IN RE SCHUESSLERAs already stated above, in In re Schuessler, Chase filed a motion for relief from the stay that failed to contain relevant information about the debtors failure to make postpetition mortgage payments. In re Schuessler, 386 B.R. at 487. Bankruptcy Judge Cecilia Morris found Chases pleadings to be sanctionable, as [w]hether deliberately or inadvertently, the process utilized by Chase Home Finance in this case stands in the way of important rights afforded to debtors under the Bankruptcy Code, including the right to the protection of the automatic stay pursuant to 11 U.S.C. 362(a), and the essential concept of a fresh start. Id. at 491. Judge Morris denied Chases motion and awarded the debtors their fees and costs in connection with Chases motion. Id. at 493.IN RE PAWSONIn the case of In re Pawson (Case No. 05-18439 (MG)), Bankruptcy Judge Martin Glenn on August 13, 2008 So Ordered a stipulation between Chase and the debtor resolving a motion12by the debtors pursuant to 11 U.S.C. 105 and 28 U.S.C. 1927 alleging improper filings in that case by Chase (Doc. No. 18). As set forth at the August 13, 2008 hearing (Aug 13 Tr.) (transcript is Doc. No. 21), Chase agreed to pay the debtors $50,000. Aug. 13 Tr. at 41: 1-4. See Zipes Decl. Ex. M (relevant portions of the Aug. 13 Tr.).Chase filed a letter (the Chase Letter) dated January 9, 2009 with the Court (Doc. No. 30) after the United States Trustee conducted informal discovery in connection with improper filings by Chase in that case. In the Chase Letter, Chase outlined certain voluntary steps to ensure the accuracy of its pleadings in future bankruptcy cases. These steps include: (i) the retention of a consultant to review motions to vacate the stay before they are filed and (ii) advance notice by letter to debtors warning that Chase intends to file a motion to vacate the stay. At a court hearing on January 22, 2009 (transcript is at Doc. No. 31), Judge Glenn, in directing that the letter be filed, stated that [n]o action the Court is taking today makes [the procedures] mandatory, but the Court will also be mindful if the procedures are changed and any issues arise in the future. Jan. 22 Tr. at 6: 4-6.4IN RE HUMPHREYIn In re Humphrey (Case No. 08-23404 (ASH)), Chase, as successor in interest to Washington Mutual Bank, filed a motion to vacate the stay (the Chase Humphrey Motion) (Doc. No. 9). Bankruptcy Judge Adlai S. Hardin, Jr. imposed sanctions on Chase NA after finding that Chase NA filed false documents in connection with the Chase Humphrey Motion.4In connection with Pawson, Chase has changed its procedures in connection with motions to vacate the stay. Specifically, the firm of Teitelbaum and Baskin, LLP has been retained by Chase to specifically review all pleadings filed by Chase in the Southern District of New York. This Motion For Stay Relief was filed before the new procedures were in place. The United States Trustee reserves her right to seek sanctions against Steven J. Baum, P.C. (the Baum Firm), which filed the Motion For Stay Relief. In this regard, the United States Trustee notes that the Baum Firm represented Chase in the In re Humphrey. Further, the Baum Firm was counsel in cases in which courts have found sanctionable conduct. IndyMac Bank F.S.B. v. Yano-Horoski, 2009 N.Y. Slip Op. 29491, 2009 WL 4544742, (N.Y. Sup. Ct. Nov. 19, 2009) (Ind. No. 2005-17926).13At a hearing on February 24, 2009, Judge Hardin stated that I view this as very serious. Your firm and your client, whether its WAMU or Chase, submitted a false affidavit, a false certification as to non-payment; demonstratively false, and violated the automatic stay. Thats really serious. Feb. 24 Tr. at 7: 21-25. (Doc. No. 24). By order dated March 27, 2009, Judge Hardin denied the Chase Humphrey Motion and imposed a sanction of $15,000, among other penalties, on Chase NA (Doc. No. 29). After the February 24, 2009 hearing, the United States Trustee filed a motion for a Bankruptcy Rule 2004 examination and, with the consent of Chase NA, has taken the examination of Chases vice president in charge of all its national residential mortgages in which the borrowers file for bankruptcy relief.

IN RE NUERIn re Nuer case (Case No. 08-14106 (REG)), Chase as servicer for Deutsch Bank National Trust Company ("Deutsch"), asTrustee for Long Beach Mortgage Trust 2006-2 ("Long Beach Trust") filed a motion for stay relief. Bankruptcy Judge Robert E Gerber, imposed sanctions on Chase NA after it was discovered that Chase NA filed several fraudulent documents with the court in connection with the Stay Relief.Motion. At the Hearing Date: January 7, 2010 Hearing Time: 10:00 a.m., The United States Trustee Diana G. Adams supported the sanction request stating Chase has filed documents that appear to be either false or misleading. Chase took the position that it was acting only as the servicer for the mortgage and at the same time attached post-petition dated documents which supported a different position by assigning the mortgage to Deutsch signed just days before Chase's motion for stay relief. The assignment was also prepared several years after the actual assignment of the mortgage. Given the opportunity to cure the matter Chase through supplemental filings, continued to file false documents with the court without regard for the court or the rules. It was also sited in that case that this was not the first time chase engaged in this type of conduct and in total disregard for the law continues to do so despite sanctions.