david j stern criminal contempt of court petition and affidavit

8/9/2019 David J Stern Criminal Contempt of Court Petition and Affidavit

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IN THE CIRCUIT COURT OF THEIN A}ID FOR PAI;M BEACH 15s .fUDICIAL CIRCUIT 'COtJNTY, FI,ORIDADeutsche Bank,Plainti-f fV.

Monica Zapata,Defendant

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)))))))))

Case No. 50200BCAO173B4XXXMBAW DivisionPetition By Affidavitto Show Cause

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PETITION BY AT'FIDAVIT FOR AN ORDER TO SHOW CAUSEFOR INDIRECT CRIMINAI. CONTE}4I

we, Lisa Epstein and Michael olenick, respectfully petition t-hisHonorable Court to initiate criminal proceedings for Indirectcrj-minat contempt, pursuant to Ft. R. crim. Pro. 3. B40n againstplaintiff Deutsche Bank, The Law Offices of David J' Stern (l awiirm for the plaintiff), Mr. David J. Stern as managing partnerof his firm, and Florida Mediation Group, Inc- based upon thesigned and sworn affidavits attached hereto'Respectfully submitted'

Lisa E3c'o

Date

Michael Oienic Date


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CER.TIFTCATE OF SERVICE

The undersigned certifies that. on , 2010, thefcreqo-ing i.ras sent via postal maj_l to theMonrca ZapataR.icardo Zapata1710 NewHawen Point Ln!{est Paim Beach, FL 33411Tia GibbsLaw Offices of David J. Stern900 South Pine fsiand Road, Suite 400Plantation, Florrda 33324-3920( 954 ) 233-8C00trlorida Medial,ion Group, Inc.44 West Flagler Streeti 9th F.l-oorMiami" Florj-da 33130(30s) s79-9990FMG File No.: 3-18986Phillip J CroylenAitorney for StoneHaven Estates liomeowners Association, rnc370 W. Camino Gardens Blvd" Suit-e 300Boca R.aton, FL 33432-58I1Mortgaqe Efectronic Registration Systems, IncC/O Corporate Counsel3300 SW 34th Avenue, Suite 101Ocala , trL 3441 4Maylene ABAD, Courtsey CopyBankruptcy Attorney3440 Hclly',vood Blvd 415Hollywood, FL 33021

Name: 'i--\tJ**- e:U*.-*li


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I}i THE CTRCUIT COURT OF TEIErN A}qD FOR PALM BEACII 15'" JUDTCTAT CIRCUTT,couNTY, FLORTDADeutsche BankPlaint i fiV.

Moi-iica Zapata,Defendant

3.

My name is l4ichael F. OlenickBeach County.

Case No. 50200BCAO173B4XXXMBAW DivisionAffidavit in Support ofOrder to Show Cause

I am a resident of Palm

AE"FTDAVTX' IN SUPPORT OF' ORDER TO SHOBI CAUSEFOR. INDIRECT CR.IMINAJ. CONTEMT

I am the co-founder a small business that, among otheractivities, a,nalyzes foreclosure case information"M.7 ccll eague Lisa Epstein brought the above-captioned casetc my attention and asked me to search for others that fitthe same fact pattern: docket entrles that prove non-ccmpliance with court orders that mandate mediation orccnciliation.My research uncovered other incidences of non-compl-iance tcmedj ation and conciliation orders. My engineeri-ng wor"k isonqoing. Earty analysis indicates that the non-complianceerrident in ihis specif ic case is not an isolated inci dent.Wtiile there is no requirement for standing to petition theCourt to issue an order to show cause for indirect criminalcontempt, blatant disregard for the authority of ourjudiciary has a ripple effect that affects the entirecomrnunity. Contempt is a crime andn like any crime wave/erodes the security and well-being of every person in thecrime*infected neighborhood-I am willing to share the findings of my research, eitherin summary form or in as much detail as requestedn with theCourt and/or law enforcement.


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Under penaity of perjbeLief, I declare theury, to the best ofabove information my knowledge andto be true.F - ;.1 . 7s; i.*-tDate

STATE OF FLORTDACOUNTY OF' PALM BEACHofSworn Lo (or affirmed)

iand subscribed before me *is ,!t/ day, 20L0, by Michael Olenick

Type of

BE}{JAhNI?{ Pt{iJIPgNOTARVPi.!8L9CSTATE OF FLORIOAcoqwn#EE0S{8{0Epires 6r2Snfi4

Personally knownProduced Identif ication

Iclentificati-on Produced fo- -_-?:Q-.*icC.3 1-**c.rr"n:a-

Michael Oleni-ck


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rN TI{E CIR.CUIT COURT OF THE 15Tg JI'DICIAT CIRCUIT,rtd AND FOR PAIM BEACIT COUNTY, FLORTDADeutsche Bank, )Plaintiff )

) Case No- 50200BCAO173B4XXXMBv. ) AW Division))Monica Zapata, ) Affidavit of Lisa EpsteinDefendant ) re Indirect Criminal) ContemPt

Af,fj:davit of Lisa Epstein, A Person llaving Knowledge of, the Facts,pursuant to FLorida RuLes of Crisrinal Frocedure Rule 3-840 Indirect

Cniminal Contelnpt.

State of Fl-oridaCounty of FaLm Beaeh

tsefore R, the undersigrned authority, personaJ-ly appeared tisaEpstein, who upon first beinE duly sworn on oath, deposes and says:1. My name is Lisa Epstein,2. I am. not an atiorneY.3. I am a person with personal knowledge of the facts contained

i-n r-,hrs af fidavit.4. I represent neither par:ty to this action.5. I am an adult- citizen of the United States, who has lived in

Paim Beach County, Elorida for the past lhirteen years.

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I am committed to the concepts of social, leqal, and economicjusticen particularly with respect to the forecfosure crrsisaffecting America today.

1 . I value the freedoms and rigrhtsc.i i i zons hrl the U. S. Constitution.

afforded to Amerrcan

B. I value the freedoms and rights afforded t-o the citizensFlorida in fhe Constitution of the State of Slorida includingrights of due process delineated in Section II and Section IX.

9- I value the rig'ht to live in a state where there exists aseparation of powers between the executive, legislative, andjudicial branch.

10. I belj-eve it' is vltal to our community, our country/ and toevery American to ensure access to a judicia::y free frompolitical pressure, even when driven by perceived pressingeconomic interests. Economically driven political pressure onthe judiciary such as the pressure from the Florida l,egislatu::eurcon the Florida Supreme Court to .set. a goal of a 62% reductionin foreclosure case backlog within a short time frame isreminiscent of the manipulation of the judiciary by the Krng ofEngland against which our founding fathers complained of whent.hey penned the Decfaration of fnciependence. These concerns fedt,c the bedrock const.itutional principle of independent courts, acore balance of power at the federal and state level.

11 - I value the right to live in a conmunity where there existsan expectation of compliance with orders by the courts of tliestate.

Affidavit of Lisa Epstein: fndirec*, Crim. ContemptDeutsche Bank v. Zapata, Case No. 50200BCA017384XXXMB

ofthe

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72. I am the mother of a belo',red American child who will growL.p to inherit the rotten fruits of the current Americanforeclosure crisis.

13. I am a reqistered nurse who has taken a solemn and sacredoa.th 1-.o devote myself to those committed to my care.

L4 " I am dedicated to the ethical ideological theory of socialresponsibility which includes helping others meet the most basicneeds of alL living things-food, water, and shelter.

15. I have personally observed over 1,000 foreclosure hearingsin the 15th Judicial Circuit, in and for Palm Beach County,Florida.

16. I have seen al1 walks of society lose their homes, manywithout- alLernative housing options. f wa tch them all; Lrefamilies with yolrnq children, the disabled, hard-working or newl-yunempJ-oyed, the men/ the women, all et.hnicities, all agles, andtneir affected animal companions. The most horrifying is theelderly, some in their BOs and 90s, whose homes were fully paidoff n yet v/ere fured into over-inflated, teaser rate foans, andn3w are in foreclosure. Some of these older FloriCians have nolivingi children, no lifespan l-eft in which to recover from thr seconomic blor,^r, and no place to gio. I question daily how we as asociety can treat our citizens of all ages, and our befoved petsthis rlay, evictinq them from the only homes they know.

I1. I offer emotional support to thousands of people impactedby the foreclosure crisis across our nation, vi a phone, emaii,online/ prayer/ and in person.

Affidavit of l,isa Epstei-n: fndirect Crim. ContemptDeut-sche Bank v. Zapata, Case No" 50200BCA017384XXXMB D:na ?


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18. Although I am not an attorney/"Interested Person" pursuant to Ffa.R.Civv Savola PB Case No. 502007CA008051) andHSBC Bank v Santlago No: 502008CAO16305)cases.

I have acted as an. Pro I - 420 (e) (U. S. Bankan Amicus Curiae (e"9.'in several foreclosure

Ig. I have submitted comments to the Florida Supreme Court TaskForce on Residential Foreclosure Cases SC09-54 & SC09-i460.

20. I spent numerous hours and great effort towards the defeatof the ncn-jud.icial foreclosure bills H81523 and S82270.

2\. f have hosted strategic sessions for: those who are equallyconcerned about America's Foreclosure Crisis. These have been inthe forn of social gatherings" forma] seminars, small groupmeetinqsn etc-

22. I have notified chief Judqre Peter Blanc of my reports ofincidents of foreclosure Plaintiffs' faw firms' misconduct- tonlany regulatory and enforcemenr' agencies including but notlimited to, the Professional Committee of the Palm Beach CountyBar Association" the Florida Bar, Office of the Attorney General,FDLE/ the U.S. Department of Justice, the FBI, FINRA' the OCC,the SEC, the FDIC, SIGTARP' etc..

23. I have observed contemptuous behavior on the part of manyhigh-volume forecfosure Plaintlff 1aw f.irms, specifically,multipl e egregi 611s violations of Court Orders otherwise termed"f ndirecl- Criminal Contempt".

Affidavit of Lisa Epstein: Indirect Crim. ContemptDer-it.sche Bank v. Zapata, Case No. 5A2A0BCA01-I3B4XXXMB Page 4


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24. I am aware of the great burden that Wall Street's recklessgamble has placed squarely on the back of Florida's judiciary.

25 - The 15th Judicial Circuit foreclosure electr:onic docket lagsup to ei-ght weeks behind the filing of a pleading. A pleadingfiled today miEht be added to the computerized docket in six toeight weeks, after which" there is an additional four lo six weeklag before the pleading is fited in the hard copy court file.The foreclosure Plaintiff law firms are notorious for their lackof nolifying defendants or their counsel

26 - In the spring 201-0 session, Florida' s legislatu,re re j ectedlegislation written by the Florida Bankers Association which, ifpassed, woufd have removed new foreclosure cases from t-he cou::tsystem unless the homeowner was able to pay up to $1,900 infiling fees in addit.ion to palzing for legal fees. By rejectingthis Iegislation, the Florida legislature soundly rejected theFlorida Banker Associations' attempt at jettisoning the dueprocess rigihts of Floridians.

21 - Fiorida's legislature allocated a one*time statewideallocation of funds to be distributed throughout the Florida'scourt system. The 15th Judicial Circuit received two allotments:$540,C00 earmarked to cover salaries of two senior ludges anC sixc,r.se manaqer,s; $403,000 to fund document management tasks -28 " Il is increasingly apparent that these funds wereexclusively budgeted to fund the newly evolved "rocket-docket"slzstem of for eclosure case dispensation without any consideratior-tgiven to monitori-ng compliance with Florida law, principles of

Affidarrit of Lisa Epstein: Indirect Crim. ContemptAgf{Elne_ Bg4_v._lepgle, Case No. 50200BCAO173B4XXX!1B Drna q


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equity, or the mandatory Florida Supreme Court Foreclosure TaskForce's orders in AOSC09-54 and SCO9-1460. These two orders werecraftecl after a year of careful consideration and effort by chemembers of the Task Force and Supreme Court Judges who took theLlnusual and signifj-cant action of requiring mediation in specificcases and amending the Rules of Civil Procedure for forecfosure

Furthermore, it is increasingly apparent that thei:udgei-ary priority is flip-flopped- The dramatic acceleration offoreclosure sunmary judgment hearings is aggravatinq ttrecatastrcphic legal outcomes of the preexisting and growingbacklogi of documents neither docketed nor filed.

29. Confidence in the docket's deplction of case actirrity hasC,eteriorated to the point that hearings and d-eadlines a::e missed,effectively eliminatinq opportunities to move for a rehearing' tooppose a pleading, to t.imely file responses or obiections, tomove to vacate a sale, and,/or to file for an appeal'30. In this specific case/ Deutsche Bank v- Zapata, Case No502O08CAO173B4XXXMB, the parties were ordered to mediation.

31. Before mediatron, the plaintiff, by and through counseltee Law Offices of David J. Stern, ted by Florida Artorney David'r Qiorn .ol d the house in direct violation of this Court/ sLU!r1, rorder" as evidenced conclusively by the record-

32. I"1r . Stern and/ or Florida tviediation Group, Inc . , sentletter indicating to Ms. Zapata the mediation fee structure/accept.able payment methods/ and led her to believe that she was

Affidavit of Lisa Epstein: fndirect Crim. Contemptlgutrcls_Esn!__y. Zapata, Case No. 50200BCAO173B4XXXMB Dta.- i.,-qY-


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responsible for mediation fees despite Judge Roger Colton's orderto the contrary.

33. Mr. Stern is a high-volume foreclosure filer who presumablyis aware that plaint.iffs in owner-occupied foreclosures bear thesole burden of fronting mediation fees pursuant to FloridaSupreme Court Administrative Order AOSC09-54.

34. Mr. Stern is a high-volume foreclosure filer who presumablyis aware cf the f act t.hat f oreclosure cases init iated prior t-othe effective date of the Flor:ida Supreme Court Administral-iveOrder AOSC09-54 may be court ordered to mediation and the upfrontpalment of the mediation costs to be borne by the party orparties at the discretion of the presiding judge-

35. Florida Mediation Group, Inc. presumably is aware of thefact that foreclosure mediation of owner-occupied foreclosures isfronted solely by the plaintiff pursuant to Florida Supreme CourtAdn,inistra.Live Order AOSC09-54. Certified mediators have thelesponsibility to read and follow the Courts' Orders.

36. Elorida Mediation Group, Inc. presumably is aware of thefact that foreclosure mediation of owner-occupied foreclosures isfronted solely by the ptaintiff pursuant to the December 28, 2009Florida Supreme Court Administrative Order AOSC09-54.

Florida Mediation Group, inc. presumably is aware of thefact that forecl osure cases initiated prior to the effective dateof the Florida Supreme Court Administrative Order AOSC09-54 maybe court ordered to mediation and the upfront payment of the

Affidavit of Lisa Epstein: fndirect Crim. ContemptDeutsche Bank v. Zapatan Case No. 50200BCAO173B4XXXMB

31

Pagie 1


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nediation costs to be borne by the party or parties at thediscretion of the presiding' judge.

38. The evidence on the docket as well- as the Notice ofMediation prove definitively that Deutsche Bank, the Law Officesof David J. Stern, Mr- Stern himself as lead attor:ney of the LawCffices or David J. Stern, and/or Florida Mediation Gro.ipo fnc.intentionally and knowi-nqlly wiolaLed a courb order, a crixnedefined by FL Crim. Stat. Sec. 3.840, Indirect Crlminal Contempt.of, JudEe RcEer CoLton" s a/L/ZAAA Order for Mediation to occurwithin 60 days at the pJ-aintiff's expense. See .Appendix &-

llow f Ca:ne Upon Ttris Knowledgre

I am a foreclosure crisis activist, a consumer advocate, andair investor advocate. I spend a great deal of time, attention,and effort focusinq on America's foreclosure crisis. I amwitnessing its deleterious effects on my community, my stale, [ycountry, my fellow citizens, and, on the state and federal levei,oi.ir three branches of government, our law enforcement agencies /anci our regulatory agencies.

2 - I am deeply affected by the immeasurable human misery causedegually by the julienning, rebundling, derivitizrnq, and shortingof securitized mcrtqa-ge. In an attempt to fessen the globaleconomic damage, the U.S- Treasury and the U.S. Senate/ over'uheobjections of the U. S. House of Representative doled out a

Affidavit ofDeutsche BankLisa Epstein : Indirect Crim. ContemptCase No. 5C2008CA01?3B4XXXMB. ZapaLa, Page B


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$700,000,000-000 in a bailout- benefitting only one party to themortgage contract. This interference effectively guillotined theright of every mo-rtgagee to negotiate with an insoLvent bankreaCy tc cut its losses by reducing individual loan principalbafances. This bailout of one party to the subject- contract wasfollowed by a diametrically opposed governmental response towardsthe other party to the subject contract; lethargic, apathetic,ineffective governmental programs that reek of corrupLion andfavoritism towards the bailed out party.

3. As part of my activities I founded a popular website,Foreclosu,reHaml-et . org - The site is dedicated to supporting,informing, and connecting people affected by the foreclosurecrisis, creating ongoing roundtab.l-e discussions about the relateds:cial, ethical, moral issues, and empowering all to defend theirfanily hones during these perilous times in our country"

4- Ms- Monica Zapatar a person unknown to me/ contacted anotherm,-mber of my website via emai] seeking informati-on and quidance:Our home went an sa-Ze today and I really needyour guldance and help with afI this. I don'teven knovr how long they give us to move out and Ihave smaf I chil-dren. This js a very horribLeand sad time for our famiJy and reaTly need help!

5. The original recipient of Ms. ZapaLa's email ::ecommenciedseveral exceilent foreclosure defense attorneys in Palm BeachCounty, Florida. With Ms- Zapata/s consent, a copy of this

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responsive email was forwarded to me I immediately openeci thelink to the Palm Beach County ClerkConnect website. I then did asearch for Ms- Zapatat s docket (Case No. 502008CA0173BAXXXXPIB),whi ch can be f or:nd at the URL ! f trii llt,111il !_,:::lt: i _:l_._1l-jl1l_119agli,-i.-i ,-:t!!i,,),!-|-Ji-,frl-:.f- pti!i.+!-. !]iy,$9q1-"-..p---!,t

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a cirect vioiation of Fla"R.civ.Pro 1"510(c) and verizzo v' Banko-f l/, y. 2B So " 3d 97 5; 2070 Ffa. See Docket entry #23 . Bethcerni, employee of The Law offices of Davicl stern executed thecritical MERS assignment of mortgage' Se Appendix B" whichpursuant to the recent 5th DCA's opinion is the fulcmm upon vihichp-l-aintiff . s nusl establish standing to foreclose in "that thew]:itten assignment of the note and mortgage from MERS to DeutscLieBank properly transferred the note and mortgage to Deutsche Bank'eaa ,r,:rti nr rr Deutsche Bank 5D0g-40i5, Ms. Cerni executedJCU tQy LvL vhunclreds, ai not thousands, of these assignments of mortgaeieassigning pr:opert.y from MERS to her employer's client. Anotherassignment of mortgage executed by Beth Cerni appears to bear aslgn_ature lhal, qreatly differs from her signature on the documentwliich was r:elied upon to f oreclose upon Ms. Zapata' s f amily home "See Appendix C.

Despite the f,aeL tl'lat Ms. f,apaLa was ef,fectlveJ"y denied herri.Eht, to cor.rrt ordered mediation on August 2, 201"0 / Ms. Eapata'sFrome" t*.here she lives wj-th her fainily, including three children,was sond to Detetsche Bank f,or $200. Ano'uher Florida fanJ-ly haslcst ttrein horce despiEe the f,aet that critieal evidence ecasbr:ought to the $ufiIgtary 3udEnment hearing preeludinE any canef,tllexamination or objeetions. ,\not}.er Florida fannily hras lost their

i:o med-iation. Anothe:c Fl-orida fami].y tras lost ttreir brome despitettrefactthatt'heassiEramentofmorLEagewasofdt.lbiousautrrenticity"

Affidavit of Lisa trpstein: Indirect crim. contemptn,eg!:glg eggEf.--Z19pg!gn Case No - 50200BCA0il 3B4XXXMB r)erta I I


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10. Per the subject mortgage filed by Plaintiff's counsel, theMERS ylIN # is 10005352 5A37656261 , found at the MERS@ ServicerI,lentification System which has the URL address ]-r_tlpiiiz'"r1v_L_.tI:-.JI:-:11;13..Y1q9 r- j'-1: !,fJi 1- 1 -.-t /11. The results of a search by the above MERS MIN on the lookup tool are copied here- See Appendix D. The role of DeutscheBank, the Plaintiff in this action is unclear, as it is neitherthe servicer nor the investor of the subject loan. It is exactlythis scenario t.hat the Florj-da Supreme Court addresses in itsArnencl-ment to the Florida Rules of Civil Procedure No. SCO9-15'79,wlrich unforturnately post-dates the fil j-ng of this case.

"Rufe 1.110 (b) is amended to require verificationof mortgage forecfosure compLaints involvingresidentiaL reaT propetty. The primary' purposesof thj-s amendment are (1) to p>tovide incelzXiwefor Xhe plaintiff to ap>prcprj,at-.ely investigateand^ verify J-ts ownetship af th,e note or tight toenforee the note aad eilsure that t}:.e aTTegaxiomsin the eoryTainx are accuraxe; (2) to conservejudiciaT resources that are currentTy beingwasted on inappropriateJy pTead-ed "-Zost no!:e"counts and j-nconsj,stemt aTTegations; (3) toprevent the wasting of jwdieial- resources andharm Xo defendants resuJ.ting from suits brawghtby pJ.aintj,f,,fs noX entitLed to enforce the naxe;

Affidavit of Lisa Epstein: Indirect Crim- Contemptlgulqche_ggnk v. Zapata, Case No. 502008CA01-73B4XXXMB Dano 1,


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and (4) to give triaf courtssanction pJ-aintj,ffs who .make

greater auLhoriLyfalse aTTeqatioms"

to

MIN: 1000 535-2503165 626-'1 Note Date: 05/3L /2006Servicer : !iti:! git]j-:C i,lg-: _l 4WaterJ-cio n IAInvestc)r: Impac Mci:1'-gage Holdings fnc.Irv-i.ne, CA

MIN Status : Acti-vePhone: (800) 166*4622Phone: (800) 597-410i

L2. Seven docke"t- entries are listed f or April 1, 20]-0 inDeutsche Bank v Zapata- Included in these seven docket entriesal:e the orders granted by the Honorable Seni-or Judge RogerCclton- One of these orders qranted mediation to be scheduled tooccul within 60


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of Mediar-icn Conference to Jul1z 74, 2010. See Appendix H for:A.rgrust i, 2010 Notice of MediaLion. The plaintif,f , by and+:l-r^rouqh eounsel , alJ-owed the sale to occur on August 2, 20L0 in

To the best of mYbelief anci knowledge, based on an in-person inquiry of clerksi,aff "Kathleen" on August 2, 20t0, +,he Plaintj-ff purchased thehouse for $200 at an online auction. The bid slleet was docket-edon docket entry #31.

L4. A specific Cle::kConnect Cocket report can be run using dataf :.etd criteria as follcws: c::der of mediation, finai judgmenL'notice of mediation. mediation report, and certificate of title'I revievreci such a report and it clearly reveais a pattern ofqgrjlglnp!_of both circuit court judges' orders and Florlda SupremeCourt Adninrstralive Order No. AOSC09-54. I obtained a printoutri such a report to do background research into wha,t Ms. Zapatahad experienced. Despite the existence of the i5th JudiciatCj,r-cuit's sepalate foreclosure "rocket-docket" eiectronicschedullng system, the ClerkConnect website is the soleel.ectronic docl


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Affidavit of Lisa EPsteinDer.rtsche Bank v. ZaPata'

unquestionably materialty misleading in that it details medrationfees and payment details but omits the criLical fact that theplainLiffs front this cost for defendants who resi de in thesubject ProPertY. See APPendix I'

L6. Court orders we.re violated. The docket entries show thatthat the plaintiff, and,/or other parties who are lepresented by aperson who, per the Fla. supreme court, "has full authority tosetr-l-e and who can bind the plaintiff to any mediated settiementaqreement" violated an order of this court. The 15th JudicialCir:cuit has an alternate docketi-ng system f or schedulinqforeclosure case hearings located at the URL addressh--tp: / /I'L]ncircuit. co.palm-beaclr. f l.us/web/divisionaw/home ' Ilogged in to this separate AW Foreclosure docketing system tocheckforanyschedulecJhearingsthatmaynothavebeenC(fntemporaneously entered into the clerk,s docket. There were noh(larings, past or present, Iisted on the alternaleschedul-ing/docketing system for the above styled case '

LT.TheeventsofthisforeclosureCaSewereofgreatinteresttomeaStheyalerepresentativeofanoftrepeatedpattern.Tlere is m-uch wo::k to do -

laTno1-.i.tionthecourtto.inthewordsofFlorida'sSupreme0. r PL er-Ccurto.'V-indicatetheauthorityoftheCourtortopunishotherwise for conduct- offensj-ve to the public in violation of anorder of the coul:t." Pugliese v. Pugliese, 34'l, So.2d 422 at 424'

: Indirect Crim. ContemPtCase lJo. 502A0BCAOi73B4XXX}"iB 9^da I a


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FURTHER AFFIANT SAYETH NAUGHT-

West Palm Beacho FL 33413E-Mail:ForeclosureHamf et Ggmail . comT4* foregoing instrumentN'.1 auy of August 2010",'trr l!.s-zil 4"4 was subscribedby Lisa Epstein and sworn towho provided me thisfication.beforeidentl

8FI'{JAMIN PHILI,JPSNOTARYPUAUCSTATE OFFTORH}AConrr#EEm18t0Expires 6i282014

Signature of Notary public,Slate of F]orida

Written Name of Notary pubiic,State of F]orida

Affidavit of Lisa EpsteinP_eutsche Bank v. Zapefg, : Indirect Crim. ContemptCase No. 50200BCAO173B4XXXMts a -.^^ 1 tfduc _L L-


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AppendixAppendi,-x A: 1/7/2070 Order On Mediation by Judgie Roger ColtonAppendi-x B: Zapata Assignment of Mortgaqe signed by Beth cerniAppendi-x C: Assignment of Mortgiage signed by Beth CerniAppendix D; screen shot of MERS MiN tool for sub;ect mortgagieAppendix E: Deutsche Bank v Zapata DockelAppendi,x F: B/3/2010 Notice of Mediation ConferenceAppendi-x G: Notice of Change of Mediation Conference to 1 /74/207AAppend:x H: 8/3/2010 Notice of MediationAppendi..x I: Notice of Change of Mediation Conf erence w/Fee Structure

david j stern criminal contempt of court petition and affidavit

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