Florida Rule 1.110(b) – Bank of America Verification of Foreclosure Complaint is a JOKE








No joke, really…

Open up Microsoft Word and pull up the JOKERMAN font and type it out…

Now we all know that these verifications are a joke but really???


Verification below…



I sure could use some…


Bank of America Verification of Foreclosure Complaint

18 Responses to “Florida Rule 1.110(b) – Bank of America Verification of Foreclosure Complaint is a JOKE”
  1. Diana says:

    Whippy, can you also send me a list of Robo-signer names? Where else can I go to look for a list of Robo-signer names??? Anybody know?

  2. Elaine S says:

    I sn’t the court clerk responsible for making sure there was a notarization on the “sworn” document before accepting it into the file?

    When are judges going to start “dismissing with prejudice,” whenever there is obvious fraud or perjury upon the court? Maybe its time to put some of the spotlight on the judges, and how many cases a day some of these rocket docket judges did in a day. They too have a responsibilty to know their cases so as to make informed decisions. If none or next to none of the paperwork is attached to an affidavit where an MBS is named, a judge should be able to tell the affidavit is potentially fraud on the court just by the lack of a stack of papers, cause I’ve read the average MBS ownership entails the mortgage/deed of trust having been transferred at least four times. Every transfer must have its own documentation to show the links of the chain of title, I do believe.

    And someone pointed out unelected judges have no right per the FL Constitution to be sitting for these foreclosure cases. Anyone know more about that? Or doing anything about that?

    How about a team of volunteers doing amicus briefs pointing out some of the obvious defects in files and all calling on one targeted judge to look at the entire set of his files himself, to cause the judge to be responsible as much as the attorney that plead it. Or just a team of volunteers watching a judge’s case load, and keep records of what foreclosures he’s hearing and do them same with them, after he has ruled. Offer the list of defects found to him. And be polite in pointing out that better given to him than to the press.

    Would an attorney put up a simple fill-in the blank form for filing such a submission? Each county may be different in some regards. A simple beginner’s checklist, and obviously not a complete one, could be of great benefit. I don’t know Florida but in my state, unless its sealed I can go and ask to look at the file of any case before the court.. If one judge had several volunteers go through say 5 files each for a simple list of possible defects. And called them all to his attention, then that judge would become very aware of what may have been glossed over before that point.

    And if you have a list of robo-signers and you’re sure of your information, please send them to states’ attorneys general, especially Att Gen Cordray in Ohio. He called for every case with a certain robo-signer’s name in the file from 133 judges in his state! . With that precedent maybe we can get this kind of call in multiple states for every known-to-be robo-signor, and every lender/servicer/MBStrustee known to be using robo-signers.

    Also who is comparing the signatures of notaries on their licensing document with the one they are using now? FL statute requires using the same name in their signature as they were commissioned under, not some initials. I do believe , by itself it is grounds to nullify the document that would need a valid notarization. Every judge should know to never accept a notary signature that is just an initial. How does one correctly subpoena a true copy of that licensing signature in the FL secretary of state’s records? Do a little research.
    Know your notary statute. Google ” FL Statute notary public law and read at least 4 or 5 entries. Reading one will often suggest the next sub-topic. and keep notes or print outs of what you found AND where you found it in a statute, by number, and so you can find it again.

    In my mind every attorney filing in defense of a foreclosure upon their client could claim the doctrine of clean hands, and demand dismissal with prejudice for lack of clean hands, or however that is technically done correctly. Maybe lack of standing for the entire Plaintiff-entity to come before the court in the state from now on?

    Remember, I do believe, that the principle is responsible for the acts of its agents and employees acting in the normal course of their assigned duties. If enough attorneys start screaming about unclean hands it could make a huge difference for a huge number of people.
    ( I am not an attorney, seek legal advise. Just educate yourself and prepare so you can use your attorneys time wisely.)

  3. Whippy FLoggman says:

    In Florida, the court fonts are 14 pt, double spaced.

  4. Dahotruth says:

    Welcome to McDonald’s …..Would you like fries with that affidavit?

  5. Whippy FLoggman says:

    Not Hartsler, its Robert Rybarczyk. I have a list of all BAC ROBO’s,

    • Joe Esquivel says:

      can you please send me the list of BAC Robo signers that you know of so I can compare them against the ones who are signing my documents.

      thank you

      • Whippy FLoggman says:

        Hey Joe,

        I have a List of all names, not signatures. However, you can look them up with relative ease if you want to view the signatures and multiple titles ( other than BAC ).. Give me your Email, and I will send you the pdf. in attachment.

      • Will you send them to me? I’m working on a game to let people whip through them in bulk but it’d be great to start w/ a set of signatures we know are real, or at least with something besides people just guessing. Working on getting it online; have one million docs to start, and that’s just the beginning; imagine there’s a couple hundred million for the crowd to scan through by the time the whole country’s records are online.

        Michael Olenick, olenick-at-legalprise.com

    • FightPredatoryLenders says:

      Whippy, could you send that list of BofA signers to me also. Thanks.

  6. Whippy FLoggman says:

    looks like BAC ROBO ” renee hartsler”. She has already been depo’ed.

  7. Matt Gutman says:

    I lost your number… sorry. Can you shoot me an email when you get a chance?

  8. Officer of the Law says:

    We are supposed to believe that all of these bankers and foreclosure mill attorneys are just stupid fools who don’t understand the law and make a bunch of mistakes like claiming that they have the right to foreclose when they don’t and accidentally forgetting to include any cap on the first adjustment in adjustable rate mortgage loans in spite of their promises and commitments.

    They seem to be so stupid that the foreclosure mill attorney for Bank of America left out the name of the Asst. Vice President (sic) of robo-signing.

    Isn’t that interesting. It seems really stupid because the name of the person making an affidavit is usually printed in the commencement, below the signature line, and in the notary’s certificate. The name of the person verifying a document is also printed in the commencement and below the signature line in the Florida Supreme Court approved forms.

    Could these crooks be so stupid that they just forgot to include the name of B of A’s robo-signer in this verification?

    I think that this shows that the bankers and their foreclosure mill minions understand that they need to avoid perjury charges. It looks like people are starting to realize that the prosecutors are the ones letting the banksters get away with their crimes, and it seems like they are starting to worry that some prosecutor might actually do something. I wonder whether they forgot to buy a couple off, don’t’ you?

    Since the identity of the person verifying this foreclosure complaint is not disclosed, if would be really hard to charge the robo-signer for perjury if the homeowner proved that the facts alleged in the complaint were not true and correct. All that everyone at B of A and its mill would have to do is say that’s not my signature, I don’t know who signed that, we have so many Vice-Presidents you know, they work long hours reviewing files and signing documents often for no pay, I guess that they were just so tired that they forgot to print their name on this verification, our attorneys are supposed to take care of that anyway. It wouldn’t even take any extra cash for a prosecutor to look the other way on that complaint.

    I would file a motion to dismiss for failure to comply with Fla. R. Civ. P. 1.110(b), or I would send B of A an interrogatory asking who signed this verification, and then, I would depose this robo-signer to see whether he, she or it reviewed the file as carefully as the verification.

  9. Am I missing something or is it missing the name of the person who signed? I mean there’s her signature but isn’t don’t the rules of judicial administration require the signer of a pleading to type or print one’s name beneath a signature?

    Anybody know what the numbers refer to?

  10. John R. says:

    Shame on you guys for publishing this. You know they only hire Ex Burger King employees to act as their Vice Presidents…. I mean how would you feel if it was your job to sign all these lousy pieces of paper that you didn’t understand what they were or what they were for and they made you use a word processor for the 1st time in your life and somehow you screwed up the font setting… hell… the person who wrote this probably doesn’t even know WHAT a font is yet! How embarrassing is that!

  11. James M says:

    OK – In what other ways, other than the funny font, is this defective ?

    1) Not a sworn and notarized affidavit. – but is done under penalty of perjury which in some cases is as good – but:
    there is no name of the person signing it. We have a scrawled signature, but what is the persons name? No guessing allowed. Who will the court going to through in jail if the statement turns out to be perjured?

    2) Affidavit not admissible at a SJ hearing as proof of complying with the rule because it is based on “information and belief” and not personal knowlage.

    3) Signs under the name of Bank of America N.A. but does not work for Bank of America N.A. but for another company BAC Home Loans Servicing, of no fixed address, in no state, who knows who this operation is.

    4) NOT sufficient for FL affidavit because it does not show where this document was notarized. A sworn affidavit that was correctly notarized would show the notary, AND the STATE and COUNTY of execution. A Mandatory Requirement. By doing a “under penalty of perjury” for a company with no address and executed in no specific place we have a problem. This is because if it is a perjured statement, without a location the court does not know who has jurisdiction to punish the un-named person who executed it.

    If this were my case I would move to dismiss complaint before filing an answer, because the verification is materially defective.

    You will probalby get the court to dismiss with ease. A request for the court to impose a sanction of fees and costs may also fly, along with a sanction for using the Jokerman type font .

    A little detective work into other cases filed by the same firm may show similarly defective affidavits.

  12. mAGGIE SIMI says:

    FUNNY !!

  13. Reggie in PHOENIX says:

    Oh I believe it! I just received a petition to Dismiss my complaint from the Fed. Courts and it basically is laughing in my face…making fun of me that I am a moron…….

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