Rivas-Quinones et al v. Wells Fargo Bank, Home Mortgage et al

OPPOSITION TO MOTION TO DISMISS

D.N.J.July 28, 2016

MARIA T. RIVAS OSVALDO RIVAS-QUINONES 206 ARMOUR AVENUE HAMILTON, NEW JERSEY 08619 PRO SE PLAINTIFFS, OSVALDO RIVAS-QUINONES MARIA T. RIVAS PLAINTIFFS, v. RECEIVED JUL 2 8 2016 AT 8:30 M UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY CIVIL ACTION NO. 3:16-cv-02381-FLW-TJB WILLIAM T. WALSH CLERK OPPOSITION TO MOTION TO DISMISS WELLS FARGO BANK HOME MORTGAGE with PREJUDICE AND LEESA WHITT-POTTER, DEFENDENTS. PLAINTIFFS' OPPOSITION TO MOTION TO DISMISS WITH PREJUDICE WELLS FARGQ BANK HOME MORTGAGE AND LEESA WHITT-POTTER, HAS FILED A MOTION TO DISMISS '("MOTION") BASED ON FEDERAL RULE OF CIVIL PROCEDURE 12(b)(l), 12(b)(6), 8 (a). PLAINTIFFS OPPOSE THE MOTION. POINT - 1 OF DEFENDANTS MOTION STATES; UNDER FED. R. CIV. P. 12(b)(l) A I DEFENDANT MAY MOVE TO DISMISS A CLAIM FOR LACK OF SUBJECT MATTER JURISDICTION AT ANY TIME. WELLS FAR,GO IS A NATIONALLY CHARTERED BANK, AND THE FACT THAT WELLS FARGO PRINCIPAL PLACE OF BUSINESS IS BASED IN DES MOINES, IOWA. IN WHICH IS IN A DIFFERENT STATE OF PLAINTIFFS, ALSO THE AMOUNT IN CONTROVERSY EXCEED $ 75.000 . Case 3:16-cv-02381-FLW-TJB Document 14 Filed 07/28/16 Page 1 of 13 PageID: 105 CONGRESS GRANTED DIVERSITY JURISDICTION TO FEDERAL COURTS IN 28 U.S.C. § 1332. THE STATUTE PROVIDE THAT FOR A FEDERAL COURT TO HAVE JURISDICTION, THE AMOUNT IN CONTROVERSY MUST EXCEED $ 75.000 AND THE DISPUTE MUST BE CITIZENS OF DIFFERENT STATES. WHEN A LITIGANT IS A CORPORATION THE STATUE MAKES THE CORPORATION A CITIZEN OF TWO PLACES; THE STATE IN WHICH IT IS INCORPORATED AND THE STATE WHERE IT HAS IT'S PRINCIPAL PLACE OF BUSINESS. SEE 28 U.S.C. § 1332 (A); DeLEON V. WELLS FARGO BANK, 729 F. SUPP. 2d 1119, 1122 (N.D. CAL. 2010). THEREFORE, CITIZENSHIP OF NATIONAL BANKS FOR DIVERSITY JURISDICTION PURPOSES IS NOT DETERMINED BY 28 U.S.C. § 1332 (C), BUT RATHER IS DETERMINED BY A DIFFERENT STATUE, CODIFIED AS 28 U.S.C. § 1348. HERE, THERE IS CONTROVERSITY FROM THE BEGINNING WELLS FARGO BANK COMMITIED FRAUD WITH MALICE FROM THE VERY START OF THE MORTGAGE AGREEMENTS. FAILURE TO FULLY DISCLOSE IMPORTANT FACTS TO PLAINTIFFS. THROUGH AGENTS AND PRINCIPALS, LEESA WHITI- POTIER AND OTHER AGENTS. WHEN, ONE SIDE TO A CONTRACT DO SO TO DECIEVE THE OTHER MAKES THE CONTRACT NULL AND VOID . HERE, ALSO PLAINTIFFS, ARE SEEKING THERE REMEDY UNDER PUBLIC LAW CHAP. 48, 48 STAT. 112 (STATUE AT LARGE) AND HJR-192. DEFENDANTS CANNOT PROVE THAT THEY LOANED ANYTHING BUT CREDIT THE CREDITOR/ PLAINTIFFS, BY WITHDRAWNING FUNDS FROM TRUST ACCOUNT PLAINTIFFS HAVE WITH FEDERAL RESERVE BANK IN THE FIRST PLACE . THE DEFENDANTS KNEW FROM THE START THEY WAS COMMITIING FRAUD THAT MAKE IT MALICE. ALSO, WHEN COMMERCIAL REMEDY IS DENIED THERE IS CONTROVERSITY. A BANK CAN NOT LEND ITS OWN CREDIT OR ITS DEPOSITS IT WILL BE AGAINST FEDERAL BANKING LAWS ACTS TO DO SO. THE SAME TRUST ACCOUNT USED TO CREATE THE CREDIT IS THE SAME ONE TO DISCHARGE ALL PLAINTIFFS, PUBLIC DEBTS. IN WHICH WELLS FARGO REFUSE TO DO SO . POINT- 2 OF DEFENDANT MOTION STATES PLAINTIFFS, FAILS TO STATE A CLAIM UPON WHICH RELIEF MAY BE GRANTED. FEDERAL RULES OF CIVIL PROCEDURE 8 (A) STATES THAT A COMPLAINT SHOULD CONTAIN "A SHORT AND PLAIN STATEMENT OF A CLAIM SHOWING THAT THE PLEADER IS ENTITLED TO [1] Case 3:16-cv-02381-FLW-TJB Document 14 Filed 07/28/16 Page 2 of 13 PageID: 106 RELIEF," FED . R. CIV. P .8{A)(2), AND THAT" [E]ACH ALLEGATION MUST BE SIMPLE, CONCISE, AND DIRECT." FED. R. CIV. P. 8{d)(l). THE SUPREME COURT HAS EXPLAINED THAT A COMPLAINT NEED ONLY" GIVE THE' DEFENDANT FAIR NOTICE OF WHAT THE PLAINTIFFS CLAIM IS AND THE GROUNDS UPON WHICH IT RESTS." SWIERKIEWICZ V. SOREMA N. A., S34 U.S. S06, S12 (2002); ACCORD ATCHISON, TOPEKA & SANTA FE RY. V. BUELL, 480 U.S. 557, 568 N.15 (1987) ( UNDER FEDERAL R. 8, CLAIMANT HAS " NO DUTY TO SET OUT ALL THE RELEVANT FACTS IN HIS COMPLAINT"). "SPECIFIC FACTS ARE NOT NEECESSARY IN A COMPLAINT; INSTEAD, THE STATEMENT NEED ONLY 'GIVE THE DEFENDANT FAIR NOTICE OF WHAT THE ... CLAIM IS AND THE GROUNDS UPON WHICH IT RESTS."' EPOS TECH, 636 F. SUPP .2d 57, 63 (D.D.C. 2009) (QUOTING BELL ATLANTIC V. TWOMBLY, SSO U.S. S44, SSS (2007) . THUS, THE FEDERAL RULES EMBODY "NOTICE PLEADING" AND REQUIRES ONLY A CONCISE STATEMENT OF THE CLAIM, RATHER THAN EVDENTIARY FACTS. ACCORDINGLY, DEFENDANTS' MOTION WOULD BE CONSIDERED PROPERLY FILED ONLY "WHERE A PLAINTIFFS COMPLAINT IS ·' UNINTELLIGA[ le] (sic),' NOT WHERE A COMPLAINT SUFFER FOR ' LACK OF DETAILS.111 EPOS TECH, 636 F. SUPP. 2d AT 63 {CITATIONS OMITTED). THE SIMPLIFIED NOTICE PLEADING STANDARD RELIES OB LIBERAL DISCOVERY RULE AND SUMMARY JUDGMENT MOTIONS , TO DEFINE DISPUTED FACTS AND TO DISPOSE OF UNMERITORIOUS CLAIMS. SEE SWIERKIEWICZ, S34 U.S. AT 512. INDEED, COURT HAVE FOUND THAT IF THE INFORMATION SOUGHT BY MOTION IS OBTAINABLE THROUGH DISCOVERY, THE MOTION SHOULD BE DENIED. SEE, E.G. TOWER TENANT ASS'N V. TOWER Ltd. P' SHIP, S63 F. SUPP. 566, 569 (D.D.C. 1983) (DENYING MOTION FOR A MORE DEFINITE STATEMENT BECAUSE DETAILS SUCH AS "DATES, NAMES, TIMES AND PLACES" ARE "THE CENTRAL OBJECT OF DISCOVERY, AND NEED NOT BE PLEADED "). HERE i THE PLAINTIFF'S COMPLAINT IS NOT UNINTELLIGIBLE OR CONFUSING AND DOES NOT VIOLATE FEDERAL R. CIV. P. 8{a)' S REQIREMENTT OF "A SHORT AND PLAIN STATEMENT OF THE CLAIM SHOWING THAT THE PLEADER IS ENTITLED TO RELIEF." THE COMPLAINT CLEARLY HAS A MORE THAN SUFFICIENT STATEMENT OF THE CLAIM AND MORE THAN MEETS THE REQIREMENT THAT IT BE "SHORT AND PLAIN." FOR EXAMPLE, THE COMPLAINT SPECIFICALLY IDENTIFIES THE ACTIONS OF DEFENDANTS AND HOW THOSE ACTIONS ARE WRONGFUL. THE DEFENDANTS CLAIM THAT TENDER OF FULL PAYMENT WAS NOT RECEIVE. NOT ONLY WAS PAYMENT RECEIVE IN [2] Case 3:16-cv-02381-FLW-TJB Document 14 Filed 07/28/16 Page 3 of 13 PageID: 107 FULL FROM THE BEGINNING OF THIS TRANSACTION . AGAIN THROUGH PLAINTIFF'S TRUST ACCOUNT, FEDERAL RESERVE BANK/ l.M.F EXEMPT ACCOUNT. WELLS FARGO BANK COMMITS FRAUD ON A DAILY BASES AGAINST CONSUMERS EVERYDAY. DEFENDANTS DEMANDED THAT PLAINTIFF'S PAY IN U.S. CURRENCY FEDERAL RESERVE NOTE IN WHICH IS A DEBT OBLIGATION OF THE FEDERAL UNITED STATES GOVERNMENT, NOT 11 MONEY. 11 THE FEDERAL UNITED STATES GOVERNMENT AND THE U.S. CONGRESS WERE NOT AND HAVE NEVER BEEN AUTHORIZE BY THE CONSTITUTION FOR THE UNITED STATES OF AMERICA TO ISSUE CURRENCY OF ANY KIND, BUT ONLY LAWFUL MONEY - GOLD- AND SILVER COIN . THERE IS A FUNDAMENTAL DIFFERENCE BETWEEN "PAYING" AND 11 DISCHARGING" A DEBT. TO PAY A DEBT, YOU MUST PAY WITH VALUE OR SUBSTANCE (i.e. GOLD, SILVER BARTER OR A COMMODITY). WITH FEDERAL RESERVE NOTE YOU CAN ONLY DISCHARGE A DEBT. NO CONTRACT IN COMMON LAW IS VALID UNLESS IT INVOLVES AN EXCHANGE OF 11 GOOD AND VALUABLE CONSIDERATION." WELLS FARGO BANK NEVER INFORMED PLAINTIFF'S THAT MONEY IS CREATED WHEN A PERSON (YOU) SIGNS A CONTRACT (PROMISSORY NOTE) WITH A BANK. THE REQUEST BY PLAINTIFF'S FOR WELLS FARGO TO PROVIDE THEM WITH ORIGINAL WET INK NOlE, ORIGINAL PROMISSORY NOTE NO COPY. NOT ONLY THAT THEY FAIL TO DISCLOSE THAT THEY WELLS FARGO SOLD THE ORIGINAL NOTE TO FEDERAL RESERVE THE MINUTE YOU SIGN IT, AND THE FED THEN GIVES THAT BANK THE AMOUNT THAT IT THEN 11 LOANS 11 TO YOU. NOT ONLY IS WELLS FARGO BALANCE IS AT $ 0.00, - WELLS FARGO DO NOT HOLD TITLE TO PLAINTIFF'S HOME ! ! ! IN ORDER FOR WELLS FARGO TO CLAIM PLAINTIFF'S OWE'S ANYTHING MUST SHOW IN A COURT OF 11 LAW 11 SHOW PROOF OF THEIR CLAIM TO COLLECT PLAINTIFF'S SUPPOSED DEBT TO THEM . THESE FACTS AND MANY OTHERS WAS NEVER DISCLOSED TO PLAINTIFF'S, IT IS THE VERY FACT THAT ALL OF THIS INFORMATION IS NOT DISCLOSED TO PLAINTIFF'S THAT'S MAKE THIS CONTRACT NULL AND VOID . WELLS FARGO HAS NO CONTRACT, NO PROOF OF CLAIM AGAINST PLAINTIFF'S DEBT, AND NO RIGHTS TO FORCE PLAINTIFF'S TO PAY ANYTHING.· THE ENTERIES PUT IN WELLS FARGO BANK BOOKS WILL SHOW THE SAME ZERO BALANCE AND NOTHING OWED . WELLS FARGO FAILED TO PROVIDE THE COURTS WITH ALL CORRSPONDENCE FROM PLAINTIFF'S SHOWING THEM HOW TO PROCEESS FINALE PAYMENT. PLAINTIFF'S TRUST ACCOUNT IS KNOWN TO DEFENDANTS AND [3] Case 3:16-cv-02381-FLW-TJB Document 14 Filed 07/28/16 Page 4 of 13 PageID: 108 DEFENDANTS KNOW HOW TO ACCESS THIS ACCOUNT FOR DISCHARGf. HERE, PLAINTIFF'S REFER TO FEDERAL GOVERNMENT OBLIGATION AS TO ME; CHAP. 48. 48 STAT. 112. SINCE THE FEDERAL GOVERNMENT TOOK AWAY THE GOLD COIN MONEY IN 1933, THUS CAUSING THE STATES TO SUSPEND OPERATIONS BY PREVENTING THEM FROM HONORING THEIR OBLIGATION TO PAY THEIR DEBTS IN GOLD AND SILVER COIN, THEN THERE HAD TO BE A REMEDY. 11 CHAP 48, 48 STAT. 112 11 IS THE REMEDY, NOT JUST FOR THE STATES, BUT ALSO FOR THE SOVEREIGN MEN AND WOMEN WHO CREATED THE STATES . UNTIL GOLD AND SILVER COINAGE IS REINSTATED INSUFFICIENT QUANTITIES FOR GENERAL CIRCULATION, THAT REMEDY CANNOT BE REPEALED., CONGRESS MAY HAVE REPEALED SOME PART OF "HJR-192", IN WHICH IS MERELY A RESOLUTION . HOWEVER, THE TRUE REMEDY IS PROVIDE TO THE PEOPLE BY PUBLIC LAW; : CHAP 48, 48 STAT. 112." THE TRUST ACCOUNT FOR THIS DISCHARGE OF PUBLIC DEBT WAS CREATED THROUGH CERTIFICATE OF LIVING BIRTH/, BIRTH CERTIFICATE . AND SOCIAL SERCURITY NUMBER ACCOUNT THE BANKS AND COURTS HAS ACCESS TO THROUGH SOCIAL SECURITY NUMBERS. WELLS FARGO IS FULL AWARE OF THIS PROCESS KNOWING THESE FUNDS CAN BE USED TO DISCHARGE THE PLAINTIFF'S PUBLIC DEBTS AFFORDED BY LAW. PLAINTIFF'S CLAIMS FOR RELIEF SHOULD NOT BE DENIED BECAUSE BY LAW, IT SHOULD RELIEF SHOULD BE GRANTED. NORMALLY, THE QUESTION OF JURISDICTION AND THE MERITS OF AN ACTION WILL BE CONSIDERED INTERWINED WHERE, AS HERE, " STA)"UE PROVIDES THE BASIS FOR BOTH THE SUBJECT MATTER JURISDICTION OF THE FEDRAL COURTS AND THE PLAINTIFF'S SUBSTANTIVE CLAIM FOR ~RELIEF." ID. AT 926 QUOTING SUN VALLY GASOLINE, INC. V. ERNST ENTERS., 711 F. 2d 138, 139-40 (9TH CIR. 1983). CONCLUSION IN SHORT, THE PLAINTIFF'S COMPLAINT FULLY COMPLIES WITH THE PLEADING REQUIREMENTS OF FEDERAL RULE OF CIVIL PROCEDURE 8(a) AND PROVIDES DEFENDANTS FAIR NOTICE OF THE CHARGES AGAINST THEM AND THE GROUNDS THEREFOR. DISCOVERY AND ARGUMENT WILL ADD FURTHER DETAILS LATER; IN FACT, MUCH ADDITIONAL SUPPORTING FACTUAL MATERIAL IS BEING PROVIDE WITH THIS OPPOSITION MOTION TO DISMISS. THIS COURT HAS SUBJECT [4] Case 3:16-cv-02381-FLW-TJB Document 14 Filed 07/28/16 Page 5 of 13 PageID: 109 MATTER JURISDICTION IN THIS MATTER. ADDTIONALLY, THE PLAINTIFF'S HAS SUFFICIENTLY ALLEGED HARM. ACCORDINGLY, FOR THE REASONS SET FORTH HEREIN, THE PLAINTIFF'S RESPECTFULLY REQUESTS THAT THE COURT DENY DEFENDANTS' MOTION TO DISMISS THE COMPLAINT WITH PREJUDICE. DATED: JULY 26, 2016 [S] RESPECTFULLY SUBMITTED, MARIA T. RIVAS/ PRO SE OSVALDO RIVAS- QUINONES /PRO SE 206 ARMOUR AVENUE HAMILTON, NEW JERSEY 08619 Case 3:16-cv-02381-FLW-TJB Document 14 Filed 07/28/16 Page 6 of 13 PageID: 110 Case 3:16-cv-02381-FLW-TJB Document 14 Filed 07/28/16 Page 7 of 13 PageID: 111 Principal Interest Escro\\• F.Ati!LTON, Cunent pa)"meut Total payment due 01/01/16 Return Mail Operaffons PO Bar 14411 Des~ IA 50306-3411 ---·-·-; Page1of 1~04/15 0420814342 I S528.90 $790-5"7 $898.00 ~~~~~~~-~+.~:::::::==::::'.:!: Year-to-date summary ~ $ap,983.o8 )To1BI received• $26,630.81 sa,21747 · $2,536.15 · Principal S6,a19.7 rc.':;•:1~:;' r:::::i:,::-:.:..7.:::;;.-:.·:".:.'-''°':;· :.•:>:::- ;-;z:::z:.iJ"bd=::::!) Int:ereSt:'* S9,613.g: Interest rate :\fa,tlirify date 3.750'6 Escrolv $10,797..2 o5/4o -TaJ_xes_disb_u_rs_ed. _____ $_6,_8_62.-3 After Ol/1.6/16 a late charge may apply 82,217-47 888.70 Insurance disbursed 8683.01 Date Descrlption laJO:f .Mtg ins P!vmeD.l · 12~04 Pa"11'leut 110i lltg ins palinettl Su1z.4t 10/28 Cit\" ta.~ panilent Ready to buy your next home? Principal •. oo -Sl.74o.J4 ~ilmaJ mar illchid: tb t:napplid &..Ilda balmiw hm dn Balnca IUlll1IW)' m:tml. "This illfa:mlllillftlb=ld not llemedfarnp~ ll)'O' h8T'S tan!atrdquftliou&. pl:aa =avlt1t11111tmcadrisor. HUD IUSIC·B.-\SBJ HAMlll'ONTWP CtID~ ·· n•e·re here to help)'Ou·understnndyour home &nan~opticms_ sqyq~ cag, ~~ j~9~ home financing decisions. Leatn about our low down pa)ment programs, ftnaoclog options_ and how we c:an help make b~·ing !'Our n~'t home a 11Mllrding eXf)erienc:e;·\'isit)'SUr-localhomemortgage consultant today. Case 3:16-cv-02381-FLW-TJB Document 14 Filed 07/28/16 Page 8 of 13 PageID: 112 File only If you are making a paynient of estimated tax by check or money order. Mall this voucher with your check or money order payable to "United States Treasury." Write your social security number and "2015Fonn1040-ES" on your check or money order. Do not send cash. Enclose, but do not staple or attach, yoUr payment with this voucher. ::=··2· -OMBNo.1545-0074 Calendar year-Due JW1e 15, 2015 Amount of estimated tax you are paying by check or money order. !~~~~~~~~~~~~~~7 0 ! i..-.~ ......... ,__.:-:_.__ .................. -...J .......... ~ .................. ---=-~----~~~--~~~~~~~~~~~~~~ Foreign postal code For Privacy Act and Paperwork Reduction Act Notice, see instructions. Tear ~ff here Case 3:16-cv-02381-FLW-TJB Document 14 Filed 07/28/16 Page 9 of 13 PageID: 113 . . TO.~TAE ATTN. OF C.F.O. ~WELLS FARGO HOME MORGAGE DES 'MOINES.IA. l1AM SENDING IN THIS STATEMENT ·WITH COUPON AS ACCEPTED FOR VALUE UNDER PUBLIC LAW STAT.48,48 -112 (HJR-192).1 ASK THAT YOU REVEIW THIS PUBLIC LAW AND DISCHARGE , MY MORTGAG.E A()tQ,,MESEND CONFlRMATION"'OFTHE·--sAME. ALSO SEE UCC ARTICLE 3 & 4 UCC CODE ,REMITTED TO THE DEPT. ·oF TREASURY /FRB TRUST AND u.~.C. TITLE 12 ... ALSO SEE PUBLIC POLICY, PL.73 -10 ,48 STAT. 31 OF AGRICULTURAL ADJUSTMENT ACT OF 1938 , AGAINST PUBLIC POLICY ,GOVERMENT OBLIGATIONS . THANK YOU FOR YGlJR TIME AND PATIENCElN THIS MATTER YOURS TRULLY /l OSVALDO R~ AS & MARIA T RIVAS fl,~;~f~ ' ~II-'. ---------------~----------r< o..i.l tJ. f. R~ IJC~·'Y LOAN #0420014342 Case 3:16-cv-02381- LW-TJB Document 14 Filed 07/28/16 Page 10 of 13 PageID: 114 Wells Fargo Home Mortgage Return Mail Operations POBox10368 · Des Moines, IA 50306-0368 January 21, 2016 Telephone: Correspon 1-800-853-8516 POBox10335 Page 1ofl DCML 1 CDTSG 003662 Des Moihes, IA 50306 I 1I1' • 1 I' I'• I• I I I 1111 11ID1•·•1I111 III1•11•I1 111 I' I•'' I• 1I1•11•1 I I OSVALDO RIVAS-QUINONES MARIA T. RIV AS 206 ARMOUR A VE. HAMILTON, NJ 08619 ~ Dear Osvaldo Rivas-Quinones: Loan number: Property address: ' 206 Armour Ave Hamilton NJ 0861 Thank you for contacting us. We're writing to l'~'~ou know that your inquiry has been received and is currently being reviewed. , · · ·· ;~c~- We expect to complete our research and ptov.i,g~ you witl1 the results on or before 02/ 02/ 2016. In the event additional time is needed we. will contacli you. · We value your feedback and appreciate the nrite ~~d ef(ort you took to bring your inquiry to our attention. · :\' ' . If you have questions during our review process~;,please call 1-800-853.28516. We are available to assist you Monday through Friday, 7:00 a.m. to v:oo p.tp'~; •-.....:.L--'-"'' ···""·~ Sincerely, ~ti!~-~ Lee.sgJfhitt-Pott==e~r __ Senior Vice President Wells Fargo-Horne Lending In order to remain compliant with state and federal guid~lines, if yo\fhave engaged legal counsel for any litigation, including bankruptcy; we will communicate with the appropriate parties going fmward. CC101 I GEM I GEM ID: GEM04823657 I Compass ID: 1640367 I UUID: GEM04823657-3408C'748-cf3b-3401-<)61c-b274521e41ac CC101 936 0005 I Cas 3:16-cv-02381-FLW-TJB Document 14 Filed 07/28/16 Page 11 of 13 PageID: 115 February 01, 2016 Osvaldo Rivas-Quinones Maria T. Rivas 206ArmoUPAvenue Hamilton, NJ 08619 Wells Fargo P.O. Box 10335 Des Moines, IA 50306-0335 -·subJect: ·Ackriow1eagmen:t· - reeeipt of mqtiiry regard1Dg ac00Uiifn1im.Befl542ooi4342 Dear Osvaldo Rivas-Quinones and Maria T. Rivas: Thank you for contacting us. We're writing to let you know that your inquiry has been received and is currently being reviewed. We expect to complete our research and provide you with the results on or before February 15, 2016. In the event additional time is needed we will contact you. We value your feedback and appreciate the time and effort you took to bring your inquiry to our attention. If you have questions during our review process, please call us at 1-800-853-8516. We are available to assist you Monday through Friday, 7:00 a.m. to 7:00 p.m. Central Time. Sincerely, ':-/_ A ~h A. -· .--:r1~.J.4 .c::,;..<~~t&lllt- ~~ - ~~A-1'. Leesa Whitt-Potter Senior Vice President Wells Fargo Home Lending In order to remain compliant with state and federal guidelines, If you have engaged legal counsel for any litigation, including bankruptcy, we will communicate With them going forward. CCS01/NONE/col653104/ge4883404/d936 Wells Fargo Home Mortgage Is a division of Wells Fargo Bank. 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