2016 recall of washington governor jay inslee, bob ferguson, tony golik and sheriff chuck e. atkins...

8/16/2019 2016 Recall of Washington Governor Jay Inslee, Bob Ferguson, Tony Golik and Sheriff Chuck E. Atkins (Electronic)

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RECALL OF

JAY INSLEE, Governor, State of Washington;

BOB FERGUSON, Attorney General, State of Washington;

TONY GOLIK, Prosecuting Attorney, Clark County Washington;

and

CHUCK E. ATKINS, Sheriff, Clark County Washington

With Supporting Declarations and Exhibits

May 30, 2016

EMANUEL MCCRAY

400 W McLoughlin Blvd., #5Vancouver, WA 98660(858) 876-4833

Email: [email protected]: @trumpgenius

Petitioner


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GREG KIMSEY Responsible Elected OfficialC/o Cathie GarberElections Supervisor1408 Franklin Street

Vancouver, WA 98660-2879Tel: (360) 397-2345; Fax: (360) 397-2394

RE: Filing of Statement of Charges in Favor of the Recall of Washington Governor Jay

Inslee; Clark County Prosecuting Attorney Tony Golik and Clark County Sheriff

Chuck E. Atkins

May 30, 2016

Dear Supervisor Garber:

This letter shall constitute the statement of the charges in support of the Recall of

Washington Governor Jay Inslee; Attorney General Bob Ferguson; Clark County Prosecuting

Attorney Tony Golik and Clark County Sheriff Chuck E. Atkins pursuant to Wash. Const. Art. I

§§ 33 and 34 (Amend. 8) and RCW 29A.56.110, et seq.

I. INTRODUCTION TO THE STATEMENT OF CHARGES.

1. In 1934, pursuant to the wisdom and guidance of President Roosevelt, the Congress of

the United States nationalized a secondary market for mortgages.

2. In 1965 the Legislature enacted the Deeds of Trust Act, Chapter 61.24 RCW, to facilitate

the State’s participation in Our Nation’s tax-payer financed national mortgage market (NMM).

3. This is a conspiracy — the concept of which had its earliest roots in fourteenth century

English common law. At that time, it saw limited use as a legal theory. It became more broadly

applied in the United States in the nineteenth century.

4. Today, conspiracy is a far-reaching legal principle, embracing antitrust actions, an

enormous number of more traditional criminal cases, and even tort lawsuits. It is the basis of

prosecutions dealing with, among other crimes, drug violations, securities fraud, murder for hire,

bank robbery, and extortion.

5. The basic criminal conspiracy principle is simple to state, but often difficult to apply.

Conspiracy is an agreement by two or more people to commit a crime. In practice, many

complex matters are often raised. One is the manner in which the crime is proved at trial.


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Agreement among conspirators is central to the offense, yet rarely is there clear and direct

evidence of an agreement, such as a written statement, a videotaped meeting, or a tape-recorded

conversation. As one judge has put it, “A conspiracy is seldom born of open covenants openly

arrived at.” Courts normally allow circumstantial evidence to be offered at trial so that the trier

of fact can infer from particular facts (e.g., the presence of the parties, their relationship, later

activities, profits received) the existence of a criminal agreement, even among a large group of

individuals.

6. Another difficult issue concerns the type of evidence which will be admissible against

specific defendants in proving their intentional membership in the agreement. Questions are

raised, in particular, with respect to out-of-court statements made by coconspirators that are used

against all members of the conspiracy, and also as to whether activities before the conspiracy

was formed demonstrate a purpose or motive to enter into the later agreement.

7. Constitutional challenges to conspiracy law are often made, but rarely succeed. Instead,

throughout the United States, in state and federal courts, conspiracy is broadly used in a diverse

pool of cases often with quite severe punishments imposed for both the conspiracy and any

attempted or completed crimes. See also: Philip E. Johnson, “The Unnecessary Crime of

Conspiracy,” California Law Review 61(1973): 11-88; Paul Marcus, The Prosecution and

Defense of Criminal Conspiracy Cases (1978 and supp. 2000); Paul Marcus, “Conspiracy: The

Criminal Agreement in Theory and in Practice,” Geo. L. J. 65 (1977): 925-67; Paul Marcus,

“Conspiracy Law: Time to Turn Back From an Ever Expanding, Ever More Troubling Area,” W.

& Mary Bill of Rights Law Journal 1 (1992): 1-45.

8. There is clear, direct, circumstantial and convincing evidence of an unlawful

conspiratorial agreement to use MERS, Inc. as a special purpose vehicle to facilitate the theft of

homes for personal profit and private gain within the State of Washington and across the United

States, at the public expense of all American taxpayers, in the form of a written statement

appearing on every Deed of Trust prepared on Fannie Mae/Freddie Mac UNIFORM

INSTRUMENT Form 3048 (Washington).

9. Fraud, on the other hand, has been variously defined. No all inclusive definition can be

framed owing to the multiform character of fraud and the great variety of attendant

circumstances. Each case must be determined on its particular and peculiar facts.


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10. Fraud in its generic sense, especially as the word is used in courts of equity, comprises all

acts, omissions, and concealments involving a breach of legal or equitable duty and resulting in

damage to another. Fraud has also been defined as any cunning or artifice used to cheat or

deceive another. Further it is frequently stated that owing to the multiform character of fraud and

the great variety of attendant circumstances no definition which is all inclusive can be framed,

but each case must be determined on its particular facts. It has been held that fraud is

synonymous with false swearing. Cole v. Utley, 188 Wash. 667, 63 P.2d 473 (1936); Dent v.

Adkisson, 184 Ark. 869; 43 S.W.2d 739 (1931); Coppo v. Coppo, 163 Misc. 249, 1937 N.Y.

Misc. LEXIS 1414 (N.Y. Misc., April 29, 1937).

11. The Washington Supreme Court in Bain v. Metro. Mortg. Grp., Inc., 175 Wn.2d 83

(2012) made known to Washington Governor Jay Inslee; Attorney General Bob Ferguson; Clark

County Prosecuting Attorney Tony Golik, Clark County Sheriff Chuck E. Atkins and all judges

in the State of Washington that naming MERS, Inc. as “beneficiary” was “deceptive” and that it

would be “unlawful” for MERS, Inc. to take any actions in its named capacity as “ beneficiary” if

it never owned or held the Notes executed by Washington homeowners.

12. There is clear, direct, circumstantial and convincing evidence that Washington Governor

Jay Inslee; Attorney General Bob Ferguson; Clark County Prosecuting Attorney Tony Golik and

Clark County Sheriff Chuck E. Atkins have objectively manifested an agreement to participate,

directly or indirectly in the MERS, Inc. Conspiracy Enterprise made apparent from: (1) the

unabated recordation of Deeds of Trust; Assignments of Deeds of Trust; Appointments of

Successor Trustees; Notices of Trustee Sales; nonjudicial foreclosure sale Trustee Deeds and

other instruments; (2) the wrongful actions commenced for unlawful detainer in the Superior

Courts; and (3) the wrongful eviction of homeowners by law enforcement personnel, all set in

motion by the members of the MERS, Inc. Conspiracy Enterprise.

13. Moreover, the MERS, Inc. Conspiracy Enterprise would have been both harder to detect

and harder to prove had the Fannie Mae/Freddie Mac UNIFORM INSTRUMENT for deeds of

trust been amended to remove all references to MERS, Inc. as the “beneficiary.”

14. The fact that members of the MERS, Inc. Conspiracy Enterprise have entered courts

across the United States and have told lies for each other with impunity is a serious matter which

rips the fibers right out of our judicial systems.


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15. A cycle of the MERS, Inc. Conspiracy to wrongfully foreclose and evict the homeowner

is completed with the issuance of IRS Form 1099-A, pursuant to Title 26 U.S.C. 6050J.

Washington Homeowner Pamela Owen and others could not with due diligence discover this

evidence in sufficient time to enjoin the sale of their homes because Federal law, Title 26 U.S.C.

§ 6050J(e), does not require IRS Form 1099-A to be issued until “on or before January 31 of the

year following the calendar year for which the return under subsection (a) was made.”

16. Tax information reporting requirements for IRS Form 1099-A was enacted by Congress

as part of the Deficit Reduction Act of 1984, P.L. 98-369. Congress explained the reason for the

change was primarily to curb income tax evasions:

“Under present law, there is no reporting requirement designed to encourageconsistent treatment by the lender and the borrower on a foreclosure,abandonment or other disposition of property which is security for indebtedness

There is no reporting requirement: to encourage the correct treatment of dischargeof indebtedness income in recourse debt cases. Thus, gain on foreclosure andother disposition events and discharge of indebtedness income may gounreported. In addition, these events are difficult to detect on audit.”

17. IRS Form 1099-A is never available for use as evidence to support the homeowner’s

lawsuit to enjoin the nonjudicial foreclosure sale of their home. The members of the MERS, Inc.

Conspiracy Enterprise are well aware of this fact and have used it to their advantage when

committing perjury in State and Federal courts to criminally thwart the claims of the

homeowners.

18. Further, an action for unlawful detainer brought pursuant to Chapter 59.12 RCW is

confined to the issue of the right of possession and its statutory incidents. The court may do one

of two things — either enter a judgment in favor of the Defendant by dismissing the action with

prejudice or render judgment in favor of Plaintiff pursuant to RCW § 59.12.120 or § 59.12.170.

Sundholm v. Patch, 62 Wn.2d 244, 245-246, 382 P.2d 262 (1963); Snuffin v. Mayo, 6 Wn. App.

525, 528, 494 P.2d 497 (Div. Two, 1972).

19. In 2009, the Legislature amended Chapter 59.12 RCW by adding RCW § 59.12.032 to

require that an unlawful detainer action commenced as a result of a trustee’s sale under chapter

61.24 RCW comply with the requirements of RCW 61.24.040 and 61.24.060.

20. Article IV of the Washington Constitution establishes courts and invests them with the

power to hear and determine every justiciable cause and proceeding. Any discussion of state

court jurisdiction proceeds from this “fundamental premise.” State v. Werner, 129 Wash.2d 485,


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492, 918 P.2d 916 (1996); State v. Pritchard, 79 Wash.App. 14, 19-20, 900 P.2d 560 (Div. Two,

1995), (citing State ex rel. New York Casualty Co. v. Superior Court for King County, 31 Wn.2d

834, 839, 199 P.2d 581 (1948).

21. Complete jurisdiction has three components: (1) Jurisdiction over the subject matter; (2)

jurisdiction over the parties; and (3) power to render the particular judgment. Werner , 129

Wash.2d at 493, 918 P.2d 916.

22. The Superior Court’s unlawful detainer subject matter jurisdiction flows from the

constitutional mandate provided in Wash. Const. art. IV, § 6. Tacoma Rescue Mission v. Stewart,

155 Wn. App. 250, 254 n.9, 228 P.3d 1289 (Div. Two, 2010). This judicial power is inherent,

even in the absence of a statute, and may not be abrogated or restricted by the Legislature. State

v. Werner, 129 Wash.2d at 494.

23. Therefore, every nonjudicial foreclosure commenced in this State pursuant to actions

taken by MERS, Inc. in its capacity as “beneficiary” deprived the Superior Court of unlawful

detainer subject matter jurisdiction. Because Washington Governor Jay Inslee; Attorney General

Bob Ferguson; Clark County Prosecuting Attorney Tony Golik and Clark County Sheriff Chuck

E. Atkins have been unwilling to defeat the MERS, Inc. Conspiracy Enterprise, judges of the

Superior Court have exercised jurisdiction with impunity when none has existed, resulting in

homeowners being wrongfully evicted from their homes.

24. All Writs of Restitution directed to Sheriffs on behalf of the MERS, Inc. Conspiracy

Enterprise have been issued in the name of the “STATE OF WASHINGTON.” Such a

consequence is sufficient to invoke the 14th Amendment and 42 U.S.C. 1983 prohibiting

unconstitutional deprivation of federal rights.

25. Washington Governor Jay Inslee; Attorney General Bob Ferguson; Clark County

Prosecuting Attorney Tony Golik and Clark County Sheriff Chuck E. Atkins each had

independent power to defeat the MERS, Inc. Conspiracy. Instead, each agreed to aid and abet

and or form and associate with the MERS, Inc. Conspiracy through actions and inactions in

furtherance of and in connection with the MERS, Inc. Conspiracy Enterprise.

26. Further, Washington Governor Jay Inslee; Attorney General Bob Ferguson; Clark County

Prosecuting Attorney Tony Golik and Clark County Sheriff Chuck E. Atkins each knew the

conspiracy’s goals and agreed to facilitate them.


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27. In fact, former Attorney General McKenna presented a brief on behalf of the State of

Washington wherein he presented the State’s legal understanding that MERS, Inc. was an

unlawful beneficiary:

See also Exhibit I attached hereto.

28. The chain linking Governor Inslee to Sheriff Atkins is of constitutional and statutory

design. The Supreme Executive Power of the State is vested in a Governor. Wash. Const. Art III,

§ 2; State ex rel. Hartley v. Clausen, 146 Wash. 588 (1928); City of Seattle v. McKenna, 172

Wn.2d 551, 259 P.3d 1087 (2011).

29. Black ’ s Law Dictionary (7th ed.), defines supreme power as: “The highest authority in

the state, all other powers in it being inferior thereto.” This means that the governor, under our

constitution, is the highest executive authority. State ex rel. Hartley v. Clausen, 146 Wash. 588

(1928); City of Seattle v. McKenna, 172 Wn.2d 551, 259 P.3d 1087 (2011).

30. It is the right and duty of the Executive Department to see that the laws as interpreted by

our Supreme Court are properly enforced. “As the final right to determine the true intent and


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purpose of all laws is lodged in the supreme court of this state, so is the final determination as to

their enforcement and execution lodged in the governor. State ex rel. Hartley v. Clausen, 146

Wash. 588 (1928); City of Seattle v. McKenna, 172 Wn.2d 551, 259 P.3d 1087 (2011).

31. The State’s Executive Department consists, among others, of the Attorney General, who

“shall be the legal advisor of the state of ficers.” Wash. Const. Art III, § 21. The Office of the

Attorney General is further subject to Chapter 43.10 RCW.

32. RCW § 43.10.010 provides, in relevant part, that

“Before entering upon the duties of his or her office, any person elected orappointed attorney general shall take, subscribe, and file the oath of office asrequired by law; take, subscribe, and file with the secretary of state an oath tocomply with the provisions of RCW 43.10.115; and execute and file with thesecretary of state, a bond to the state, in the sum of five thousand dollars, withsureties to be approved by the governor, conditioned for the faithful performance

of his or her duties and the paying over of all moneys, as provided by law.”

33. Under RCW § 43.10.030, the attorney general shall, among other mandatory duties: “(4)

Consult with and advise the several prosecuting attorneys in matters relating to the duties of their

office….” Additionally, the Attorney General may properly be substituted as counsel on appeal

in a case which was tried and appealed by a prosecuting attorney. State v. Conifer Enters., Inc.,

82 Wn.2d 94, 508 P.2d 149 (1973).

34. In the event a prosecuting attorney defaults, the Attorney General is authorized to act

pursuant to RCW § 43.10.090:

“Upon the written request of the governor, the attorney general shall investigateviolations of the criminal laws within this state.

If, after such investigation, the attorney general believes that the criminal laws areimproperly enforced in any county, and that the prosecuting attorney of thecounty has failed or neglected to institute and prosecute violations of suchcriminal laws, either generally or with regard to a specific offense or class ofoffenses, the attorney general shall direct the prosecuting attorney to take suchaction in connection with any prosecution as the attorney general determines to benecessary and proper.

If any prosecuting attorney, after the receipt of such instructions from the attorneygeneral, fails or neglects to comply therewith within a reasonable time, theattorney general may initiate and prosecute such criminal actions as he or sheshall determine. In connection therewith, the attorney general shall have the same powers as would otherwise be vested in the prosecuting attorney.


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From the time the attorney general has initiated or taken over a criminal prosecution, the prosecuting attorney shall not have power or authority to take anylegal steps relating to such prosecution, except as authorized or directed by theattorney general.”

35. Prosecuting attorneys are subject to Chapter 36.27 RCW. Prosecuting attorneys areattorneys authorized by law to appear for and represent the state and the counties thereof in

actions and proceedings before the courts and judicial officers. RCW § 36.27.005.

36. The prosecuting attorney, among other things, shall, pursuant to RCW § 36.27.020:

Duties.

“(2) Be legal adviser to all county and precinct officers and school directors in allmatters relating to their official business, and when required draw up allinstruments of an official nature for the use of said officers;***

(4) Prosecute all criminal and civil actions in which the state or the county may bea party, defend all suits brought against the state or the county, and prosecuteactions upon forfeited recognizances and bonds and actions for the recovery ofdebts, fines, penalties, and forfeitures accruing to the state or the county;****(11) Seek to reform and improve the administration of criminal justice andstimulate efforts to remedy inadequacies or injustice in substantive or procedurallaw.

37. County Sheriffs are subject to Chapter 36.28 RCW. The sheriff is the chief executive

officer and conservator of the peace of the county. RCW § 36.28.010 provides that the County

Sheriff, in the execution of his or her office, he or she and his or her deputies, among other

things:

(1) Shall arrest and commit to prison all persons who break the peace, or attemptto break it, and all persons guilty of public offenses;

(2) Shall defend the county against those who, by riot or otherwise, endanger the public peace or safety;

(3) Shall execute the process and orders of the courts of justice or judicial

officers, when delivered for that purpose, according to law;

38. RCW § 36.28.011 imposes upon County Sheriffs a mandatory duty to make complaint:

“In addition to the duties contained in RCW 36.28.010, it shall be the duty of allsheriffs to make complaint of all violations of the criminal law, which shall cometo their knowledge, within their respective jurisdictions.”


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39. Under RCW § 36.28.010, Sheriff Atkins must only execute the process and orders of the

courts of justice or judicial officers “according to law.” See, State v. Twitchell, 61 Wn.2d 403,

378 P.2d 444 (1963) (Officers are elected not for their benefit but for the benefit of the

community.); State v. Liewer, 65 Wn. App. 641; 829 P.2d 236 (Div. One, 1992) (RCW

42.20.100 is directed to the misconduct of a public officer.); State v. Torgeson, 19 Wn. App. 17;

573 P.2d 817 (Div. One, 1978) (The duty to investigate and prosecute crime is enjoined by law

upon the county sheriff.)

40. Both the Writ of Restitution, which is issued in the name of the State of Washington and

the Declaration of Margie Johnson, attached hereto at Exhibit C, implicates Sheriff Atkins in the

knowing and intentional violation of his mandatory duties and services enjoined under RCW §§

36.28.010 and .011 and RCW § 59.12.100, in direct violation of Wash. Rev. Code §§ 9A.80.010;

40.16.010; 40.16.020; 40.16.030; 42.20.080 and 42.20.100.

41. At the end of all mandatory duties and services imposed by law, it is the Washington

Governor who is vested with the Supreme Power of the State to intercept the MERS, Inc.

Conspiracy Enterprise and prevent any and all harms to all homeowners.

42. Contained under the State and Federal social schemes for housing and the general welfare

are numerous alternatives to wrongful nonjudicial foreclosures and evictions involving

Washington Governor Jay Inslee; Attorney General Bob Ferguson; Clark County Prosecuting

Attorney Tony Golik and Clark County Sheriff Chuck E. Atkins, e.g.:

(1) homeowners who lost their jobs could be moved to the front of the line forunemployment benefits, food stamps, retraining and home refinancing; (2)Federal and State liens could be placed on the home to recover State expenses forhealth care and job assistance; and (3) reports could be required of all lendershaving loans that are in default and or facing foreclosure to ensure the properlenders are involved with the default and foreclosure.

43. The dichotomy of blame and responsibility created by the constitution and laws became

manifest when former Attorney General McKenna, through a Hilton Vancouver Washington,

informed the hotel employees that he could not investigate death threats because the Governor

refused to allow the investigation. See Exhibits W through Z attached hereto.

44. The City of Vancouver Washington, which owns the Hilton Vancouver Washington, was

informed that the hotel’s union had allegedly falsified its pension plans for $341,012.00 in Tax

Year 2010:


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45. The City was further informed through the U.S. Department of Justice (Criminal

Division) that the whistleblowing was associated with “an organized crime ring,” Exhibit W at 1,

which had previously been found to be under the influence and control of the heirs of Al

Capone’ Chicago Outfit, Exhibit W at 2-6.

46. Eric Walter, the City’s Hotel Manager, informed the City that its hotel was not

contributing twice the rate the organized crime ring claimed it was contributing on the union’s

tax returns. Exhibit X at 8-10.

47. The City’s hotel union informed the Federal Court in New Jersey that Petitioner lacked

standing to file any claims and causes of action because Petitioner was never a member of the

hotel’ union:

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***

***

See Exhibit Y, 1-27 attached hereto.

48. The union’s admissions in federal court that Petitioner was not a member of the hotel’s

union established the crime of identity theft proscribed in Chapter 9.35 RCW, and necessitating

the requirement that Petitioner file a police report. See Exhibit Z at 1.


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49. In an apparent effort to distance itself from “an organized crime ring,” the U.S. DOJ’s

Criminal Division notified Petitioner to cease and desist from providing any further

whistleblowing materials to its office. See Exhibit Z at 2.

50. As of the date of the filing of this Petition for Recall, no person from the State or Federal

Governments has investigated the death threats; pension fraud or identity theft.

II. HISTORY OF THE NATIONAL MORTGAGE MARKET (NMM).

A. Promotion of a National Mortgage Market.

51. The federal government’s role in the market for buying and selling residential mortgages

in the United States was established in response to the Great Depression when incomes and

housing prices fell sharply and foreclosure rates skyrocketed.

52. As part of President Franklin Roosevelt’s New Deal, Congress enacted the National

Housing Act (NHA) of 1934, a taxpayer-financed system, to provide relief, recovery, and reform

after great depression; make housing and home mortgages more affordable and to protect lenders

from the risk of default.

53. A simplified description of this new national market is shown in the following graphic:

53. The NHA created the Federal Housing Administration (FHA) to: provide assistance in

the construction, acquisition, and or rehabilitation of residential properties; regulate rate of


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interest and terms of mortgages; insure mortgages; increase the number of people who can afford

down payment and monthly mortgage payments; and increase the size of the market for single

family homes.

55. In 1938, Congress created the Federal National Mortgage Association (Fannie Mae) as a

government agency with a mission to: establish a secondary mortgage market; purchase FHA-

insured loans from private lenders; make lenders more inclined to extend mortgage credit; and

equalize supply and demand of funds in capital rich and capital poor areas.

56. In 1954, Congress began the process of shifting Fannie Mae to private ownership. Each

lender selling mortgages to the agency was required to make a capital contribution to purchase

nonvoting common stock in Fannie Mae, which would gradually help retire the preferred stock

held by the Treasury. Under the Charter Act of 1968, Fannie Mae became a private government

sponsored enterprise (GSE)/public-private partnership.

57. In 1970, Congress enacted the Emergency Home Finance Act which provided for the

creation of the Federal Home Loan Mortgage Corporation or “Freddie Mac,” a second private

GSE. Congress’ goal was to expand the secondary mortgage market and eliminate the perceived

monopoly of Fannie Mae.

58. In 1972, Fannie Mae (OTCBB: FNMA) and Freddie Mac (OTCBB: FMCC), began

purchasing “conventional” mortgages, which are mortgages not guaranteed by the FHA or the

Veterans Administration. Structural features of the mortgage market at this time made it highly

susceptible to disruptions in the flow of funding.

59. In the late 1970s and early 1980s, Fannie Mae suffered a series of deeply unprofitable

years that put its viability in doubt. Much like the savings and loan industry, it had financed its

mortgage investments by issuing shorter-term debt, seeking to take advantage of lower short-

term interest rates. That strategy exposed Fannie Mae to interest rate risk — when interest rates

rose, its borrowing costs increased commensurately, while its income from existing mortgages

remained fixed.

60. As interest rates declined after 1984 and Fannie Mae did a better job matching the

duration of its assets and liabilities, it returned to profitability. After this period, the business

strategies of Fannie Mae and Freddie Mac began to converge.

61. In 1989, Congress enacted the Financial Institutions Reform, Recovery, and Enforcement

Act (FIRREA), which authorized thrifts to sell their shares in Freddie Mac to the public as a way


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of injecting more capital into the thrift industry during the savings and loan crisis. Shares in

Fannie Mae and Freddie Mac became more attractive for investors, which prompted the need for

the electronification of the mortgage process and the creation of the Mortgage Electronic

Registration System (MERS) and the Mortgage Electronic Registration System, Inc. (MERS,

Inc.) in 1995.

62. By 2001, the operations of Fannie Mae and Freddie Mac looked virtually the same, as

depicted in the following chart:

63. In 2001, Fannie Mae and Freddie Mac issued standardized contractual language for the

role of MERS, Inc. and the Deed of Trust created in each State to appear on Fannie Mae/Freddie

Mac UNIFORM INSTRUMENT (MERS) Form 3048, as shown here for the State ofWashington:

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64. On September 6, 2008 the Federal Housing Finance Agency (FHFA) placed Fannie Mae

and Freddie Mac into conservatorship in accordance with the Federal Housing Finance Regulatory

Reform Act of 2008 (Public Law 110-289) and the Federal Housing Enterprises Financial Safety and

Soundness Act of 1992.

65. At that time and pursuant to the statutes, the FHFA set forth the purpose and goals of

conservatorship as follows:

“The purpose of appointing the Conservator is to preserve and conserve theCompany’s assets and property and to put the Company in a sound and solventcondition. The goals of the conservatorship are to help restore confidence in the


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Company, enhance its capacity to fulfill its mission, and mitigate the systemic riskthat has contributed directly to the instability in the current market.”

66. Critical to the establishment of the conservatorships were the actions taken at the same

time by the U.S. Treasury Department, consistent with its authority granted in the Housing and

Economic Recovery Act of 2008 (HERA), to establish three funding facilities. Two of these —

the liquidity facility and the mortgage-backed securities purchase facility — expired as scheduled

at the end of 2009.

67. The third facility — the Senior Preferred Stock Purchase Agreements (PSPAs) — was

structured to provide ongoing financial support to the Enterprises to ensure they remain active

participants in the marketplace. The PSPAs work by ensuring that the Enterprises maintain a

positive net worth. The U.S. Treasury’s initial financial commitment was up to $100 billion per

company. As explained at the time of the conservatorships by Treasury Secretary Paulson:

“These agreements support market stability by providing additional security andclarity to GSE debt holders - senior and subordinated - and support mortgageavailability by providing additional confidence to investors in GSE mortgage backed securities. This commitment will eliminate any mandatory triggering ofreceivership and will ensure that the conserved entities have the ability to fulfilltheir financial obligations. It is more efficient than a one-time equity injection, because it will be used only as needed and on terms that Treasury has set.”

68. As nearly all other non-governmental participants in housing finance abandoned the

market, the conservatorship of Freddie Mac and Fannie Mae, operating with the benefit of the

PSPAs, ensured that credit continued to flow to housing. As evidence of this, the share of

Freddie Mac and Fannie Mae in financing or guaranteeing new single-family mortgage

production rose from 54 percent in 2006 to 73 percent in 2008 and 78 percent in 2009 through

September.

69. Freddie Mac and Fannie Mae, while under conservatorship, have played a significant role

in multifamily housing finance with their market share growing from 33 percent in 2006 to 79

percent in 2008 and 64 percent in 2009 through September.

70. On March 31, 2011, Senator McCain, for himself and Senator Hatch, introduced

Senate Bill S.693, “A Bill To establish a term certain for the conservatorships of Fannie Mae and

Freddie Mac, to provide conditions for continued operation of such enterprises, and to provide

for the wind down of such operations and dissolution of such enterprises,” “GSE Bailout

Elimination and Taxpayer Protection Act.”


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71. During a Senate banking hearing on November 18, 2014, South Dakota Senator Tim

Johnson (D) called on Federal Housing Finance Agency Director Melvin Watt to engage with the

Treasury Department in talks to end the conservatorship of Fannie Mae and Freddie Mac.

Johnson commented that the “conservatorship cannot continue forever …. However, if Congress

cannot agree on a smooth, more certain path forward, I urge you, Director Watt, to engage the

Treasury Department in talks to end the conservatorship.” Source: “The Federal Housing

Finance Agency: Balancing Stability, Growth, and Affordability in the Mortgage Market,”

http://www.banking.senate.gov/public/index.cfm/2014/11/johnson-holds-fhfa-oversight-hearing

[Last visited: May 22, 2016)

72. On February 14, 2012, Attorney General Robert M. McKenna submitted his “Brief of

Amicus Curiae Attorney General of State of Washington In Support of Petitioner ” in Bain v.

Metro. Mortg. Grp., Inc., 175 Wn.2d 83 (2012), which was decided on August 16, 2012.

73. Attorney General McKenna informed the Supreme Court that:

“The State files this Amicus Petition to provide the Court with both statutory and public policy reasons why the MERS system conceals the true owner of the promissory note and why this is damaging to a free, fair and transparent mortgagemarketplace…. MERS argues that...it only holds legal title to members’mortgages in a nominee capacity and is contractually prohibited from exercisingany rights with respect to the mortgages (i.e., foreclosure) without theauthorization of the members. Further, MERS argues that it does not own the promissory notes secured by the mortgages and has no right to payments made on

the notes. MERS explains that it merely “immobilizes the mortgage lien whiletransfers of the promissory notes and servicing rights continue to occur….Therefore, the very purpose of MERS is to hold onto the security interest whileownership of the loan passes from party to party. This role is contrary toWashington’s fundamental principle of real property finance law that ‘the note isconsidered the obligation, and the mortgage but an incident of the note which passes with it.’ It is not just decades of case law that rely on the note and thesecurity instrument transferring together. The Deed of Trust Act (DTA) assumesit throughout its provisions.” (Footnote and citations omitted.) AG Br. at 3-4.

74. The Supreme Court’s relevant holdings in Bain v. Metro. Mortg. Grp., Inc., 175 Wn.2d

83 are as follows:

“Simply put, if MERS does not hold the note, it is not a lawful beneficiary….Since 1998, the deed of trust act has defined a “beneficiary” as “the holder of theinstrument or document evidencing the obligations secured by the deed of trust,excluding persons holding the same as secur ity for a different obligation.’ Thus,in the terms of the certified question, if MERS never ‘held the promissory note,’ then it is not a “lawful 'beneficiary….’

http://www.banking.senate.gov/public/index.cfm/2014/11/johnson-holds-fhfa-oversight-hearinghttp://www.banking.senate.gov/public/index.cfm/2014/11/johnson-holds-fhfa-oversight-hearing


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MERS also argues that it meets the statutory definition itself…. In these particularcases, MERS contends that it is a proper beneficiary because, in its view, it is‘indisputably the ‘holder’ of the Deed of Trust. It provides no authority for itscharacterization of itself as “indisputably the ‘holder’ of the deeds of trust…. We

agree that an interpretation of “beneficiary” that has the deed of trust securingitself is untenable....

There is no evidence in the record or argument that suggests MERS has the power“to reach a resolution and avoid foreclosure on behalf of the noteholder, and thereis considerable reason to believe it does not…. The legislature was attempting tocreate a framework where the stakeholders could negotiate a deal in the face ofchanging conditions….

The plaintiffs argue that our interpretation of the deed of trust act should beguided by these UCC definitions, and thus a beneficiary must either actually

possess the promissory note or be the payee…. We agree. This accords with theway the term ‘holder’ is used across the deed of trust act and the WashingtonUCC. By contrast, MERS’s approach would require us to give “holder” adifferent meaning in different related statutes and construe the deed of trust act tomean that a deed of trust may secure itself or that the note follows the securityinstrument. Washington’s deed of trust act contemplates that the securityinstrument will follow the note, not the other way around. MERS is not a “holder” under the plain language of the statute….

In the alternative, MERS argues that the borrowers should be held to theircontracts, and since they agreed in the deeds of trust that MERS would be the beneficiary, it should be deemed to be the beneficiary…. The legislature has setforth in great detail how nonjudicial foreclosures may proceed. We find noindication the legislature intended to allow the parties to vary these procedures bycontract. We will not allow waiver of statutory protections lightly. MERS did not become a beneficiary by contract or under agency principles.”

75. MERSCORP Holdings, Inc., the parent company of Mortgage Electronic Registration

Systems, Inc. (MERS, Inc.), further admits on its website that MERS, Inc. and the MERS, Inc.

electronic recording “System,” never owns or holds the mortgage note, to wit:

///

///

///

///

///

///


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Source: https://www.mersinc.org/join-mers-docman/1037-mers-system-marketing-brochure[Last visited: May 22, 2016.]

III. CONSPIRACY TO USE MERS, INC. TO GAME THE NMM, DEFRAUD THE

UNITED STATES AND THE SEVERAL STATES AND EXTORT HOMEOWNERS.

A. INTRODUCTION TO CONSPIRACY LAW.

76. Title 18 U.S.C. 371 makes it a separate Federal crime or offense for anyone to conspireor agree with someone else to do something which, if actually carried out, would amount to

another Federal crime or offense. Under this law, a ‘conspiracy’ is an agreement or a kind of

‘partnership’ in criminal purposes in which each member becomes the agent or partner of every

other member.

https://www.mersinc.org/join-mers-docman/1037-mers-system-marketing-brochurehttps://www.mersinc.org/join-mers-docman/1037-mers-system-marketing-brochure


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77. In order to establish a conspiracy offense it is not necessary for the Government to prove

that all of the people named in the indictment were members of the scheme; or that those who

were members had entered into any formal type of agreement; or that the members had planned

together all of the details of the scheme or the ‘overt acts’ that the indictment charges would be

carried out in an effort to commit the intended crime.

78. Because the essence of a conspiracy offense is the making of the agreement itself ,

followed by the commission of any overt act, it is not necessary for the Government to prove that

the conspirators actually succeeded in accomplishing their unlawful plan.

79. A person may become a member of a conspiracy without knowing all of the details of the

unlawful scheme, and without knowing who all of the other members are. So, if a person has an

understanding of the unlawful nature of a plan and knowingly and willfully joins in that plan on

one occasion, that is sufficient to convict him for conspiracy even though he did not participate

before, and even though he played only a minor part. United States v. Socony-Vacuum Oil Co.,

310 U.S. 150, 253 (1940); United States v. Rabinowich, 238 U.S. 78, 88 (1915); Pinkerton v.

United States, 328 U.S. 640 (1946).

80. On May 2, 2016, the United States Supreme Court decided Ocasio v. United States, 578

U.S. ___ (2016), 2016 U.S. LEXIS 2932. Therein, the Court held that a defendant may be

convicted of conspiring to violate the Hobbs Act, 18 U.S.C. § 1951, based on proof that he

reached an agreement with the owner of the property in question to obtain that property under

color of official right.

B. THE MERS, INC. CONSPIRACY.

THE CONSPIRACY

81. From in or about January 2001, and continuing through the present, in the State of

Washington and elsewhere, Melvin L. Watt, Director of Federal Housing Finance Agency

(FHFA); Kurt Pfotenhauer, Chairman of the Board of Directors, MERSCORP Holdings, Inc. and

MERS, Inc.; Bill Beckmann; Timothy J. Mayopoulos, President and Chief Executive Officer,

Fannie Mae; Egbert L. J. Perry, Non-Executive Chairman of the Board, Fannie Mae; Donald H.

Layton, Chief Executive Officer, of Freddie Mac and over 5,000 other individuals affiliated with

members of MERS, Inc., did knowingly and unlawfully combine, conspire, confederate, and

agree together, with state law enforcement officers and homeowners across the United States to


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obstruct, delay, and affect commerce and the movement of any article and commodity in

commerce by extortion, that is, to unlawfully obtain property from homeowners, with their

consent, induced by wrongful use of actual or threatened force, violence, or fear, or under color

of official right, not due to any of them or their official positions, in violation of 18 U.S. Code,

Section 1951(a).

PURPOSE OF THE CONSPIRACY

82. It was a purpose of the conspiracy for state and county law enforcement officers to enrich

Melvin L. Watt; Kurt Pfotenhauer; Bill Beckmann; Timothy J. Mayopoulos, Egbert L. J. Perry,

Donald H. Layton and over 5,000 other individuals by exercising their official positions and

influence to cause homeowners to relinquish possession of their home for delivery of possession

to a third party such as Fannie Mae or Freddie Mac.

MANNER AND MEANS

83. It was part of the conspiracy that MERS, Inc. would use its unlawful authority as

“beneficiary” named on the Deed of Trust to assign the Note and Deed of Trust to a member of

MERS, Inc. when in fact MERS, Inc. never held or owned the Note and the assignee was aware

MERS, Inc. did not possess such authority at the time the assignment was made.

84. Recorded document searches of the records of the Clark County Washington Auditor’s

Office revealed the conspiracy involving MERS, Inc.’s unlawful assignments of the note and

deed of trust began operating in Clark County Washington in 2002:

1. Recorded Documents Search Results

Search Criteria:

Grantor mortgage electronic registration system

Title ADT

Start Date 01/01/2001

End Date 12/31/2001

No matching records found.


Search Criteria:


Title ADT


End Date 12/31/2000



Search Criteria:


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Title ADT


End Date 12/31/1999


85. It was further part of the conspiracy that Melvin L. Watt; Kurt Pfotenhauer; Bill

Beckmann; Timothy J. Mayopoulos; Egbert L. J. Perry, Donald H. Layton and over 5,000 other

individuals associated with members of MERS, Inc. agreed to use the power of the State to cause

homeowners to be wrongfully dispossessed of their homes pursuant to the following general

pattern:

(a) MERS, Inc. would use its unlawful authority as “beneficiary” to cause an

“Assignment of Deed of Trust” to be recorded in the Clark County Auditor Office in violation of

RCW § 40.16.030.

(b) After receiving the assignment from MERS, Inc., the assignee purports to exercise

rights as the owner/holder of the promissory note, such as appointing a successor trustee or

directing the commencement of nonjudicial foreclosure procedures.

(c) In some instances, after receiving the unlawful assignment, the assignee will

appear in Federal Bankruptcy Court and untruthfully represent itself to the Court as the

owner/holder of the promissory note which is provided by MERS, Inc. for the sole purpose of

thwarting the homeowner’s claim.

(d) After becoming aware of the assignment from MERS, Inc., the Trustee would fail

to postpone the nonjudicial foreclosure sale after being further aware of the homeowner’s lawsuit

and the recordation of a lis pendens on the homeowner’s property.

(e) After receiving the assignment from MERS, Inc., members of the conspiracy

would offer or pretend to offer loan modifications for which no authority existed.

(f) After receiving the assignment from MERS, Inc., members of the conspiracy

would engage in practices designed to conceal the true owner/holder of the promissory note.(g) After receiving the assignment from MERS, Inc., members of the conspiracy

would invoke state action by unlawfully commencing a state court action for unlawful detainer

with a demand that the homeowner be taken out of possession using the power of the County

Sheriff or other law enforcement personnel.


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(h) After receiving the assignment from MERS, Inc., members of the conspiracy

would fail to voluntarily dismiss the action for unlawful detainer when presented with a copy of

IRS Form 1099-A which tended to demonstrate the assignment was unlawful and the notices of

default and foreclosure were null and void.

OVERT ACTS

86. In furtherance of the conspiracy and to effect the purpose of the conspiracy, at least one

of the conspirators performed and or caused to be performed, at least one of the following overt

acts on or about the dates set forth below, in Clark County Washington, which consists of at least

171 recorded overt acts in 2015 and 11 recorded overt acts from January 1, 2016 to May 20,

2016:


Search Criteria:


Title ADT


End Date 01/10/2015

Document Title (type) Parcel(s) Excise Date Recorded Grantor(s) Grantee(s)

5136148 ADT Jan 09, 2015 MORTGAGE

ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,

5136083 ADT Jan 09, 2015 MORTGAGEELECTRONIC

REGISTRATION

SYSTEMS,

BANK OFAMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,

5136203 ADT Jan 09, 2015 MORTGAGEELECTRONIC

REGISTRATION

SYSTEMS,

BANK OFAMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,

5135778 ADT Jan 08, 2015 MORTGAGE BANK OF

http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136148http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136083http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136170http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136201http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136203http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135742http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135778http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135778http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135742http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136203http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136201http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136170http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136083http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136148


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ELECTRONIC

REGISTRATION

SYSTEMS,

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,

5135143 ADT 186340005 Jan 07, 2015 MORTGAGE

ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,

5135130 ADT 105832798 Jan 07, 2015 MORTGAGE

ELECTRONIC

REGISTRATION

BANK OF

AMERICA NA,

http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135780http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135595http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135676http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135526http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135587http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135589http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135813http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135816http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135679http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135845http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135143http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135130http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135130http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135143http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135845http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135679http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135816http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135813http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135589http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135587http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135526http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135676http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135595http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135780


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SYSTEMS,

5135318 ADT 178186004 Jan 07, 2015 MORTGAGE

ELECTRONIC

REGISTRATION

SYSTEMS,

FIRST MORTGAGE

CORPORATION,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135318http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135362http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134633http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134635http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134637http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134639http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134651http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134140http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134142http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134144http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134146http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134148http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134062http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134062http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134148http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134146http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134144http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134142http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134140http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134651http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134639http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134637http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134635http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5134633http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135362http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5135318


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ELECTRONIC

REGISTRATION

SYSTEMS,

AMERICA NA,


Search Criteria:


Title ADT


End Date 01/20/2015


5138813 ADT Jan 21, 2015 MORTGAGE ELECTRONIC

REGISTRATION SYSTEMS,

BANK OF

AMERICA NA,



BANK OF

AMERICA NA,

5138817 ADT Jan 21, 2015 MORTGAGE ELECTRONICREGISTRATION SYSTEMS, BANK OFAMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,

5138470 ADT 256766000 Jan 20, 2015 MORTGAGE ELECTRONIC


WELLS FARGO

BANK NA,

5138458 ADT 92011516 Jan 20, 2015 MORTGAGE ELECTRONIC


BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,5138127 ADT Jan 16, 2015 MORTGAGE ELECTRONIC


BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,

5137328 ADT Jan 15, 2015 MORTGAGE ELECTRONIC BANK OF

http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138813http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138815http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138817http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138830http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138834http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138832http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138837http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138470http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138458http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137867http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137852http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137854http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137857http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138125http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138127http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138129http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137739http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137328http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137328http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137739http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138129http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138127http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138125http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137857http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137854http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137852http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137867http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138458http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138470http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138837http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138832http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138834http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138830http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138817http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138815http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138813


28/70

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REGISTRATION SYSTEMS, AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,

5136992 ADT Jan 13, 2015 MORTGAGE ELECTRONICREGISTRATION SYSTEMS, BANK OFAMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,



BANK OF

AMERICA NA,5136598 ADT Jan 12, 2015 MORTGAGE ELECTRONIC


BANK OF

AMERICA NA,


Search Criteria:


Title ADT


End Date 01/31/2015


5141872 ADT 108858316 Jan 30, 2015 MORTGAGE

ELECTRONIC

REGISTRATION

SYSTEMS,

FIDELITY

NATIONAL TITLE,

5141867 ADT 111033018 Jan 30, 2015 MORTGAGE

ELECTRONIC

REGISTRATION

FIDELITY BANK,

http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137330http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137014http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136992http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136994http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136996http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136920http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136998http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136933http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136935http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136938http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136922http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136926http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136931http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136594http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136598http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5141872http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5141867http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5141867http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5141872http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136598http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136594http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136931http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136926http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136922http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136938http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136935http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136933http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136998http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136920http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136996http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136994http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5136992http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137014http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5137330


29/70

29 |

SYSTEMS,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,

5140786 ADT 29276090 Jan 27, 2015 MORTGAGE

ELECTRONIC

REGISTRATION

SYSTEMS,

CITIMORTGAGE

INC,


ELECTRONIC

REGISTRATION

SYSTEMS,

CAROLINA

PREMIER BANK,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,




30/70

30 |

ELECTRONIC

REGISTRATION

SYSTEMS,

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

BANK OF

AMERICA NA,

http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5140428http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5140049http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5140051http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5140055http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5139435http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5139437http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5139439http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5139474http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5139428http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5139431http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138813http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138815http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138815http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138813http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5139431http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5139428http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5139474http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5139439http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5139437http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5139435http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5140055http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5140051http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5140049http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5140428


31/70

31 |

SYSTEMS,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


Search Criteria:


Title ADT


End Date 02/28/2015


5149710 ADT 150048050 Feb 26, 2015 MORTGAGE

ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,

5148878 ADT 21310000 Feb 24, 2015 MORTGAGE

ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,

5147202 ADT 153965000 Feb 20, 2015 MORTGAGE

ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,

5146764 ADT Feb 19, 2015 MORTGAGE

ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,

http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138817http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138830http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138834http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138832http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138837http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5149710http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5148878http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5147202http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5146764http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5146835http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5146835http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5146764http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5147202http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5148878http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5149710http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138837http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138832http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138834http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138830http://gis.clark.wa.gov/applications/gishome/auditor/index.cfm?pid=detail&DocNum=5138817


32/70

32 |


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATIONSYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,

5146139 ADT 118136586 Feb 17, 2015 MORTGAGE

ELECTRONIC


WELLS FARGO

BANK NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,

5145444 ADT 37913324 Feb 13, 2015 MORTGAGE

ELECTRONIC


FIRST

MORTGAGE

CORPORATION,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC


BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,

5144951 ADT 114783570 Feb 11, 2015 MORTGAGE

ELECTRONIC

PROVIDENT

FUNDING ASSOC,



33/70

33 |

REGISTRATION

SYSTEMS,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BANK OF

AMERICA NA,


ELECTRONIC

REGISTRATION

SYSTEMS,

BA