IN THE MATTER OF RESIDENTIAL

MORTGAGE FORECLOSURE PLEADING

AND DOCUMENT IRREGULARITIES
FILED Aug 15, 2011
)
) SUPERIOR COURT OF NEW JERSEY
) CHANCERY DIVISION-
) GENERAL EQUITY PART
) MERCER COUNTY
)
) DOCKET NO. F-059553-10
)
) CIVIL ACTION
)
) REPORT OF THE SPECIAL MASTER
) CONCERNING JPMORGAN CHASE
) BANK AND CHASE HOME FINANCE
_____________________________ ) LLC
INTRODUCTION
On December 20,2010 Chief Justice Stuart Rabner announced emergency reVISIOns to the
Rules of Court and a series of other steps to ensure the integrity of filIngs of documents In
residential mortgage foreclosure proceedings in New Jersey. The Chief Justice acted after
widespread publIc disclosure of irregularities stemming from a practice known as "robo-slgnlng"
utilIzed by mortgage lenders and servicers throughout the country and after review of va no us
documents including a report hy Legal Services of New Jersey, entitled "Report and
Recommendations to the New Jersey Supreme Court Concernmg False Statements and Sweanng
In Foreclosure Proceedings." The Legal Services report and other material reviewed cited
problematic certification and evidentiary practices in the following areas:
1. Lack of personal knowledge of an affiant whose certificatIOn states that s/he has
personal knowledge.
2. Failure to review documents or other evidence on which the certificatIOn is based
and which it may generally reference.
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3. Actual false statements about when and how a loan has been transferred since Its
originatIOn.
4. False identification of signatory.
5. Forged sIgnatures.
6. Execution outside the presence of a notary, who nevertheless notarizes the
sIgnature.
On a natIOnal scale these kinds of irregularities in preparation of documents to support
mortgage foreclosures manifested themselves in a practice that became known as "robo-signIng,"
where a person would sign hundreds of affidavIts or certificatIons a day with no personal
knowledge of the contents of any of them. In many instances the underlyIng facts asserted In the
documents submitted to support foreclosures may have actually been true but because of the
false representations concernIng the process by whIch the documents were created, there was no
way for courts to be able to separate assertions that were accurate from those that were not.
If each uncontested mortgage foreclosure were to be heard by a judge wIth the
presentation of oral testimony, the judge could cross-examIne the witnesses to determine the
reliability and veracity of testimony presented. However, uncontested foreclosures represent
over 90% of all residential mortgage foreclosure proceedings pending in New Jersey and
presentation of oral testImony IS not a sensible or practIcal way to resolve the thousands of
foreclosures filed every year. Therefore courts have traditionally relied upon the truthfulness of
affIdaVIts or certIfications submitted to support a mortgagee's request for a judgment of
foreclosure. When confidence in the reliabilIty of such submissions is lost, the court must be
persuaded by the mortgagee that It has processes and procedures in place that wIll restore the
necessary confidence to justif'y the court's reliance on documents submitted.
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Toward that end, on December 20, 2010, General Equity judge Mary C. jacobson,
designated by the Chief Justice to oversee uncontested foreclosure cases In the State, entered an
Order to Show Cause directed at: Bank of America, d/b/a BAC Home Loan Servicing, LP; Cltibank,
N.A. and Cltl Residential Lending, Inc.; GMAC Mortgage, LLC; jPMorgan Chase Bank, N.A. and
Chase Home Finance LLC; OneWest Bank, FSB; and Wells Fargo Bank, N.A. (collectively,
"Respondents") requiring each to show cause why the processing of pending uncontested
reSidential mortgage foreclosure actions filed by them should not be suspended. WhIle the Order
to Show Cause did not order an immediate suspension of foreclosure processing for the
Respondents, de facto there has been such a suspension, either because Respondents or some of
them had earlier ceased processing foreclosures in New jersey on their own while attempting to
address the "robo-slgnIng" Issue or because the effect of the Rule Amendments, as worded in the
December 20th emergency revisions, was to make it Impractical or unfeasible for Respondents to
pursue foreclosures.
The six Respondents were selected specifically for the Order to Show Cause for two
reasons. First, the SIX Respondents account for a large majority ofthe foreclosure actions In the
New jersey courts. Any Judiciary-wide correction of the "robo-signing" Issue in the State of New
Jersey must logically begin with these SIX Respondents. Second, the six Respondents were
selected for inclusion In the Order to Show Cause because there has been depOSition testimony
and/or other materials forming a public record In various jUrISdictIOns across the United States
indicating that each of the SIX Respondents has encountered "robo-signIng" problems concerning
their foreclosures in the past.
In response to the Order to Show Cause, Respondents and court appointed counsel
entered into diSCUSSions resulting in a Consent Order. That Order appointed a Special Master
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charged with responsibility to conduct a review to determme whether each of the respective
service providers has processes and procedures in place which, if adhered to, will ensure that the
mformation set forth m affidavits/certificatIOns submitted in foreclosure proceedmgs IS
personally reviewed by an affiant authorized to act on behalf of the plamtlff in the foreclosure
actIOn and that each affidavit or certification submitted is properly executed and IS based upon
knowledge gained through a personal review of relevant records which are made in the regular
course of business as part of the regular practice of that business to make them. The review also
contemplated a process to verify that the respective servicers are, in fact, adhering to those
processes and procedures following the resumptIOn of residential mortgage foreclosure activities
m New jersey.
While there has also been much public discussion and litigatIOn concerning complex
Issues relatmg to the standing of mortgagees and loan servicers to foreclose, including Issues
flowmg from the securItization of mortgages, assignments of mortgages, and the utilization of
Mortgage Electronic Registration Systems, Inc. ("MERS"), these broad issues of standing,
assignments, and MERS, though important, are beyond the scope of the Special Master's charge.
The focus of the Consent Order entered by judge jacobson is on Respondents' busmess practices
and procedures that generate the sworn documents that are submitted to the Judiciary in support
of fmal Judgments and other relief requested in uncontested foreclosure cases. Nothing m this
report is Intended, nor should be construed In any way, to prejudge or comment on Issues
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concerning a plaintiffs standing to foreclose in any indiVidual case.
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THE REVIEW PROCESS
The review by the Special Master is systems orIented and not intended to deal with
individual pending cases, although selected individual cases may be reviewed as part of the
process. The first phase of the review process, involving an examination of the respondents'
business practices, required that each respective servlcer make a prima facie showing that It has
processes and procedures in place which, If adhered to, will assure the JudiCiary that It can rely
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on the veracity of representations contained in documents filed by the servlcer. Upon a
determinatIOn that such a showing had been made the Judiciary would resume proceSSing
uncontested foreclosure cases filed by the servicer. The second phase, to be commenced later,
will involve a monitoring process to ensure that the servicers' processes and procedures are
effective and, in fact, are being followed.
In determining whether a respondent had made the requisite prima facie shOWing the
inquiry focused on three major areas:
1. Respondent's authority to pursue the foreclosure proceeding.
2. The admissibility in evidence of data from Respondent's records.
3. The reliability of Respondent's document preparation and execution process.
As part of the inquiry in the first phase of thiS work, each Respondent was directed to
respond to the following requests for Information about ItS business processes:
(a) If the Respondent is acting on behalf of a mortgagee, but is not the
mortgagee Itself, provide examples of the source of the Respondent's authOrIty to
act, including providing representative samples of documentation evidencing the
authority to act on behalf of mortgagees;
(b) Does the Respondent have a record keeping system of Business
Records that provides accurate up to date information on the payment history and
status of the loan? If so, describe the system;
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(c) Describe the Respondent's case processing steps for the review of
Information contaIned in, and the executIOn of, affidavits/certifications submitted
In support of foreclosure proceedings;
(d) Has the Respondent established specific procedures for staff to
ensure that the Information! set forth In affidavits/certificatIOns submitted In
foreclosure proceedIngs is based on a personal review of BusIness Records? If so:
(e)
(i)
(ii)
I
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DescrIbe the procedures;
,
Produce ,!II documents eVidencing establishment of the
procedures;
(Iii) Produce samples of all documents or screens reviewed by
staff in the affidavit/certification of indebtedness process;
and I
(IV) ProVide the numerIcal range and average of how much
tIme is per loan to review the Respondent's busIness
records a'nd complete an affidaVit/certification of
indebted hess.
Has the Respon6ent implemented a traInIng program for Its staff to
,
review relevant Business Records and source documents and complete foreclosure
affidavits/certifications a personal review of such materials? If so:
(i) Describe! the program;
(il) Produce copies of all written materials used and screen
samples from any powerpoint or other presentations; and
(Iii) Produce 'a statement that all staff who are preparing
have received thiS training.
!
(f) Has the Respo'ndent established quality assurance procedures to
insure that the established drocedures for review of relevant source documents
and completion of affidavits/ certifications based on a personal review
of BUSIness Records are In each case? If so:
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(I) Describe the procedures; and
(Ii) Produce copies of all documents eVidencing establishment
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of quality assurance procedures.
(g) Does the RespJndent have a process for inSUrIng effective and timely
communication with foreclosure counsel in connectIOn with the completion and
executIOn of foreclosure affidavits/certificatIOns? If so:
(i) Describe the process; and
(ii) Describe the procedures that will enable foreclosure counsel to
comply with their duties concerning the completion and execution of
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foreclosure affidavits/certIfIcatIOns, under the Court Rules as they
are finally adopted by the New Jersey Supreme Court.
After reviewIng the documentation submItted, the Special Master and counsel to
the Special Master conducted follow-up telephone conferences on a number of occasIOns
wIth representatIves of each respondent to obtain further explanation and clarIficatIOn of
the materials submItted and to request supplemental InformatIon. Each respondent
provIded the clarIficatIOn, explanatIOn, and supplemental information by way of at least
one supplemental certIfIcatIOn. If further clarIficatIOn or supplemental InformatIOn was
reqUIred, this was communicated to the respondent through counsel and additional
certIfIcations were submitted.
FINDINGS
The InitIal PrIma FacIe submlssIOn
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of JPMorgan Chase Bank and Chase Home FInanCIal
LLC was accompanIed by the affidavit of Michael R Zarro, Senior Vice PreSIdent in charge of
Default Specialty Operations, who IS responSIble for support, management, and dIsposItIOn of
assets secured by real estate, IncludIng the foreclosure process. Mr. Zarro's affidavit provided
background information about JPMorgan Chase's mortgage loan serVICIng operatIons, as well
detaIls concernIng: Chase's sources of authority to act as servicer for non-Chase mortgagees;
Chase's system of record; ItS case processIng steps and workflow for certifIcations and affidavIts
submitted In support of foreclosure proceedings; Chase's training and quality assurance
programs concernIng foreclosure documents; and Chase's processes for commUnIcatIOns wIth
foreclosure counsel. NIneteen exhibits accompanied Mr. Zarro's affidavit, which included: sample
1 The entire JPMorgan Chase & Co. and Chase Home Finance submission has been filed on the
Judiciary website at http//www.judiciary.state.nj.us/superior/f5955310.htm
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powers of attorney and pooling and servicing agreements, sample foreclosure affIdavits and
screenshots, foreclosure document execution procedure manuals, training materials, and quality
assurance materials.
Thereafter, jPMorgan Chase and Co. submitted a supplemental filing which consisted of an
affidavit from ChriS Collins, a Vice President of Foreclosure OperatIOns at jPMorgan Chase Bank,
N.A. Mr. Collins's affidavit provided additional detail concerning jPMorgan Chase & Co.'s
acqUisition of former Bear Stearns-related servICing company EMC Mortgage Corporation and the
May 2011 merger of Chase Home Finance LLC into jPMorgan Chase Bank, N.A. Mr. Collins also
described additional information about Chase's use of third party vendors in its foreclosure case
processing, Chase's procedures concerning acceptance of payments after a case has been referred
to foreclosure, and Chase's oversight and supervIsion of, as well as communications With
foreclosure counsel. Mr. Collins attached four exhibits to his affidaVit, all of which dealt with
Chase's acqUISitIOn of EMC Mortgage Corporation and the Chase Home Finance LLC merger.
jPMorgan Chase & Co. is a financial services holding company. Respondent jPMorgan
Chase Bank NA ("Chase") is a subsidiary of the holding company and a national banking
association With branches in 23 states. Chase Home Finance LLC ("CHF"), a former subsidiary of
Chase, was a mortgage servlcer responsible for the day-to-day management of loan accounts,
including handling customer inquIrIes, collecting and crediting loan payments, reporting and
remitting to investors, payment of taxes and insurance, engaging in loss of mitigatIOn efforts With
borrowers, and pursing foreclosure proceedings. Effective May 1, 2011, CHF merged into Chase
and Chase is now the servlcer of the residential mortgage loans prevIOusly serviced by CHF.
Chase has certified that all processes and procedures detailed in Chase's submiSSIOns in thiS
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matter are unaffected by this merger and any practices referred to as being those of CHF apply
equally to Chase.
Chase serVices loans orIginated by Chase as well as loans orIginated and/or owned by
other lenders. Chase does not act as a sub-servicer for other servlcers. Chase is the serVlCer on
approximately 10,000 loans that are the subject of pending foreclosure proceedings in New
Jersey. As of April 1, 2011, Chase acquired the serVicing rights to loans previously serViced by
EMC Mortgage Corporation. As to those loans Chase will follow the same procedures that it uses
to execute all other foreclosure affidavits.
RESPONDENT'S AUTHORITY TO PURSUE FORECLOSURE PROCEEDINGS
The first element of proof in any type of case is to establish that the party Initiating
the proceeding has authority to ask the court for relief. Respondent is involved herein in
Its capacity as a mortgage loan servlcer. In some foreclosure cases initiated by Respondent
it may be servicing Its own mortgage loan. But In other cases it may be servicing the
mortgage loan of an Independent party. For that reason the inqUiry began with an
examination of Respondent's authOrIty to pursue foreclosure proceedings under the
various Circumstances in which it appears before the court
There are three types of arrangements by whICh Chase serVices loans' (1) loans orIginated
by Chase, (2) loans originated and/or owned by other lenders including Government Sponsored
Enterprises, such as Fannie Mae and Freddie Mac, and (3) pools of loans held by prIvate Investors
in securitized trusts.
For those loans originated by Chase, the authority to proceed Will be grounded In the
documents evidencing the mortgage loan. In cases where Chase acts as a servicer for a
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Government Sponsored Enterpnse (GSE) It wIll do so pursuant to an agreement that Incorporates
the terms of GUIdelInes publIshed by the GSE. By way of example, page 801-3 of the Fannie Mae
2010 Servicing Guide Update Part VII and Part Vlll, dated Apnl 2010
2
, reqUIres servlcers
generally to InItiate "foreclosure proceedIngs for a first mortgage loan ... 30 to 34 days after an
acceleratIOn or breach letter is sent upon the completIOn of the pre-referral account revIew and
after any applicable notice and waItIng period under state law IS met." The Servicing GUIde, page
801-1, also provIdes: "A servicer must process foreclosures, conveyances, and claims in
accordance with the provisions of the mortgage loan; state law; the requirements of FHA, HUD,
VA, RD, or the mortgage Insurer; and any special requirements that Fannie Mae may have."
Freddie Mac's Single-Family Seller/Servicer Guide at Section 66-1 provides that "the Servicer
must initIate foreclosure in accordance with this chapter when there is no viable alternatIve to
foreclosure." The GUIde also reqUIres the Servlcer to manage the foreclosure process to acqUIre
tItle to the property in a cost-effective and efficient manner.
When servIcIng mortgage loans for a Government Sponsored Enterprise the GSE usually
requIres that the foreclosure proceeding be InitIated in the name ofthe servicer. For this reason
Chase will obtain possession of the note prior to initiatIng the proceedIng. Thus Its authonty to
prosecute the foreclosure actIon is also grounded In the fact that it is the holder of the note.
With regard to the thIrd category of loans, loans held by prIvate investors In securitized
trusts, Chase provIded three sample Pooling and Servicing Agreements. The first sample
Agreement contaInS the folloWIng provision:
The Servicer shall servIce and admInIster the Mortgage Loans and
shall have full power and authority ... to do any and all things which it
may deem necessary or desirable in connectIOn WIth such servIcing
2 The Fannie Mae 2010 ServicIng Guide Update Part VII and Part VIII is available at
https:/ /www.efanniemae.com/sf/guides/ssg/svcg/svc042810.pdf.
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and admInistration, all In accordance wIth Accepted ServIcIng
PractIces.
The Agreement further provides:
The Servicer, on behalf of the Trustee, shall foreclose upon or
otherwise comparably convert the ownershIp of Mortgaged
PropertIes (or stock allocated to a dwelling unit, in the case of a Co-
op Loan) securIng such of the Mortgage Loans as come Into and
continue in default and as to which no satisfactory arrangements can
be made for collection of delinquent payments pursuant to SectIOn
5.07 ....
The Agreement also has attached to it, as an exhibit, a Form of Special ServIcing and
Collateral Fund Agreement that states, In relevant part, as follows:
In connection wIth any Mortgage Loan Identified In a report under
SectIOn 2.01(a)(I)(B), the Purchaser may elect, for reasonable cause
as determined by the Purchaser, to instruct the Company to proceed
wIth the Commencement of Foreclosure as soon as practIcable. Such
election must be eVIdenced by written notice receIved by the
Company ....
The second sample agreement contains the same sectIOns as those CIted above.
The third sample agreement contains the following provisions, In relevant part:
The Servlcer shall service and administer the Mortgage Loans, as
servicer, on behalf of the Trust Fund and in the best Interests of and
for the benefIt of the Certlficateholders (as determined by the
Servicer In accordance wIth Accepted ServicIng PractIces) In
accordance with the terms of this Agreement, the Mortgage Loans
and Accepted Servicing Practices ..
... [T]he Servlcer ... ls hereby authorized and empowered ... to instItute
foreclosure proceedings or obtain a deed-in-lIeu of foreclosure ....
As further proof of its foreclosure authority, Chase has supplied three sample powers of
attorney. The fIrst sample Includes among the powers granted, the folloWIng:
With respect to a Mortgage or Deed of Trust, the foreclosure, the
takIng of a deed In lIeu of foreclosure or the completion of judIcIal or
non-judicial foreclosure or termination, cancellation or recessIOn of
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terminatIOn, cancellation or rescissIOn of any such foreclosure,
including, without limitation, any and all of the following acts:
a. the substitution oftrustee(s) serving under a Deed of Trust,
in accordance with state law and the Deed of Trust;
b. the preparation and issuance of statements of breach
or non-performance;
c. the preparation and filing of notices of default
and/ or notices of sale:
d. the cancellation/rescission of notices of default and/or
notices of sale;
e. the taking of a deed in lieu of foreclosure; and
f. the preparation and execution of such other documents and
performance of such other actions as may be necessary under
the terms of the Mortgage, Deed of Trust or state law to
expeditiously complete said transactions in paragraphs 8.a.
through 8.e., above ....
The other two powers of attorney contain Similar language.
Respondent has certified that the categorIes cited accurately descrIbe the types of cases it
has filed with the court in its capacity as a mortgage loan servicer. It has also certified that the
examples submitted are representative of its source of authority to prosecute foreclosure
proceedings In such cases. For the purposes of this review, Respondent's submissIOn meets the
standard of a Prima Facie showing that it has authority to ask the court for relief in the
foreclosure proceedings within its portfolio.
ADMISSIBILITY OF DATA FROM RESPONDENT'S RECORDS
An essential element of proof in a foreclosure case is the existence ofa note and mortgage
and a default on the part of the mortgagor. Most typically the claim of default IS based on
allegations of non-payment of amounts due on the note. To prove that fact, the servicer of the
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mortgage will usually offer proof In the form of a statement of account produced from its records
Such evidence IS classified as "hearsay" under our Rules of Evidence. "Hearsay" evidence is
considered Inherently unreliable and is therefore generally inadmissible In court proceedings.
There are exceptIOns to thiS rule, however, where CIrcumstances warrant consldenng "hearsay"
eVidence as reliable. Evidence Rule 803(c)(6) is one of those exceptIOns, providing for
admissibility of data from business records under the following circumstances:
Records of regularly conducted activity. A statement contained in
a writing or other record of acts, events, conditions, and, subject
to Rule 808, opinions or diagnoses, made at or near the time of
observatIOn by a person with actual knowledge or from
informatIOn supplied by such a person, If the wnting or other
record was made In the regular course of business and It was the
regular practice of that business to make it, unless the sources of
informatIOn or the method, purpose or circumstances of
preparation Indicate that it is not trustworthy.
This inquiry has therefore focused on how Respondent maintains the data that it offers
as evidence to support ItS requests for judgments of foreclosure.
Chase uses an electrOnic record-keeping system known as Mortgage Servicing Package
("MSP") to maintain and update informatIOn concerning, among other things, the status of the
loan and payment history. MSP is a commercially available system that is widely used by the
mortgage servicing industry. Monetary transactions are posted on MSP in real-time (transactIOns
are batched and updated nightly). MSP also stores data about payments Chase makes on behalf
of the borrower, including tax payments and hazard insurance, as well as records of
communications with borrowers. Chase relies on the MSP system to store, retneve, and
otherWise access critical loan data for all loans In Chase's Servicer Portfolio, regardless of how
Chase came to be servicer of an individual loan or who owns the beneficial interest in the loan.
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Chase employs a number of Internal and external controls to ensure that the informatIOn
IS MSP is accurate and reliable, includIng real-time posting of transactIOns, dally reconciliations,
control self-assessment processes, Internal audit review, and testing by Chase's external auditor,
PncewaterhouseCoopers. Chase also relies on the integnty of its hard copy loan files, most of
which are maIntained In a secure facility of JPMorgan Chase Custody Services in Monroe,
Louisiana. These files typically contain original notes. [mages of those hard copy files are
maIntained on an ImagIng system.
Most borrowers receive monthly loan statements reflectIng, among other Items, the
unpaid principal balance, Interest rate, and the amount of the outstanding Indebtedness.
Borrowers also receive annual Form 1099 tax statements as appropriate. Escrow accounts for
taxes and lor insurance are reconciled at least once per year as required by federal law, and
borrowers are provided with annual escrow disclosure statements. Similarly, most borrowers
also have access to key Information about their loans through Chase. com.
Although Chase uses some outSide vendors to assist in the management of defaulted loans
and processing of foreclosures, Chase certifies that "there is no ability for the manipulatIOn of
core loan records" by these vendors.
[n order for informatIOn contained In the electronic record keepIng system to be admitted
In eVidence the record has to be made at or near the time of observation by a person With actual
knowledge, or from Information supplIed by such a person, and must be made In the regular
course of business as part of a regular practice of that business to make the record. The
Information in the electronic record keeping system will then be admiSSible unless the sources of
InformatIOn or the method, purpose or circumstances of preparatIOn indicate that It is not
trustworthy.
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For the purposes of thIs review, Chase has met the standard of a Prima Facie shoWIng that
data In Its record keeping system is entered at or near the tIme of the transactIOn recorded as a
part of a regular practice to make such records and that there is nothing in the sources of
information or the method, purposes or circumstances of preparatIOn to Indicate that the data IS
not trustworthy.
THE RELIABILITY OF RESPONDENT'S DOCUMENT PREPARATION
AND EXECUTION PROCESS
Including affiants and qualIty control personnel, Chase has approxImately 400 employees
Involved in the foreclosure document execution process. Prior to permitting them to execute
Affidavits of Indebtedness (HAOIs"), Chase trains all of Its document executIOn employees,
Including both affIants and the qualIty control personnel. Chase provides classroom training of
2 5 days for current employees and 10 days for new employees. All document executIOn
employees also take part In lab work in addition to their classroom training. After receIving the
classroom and lab traInIng, each employee then executes a Hscreening certificatIOn," which is an
AOI that sImulates the information and types of conditIons and or questions that the employee
wIll encounter in the field. After going through the "screening certIfication" process, each
employee meets one-on-one with outsIde counsel to confIrm their understanding of Chase's
document execution processes and practices. In additIOn, Chase's independent audIt group
revIews and audits the employees' understanding of the execution process. The training process
described applies to all Chase personnel involved in preparIng and executIng foreclosure
certifIcations. Chase does not use thIrd party vendors in its document revIew and execution
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process; all sworn documents executed by Chase in connection with residential mortgage
foreclosures for the Chase Servicer Portfolio are executed "In house" by Chase employees.
The document preparation and execution process begIns when Chase's Loan Review Team
concludes that foreclosure IS appropriate and refers the case to outside counsel Chase has
established a practice that once a mortgage loan IS In default and has been referred to counsel for
foreclosure, it will not accept partial payments on the loan unless such payments are submitted
pursuant to an express agreement between the bank and the mortgagor. If such an agreement IS
made, further prosecutIOn of the foreclosure will be ended. Upon referral to counsel, documents
necessary to pursue foreclosure are transmitted to counsel via LPS Desktop, a commercially
available system that faCilitates communication between counsel and servicers.
Counsel will then prepare drafts of the documents necessary to Initiate and su pport the
foreclosure. Chase has developed its own standardized, state-specific forms for the AOI that it
provides to local foreclosure counsel. In preparing the AOI, counsel will populate the caption,
leaving the remaInder of the document to be completed by the affiant. Counsel transmits the
documents to Chase USIng LPS Desktop.
The AOI is then reviewed and executed by a Chase foreclosure analyst using a 132-step
checklIst. USIng MSP, the affiant venfies all the informatIOn as It appears on the AOI. For example,
the affiant first verifies the property address and borrower name. Then the affiant verifies the
principle balance and reviews the file's foreclosure status as listed on MSP. The affiant reviews
the note and mortgage to match the name, address, and loan amount as appearIng on the AOI.
The affiant then hand writes the follOWIng informatIOn onto the AOI, either from personal
knowledge or from informatIOn on the note: affiant's name, borrower(s)'s name(s), affiant's
signing authority (i.e., title), ongInalloan amount, property address. Using MSP, the affiant
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confirms the mortgage figures on the MSP screen with the note, including the interest rate and
the original mortgage amount.
The affiant verifies the "Name to foreclose in" (i.e., Investor) on MSP and ensures that It
matches the plaintiff listed In the AOl's captIOn. If the plaintiff IS not one of six specifIed Chase-
related entIties the affiant will ensure that an appropriate power of attorney is in the file. The
affIant also reviews the total amount due on MSP and hand writes it into the AO!. After
performing this review the affiant prints the relevant documents from MSP and attaches them to
the AO!. The affiant then signs the AOI and gives the completed AO] to Quality Control.
After execution, every AOI is reviewed by a Quality-Check Analyst, who performs preCIsely
the same revIew of Information that the affIant performed to confirm that the informatIOn In the
AOI corresponds with Chase's business records on MSP. At present, Chase's Quality-Check
Analyst team performs thIs second, mIrror review for every AOI that Chase generates. Chase has
indicated that the revIew of 100% of affidavits and certifIcatIOns will continue until Chase
management determines that quality levels are consistently hIgh and support a more streamlined
review going forward. At that time Chase intends to use a system of random sampling of the
executed AOls. In addition to thIs quality control process, executed AOls will also be subject to
sampling by Chase's Independent Internal Audit team.
For the purposes of this review, the process descnbed by Respondent's submIssIOns meets
the standard of a Prima Facie showing that each certIfIcation submitted to the court is reviewed
and executed by an authorized person who has been trained in how to understand Respondent's
business records and source documents and who has personal knowledge of the content of the
relevant records and documents upon which the certification is based. Respondent has also
shown, on a Pnma Facie basis, that it has a training process and a post-certification review
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process to ensure that its established procedures are in fact followed. The process described In
these submIssIOns, If followed, could justify reliance by the court on the accuracy of the
informatIOn contained In certifIcations submItted to the court by the Respondent. This
conclusion should not be deemed as dispositive of issues in any individual foreclosure case, each
of whIch must be determined upon its own facts and record.
RESPONDENT'S OVERSIGHT AND COMMUNICATION WITH COUNSEL
DUrIng the period of this revIew the New Jersey Supreme Court adopted further
amendments to Rules 4:64-1 and 4:64-2. The pertInent part of revised Rule 4:61-4 provIdes;
In all residentIal foreclosure actions, plaintIffs attorney shall
'annex to the complaint a certification of diligent Inquiry:
confIrmIng that the attorney has communicated with an
employee or employees of the plaintiff or of the plaintiffs mortgage loan
servlcer (I) who personally revIewed the complaint and confirmed the
accuracy of its content, as mandated by paragraphs (b) (1) through
(b)(10) and (b)(12) through (b)(13) of thIs rule, based on bUSIness
records kept in the regular course of business by the plaintiff or the
plaintIffs mortgage loan servicer, and (ii) who, If employed. by the
plaintiffs mortgage loan serVlcer, (a) identified the relationship between
the mortgage loan servicer and the plaintiff, and (b) confirmed the
authorIty of the mortgage loan servicer to act on behalf of the plaintIff;
and
lID. statIng the date and mode of commUnIcatIOn employed
and the name(s), title(s) and responsibIlitIes in those titles of the
plaIntIffs or plaintIffs mortgage loan servicer's employee(s) wIth whom
the attorney communIcated pursuant to paragraph (2) (A) of this rule.
The revised Rule 4:64-2 now provides In relevant part:
(c) TIme: signatory. The affidavIt prescrIbed by thIs rule shall be sworn
to not more than 60 days prior to its presentation to the court or the
Office of Foreclosure. The affidavIt shall be made eIther by an employee
of the plaintiff, if the plaintiff servIces the mortgage, on the affiant's
knowledge of the plaintiffs business records kept in the regular course of
business, or by an employee of the plaintiffs mortgage loan serVlcer, on
the affiant's knowledge of the mortgage loan servicer's bUSIness records
18
kept in the regular course of busIness. In the affidavit the affiant shall
confirm:
ill that he or she IS authOrIzed to make the affidavit on behalf of the plaIntiff or
the plaintiffs mortgage loan servicer;
ill that the affidavit IS made based on a personal review of busIness records of
the plaIntiff or the plaintiffs mortgage loan serVlcer, which records are maintaIned In
the regular course of business;
ill that the financial Information contained in the affidaVit IS accurate; and
ill that the default remains uncured.
The affidavit shall also include the name, title, and responsibilities of the Individual,
and the name of hiS or her employer. If the employer IS not the named plaintiff in the
action, the affidavit shall provide a description of the relationship between the
plaIntiff and the employer.
Cd) Affidavit. Plaintiffs counsel shall annex to every motIOn to enter
Judgment in a residential mortgage foreclosure action an affidavit of
diligent inqUiry statIng: (1) that the attorney has communicated with an
employee or employees of the plaintiff or the plaintiffs mortgage loan
servicer who (A) personally reviewed the affidaVit of amount due and the
original or true copy of the note, mortgage and recorded assignments, If
any, beIng submitted and (B) confirmed their accuracy; (2) the date and
mode of communication employed; (3) the name(s), title(s) and
responsibilities In those titles of the plaintiffs employee(s) or the
employee(s) of the plaIntiffs mortgage loan servicer with whom the
attorney communIcated pursuant to this rule; and (4) that the aforesaid
documents comport With the requirements of R. 1:4-8(a).
The revisions to the Rules reqUire an examInatIOn of Respondent's procedures for
oversight and communicatIOn With foreclosure counsel. Chase's primary method of
communication with foreclosure counsel IS through LPS Desktop as previously explained herein.
However, Chase's employees are available to coun'sel via a variety of modalities, includIng
telephone and email. Chase IS also assigning specific affiants to work with each outside
foreclosure law firm it uses.
In order to ensure foreclosure counsel's compliance with the amended Rules deSCrIbed
above, a representative of Chase Will review the complaint, Chase's systems, the note and
mortgage (and recorded assignments, If any) to confirm the accuracy of the core facts alleged in
19
the complaint. The revIewer wIll record the results of the review in a written statement. This
statement of revIew wIll contaIn the name, title, and contact Information for the reviewer.
The WrItten statement of revIew WIll be imaged into LPS Desktop for counsel's review, and
a message confirming the transmIssion of the Image WIll be sent to counsel through LPS
Desktop's "intercom" functIOn. Chase has deSCrIbed thIs "intercom" function of LPS Desktop to be
"an electronIc messagIng system that provides for dIrect, two-way, personal communIcation
between foreclosure counsel and the reviewer." Foreclosure c'ounsel WIll then be able to raise
any follow-up questions, comments, or concerns with the reviewer through "intercom" or the
contact information set forth In the statement of review.
Chase certIfies that It has recently enhanced ItS practices concernIng oversIght and
supervIsIOn of foreclosure counsel. FIrst, under the current structure, an Attorney Management
team, made up of non-lawyer Chase employees, IS responsible for managing the overall
relatIOnshIp with foreclosure counsel. This group is in constant contact with foreclosure counsel.
and questions from counsel can be addressed and/or forwarded for appropriate action through
thIS group.
Second, Chase has established an independent team to conduct on-site audIt revIews of
foreclosure firms ThIS group does not report through Chase's foreclosure and bankruptcy
management.
ThIrd, Chase has created a new attorney management group within Chase's Legal
Department, known as the Attorney Oversight Group ("AOG"). The AOG conducts its own on-site
VIsits (separate from the audit team), reviews poliCIes and procedures, and prOVIdes support and
advice to Chase's businesspeople in charge of foreclosure management. The AOG is a team of
lawyers whose sole responsibility is the oversight and supervIsion of foreclosure, bankruptcy,
20
and evictIOn counsel The team is currently comprIsed of eight attorneys, plus a supervIsing
attorney and managing attorney. In addition to these ten attorneys, Chase is currently
interviewing and plans to add another two-to-four attorneys in the Immediate future. Over the
past several months, the AOG has developed a proprietary process for the superVISIOn and
oversight of local counsel, which includes regular on-site visits which last several days at a time.
PROPOSED DETERMINATION
Based on the submissions discussed herein it is my proposed determination that Chase
has shown, on a PrIma Facie basis, that It has processes and procedures in place which, if adhered
to, will ensure that the Information set forth In affidavits or certifications submitted in
foreclosure proceedings is provided by an affiant authorIzed to act on behalf of the plaintiff in the
actIOn and that each affidavit or certification submitted IS properly executed and IS based upon
knowledge gained through a personal review of relevant records which were made in the regular
course of business as part of Chase's regular practice to make such records. Chase has filed the
required ServICe Portfolio with the court and has certified that'all uncontested mortgage
foreclosure cases in that portfolio will be prosecuted under the processes outlined in Its PrIma
FaCie shOWing. Therefore it IS my recommendation that Chase be permitted to resume
prosecution of the uncontested residential mortgage foreclosure proceedings Included in its
Servicer Portfolio.
Consistent with paragraph 3 of the Court's March 29, 2011 Order Approving the
Recommended Stipulation and Appointing Special Master in thiS case, nothing in thiS report and
recommendation should be construed as altering or interfering With the rIght of any party to a
foreclosure action to contest the foreclosure in any way that party sees fit, nor altering or
21
interfering with the dIscretion of any Superior Court judge of the State of New jersey to
adjudIcate all Issues raIsed by the parties in contested foreclosure matters.
Respectfully submitted,
RIchard j. Williams
Special Master
22
New Jersey Courts
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Resi dent i al Mor t gage
For ecl osur e Or der s t o
Show Cause Fi l ed Pur suant
t o t he Apr i l 4, 2012
Supr eme Cour t Or der
" Mor t gage For ecl osur es - -
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Of f i ce of t he Super i or Cour t Cl er k
Jenni f er M. Pr ez, Esq.
Clerk
Richard J. Hughes Just ice Complex
25 W. Market St reet , 6t h Floor Nort h Wing
P. O. Box 971
Trent on, NJ 08625
609- 421- 6100
Fax: 609- 292- 6564
Direct ions
The Superior Court Clerk' s Office was est ablished by t he 1947 New Jersey St at e Const it ut ion ( Art . VI ,
Sect ion 7, Paragraph 3) . I t is a st at ewide clerks office for t he t rial court s. The t rial court s operat e at t he
local level, eit her count y or vicinage ( which is a court management region consist ing of one or more
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I n t he cent ral office, t he Superior Court Clerk is responsible for foreclosure case processing, st at ewide
j udgment processing, managing elect ronic access t o court records st ored in t he Judiciary' s case
management dat abase, t he Bail Suret y Program, and records management .
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Resi dent i al Mor t gage For ecl osur e Or der s t o Show Cause Fi l ed Pur suant t o t he Apr i l 4, 2012 Supr eme Cour t Or der
" Mor t gage For ecl osur es - - Not i ces of I nt ent i on t o For ecl ose - - I mpl ement at i on of Gui l l aume Deci si on"
Supr eme Cour t Or der Fi l ed - Apr i l 4, 2012
Click here t o search for your foreclosure case
I n Re Not i ces of I nt ent i on t o For ecl ose Ser v ed by AMS Ser v i ci ng, LLC
Dock et No. F- 17368 - 12
Document s Fi l ed - Updat ed August 30, 2012
I n Re Not i ces of I nt ent i on t o For ecl ose Ser v ed by Aur or a Fi nanci al Gr oup, I nc.
Dock et No. F- 16932 - 12
Document s Fi l ed - Updat ed August 30, 2012
I n Re Not i ces of I nt ent i on t o For ecl ose Ser v ed by Rushmor e Loan Management Ser v i ces, LLP
Dock et No. F- 15420 - 12
Document s Fi l ed - Updat ed August 9, 2012
I n Re Not i ces of I nt ent i on t o For ecl ose Ser v ed by Speci al i zed Loan Ser v i ces, LLC
Dock et No. F- 14989 - 12
Document s Fi l ed - Updat ed Jul y 31, 2012
I n Re Not i ces of I nt ent i on t o For ecl ose Ser v ed by BSI Fi nanci al Ser v i ces, I nc., on behal f of RESFUND LLC
Dock et No. F- 13792 - 12
Document s Fi l ed - Updat ed Jul y 31, 2012
I n Re Not i ces of I nt ent i on t o For ecl ose Ser v ed by Mi df i r st Bank
Dock et No. F- 12399 - 12
Document s Fi l ed - Updat ed Jul y 24, 2012
I n Re Appl i cat i on by Wel l s Far go Bank , N.A. To I ssue Cor r ect ed Not i ces of I nt ent t o For ecl ose on Behal f of I dent i f i ed
For ecl osur e Pl ai nt i f f s i n Uncont est ed Cases
Dock et No. F- 9564- 12
Document s Fi l ed - Updat ed Jul y 19, 2012
New Jer sey Cour t s Tak e St eps t o Ensur e I nt egr i t y of Resi dent i al Mor t gage For ecl osur e Pr ocess
March 1, 2011 - Order - Judge Walt er Barisonek Assigned as Superior Court Judge t o Serve As Special Mast er Pursuant t o
Administ rat ive Order 01- 2010
January 31, 2011 - Not ice and Order - Resident ial Mort gage Foreclosures - ( 1) Comment s Sought on December 20, 2010 Emergent
Rule Amendment s; ( 2) Suspension of Deadlines for Filing Cert ificat ions of Diligent I nquiry in Pending Cases
January 18, 2011 - Not ice - I n t he Mat t er of Resident ial Mort gage Foreclosure Pleading and Document I rregularit ies ( Administ rat ive
Order 01- 2010) - Submissions t o Special Mast er [ Barisonek]
January 7, 2011 - Not ice - Resident ial Mort gage Foreclosures - Cert ificat ions of Diligent I nquiry
Residential Mortgage Foreclosure Pleading and Document Irregularities
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December 20, 2010 - Press Release
December 20, 2010 - Not ice and Order - Emergent Amendment s t o Rules 1: 5- 6, 4: 64- 1, and 4: 64- 2 - Resident ial Mort gage
Foreclosures
December 20, 2010 - Administ rat ive Order Direct ing Submission of I nformat ion from Resident ial Mort gage Foreclosure Plaint iffs
Concerning Their Document Execut ion Pract ices t o a Special Mast er
I n t he Mat t er of Resi dent i al Mor t gage For ecl osur e Pl eadi ng and Document I r r egul ar i t i es
Super i or Cour t of New Jer sey , Chancer y Di v i si on - Gener al Equi t y Par t , Mer cer Count y
Dock et No. F- 59553 - 10
Document s Fi l ed - Updat ed Sept ember 12, 2011
I n t he Mat t er of Resi dent i al Mor t gage For ecl osur e Pl eadi ng and Document I r r egul ar i t i es
Admi ni st r at i v e Or der 01 - 2010
Uni on Count y
Dock et No. F- 00238 - 11
Document s Fi l ed - Updat ed Febr uar y 7, 2012
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I n t he Mat t er of Resi dent i al Mor t gage For ecl osur e Pl eadi ng and Document I r r egul ar i t i es
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Dock et No. F- 59553 - 10
Document s Fi l ed
Sept ember 12, 2011 Order as t o GMAC I ssued by Judge Mary Jacobson
Sept ember 12, 2011 Report of t he Special Mast er as t o GMAC
Sept ember 2, 2011 Supplement al Affidavit s - GMAC
August 17, 2011 Report of t he Special Mast er as t o OneWest Bank
August 17, 2011 Order as t o OneWest Bank I ssued by Judge Mary Jacobson
August 15, 2011 Report of t he Special Mast er as t o Bank of America
August 15, 2011 Order as t o Bank of America I ssued by Judge Mary Jacobson
August 15, 2011 Report of t he Special Mast er as t o Cit ibank
August 15, 2011 Order as t o Cit ibank I ssued by Judge Mary Jacobson
August 15, 2011 Report of t he Special Mast er as t o JP Morgan
August 15, 2011 Order as t o JP Morgan I ssued by Judge Mary Jacobson
August 15, 2011 Report of t he Special Mast er as t o Wells Fargo
August 15, 2011 Order as t o Wells Fargo I ssued by Judge Mary Jacobson
August 8, 2011 Supplement al Cert ificat ion ( Ebers) - OneWest
July 28, 2011 Cert ificat ion ( Kramer) - Cit ibank
July 28, 2011 Supplement al Cert ificat ion ( O' Brien) - Wells Fargo
July 28, 2011 Cert ificat ion ( Collins) - JP Morgan
July 28, 2011 Supplement al Cert ificat ion ( Cunningham) - GMAC
GMAC Exhibit 1
GMAC Exhibit 2
GMAC Exhibit 3
July 22, 2011 Supplement al Cert ificat ion ( Barron) - Bank of America
July 12, 2011 Supplement al Cert ificat ion ( Ebers) - OneWest
July 5, 2011 Supplement al Cert ificat ion ( O' Brien) - Wells Fargo
June 28, 2011 Supplement al Cert ificat ion - Cit ibank
Part 1
Part 2
June 27, 2011 List of Foreclosure Cases - JP Morgan
Part 1
Part 2
Part 3
Part 4
June 16, 2011 Supplement al Cert ificat ion - OneWest
June 16, 2011 Cert ificat ion in Support of Prima Facie Showing ( Wardlow) - Bank of America
June 16, 2011 Cert ificat ion in Support of Prima Facie Showing ( Kuret ich) - Bank of America
June 16, 2011 Supplement al Cert ificat ion in Support of Prima Facie Showing ( Barron) - Bank of America
June 16, 2011 Supplement al Cert ificat ion in Support of Prima Facie Showing ( Let t ) - Bank of America
May 27, 2011 Servicer Port folio - Wells Fargo
May 26, 2011 Submission in Support of Prima Facie Showing - OneWest
May 26, 2011 Submission in Support of Prima Facie Showing - Well Fargo
May 26, 2011 Submission in Support of Prima Facie Showing - Bank of America
May 26, 2011 Submission in Support of Prima Facie Showing - Cit ibank
May 26, 2011 Submission in Support of Prima Facie Showing - JP Morgan
May 26, 2011 Submission in Support of Prima Facie Showing - GMAC
May 12, 2011 Servicer Port folio - GMAC
May 9, 2011 Order Regarding Submission by GMAC I ssued by Judge Mary Jacobson
April 13, 2011 Scheduling Order ( GMAC) I ssued by Judge Mary Jacobson
April 13, 2011 Order Denying Mot ion t o Seal Servicer Port folios I ssued by Judge Mary Jacobson
April 7, 2011 Submission in Support of Prima Facie Showing - Bank of America
Residential Mortgage Foreclosure Pleading and Document Irregularities
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April 7, 2011 Mot ion t o Seal Service Port folios - All Respondent s
April 7, 2011 Affidavit - JP Morgan
April 4, 2011 Subst it ut ion of At t orney - Haber - JP Morgan
March 29, 2011 Let t er Brief in Opposit ion t o Mot ion t o I nt ervene ( Jyll S. Jakes) - Edward J. Dauber, Esq.
March 29, 2011 Let t er Brief in Opposit ion t o Mot ion t o I nt ervene ( Jyll S. Jakes) - Cit ibank
March 29, 2011 Order Approving Recommended St ipulat ion and Appoint ing Special Mast er I ssued by Judge Mary Jacobson
March 29, 2011 Order Denying Set on Hall Law School' s Mot ion t o I nt ervene I ssued by Judge Mary Jacobson
March 29, 2011 Order Denying Legal Services of New Jersey' s Mot ion t o I nt ervene I ssued by Judge Mary Jacobson
March 29, 2011 Order Denying Jyll S. Jakes' Mot ion t o I nt ervene I ssued by Judge Mary Jacobson
March 28, 2011 Mot ion t o I nt ervene - Jyll S. Jakes
March 28, 2011 Joint Opposit ion t o Mot ions t o I nt ervene - Wells Fargo
March 28, 2011 Let t er Brief in Opposit ion t o Mot ion t o I nt ervene ( Legal Services of NJ) - Edward J. Dauber, Esq
March 28, 2011 Let t er Brief in Opposit ion t o Mot ion t o I nt ervene ( Cent er for Social Just ice, Set on Hall Law School) - Edward J.
Dauber, Esq.
March 25, 2011 Amended Consent Order AD PR HC VC - Bank of America
March 25, 2011 Order I ssued by Judge Mary Jacobson on Mot ion t o I nt ervene from Cent er for Social Just ice, Set on Hall Law School
March 25, 2011 Order I ssued by Judge Mary Jacobson on Mot ion t o I nt ervene from Legal Services of New Jersey
March 25, 2011 Mot ion t o I nt ervene, Legal Services of NJ
March 24, 2011 Mot ion t o I nt ervene - Cent er for Social Just ice, Set on Hall Law School
March 22, 2011 Consent Order t o AD PR HC VC - Bank of America
March 21, 2011 Cert ificat ion for AD PR HC VC - Adams - Bank of America
March 21, 2011 Cert ificat ion for AD PR HC VC - Boland - Bank of America
March 21, 2011 Cert ificat ion for AD PR HC VC - Boyle - Bank of America
March 21, 2011 Cert ificat ion for AD PR HC VC - Cullen - Bank of America
March 21, 2011 Cert ificat ion for AD PR HC VC - Fennelly - Bank of America
March 18, 2011 Recommended St ipulat ion - Edward J. Dauber, Esq. , and Respondent s
March 18, 2011 Let t er Brief - Edward J. Dauber, Esq. , Counsel Appoint ed by t he Court
March 11, 2011 Scheduling Order I ssued by Judge Mary Jacobson
March 3, 2011 Cert ificat ion for AD PR HC VC - Brooks and McKeen - OneWest
February 24, 2011 Scheduling Order I ssued by Judge Mary Jacobson
February 9, 2011 Cert ificat ion - McKeon - JP Morgan
February 9, 2011 Scheduling Order I ssued by Judge Mary Jacobson
January 28, 2011 Scheduling Order I ssued by Mary C. Jacobson
January 24, 2011 Order AD PR HC VC - Karp - Cit ibank
January 24, 2011 Order AD PR HC VC - Huang - Cit ibank
January 24, 2011 Order AD PR HC VC - Velazquez - Cit ibank
January 24, 2011 Order AD PR HC VC - Ayers - GMAC
January 24, 2011 Order AD PR HC VC - Allen - GMAC
January 24, 2011 Order AD PR HC VC - Maddox - GMAC
January 19, 2011 Order AD PR HC VC - McKeon - JP Morgan
January 19, 2011 Order AD PR HC VC - McKeen - OneWest
January 19, 2011 Order AD PR HC VC - Brooks - OneWest
January 20, 2011 MTN AD PR HC VC - Karp - Cit ibank
January 19, 2011 MTN AD PR HC VC - Velazquez - Cit ibank
January 19, 2011 MTN AD PR HC VC - Huang - Cit ibank
January 14, 2011 MTN AD PR HC VC - Maddox, Allen, and Ayers - GMAC
January 12, 2011 Scheduling Order I ssued by Judge Mary Jacobson
January 7, 2011 Not ice of Ans Filed
January 7, 2011 FCI S - Cert - Cit ibank
January 6, 2011 Cert Serv - OneWest
January 6, 2011 FCI S - BOA
January 6, 2011 FCI S - JPMorgan
January 6, 2011 FCI S - OneWest
January 6, 2011 FCI S - Wells Fargo
January 6, 2011 Cert Serv - OneWest
January 5, 2011 BOA- BAC Home Response
January 5, 2011 GMAC- Ally Responsive Pleading
January 5, 2011 JPMorgan Chase Response
January 5, 2011 Wells Fargo Response
January 5, 2011 Cit ibank - Cit i Res Not ice of Appearance - Krovat in
January 5, 2011 Cit ibank - Cit i Resident ial Response
January 5, 2011 MTN AD PR HC VC - Brooks- OneWest
January 5, 2011 MTN AD PR HC VC - McKeen- OneWest
January 5, 2011 MTN AD PR HC VC - McKeon- JP Morgan
January 5, 2011 OneWest Bank Response
January 5, 2011 Cit ibank - Cit Res Not ice of Appearance - - Wells
December 20, 2010 - Order t o Show Cause I ssued by Judge Mary Jacobson - Resident ial Mort gage Foreclosures - Robosigning
Residential Mortgage Foreclosure Pleading and Document Irregularities
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JP Mor gan
I n t he Mat t er of Resi dent i al Mor t gage For ecl osur e Pl eadi ng and Document I r r egul ar i t i es
Super i or Cour t of New Jer sey , Chancer y Di v i si on - Gener al Equi t y Par t , Mer cer Count y
Dock et No. F- 59553 - 10
Document s Fi l ed
May 26, 2011 Submission in Support of Prima Facie Showing - JP Morgan
Part 1
Part 2
Part 3
Part 4
Part 5
Part 6
Part 7
Part 8
Part 9
Part 10
Part 11
Part 12
Part 13
Part 14
Part 15
Part 16
Part 17
Part 18
Part 19
Part 20
Part 21

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