proximate cause of harm to

the Plaintiff.



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COUNT TWEVELEPROFESSIONAL NEGLIGENCE

(Against Defendant MIT)Plaintiff re-alleges and reincorporates each and every allegation contained in the General



63. The Defendant had a legal duty to conform to a standard duty of conduct as all other

lenders practicing in the same profession. The Defendants is a Mortgage Lender that

performs professional services for consumers.

64. The Defendant, MIT owed the Plaintiff the duty of reporting her mortgage history

to the CRAs after its agent GMACM failed to do so . Defendants transferred the

servicing rights of Plaintiffs first loan on July 14, 2006 to GMACM. as the owner and

holder of plaintiff note, MIT still was responsible and held control of Plaintiffs

mortgage and note. Defendant failed to conform to the standard duty of conduct that all

other lenders practicing in the same profession adhere to when reporting residential

mortgage history to the CRAs after 60 days of servicing following the transfer of

servicing rights.

65. SPS formally known as (Fairbanks Capital Corporation) is a professional mortgage

servicing company that practices in the same profession and capacity as GMACM in

servicing residential loans that are transferred to them. MIT transferred the servicing

rights of Plaintiffs second mortgage to SPS on July 3, 2006. Following 60 days of

servicing after the transfer of Plaintiffs loan, SPS reported Plaintiffs mortgage history

to the CRAs in October of 2006.66. MIT transferred the servicing rights of Plaintiffs first loan to the GMACM on July

14, 2006. Following 60 days of servicing after the transfer of Plaintiffs loan

GMACM failed to report Plaintiffs loan to the CRAs. The MIT then transferred the

servicing rights of Plaintiffs first loan away from GMACM in December of 2006 to

Americas Servicing Company. Following 60 days of servicing after the transfer of



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Plaintiffs loan, American Servicing Company reported Plaintiffs mortgage history to

the CRAs in February 2007.

67. All Lenders and Banks practicing in the same profession as the Defendants that service

newly transferred residential loans conform to the same practice and protocol of

reporting a consumers residential mortgage history to the CRAs after 60 days of

servicing following a transfer of servicing rights.

68. MIT and its agent GMACM failed to conform to this standard of conduct by not

reporting Plaintiffs mortgage history to the CRAs after 60 days of servicing Plaintiffs

loan following the transfer of servicing rights. The Defendants failure was the

proximate and legal cause of injury and damages to Plaintiffs credit.

COUNT THIRTEEN

BREACH OF CONTRACT

(Against MIT)Plaintiff re-alleges and reincorporates each and every allegation contained in the General



69. Plaintiff and Defendants entered into a mortgage contract on April 21, 2006. Plaintiff

fulfilled her obligations pursuant to the mortgage contract. GMACM as servicer of the

loan breached the mortgage agreement by charging the Plaintiff an unwarranted late

fee. MIT was the principle who had a duty to oversee the acts and omissions of its

servicing agent GMACM. MIT clearly stated that although the loan servicing rights had

been transferred to its agent GMACM, all the original terms of the mortgage contract

would remain the same.

70. GMACM breach the contract when it charged the Plaintiff a late fee before the

expiration of the 15 day grace period. MIT allowed GMACM to breach the contract a

second time when it increased the principle amount of the loan from $371,200 to

$373,317 and then report the increased amount to the CRAs without notifying the

Plaintiff that the terms of her contract had changed. Defendants also failed to

accurately report Plaintiffs payment history, did not notify the Plaintiff that it had

submitted inaccurate and false information to the CRAs and refused to correct or



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retract its credit reporting errors. MIT failed to oversee agent GMACM servicing

practices and correct GMACMs negligent acts.

71. This failure was a dereliction of it duty to service, or, insure that it agent properly

serviced Plaintiffs loan. Plaintiff alleges that Defendants breach of the mortgage

contract caused Plaintiff irreparable harm for which she should be compensated and for

which the Defendants should be punished. Defendants breach of the terms of the

original mortgage agreement was the direct and approximate cause of harm to Plaintiff.

COUNT FOURTEEN

BREACH OF THE IMPLIED COVENT OF GOOD FAITH AND FAIR DEALING

(Against MIT)Plaintiff re-alleges and reincorporates each and every allegation contained in the General



72. The written contract between Plaintiff and MIT is subject to the principle of a Implied

Covenant of Good Faith and Fair Dealing which is inherent in all contracts and loan

agreements entered into in California. A lender has a duty to exercise discretion in

good faith within the standard of fair dealings. (section 36:17,1:6(the Implied

Covenant of Good Faith and Fair Dealing).

73.The Defendants breached the implied covenant of good faith and fair dealings as

follows: 1) November 2006 MIT allowed its agent GMACM to improperly charge

Plaintiff a late fee and then refused to remove the late fee after Plaintiff disputed the

charges; 2) MIT failed to monitor GMACM servicing practice who failed to report

Plaintiffs mortgage history to the CRAs after 60 days of servicing 3) MIT allowed its

agent GMACM to change the terms of the contract by increasing the original loan

amount of $371,200 by $2117.00 as reported to the CRAs and by adding that amount

to the back end of Plaintiffs loan amount increasing the loan amount to $373,317.

Plaintiffs loan and contract agreement with MIT was not a for a pay option arm loan

in which the interest only monthly payments are added to the back end of the loan to

increased the principle loan amount. Plaintiffs loan was a five (5) fixed interest only

loan in which the principle loan would remain the same and fixed for the term of five

(5) years.



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74. Plaintiffs was not behind in any of her mortgage payments and did not need or request

a forbearance agreement. Plaintiff did not renegotiate the terms of the April 2006

mortgage contract with MIT nor its agent GMACM, she did not agree to refinance or

otherwise increase the original loan amount to $371,200.

75. Plaintiff alleges that the MIT and GMACM breached the mortgage contract by

unilaterally changing the contract terms of amount owed by Plaintiff. The Defendants

agent GMACM unfairly interfered with Plaintiffs right to receive the benefits of the

contract. As a result of the breach of the Implied Covenant of Good Faith and Fair

Dealing as set forth above, Plaintiff has been damaged and seeks any and all

compensation to which she is entitled as Defendants actions resulted in the direct and

proximate cause of harm to Plaintiff.

COUNT FIFTEEN

VIOLATION OF THE BUSINESS AND PROFESSIONS CODE 17200




76. The actions of the Defendants, which is described above constitutes an is incorporated

herein by reference, are unfair business and consumer practices that violates California

Business and Professions Code 17200. which specifically states the above practices

are prohibited.

77. As a result of Defendants violating 17200, Plaintiff has suffered damage to her credit

and suffered tremendously emotionally and physically distress. Plaintiff seeks all

monetary relief to which she is entitled.

78. Further, Plaintiff seeks injunctive relief in the form of a permanent injunction

prohibiting GMACM or MIT from terrorizing and threatening the Plaintiff credit by

violating the California Consumer Protection Statutes. Defendants are the direct and

proximate of harm to Plaintiff. Plaintiffs seeks all damages.



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COUNT SIXTEEN

VIOLATION OF CIVIL CODE 1750 LEGAL REMEDIES ACT




79. The California Consumer Legal Remedies Act(CLRA) is set forth in Civil

Code1750. The CLRA was promulgated to protect consumers from deceptive and

dishonest practices by venders and providers of business services in California.

80. The conduct of GMACM as set forth herein violates 1770(A)(5)and(7). Defendant

represented it possessed the skills and knowledge necessary to service the Plaintiff

mortgage.

81. GMACMs policies and practice are substandard and do not meet the minimum

industry standards of quality for servicing residential mortgages. GMACMs policies

do not comply with the applicable State and Federal Statues governing mortgage

transfers and loan servicing. Nor does GMACM comply with state laws governing the

protection of consumer credit rights.

82. Based on Defendants violation of the CLRA, Plaintiff has been damage and seeks all

statutory damages provided under Civil Code1780 including actual damages, punitive

damages and all other relief as the Court deems proper.

83. Defendants ineptitude and negligence is particularly repugnant and egregious in that

GMACM actions were fraudulent, oppressive, malicious, and was done with the intent

to harm Plaintiff.

84. Defendants actions cause Plaintiff significant harm affecting many aspects of her life.

Defendants effectively ruined her credit, destroyed her reputation, caused her physical

pain and suffering, and overwhelming mental anguish. Defendantsprevented Plaintiff

from refinancing her home in 2006 and cause her to lose thousands of dollars in equity.



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The misrepresentations made in the credit payment history the Defendants filed with

the CRAs caused Plaintiff to be unable to secure gainful employment with any banking,

lending and non-lending institution that pulls credit and uses it as hiring criteria for

employment.

85. Plaintiff alleges that Defendants illegal actions, unethical behavior, and callous attitude

inflicted a tremendous amount of harm and hardship on Plaintiff. Defendants actions

have gone beyond the pale and should be considered worthy of not only the award

actual and compensatory damages, but, also punitive and exemplary damages.

Defendants actions were the direct and proximate cause of harm to Plaintiff.

COUNT SEVENTEEN

FAILURE TO USE RESONABLE CARE




86. Plaintiff contends she was harmed by MITs failure to use reasonable care when hiring

a loan servicing company to administer her loan. MITs decision to employ GMACMto service Plaintiff loan shows its lack of due diligence in investigating GMACM to

determine if GMACM was of good reputation, honest, experienced and skilled in

properly service mortgage loans.

87. Plaintiff contends that if MIT had conducted even the most very basic investigation of

GMACM it would have discovered that hundreds, if not thousands, of consumer

complaints had been filed against GMACM for its negligent servicing practices.

88. MIT had a fiduciary duty to act in good faith and to deal fairly with the Plaintiff, which

included, not hiring a loan servicing company which had a dismal public record of

mishandling and mistreating mortgagors. Plaintiff also alleges MIT failed to use

reasonable care in carrying out it fiduciary duty when it hired an incompetent and inept

servicing company as its agent and then failed to supervise and intervene when its agent

failed and/or refuse to abide by the terms of the mortgage contract. Surely, MIT



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received monthly servicing reports from GMACM and could have readily determined

that there were discrepancies with regard to Plaintiffs mortgage account.

89. GMACM was employed by MIT and was under contract to service Plaintiffs mortgage

loan. Pursuant to the service agreement GMACM acted on behalf of MIT. As its agent

GMACM was to collect monthly mortgage payments and generate monthly servicing

reports. GMACM was also required to accurately report mortgage history payments to

the CRAs.

90. Under the laws of agency, plaintiff believes MIT is vicariously liable for the wrongful

acts of GMACM. GMACM failed to act and use reasonable care while servicing

Plaintiffs loan MIT as the principal, and GMACM acting as MITs agent engaged in

conduct which was a substantial factor in causing harm to Plaintiff.

COUNT EIGHTEEN

DEFAMATION OF CHARACTER




91. The Defendants engaged in furnishing the CRAs with false and inaccurate statements

about Plaintiffs mortgage payment history knowing the information would be available

for public view. Defendants clearly understood that furnishing wrongful information

about Plaintiffs mortgage history would be view as a negative reflection of Plaintiffs

mortgage history.

92. Plaintiff alleges that Defendants knew or should have known that Plaintiff would be

harmed by the publication of false and inaccurate information as such negligent

behavior would effectively deny anyone accessing Plaintiffs credit history a true and

accurate depiction of Plaintiff financial history and current financial status.

93. Plaintiff has in fact been harmed by Defendant negligence and has suffered harm to her

property, business, profession and occupation causing her to suffer shame,

embarrassment, mortification and rejection by her friends and community. The

statements made by Defendants was a substantial factor in causing Plaintiff harm.



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Plaintiff alleges the Defendants intentionally defamed her good name and character

and she be compensated accordingly.

COUNT NINETEEN

SPECIAL DOCTINE OF RES ISPA LOAUITUR(Against all Defendants)Plaintiff re-alleges and reincorporates each and every allegation contained in the General



94. Plaintiffs harm ordinarily would not have happened unless someone was negligent.

The non-reporting and then the inaccurate reporting to the CRAs was the cause of

great harm to the Plaintiff that was under the exclusive control of the MIT at the timeof the negligent act.

95.Plaintiffs actions did not cause or contribute to the events that happened to Plaintiff.

The Defendants negligence was the cause-in-fact of the harm, as well as, the

proximate cause of the harm to Plaintiff.

COUNT TWENTY

VIOLATION OF THE ROSENTHAL ACT

VIOLATION OT CAL. CIV. CODE SEC. 1788(Against all Defendants)




96. The Defendants violated California statues governing debt collection practices, the

Rosenthal Act and Cal. Civ. Code, section 1788. Defendants sent false

communication to financial title indicating that Plaintiff owed a late. Defendants did

not disclose on the November 2006 pay off demand sent to financial title the month

the late fee was owed, nor, did they ever send Plaintiff any collection letters

demanding payment of the alleged late fee. The title officer Denise Perrucci notified

Defendants of error and requested they remove the erroneous late fee and send her

http://en.wikipedia.org/wiki/Cause-in-facthttp://en.wikipedia.org/wiki/Proximate_causehttp://en.wikipedia.org/wiki/Cause-in-facthttp://en.wikipedia.org/wiki/Proximate_cause


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new title instructions with the removal of the late fee. Defendants refused to send her

new title instructions deleting the unjustified late fee.

97.Plaintiff ordered a supplemental credit report through Land America INFO1 credit to

verify Plaintiffs mortgage history. Land America INFO1 verified Plaintiffs mortgage

with Defendants employee named Manny. Manny verified there were no late fees

on Plaintiffs account. Plaintiff also ordered a accounting of her payment history from

Defendant. The accounting record verified that there were NO record of any late fees

posted on the account. After Defendants were notified by the Department of

Corporation of Plaintiffs complaint of the erroneous late fee and warned about

mishandling of her account, Plaintiff received hourly harassing phones calls from the

Defendant daily stating her mortgage was late.

98. The Rosenthal Act was enacted to prohibit debt collectors such as the Defendants from

engaging in unfair deceptive acts or practices in the collection of a debt. The Act states

that debt collectors must comply with Chapter 15 of the United States Code sections

1692(b) -1692(j) and subject to the remedies prescribed in Chapter 15 of the United

States Code sections 1692(k) and Cal. Civ. Code, section 1788.17. The statue prohibits

actions such as false communications, threats or harassment in the collection of a debt.

99. Defendants conduct was a substantial factor in causing Plaintiff harm. Plaintiff

suffered worry, fear, distress, mental anguish, frustration. Plaintiff is entitled to

statutory and punitive damages in the amount to be determined by the jury. Plaintiff is

entitled to attorneys fees. Defendants actions and conduct were a direct and proximate

cause of harm to the Plaintiff.

COUNT TWENTY-ONE

INDUCING BREACH OF CONTRACT (Against Defendant GMACM)Plaintiff re-alleges and reincorporates each and every allegation contained in the General





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100. A valid contract existed between Plaintiff and MIT as of April of 2006. Defendant

GMACM knew of the existence of this contract. GMACM intentionally engaged in

acts and conduct which induced MIT to breach the contract with Plaintiff.

101. GMACM intended to induce a breach of such contract between MIT and the

Plaintiff. The contract was in fact breached by MIT. The acts and conduct of the

Defendant which induced the breach caused damage to the Plaintiff. Defendants

action were a direct and proximate cause of harm to the Plaintiff.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for relief on all counts against all Defendants as

follows:

(a) For all compensatory, consequential, special, actual, incidental, statutory and general

damages according to proof at trial.

(b) GMACM submission of a permanent letter of deletion to the CRAs which would instruct

the CRAs to delete all reports made by GMACM from Plaintiff credit file as well as

remitting Plaintiff a copy of the deletion letter.

(c) Permanent injunctive relief prohibiting GMACM from reporting inaccurate and negative

information to Plaintiffs credit report.

(d)Post judgment and prejudgment interest as allowed by law.

(e)For attorneys fees under Code of Civil Procedure 1021.5 and any other applicable

statute and case law. All out of pocket attorneys fees incurred to date.

(f) For all other relief that the Court deems just and proper.

(g) Demand for Jury trial.

(h) For cost of suit.

Dated this 5th day of January, 2009

Respectfully submitted by:



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__________________________________

Sylvia Jones, Pro SeP.O. Box 6043Santa Clara, CA 95056Ph: 408-310-2621

Documents

GMAC Mortgage LLC ruin my credit, prevented me from getting a job causing me to go into foreclosure