01.26
(Filed in Bucks County PA)
1. The Letter from Kevin Cornwall dated February 12, 2014 indicates the preference of the Defendant to continue to conduct business with First Savings Bank of Perkasie.
2. Defendant has had an ongoing personal and professional relationship with First Savings Bank of Perkasie conducting business and financing construction projects for over 15 years.
3. The document referred to as the ASSIGNMENT OF MORTGAGE dated December 13, 2013 was prepared by Nicole Plank, Esq.
4. The ASSIGNMENT OF MORTGAGE directly refers to “all that certain Mortgage executed and delivered by Defendant dated April 15, 2002 and recorded with the Recorder of Deeds Office of Bucks County, Pennsylvania in Book 2686, Page 1508, to secure the payment of the sum of $400,000…”
5. A MORTGAGE was executed between First Savings Bank of Perkasie and Defendant on April 15, 2002 for the principal sum of $400,000.00 and recorded with the Recorder of Deeds Office of Bucks County, Pennsylvania in Book 2686, Page 1513, 1514, 1515.
6. The MORTGAGE executed on April 15, 2002 includes the following paragraph at 16:
Payment to the Mortgagee by the Mortgagor shall begin as demanded by the Mortgagee and shall be paid on the first day of each month thereafter or as required by the Mortgagee and under all events, payments of interest, unpaid principal and all amounts due under this Mortgage and accompanying Mortgage Note shall be fully paid on of before MAY 1, 2003.
7. As of May 1, 2003, the Mortgage indicated in the ASSIGNMENT OF MORTGAGE dated December 13, 2013 was satisfied – ALL payments of interest, principal, and amounts due on the Mortgage were completed.
8. On December 13, 2013, the ASSIGNMENT OF MORTGAGE prepared by Nicole Plank, Esquire referred to a mortgage which had been satisfied since May 1, 2003 as was required by the original Mortgage document.
9. On December 13, 2013, the ASSIGNMENT OF MORTGAGE prepared by Nicole Plank, Esquire “in consideration of the sum of One Dollar ($1.00) lawful money, unto it in hand and paid at the time of execution thereof, the receipt whereof is hereby acknowledged, does hereby grant, bargain, sell, assign, transfer, and set over unto KTMT NEWBURY, LP, a Pennsylvania limited partnership with an address of 1030 Reed Avenue, Suite 100, Wyomissing, Pennsylvania 19610” …
KTMT NEWBURY, LP received a satisfied mortgage to which there would be no future revenue or income.
10. The prolonged litigation where no hearings have been held seeks to convert an expired and satisfied mortgage into property ownership through the manipulation of the Court Administration and the Judiciary
11. Compensation for this fraud and concealing the improper initial foreclosure action would be the deed to a property currently valued at $1.2 million.
12. Compensation for also concealing the improper foreclosure action initiated by Jeffrey Trauger of Grim, Beihn and Thatcher on behalf of First Savings Bank of Perkasie.
13. Jeffrey Trauger, and the law offices of Grim Beihn and Thatcher have multiple prior, and current, attorney-client relationships with the involved parties, and county personnel and departments which obstruct and prevent justice and deny the Rule of Law pursuant to a mandate under Rule 1.6 Confidentiality of Information.
14. Rule 1.6 collaterally affects, undermines and denies the constitutional rights of the Defendant.
15. Rule 1.6 conceals the truth and the facts of the matter from being presented to this Honorable Court where lawyers are required to maintain confidentiality pursuant to this unconstitutional mandate.
16. Where the rights of the Defendant are affected, the Supreme Court of Pennsylvania was without constitutional authority pursuant to Article V Section 10(c) to enact Rule 1.6.
WHEREAS, The Defendant respectfully requests this Honorable Court refer the matter to law enforcement for investigation and criminal prosecution by an person unencumbered by obligations of attorney-client privilege and confidentiality which would affect justice and deny the Rule of Law as indicated in Defendant’s MOTION FOR INVESTIGATION (Filed Concurrently and incorporated herein).
Respectfully,
No Comment.
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