“XEE MOUA IS A FRAUD” | WELLS FARGO v. KOSAR MOTION TO STAY AND PETITION FOR RULE TO SHOW CA– USE WHY ACTION SHOULD NOT BE DISMISSED, WITH PREJUDICE, FOR WIDESPREAD, SYSTEMIC AND DELIBERATE VIOLATION OF THE RULES OF COURT

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A., S/B/M CIVIL DIVISION WELLS FARGO HOME MORTGAGE, lNC.,

Case No. MG-10-000400 Plaintiff,

v.
JOHN C. KOSAR and LINDA S. KOSAR,
Defendants.

MOTION TO STAY AND PETITION FOR RULE TO SHOW CA– USE WHY ACTION SHOULD NOT BE DISMISSED, WITH PREJUDICE, FOR WIDESPREAD, SYSTEMIC AND DELIBERATE VIOLATION OF THE RULES OF COURT AND FOR ATTORNEY’S FEES

Some excerpts from the motion…

16. The law firm Phelan, Hallinan & Schrnieg, PC (hereinafter “The Phelan Firm”)
and its client, Wells Fargo, have engaged in a deliberate and systemic practice of filing defective and/or false attorney verifications to the lawsuits they file in this County, including the instant
lawsuit.

17. By means of this Petition, it will become crystal clear to this Honorable Court that
the Phelan Law Firm, and its client Wells Fargo, utilize a “business model” that mandates that
attorneys file verifications that are either defective, false, or both. The business model then
requires that these lawyers then follow-up their own verifications with “robo-signed” substitute verifications that are patently false. These substitute verifications are executed by admitted
frauds.

20. Before providing the Court with the evidence of systemic and deliberate violations of the Rules of Court, Defendants will first finalize presenting the procedural history
of this case.

Well Fargo’s Complaint was served upon Defendants on March 2, 2010.
On March 4, 2010, the Kosars filed their request for Conciliation.
On_March 9, 2010, a Praecipe to Substitute Verification was filed.

Another lawyer working at the Phelan Law Firm, specifically, Jenine R. Davey,
Esquire, signed the Praecipe to Substitute Verification on behalf of Wells Fargo.

25. The actual verification appended to the Praecipe to Substitute Verification was
signed by a woman named Xee Moua. This verification is attached hereto as Exhibit 5.

The verification signed by Ms. Moua states, in full:

Xee Moua hereby states that he/she is V.P. Loan Documentation of Wells Fargo Home Mortgage, Inc., servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of hisfher knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unswom falsification to authorities.
Date: 2/16/10

/s/ Xee Moua Name: Xee Moua Title: V.P. Loan Documentation Company: Wells Fargo Home Mortgage, Inc.

II. XEE MOUA IS A FRAUD

28. Below, the Court is presented with a chart listing eighty-nine (89) other cases
filed in this county during the first few months of 2010. These cases have been identified by
unde1sig;ned counsel searching the dockets for cases filed by the Phelan Law Firm on behalf of
Wells Fargo.

29. All 89 lawsuits were filed by the Phelan Law Finn.

30. The plaintiff in each of the 89 cases is Wells Fargo.

31. In all 89 lawsuits, an attorney initially verified the Complaint, claiming, falsely,
that there was insufficient time to obtain Wells Fargo’s verification. The chart below lists the
last name of the attorney who signed the verification.

32. In all 89 lawsuits, a Praecipe to Substitute Verification was filed, by means of
which a robo-signed verification was submitted. The chart below lists the name of the robo
signer, as well as the last name of the lawyer at the Phelan Law Firm who signed the Praecipe to
Substitute Verification.

33. Shockingly, (58) of the substitute verifications were signed by Xee
Moua, who, as the Court will see below, is not only an admitted robo-signer, but she is well
know to Wells Fargo, the Ohio Attorney General, the New York Times, Bloomberg News,
Reuters, and many other news media.

34. This Motion to Stay and Petition for Rule To Show Cause calls to the Court’s
attention a total of 59 instances (the 58 cases listed in the chart below, plus this case involving
the Kosars) where Xee Moua has swom, subject to the pains and penalties of perjury, that the
information contained in 59 separate lawsuits, was true and correct to the best of her knowledge,
information and belief. She has done so despite the fact that she has admitted — under oath — that she reads nothing other than her name and title prior to verifying a document, as we establish immediately below.

35. Sometimes the stars align, and they sure have for the Kosars, this Court, and
Justice in general. This is a good thing, because it helps make the presentation of the
grotesqueness of Wells Fargo’s and its “robo-lawyers” conduct much easier.

36. On the Day that Xee Moua’s substitute verification was filed in this action
(i.e. 3/9/10), Ms. Moua was sitting in a deposition room in Charlotte, North Carolina being deposed in the matter of Wells Bank. NA v. Stipek, case No. 50 2009 CA Ol2434XXXXMB AW, Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County, Florida. The full transcript of this deposition is attached hereto as Exhibit 6.

37. During that deposition, Ms. Moua testified that she held the title of Vice President
of Loan Documentation for the purpose of signing the documents.1

Be sure to check out the full motion below…

~

4closureFraud.org

~

WELLS FARGO v. KOSAR MOTION TO STAY AND PETITION FOR RULE TO SHOW CA– USE WHY ACTION SHOULD NOT BE DISMISSED, WITH PREJUDICE, FOR WIDESPREAD, SYSTEMIC AND DELIBERATE VIOLATION OF THE RULES OF COURT

[scribd id=60574149 key=key-2akpd1n9g59x6qpk7oq9 mode=list]

Comments
5 Responses to ““XEE MOUA IS A FRAUD” | WELLS FARGO v. KOSAR MOTION TO STAY AND PETITION FOR RULE TO SHOW CA– USE WHY ACTION SHOULD NOT BE DISMISSED, WITH PREJUDICE, FOR WIDESPREAD, SYSTEMIC AND DELIBERATE VIOLATION OF THE RULES OF COURT”
  1. angry & NOT TAKIN IT! says:

    DOJ is busy with a MOTION pulling the pud of the clown GOP chairman Spencer Bachus ” that stated “congress is here to serve the banks” while their waiting for a ride in the clown-mobile to the choad circus .
    fuk em …they all need to be purified ….with fire

  2. WhatSignature says:

    What about Shoua Moua? Shoua is on my documents. And of course, some ’employee’ of Wells Fargo and/or JPMorgan Chase.

  3. lvent says:

    THE PRETENDER LENDERS HAVE NO RIGHT TO COLLECT A DIME FROM THE AMERICAN PEOPLE., IF THEY LOST TRACK OF WHO OWNS THE LOAN BECA– USE THEY COMMITTED MASSIVE MORTGAGE FRAUD IN THE NAMES OF THE AMERICAN PEOPLE. WE THE PEOPLE DO NOT OWE GLOBAL TRUST FUNDS, THEY INVESTED IN A FRAUDULENTLY BASED AND DERIVED MONEY FLOW THAT ONLY DEPENDED ON SUCCESS, NOT FAILURE. THE NEW WORLD ORDER INTENTIONALLY CA– USED THE FAILURE (SEE YOU TUBE VIDEO CNBC ILLUMINATI CRASHES STOCK MARKET.) GLOBAL TRUSTS LOSE,_ GAME OVER_…. THEY DO NOT OWN OUR HOMES OUR OUR PROPERTY RIGHTS. THE NEW WORLD ORDER OWNED BANKSTERS DESTROYED THEIR OWN CONTRACT. THEY MUST RESCIND AND GIVE CLEAR TITLE TO THE HOMEOWNERS WHO HAVE BEEN ROBBED OF EVERYTHING VIA THEIR CRIMINAL MORTGAGE FRAUD PONZI SCHEME. .

  4. Gary J says:

    Amen Ivent!

  5. lvent says:

    WITH PREJUDICE MY ASS, THEY DON’T DESERVE A SECOND CHANCE, NOT EVER!!!!!!! GET IT RIGHT THE FIRST TIME ASSHOLES. IF YOUR DON’T HAVE THE PROPER DOCS THE FIRST TIME, YOU DON’T HAVE THEM AND YOU NEVER WILL. BRINGING FORECLOSURE COMPLAINTS ON CLOUDY TITLES IS ILLEGAL..GIVE THE PEOPLE BACK THEIR TITLES FREE AND CLEAR. STOP TYING UP THE LEGAL SYSTEM WITH FRAUD. STOP BLOCKING CRIMINAL PROSECUTIONS FOR THE CRIMINALS. THE AG’S OFFICE CAN ONLY FINE. THE STATES ATTORNEY’S OFFICE MUST START BRINGING CRIMINAL PROSECUTIONS. WHERE IS THE UNITED STATES DEPARTMENT OF JUSTICE???????????????????????????????

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