in the superior court of fulton county - sentasha · 2015-08-02 · sentasha keyama-joy el vs....

Submitted In the Name and Respect of All’Law:

Nature, Religion, Isonomy, and the

Supreme Law of the

Land

P.O. Box 957

Atlanta,

Georgia 30301

North America

Nation-State:

United States

of America

Amity & Commerce 1777 • 1786 1787 • 1836 ~Present~

AMEN

PEACE AND GREETINGS TO THE HONORABLE JUDGE OF SAID COURT: 1

Coming Forward Plaintiff, SentAsha KeyAma-Joy EL (f/k/a SentAsha 2

KeyAma-Joy Williams) (“SentAsha”), for herself (pro se / in propria persona 3

civilian / civil society scribe) via this civil action seeks injunctive, declaratory and 4

compensatory relief against Ocwen Loan Servicing LLC, Deutsche Bank National 5

Trust Company solely as Trustee for Pooling and Servicing Agreement dated 6

November 1, 2006 Securitized Asset Backed Receivable LLC Trust 2006-FR4, 7

Ronald Matthew Farris, Mable Scarlett, and Amy McNulty (f/k/a Amy Stoddard), 8

collectively referred to as (“Defendants”). 9

Civil Action No. __________________

Hon.___________________________

Verified Consolidated

Complaint Supported by

Affidavit & Exhibits

Jury Trial Demanded

SentAsha KeyAma-Joy EL

Plaintiff In Pro Per » Pro Se

vs. OCWEN LOAN SERVICING LLC, DEUTSCHE BANK NATIONAL TRUST COMPANY solely as trustee for the Pooling and Service Agreement (PSA) dated November 1, 2006, Securitized Asset Backed Receivables LLC Trust 2006 FR-4, Mortgage Pass through Certificates, Series 2006 FR-4, Ronald Matthew Faris and Mable Scarlett in their individual capacities, Amy McNulty (f/k/a Amy Stoddard) in her individual capacity. Defendants

IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA

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☉ SentAsha KeyAma-Joy EL vs. Ocwen Loan Servicing LLC et al

Verified Consolidated Complaint • Superior Court Fulton County, Georgia

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1.) Why is SentAsha bringing this action and seeking such relief? 10

Because the Defendants are in violation of Georgia’s Fair Business Practices 11

Act, and have facilitated and/or performed wrongs that are outside of the 12

State and Federal constitutional fold. Overview of actions include: 13

a) Unfair Business Practices with respect to foreclosure-related acts. The 14

Defendants have wrongfully attempted to foreclosure on SentAsha’s homestead 15

— under color-of-title — by way of false conveyances — a robo-signed 16

fraudulent allonge and a robo-signed fraudulent security deed assignment that 17

were executed in favor of Deutsche Bank National Trust Company as Trustee 18

for the Securitized Asset Backed Receivables LLC Trust 2006-FR4 during a 19

bankruptcy proceeding. The wrongful foreclosure acts occurred from 20

November 2014 to March 2015. (Further Details in Statement of Factual 21

Allegations). 22

b) Unfair business practices with respect to loan servicing. 23

c) Real Estate Procedures Act (RESPA Regulation X) 12 USC §2605. 24

d) Constitution for the State of Georgia, Enumeration Clause, Article 1, Section 1, 25

Paragraph XXIX. 26

e) Constitution for the United States of America, Supremacy Clause, Article 6. 27

f) Fair Debt Collection Practices Act 15 USC §1692 e,f,g. 28

g) Unjust Enrichment. 29

h) Submission of a fraudulent security deed assignment onto the Fulton County 30

real estate records. 31

i) Breach of Privacy (Sharing of a private assigned Old Age Survivors Insurance 32

Trust Fund Account Number a/k/a Social Security Number.) 33



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j) Trademark Infringement (Unauthorized Publishing of a Trademark.) 34

k) Breach of Consent Order. The Defendants violated the December 19, 2013 35

consent judgment that was issued by the United States Court for the District of 36

Columbia in Consumer Financial Protection Bureau et al vs. Ocwen et al. The 37

CFPB along with the State of Georgia and 47 other states sued Ocwen and 38

Ocwen settled the matter. A consent judgment, led to the signing of a 39

settlement agreement and consent order where the principals of Ocwen Loan 40

Servicing and Ocwen Financial agreed to adhere to the Dodd-Frank Wall Street 41

Reforms and the Consumer Protection Act which protects homeowners and 42

consumers (3rd party beneficiaries) from mortgage servicer’s unfair deceptive 43

abusive acts and practices. Signatories of this consent order/agreement 44

included Lucy Morris, Deputy Enforcement Directory for the Consumer 45

Financial Protection Bureau (“CFPB”) and The State of Georgia. Georgia’s 46

authorized signatory was Jeffrey Stump, Sr. Assistant Attorney General. A 47

copy of the consent order was filed with the Georgia Department of Banking 48

and Finance on February 26, 2014 49

files.consumerfinance.gov/f/201312_cfpb_consent-order_ocwen.pdf 50

Highlighted Background Information Regarding Securitization, the

Securitized Asset Backed Receivables LLC 2006 Trust (“SABR Trust LLC

2006-FR4”), the Fiduciary Roles and Obligations that Each of the

Defendants Have in Regards to the Trust

Along with Details about the Trust’s REMIC Status

2.) It is alleged that the note and the security deed attached to SentAsha’s 51

homestead have been assigned to the Securitized Asset Backed Receivable LLC 52

Trust 2006-FR4 (“the Trust”, “SABR LLC Trust 2006-FR4”) (a relevant non-53

defendant). The Defendants are working on behalf of the Security Asset Backed 54

Receivables LLC Trust 2006-FR4. It is a securitization trust that was formed 55

http://www.files.consumerfinance.gov/f/201312_cfpb_consent-order_ocwen.pdf



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in November 2006 that has a closing date of December 12, 2006. Securitization 56

trusts hold pools that contain hundreds of mortgage notes that have been bundled 57

together. The securitization process: After an investment bank purchases the pool 58

(bundles) of mortgages they are securitized into a securities commonly known as 59

mortgage backed securities (“MBS”) and residential mortgage backed securities 60

(“RMBS”). Investors buy into these securities and receive certificates of 61

ownership. Mortgage backed securities certificate holders receive a percentage of 62

the interest and principal payments that homeowners make on the mortgages. 63

The securities are often sliced up and sold into portions called “tranches” which 64

allow buyers to customize their payments. Per the 2011 USA Financial Crisis 65

Inquiry Commission Inquiry Report page 43, “Risk-averse investors would buy 66

tranches that paid off first in the event of default, but had lower yields. Return-67

oriented investors bought riskier tranches with higher yields.” The Securitized 68

Asset Backed Receivables LLC Trust 2006-FR4 is regulated by the United States 69

of America Security Exchange Commission, and the Trust’s governing document is 70

the Pooling and Service Agreement (“PSA”). Per the PSA, Deutsche is the Trustee 71

and Ocwen is the Servicer. Ocwen collects debt payments from homeowners on 72

behalf of the Trust and its investors. Keep in mind that — within the frame of the 73

matters outlined within this verified consolidated complaint — Deutsche and 74

Ocwen are not functioning as standalone entities (like how a local small credit 75

union functions). Instead, they are functioning as obligated entities that are 76

working in conjunction on behalf and for the benefit of SABR LLC Trust 2006-77

FR4; a securitization trust. 78

3.) Taxwise, the Trust is recognized by the IRS as a Real Estate Mortgage 79

Investment Conduit (“REMIC”). A REMIC holds a pool of mortgages in trust and 80

issue interests in these mortgages to investors. To obtain the REMIC 81



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classification, a trust must satisfy several IRS requirements. After the IRS 82

recognizes the Trust as a REMIC, the Trust is exempt from taxation on its 83

transactions. However, the investors are individually responsible for their own 84

capital gains tax. In order for the Trust to keep its REMIC status, the Trust must 85

abide by the Internal Revenue Code. If the Trust violates the Internal Revenue 86

Code then the REMIC status is forfeited. Per the Internal Revenue Code, one of 87

the perquisites required is for ALL assets to be pooled into the Trust by a certain 88

date. This requirement correlates with the Pooling Servicing Agreement that 89

stipulates that the closing date for the Trust is December 12, 2006. Assets 90

transferred into the Trust after the closing dates are outside of the frame of the 91

Pooling and Servicing Agreement, and pierces the Trust's tax-exempt REMIC 92

status. See IRS Manual Form 1066, IRC § 860G(a)(3)(A). 93

4.) The Defendants purport that they have a secured interest in SentAsha's 94

homestead however, the robo-signed fraudulent conveyances used for such 95

alleged transfer of such interests, were issued 4 years after the Trust's closing date 96

which is in violation of the PSA and the REMIC. The PSA, REMIC, and the SEC 97

are the foundational source of the Trust’s legal framework. The Defendants are not 98

superior to the PSA, REMIC, and the SEC. They are obligated and subject to the 99

aforementioned. As you read this, keep in mind that these details about the Trust 100

are provided as fundamental pertinent background information; not to be 101

interpreted as SentAsha’s claims for relief that are detailed in paragraphs 44-140. 102

The Trust is a relevant non-defendant. 103

Trust Structure Diagram Next…



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104

Deutsche Ocwen, Servicer

(Original Servicer HomEq)

SABR

Trust LLC

2006 FR-4

(Issuing Entity)

Trust Assets

(Securitized Promissory Notes)

Mortgage Backed

Securities (MBS)

The Trust Structure / Real Estate Mortgage Investment Conduit #REMIC Issuing Entity: Securitized Asset Backed Receivables LLC Trust 2006-FR4

Borrowers / Consumers / Homeowners Signs the Promissory Notes

Borrowers / Consumers / Homeowners are and 3rd

Party Beneficiaries of the Trust Assets Also, they are Beneficiaries of the Old Age Survivors Insurance Trust Fund Accounts a/k/a Social

Security Accounts

Freemont Investment & Loans Created the Promissory Notes. Ocwen and Deutsche are neither the originator or the secured creditor.

Freemont closed in 2008. Per the FDIC there was no acquiring company/successor.

Allegedly the security deed was assigned over to

Deutsche as Trustee for SABR

Trust LLC 2006-FR4

*Sutton Funding, Depositor Freemont, Responsible Party

Wells Fargo, Custodian

Signatory Parties of the Pooling and Servicing Agreement. The PSA is the Trust’s official governing document.

$

$

$

$

MBS Investors

Ocwen, Servicer

NOTE

NOTE

NOTE

Deutsche, Trustee

DEED

ALLEGED DEPOSIT *Alleged Securitization of Mortgage Notes

Diagram 1.1 • Infographic by SentAshaTM Design No. 1436-2015-46-1A-SABR © 2015. All Rights Reserved.



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5.) Point of reiteration: It is alleged that the promissory note that contains 105

SentAsha's wet-ink signature was securitized and that the security deed connected 106

to SentAsha’s homestead was assigned to the Securitized Asset Back Receivables 107

Trust LLC 2006 - FR4. Pursuant to the Pooling and Service agreement dated 108

November 1, 2006 Deutsche Bank National Trust Company is the designated 109

Trustee and HomEq was the former servicer. Under an acquisition agreement 110

formed in May 2010 Ocwen Loan Servicing LLC became a party to the Trust as the 111

new servicer. The Trust is governed by the PSA. Amy Stoddard (n/k/a Amy 112

McNulty) is a Trust Officer at Deutsche and was the signatory party of the Pooling 113

and Servicing Agreement (Source: Form 8-K, Dated 12.12.2006, Page 123. 114

Security Exchange Commission File#333-138183-02.) 115

6.) The creation of the robo-signed false allonge and robo-signed false security 116

deed assignment were created and executed in May 2010. As the designated 117

Trust Officer, Amy McNulty had a fiduciary duty to assure that there were no 118

occurrences of unfair or deceptive practices that could adversely affect trust 119

assets, investors, and 3rd party beneficiaries (homeowners/consumers). 120

7.) Concurrently, Ocwen Loan Servicing, Ronald Matthew Faris as a leading 121

Principal of Ocwen, and Mable Scarlett as the Compliance/Licensing Paralegal of 122

Ocwen had a fiduciary responsibility to assure that there were no occurrences of 123

fraudulent or unfair or deceptive practices. Given the fact that the 2011 United 124

States of America’s $1 billion lawsuit against Deutsche contained allegations 125

regarding the creation of fraudulent documents (conveyances) during bankruptcy 126

proceedings, the allegations within this verified consolidated complaint are not 127

rare phenomena. (See USA vs. Deutsche Bank AG et al, 11CIV2976, United States 128

District Court New York). The Defendants have an obligation to curtail and 129

remedy any form of unfair and deceptive practices that affect 130



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homeowners/consumers throughout continental Georgia and across the 131

continental United States of America. 132

8.) SentAsha KeyAma-Joy EL (f/k/a SentAsha KeyAma-Joy Williams) 133

(“SentAsha”) is a granddaughter of indigenous aboriginal American descent 134

(non-Indian, ancient American Moslems-Hebrews of the Western Hemisphere, 135

8 USC 1401b / Public-Law 94-171 Federal Ethnic Classification#D23/#667: Moor). 136

She is an American Citizen, a Civilian over the age of 18, and she is a holder of a 137

United States of America passport. She is domiciled in the continental United 138

States of America (“USA”) in the southeastern Piedmont plateau region that is 139

styled as Atlanta, Georgia, Fulton County; 11th Circuit Northern District, 5th 140

Congressional District, 5th Judicial Administrative District. 141

In terms of talent, trade, and civics — SentAsha is a polymath; civil society scribe, 142

researcher, craftswoman, information & technology contractor, and she is a 143

former American Stock Exchange intern, previous microbusiness owner, and a 144

prior Toastmasters International member who served as a public relations lead. 145

In addition, she is a survivor of human rights abuse. In terms of philanthropy, 146

SentAsha has served as a volunteer English/ESL Literacy Tutor for the Atlanta-147

Fulton Public Library System, as a technology consultant for Teaming for 148

Technology (f/k/a TeamTech), and she has contributed equipment/service to 149

Moving Young Minds, Southwest Atlanta Youth Business Organization, Literacy 150

Volunteers of America, Foundation for Fighting Blindness, and the general public 151

via open Civil Society educational interviews and forums. In addition, she has 152

provided complimentary computer basics/ graphics/web design training to non-153



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profits and individuals. SentAsha, as a beneficiary, consumer, and homeowner 154

became aware that Ocwen was the new servicer in 2010. During a time of 155

hardship, An Ocwen agent signed-off on a modification agreement in April 2011 156

after SentAsha received a discharge via bankruptcy. (See 2015 Affidavit of Truth 157

Points 1-7) 158

9.) Ocwen Loan Servicing LLC (“Ocwen”) Ocwen is a limited liability 159

company, wholly owned subsidiary of Ocwen Financial Corporation. Ocwen is 160

registered as a foreign entity within the State of Georgia, Secretary of State 161

corporations division under control #0225905. They are also licensed via the 162

Georgia Department of Banking and Finance, license #19438 and listed within 163

the National Mortgage Licensing System under #1852. Ocwen transacts business 164

throughout continental Georgia and across the continental United States of 165

America. Concerning the SABR LLC Trust 2006 FR-4, Ocwen is the designated 166

servicer. Per, the Pooling and Servicing Agreement (“PSA”) dated November 1, 167

2006, Article III, Section 3.01, the Servicer works on behalf of the certificate-168

holders (mortgage backed securities investors), and shall service and administer 169

the mortgage loans to the extent consistent with such terms, in the same manner 170

in which it services and administers similar mortgage loans for its own portfolio. 171

The PSA for the SABR LLC Trust 2006 FR-4 was filed with the United States of 172

America Security Exchange Commission under file #333-138183-02, pursuant to 173

the provisions of the Securities Exchange Acts of 1934. Concerning the matters 174

within this verified consolidated complaint, Ocwen was the servicer of the 175

mortgage loan that was originated by Freemont Investment & Loans; a lender 176

that folded in 2008. Per the FDIC, at the time of closing there was not an 177

acquiring institution. Ocwen was neither a creditor nor a mortgage originator of 178



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the original promissory note that contains SentAsha’s wet-ink signature. Ocwen 179

serviced and modified the original loan. The previous servicer prior to Ocwen was 180

HomEq. Via a purchase agreement dated May 2010 Ocwen acquired mortgage 181

servicing rights from HomEq. Such purchase is stipulated within Ocwen’s 182

November 2013 Investor Presentation that was filed via form 8-K, Exhibit 99.1, 183

with the Security Exchange Commission file# 001-131219. On page 10 of the 184

presentation, it states that Ocwen acquired loans via purchasing Mortgage 185

Servicing Rights. Ocwen is HomEq’s successor/assignee. Ocwen’s principal 186

location is at 1661 Worthington Road, Ste 100, West Palm Beach, Florida 33409 187

and their registered agent is Corporation Service Company, 40 Technology 188

Parkway South, Suite 300, Norcross, Georgia 30092. Their Georgia office is 189

located at 1000 Abernathy Road, #210, Atlanta, Georgia 30328. 190

10.) Ronald Matthew Faris (“Ron”) Ronald Matthew Faris is a Principal 191

(Managing Partner) of Ocwen Loan Servicing LLC. Ron provides oversight over 192

Ocwen Loan Servicing LLC’s operations and servicing. As a principal, Ron is 193

responsible for exercising keen discernment in the appointment of agents who 194

work on behalf of and for the benefit of Ocwen. Also, Ron communicates via open 195

letters in order to exude due care for matters that affect homeowners and 196

investors. A demonstration of such care was shown in Ron’s October 24, 2014 197

correspondence to homeowners where he addressed the New York Department of 198

Financial Services’ investigation of Ocwen’s backdating of mortgage-foreclosure 199

letters. http://shareholders.ocwen.com/releasedetail.cfm?ReleaseID=878151 200

http://shareholders.ocwen.com/releasedetail.cfm?ReleaseID=878151



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11.) Mable Scarlett (“Mable”) Mable Scarlett is the Licensing Paralegal for 201

Ocwen. She facilitates and manages licensing and compliance matters to ensure 202

that Ocwen is able to maintain its license to operate in continental Georgia and 203

other States throughout the continental United States of America. For several 204

years, Mable has been instrumental in Ocwen’s legal presence within the State of 205

Georgia. 206

12.) Deutsche Bank National Trust Company as trustee 207

(“Deutsche”,“Trustee”) Deutsche is a national banking association that 208

operates as a subsidiary of Deutsche Bank Holdings, Inc. The principal location 209

for their trust administration officers and directors is at 1761 East St. Andrew 210

Place, Santa Ana, California 97025 (Orange County). Per the Pooling and 211

Servicing Agreement that’s filed with the SEC, Deutsche is the sole-designated 212

Trustee for the Securitized Asset Backed Receivables Trust LLC 2006-FR4 213

(“SABR LLC Trust 2006-FR4” or “Trust”)(CIK# 0001020242) (SEC File # 333-214

138183-02). As the Trustee for the SABR LLC Trust 2006-FR4, Deutsche handles 215

management duties on behalf of and for the benefit of the Trust and the Trust’s 216

investors. Per the Federal Financial Institutions Examination Council, Deutsche 217

is regulated by the United Sates Department of Treasury – Office of the 218

Comptroller of Currency (“OCC”). As a national banking association that’s 219

regulated by the OCC, Deutsche is not registered with the State of Georgia 220

Secretary of State corporations division, and they do not have a designated 221

registered agent. Per the OCC, documents concerning legal matters can be served 222

upon any director or officer at any of Deutsche’s nationwide office locations. 223



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Many security deed assignments for lands/homes, and promissory notes that 224

were executed by homeowners/homesteaders throughout out continental 225

Georgia lists Deutsche’s name as being the trustee. Within this matter, 226

SentAsha’s homestead is in the continental area that is styled as Fulton County, 227

Georgia. Deutsche’s name is latched onto both the security deed assignment for 228

SentAsha’s homestead, and the promissory-note that contains SentAsha’s 229

signature. The latching was done via a robo-signers that created and executed 230

false conveyances. In true essence, Deutsche has been squatting on the 231

promissory note and the security deed that is connected to SentAsha’s homestead 232

for approximately 4.85 years. 233

13.) Amy McNulty (f/k/a Amy Stoddard) (“Amy”) Amy McNulty is a 234

Trustee Administrator/Officer at Deutsche, and the authorized signatory of the 235

Pooling and Servicing Agreement (PSA) dated November 1, 2006 for the SABR 236

LLC Trust 2006-FR4. Per the PSA, Article VIII, concerning the Trustee, Section 237

8.01, some of the key duties of the trustee entail curing of all events of default, 238

and examination of trust documents to determine if they are in the form that 239

meets PSA-form requirements. Section 8.01, 3rd paragraph also states that no 240

provision of the PSA shall be construed to relieve the Trustee from liability for its 241

own negligent actions, its own negligent failure to act or its own willful 242

misconduct. By way of the robo-signed false allonge, and the robo-signed false 243

security deed assignment, it is assumed that SentAsha is part and parcel of the 244

Trust that Amy McNulty administers. Under supervision of Deutsche and Ocwen, 245

legal notice of sale advertisements were published in the Fulton County Daily 246

Report — listed Deutsche/Aldridge Connors LLP (Ocwen’s alleged attorney, 247

relevant non-defendant) as being the “attorney-in-fact” and “agent” for SentAsha 248



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KeyAma-Joy WilliamsTM. A revocation of power of attorney letter has been issued 249

and served to the above Defendants including Amy’s subordinate, 250

Hang-Thai Luu, Trust Associate. <(Affidavit Point#16c and Exhibits U1-U3, W1-251

W3, and S1-S7)> 252

Per the Constitution for Georgia,

Article VI: Section I, Paragraphs I, IV,VI • Section II, Paragraph II Section IV Paragraph I, etc. this court has jurisdiction.

Also, this court has jurisdiction over this action because it is brought under the Georgia Consumer Protection Laws.

This venue is proper.

14.) Constitution for the State of Georgia, Article VI, Section I, Paragraph IV 253

Exercise of judicial power. Each court may exercise such powers as necessary 254

in aid of its jurisdiction or to protect or effectuate its judgments; but only the 255

superior and appellate courts shall have the power to issue process in the nature of 256

mandamus, prohibition, specific performance, quo warranto, and injunction. Each 257

superior court, state court, and other courts of record may grant new trials on legal 258

grounds. 259

15.) Constitution for the State of Georgia, Article VI, Section II, Paragraph II 260

Land Titles. Cases respecting titles to land shall be tried in the county where the 261

land lies, except where a single tract is divided by a county line, in which case the 262

superior court of either county shall have jurisdiction. 263

Official Code for Georgia Annotated 264

Per OCGA §9-5-1, this court has authority to issue the requested injunctive relief. 265

Per OCGA §9-4-2, this court has authority to issue the requested declaratory relief. 266

Under OCGA §10-1-390 set seq., the Fair Business Practices Act ("FBPA"), 267

this court has the authority to issue the requested damages. 268



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16.) Qualifying Elementals: This case is concerning unfair business practices with 269

regards to real estate-centered matters within the continental Fulton County area; 270

within the same judicial circuit area as the Fulton County Superior Court — 5th 271

Judicial Administrative District. Ocwen has Georgia corporate citizenry registered 272

with the Secretary of State under control #0225905. As a servicer, Ocwen conducts 273

ample business and administers directives concerning real estate foreclosures 274

throughout the Fulton County area. Although Deutsche is a California-based 275

entity, the real estate that it has latched itself to — is within the geographic confides 276

of the continental Fulton County, Georgia area. The court has jurisdiction over all 277

Defendants because each of them are part and parcel of business transactions 278

within Fulton County, Georgia and because they have facilitated and/or 279

participated in committing unfair business practices within Fulton County, 280

Georgia. 281

17.) Concurrent Jurisdiction, etc: Although the main basis of this verified 282

consolidated complaint is under the FBPA, a portion includes claims for violation 283

of RESPA, FDCPA, and State/Federal Constitutional torts. Per 12 U.S. Code § 284

2614, this court has concurrent jurisdiction over sections 2605, 2607, or 2608 of 285

RESPA claims. Per 15 U.S. Code § 1692i, this court has concurrent jurisdiction 286

over FDCPA claims. Per OCGA §45-3-11 et seq (Loyalty Oath) and OCGA §15-6-6 287

(Oath of Office), Georgia judges and magistrate swear to uphold the Constitution of 288

Georgia and the Constitution of the United States. Also, per the Constitution for 289

the United States, Article 6, Section 3, judicial officers of the state are obligated by 290

oath and affirmation to support the federal constitution. 291



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Affidavit: http://sentasha.com/publicrecords/ocwen/2015affidavit.pdf

Exhibits: http://sentasha.com/publicrecords/ocwen/2015exhibit.pdf

18.) In mid 2013, while SentAsha was reviewing her credit report, she noticed that 292

the mortgage that she had been paying on was discharged in 2011 via bankruptcy. 293

Thereafter, she found out about robo-signing, breaks in the chain of title, the 294

securitization of the note, and the robo-signed false conveyances that were used to 295

transfer the note and the title of her homestead over to Deutsche <Exhibit A: 296

Bankruptcy Discharge Order> <Exhibit B: Experian Report> 297

19.) On May 12, 2006, SentAsha signed a promissory note that was originated by 298

Freemont Investment and Loans. Thereafter, she received a warranty deed from 299

the previous homeowner and conveyed a security deed to Mortgage Electronic 300

Registration Systems (“MERS”). At the time, MERS was the nominee for Freemont 301

Investment and Loan. Freemont’s FDIC Certificate number was 25653. Per the 302

FDIC, Freemont liquidated and closed in July 2008 and was not acquired by any 303

other entity. https://www2.fdic.gov/idasp/confirmation_outside.asp?inCert1=25653 304

<Exhibit D: FDIC Status Report> <Exhibit E: MERS Status Report for Security 305

Deed> The warranty deed and security deed are filed at the Clerk of Superior 306

Court Fulton County, Georgia Warranty Deed: Book 42617, Page 248. Security 307

Deed: Book 42617, Pages 250, 269. 308

20.) Fulton County, Georgia property taxes on SentAsha’s homestead have been 309

paid via an escrow account that was funded from a percentage of the direct loan 310

payments that she made to the various loan servicers/lender (i.e. 311

Freemont/HomEq/Ocwen Loan Servicing LLC). In addition, a homestead 312

http://sentasha.com/publicrecords/ocwen/2015affidavit.pdf

http://sentasha.com/publicrecords/ocwen/2015exhibit.pdf

https://www2.fdic.gov/idasp/confirmation_outside.asp?inCert1=25653



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exemption has existed on my domicile for several years. Exemption code: HFO, 313

HA01; Parcel# ending in 0912. 314

21.) Due to hardship in January 2010, SentAsha filed bankruptcy. Five months 315

thereafter in May 2010, a robo-signed allonge and security deed assignment 316

‘appeared’ and was executed in order to convey the promissory note and security 317

deed to Deutsche Bank National Trust Company as trustee under the Pooling and 318

Service Agreement (“PSA”) dated November 1, 2006 Securitized Asset Backed 319

Receivables LLC 2006 FR-4. Such conveyance was done four years after the cut-off 320

date of the Trust; while SentAsha was in bankruptcy. Ocwen started servicing the 321

loan when the loan was in default1. Per the PSA, the cut-off date was November 1, 322

2006, and the closing date was December 12, 2006 (the extended close-out date 323

grace period as approximately 30 days thereafter.) The servicer under the, PSA 324

was HomEq, (Per Ocwen’s 2011 10-K Annual Report, Page 3, 4th Paragraph, 325

HomEq was sold to Ocwen Loan Servicing under an Asset Purchase Agreement 326

formed in May 2010). <Exhibit F: Bankruptcy Notice of Creditors Meeting. 327

Shows Filing Date> <Exhibit G: Allonge> <Exhibit H: Security Deed Assignment> 328

1 Regarding the Acquiring of a Default Debt

Per the Fair Debt collection Practices Act § 15 USC 1692a subsection 4 , one who receives an assignment or transfer of a debt in default solely for the purpose of facilitating collection of such debt for another is not a creditor. Ocwen is not a secured creditor. They are a debt collector. For Ocwen to say that they are a secured creditor is antithetical to what’s stipulated in the servicer’s role description within the Pooling and Servicing Agreement that governs the Trust and Ocwen’s Nov. 2014 Investor Presentation that was filed with the SEC where it is stated that Ocwen purchased Mortgage Servicing Rights. Also being that a robo-signed false security deed assignment and a robo-signed false allonge exists — the validity of the Defendant’s allegations of having a secured interest in SentAsha’s homestead is in question.



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22.) Squatting on the promissory note that contains SentAsha’s 329

signature In May 2010, robo-signer Noriko Colston executed an allonge in order 330

to convey the promissory note from Sutton Funding LLC to Deutsche Bank 331

National Trust Company as Trustee for the Pooling and Servicing Agreement 332

(“PSA”) dated November 1, 2006 Securitized Asset Backed Receivables LLC Trust 333

2006-FR4 (“SABR Trust 2006 FR-4”). Noriko Colston signed as the Assistant 334

Secretary for Sutton Funding LLC. At the time Noriko Colston was an employee of 335

HomEq Servicing. Point of reiteration: Ocwen entered into a purchase agreement 336

with HomEq in May 2010 <Exhibits F,G><2015 Affidavit Point #8> 337

Diagram 1.2 • Infographic by SentAshaTM Design No. 1436-2015-46-1B-SABR © 2015. All Rights Reserved.



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23.) Squatting on the security deed that’s connected to SentAsha’s 338

Homestead In May 2010, robo-signers Noriko Colston and Joyce Nelson 339

executed an assignment of the security deed. The assignment was requested and 340

prepared by Michelle Schuessler of HomEq Servicing. On this assignment Noriko 341

Colston and Joyce Nelson signed as Assistant Secretaries for Mortgage Electronic 342

Registration Systems (MERS). At the time Noriko Colston was an employee of 343

HomEq Servicing. In reading this, keep in mind that the false conveyances were 344

executed on the day before the Meeting of Creditors/Proof of claim cut-off date 345

during SentAsha’s bankruptcy proceeding. <2015 Affidavit Point/Diagram: #9> 346

<Exhibits F, H> 347

348



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24.) How does SentAsha know that Noriko Colston and Joyce Nelson 349

are Robo-Signers? What is the Proof? In 2011 John O’Brien, the duly elected 350

Register of Deeds of the Commonwealth of Massachusetts Southern Essex District 351

Registry of Deeds, Salem Massachusetts who has held the position since 1977 hired 352

Marie McDonnell, expert Mortgage Fraud and Forensic Analyst, President of 353

McDonnell Analytics to examine over 50,000 deeds, assignments, cancellations 354

that were recorded in John O’Brien’s department. In Marie McDonnell’s audit, 355

amongst many things found, she identified that Noriko Colston and Joyce Nelson 356

were both robo-signers who signed deeds for/as Assistant Secretaries for MERS. 357

By SentAsha’s request, on November 20, 2013, John O’Brien issued 2 affidavits 358

attesting that Noriko Colston and Joyce Nelson are on his department’s robo-359

signers list. See page 47 of Marie McDonnell’s 73-page Audit. 360

http://www.salemdeeds.com/pdf/Audit.pdf <Exhibits I1 – I5: John O’Brien 361

Affidavits> <Exhibits I6 – I8: Marie McDonnell Affidavits> <Exhibits I9 – I11: 362

Robo-Signer List> 363

25.) Below is abridged robo-signing timeline for Noriko Colston that spans across 364

the country: 2011 – Southern Essex District, Massachusetts, Registry of Deeds 365

department. While conducting an audit principals/agents of McDonnell Analytics 366

identifies that within John O’Brien’s department, robo-signed documents were 367

recorded that were executed by Noriko Colston. She was listed as being the being 368

an Assistant Secretary for MERS. <Exhibits I1 ─ I4> 369

May 12, 2010 – Noriko signed a security deed assignment as Assistant 370

Secretary for MERS recorded in Fulton County, Georgia; Book 49082 Page 371

165. <Exhibit G> 372

http://www.salemdeeds.com/pdf/Audit.pdf



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May 17, 2010 – Noriko Colston executed an assignment as Assistant 373

Secretary for HomEq Servicing recorded in Pottawamie County, Iowa; Book 374

2010 – Page 006817. <Exhibit J> 375

May 19, 2010 – Noriko Colston executed an assignment as Assistant 376

Secretary for MERS recorded in Pottawamie County, Iowa; Book: 2010 Page 377

006814. <Exhibit K> 378

26.) An Ohio Appellate court has already recognized the faulty 379

representation of Noriko Colston. In the opinion for Wachovia Bank of 380

Delaware, N.A. v. Jackson, 2011-Ohio-3203 (Case No. 2010-CA-00291– Court of 381

Appeals Stark County, Ohio 5th Appellate District) Page 6, Paragraph 24 states 382

that Noriko Colston submitted an affidavit (in 2010) to an Ohio lower court 383

identifying herself as an assistant secretary of HomEq Servicing (subsidiary of 384

Barclay’s Capital Real Estate, Inc.) The appeals court reversed a lower court’s 385

opinion in favor of the homeowner (plaintiff) due to Wachovia’s lack of standing 386

and Noriko Colston’s affidavit. Per the judges’ opinion Noriko erred in thoroughly 387

substantiating without a shadow of doubt that she truthfully had first-hand 388

knowledge of a homeowner’s account records. 389

27.) The robo-signing scandal clouded so many titles through the USA that 390

even the Congressional Oversight Panel — of the 111th Congress — had to examine 391

the consequences of mortgage irregularities for financial stability and foreclosure 392

irregularities. In November 2010, former Senator Ted Kaufman Chairman of the 393

United States Congressional Oversight Panel issued a 127-page report that 394

highlighted wrongful foreclosures and the dangers of robo-signed documents. The 395

report emphasis that robo-signed documents causes clouded titles, and makes it 396

difficult for anyone (homeowners, servicers, attorneys, etc.) to determine the 397



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rightful title and note holder. The word robo-signer is mentioned over 20 times. 398

Government Printing Office Doc: EXAMINING THE CONSEQUENCES OF 399

MORTGAGE IRREGULARITIES FOR FINANCIAL STABILITY AND FORECLOSURE 400

MITIGATION. LINK: 401

www.gpo.gov/fdsys/pkg/CPRT-111JPRT61835/html/CPRT-111JPRT61835.htm 402

─

28.) Consumer Financial Bureau et al vs. Ocwen et al (United States District 403

Court District of Columbia, 1:13-cv-02025, December 2013) resulted in a consent 404

judgment, settlement agreement of which Ocwen continues to breach. The CFPB 405

& 48-States suit makes mention of Ocwen’s involvement in 17 unfair business 406

practices that have adversely effected homeowners/consumers (3rd party 407

beneficiaries) throughout 48 States; Georgia included. Concerning SentAsha, 408

based on the aforementioned collective unfair/deceptive business acts of 409

principals/agents of Deutsche, and HomEq (acquired by Ocwen in 2010) an 410

assumption has been made that SentAsha’s borrower rights have been waived. 411

The Defendant’s so-called authority was derived from the execution of robo-412

signed false allonge, and a robo-signed false security deed assignment thus, 413

Deutsche’s, and Ocwen’s claims of SentAsha’s waiver of borrower rights is void; 414

authority shouldn’t have been conferred onto them. As a result of such alleged 415

“conferring of borrower rights waiver”, they all have assumed that they have the 416

right to delegate authority over to their tributary-agents who via color-of-authority 417

have presumed to have an apparent right to: 418

http://www.gpo.gov/fdsys/pkg/CPRT-111JPRT61835/html/CPRT-111JPRT61835.htm



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29.) Intermeddle into SentAsha’s communications path by sending 419

her deceptive mailings; false representation/deceptive means in debt 420

collection acts. The letters have been sent from Western Progressive LLC 421

(Altisource subsidiary, relevant non-defendant) under the ‘guise’ of coming 422

from Atlanta-based/Florida-based firm Aldridge Connors LLP (Ocwen’s 423

alleged attorney, a relevant non-defendant). The batch of letters that SentAsha 424

received shows a return address of Aldridge Connors LLP, PO Box 9087 425

Temecula, CA 92589-9087. So from the outside it appears that Aldridge Connors 426

LLP has a corporate mailbox-locale in California. However, the United States Post 427

Office requires a business license and proof of incorporation in order to get a 428

corporate P.O. Box. According to the certified statement from the Secretary of 429

State of California, there isn’t a business by the name of Aldridge Connors LLP 430

that is registered to do business in California. Also, according to the email that I 431

received on December 9, 2014 from Scott Liebschutz Aldridge Connors LLP 432

doesn’t have an office in California. In 2013, SentAsha received mail from Western 433

Progressive LLC that contained the same post office zip code in Temecula, 434

California. Western Progressive LLC (“Altisource subsidiary”) is registered to do 435

business in California. Entity #200835710284. In addition, in 2013, Altisource 436

published Notices of Sale in the Fulton County Daily Report. Thus, based on the 437

provided information, SentAsha can only infer that the debt collection letters 438

actually came from Western Progressive LLC under the ‘guise” of coming from 439

Aldridge Connors LLP. <Exhibit P1, P2: 2015 Aldridge Connor LLP Letter> 440

<Exhibit P3: 2015 Certified Statement from California Secretary of State, Debra 441

Bowen regarding Aldridge Connors LLP><Exhibit P4 – P10: Emails – Scott 442

Liebschutz Nathan and others at Aldridge Connors LLP> On December 11, 2014 443

SentAsha sent a letter of complaint regarding deceptive mailings to Scott Liebschutz 444



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Nathan, the Supervising Partner of Foreclosures at Aldridge Connors LLP (Georgia 445

Office). <Exhibit Q> 446

30.) Handle and store my assigned private Old Age Survivors 447

Insurance Trust Fund account number (a/k/a Social Security 448

Number). On December 3, 2014, SentAsha found out that the attorneys, 449

paralegals and staff of Aldridge Connors LLP (Ocwen’s alleged attorney) has her 450

entire social security number. When she asked Alex Taylor Crandall (relevant non-451

defendant, Supervisor Foreclosures Paralegal @ Aldrdige Connors LLP) from 452

whom he received her private assigned Old Age Survivors Insurance Trust Fund 453

account number, he responded “from a referral”. He didn’t mention Ocwen, 454

Deutsche or the Securitized Asset Backed Receivables LLC. On December 8, 2014 455

SentAsha sent a letter of complaint regarding a breach of privacy to Scott 456

Liebschutz Nathan of Aldridge Connors LLP (Alex’s superior); Faxed, Mailed & 457

Emailed. <Exhibit R> 458

31.) Engage in Power of Attorney Fraud 459

From December 18, 2014 onward, SentAsha’s former name “SentAsha KeyAma-460

Joy WilliamsTM” was been published in the Fulton County Daily Report and 461

Deutsche/Aldridge Connors LLP were listed as being her “attorney-in-fact” and 462

“agent”. On January 9, 2015, SentAsha issued a revocation of Power of Attorney 463

for Deutsche, Ocwen, and Aldridge Connors LLP; revocation also pertains to all 464

unknown others. A copy was sent via certified mail to: 465

Hang-Thai Luu at Deutsche Bank National Trust 466

USPS Cert# 7013 1710 0000 6992 4293 467

Note: Hang-Thai Luu is the Trust Associate, she is a subordinate to Amy McNulty 468



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Marissa Connors of Aldridge Connors LLP 469

USPS Cert# 7013 1710 0000 6992 4309 470

John G. Aldridge Jr. 471

USPS Cert# 7013 1710 0000 6992 4442 (returned as “undeliverable”) 472

<Exhibit S1─ S7> 473

32.) Unfair Debt Collection Practices — Circumnavigation around 474

consumer protection laws, fair debt collection practices by exuding 475

unfair unconscionable actions towards SentAsha. Actions like… 476

» Circumnavigation around debt validation. On November 19th 2014 Aldridge 477

Connor’s LLP debt collection stated that the debt should be disputed within 30 478

days or else it would be considered to be valid. On December 16, 2014, 479

SentAsha rebutted the debt and demanded thorough validation USPS Cert# 480

70131710000069899911. On December 18, 2014 principals/agents of Aldridge 481

Connors LLP via Barry Chester Bramlett CEO of Equity Depot LLC (relevant 482

non-defendants) published a Notice of Sale of SentAsha’s homestead within the 483

Fulton County Daily report legal newspaper. They had done so prior to 484

thoroughly validating the debt. » False Representation of the character, 485

amount, and legal status of the alleged debt along with issuance of threat to 486

take foreclosure action in light of such false representations Although the debt 487

was discharged in bankruptcy, and there exited a corrupt allonge and security 488

deed assignment, the Defendants persisted in debt collection, and wrongful 489

foreclosure attempts. 490

<Exhibit T1: November 19, 2014 Debt Collection Letter, T2: Rebuttal, T3: 491

USPS Delivery Confirmation> <Exhibit U1-U3: December 18, 2014 Notice of 492

Sale Advertisement> 493



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33.) Publishing/use of SentAsha’s common law trademark in the 494

Fulton County Daily Report public notices section of the newspaper 495

without her consent which violated her public constructive notice that 496

went out to the world in September 2013. SentAsha’s public constructive 497

notice includes documented claim to ALL of her intellectual property which 498

includes her trademark “SentAsha KeyAma-Joy WilliamsTM” which has been used 499

for over 20+ years in connection with the following trades: graphic design, web 500

design, fashion design, software-add-in product development, web development, 501

consulting, voice-over, marketing assistance/client services, training, writing, 502

public speaking and research, etc. 503

34.) Violation of SentAsha’s public constructive notice creates a self-504

executing agreement where the transgressor agrees to provide punitive damages 505

for any nonconsensual use of any of her intellectual property. This 506

breach/intellectual property infringement occurred under Ocwen’s direction, 507

Ocwen’s agents. On January 16, 2014 SentAsha sent a 1st notice of cease and 508

desist notice to all involved parties demanding for such infringement to stop. 509

Carbon copies were sent to the agents, principals of Aldridge Connors LLP, civil 510

society, and the general public. <Exhibits U4, U5, U6><Exhibit U7: Aldridge 511

Connors LLP’s rebuttal to SentAsha’s cease and desist notice and revocation 512

letter> 513

35.) Refusing to provide proof of agency that shows that Aldridge 514

Connors has delegated authority to work on behalf of Deutsche / 515

Ocwen: Out of concern of “who” exactly had power of attorney (POA) to send her 516

debt collection letters, SentAsha sent out a request for proof of agency. Neither 517

Ocwen nor their alleged attorney Scott Liebschutz Nathan provided a POA letter 518



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showing authorization from the principals of Ocwen Loan Servicing LLC, 519

Deutsche National Banking Trust or Securitized Asset Backed Receivable LLC 520

stating that he/Aldridge Connor LLP has delegated authority. The alleged agent, 521

Scott L. Nathan has simply stated in an email message that he has POA as if “his 522

words” supersede actual documented delegated authority from the principal(s). 523

36.) Continual attempts to foreclose and sending of letters even after 524

an issuance of a cease and desist notice that called for cessation of false 525

advertisements, trademark infringements, and the sending of a series of dunning 526

letters from Jennifer Ann James of Aldridge Connors (Ocwen’s alleged attorney 527

and a relevant non-defendant) Per Jennifer Ann James’ January 23, 2015 letter, 528

she stated that SentAsha’s revocation of the Power of Attorney Letter and Cease 529

and Desist Notice regarding false advertising and unauthorized publishing of 530

SentAsha’s trademark is nonsensical and non-factual and that SentAsha does not 531

have the right to revoke Deutsche/Aldridge Connor LLP/Ocwen’s agency status. 532

On February 25, 2015, Jennifer Ann James sent a 2nd version of the same letter 533

where she omitted the “nonsensical and non-factual” verbiage. From November 534

2014 – March 2015, Deutsche & Ocwen via their alleged agents Aldridge Connors 535

LLP by way of Scott Liebschutz Nathan, Alex Taylor Crandall, Sarah Lavonne 536

Smith, and Jennifer Ann James continued to attempt to foreclose on SentAsha’s 537

homestead; On January 21, 2015, SentAsha received a notice stating that the 538

foreclosure date was rescheduled for March 3, 2015, file# ending in 658623A; the 539

first date was February 3, 2015 file# ending in 658115A. <Exhibit V1 – V3: 540

January 21, 2015 Notice of Sale Letter> 541

37.) Other unconscionable actions include additional instances of false 542

advertising. Ocwen and their tributary-agents (alleged attorneys) at Aldridge 543



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Connors LLP placed an ad in the Fulton County Daily Report December 18, 2015, 544

page 10-C - Notice of Sale. The ad shows Deutsche as Trustee for the SABR Trust 545

LLC 2006-FR4 and then on January 16, 2015 the ad displays MERS as the lender. 546

Deutsche’s name is not present. Also, in the December 18, 2015 advertisement 547

Aldridge Connor’s name is boldly listed with phone number 404.994.7400 and 548

then on January 16th SentAsha’s common law trademark appears again, Aldridge 549

Connors’ name is removed and Equity Depot LLC is listed as the “firm” with a 550

phone number of 404.994.7400. 404.994.7400 IS THE NUMBER FOR 551

ALDRIDGE CONNORS! What’s interesting is that this switcharooney wasn’t just 552

for SentAsha’s homestead it appeared for several other homes (#public risk 553

#private risk). During a quick comparative analysis, SentAsha noticed at least 554

seven instances of this. Upon calling 404.994.7400, SentAsha was informed that 555

Equity Depot LLC is not the firm of contact and that Aldridge Connors is. Dennis 556

at Aldridge Connors (a relevant non-defendant) never explained why Equity 557

Depot’s name was present within the false advertisement.<Exhibits U1, U2, U3 > 558

<Exhibits W1, W2, W3: January 16, 2015 Fulton Daily Report Notice of Sale 559

Pages: 4B, 4C under zip 30303> On January 28, 2014, SentAsha sent a 2nd cease 560

and desist notice. <Exhibits W4, W5, W6> 561

38.) Refusing to Resolve Complaints − Ocwen continued to evade 562

SentAsha’s questions and complaints about the false conveyances; robo-signed 563

allonge and robo-signed security deed assignment. There has been no resolve of 564

this issue. Such evasiveness regarding the chain of title has even occurred during 565

the Consumer Financial Protection Bureau complaint proceeding; complaint# 566

141216-000127. Instead of bringing forth resolve, they continuously insist that 567

they are the secured party creditor who has a right to foreclose. 568

» Absolute Refusal to Answer Questionnaires – The Defendants have 569



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turned a blind-eye to SentAsha 18-part questionnaire/qualified written requests 570

(“QWRs”). Per Ocwen’s alleged attorney Jennifer Ann James at Aldridge Connors, 571

Ocwen doesn’t have to answer my questionnaire and support their claims of 572

standing and right to foreclose with a notarized affidavit. 573

» Incomplete Fulfillment of QWRs – As of April 7, 2015, the Defendants have 574

left over 20% of my debt validation demands and qualified written requests 575

unanswered. In addition to the direct principals and agents of Ocwen, Ocwen’s 576

agents/affiliates have also failed at fulfilling my QWRs. Instead of fulfilling the 577

request, Sarah Lavonne Smith of Aldridge Connors sent me a letter on December 578

30, 2014 stating that “all other claims are denied.” Within Regulation X of the 579

Real Estate Settlement Procedures Act it doesn’t state that mortgage 580

servicing companies (and their affiliates) can deny QWRs. 581

39.) Issuance of False Affidavit − Ocwen Issued an Affidavit of Lost 582

assignment, although there is a recorded assignment on record. 583

<Exhibits H and O> 584

40.) Obstruction of Customer Relationship Management Calls 585

On August 6, 2014, SentAsha called Ocwen to speak with a customer relationship 586

manager. Vipal answered and refused to move forward with the call after she 587

informed him that she was recording the call. Per his words, Ocwen was recording 588

the call but, he could not continue with the call if she also records. On December 1, 589

2014 – she called Ocwen to speak with a relationship manager. After informing 590

Angelo that she was recording the call, she was told that the call could not 591

continue; although Ocwen was recording the call for quality control purposes. 592

<Exhibits M & N> Audio Links: http://sentasha.com/publicrecords/ocwen/ 593

Folder: obstruction-of-customer-relationship-management-calls 594

http://sentasha.com/publicrecords/ocwen/



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41.) On January 30, 2015, SentAsha sent out a notice of default regarding unfair 595

business practices and the breach of the CFPB 48-State Consent order along with 596

reiteration of the cease and desist notices. SentAsha informed Deutsche, Ocwen, 597

and all of their tributary-agents that their continual unfair acts are grounds for 598

litigation <Exhibits X1,X2,X3> <Exhibit X4: Consent Order/Settlement 599

Agreement Links> 600

www.sentasha.com/publicrecords/ocwen/georgiabankingfinance/ 601

http://files.consumerfinance.gov/f/201312_cfpb_consent-order_ocwen.pdf 602

42.) On February 10, 2015, SentAsha received a frivolous 1099C from Ocwen 603

that contained no correspondence or explanation as to why the 1099C was issued. 604

In response, on February 11, 2015 SentAsha issued a Notice of Rejection of 605

Ocwen’s Creation and Issuance of a Frivolous 1099C. Ocwen listed itself as the 606

creditor. In truth, Ocwen is a servicer. <Exhibit Y1: 1099C Exhibit Y2: Notice of 607

Rejection of the 1099C> 608

43.) This verified consolidated complaint is brought forth based on the 609

following governing standards, principles and precepts:610

Universal Law as demonstrated via nature, etc. 611

Religious precepts: as relayed through ancestral customs and sacred 612

texts, etc.613

Principles of Equity: Maxims of Law, Ancestral Maxims, etc.614

615

United States of America & Georgia Constitutional Law 616

along with previous engagements i.e. 1777 Articles of Confederation) and 617

applicable vintage perpetual treaties (i.e. Amity & Commerce Treaties from 618

1786 to present, etc.619

http://www.sentasha.com/publicrecords/ocwen/georgiabankingfinance/

http://files.consumerfinance.gov/f/201312_cfpb_consent-order_ocwen.pdf



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Statutes of Georgia i.e. Fair Business Practices Act of 1975, 620

OCGA § 10-1-390 et seq., etc.621

Laws of the United States i.e. Real Estate Settlement Procedures Act-622

Regulation X, Fair Debt Collection Practices Act, Interstate Commerce, 623

National Origin Discrimination precepts, etc.624 625

Laws of Nations i.e. United Nations Charter, Organization of American 626

States Charters along with Standards and Protocols, Declarations and 627

Covenants that the United States of America have signed and ratified i.e. UN 628

Int’l Convention on the Elimination of All Forms of Racial Discrimination*, 629

and the OAS American Declaration on the Rights and Duties of Man.630

Case Precedents: 631

Bellistri v. Ocwen Loan Servicing LLC - No. ED 91369 632

Missouri Court of Appeals, Eastern District, Division Five 633

Decision: MERS never held the promissory note. Thus, its assignment of the 634

deed of trust to Ocwen separate from the note had no force. Ocwen held neither 635

the promissory note, nor the deed of trust, Ocwen lacks a legally cognizable 636

interest and lacks standing to seek relief from the trial court. 637

Zervos v. Ocwen Loan Servicing LLC - Civil No. 1:11-cv-03757-JKB 638

United States District Court, D. Maryland 639

Decision: Ocwen violated parts of the Federal Fair Debt Collections Acts. 640

Primarily: 15 USC § 1692e, e(10), e(11), e(2), e(5).641

Consumer Financial Protection Bureau & 48-States (incl. Georgia) 642

v. Ocwen Financial Corporation & Ocwen Loan Servicing LLC 643

United Sates District Court, District of Columbia, Administrative Proceeding 644

No. 3300-F-07/13, 1:13-cv-02025, United States District Court District of 645

Columbia • December 2013 • Consent Judgment, Order, Settlement. 646


Plaintiffs Brought Forth Verified Allegations. Ocwen Settled. 648

Unfair and deceptive business practices i.e. issuance of false affidavits, unfair 649

debt collection practices, wrongful foreclosure attempts, failure to fulfill 650

qualified written requests, double-tracking, and robo-signing, etc. 651

*NOTE: In this Convention, the term "racial discrimination" shall mean any distinction, exclusion, restriction or preference based on race, colour, descent, or national or ethnic origin which has the purpose or effect of nullifying or impairing the recognition, enjoyment or exercise, on an equal footing, of human rights and fundamental freedoms in the political, economic, social, cultural or any other field of public life.




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New York State Department of Financial Services in the 652

Matter of Ocwen Financial and Ocwen Loan Servicing 653

Consent Order/Settled – Re: Breach of Contract – Ocwen’s 654

non-adherence to 2011 Agreement on Mortgage Servicing Practices 655


Case was similar to the CFPB & 48-States allegations including failure to 657

properly validate document execution processes, missing documentation, faulty 658

accounting, and initiation of foreclosure actions without proper legal standing. 659

http://www.dfs.ny.gov/about/ea/ea141222.pdf 660

California Department of Business Oversight, in the Matter of the 661

Accusation of the Commissioner of Business Oversight vs. Ocwen 662

Loan Servicing LLC - Consent Order/ Settlement 663

File No.: 413-0544 • OAH No. 2014100930 • January 2015 664


Case was similar to the CFPB & 48-States allegations including failure to fulfill the 666

State of California’s requests for documentation. Ocwen settled with the California 667

paid sanctions and is prohibited from servicing any new accounts for a year. 668

www.dbo.ca.gov/ENF/pdf/2015/Ocwen%20Loan%20Servicing,%20LLC-669

Consent%20Order.pdf 670

Press Release from California Department of Business Oversight 671

www.dbo.ca.gov/Press/press_releases/2015/Ocwen%20Settlement%20Announ672

cement%2001-23-15.pdf673

Lacombe v. Deutsche Bank National Trust 674

District Court of Appeal of Florida, First District, No. 1D13–4094 675

Decision: The final judgment of foreclosure issued from the lower court was 676

reversed due to Deutsche’s insufficiency of the evidence to support such 677

foreclosure judgment. Deutsche had 5 years to produce competent evidence to 678

prove its right to enforce the note and failed in doing so. 679

U.S. Bank National Association v. Ibanez, 941 N.E. 2d 40, Mass. 2011 680

Decision: Established that the mortgage follows the note as a security as a 681

security interest, but not as a real property interest. No bonafide proof of 682

assignment; identified that the securitization agreement did not contain loan 683

schedules specifically identifying the homeowner’s mortgages as among those 684

assigned. 685

http://www.dfs.ny.gov/about/ea/ea141222.pdf

http://www.dbo.ca.gov/ENF/pdf/2015/Ocwen%20Loan%20Servicing,%20LLC-Consent%20Order.pdf

http://www.dbo.ca.gov/ENF/pdf/2015/Ocwen%20Loan%20Servicing,%20LLC-Consent%20Order.pdf

http://www.dbo.ca.gov/Press/press_releases/2015/Ocwen%20Settlement%20Announcement%2001-23-15.pdf

http://www.dbo.ca.gov/Press/press_releases/2015/Ocwen%20Settlement%20Announcement%2001-23-15.pdf



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United States of America vs. Deutsche Bank AG et al 686

11CIV2976, United States District Court New York 687

Plaintiffs Brought Forth Verified Allegations. Deutsche Settled. 688

Suit contains allegations that are similar to those found within CFPB et al vs. 689

Ocwen et al. Highlighted allegations consisted of creation of false documents 690

during bankruptcy proceedings. 691

692

Case precedents regarding pro se litigants. 693

Haines v. Kerner, 404 U.S. 519, 520, 92 S. Ct. 594, 30 L. Ed. 2d 652 (1972) 694

Holding Principle: Courts are required to liberally construe the complaint and 695

hold it to a less stringent standard than a similar pleading drafted by an 696

attorney. 697

Adopted Uniformities and Best Practices: i.e. Commerce Protocols - 698

Uniform Commercial Code, Restatement (Second) of Contracts, Negotiable 699

Instruments Precepts, Restatement (Third) of Property Mortgages, etc. 700

International Adopted Uniform Moral Standards: 701

United Nations Declaration on the Rights of Indigenous Peoples 702

Articles that focus on property rights: Articles: 8, 10, 27, 29, 32. 703

Excerpts:704

• Article 8.2b - States [Nation-States] shall provide effective mechanisms for 705

prevention of, and redress for: Any action which has the aim or effect of 706

dispossessing them of their lands, territories or resources; 707

• Article 10 - Indigenous peoples shall not be forcibly removed from their 708

lands or territories. No relocation shall take place without the free, prior and 709

informed consent of the indigenous peoples concerned and after agreement on 710

just and fair compensation and, where possible, with the option of return. 711

• Articles 27,29,32, etc. United Nations link to the entire declaration: 712

http://www.un.org/esa/socdev/unpfii/documents/DRIPS_en.pdf 713

714

Note: The announcement of USA acknowledgment and support for the 715

United Nations Declaration on the Rights of Indigenous Peoples has been 716

Issued by President Obama and the USA Department of State: 717

http://www.state.gov/s/tribalconsultation/declaration 718

http://www.un.org/esa/socdev/unpfii/documents/DRIPS_en.pdf

http://www.state.gov/s/tribalconsultation/declaration



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Preamble / Allegations of Law

Total Number of Claims: 11 719

44.) Six of the eleven claims are under OCGA § 10-1-390 et seq - Georgia Fair 720

Business Practices Act with Respect to Loan Servicing & Wrongful Attempted 721

Foreclosure. The Fair Business Practices Act ("FBPA") is a Georgia consumer 722

protection statute that prohibits deceptive unfair wrongful acts in a vast array of 723

transactions either in commerce or trade. It exists in order to protect the 724

consumers and businesses. At the foundation of the FBPA lies adherence to fair 725

business acumen principles. Per § 10-1-391(a)(b), and § 10-1-393(a)(b) under the 726

FPBA, it is mandatory for unfair and deceptive practices to be swiftly stopped, and 727

it is intended for the FPBA to be liberally construed and applied in order to 728

promote its underlying purposes and policies. Thus, the FPBA shall be applied 729

without limiting the scope. With that being stated, an act that may be declared as 730

wrongful via any other Georgia statute or by way of any other Georgia case 731

precedent can be considered to be within the FBPA-fold. The remaining five claims 732

of which SentAsha seeks relief against the Defendants are for state and federal 733

constitutional torts, and abrogation of mortgage-servicing and debt-collection 734

centered laws of the United States. 735

45.) Within each of the following claims the Defendants have been/are directly 736

and/or indirectly active participants who had/have an obligated responsibility to 737

uphold the laws of Georgia, the United States of America, the laws of Nations, and 738

to be respectful of SentAsha’s religious precepts, human rights, and property 739

rights. Per OCGA §10-6-60, the principal is bound for neglect and fraud of agent. 740

The principal shall be bound for the care, diligence, and fidelity of his agent in his 741

business, and hence he shall be bound for the neglect and fraud of his agent in the 742

transaction of such business. 743

OCGA § 10-1-393 (a)(b), Fair Business Practices Act Unfair or Deceptive Practices in Trade and Commerce

The act/practice: False Conveyances — Robo-Signing – Creation, Execution, and Facilitation

of a Fraudulent Allonge and a Fraudulent Security Deed Assignment (against all Defendants)

46.) SentAsha incorporates by reference, the statement of factual allegations 744

paragraphs 18, 21-28, diagrams 1.1, 1.2, 1.3, and reiterates the claims for relief 745

preamble. 746



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47.) SentAsha seeks relief against the Defendants under section § 10-1-393 747

subsection (a) & (b) of the Fair Business Practices Act. 748

48.) As set forth above, under the principals and agents of Deutsche and Ocwen, 749

and by way of the acquisition agreement that was formalized in May 2010 between 750

Ocwen and HomEq (former servicer of the Trust) — the Defendants functioned as 751

a collaborating cooperative coalition whose agenda consisted of funneling assets 752

into the Securitized Asset Backed Receivables LLC Trust 2006 - FR4 by way of false 753

conveyances; a robo-signed false allonge and a robo-signed false security deed 754

assignment. 755

49.) In this matter, as a collective the Defendants facilitated such funneling of an 756

asset into the Trust — 4 years after the Trust’s closing date — during SentAsha’s 757

bankruptcy proceeding<See Exhibits F, G, H>. Such an act is not a new 758

phenomenon for the Defendants. Such activity was part of the foundational claims 759

against the Defendants in the following cases. In 2011, United States of America 760

vs. Deutsche Bank AG et al, 11CIV2976, United States District Court New York, 761

and in 2013 — Consumer Financial Protection Bureau et al vs. Ocwen et al, 762

1:13-cv-02025, United States District Court District of Columbia. By way of both 763

state and federal examination, such allegations were brought forth and both 764

lawsuits were settled outside of court. The state and federal examinations found 765

that the Defendants either engaged in, facilitated or benefited from a pattern and 766

practice of constructive fraud which included robo-signing, and the creation of 767

false conveyances in general; especially during bankruptcy proceedings. 768

50.) Given the fact that the Defendants have treated SentAsha’s complaint letters 769

regarding this act as a micro minor business-as-usual occurrence and have held an 770

adverse nonchalant position that’s absent of attempts to make an amends for such 771

an unfair practice, the Defendants have demonstrated unreasonable intentionality. 772

Under state law, federal law, and case precedents — the creation of false 773

conveyances and robo-signing is form of constructive fraud. In addition, under the 774

Fair Business Practices Act (“FBPA”) it is considered to be an unfair and deceptive 775

act in trade and commerce. 776



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51.) According to the FBPA § 10-1-393: (a) Unfair or deceptive acts or practices 777

in the conduct of consumer transactions and consumer acts or practices in trade or 778

commerce are declared unlawful. 779

(b) By way of illustration only and without limiting the scope of subsection 780

of this Code section, the following practices are declared unlawful: 781

(1) Passing off goods or services as those of another; 782

(2) Causing actual confusion or actual misunderstanding as to the 783

source, sponsorship, approval, or certification of goods or services; 784

(3) Causing actual confusion or actual misunderstanding as to 785

affiliation, connection, or association with or certification by another; 786

52.) The robo-signed false allonge and false security deed assignment gave the 787

deceptive impression that an officer/employee of MERS (assignor) transferred the 788

security deed over to SABR LLC Trust 2006-FR4 and Deutsche as trustee 789

(assignees) when in fact it did not. Assignments and conveyances are to be 790

executed by the assignor who then endorses the note or security deed assignment 791

over to the assignee. Anyone that is authorized to sign on behalf of the assignor 792

shall display that are doing as such, also such authority shall be demonstrated via 793

an issued Power of Attorney (showing proof of agency) from the party(principal) 794

that delegated such authority. In this matter, HomEq/Ocwen affiliated robo-795

signers Noriko Colston, and Joyce Nelson executed a security deed assignment, 796

and Noriko Colston solely executed an allonge in favor of and for the benefit of 797

Deutsche Bank National Trust Company, under Pooling and Servicing Agreement 798

dated November 1, 2006 Securitized Asset Backed Receivables LLC Trust 2006 FR-799

4, Mortgage Pass through Certificates, Series 2006 FR-4, four years after the 800

securitization trust’s closing date. This was done under the guise of being executed 801

by Sutton Funding and MERS (relevant non-defendants). However, the robo-802

signers were not actually Assistant Secretaries for Sutton Funding and MERS. 803

Such an act has caused confusion, and a misunderstanding of who exactly has a 804

legal cognizable interest in SentAsha’s homestead. As a result the title to 805



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SentAsha’s homestead has been corrupted. On paper it appears that the false 806

allonge and false security deed assignment have been legitimately passed over to 807

SABR LLC Trust 2006-FR4 and Deutsche as trustee but in reality they have not. 808

53.) Per UCC § 3-308 codified as OCGA § 11-3-308 Proof of Signatures and 809

Status as Holder in Due Course (a) In an action with respect to an instrument, the 810

authenticity of, and authority to make, each signature on the instrument is 811

admitted unless specifically denied in the pleadings. If the validity of a signature is 812

denied in the pleadings, the burden of establishing validity is on the person 813

claiming validity. 814

54.) Both the public and the plaintiff have been misled and affected by the 815

Defendants actions. <See 2015 Affidavit Points 8,9><Exhibits G,H> 816

55.) Damage that SentAsha incurred as a result of the Defendant’s unfair 817

business acts, and the damages are outlined in the paragraphs 142, 143, 146, 149, 818

and 150. 819

OCGA § 10-1-393a, Fair Business Practices Act Unfair or Deceptive Practices in Trade and Commerce

The act/practice: Submission of a False Security Deed Assignment

onto the Fulton County, Georgia Superior Court Real Estate Records for Filing and then Assuming Authority Based on Such False Allonge and

False Security Deed Assignment (against all Defendants)



preamble. 822



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57.) SentAsha seeks relief against the Defendants under section § 10-1-393a of 823

the Fair Business Practices Act. Under the tutelage of the Defendants, after the 824

robo-signers created the false allonge and false security deed — they were 825

submitted to the Fulton County, Georgia Superior Court Real Estate Recording 826

Division for filing on the County’s Public Records. 827

58.) Per OCGA §10-6-60, the Principal is bound for neglect and fraud of agent. 828

Such actions are a form of fraud upon Fulton County’s real estate records and is an 829

unfair business act against SentAsha (consumer/homeowner) and the public. 830

59.) In addition, such an act is unlawful under Georgia House Bill 985 codified 831

as OCGA §16-10-20 et seq. Per Georgia House Bill 985 (§16-10-20.1): 832

(1) It shall be unlawful for any person to knowingly file, enter, or record any 833

document in a public record or courts within Georgia or of the United States 834

knowing or having reason to know that such lien or encumbrance document is false 835

or contains a materially false, fictitious, or fraudulent statement or representation; 836

or 837

(2) Knowingly alter, conceal, cover up, or create a document and file, enter, or 838

record it in a public record or court of this state or of the United States knowing or 839

having reason to know that such document has been altered or contains a 840

materially false, fictitious, or fraudulent statement or representation. 841

(c) Any person who violates subsection (b) of this Code section shall be guilty of a 842

felony and, upon conviction thereof, shall be punished by imprisonment of not less 843

than one nor more than ten years, a fine not to exceed $10,000.00, or both. 844

60.) Protocols Regarding Submission of False Conveyances - The above 845

wrongful act is codified in the criminal code. Per OCGA §16-10-20 false statements 846

and writings, concealment of facts, and fraudulent documents in matters within 847

jurisdiction of state or political subdivisions is unlawful. Per OCGA §44-14-33, in 848

order to admit a mortgage to record, it must be attested by or acknowledged before 849



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an officer as prescribed for the attestation or acknowledgment of deeds of bargain 850

and sale; and, in the case of real property, a mortgage must also be attested or 851

acknowledged by one additional witness. In the absence of fraud, if a mortgage is 852

duly filed, recorded, and indexed on the appropriate county land records, such 853

recordation shall be deemed constructive notice to subsequent bona fide 854

purchasers. 855

61.) Under the FBPA, acts that may be declared as wrongful via any other Georgia 856

statutes or by way of any other Georgia case precedents can be interlaced within 857

the FBPA. 858



and 150. 861

O.C.G.A. § 10-1-393a, Fair Business Practices Act Unfair or Deceptive Practices in Trade and Commerce

The act/practice: Unjust Enrichment. Collecting Payments on a Discharged Note

While Justifying Such Payment Collection via a Fraudulent Security Deed Assignment and a Fraudulent Allonge

(against all Defendants)



preamble. 864

64.) SentAsha seeks relief against the Defendants under OCGA §10-1-393a of the 865

Fair Business Practices Act. 866

65.) Unjust enrichment entails wrongfully receiving profits and/or benefits at the 867

expense of another. The Defendants as trustee/mortgage servicer/debt collector 868



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have a legal duty to abide by Bankruptcy laws regarding discharge, and Georgia 869

laws regarding the unlawful act of creating and executing false conveyances. Being 870

that SentAsh’a mortgage note was discharged in bankruptcy and that the security 871

deed assignment and the allonge are fraudulent robo-signed conveyances, Ocwen’s 872

execution of a modification and collection of payments were unjust. As a result of 873

the Defendants actions, they unjustly benefited and collected approximately 874

$23,500 USD from SentAsha since 2010. 875

66.) In Bellistri vs. Ocwen, Missouri Court of Appeals, Eastern District Division 876

Five, March 3, 2009, No. ED91369 it was decided that as Ocwen holds neither the 877

promissory note, nor the deed of trust, Ocwen lacked a legally cognizable interest 878

and lacked standing to seek relief from the trial court. Also, per the UCC § 3-201 879

(OCGA § 11-3-201), two elements required for negotiation are (1) transfer of 880

possession to the transferee (2) indorsement by the holder. 881

67.) In this matter, there exists a myriad of issues. First, we have instances of 882

robo-signing and we have color-of-transfer-into-trust where on the face of the false 883

conveyances it is alleged that assets have been pooled into the Trust in 2010. 884

However, according to the Trust’s very own governing documents — the Pooling 885

and Service Agreement (“PSA”) — the Trust’s closing date was in 2006. According 886

to (a) the SEC certified copy of the Trust’s PSA, (b) the certified security deed 887

assignment as provided via the Real Estate Division of this said court (Fulton 888

County, Georgia Superior Court), (c) John O’Brien’s and Marie McDonnell’s 889

affidavits, and (d) certified copies of security deed assignments from the Real 890

Estate Recording Division of Pottawamie County, Iowa — it is conclusive that the 891

robo-signers were not Assistant Secretaries for MERS and Sutton Funding, the 892

asset may not have been placed into the Trust — if the asset is inside of the Trust it 893

is by way of breach of the pooling and servicing agreement and security exchange 894



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commission laws, and Ocwen never had a legal right to administer a modification 895

because their alleged authority was based on a set of false conveyances and breach 896

of trust. 897

69.) As you read this, please keep in mind that neither this particular claim nor 898

the other 10 claims are for SEC violations or breach of trust. This — claim #3 — is 899

for unfair and deceptive practices via unjust enrichment. The SEC violations and 900

the Pooling and Service Agreement breach of trust information is highlighted to 901

merely provide an illustrative irrefutable backdrop that serves as the planted legal 902

governing roots that the Defendant’s practices are antithetical to. 903

70.) Ocwen’s assumed right of modifying SentAsha’s loans and collecting 904

payments is built upon the existence of a fraudulent robo-signed defective allonge 905

and security deed assignment. Per OCGA § 44-14-64 (a) All transfers of deeds to 906

secure debt shall be in writing; shall be signed by the grantee or, if the deed has 907

been previously transferred, by the last transferee; and shall be witnessed as 908

required for deeds. In this case the grantee/last transferee did not sign the 909

conveyance. 910

71.) The robo-signers Noriko Colston and Joyce Nelson were not Assistant 911

Secretaries for Sutton Funding (last transferee on the allonge) or MERS (last 912

transferee on the security deed assignment). MERS was the nominee for Freemont 913

Investment and Loan and their successors or assigns. Freemont closed in 2008. 914

Per the FDIC, Freemont folded in 2008 and there was no acquiring institution 915

thus, MERS’ nominee status for Freemont ceased as of 2008. 916



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72.) Regarding the bankruptcy discharge, Pursuant to the bankruptcy code, 11 917

USC §524, a discharge voids any judgment at any time that may obtained, operates 918

as an injunction against the commencement or continuation of an action, the 919

employment of process, or an act to collect, recover or offset any such debt as a 920

personal liability of the debtor, whether or not discharge of such debt is waived. 921

Also, In Johnson v. Home State Bank, 501 U.S. 78, 84 (1991) it was decided that 922

only a creditor with a valid security interest may enforce has right to demand 923

payment and foreclose. In this matter the Defendants are neither the creditors nor 924

holders of the original note, and there is no existence of a valid security interest 925

that is absent of fraud. However, the Defendants have assumed authority and 926

benefitted from the facilitation, creation and execution of false conveyances that 927

have been used since 2010 under the guise of providing them with a valid security 928

interest. In reiteration, in both United States of America vs. Deutsche Bank AG et 929

al, 11CIV2976 and Consumer Financial Protection Bureau et al vs. Ocwen et al , 930

1:13-cv-02025 — Ocwen and Deutsche settled both lawsuits that contained explicit 931

findings in regards to their creation of false documents during bankruptcy 932

proceedings and a myriad of other unfair deceptive practices. In both cases the 933

Defendants settled. 934

73.) Per OCGA §44-14-33 In order to admit a mortgage to record, it must be 935

attested by or acknowledged before an officer as prescribed for the attestation or 936

acknowledgement of deeds of bargain and sale; and, in the case of real property, a 937

mortgage must also be attested or acknowledged by one additional witness. In the 938

absence of fraud, if a mortgage is duly filed, recorded, and indexed on the 939

appropriate county land records, such recordation shall be deemed constructive 940

notice to subsequent bona fide purchasers. In this matter, Noriko was not the 941



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Assistant Secretary for MERS, thus the execution of the security deed assignment is 942

not absent of fraud. Under Georgia law conveyances based on fraud is not deemed 943

as a constructive notice to subsequent bona fide purchasers. 944

74.) The Defendants were unjustly enriched at the expense of SentAsha. Under 945

the FBPA, acts that may be declared as wrongful via any other Georgia statutes or 946

by way of any other Georgia case precedents can be interlaced under the FBPA. 947

75.) Damage that SentAsha incurred as a result of the Defendant’s unfair business 948

acts, and the damages are outlined in the paragraphs 142, 143, 146, 149, and 150. 949

O.C.G.A. § 10-1-393a, Fair Business Practices Act Unfair or Deceptive Practices in Trade and Commerce

The act/practice: Wrongful Loan Servicing Acts

(against Ocwen, Ron Farris, and Mable Scarlett)


paragraphs 18, 21-35, 38, 39-42, diagrams 1.1, 1.2, 1.3, and reiterates the claims for 951

relief preamble. 952

The unannotated list of wrongful loan servicing acts includes: 953

Reluctance in fulfilling qualified written requests, questionnaires, thorough 954

rebuttal of affidavits, etc. 955

Obstruction of customer relationship management calls 956

Breach of Privacy 957

Reluctance to resolve color-of-title issues 958

Issuance of a frivolous 1099C 959

Constant misrepresentation – on certain occasions the Defendants purport to 960

be the secured creditor while on other occasions they stipulate themselves to 961

be servicers that are collecting on a debt. 962

Note: Such contradictory allegations are contradictory to what Ocwen has 963

recorded in their November 2013 investor presentation that’s on file with the 964

Securities Exchange Commission, Pages 10, 23, Form 8-K, current report, 965



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received in the SEC on November 12, 2013, under the name of Ocwen 966

Financial Corporation, File No. 001-13219, pursuant to the provisions of the 967

Securities Exchange Act of 1934. 968

77.) SentAsha seeks relief against the Defendants under section § 10-1-393a of the 969

Fair Business Practices Act. 970

971

78.) According to the guidelines of the FBPA and the standing consent order and 972

settlement agreement that Ocwen has with the Consumer Financial Protection 973

Bureau (“CFPB) and 48-States (Georgia included), the loan servicing acts of Ocwen 974

and its principals and agents, as outlined above within SentAsha’s statement of 975

factual allegations, is evidence of continual unfair and deceptive practices which is 976

unlawful in the eyes of the FBPA. Below is further elaboration on a couple of 977

highlighted wrongs and how such acts violate the FBPA. 978

979

79.) Ocwen’s Obstruction of the Special Point of Contact (“SPOC”) 980

Customer Service Relationship Management Calls Why is this unfair? 981

Because on several occasions when SentAsha called Ocwen, an announcement was 982

made that the calls may be recorded for quality control purposes. When SentAsha 983

informed the Ocwen customer service relationship management reps that she too 984

was also recording, Ocwen’s reps refused to move forward. In terms of basic 985

algebraic equations x+2 = 4 where “x” is “2” #balanced #true #fair. In the case of 986

Ocwen’s algebra — they want “x” to be 4, 5, 1500, 7000 — whatever number they 987

decide — regardless of the level of imbalance. #Ocwen’s Algebra Doesn’t Add Up# 988

If homeowners are not permitted to record calls then Ocwen should not be 989

permitted to record any calls. Given the fact that there has been a slew of 990

complaints from thousands of consumers, federal authorities, state regulators and 991

case precedents/consent judgment orders which demonstrate that Ocwen has 992

engaged in unfair business practices, it would be naive for anyone to speak to 993



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Ocwen’s reps without recording the conversation. Ocwen’s obstruction of the 994

SPOC customer relationship management calls in light of the existing consent 995

order/settlement agreement with CFPB, the State Georgia, and 47 other states; this 996

constitutes a violation of the FBPA. <See CFPB vs. 48-States Settlement Term 997

Sheet, Part IV, Section C, Exhibits A22-A25> 998


Point of reiteration: Per the FBPA § 10-1-391a. The purpose of the FBPA shall 1000

be to protect consumers and legitimate business enterprises from unfair or 1001

deceptive practices in the conduct of any trade or commerce in part or wholly in 1002

the state. It is the intent of the General Assembly that such practices be swiftly 1003

stopped, and this part shall be liberally construed and applied to promote its 1004

underlying purposes and policies. 1005

80.) Sharing of SentAsha’s assigned private Old Age Survivors 1006

Insurance Trust Fund Account number with 3rd parties. Under the FBPA 1007

the aforementioned act is a violation of OCGA § 10-1-393.8. Protection from 1008

disclosure of an individual's social security number. The Defendant’s alleged 3rd 1009

party attorneys serving as debt collectors, requested that SentAsha provide her 1010

complete 9-digit private assigned social security number over the phone before 1011

answering questions regarding debt collection letters that were mailed to her from 1012

Western Progressive LLC ‘under the guise’ of coming the Defendant’s alleged 1013

attorneys, Aldridge Connors LLP. At the time of the request there was evidence of a 1014

misrepresentation of geographic location and the Defendant’s alleged attorney 1015

absolutely refused to show proof of agency. SentAsha refused to provide them with 1016

her social security number although they asked for her to verify it on 2 occasions. 1017




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Notice of this has already been provided to the Social Security Administration 1018

Trustees and other pertinent Federal agencies. 1019

81.) Issuance of false affidavit of lost assignment. 1020

The Defendants facilitated the issuance of an affidavit of lost assignment although 1021

there was already an assignment recorded on record. This constitutes a deceptive 1022

business practice and in violation of the FBPA. 1023

82.) Per OCGA § 10-1-391 (a)(b) of the FBPA, consumers are to be protected from 1024

unfair or deceptive practices in the conduct of any trade or commerce in part or 1025

wholly in the state. Parties who engage in such practices are to be swiftly stopped, 1026

and such unfair deceptive practices shall be liberally construed and applied to 1027

promote the FPBAs underlying purposes and polices. In addition per the Georgia 1028

General Assembly, the FPBA is to be interpreted and construed consistently with 1029

interpretations given by the Federal Trade Commission in the federal courts 1030

pursuant to Section 5(a)(1) of the Federal Trade Commission Act (15 U.S.C. Section 1031

45(a)(1)), as from time to time amended. 1032

83.) When Ocwen issued the loss of affidavit in light, of there being an affidavit 1033

recorded on the public records this was an act of misrepresentation. In 2013, at the 1034

time of issuance of their affidavit of lost assignment they could have sent SentAsha 1035

a copy of the security deed assignment that was recorded on the Fulton County 1036

public records (since 2010) and elected not to do so. Such a selective action was 1037

done in an attempt to keep attention away from the publicly recorded robo-signed 1038

false conveyance that was not executed by a MERS employee. 1039



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84.) Failure to substantiate why a frivolous 1099C was issued to 1040

SentAsha; even after receiving a notice of rejection and a demand for 1041

validation. On the 1099C that Ocwen issued they have listed themselves as a 1042

Creditor when in fact they are not a ‘Creditor’. SentAsha issued a notice of 1043

rejection of the 1099C and requested for them to substantiate their claim via an 1044

affidavit signed under the penalty of perjury. The Defendants have defaulted due to 1045

lack of response. These actions constitutes misrepresentation and is a deceptive 1046

business practice in violation of the FBPA. 1047

85.) Reiteration Point: Consent Order Settlement Holding - It has 1048

already been decided that the aforementioned are forms of unfair deceptive 1049

business practices as documented by the Consumer Financial Service Bureau and 1050

the regulators of 48 states who conducted examinations of Ocwen. Per the 1051

December 19, 2013 Consumer Financial Service Bureau Fact Sheet, announcement 1052

of the $2 billion dollar settlement with Ocwen was made and it was documented 1053

that Ocwen’s pattern of conduct has affected individual consumers and the public-1054

at-large resulting in over 185,000 consumers who have lost their homesteads. In 1055

the uncontested settlement Ocwen agreed to comply to Dodd-Frank Wall Street 1056

Reform and Consumer Protection Act and uniform consumer protections laws for 1057

each of the 48 states (Georgia included). CFPB Fact Sheet Link: 1058

http://files.consumerfinance.gov/f/201312_cfpb_factsheet_ocwen.pdf 1059

86.) SentAsha’s statement of factual allegations and claims demonstrate that 1060

Ocwen’s pattern of practice has not changed thus, they are in violation of the FPBA. 1061

87.) In reading and analyzing this particular claim (#4), please keep in mind that 1062

claim is violation of OCGA§ 10-1-393 (a)(b) There is mention of the CFPB consent 1063

http://files.consumerfinance.gov/f/201312_cfpb_factsheet_ocwen.pdf



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order, consent judgment, settlement agreement and violations in order to provide 1064

an illustrative irrefutable backdrop that serves as the planted legal governing roots 1065

that the Defendant’s wrongful loan servicing practices are antithetical towards. 1066

88.) What does Ronald Matthew Faris and Mable Scarlett have to do with 1067

Ocwen’s antithetical practice of wrongful loan servicing? Ron is the principal over 1068

it and Mable is the agent who ensures that Ocwen retains its’ licensing/registration 1069

in the State of Georgia (Georgia Department of Banking and Finance) so that they 1070

can continue with such unfair carryin’ on. 1071



149, and 150. 1074

OCGA § 10-1-393 (a)(b), Fair Business Practices Act Unfair or Deceptive Practices in Trade and Commerce

The act/practice: Wrongful Attempted Foreclosures



paragraphs 28, 29-37, 18, 21-27, diagrams 1.1, 1.2, 1.3, reiterates the claims for 1076

relief preamble, and the verbiage for OCGA § 10-1-393 (a)(b) as stated in claim #1. 1077

91.) The unannotated lists within the points includes the following list of unfair 1078

and deceptive acts regarding the wrongful processing of attempted foreclosures: 1079

Sending of deceptive debt collection mailings that contain misrepresentation 1080

Breach of Privacy 1081

Power of Attorney Fraud 1082

Circumnavigation around the consumer protection and debt collection 1083

practices laws 1084

Intellectual Property Infringement 1085

False Advertising 1086



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Refusal to provide Proof of Agency 1087

Issuance of a False Affidavit 1088

Presentment of false robo-signed conveyances in an attempt 1089

to substantiate a right to foreclose 1090

92.) SentAsha seeks relief against the Defendants under section § 10-1-393 (a)(b) 1091

of the Fair Business Practices Act. 1092

93.) According to the guidelines of the FBPA and the standing consent order that 1093

Ocwen has with the Consumer Financial Protection Bureau (“CFPB”) and Georgia 1094

(including 47 States), the unfair and deceptive attempted foreclosure by Ocwen 1095

and its principals and agents, as outlined above within SentAsha’s statement of 1096

factual allegations is evidence of continual unfair and deceptive practices. 1097

94.) In reading and analyzing this particular claim (#5), please keep in mind that 1098

claim is violation of OCGA§ 10-1-393 (a)(b) There is mention of the CFPB consent 1099

order, consent judgment, settlement agreement and violations in order to provide 1100

an illustrative irrefutable backdrop that serves as the planted legal governing roots 1101

that the Defendant’s wrongful attempted foreclosure practices are antithetical 1102

towards. 1103


acts, and the damages are outlined in the paragraphs 142-148, and 150. 1105

12 USC § 2605 Violation of the Real Estate Settlement Procedures Act

(RESPA, Regulation X) (against Deutsche, Ocwen, Ronald Matthew Faris)


paragraphs 28, 38, 40-41, diagrams 1.1, and reiterates the claims for relief 1107

preamble. 1108



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97.) SentAsha seeks relief against the Defendants under RESPA 12 USC § 2605, 1109

Regulation X. According to RESPA Regulation X, the Defendants are obligated to 1110

answer borrower’s qualified written requests, provide notice of receipt of inquiry, 1111

address error resolution, fulfill escrow and accounting information requests, abide 1112

by general servicing policies, procedures, and requirements, and prevent wrongful 1113

foreclosures. 1114

98.) Per 12 U.S. Code § 2605 (e) mortgage servicing companies have a duty to 1115

follow structured procedures when handling qualified written requests (“QWR”): 1116

(1) After receiving the QWR, a notice of receipt of inquiry is sent. The servicer shall 1117

provide a written response acknowledging receipt of the correspondence within 5 1118

days (excluded holidays and weekends). 1119

(2) Action with respect to inquiry Not later than 30 days (excluding holidays and 1120

weekends) after the receipt from any borrower of any qualified written request 1121

under paragraph (1) and, if applicable, before taking any action with respect to the 1122

inquiry of the borrower, the servicer shall (A) make appropriate corrections in the 1123

account of the borrower, including the crediting of any late charges or penalties, 1124

and transmit to the borrower a written notification of such correction (which shall 1125

include the name and telephone number of a representative of the servicer who can 1126

provide assistance to the borrower); 1127

(B) after conducting an investigation, provide the borrower with a written 1128

explanation or clarification that includes— 1129

(i) to the extent applicable, a statement of the reasons for which the servicer 1130

believes the account of the borrower is correct as determined by the servicer; and 1131

(ii) the name and telephone number of an individual employed by, or the office 1132

or department of, the servicer who can provide assistance to the borrower; or 1133



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(C) after conducting an investigation, provide the borrower with a written 1134

explanation or clarification that includes— 1135

(i) information requested by the borrower or an explanation of why the 1136

information requested is unavailable or cannot be obtained by the servicer; and 1137

(ii) the name and telephone number of an individual employed by, or the office 1138

or department of, the servicer who can provide assistance to the borrower. 1139

99.) Ocwen with Ron being a leading Principal are obligated to adhere to 1140

governing principles of RESPA Regulation X. After SentAsha issued her 2013 1141

Affidavit of Truth (September 2013) which included points regarding debt 1142

validations, Ocwen failed to respond. As a result, SentAsha issued a notice of 1143

default (December 2013) regarding their lack of response on December 2013. 1144

Thereafter, there were periodic responses from various attorneys however, the core 1145

issues were not resolved, and there was not thorough fulfillment of SentAsha’s debt 1146

validation demands, and the Defendants absolutely refused to answer SentAsha’s 1147

questionnaires. By way of the Consumer Financial Protection Bureau’s complaint 1148

mechanism from Jan 2014 – March 2015, Ocwen reached a QWR fulfillment rate 1149

of approximately 80% fulfillment but has failed to bring forth reasons for the break 1150

in the chain of title and the false conveyances. 1151

100.) Although, Ocwen has been more responsive in light of SentAsha’s CFPB 1152

complaint, the fact still stands that prior to the presence of the Federal regulators, 1153

Consumer Financial Protection Bureau (“CFPB”) and the Office of the Comptroller 1154

of Currency (“OCC”), the Defendants abrogated RESPA Regulation X. Ocwen, 1155

under the leading tutelage of Ron and their attorneys were withholding some of the 1156

RESPA-Regulation X-Compliance-Waters like the Hoover dam. 1157



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101.) To date, some unanswered items include requests for certified copies of 1158

documents, affidavit of fact to substantiate claims of being a secured creditor, 1159

justification for issuance of a 1099C, questionnaires regarding the allonge, 1160

assignment, and the Trust that is allegedly holding the title/note connected to 1161

SentAsha’s signature and homestead. 1162

102.) Deutsche solely as the Trustee, and Amy McNulty (f/k/a Amy Stoddard) as 1163

the designated Trust Officer/Direct Signor of the Trust Agreement for the SABR 1164

LLC Trust 2006-FR4 are obligated to adhere to RESPA, Regulation X. 1165

Furthermore, In Frethey v. Durant, 48 N.Y.S. 839 (N.Y.A.D. 1 Dept. 1897), it was 1166

held that: “When a fiduciary relation is shown to exist, and property or property 1167

interests have been entrusted to an agent or trustee, the burden is thrown upon 1168

such agent entrusted to render an account, and to show that all his trust duties 1169

have been fully performed, and the manner in which they have been performed. It 1170

is assumed that the agent or trustee has means of knowing, and does know, what 1171

the principal or cestui que trust, cannot know, and is bound to reveal the entire 1172

truth” 1173

103.) If the Defendant’s claim that SentAsha is not a party to the Trust then the 1174

logical questions are: “If SentAsha is not a party to the Trust then why is it that 1175

Deutsche and Ocwen gave authorization for the printing of a Notice of Sale 1176

Advertisement in the December 16, 2015 and January 16, 2015 Fulton County Daily 1177

Report Legal Newspaper stating that Deutsche/Aldrige Connors LLP is SentAsha’s 1178

attorney-in-fact and agent? Why is that for 16+ months whenever SentAsha 1179

formally asked if her private assigned Old Age Survivors Insurance Trust Fund 1180

Account number is interlaced with any CUSIPS within the SABR LLC Trust 2006 – 1181

FR4, Deutsche, Ocwen and all of their attorneys became nonresponsive and quiet 1182



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like church mice during communion, quiet like a masjid between prayer times, 1183

quiet like the pauses between the blowing of the shofar, quiet like a law library’s 1184

environment. 1185

104.) Allegorically speaking there exists a rare silence on side A of their cassette 1186

tape when it comes to the robo-signing, break in the chain of title, and trust-related 1187

questions and then on side B of their cassette tape you can clearly hear a rare 1188

nonstop utterance of “We have a right to foreclose. We are a secured creditor.” “We 1189

have right to foreclosure. We are a secured creditor.” 1190

105.) As a result of the Defendants’ RESPA Regulation X violations, SentAsha has 1191

suffered a loss of time, energy and resources that were required in order to do 1192

consistent follow-up over the past 16+ months and to reinforce the laws and 1193

regulations that exist to protect her consumer rights, human rights, property rights, 1194

3rd party beneficiary rights. Although the laws and precedents for such protection 1195

exists in black-letter the Defendants acts demonstrate continual intentional 1196

disobedience. Damage that SentAsha incurred as a result of the Defendant’s unfair 1197

business acts, and the damages are outlined in the paragraphs 142, 143, 146, and 1198

150. 1199

Breach of Contract Obligations that Were Partly Instituted to Benefit and Ensure Protections of

3rd Party Beneficiaries (Homeowners/Consumers in Georgia)

The act/practice:

Abrogation of the Standing December 2013 Consent Judgment/Settlement Agreement/Consent Order

Consumer Financial Protection Bureau et al



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vs. Ocwen Financial and Ocwen Loan Servicing LLC

(against Ocwen, Ronald Matthew Faris, and Mable Scarlett)


paragraphs 28, 18, 21-42, diagrams 1.1, 1.2, 1.3, and reiterates the claims for relief 1201

preamble, along with reiteration of Claims 1-6 and 8-11. 1202

107.) As a consumer/homeowner (3rd party beneficiary) SentAsha seeks relief 1203

against the Defendants under the existing consent order and settlement agreement 1204

that was executed between Ocwen, the CFPB, the State of Georgia, and 47 other 1205

states. Under this agreement consumers/homeowners’ rights were to be respected 1206

and honored and Ocwen agreed to obey Georgia’s laws with regards to servicing 1207

and foreclosure processing. Per OCGA § 9-2-20 (b), the beneficiary of a contract 1208

made between other parties for his/her benefit may maintain an action against the 1209

promisor on the contract. 1210

108.) By way of an extensive examination and investigations the Consumer 1211

Financial Service Bureau and 48-states found it necessary to sue Ocwen. The 1212

statement of factual allegations, supporting affidavit and exhibits for this verified 1213

complaint illustrate the Defendant’s pattern of unfair and deceptive practices 1214

which is a pure breach of the standing consent order, consent judgment and 1215

settlement agreement that Ocwen is currently obligated to uphold. (For links see 1216

below*) 1217


business acts, and the damages are outlined in the paragraphs 142-150. 1219

Violation of the Constitution for the State of Georgia Enumeration Clause/ Inherent Rights Article I, Section I, Paragraph XXIX



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(against Deutsche and Ocwen)


paragraphs 28, 31, 33, 36, diagrams 1.1, 1.2, 1.3, and reiterates the claims for relief 1221

preamble. 1222

111.) Constitution for the State of Georgia - Action 8, Principle Paragraph XXIX : 1223

Enumeration of rights not denial of others. The enumeration of rights herein 1224

contained as a part of this Constitution shall not be construed to deny to the 1225

people any inherent rights which they may have hitherto enjoyed. 1226

112.) Per the Random House Dictionary of English Language, 1968 page 685 1227

Inherent - Permanently existing; naturally pertaining to; inalienable; innate, inborn. 1228

113.) Per the Black’s Law Dictionary 4th Edition. 1229

Inhere – To exist in and inseparable from something else; to stick fast. Majestic 1230

Theater Co. v. Lutz, 210 Ky. 92, 275 S.W. 16, 20 1231

Inherent Power – An authority possessed without its being derived from another. 1232

A right, ability, or faculty of doing a thing, without receiving that right, ability or 1233

faculty from another. 1234

114.) One of SentAsha’s inherent rights is my right to freely contract and the right 1235

to rescind contracts and issue revocation letters. Per the January 23, 2015 letter of 1236

Ocwen’s alleged tributary-agent Jennifer Ann James of Aldridge Connors LLP, 1237

such right doesn’t exists and is nonsensical. <Exhibit U7> 1238

So, Ocwen and the tributary-agents that work for their behalf and have it fixed in 1239

their minds that they are superior to the dictates provided via the Supreme Creator 1240

of the Universe, and that they are superior to what is documented within the 1241

Georgia Constitution. 1242



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acts, and the damages are outlined in the paragraphs 142, 143, 146, and 150. 1244

Violation of the Constitution for the United States of America Enumeration Clause/ Inherent Rights

Amendment 9 (against Deutsche and Ocwen)


paragraphs 28, 31, 33, 36, diagrams 1.1, 1.2, 1.3, and reiterates the claims for relief 1246

preamble. 1247

117.) Constitution for the United States of America – Amendment 9: 1248

The enumeration in the Constitution, of certain rights, shall not be 1249

construed to deny or disparage others retained by the people. 1250

118.) Per the Black’s Law Dictionary 4th Edition 1251

Shall – As sued in statutes, contracts, or the like, this word is generally 1252

imperative or mandatory. 1253

Retain – To continue to hold, have, use, recognize, etc, and to keep. 1254

Enumerated – This term is often used in law as equivalent to “mentioned 1255

specifically,” as in speaking of “enumerated” governmental powers, items of 1256

property or articles in a tariff schedule. 1257

Construe – to put together; to arrange or marshal the words of an instrument. 1258

To ascertain the meaning of language by a process of arrangement and 1259

inference. 1260

Disparage – to connect unequally; to match unsuitably. 1261

119.) In light of amendment 9, if the Constitution limits the state and federal 1262

government’s power to interfere with the people’s personal rights, then, Ocwen and 1263



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Deutsche — as corporations that exist by way of licensing, registration, regulation, 1264

and authorization from state and/or federal government, do not have authority to 1265

abrogate the inherent rights of the people. 1266

120.) In reiteration of claim 8, SentAsha’s inherent rights shall not be 1267

construed, denied or disparaged. Thus, she retains a right to freely contract and 1268

the right to rescind contracts and issue revocation letters. Per the January 23, 2015 1269

letter of Ocwen’s alleged attorney-agent Jennifer Ann James of Aldridge Connors 1270

LLP, such right doesn’t exists and is nonsensical. <Exhibit U7> 1271


business acts, and the damages are outlined in the paragraphs 142, 143, 146, and 1273

150. 1274

15 USC § 1692 et seq Violation of the Fair Debt Collection Practices Act

Laws of the United States (against Ocwen, Ronald Matthew Faris, and Mable Scarlett)


paragraphs 28, 29-32,35-37,39,42, diagrams 1.1, 1.2, 1.3, and reiterates the claims 1276

for relief preamble. 1277

123.) The defendant’s actions are in violation of the FDCPA. The Fair Debt 1278

Collection Practices is in place to curb unfair practices during the debt collection 1279

process. 1280

124.) Regarding ceasing communications 15 USC § 1692e 1281

Ocwen’s agents continued to send SentAsha communications after SentAsha issued 1282

a cease and desist notice and emails demanding for all harassing letters to cease. 1283

Afterwards SentAsha still receive letters from Ocwen’s Agents. Such activity is a 1284



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violation of 15 USC § 1692e subsection (c): 1285

CEASING COMMUNICATION. If a consumer notifies a debt collector in writing that 1286

the consumer refuses to pay a debt or that the consumer wishes the debt collector 1287

to cease further communication with the consumer, the debt collector shall not 1288

communicate further with the consumer with respect to such debt, except (1) to 1289

advise the consumer that the debt collector's further efforts are being terminated; 1290

(2) to notify the consumer that the debt collector or creditor may invoke specified 1291

remedies which are ordinarily invoked by such debt collector or creditor; or (3) 1292

where applicable, to notify the consumer that the debt collector or creditor intends 1293

to invoke a specified remedy. 1294

125.) Regarding false or misleading representations 15 USC § 1692e (2a) & (10) 1295

A debt collector may not use any false, deceptive, or misleading representation or 1296

means in connection with the collection of any debt. The Defendants’ unfair debt 1297

collection practices are a violation of this section: 1298

(2) The false representation of: (a) the character, amount, or legal status of any 1299

debt; or (10) The use of any false representation or deceptive means to collect or 1300

attempt to collect any debt or to obtain information concerning a consumer. 1301

126.) When Ocwen’s agents mailed SentAsha debt collection letters from 1302

Temecula California that attached Ocwen’s alleged agent, Aldridge Connor LLP to a 1303

corporate mailbox in California — although Ocwen’s agent was not authorized or 1304

incorporated to do business in California — this was an act of deception and 1305

misrepresentation. Ocwen’s agents misrepresented the geographic location of 1306

their actual corporate mail location, and the letter did not list a point of contact or 1307

a principal or agent’s name. Overall, this act caused confusion as to who the truly 1308

created and sent the letter. Ocwen’s agents violated 15 USC § 1692e (2a) and (10). 1309



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127.) Concerning Unfair practices §15 USC 1692f (6a), (8) 1310

(6) Taking or threatening to take any nonjudicial action to effect dispossession or 1311

disablement of property if — (A) there is no present right to possession of the 1312

property claimed as collateral through an enforceable security interest; 1313

128.) From November 2015 – Present the defendants continual to issue threats 1314

to take nonjudical action to foreclosure upon SentAsha’s homestead, although 1315

there has been ample evidence provided to show that there has been a break in the 1316

chain of title, and that there exists a breach of trust, robo-signing, and a false 1317

allonge and a false security deeded assignment. Fraudulent conveyances and robo-1318

signing shall not be ignored for it is by a valid negotiation and of the negotiable 1319

instrument (absent of fraud) along with an actual authorized transfer from the 1320

previous grantor (assignor or transferor) that presents that the Defendants have a 1321

legal cognizable interest. The Defendants do not have a legal cognizable 1322

enforceable security interest in SentAsha’s homestead. Instead what they have is a 1323

whole bunch of paper work i.e. modification agreements, closing documents, 1324

accounting spreadsheets that have been circulated and presented as a form of 1325

dispute in order to justify their standing. Their ample paperwork has been used in 1326

an attempt to distract SentAsha and others from the fact that everything that the 1327

Defendants are basing their claim on is rooted in the presence of fraudulent 1328

conveyances that have effectuated a color-of-title and a color-of-transfer-into-trust. 1329

Considering these facts, the Defendants are in violation of 15 USC §1692f (6a). 1330

129.) Ocwen is also in violation of 15 USC §1692f (8) which states: (8) 1331

Using any language or symbol, other than the debt collector's address, on any 1332

envelope when communicating with a consumer by use of the mails or by telegram, 1333

except that a debt collector may use his business name if such name does not 1334



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indicate that he is in the debt collection business. SentAsha reiterates paragraph 1335

#11 and incorporates lines 1224-1231. When Ocwen’s agents sent SentAsha a debt 1336

collection letter whose envelope contained an address that was — other than their 1337

own address — they committed an act of misrepresentation which is an unfair 1338

practice under the FDCPA. 1339

130.) In review of this claim, please keep in mind that per OCGA §10-6-60 —the 1340

principal is bound for neglect and fraud of agent. Ocwen via its leading principal 1341

Ronald Matthew Farris and its Compliance/Licensing Paralegal Mable Scarlett 1342

ensured that Ocwen was able to operate in the State of Georgia so that 1343

homeowners can be adversely affected by the unfair and deceptive practices of 1344

Ocwen’s agents. 1345

131.) Ocwen has also violated 15 USC § 1692g – validation of debts. 1346

How so? Taking into consideration paragraphs 11-18 and from review of the set of 1347

debt collection letters / responses to my disputes that SentAsha has received, the 1348

debt has not been validated. Per 15 USC § 1692g: 1349

(a) Within five days after the initial communication with a consumer in connection 1350

with the collection of any debt, a debt collector shall, unless the following 1351

information is contained in the initial communication or the consumer has paid the 1352

debt, send the consumer a written notice containing (2) the name of the creditor to 1353

whom the debt is owed. Note: Neither Ocwen nor their agents/debt collectors 1354

have provided the name of the actual creditor(s) to whom the alleged debt is owed. 1355

In this matter, Deutsche Bank National Trust Company and Ocwen Loan Servicing 1356

LLC are not the creditors. The original creditor pursuant to SentAsha’s records was 1357

Freemont Investment and Loans who ceased operations in 2008. Per the FDIC 1358

there was no acquisition by another entity. So, Freemont closed in 2008 without a 1359



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successor and without being acquired by another party and then in 2010 1360

PolyEsther popped up on the scene. Who is PolyEster? Allegorically speaking Poly 1361

is the robo-signed false allonge that popped-up and latched itself onto the 2006 1362

promissory note that contains SentAsha’s signature. Poly’s partner is Ester, the 1363

robo-signed false security deed assignment that popped-up and was recorded onto 1364

the real estate records in Fulton County, Georgia. In addition, Poly and Esther 1365

arrived to the party 4 years after the party was over. What party? Allegorically, the 1366

Party is the Securitized Asset Backed Receivables LLC Trust 2006 FR-4 (“SABR 1367

LLC 2006 FR-4). The trust’s closing date was December 12, 2006. So, Poly-&-1368

Esther arrived 4 years after the trust closed and the principals and agents of 1369

Deutsche and Ocwen are silent when SentAsha presents Trust-related questions as 1370

to who “truly” has a legal cognizable interest in her homestead. 1371

132.) A point of reiteration is that the Securitized Asset Backed Receivables LLC 1372

Trust 2006 FR-4 is subject to the Securities Exchange Act of 1934 which is 1373

regulated by the United States Securities Exchange Commission; Mary Jo White is 1374

the current chairman. According to the certified documents that were attested by 1375

Joseph Horneman, the Management and Program Analyst for the Securities 1376

Exchange Commission, the 8-K report dated December 12, 2006 was received by 1377

the SEC on Dec 28, 2006 under the name of the Securitized Asset Backed 1378

Receivables LLC Trust 2006 FR-4, File No. 333-138183-02, pursuant to the 1379

provisions of the Securities Exchange Act of 1934. Within the 8-K report exists all 1380

of the governing documents that the Trust is subject to. Meaning that the 1381

Trust is not governed by and subject to the hypothetical purports of Deutsche and 1382

Ocwen and their agents. According to the Trust’s governing documents the 1383

Trust’s closing date was on December 12, 2006. So, the Party was over in 1384



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2006. So until Deutsche and Ocwen can explain and document via evidence that 1385

is certified by the SEC demonstrating how Poly-&-Esther got into a closed party, 1386

they absolutely have no right to bring forth any further claims regarding being a 1387

secured creditor who has a right to foreclose. 1388

133.) Each time the principals and agents of Deutsche and Ocwen write 1389

statements that are antithetical to governing Trust docs that are recorded with the 1390

SEC, they are in pure violation of the Federal Securities Laws. Each time the 1391

principals and agents of Deutsche and Ocwen write statements that are 1392

antithetical to the very presentations and reports that they have filed with the 1393

SEC, they are in violation of Federal Securities Laws. Each time the Defendants 1394

and their agents turn a blind-eye to the fact that Deutsche and Ocwen are 1395

operating as designated administrators/debt collectors for a Trust which is 1396

governed by a Pooling and Servicing Agreement PSA and that the PSA is the 1397

supreme governing rule of that Trust, those particular persons are assisting 1398

Deutsche and Ocwen with violating Federal Securities Laws. Contrary to the 1399

Defendant’s belief, their purports are not superior to the Trust’s governing 1400

documents. Ask Deutsche’s Trust Officer Amy McNulty (f/k/a Amy Stoddard), the 1401

woman who signed the 2006 Trust agreementdocs on behalf of Deutsche; she’ll 1402

tell you. 1403

134.) In closing, the name of the true creditor has not been provided which is a 1404

violation of 15 USC §1692g. There is a reason why no one from Deutsche has 1405

responded to SentAsha’s questionnaires, affidavits, or debt validation demands. 1406

Even when SentAsha directed her correspondences direct to Deutsche; they 1407

wouldn’t respond to it. Why is that? Even when SentAsha called Deutsche’s VP of 1408



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Trust Services Renaldo Reyes to ask basic questions, Renaldo got a lil’ hot 1409

underneath-the-collar. Why is that? 1410



and 150. 1413

Constitution for the United States of America(1787 amended 1791) Violation of the Supremacy Clause, Article 6




preamble, along with reiteration of Claims 1-10. 1416

137.) Constitution for the United States of America, Supremacy 1417

Clause, Article 6 states: This Constitution, and the Laws of the United States 1418

which shall be made in pursuance thereof; and all treaties made, or which shall be 1419

made, under the authority of the United States, shall be the supreme law of the 1420

land; and the judges in every state shall be bound thereby, anything in the 1421

constitution or laws of any state to the contrary notwithstanding. 1422

138.) The Defendant’s acts are antithetical to the laws of the United States, the 1423

Federal Constitution, Georgia’s Constitution, standing consent orders, settlement 1424

agreements and consent judgments issued from the Federal judiciary. 1425

139.) Altruistically speaking, Deutsche’s, Ocwen’s and their Principals’ and 1426

Agents’ customary practices are anti-government. They have signed agreements 1427

with state and federal government agencies/regulatory authorities, and then have 1428



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elected to continually violate the terms and stipulations of agreements that were 1429

instituted to protect the consumer rights and inherent rights of SentAsha (and 1430

other similarly situated homeowners/consumers/homemakers). Allegorically 1431

speaking on side A of the cassette they have agreed to behave and then on side B of 1432

the cassette they have flipped-the-script. 1433


business acts, and the damages are outlined in the paragraphs 142-150. 1435

141.) The unfair business practices of the Defendants have caused 1436

SentAsha to have: 1437

Irreparable Damage —Punitive Damages Determination by Jury 1438

142.) Energy Loss (Mental, Spiritual, Physical Energy) & 1439

Inadvertent Opportunity Costs – SentAsha has spent a voluminous amount of 1440

energy over the past 19 months on investigating and researching this matter. The 1441

energy spent removed energy that could've been allotted to trade/commerce, more 1442

studying and more creating i.e. creating gourmet vegetarian meals, collecting 1443

frankincense & myrrh, flowers, and greenery for the creation of fresh body washes 1444

and pure essential oils, studying more about the frequencies and divine essence of 1445

flowers, more speaking and visiting with the elderly, performing more volunteer 1446

work for select local non-profits/libraries, continue witch civil society duties 1447

(without distraction), further study and development of her technology skills that 1448

would allow her to secure lucrative information technology contracts. Also, 1449

SentAsha's sleeping schedule has been altered which is antithetical to her natural 1450

circadian rhythm and nature's day-light cycle. The damages for energy loss 1451

damage are immeasurable thus, a punitive damages decision by jury is 1452

appropriate. 1453



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143.) Time loss – SentAsha has been going back and forth with this issue with 1454

the Defendants for 19 months. During the past 16 months there has been over 650 1455

hours spent on administering a thorough examination of this matter and enforcing 1456

her inherent rights, property rights, and consumer rights. Also a voluminous 1457

amount of irreplaceable time has been spent in writing rebuttals, affidavits, cease 1458

and desist notices, claim notices, public constructive notices, annotating Exhibits, 1459

desktop publishing/page layout, graphic-diagramming, creation and submission of 1460

certified document requests, conducting proprietary interviews and research, etc. 1461

The damages for time loss damage are immeasurable thus, in addition to 1462

SentAsha’s demand for compensatory damages (see paragraph 146) — a punitive 1463

damages decision by jury is appropriate . 1464

144.) Libelous Damage (Untrue published communications) – As a 1465

result of the false advertisements that were printed in the Fulton County Daily 1466

Report via the directives of the Defendant's and their agents, the general public is 1467

under the impression that I have hired Deutsche/Aldridge Connors LLP to be my 1468

attorney/agent and that I have business dealings with the SABR LLC Trust 2006-1469

FR4; not as homeowner but as an investor. For as a standalone homeowner, it 1470

would be nonsensical to have Deutsche or Aldridge Connors LLP (Ocwen's alleged 1471

attorneys) as my attorney-in-fact or agent in fact; especially in light of a robo-signed 1472

false allonge and a robo-signed false security deed assignment. The damages for 1473

libelous damage are immeasurable thus, a punitive damages decision by jury is 1474

appropriate. 1475

145.) Privacy Compromised – The defendants have facilitated the sharing of 1476

SentAsha’s private assigned Old Age Survivor's Insurance Trust Fund Account 1477

Number (a/k/a Social Security Number) with 3rd parties. To date it is unknown 1478

exactly how many people and entities have received/handled/ stored/accessed 1479

SentAsha’s assigned private information — by way of the Defendants. In addition, 1480

the timeframe of such sharing is unkown. Since 2010? 2011? 2012? 2013? 2014? 1481

Per a letter that SentAsha received from the IRS dated March 13, 2015, someone 1482

filed a return using her information, in an attempt to get her tax refund. The 1483

attempt was not successful. SentAsha has filed an affidavit of identity theft. The 1484

IRS has flagged SentAsha’s file with notation of their findings to deter additional 1485



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wrongful activity. The damages for privacy breach damage are immeasurable 1486

thus, a punitive damages decision by jury is appropriate. 1487

Reparable Damage/Economic Damage — Compensatory Damages: 1488

146.) Money Loss/Costs – From 2010-2013, SentAsha made approximately 1489

$23,500 in payments on a discharged debt that was being reinforced based on a 1490

robo-signed false security deed assignment, and a robo-signed false allonge. In 1491

addition, SentAsha has accumulated legal/administrative expenses in her ongoing 1492

continual mission to defend her consumer rights and property rights. SentAsha has 1493

incurred adverse opportunity costs while administering the examination of the 1494

Defendant's continual unlawful and unfair business practices. In light of the facts 1495

presented, the defendants elected not to resolve this matter in a timely fashion which 1496

caused SentAsha to incur more loss. SentAsha also incorporates with reference to 1497

paragraph 143. The 650 hours consists of approximately 40 hours per month over the 1498

past 19 months spent on a combination of legal research, interviewing, administrative 1499

tasks, and writing, etc. Valued at $150 per hour, there exists costs of $97,500. 1500

1501

147.) Benefit / Licensing Fee Loss – SentAsha didn’t benefit from the 1502

unauthorized publishing of her common-law trademark “SentAsha KeyAma-Joy 1503

WilliamsTM”. However, the Defendant paid their 3rd party tributary-agents to run a 1504

Notice of sale advertisement in the Fulton County Daily Report. Such ad was ran in 1505

order to (1) alert any party that may be adversely affected by such sale and (2) to 1506

inform and attract prospective buyers/investors. In doing this the Defendants and 1507

their agents infrindged upon SentAsha’s trademark that is connected to her creative 1508

works i.e. graphic designs, writings, jingles, vegetarian recipies, tutorials, etc. Per 1509

SentAsha’s public constructive notice that went out to the world in 2013, 1510

unauthorized use of her intellectual property is prohibited. Nonexclusive 1511

authorized use is only permitted upon her written consent and receipt of a licensing 1512

fee that is based on the scope of usage, the scope of the corporation, scope of 1513

circulation, amount of insertions, and the prospective gain as a result of receiving 1514

grant of temporary non-exclusive usage. In this situation, SentAsha’s trademark 1515

was printed approximately 6 times. The licensing fee would’ve been $7,000 per 1516

insertion. Thus, SentAsha licensing fee loss is $42,000. 1517



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148.) In addition to the public notices of sale, over 50 local attorneys/foreclosure-1518

assistance firms have been sending me voluminous amounts of solicitous 1519

marketing mail. Since 2013, SentAsha has been working diligently to get her 1520

address removed from the database of mass-marketers. Junk mail had declined by 1521

over 300% until the Defendants directed their agents to publish SentAsha’s former 1522

name (SentAsha KeyAma-Joy WilliamsTM) inside of the Fulton County Daily Report. 1523

As of March 6, 2015, I have had to take time to handle over 125 pieces of mail of 1524

which I didn’t ask to receive. From Dec 2014 - March 2015, the influx of junk-mail 1525

is up by 300% which totally canceled out SentAsha’s 2-year effort of curtailing junk-1526

mail. During the 2-year period SentAsha spent approximately ~2 hours per month 1527

(30 minutes per week) writing return to sender notes, sending emails and making 1528

phone calls informing the senders to remove me from their do not call list. ~2 hours 1529

x 24 months = 48 hours @ $30/hour (Admin Contract Rate) = $1,440. The 1530

Defendant’s acts totally obliterated the results of SentAsha’s 2-year anti-junk mail 1531

mission. The damages as a result of such obliteration is $1,440. 1532

149.) Clouds on the Title – The title to SentAsha's homestead has been 1533

corrupted. Thus, there exists a break in the chain to title. Such encumbrance has 1534

discouraged actions regarding selling and attempts to receive home improvement 1535

financing. Title companies do not issue clear title report when there are clouds on 1536

the title. Likewise, a title insurance company will refuse to issue a policy. As a 1537

result of such discouragement SentAsha decided not to sell or seek out home 1538

improvement financing. If the clouds were not present, SentAsha would’ve been had 1539

an opportunity to either sell and receive a profit of at least $65,000 or she would’ve 1540

been able to remodel her homestead and increase value by at least $15,000. 1541

spending ample time and resources — 19 months of going back & forth & back & 1542

forth — with the Defendants, SentAsha has removed the ideas of selling and home 1543

improvement from her mind. The Defendant’s lack of action in resolving this cloud 1544

issue has caused damages in the form of involuntary opportunity costs that have 1545

an average value of $40,000 [ (65K + 15K) / 2= 40K) ]. 1546

Civil Damage/ Reparable Damage 1547

Punitive Damages Determination by Jury: 1548



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150.) Abrogation of SentAsha's rights: inherent rights, consumer rights, 1549

and property rights, that are constitutionally secured via the Constitutions and laws 1550

for the USA/US and Georgia. Such continual abrogation has resulted in continuous 1551

aggravation and energy loss. SentAsha’s incorporates by reference paragraphs 142 1552

and 143. The Defendant’s unfair acts were done in attempt to sell/foreclose on 1553

SentAsha’s homestead at the advertised principal loan amount of $143,920. 1554

151.) Over the past 19 months, SentAsha has been informing the 1555

principals/agents of Ocwen Loan Servicing LLC (Deutsche towards the later) that 1556

the promissory note had been discharged, and that the security deed assignment 1557

had patent and latent defects. In April 2013, SentAsha issued her first qualified 1558

written request (“QWR”) to Ocwen’s attorney Jon Young of Weisman Nowack 1559

Wilco Curry. In September 2013, she issued the first affidavit. In December 2013, 1560

as a result of Ocwen’s lack of rebuttal to her 2013 affidavit of truth and incomplete 1561

fulfillment of her qualified written requests, she issued the first notice of default to 1562

Ocwen. Some of the points throughout her 2015 Affidavit of Truth contain 1563

reiterations from her 2013 affidavit. (2015 Affidavit attached) 2013 Affidavit and 1564

Default as a result of Ocwen’s non-response 1565

Link: http://www.sentasha.com/publicrecords/ocwen/affidavits. 1566

Via referral, SentAsha’s December 3rd, 2014 Demand Letter to Ocwen was sent to 1567

the Consumer Financial Protection Bureau (“CFPB”) complaint# 141216-000127. 1568

152.) Administrative Remedy − On January 26, 2015 a complaint against 1569

Deutsche was submitted to the US Department of Treasury, Office of Comptroller 1570

of Currency complaint #0302006. Thereafter the OCC referred the Deutsche 1571

complaint to the CFPB. In addition SentAsha has sent carbon copies of some of 1572

her correspondences to Sam Olens, Georgia Attorney General, Jeffrey Stump, 1573

http://www.sentasha.com/publicrecords/ocwen/affidavits



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Georgia Sr. Assistant Attorney General and signor of the 2013 CFPB et al vs. Ocwen 1574

et al Settlement Agreement, and other state and federal agencies and departments 1575

(i.e. Georgia Department of Banking and Finance, Social Security Administration 1576

Board of Trustees, Federal Trade Commission, and the Securities Exchange 1577

Commission. For more details, see the communications log within SentAsha’s 1578

2015 Affidavit of Truth Pages 6-8 (Hardcopy Attached). 1579

153.) Notice of SentAsha’s intent to sue has been interlaced throughout 1580

SentAsha’s correspondences from 2014 to March 2015) i.e. cease and desist 1581

notices, notices of default letters, and her multi-prong rebuttal that was sent 1582

against Ocwen via the Consumer Financial Protection Bureau complaint-1583

mechanism. 1584

154.) Final Notice of Intent to Sue and Claim Filed Against Ocwen’s 1585

Surety Bond − On February 27, 2015, SentAsha issued a notice of claim against 1586

Ocwen’s Surety Bond that they placed on file with the Georgia Department of 1587

Banking and Finance. The issuer is Platte River Insurance Company. A claim 1588

number was issued on March 4, 2015. On March 31, 2015, an insurance adjuster 1589

informed SentAsha that a proof of claim form will be mailed. In addition, SentAsha 1590

sent a final notice of intent to sue to the Defendants via first class mail on 1591

March 15, 2015. 1592



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In support of SentAsha’s facts and allegations: 1593

2015 Affidavit of Truth (14 pages) - Enclosed and online @ 1594

http://sentasha.com/publicrecords/ocwen/2015affidavit.pdf 1595

Exhibits (90 pages) - Enclosed and online @ 1596

http://sentasha.com/publicrecords/ocwen/2015exhibit.pdf 1597

Hardcopies are enclosed with this verified complaint. 1598

Plaintiff demands a trial by jury.1599

Plaintiff respectfully prays for relief as follows: 1600

Judgment in favor of the Plaintiff against all Defendants, individually and 1601

jointly, for all damage incurred as a result of the Defendants’ unfair business 1602

practices and decisional mistakes of facts; also binding on Ocwen’s and Deutsche’s 1603

successors and/or assigns if their alleged title interests in the Plaintiff’s homestead 1604

have been conveyed over to others. 1605

Permanent injunctive relief prohibiting Defendants (principals and agents) from 1606

pursuing foreclosure/adverse possession/ quiet title actions against the Plaintiff’s 1607

homestead. 1608

Declaratory relief stating that the Defendants have violated the Fair Business 1609

Practices Act and other designated laws as outlined in the Plaintiffs’ claims 1-11, 1610

Paragraphs 44-140. 1611

1612

Annulment of the robo-signed false security deed assignment (false 1613

conveyance) that allegedly conveyed title of the Plaintiff’s homestead to Deutsche 1614

Bank National Trust Company solely as trustee for the Pooling and Service Agreement 1615

(PSA) dated November 1, 2006 Securitized Asset Backed Receivables LLC Trust 2006 1616

FR-4, Mortgage Pass through Certificates, Series 2006 FR-4. 1617

http://sentasha.com/publicrecords/ocwen/2015affidavit.pdf

http://sentasha.com/publicrecords/ocwen/2015exhibit.pdf



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Rescission of the modification agreement between Ocwen and the 1618

Plaintiff that was made based on mistake of fact where Deutsche and Ocwen didn’t 1619

have a valid legal cognizable interest in neither the security deed assignment nor the 1620

original promissory note (that was discharged in Bankruptcy), and where there was a 1621

presence of a robo-signed false allonge, and a robo-signed false security deed 1622

assignment (fraudulent conveyances). 1623

Punitive damages - Value of the original promissory note $143,920 x3* plus a 1624

sufficient amount to deter the Defendants from further wrongdoing against 1625

Georgia homeowners and consumers. 80% of awarded punitive damages to be 1626

made payable to designated non-profit philanthropic/charitable causes. 1627

1628

Award of compensatory damages in the amount $320,820* USD. 1629

Reflects total of damages as outlined in paragraphs 146-149 times three. 1630

25% of the compensatory damages to be made payable to designated 1631

non-profit philanthropic/charitable causes. 1632

1633

Costs and expenses incurred in this action plus the past 16 months of legal 1634

research, writing, administrative tasks, postage/handling etc. in the amount of 1635

$97,500 USD. (Total of costs as outlined in paragraph 146.) 1636

1637

Issuance of notarized apology letters from the Defendants for: 1638

(A.) Continual facilitation of unfair business practices and disrespect of the 1639

Plaintiff’s civil society status, property rights, consumer rights, and breach of 1640

the Dec. 2013 settlement agreement that Ocwen formed with the Consumer 1641

Financial Protection Bureau, the State of Georgia and 47 other states, that 1642

exists in order to ensure protections for homeowners and consumers. 1643

(B.) Being outside of the constitutional fold. 1644

An examination of Ocwen’s loan servicing practices and foreclosure 1645

processing practices conducted by the Georgia Department of Law, Georgia 1646

Department of Banking and Finance, and Governor’s Office of Consumer Protection 1647

to determine the appropriate State regulatory measures that are proper for Ocwen’s 1648

continual breach of the Dec. 2013 settlement agreement that Georgia and the CFPB 1649

are signatory parties of. 1650

Other and further relief that the Court deems just and proper. 1651

*Note: Damages are 3 times the actual damage amount as allowed per § 10-1-399(c).



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ANTI-RETALIATION PROVISION

This complaint shall not be misconstrued to be a form of ill-will or malice. For the 1652

ethereal and tangible records, the unfair business practices of the Defendants — that 1653

have been against SentAsha as well as nationwide homeowners/consumers has already 1654

been examined and identified as being unlawful and unjust by 48 state governments, 1655

Federal regulatory agencies, Congress members, civil society, consumer advocates, 1656

investors, and hedge fund managers. SentAsha has a right to seek redress, any 1657

retaliation brought forth as a result of filing this lawsuit will be reported to the Supreme 1658

Creator of the Universe and the Universal Forces of Nature. Also, an instantaneous 1659

motion for the Court to enjoin any transgressor(s), and an order for appropriate 1660

equitable redress relief/sanctions for inappropriate retaliatory acts. Thus, neither the 1661

Defendants nor their agents shall engage in harassment or direct/indirect intimidation 1662

tactics via phone, mail, email or in-person. Including but not limited to prank calls, 1663

robo-calling with automated messages, stalking, spamming, and all other forms of 1664

tortious interference. 1665

In memorandum: the first Amendment of the Constitution for the United States of 1666

America 1787 amended 1791 — Congress shall make no law respecting an establishment 1667

of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, 1668

or the press; or the right of the people peaceably to assemble and to petition the 1669

government for a redress of grievances. Part of SentAsha’s religion exercise includes the 1670

enforcement of equity, respect for divine order, freedom of peaceful association, 1671

freedom of expression, freedom of the written and spoken word, freedom of movement 1672

upon the land, freedom from based implied contracts that are layered with unilateral 1673

unjust enrichment adhesions, freedom of conscience, freedom from wrongful 1674

conversion/seizure, freedom to seek truth, and enforce the protections reinforced by the 1675

law of the land. Surely, the aforementioned are to be secured throughout the Land; 1676

pastures, plains, mountains, valleys, still waters, sacred mounds and pyramids that 1677

serenely exist upon the Supreme Universal Creator’s illustrious continent of North 1678

America. 1679

“The Earth is God’s and the fullness thereof, the world and those 1680 who dwell therein; for he has founded it upon the seas, and 1681

established it upon the rivers.” 1682 — Psalm 24:1,2 1683



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I trust that this 19-month ordeal is resolved in harmony with the

Principles of Equity and the Law of the Land.

SentAsha KeyAma-Joy EL, Plaintiff (f/k/a SentAsha KeyAma-Joy Williams)

SENTASHA KEYAMA-JOY WILLIAMSTM

• In Full Life • No Waiver of Rights

• All Rights Claimed and Reserved

• In Propria Persona Sui Juris • Pro Se (For Herself)

• Civil Society Scribe • Civilian • Polymath

»Mailing Location

P.O. Box 957 • Atlanta, Georgia 30301

Nation-State: United States of America

+1 404.496.5100 * / [email protected]

NOTE: As of January 9, 2015, a revocation of power

of attorney regarding faulty agency status claims over

SENTASHA KEYAMA-JOY WILLIAMS TM was issued

against Deutsche Bank, Aldridge Connors, Ocwen and all

unknown others. Reason: Wrongful Assumed Authority.

Regarding 404.496.5100, this phone number is a

personal number and placed on the United States Federal

Trade Commission’s Do Not Call Registry. Thus, calls

from telemarketers, mass marketers, intermeddlers, and

interlopers are prohibited. When necessary, calls may be

recorded for quality control purposes. Calls from

respective parties that are connected directly to this

lawsuit i.e. defendants and their legal representatives,

regulatory consumer-rights agencies, and/or calls from

sincere civilians, truthseekers, and obedient beacons of

the civil society are permissible.

I Am:

Amen

Date: April 10, 2015 Continental Atlanta, Georgia Nation-State: United States of America North America, Land in the Direction of the Setting Sun

“As one who tranverseth the burning sands, in search of water, so is the soul that thirsteth after knowledge.” — Sheik Sharif Abdul Ali (Prophet Noble Drew Ali)

“When Moses prayed for water for his people, We said to him, ‘Strike the rock with your staff!’ And there gushed out from it 12 springs. Each tribe knew its drinking-place [We said] Eat and drink what Allah has provided and do not act wrongfully in the land, spreading corruption.”

— Al Baqarah 2.60 “When a stranger sojourns with you in your land, you shall not do him wrong. The stranger who sojourns with you shall be to you as the native among you, and you shall love him as yourself; for you were strangers in the land of Egypt: I am the Lord your God.”

— Leviticus 20:33-34

SentAshaTM Lawsuit against Ocwen Loan Servicing LLC et al © 2015. All Rights Reserved. Sources provided where applicable.

Document No.1436-2015-Suit-410-Ocwen

/s/ SentAsha KeyAma-Joy EL



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Submitted In the Name and Respect of All’Law:

Nature, Religion, Isonomy, and the

Supreme Law of the

Land

VERIFICATION OF COMPLAINT

North America

United States of America

Georgia, Fulton County, to wit:

I, SentAsha KeyAma-Joy EL, am the plaintiff in the above‑entitled action I have

written and read this 73-page verified consolidated complaint that is supported by a

14-page 2015 Affidavit of Truth and 90 pages of exhibits, and I am aware of the contents

thereof. The same is true of my own knowledge, except as to those matters that are therein

alleged on information and belief, and as to those matters I believe it to be true.

I declare under penalty of perjury under the laws of Georgia, and the United States of

America that the foregoing is true and correct.

Affirmed to and subscribed before me,

this 10th day of April 2015.

___________________________________

Notary Public

My Commission Expires: ________________

SentAsha KeyAma-Joy EL, Plaintiff (f/k/a SentAsha KeyAma-Joy Williams) SENTASHA KEYAMA-JOY WILLIAMSTM • In Full Life • No Waiver of Rights • All Rights Claimed and Reserved • In Propria Persona • Sui Juris • Pro Se (For Herself) • Civil Society Scribe • Civilian • Polymath • Part and Parcel of the Continental United States of North America

I Am:

✡

☪

/s/ SentAsha KeyAma-Joy EL

Notary Signature and Seal on Original File

on Original

in the superior court of fulton county - sentasha · 2015-08-02 · sentasha keyama-joy el vs....

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