WHEREFORE, Plaintiff respectfully requests this court to provide the requested legal and equitable relief and any other such relief this court deems as just and proper, including but not limited to:

a.  Declaratory Judgment that the neither the Defendant Trust, or any other named or unnamed Defendant in this action, possess any sufficient evidentiary indicia that provide standing as a real party in interest to enforce the Plaintiff‘s note under G.L. c. 106.

b.  Declaratory Judgment that the neither the Defendant Trust, or any other named or unnamed Defendant in this action, possess any sufficient evidentiary indicia that provides standing as a real party in interest to enforce the Plaintiff‘s mortgage

c. That the Defendant enterprise acted collectively and intentionally through predicate acts that proximately caused injury to the Plaintiff

d. All other legal and equitable claims made in the above paragraphs

e. All of Plaintiff‘s reasonable attorney fees, and attendant costs with defending the Defendant(s) legally deficient proof of claim in this matter, as well as its legally deficient Motion to Lift Stay hearing.

f. All other equitable and legal remedies that this court deem just and proper.

Respectfully Submitted,
Plaintiff
Peter H. Koufos
By his Attorney

/s/ Glenn F. Russell, Jr.
June 06, 2011        Glenn F. Russell, Jr.

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In Re: PETER HARRY KOUFOS