Here comes the Defendant’s, pro se, move to vacate Plaintiff’s judgment/order pursuant to FRCP 60 (b.) (4.) and (d.) (3.). This court granted relief on Oct.19, 2013, based on false & misleading statements by PLAINTIFF’S. Defendant’s state in support of their motions:

Plaintiff’s Motion To Substitute Plaintiff’s claiming they were a “new party” was a false and misleading statement by Plaintiff’s evidenced by the letter Defendant’s recently received from Bayview stating they are still the Plaintiff/Servicer. A copy of the letter is attached to this motion as Exhibits A and B.

Plaintiff’s Lack of Proper Notice by the time of the hearing on Oct. 19, 2013 was a violation of Defendant’s right to due process and caused the offensive order to be entered.

Defendant’s discovered Plaintiff’s Bayview Loan Servicing do not have a Notorial Certificate and therefore can have nothing in writing that would satisfy the Statute of Frauds.

Plaintiff’s lack of due diligence and subsequent actions has caused Fraud in the Procurement. As a,result, Plaintiff’s entire judgment/order is void and of no legal force or effect.

Because of Plaintiff’s lack of due diligence, and Plaintiff’s subsequent actions have caused Fraud in the Procurement of Plaintiff’s suit, and is a cause for dismissal of Plaintiff’s entire Foreclosure Complaint and also supports Motion to Dismiss scheduled for hearing on December 16, 2013. Fraud in the Procurement of Plaintiff’s suit supports Defendant’s argument in their Motion to Dismiss that Plaintiff’s suit lacks subject matter jurisdiction (810 ILCS 5/3-102).

Defendant’s argument in support of their Motions is based on well settled case law as follows:

Void order which is one entered by a court which lacks jurisdiction over parties or subject matter, or lacks inherent power to enter judgment, or order procured by fraud, can be attacked at any time, in any court, either directly or collaterally provided that party is properly before the court, People ex. re. Brizica v. Village of Lake Barrington, 644 N.E. 2d. (Ill. App 2 Dist. 1994).

In re Marriage of Macino, 236 Ill. App, 3d. 886 (2nd Dist. 1992) (“If the order if void, may be attacked at any time in the proceeding.”).

Moreover, what would the VATICAN’S opinion be on their behavior towards CATHOLICS?

I think it’s RELIGIOUS PERSECUTION because nothing they’re doing can be legally validated.

When that’s discovered everything is fraudulent upon it’s face which involves fraud & forgery from the onset to today.

The essence of fraud is how it vitiates everything once it enters.

Tomorrow I’m going to post my motion in response to their inquisition that can’t be explained because my motion was denied for no valid reason.

The fact fraud was prevalent in the mortgage industry is well known so the conclusion can be made based on that which gives my claim legal relevance.

There’s too many party’s to one capital gain which can only mean there’s money laundering, tax evasion & trafficking of every kind going on behind the scenes of this.

Therefore we’re either living in some foreign land or some foreign land is living in the U.S.

Therefore, they’re not going to have discovery because the topic is feudalism over non disclosure.

To those who say that doesn’t matter that’s fraudulent concealment of the legal facts.

That’s legal bias because they’re post judgments & that’s what they’re hiding because the RPII is unknown.