SS OINDER. LITIGATION SERVICES '";: MASS LITIGATION

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1 SS OINDER. LITIGATION SERVICES '";: MASS LITIGATION LLIANCE

2 I T RODUCTION On November 10', 2010, Mass Litigation Alliance, announced the expansion of our services to now include 6 New Mass Joinder Litigation Cases The springboard for these cases has been the extensive work and case precedence established via the Ronald et al v. Bank of America case. j Millions of American homeowners today work hard to sustain the demands of paying their mortgages. What they do not know because lenders are running fast to sweep the facts under the rug is that millions of these loans have shown evidence of &aud. /I You cannot turn on the television or open a newspaper without hearing or seeing some story regarding "MERS", "robo-signing" or how banks are foreclosing on American homeowners without the proper procedures being followed. These lenders will imply that this is simply a technicality in the paperwork. Many courts across America, multiple state Attorneys General, and millions of struggling homeowners adamantly disagree. YOU truly have legal cause against your lender and with MLA you can join thousands of Americans who are fighting back!!!! y 4* f y '". MASS LITIGATION. ALLIANCE

3 TTHEW K. DAVIS I'N I Mr. Davis is a partner and founding member of Mass Litigation Alliance, a Professional Law Corporation. Serving as a beacon of hope to distressed homeowners, his practice specializes in Litigation and Real Estate Law. As a partner at Mass Litigation Alliance, pc, Mr. Davis has emerged as a pioneer in the lender litigation arena and he and his team have helped hundreds of homeowners nationwide negotiate better terms on their home mortgages. Mr. Davis has extensively drafted, negotiated, consulted, and litigated various Real Estate documents and disputes, and guided many homeowners through the various pitfalls inherent in modern day homeownership. In addition to his law practice, Mr. Davis has acquired much knowledge and experience through his own Real Estate, mortgage and financial services company, and is able to leverage this knowledge in the legal representation of Mass Litigation Alliance, pc clients. 4 -~ "> Education: fg g' Santa Clara University (B.A 1998); Loyola Law School (J.D. 2001); Licensed Real Estate Broker (CA Department of Real Estate 2003); UCLA (extension: HOA Law, 2008). Member: State Bar Of California (Bar Number: ); San Luis Obispo Bar Association; National Association of Realtors; California Association of Realtors; Central Coast Association of Realtors. Our Firms Expertise and Areas of Practice: Real Estate Law Franchise Law /I Bankruptcy Entertainment Law Estate Planning y 4* f y '". MASS LITIGATION. ALLIANCE

4 pt ILIP A. KRAMER, ESQ. Mr. Kramer's practice emphasizes commercial litigation and trial advocacy, with a concentration on franchise law, banking litigation, and real property matters. He has tried in excess of 200 cases and has appeared on nationally televised programs regarding pre-trial procedure and trial strategy and has appeared as a guest lecturer on topics ranging from constitutional law to trial practice. Mr. Kramer is a past president of the Los Angeles West Inns of Court, a national organization dedicated to bringing back professionalism and civility into the legal.q profession. 'a '/ He is also a supporting member of the American Association of Franchisees &, Dealers, an organization dedicated to promoting fairness in franchising. Mr. Kramer chairs the American Association of Franchisees and Dealers' Speakers and Experts Panel. Mr. Kramer is also a member of the American Bar Association Forum on Franchising and serves as general counsel to the Hispanic Franchise Foundation, a national not-for-profit foundation dedicated to empowering Hispanic franchise business. Mr. Kramer received a Juris Doctorate from the Catholic University of America and a Bachelors' of Arts from The Ohio State University. Education: Juris Doctorate - Catholic University of America Bachelors' of Arts Ohio State University Areas of Practice: Real Estate Law and Litigation Franchise Law Bankruptcy y 4* f y Entertainment Law '". MASS LITIGATION Estate Planning. ALLIANCE

5 ITCHELL. STEIN ~</II +j t' y Mitchell J. Stein, Esq. is a 25-year award-winning litigator, trial lawyer, financier, and entrepreneur. He has represented many of the world's largest companies in State and Federal Court, and has been involved in some of the highest profile cases in the nation's history. With Mr. Stein, you will find a level of lawyering that is among the best in the profession. Mr. Stein is focused on providing high-quality service and customer satisfaction in all fields of legal endeavor. He will do everything we can to meet your expectations. He guarantees your outcome will command a unique level of attention to detail and creativity. It will be beyond your expectations or imagination. Mitchell J. Stein X Associates are the only law firm to guarantee it. 4* f y '". MASS LITIGATION. ALLIANCE

6 PENDING CASES '";: MASS LITIGATION LLIANCE

7 R NALD ET AL V. BANK OF AMERICA This case was filed and then transferred by court order to the Los Angeles complex litigation department Case ¹ BC Currently there are close to 1,100 clients (growing daily) represented in this case. The following updates to the case occurred as recently as the October 19th 2010 via the "Plaintiffs Status Report". Claims include: Ma lfeasance St atutory Violations 3r d Party Beneficiary Claims Phantom Investors and Beneficiaries /I Un f a ir Business Practices y 4* f y IM I I] I I '". MASS LITIGATION. ALLIANCE

8 , ' A D I TIONAL MASS OINDER CASES Wa er v. Citibank Case Filed: 30 December, Case Number: BC Presiding Judge: Hon. Mel Red Recana Los Angeles Superior Court, Department 45 r Nelson v. Wells Far o Case Filed: 30 December 2010 Case Number: BC Presiding Judge: Hon. Ernest M. Hiroshige Los Angeles Superior Court, Department 54 C arlson v. M o r an Case Filed: 30 December, 2010 Case Number: BC / Presiding Judge: Hon. Yvette M. Palazuelos y Los Angeles Superior Court, Department 28 Mar uette v. One West si., O S S a a e1 Case Filed: 30 December 2010 Case Number: BC Presiding Judge: Hon. Michael Stern Los Angeles Superior Court, Department 62 Locker v. All Summons p I (roo %.'t-; TRi..S't Case Filed: 30 December Case Number: BC Presiding Judge: Hon. Rex Heeseman 4- i " ) og >i ' ) i i. Los Angeles Superior Court, Department 19 ~ ~ I ~ 4* f y '". MASS LITIGATION First Amended Complaints adding all current client retainers were updated in January.. ALLIANCE

9 LITIGATION CAS E CRITERIA '";: MASS LITIGATION LLIANCE

10 LITIGATION CASE CRITERIA MERS Over 62 million mortgages a arenowheldinthename o f MERS, an electronic recording system nvenience of the mortgage in d ustry. t A California a i bankruptcy court, f ollowing landmark cases in other o jurisdictions, recently h e ldth t a t this i e1 t om hort t k impossible for banks to esta stablish their ownership of property titles and therefore to foreclose on mortgage d prope rt ies.. The logical result could be 62 mi illion ion homes that a are foreclosure-proof. M' rities ' were a favorite inves tm en t o f speculators at the height of the in u to the crash of The securities c h ange dan h d s f 1» d h companies profiting from mort g a g e p aym y ments were often not t tht e same pa rt th t ot t d th loans. At the heart of this disconnect was the Mortgage E Iectronic rome Registration e ' System, or MERS, a company that serves as the mo rt g a gee ofrecord d or f 1 en d ers, allow a ing properties to change hands without the necessity of recording each transfer. mort a e industry, but courts are now questioning t e im p act of all 11 plaintiffmustbe ab ble e to o establish the chain of title entitling it to relic. u acknowledged, and recent cases have held, that MER ERS is a mere "nominee" n an entity appoin e r the u ose of holding property rty in rde or er r t o facilitate transactions. Recent court opinions stress that this defect t is not just a procedural but u is a substantive failure one that is fatal to the plaintiff's legal ability to foreclose. T h tmeanshordesofvictimsofpredatory ato l endin ingcou could end e up owning their homes free and clear while the financial industry could end up skewered s e on its own swor. MAS S LITIGATION AL LIAN C K

11 ' LITIGATION CASE CRITERIA PROOF OF NOTE SECURITY M ritized,packaged, sold, and resold our mortgages, they created a system where it is o often im possible to figure out w o ac ua notes and therefore has the e authorit y to foreclose on properties.. But u the big banks are eir own web. Recent events have expose d a handful of banks i s out of their homes even t h oug h th ey do 't h th ort note that proves they actua tuall y have a legal right to o so. Th ere h b two banks t trying ot o foreclose on the same home, and in at a least one o case, of a bank trying to foreclose on a house whe here the h h homeowner er had a ne ver even taken out a mortgage with anyone in the first place. PROOF OF NOTE SECURI CURITY (PATRIOT ACT VIOLATIONS) Not only do banks s have to prove the e documentation of the origin ' al note the must ndin on each speci ic no te e transaction. Banks have to rovide evidence of a securitization poo 1 as as pproof of funds but h led t h i s as inadequate evidence. TT h e t two o major 'o h 11 thi T he sheer impossi 'b'i'ey i i' o f banks a n being able to unwind mortgage poo s individual investors tied to individual property Banks unwillingness to disclose the participa atin ing e n t ities within the investment pools. MAS S LITIGATION AL LIAN C K

12 POTENTIAL CASE OUTCOMES '";: MASS LITIGATION LLIANCE

13 POT E NT IAL CAS E OUTCOME S Potential Case Outcomes MLA cannot and will not provide a guarantee of any specific outcome. Litigation is a calculated decision based on various case and legal precedence. MLA feels the preceding cases carry extreme merit that may carry the following potential outcomes: Pre Trial Settlement Amnesty Program Full Lien Strip MAS S LITIGATION AL LIAN C K

14 POT E NT IAL CAS E OUTCOME S PRE- TRIAL SETTLEMENT As each client joins the mass join oinder action the lender will receive a pre-trial s ettlement of f er per th e f ollowi n g terms.(note we are not nego ia ing, using legal document demands on Form 998) P rincipal loan balance re d uce d t o 80% 0 of current market value. Interest rate reduced to 2% fixed for life of loan. AMNESTY PROGRAM Counsel will be working with legislation to create an potential amnesty 'll likel b e a universal modification approach. If successful,, this process wi 11 i n d e mni n if yt h e lending institutions from mu trillion dollar litigation while provi rovidin ingh omeowners universal term reductions. Counsel anticipates our clients "havin ga seat at t h e tab l e " wi'llbe offered increased settlement options. FULL LIEN S TRIP This is the desired and intentional outcome of each o of the e6 Mass Joinder law suits. Counsel has stated they are seeking a complete dismissal of the lien. MAS S LITIGATION AL LIAN C K

15 LITIGATION PROCESS '";: MASS LITIGATION LLIANCE

16 LITIGATION PR.OCESS L itigation of this size is a very comp corn lex and itime m e consuming process. The following is a VERY brief outline of the litigation process: A ttorney Retain e r Agreement Execu uted C opy of the Deed o f T r u st k, Copy of Note submitted wi ith file 998 Offer and Compromise (30 day wait) Seek foreclosure injunction / moratorium Plaintiff update from counsel every 30da ys Settlement Offer Case Resolution MAS S LITIGATION AL LIAN C K

17 ARTICLES R. VIDEO LINKS Homeowners Sa Loan Mods Lead Them to Foreclosure Si n On San Die o The Human Face of "Robo-Si nin " Real In Fusion Courts Hel in Banks Screw Over Homeowners Rollin Stone Ma azine GMAC Foreclosure Case Ma Set Anti-Bank Precedent Business Week Some ud es chastise banks over foreclosure a erwork Washin ton Post Fi ht over who has le alri htto foreclosemakes mess worse ~USA Toda Mort a e Mess: Shreddin the Dream Business Week Foreclosure Mess More Shoes to Dro? Mone Talks News Tired "Robo-Si ners" Let Other Peo le Si Mone Talks News T h eir Names Bi Problems for Banks: Due Process New York Times Landmark Decision Promises Massive Relief For Homeowners And Trouble For Banks Web Of Debt.com The Newest Foreclosure Mess Ohio Attorne General Sus ects 'Thousands' Of Cases Of Foreclosure Fraud Faul Pa erwork Prom ts Dee enin Foreclosure Problem PBS News MERS "Foreclosure Proof' Homes Fox News Insider Lenders Must Now 'Produce The Note' CNN Foreclosure News Banks Foreclose On Homes That The Don't Own Produce The Note Good Mornin America Fi ht Foreclosure Demand The Banks Produce The Note! MAS S LITIGATION AL LIAN C K

18 Yet ING R. CONTACT INFO YOUR MLA CLIENT AMBASSADOR t Thank you for taking some time to learn m as an e r i can homeowner. Lenders an and a banks s h ave ha been given billions so s f d o 11a r s tohel p resol ve an epidemic housin sing challenge. very little of o those funds have truly resulted in in omeowners horn balances reduced an" interest rates lowered to o provide the much needed relief these e s e fundn d s were intended to ppo su ort.. Re c ent case precedent as well as many news sources ppoint to o an even larger problem that of bank &aud. NOW IS THE TIME TO FIGHT BACK>>> If you would like more information re ar ass Joinder Litigation process please contact your MLA c 1ient ambassador. We look forward to serving you during this challenging time. /I Mass Litigation Alliance»»*»»»» '". MASS LITIGATION

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