Full Deposition of Angela Edwards “Robo-Verifier” as Servicer for the Plaintiff for Verification of Foreclosure Complaint

4closureFraud's picture


Full Deposition of Angela Edwards "Robo-Verifier" as Servicer for the Plaintiff for Verification of Foreclosure Complaint

Great depo of a "Robo-Verifier" who knows nothing in a foreclosure case...

First, although the Ms. EDWARDS listed her position as "Vice President" in the verification of the Complaint, Ms. EDWARDS admitted that she was “not the vice president” of the company. Then, Ms. EDWARDS admitted that the alleged Power of Attorney which allegedly gave the servicer, her employer, the right to act on behalf of the Plaintiff, was not made by the Plaintiff and did not even mention the Plaintiff's name. Further, the Corporate Resolution from the Plaintiff’s employer contained conflicting directives as to whether or not Ms. EDWARDS was actually even authorized to sign for the company for which she worked, HOMEWARD RESIDENTIAL, which is not even a party to this action.

Even if she was authorized to sign on behalf of the Plaintiff, Ms. EDWARDS admitted that she did not and could not verify all of the factual allegations in the Complaint. Although Ms. EDWARDS signed the verification on the Complaint under penalty of perjury and swore that all of the facts alleged in the complaint were true and correct to the best of her knowledge and belief, she admitted in her deposition that her knowledge regarding most of the information was gained solely from the information found in the Complaint. The very document Ms. EDWARDS was charged with verifying.

Some excerpts from the depo...

Paragraph 5 of Complaint: "Plaintiff is entitled to enforce the terms of the note and mortgage pursuant to Florida Statute 673.3011."

At the deposition, Ms. EDWARDS admitted she was not familiar with Florida Statute 673.3011.

Q: How do you know that the plaintiff is entitled to enforce the terms of a note and mortgage pursuant to that statute?

A: Because the mortgagors have signed off on those documents stating.

Q: Do you know what that statute says?

A: No, I do not, not at this time.

Q: Have you ever known what that statute says?

A: It was a part of our training, I'm sure that -- but I just can't remember off the top of my head right now.


Paragraph 7 of Complaint: "Plaintiff declares the full amount payable under the note and mortgage to be due."

Q: How do you know that the plaintiff declares the full amount payable under the note and mortgage to be due?

A: Because of their signature. They've signed off stating they would pay that amount and they became delinquent.

Q: But how do you know the plaintiff is declaring that amount payable?

A: Oh, I'm sorry. Because of the complaint that's been filed. I apologize. Okay. It's because they placed a judgment against the borrowers.

Q: The plaintiff placed a judgment against the borrowers?

A: Meaning us - well, the attorneys have filed a complaint stating that they have been delinquent with their payments, so, therefore, they have -- they're no -- they're not keeping up with what they have stated that they would pay, their payments monthly, if that makes -- I'm trying to make sense of it.

Q: What in the documents that you've reviewed for this case tells you that the plaintiff declares the full amount payable under the note and mortgage to be due?

A: The demand letters that were served to the borrowers.

Q: Let's take a look at that. Can you show me in either D-2 or D-3 where the plaintiff declares the full amount due?

A: Not -- okay. I see what you're saying, the full amount due. It shows the delinquent payments, of course. But the actual note has the full amount that the borrower signed off on that shows the amount that they were to pay. And, of course, I have my fact verification sheet, which is D-4, that shows the original amount of the mortgage, which was 5,020, and the amount of each payment that should have been paid and when the last payment was received.

Q: And I appreciate what you're saying, but none of that's answering the question. I just want to know what shows you that the plaintiff has made this declaration.

A: Okay. When you say -- meaning the complaint itself -- I'm not sure. Really, I'm not sure what you're -- other than -- I'm just going to be quiet on that one. I'm not sure.


Paragraph 9 of Complaint: "In order to protect its security, the Plaintiff may have advanced and paid Ad Valorem Taxes, premiums on insurance required by the mortgage and other necessary costs, or may be required to make such advances during the pendency of this action. Any such sum so paid will be due and owing Plaintiff."

Q: Okay. How do you know that in order to protect its security the plaintiff may have advanced or paid taxes -- excuse me, ad valorem taxes, premiums on insurance required by the mortgage and other necessary costs or may be required to make such advances during the pendency of this action?

A: The actual payments are on the -- are on this payment history that you've been given. And then, of course, we have the note and mortgage. It shows the --

Q: So has the plaintiff advanced any taxes or premiums on insurance or other costs?

A: Yes. I mean, according to what I have here on the pay history.

Q: Can you show me on the pay history where the plaintiff --

A: When you say the plaintiff, I hope I'm understanding that correctly. We're talking about the borrower or the actual ...

Q: Sure. The plaintiff in this case is, technically, Master Adjustable Rate Mortgages Trust 2007-1, Mortgage Pass-through Certificates Series 2007-1.

A: Oh, where they've actually paid anything? No. I don't see that for them. I'm talking about the actual mortgagor . So I'm sorry. I misunderstood that question.


Paragraph 10 of Complaint: "On or about February 28, 2008, TERRY CARTER died."

Q: Your knowledge that she is dead is because -- on that date is because it's stated on the complaint; isn't that what you just said to me?

A: Yes, that is correct, because it's stated on the complaint.


Paragraph 11 of Complaint: "The record legal title to said mortgaged property is vested in Defendant(s), JOHN CARDER, living and if dead, the unknown spouses,heirs, and beneficiaries who hold or holds possession."

Q: How do you know that the record legal title to the mortgage property is vested in John CARTER?

A: Because of the documents he signed, the note and mortgage.

Q: The note and mortgage tells you that he owns the property?

A: Yes.

Q: And that legal title is vested to him?

A: Once he pays it off completely, then yes.

Q: What was that? I'm sorry?

A: Once it's paid in its entirety.

Q: I couldn't hear you. If he's paid in its entirety?

A: I said once he's paid this debt off in its entirety, then he would own this title -- own it. But, yes, he's in pursuit of paying for the title.


Paragraph 12 of Complaint: "All conditions precedent to the acceleration of this mortgage note and to foreclosure of the mortgage have been fulfilled and have occurred."

Q : Can you tell me what a condition precedent is?

A : I cannot.

Q: Tell me how you know that all conditions precedent to the acceleration of the mortgage note and to foreclosure of the mortgage have been fulfilled and have occurred.

A:By reading the complaint, the information that's here.


Paragraph 13 of Complaint: "For purposes of collection and foreclosure, the Plaintiff has retained the undersigned attorney and is obligated to pay said attorney a reasonable fee for his services."

Q : How do you know that for purposes of collection and foreclosure the plaintiff has retained the undersigned attorney and is obligated to pay said attorney a reasonable fee for services?

A : That, again, dates back to the demand letter that was issued, the delinquent payments. And how he was obtained or who obtained and what date, I'm not sure.

Q: So how do you know that ROBERTSON, ANSCHUTZ & SCHNEID the attorney -- the undersigned attorney that's been retained by the plaintiff?

A: I'm not sure.


Paragraph 14 of Complaint: "Plaintiff alleges that the claims of the remaining Defendants are secondary, junior, inferior and subject to the prior claim of Plaintiff, and more particularly the remaining Defendants claim some right, title and interest in and to the mortgaged premises . . ."

Q: How do you know that the remaining defendants claim some right, title and interest in the mortgage premises?

A: Again, all of this just goes back to the information that's in this packet and what they were -- so I don't have any -- other than what I see before me and what I would have viewed at that time.

Q: Besides what's stated here in the complaint, in Paragraph 14 that I just read to you --

A: Yes.

Q: -- is there any other document that you reviewed that states the defendants -- other defendants have some right, title and interest to the mortgage premises?

A: No. I cannot think of it right off. I cannot recall.


It is plainly obvious that Ms. EDWARDS has very little knowledge of even the basics of her employer's business. Although she claims she received training to verify complaints, she cannot explain basic facts that are alleged in the Complaint and does not even know what to look for in order to verify those facts. Most poignantly, she admittedly did not verify certain key aspects of the Complaint but instead relied on the Complaint itself as her proof that the allegations stated therein are true and correct. If this were a philosophy paper, a somewhat circular statement such as “I think therefore I am” is perfectly acceptable. However, in a court of law, when a document requires that it be verified as true and correct, under penalty of perjury, one cannot sign off that what is stated in the Complaint is true because it is stated in the Complaint. This is preposterous.The entire reasoning behind the Florida Supreme court taking unprecedented, historic action to amend rule 1.100(b) was because of the financial industry’s well documented illegal behavior. It was primarily in response to the “robo signing” scandal, which ultimately led to settlements with 49 states, OCC consent orders, and numerous class action and shareholder lawsuits. We now know that “robo-signing” is used to describe the rampant process of having a person sign a document without authority to do so and/or knowledge as to that which they are signing, despite swearing otherwise. Yet, no matter the amount and severity of lawsuits, settlements, and bad publicity, it appears, at least in this case, that the act of signing without proper authority or knowledge as to that which one is signing, continues.

Full deposition below... 




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ebworthen's picture

"I'm not sure" appears sufficient to steal someone's property.

I'm not sure which is more like a cockroach; lawyers or politicians - though most politicians are lawyers so...

kayaky's picture

Forget about mortgages: this whole idea that "just because a complaint is made doesn't mean it is true" is the real concern behind changes to the NDAA that allow arrest/execution of US citizens.


one cannot sign off that what is stated in the Complaint is true because it is stated in the Complaint.


But this is exactly what is going on.


God bless America.

Al Trueman's picture

I'm still waiting for a record setting Class Action suit by the 3,143 County Recorders Offices in the United States to recover the fees and tax revenues they lost ( and continue to lose ) when mortgage ownership is transferred by other ( illegal ) means such as MERS and such.

What happened was a multi-billion dollar ( perhaps a trillion ) coups by an organized/centralized agressor , against a totally disorganized and utterly de-centralized population of tiny counties throughout the states.

Now THAT was a cute trick.

Joebloinvestor's picture

Housing market is making a recovery (so they say).


Won't be one until they prosecute for all the shit that came before.

Colonel Klink's picture

Please wake me when the rule of law is reinstated and applies to everyone equally again.

janchup's picture

You will probably die in your sleep.

Toolshed's picture

You will be making Rip Van Winkle look light a light sleeper I guess.

Bearwagon's picture

Prepare for long hibernation, lasting many years!

Colonel Klink's picture

Ain't dat da troof my little blue friend.  Earliest I expect to be wakened is January 2016.  Hopefully it's not to Hellary or Jeb.

NotApplicable's picture

Maybe by 3016. 2016? Well, that's just being delusional, as voting is the problem.

monoloco's picture

Maybe Linda Green can clear this up.

chunga's picture

We are livng in a fucked up world.

If you're looking for justice the last place you will find it is in a "court".

If you're sick the last place you want to be is in a hospital.

If you've got any money the last place you want to put it is in a bank.

Northeaster's picture

Minor victory in MA today regarding Harmon Law (hang those fuckers too):



No. 12-P-407.

Suffolk. October 11, 2012. - June 28, 2013.

swmnguy's picture

Well, obviously, mortgage servicers don't care enough about the process to hire competent, qualified people, or to train the people they do hire.  And in the vast majority of cases, it doesn't matter whether any of these cases is handled properly or not.  There's no accountability, because the bankers have bought the enforcement process.  For a ridiculously cheap amount of money, compared to the money to be made by intentional bungling.

So there are literally millions of homes out there with completely screwed up titles and documentation history, and nobody cares.  It really all boils down to whether or not one has the wherewithal to hire a decent attorney.  If you do, you will be able to prove that your loan was mishandled.  That doesn't mean you'll win anything, or that anyone will be held accountable for fraud, forgery, or incompetence.  And that doesn't matter either.  All the loans have been resold a number of times, and eventually all the counterparties are reimbursed by the Federal Reserve and the Treasury one way or another.  It's a complete cycle of fraud.

If you make all your payments and never have any problems and nobody comes after you on the basis of falsified documents, and you are able to sell your home free and clear, you'll probably never care either.

On the other hand, I have a friend who had a Wells Fargo mortgage.  He and his wife were consultants, and did a few months worth of work for Wells Fargo.  In early 2009, WF just cancelled the project they were working on, and didn't pay them nearly $20,000.  So, they were completely strapped for cash, and asked for some consideration on their mortgage.  Wells then sold their mortgage to Fannie Mae, but kept servicing it.  Wells told them to apply for a relief program (probably HAMP).  Wells told them to not pay for one month, to become eligible, but to pay every month afterward; at a reduced rate which would eventually be retroactively approved.  Every month or so, Wells told them to re-submit documents; claiming they'd been lost or improperly filled-out, or something. 

Finally, over a year later (mid-2010), my friend was driving when his cell phone rang, and he answered.  A guy said, "Hi, you don't know me.  I'm so-and-so with Fannie Mae.  How come you haven't made a payment on your mortgage in 13 months?"  My friend flipped out.  He said, "I've made every single payment on time for the amount Wells told me to.  The one payment I didn't make they told me not to make.  I've got all the cancelled checks.  They're the ones dragging their feet and losing documentation and stalling."  The guy said, "That's not what they're telling me.  They're telling me you haven't made a payment in 13 months.  I'll call them."  A week later, my friend got a letter from Wells telling him he was ineligible for the mortgage modification, and he owed them the difference between his old payment and the reduced payment they'd had him pay for the past 13 months, and if they didn't have it in 7 days, they'd throw him out of his house.  He tried to call them but they hung up on them as soon as they figured out who he was.  Fortunately, he had just done a large project for another client, so he had the money and paid them. 

Last week he sold that house, and used the money to pay off all his other debts, buy another (much smaller) house, and close every single account he had with Wells Fargo.  No doubt he was dealing with dumb bunnies like this Angela Edwards the whole time at Wells  Nobody would accept ignorance or stupidity from you or me as an excuse for incompetence and fraud, but if you work in the Finance industry, it's just fine (until your boss needs a scapegoat and they throw you to the wolves).

ebworthen's picture

"Well, obviously, mortgage servicers don't care enough about the process to hire competent, qualified people, or to train the people they do hire."

This is true of 99.9% of Corporations and Businesses in America.

How else do you rip people off coming and going - without having incompetent untrained employees that you pay dirt?

Northeaster's picture

It worked out for your friend, but for millions of others, not so much.

No indictments, no arrests, and no jail.

You're right, no one cares, as long as it's not them. When it is them, it's too late.

How Wells, Citi, and B of A executives and CONgress Members are not already hanging from lampposts already due the HARM they have already done eludes me.

slightlyskeptical's picture

The friend paid everything he owed. I doubt he ever got his $20k in wages either. I doubt WF cares about his banking as they already got a good piece of what he has.

What was the moral of the story again?

RaceToTheBottom's picture

It would be interesting to know the effect that had on his credit rating.

I hope he sent a letter to the CEO when canceling everything.  I do that; I know it has no effect; that they get a laugh; but it makes me feel better as I funnel all my work through CUs.

chumbawamba's picture

LOL, right.  Like the bank cares.  They'll just send a memo to Ben to "PRINT MOWAR!"  They are laughing that this guy actually paid off all his loans rather than defaulting and playing the "evict me if you can" game with them for another year.

And I like how every attorney always recommends that you "hire a competent attorney".  Well, first of all, that's basically impossible, because most attorneys aren't competent, and those that are already work for the banks.  Second, attorneys swore an oath to The Crown.  Their first duty is to the court, then to the public, and then not necessarily to the client.

"His first duty is to the courts and the public, not to the client, and whenever the duties to his client conflict with those he owes as an officer of the court in the administration of justice, the former must yield to the latter." - Corpus Juris Secundum Vol. 7 Sec. 4

If you want to lose (even if you "win"), by all means, hire an attorney.

I am Chumbawamba.

pods's picture

They should have asked her if she had ever used steroids or used the N word.

Seems that is much more important in today's world.

Crooks, all of them. There to shear and eventually butcher anyone that they set their eyes upon.

How the hell can this actually be going on in an actual court?

Because we have become the banana republic.

It is right because I said it is right!


RichardP's picture

What person who is current on their mortgage payment has ever been caught up in this violation of the law?

Out of the total population of mortgage payers, the number caught up in the snafu you describe is only a small percentage (those who aren't current on their mortgage payment).  Since their misbehavior affects only a small percentage of the population, the legal types will claim that their misbehavior has no serious consequences and so should be allowed to continue.  All involved in the legal chain will concur.

Cloud9.5's picture

The people are not stupid.  They know.  Florida courts have been bought and paid for by the banks and the insurance industry.  Every judicial appointment committee is filled with officers from these two industries.   These committees appoint judges to the appellate courts that will uphold their interests.  Every circuit judge knows this.  No sitting judge likes to have his ruling overturned.   And it is well understood that any sitting judge eyeing an appointment to an appellate court must remain a friend to the insurance and banking industries.


Two equals going to trial in a Florida court will more than likely receive a fair trial.  Two insurance companies suing each other will receive a fair trial.   Two banks should they sue each other, will receive a fair trial.   On the other hand, a lone individual going up against either of these institutions will more than likely have his cause of action dismissed with prejudice.  His issues will never be heard in open court and the facts will never be reviewed by a jury.


The embracement of an open and known fraud by the courts to enable banks to pursue their foreclosures is proof positive of the collapse of the rule of law in Florida courts. Now it is perfectly acceptable to base a cause of action in a Florida court on an open well understood lie.   There is no justice.  There is just us.

chumbawamba's picture

California courts are a bigger joke thank Florida's, if you can believe that.  It might be helpful if people understood that the courts are the largest bank on the planet.  Replace "case" with "account" and that should clue you in.

But the fact is, we can learn how to properly fight back.  Study the Constitution, your state one and the federal one.  Memorize them.  Then start memorizing the rules of court and code of civil procedure, the evidence code, and the 33 objections of American Jurisprudence.  That's all you need.  Fuck the statutes regarding foreclosure, they aren't followed anyway.  Just get them on the innumerable violations and technicalities they hand you at every step of the way.  Object, object, object!  Also, familiarize yourself with your state's code for dismissing magistrates for bias, conflict of interest, etc., and use them.

When you come into the court educated and remember who you are then these people become more afraid of you than you are of them.  If you know how to dismiss a magistrate (they are not judges, they are magistrates) and shut down the bank's attorney by objecting to anything s/he says on the record as hearsay (a good case to review on this is Trinsey v. Pagliaro, http://freedom-school.com/law/with-regards-to-trinsey-v-pagliaro.html) then you will win.  They have no facts, period.  All they can offer is hearsay, lies, and forged documents.  Hold them to it!  Subpoena everyone whose name appears in the record as a fact witness and depose them.  Those that do show up will embarrass (and perhaps even perjure) themselves.

We are winning.  And you can win, too.  But you have to be willing to fight for it.

I am Chumbawamba.

NotApplicable's picture

Well said.

If you ain't in the club, you're gonna get clubbed.

RaceToTheBottom's picture

She is just a cog in the machine

Seasmoke's picture

Hang Pam Bondi.

csmith's picture

Automation...ain't it great!

illyia's picture

Painfully irrelevant. It is amazing how far we have fallen...

Eventually all this will become part of the Big Ball of Corruption Goo to be written about at length in history books. I hope there is no book titled "The Decline and Fall of the United States" - hopeum...

Milestones's picture

Oswald Spengler wrote "The Decline of the West" some 100 years ago.           Milestones

Colonel Klink's picture

What difference does it make!


Seasmoke's picture

You are painfully wrong.

NotApplicable's picture

Are you trying to claim there's more than mere fiction to the "Rule of Law?"

Nearly every one of fifty state AGs (or is that AsG?) are sitting on what amounts to massive fraud while waiting for their cut of the settlement loot in order that they fill a billion dollars of their budget holes.

MERS has destroyed chain of title on every mortgage it touched, yet what is being let into the courts are the cases of fraud where entities have been caught either recreating the chain, or ignoring the deficiencies altogether.

If I believed in the sanctity of the court system, I would force my own servicer to prove they actually transfer my payment to the rightful owners of the note. Thing is, thanks to MERS there are NO RIGHTFUL OWNERS. All there is fraud, on top of fraud, on top of fraud...

It's merely another instance of Too Big To Jail.

chumbawamba's picture

LOL, they made it easy for me.  In my case, the UD attorney hired by the bank to finish their evil deed verified the complaint himself.  Yes, my house was taken by a bank that never even appeared on the record.

But here's the funny part: my lawsuit (proceeding under the common law in a court of record) now involves as defendants the bank, their three attorneys, two magistrates, and the court itself.  You wanna know how corrupt these niggers are?  They referred my case to the California Supreme Court rather than prove jurisdiction on the record, as I had demanded.

Now, they're all gonna get it.  Each of these persons, in their individual capacity, defrauded me.  If they're lucky I won't then go after their houses once I've got mine back.

Send that along to the proper parties, NSA.

I am Chumbawamba.