motion to dismiss by steven stoll based on lender negligence

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case No. 10-60194-CR-COHN/SELTZER

UNITED STATES OF AMERICA, Plaintiff, v. STEVEN STOLL, et al. Defendants. ____________________________________/

DEFENDANT STOLL’S MOTION FOR MISTRIAL OR IN THE ALTERNATIVE FOR REMEDIAL SANCTIONS FOR BRADY VIOLATIONS REGARDING LENDER

MISCONDUCT AND INCORPORATED MEMORANDUM OF LAW

Defendant Steven Stoll, by and through the undersigned counsel, requests this Court

Order a mistrial in this case, or in the alternative impose remedial sanctions against the

Government for Brady violations regarding lender misconduct and complicity based upon newly

discovered evidence of undisclosed Government investigations and law suits against lenders, and

in support thereof states as follows:

I. Introduction and Summary of the Argument

On September 2, 2011, the United States of America, through the Federal Housing

Finance Authority, announced that it had filed seventeen (17) separate law suits against

numerous lenders and other financial institutions in an effort to recover hundreds of millions of

dollars in losses suffered by Fannie Mae and Freddie Mac as a result of their purchase of

mortgage backed securities that contained residential home loans that had not been underwritten

to lender guidelines as represented by the lenders and underwriters in related securities offerings.

Case 0:10-cr-60194-JIC Document 1453 Entered on FLSD Docket 09/05/2011 of 17

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Among the revelations contained in the Complaints filed in the suits was the disclosure

that the Department of Justice is actively investigating allegations of lender misconduct relating

to the widespread and willful failure of lenders to follow loan underwriting guidelines. This

revelation is most pertinent to this case because the prosecution, in response to specific Brady

demands, has mostly denied the existence of information in the Government’s possession

regarding lender misconduct in loan origination, and has failed to provide any information

regarding the current Department of Justice investigation and the sweeping allegations contained

in the Complaints filed on September 2, 2011.

Moreover, the prosecution has repeatedly sought in this trial to exclude evidence of

lenders’ failure to follow underwriting guidelines, and has sought through its experts to establish

that lenders did follow the underwriting guidelines, and that the adherence to these guidelines by

the lenders made the alleged false statements and omissions in this case factually material to the

lenders.

As the allegations in the recently filed Government law suits describe in great detail,

nothing could be further from the truth. The inconsistent position taken by the Government in

the case against Mr. Stoll regarding lender adherence to underwriting standards, and the resulting

misleading testimony sponsored by the Government through its lender and mortgage industry

experts, cannot be allowed to stand.

The prejudice resulting from the Brady violation in this case is exponentially

compounded by the fact that the Government failed to call a single lender representative witness

that was actually involved in the underwriting and approval of any of the loans in this case.

None of the three lender representatives the Government called as witnesses had any personal

knowledge of the underwriting of any of the loans, and the failure of the Government to disclose


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the information in its possession regarding an active Department of Justice investigation(s) of

lender underwriting practices deprived Mr. Stoll of the ability to impeach these witnesses

testimony, as well as the hearsay evidence of the lender’s files, with the fact that lender’s were

under government investigation for failing to follow and making false statements regarding their

adherence to the very same underwriting guidelines these witnesses were called as witnesses to

explain.

As a consequence of these significant Brady violations, Mr. Stoll has been deprived of a

fair trial, thereby necessitating a mistrial. Alternatively, in order to remedy the Government’s

Brady violations, to correct the false and misleading position taken by the Government in this

case regarding lender misconduct and complicity in loan underwriting, and to ensure that Mr.

Stoll receives a fair trial in this case, Mr. Stoll requests the Court impose remedial sanctions

against the Government as set forth below.

II. Factual Background

A. The Government Law Suits Against the Lenders

The seventeen (17) separate law suits filed this past Friday on behalf of the Federal

Housing Finance Agency contain numerous and detailed allegations of a complete abandonment

of normal and expected lender underwriting practices during the last decade. The failure of

lenders to follow their stated underwriting guidelines and criteria resulted in countless loans

being packaged into mortgage backed securities that were not as creditworthy as represented in

the securities’ offering materials.

As a consequence of the lenders’ purposeful failure to underwrite loans in accordance

with the underwriting guidelines, the default rate of the loans contained in mortgage backed


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securities purchased by Fannie Mae and Freddie Mac was far higher than expected, costing these

government agencies (and taxpayers) hundreds of millions of dollars in losses.

The allegations of lender and underwriter misconduct are chronicled in the more than one

thousand pages of civil Complaints filed by the Federal Housing Finance Agency on September

2, 2011. The allegations and supporting documents are so numerous that it is impractical to

attach them to this Motion. However, copies of the Complaints can be found at

http://www.fhfa.gov/Default.aspx?Page=110.

For illustration purposes, the Complaints filed against GMAC, and its subsidiary

Residential Funding Company, LLC, (the parent company of Homecomings Financials Network,

LLC – a lender in this case), and Countrywide are attached hereto as Exhibits 1 and 2,

respectively.

By way of brief excerpt and summary, the allegations of lender misconduct regarding

underwriting include the following:

1. GMAC Complaint

-Among other things, the Registration Statements presented the loan origination

guidelines of the mortgage loan originators who originated the loans that underlay the

Certificates. The Registration Statements falsely represented that those guidelines were adhered

to except in specified circumstances, when in fact the guidelines systematically were disregarded

in that the loans were not originated in accordance therewith. (GMAC Complaint, Exhibit 1,

Page 2 at ¶5).

-The Prospectus Supplements for each of the Securitizations made similar representations

with respect to the underwriting guidelines employed by each of the originators in the

Securitizations, which included: Aegis Mortgage Corporation, Decision One Mortgage

Company, LLC, EFC Holdings Corporation and its subsidiary EquiFirst Corporation, Finance


http://www.fhfa.gov/Default.aspx?Page=110

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America, LLC, First National Bank of Nevada, Home123 Corporation, Homefield Financial Inc.,

Mortgage Lenders Network USA, Inc., New Century Mortgage Corporation, Ownit Mortgage

Solutions Inc., People’s Choice Home Loan, Inc., Pinnacle Financial Corporation and SCME

Mortgage Bankers, Inc. (GMAC Complaint, Exhibit 1, Page 28 at ¶75).

-Contrary to those representations, however, these originators routinely and egregiously

departed from, or abandoned completely, their stated underwriting guidelines . . . As a result, the

representations concerning compliance with underwriting guidelines and the inclusion and

descriptions of those guidelines in the Prospectus Supplements were false and misleading, and

the actual mortgages underlying each Securitization exposed the purchasers, including Freddie

Mac, to a materially greater risk to investors than that represented in the Prospectus

Supplements. (GMAC Complaint, Exhibit 1, Page 28 at ¶76).

-The Non-Party Originators -- companies such as New Century, Decision One, and others

-- systematically disregarded their respective underwriting guidelines, as confirmed not only by

the pervasively false owner-occupancy and LTV figures . . , but also by: (1) government

investigations and private actions relating to their underwriting practices, which have revealed

widespread abandonment of their reported underwriting guidelines during the period of the

Securitizations; . . . (GMAC Complaint, Exhibit 1, Page 42 at ¶106).

-Further, on June 29, 2011, the SEC and the DOJ launched investigations of, among

other things, “potential fraud related to the origination and/or underwriting of mortgage

loans” by GMAC. As an originator of residential mortgage loans for the GMAC entities, the

scope of the SEC and the DOJ’s investigation will likely include a review of HFN’s compliance

with its own loan origination underwriting guidelines. (GMAC Complaint, Exhibit 1, Page 48 at

¶120)(Emphasis added).


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-In the case of GMAC, the GMAC entities were so closely integrated and the abusive

lending practices so rampant from the top down that the depositors (RALI, RAMP and RASC),

the sponsor (RFC) and the underwriter (RFS), knew -- or were reckless in not knowing -- that

HFN -- a subsidiary of the sponsor -- systematically was disregarding prudent underwriting

standards and that its loans lacked the characteristics represented in the Offering Materials. As

detailed above, a sampling of GMACM loans conducted by MBIA has revealed a

noncompliance rate of at least 89 percent. (GMAC Complaint, Exhibit 1, 3 at

¶161)(Emphasis added).

2. Countrywide Complaint

-The SEC and the U.S. Department of Justice investigated potential securities law

violations by Countrywide and its personnel in the securitizations of mortgage loans and

offerings of mortgage-backed securities in the secondary market, including allegations that

Countrywide made false and misleading disclosures to influence the stock trading price, and

allegations of insider trading by the three most senior executives of Countrywide Financial:

Angelo Mozilo (Countrywide’s CEO), David Sambol (Countrywide’s President and COO), and

Individual Defendant Eric Sieracki (Countrywide’s CFO). (Countrywide Complaint, Exhibit 2,

Page 71 at ¶145)(Emphasis added).

-To apply its “matching strategy” effectively, Countrywide expanded the number of

employees who were authorized to grant [loan underwriting] exceptions. A wide range of

employees were given authority to grant exceptions and to change the terms of a loan, including

underwriters, their superiors, branch managers, and regional vice presidents. If Countrywide’s

automated system recommended denying a loan, for example, an underwriter could override that

Case 0:10-cr-60194-JIC Document 1453 Entered on FLSD Docket 09/05/2011 Page 6 of 17

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denial by obtaining permission from his or her supervisor. SEC Complaint at 11-12.

(Countrywide Complaint, Exhibit 2, 4 at ¶149).

-The SEC action established that it was openly known at Countrywide that loans were

being approved for securitization based solely on Countrywide’s ability to sell the loan in the

market, rather than on compliance with underwriting criteria. Countrywide’s high-volume

computer system, called the “Exception Processing System,” was known to approve virtually

every borrower and loan profile, albeit with a pricing add-on by which Countrywide charged the

borrowers extra points and fees. The Exception Processing System was known within

Countrywide as the “Price Any Loan” system. Through the Exception Processing System,

Countrywide was able not only to generate enormous profits from these higher fees, but also

routinely approve loans that did not satisfy even its weakened theoretical underwriting criteria.

(Countrywide Complaint, Exhibit 2, Page 74 at ¶150)(emphasis added).

All totaled, the Complaints filed by the Federal Housing Finance Agency implicate at

least 69 different lenders and underwriters in the securitization of mortgage loans originated

without regard for underwriting practices and guidelines, including: 1) Homecomings; 2)

Countrywide; 3) Fremont Investment & Loan; 4) Option One Mortgage Corporation; 5)

Wachovia (AMNET); 6) National City; and 7) Accredited.

III. Brady and Other Discovery Violations by the Government

A. The Demands

Despite the receipt of multiple specific Brady demands and Motions seeking the

disclosure of information regarding civil or criminal investigations of lenders, the Government

failed to disclose the existence of the Department of Justice investigations revealed in the

attached Complaints, and/or the substance thereof.

Case 0:10-cr-60194-JIC Document 1453 Entered on FLSD Docket 09/05/2011 Page 7 of 17

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More specifically, by way of letter on August 20, 2010 (a copy of which is attached as

Exhibit 3), Mr. Stoll’s counsel specifically demanded disclosure of “[a]ny criminal complaint

and/or investigation to any state or federal investigative agency or any civil complaint or

administrative action, relating to any lender involved in or associated with any defendant and/or

the 68 loan transactions, as well as any civil litigation relating to these lenders.” When no

substantive response was received from the Government in response to the demand, Mr. Stoll

repeated the specific Brady demand in a Motion to Compel the Government to produce Brady

material regarding Government witnesses [D.E. 399] filed on October 8, 2010.

The Government responded to this motion on November 5, 2010 (D.E. 516), and asserted

that “[t]he government has no information or documents that are responsive to Defendant’s

request #8 concerning criminal and civil complaints and investigations against lenders involved

with the 68 fraudulently acquired properties, or associated with any defendant.” Although the

Government has acknowledged the continuing nature of its Brady obligations to Mr. Stoll, no

disclosure of the Department of Justice investigations or the damning allegations against the

lenders regarding their failure to follow underwriting practices was provided to the defense by

the prosecution in this case.

Under Brady v. Maryland, 373 U.S. 83, 88 (1963), the Government was under an

affirmative obligation to inquire and obtain the favorable information possessed within its own

department, as well as the other agencies that comprised the prosecution team. Kyles v. Whitley,

514 U.S. 419, 437 (1995); United States v. Safavian, 233 F.R.D. 12, 17-18 (D.C.C.

2006)(prosecutor obligated to cause files to be searched that are not only maintained by the

prosecutor's or investigative agency's office, but also by other branches of government "closely

aligned with the prosecution."); United States v. Jennings, 960 F.2d 1488, 1490 (9th Cir.


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1992)(the prosecutors "personal responsibility cannot be evaded by claiming lack of control over

the files . . . of other executive branch agencies").

It is axiomatic that the Office of the United States Attorney is a part of the Department of

Justice, and the prosecutors in this case therefore are charged with knowledge of the Department

of Justice investigations of the lenders, were also charged with the obligation to inquire as to the

existence of the investigations upon receipt of a specific Brady demand for the information, and

were obligated to disclose the existence of the investigations to Mr. Stoll and his counsel.

B. Prejudice Resulting From the Brady Violations

The Government’s failure to disclose the information in its possession regarding active

investigations of the lenders in this case, as well as the substantive information regarding the

wholesale failure of lenders to adhere to their purported loan underwriting standards has resulted

in overwhelming and irremediable prejudice to Mr. Stoll in this case.

First, the purported importance and adherence to underwriting guidelines by the lenders

is an essential underlying premise of the Government’s theory of prosecution in this case. The

fact that there exists significant evidence that the lenders regularly and willfully failed to follow

these guidelines casts more than substantial doubt on the sustainability of the Government’s

prosecution theory. This is particularly true in light of the failure of the Government to call a

single lender witness that was involved in the underwriting or approval of the loans in this case

to testify that the underwriting guidelines were followed or that the alleged false statements and

omissions had any potential impact (materiality) on the approval of the loans in this case.

Said differently, the previously undisclosed evidence that an agency of the Government

has determined, and that the Department of Justice was investigating allegations, that lenders

approved loans without any regard for whether the loans met the guidelines, and that lenders


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routinely waived or made exceptions to compliance with the guidelines and criteria, that the

lenders did so for their own financial gain, and that the lenders thereafter misrepresented their

compliance with the underwriting guidelines to the purchasers of the loans, casts insurmountable

doubt upon whether the Government could ever sustain its burden of proof without calling a

lender witness that was actually involved in the underwriting or approval of any of these loans.

At a minimum, the Government was required to disclose this information to the defense so that it

could have been presented to the jury for its consideration in deciding this case.

To add insult to injury, the Government has actively resisted, and for all intents and

purposes, has succeeded in thwarting the defendants’ attempts to introduce evidence of lenders’

willful failure to follow the underwriting guidelines, their financial incentive for doing so, and

the resulting impact upon the reliability of the “lender files” in evidence. The Government did

so under the guise that there was no evidence that these lenders were engaged in these practices.

However, as demonstrated in the 17 complaints recently filed by the Government, as well as

existence of one or more Department of Justice investigations into the underwriting practices of

these lenders, the Government has taken a diametrically opposed position regarding these lenders

elsewhere.

As the record stands, the jury in this case has been deprived of substantial favorable

evidence to the defense regarding the lenders’ actions, intent, motive, and the lack of materiality

of the statements and alleged omissions in dispute in this case.

Moreover, the Government, in a disingenuous substitute for testimony from lender

representatives with actual knowledge of the underwriting and approval of the loans in this case,

has presented testimony from former lender employees and purported expert witnesses with no

personal knowledge about these loans to testify that the lenders did actually follow underwriting


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guidelines, and to testify that the statements and alleged omissions in dispute in this case were

material to the lenders’ decisions to approve these loans.

In addition to being deprived of the favorable evidence regarding the failure of lenders to

follow underwriting guidelines, the Government’s failure to disclose the existence of the

investigation(s) of the lenders by the Department of Justice also deprived the defense of the

ability to impeach the credibility of the “lender files” being relied upon by the Government, as

well as the potential motive and bias of the lender representatives called by the Government as

witnesses in this case.

Each of the lender witnesses, having been employed by lenders during a time period

when according to the recently filed Complaints they were engaged in massive frauds on

government agencies and others purchasing mortgage backed securities, had an undisclosed and

unexplored motive to color their testimony so as to minimize their own potential culpability and

involvement in the fraud. These witnesses had a similar motive to minimize the culpability of

their former lender employers.

Further, if the Government had informed the defendants of the investigation of the

lenders, and the fact that the lenders had a financial motive to conceal their failure to follow

underwriting guidelines within their own files, the defense would have had the ability to impeach

the credibility of the lender files produced in this case, and would have been able to present a

compelling explanation for the absence of certain documents (such as conversation logs, escrow

agreements, emails, etc.) from the lender files.

The Government, on the other hand, in taking full and unfair advantage of the lenders’

purging of files, has been pointing to the lack of such documents in the files as evidence that the

lenders were never aware of the escrow withholds and sourcing of deposits from the third parties.


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Accordingly, the Government’s Brady violation has impacted this case in multiple, varied

and profound ways to the detriment of Mr. Stoll.

IV. Requested Relief

A. Mistrial The profound and cumulative effect of the Government’s Brady violation, coupled with

the exclusion of evidence of lender misconduct regarding the failure to follow underwriting

guidelines, the deprivation of the ability to introduce evidence that the lenders are under

Department of Justice investigation, and the loss of the resulting impact that evidence would

have had on the jury’s evaluation of the lender files and the lender witnesses, along with the

Government’s exploitation of the withholding of this information and evidence favorable to the

defense, necessitates a mistrial in this case.

Granting or denying a motion for a mistrial is a matter committed to the trial court’s

discretion. See United States v. Perez, 30 F.3d 1407, 1410 (11th Cir. 1994). The court should

grant a mistrial if the taint is ineradicable. See United States v. Sepulveda, 15 F.3d 1161, 1184

(1st Cir. 1993). Although alternative remedies are proffered below, it is difficult to conceive

how, at this stage of the trial, the substantial prejudice to Mr. Stoll that has resulted from the

Government’s misconduct described above could be adequately addressed short of a mistrial.

Accordingly, Mr. Stoll respectfully moves for a mistrial with prejudice in this case.

B. Alternative Remedies

While not retreating in any way from his request for a mistrial, but recognizing that a

mistrial will generally be granted only as a last resort by the court, Mr. Stoll submits that the

following remedies should be imposed should the court not declare a mistrial in this case.


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1) Ordering the immediate disclosure by the Government of all pertinent information

regarding the current Department of Justice investigation of lender misconduct and complicity in

loan underwriting, and any related information regarding same or similar allegations;

2) Taking Judicial Notice of the law suits filed by the Federal Housing Finance Agency,

and grant Mr. Stoll surrebuttal to allow the introduction into evidence of the existence of the

Department of Justice investigation of lenders and the allegations contained in the Complaints

concerning lenders’ wholesale failure to follow loan underwriting guidelines, and the false

statements made by the lenders to Fannie Mae, Freddie Mac regarding whether they followed

loan underwriting guidelines;

3) Striking the testimony of Marta McCall, Michael Adams, Curt Lane, Douglas Pollock,

and Rebecca Walzak with respect to the issue of whether lenders follow loan underwriting

guidelines and any testimony as to the application of loan underwriting guidelines to the loans in

this case;

4) Prohibiting the Government from arguing in closing argument that the lenders

followed loan underwriting guidelines and that no exceptions were made to loan underwriting

guidelines, criteria or procedures in this case; and

5) Prohibiting the Government from arguing in closing argument that the absence of

documents in the lender files, such as conversation logs, escrow agreements and emails, is

evidence that the lenders did not previously have these documents and the information relating

thereto.

V. Conclusion For the reasons set forth above, and consistent with the mandates of the Due Process

Clause of the Constitution, Steven Stoll requests the Court enter an order declaring a mistrial in


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this case, and any other relief the Court deems just and proper.

Respectfully submitted,

s/ Robert N. Nicholson Florida Bar No. 933996 [email protected] Nicholson Law Group, P.A. 200 South Andrews Avenue, Suite 100 Fort Lauderdale, Florida 33301 Telephone: (954) 351-7474 Facsimile: (954) 351-7475

Michael S. Pasano Florida Bar No. 0475947 CARLTON FIELDS 100 S.E. 2nd Street 4200 Miami Tower Miami, Florida 33131-2114 Telephone: (305) 530-0050 Facsimile: (305) 530-0055 E-mail: [email protected]

Bruce Zimet, Esq. 1 Financial Plaza Suite 2612 Ft. Lauderdale, Florida 33394 Telephone: (954) 764-7081 Facsimile: (854) 760-4421 E-mail: [email protected]

Attorneys for Defendant Steven Stoll


mailto:[email protected]

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CERTIFICATE OF SERVICE

I hereby certify that on September 5, 2011, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified below in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. s/ Robert N. Nicholson

SERVICE LIST United States v. Guaracino, et al.

Case No. 10-60194-CR-COHN/SELTZER United States District Court Southern District of Florida

Jared Strauss, Esq. Laurie E. Rucoba, Esq. [email protected] [email protected] United States Attorney’s Office United States Attorney’s Office 500 East Broward Boulevard, 7th Floor 500 East Broward Boulevard, 7th Floor Fort Lauderdale, Florida 33301-3002 Fort Lauderdale, Florida 33301-3002 (954) 356-7255 x3593 (954) 356-7255 x3613 (954) 356-7336 (fax) (954) 356-7336 (fax) Attorney for Plaintiff Attorney for Plaintiff United States of America United States of America Via Electronic Court Filing Via Electronic Court Filing Michael Patrick Sullivan, Esq. Michael Dennis Walsh, Esq. [email protected] [email protected] 99 Northeast 4th Street 46 Northeast 6th Street Miami, Florida 33132 Miami, Florida 33132 (305) 961-9274 (305) 444-7700 (305) 536-4675 (fax) (305) 441-1423 (fax) Attorney for Plaintiff Attorney for Defendant United States of America Joseph Guaracino Via Electronic Court Filing Via Electronic Court Filing Jordan M. Lewin, Esq. Howard Leslie Greitzer, Esq. [email protected] [email protected] Downtown Legal Center Lyons & Sanders 46 Northeast 6th Street, Suite 104 1301 East Broward Blvd, Suite 220 Miami, Florida 33132 Fort Lauderdale, Florida 33301 (305) 577-8525 (954) 467-8700 (305) 441-1423 (fax) (954) 763-4856 (fax) Attorney for Defendant Attorney for Defendant Dennis Guaracino, Jr. Matthew Gulla Via Electronic Court Filing Via Electronic Court Filing








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Anthony M. Livoti, Esq. Deric Zacca, Esq. [email protected] [email protected] 721 Northeast 3rd Avenue Cabrera & Zacca, LLP Fort Lauderdale, Florida 33304 Monarch Professional Centre (954) 463-3777 12781 Miramar Pkwy, Suite 303 (954) 463-3792 (fax) Miramar, Florida 33027-2908 Attorney for Defendant (954) 450-4848 Joseph Lagrasta (954) 450-4204 (fax) Via Electronic Court Filing Attorney for Defendant Casey Mittauer Via Electronic Court Filing Michael E. Dutko, Esq. Fred Haddad, Esq. [email protected] [email protected] Bogenschutz, Dutko & Kroll, PA 1 Financial Plaza 600 South Andrews Avenue Suite 2612 Suite 500 Fort Lauderdale, Florida 33394 Fort Lauderdale, Florida 33301 (954) 467-6767 (954) 764-2500 (954) 467-3599 (fax) (954) 764-5040 (fax) Attorney for Defendant Attorney for Defendant Rene Rodriguez, Jr. Daryl Radziwon Via Electronic Court Filing Via Electronic Court Filing Alan Randall Haas, Esq. Jayne Claire Weintraub, Esq. [email protected] [email protected] 600 South Andrews Avenue Wachovia Financial Center Fort Lauderdale, Florida 33301 200 South Biscayne Blvd. (954) 763-9211 Miami, Florida 33131 (954) 467-8806 (fax) (305) 374-1818 Attorney for Defendant (305) 379-0069 (fax) Jacqueline Trumbore Attorney for Defendant Via Electronic Court Filing Robert Depriest Via Electronic Court Filing Steven Hunter Kassner, Esq. David William Macey, Esq. [email protected] [email protected] 4000 Ponce de Leon David W. Macey, P.A. Suite 470 2699 South Bayshore Drive, 7th Floor Coral Gables, Florida 33146 Coconut Grove, Florida 33133 (305) 740-5405 (305) 860-2562 (305) 278-7795 (fax) (305) 675-5841 (fax) Attorney for Defendant Attorney for Defendant Joseph Derosa Joseph Derosa Via Electronic Court Filing Via Electronic Court Filing










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Bradford M. Cohen, Esq. Martin Alan Feigenbaum [email protected] [email protected] Bradford Cohen Law P.O. Box 545960 1132 Southeast 3rd Avenue Surfside, Florida 33154 Fort Lauderdale, Florida 33316 (305) 866-8334 (954) 523-7774 (305) 866-8335 (954) 523-2656 (fax) Attorney for Defendant Attorney for Defendant Steven Orchard John Velez Via Electronic Court Filing Via Electronic Court Filing



motion to dismiss by steven stoll based on lender negligence

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